Public Legal Documents
1. Privacy Policy
This Privacy Policy explains how the Qarshi Pay App pre-launch project ("Qarshi," "we," "us," or "our") may collect, use, disclose, retain, and protect personal information through its application, website, testing environment, waiting list, or support channels. Before launch, this section must be reconciled with the registered legal entity, actual production data inventory, approved providers, and applicable notices.
Information we may collect
- Identity and eligibility: name, date of birth, address, identification number, government identification, selfie or liveness result, and verification outcome.
- Contact and account: email, mobile number, credentials, authentication events, language, and settings.
- Financial connection and funding: institution name, account type, masked details, tokens, funding status, authorization, returns, and chargebacks.
- Transfer and recipient: sender and recipient details, amount, fees, rate, recipient amount, payout method, status, timestamps, receipt, and reference.
- Compliance and risk: identity, sanctions, fraud, transaction-monitoring, source-of-funds, case, and eligibility records.
- Device, usage, and security: IP address, device/app identifiers, version, logs, diagnostics, approximate IP location, and security events.
- Communications: support messages, complaints, requests, consents, and notices.
How information may be collected and used
Information may be obtained directly from you, automatically from the app or device, from approved banks and service providers, and from lawful fraud-prevention, public, or regulatory sources. It may be used to create and secure accounts; verify identity and eligibility; perform sanctions, AML, and fraud controls; connect funding methods; calculate and process approved transfers; provide receipts and support; resolve errors and complaints; protect rights and security; and meet legal, regulatory, audit, tax, and recordkeeping obligations.
How information may be disclosed
Information may be disclosed as necessary to approved funding institutions, bank-link providers, licensed remittance providers, payout institutions and wallets, identity and screening providers, hosting and support vendors, professional advisers, regulators, law-enforcement or other lawful recipients, and transaction participants subject to appropriate restrictions. Qarshi does not sell personal information for money.
Connected financial accounts
If an approved bank-link service such as Plaid is enabled, it may provide its own consent and privacy notice. Qarshi should receive only the information and permissions required for the enabled service. A connection does not itself authorize a payment or prove that a transfer was submitted or delivered.
Retention, security, and privacy rights
Records are retained according to service, security, dispute, tax, AML, sanctions, regulatory, legal-hold, and provider requirements. Certain identity, transfer, or compliance records may require retention for five years or another applicable period. We use risk-based administrative, technical, and physical safeguards, but no system can guarantee absolute security.
Subject to applicable law and exceptions, you may request access, correction, deletion, portability, withdrawal of consent, marketing opt-out, or an appeal. Identity verification may be required before a request is fulfilled.
Children, international processing, and changes
The service is not intended for children under 13, and money-transfer functionality is intended only for users satisfying the approved age and eligibility rules. Cross-border services may involve processing in the United States and approved destination or service-provider jurisdictions. We may revise this notice when practices, partners, laws, or product features change and will post the revised effective date.
2. Terms of Service
These pre-launch Terms govern access to Qarshi-controlled test, informational, waiting-list, and support services. They do not create a promise that money-transfer services are available. Transaction services, when lawfully launched, will also be governed by the final provider-approved terms and transaction disclosures.
Eligibility and account responsibilities
- You must provide accurate information, meet applicable age and residency rules, use the service only for lawful personal purposes, and complete required identity and risk reviews.
- You are responsible for protecting credentials and promptly reporting suspected unauthorized access.
- You may not impersonate another person, use another person's funding source without authority, structure activity to avoid controls, exploit errors, or use the service for prohibited goods, fraud, sanctions evasion, or unlawful conduct.
Transfers and service availability
- A displayed estimate, provider, wallet, bank, rate, fee, or delivery time is not an offer until confirmed in a valid transaction-specific disclosure.
- A transfer may be delayed, reviewed, declined, cancelled, returned, or restricted as required by law, risk controls, funding status, recipient information, or provider availability.
- Customer rights provided by applicable law or a final receipt are not waived by these Terms.
Intellectual property and service changes
The Qarshi Pay name, logo, application design, software, documentation, and content are owned by their respective rights holders and may not be copied or misused. We may change or discontinue pre-launch features. Final warranty, liability, dispute-resolution, governing-law, and arbitration provisions must be approved by counsel and the licensed provider before launch; this page does not attempt to reduce any non-waivable consumer right.
3. Electronic Communications and E-Sign Consent
If you separately consent, Qarshi and applicable service providers may deliver agreements, disclosures, receipts, notices, statements, privacy communications, and signatures electronically. Consent must be presented separately and may not be preselected.
- You need a supported internet-connected device, a current browser or app, a valid email address or mobile number, and the ability to view, save, or print electronic records.
- You should test that you can open and retain the consent before agreeing.
- You may update contact information and request available paper copies using the contact method below. Any disclosed paper-copy fee must be provided before a charge.
- You may withdraw consent prospectively, but withdrawal may affect access to an electronic-only service and does not invalidate prior electronic records or signatures.
Consent statement: “I confirm that I can access and retain electronic records and consent to receive required communications and use electronic signatures, subject to my right to withdraw as described above.”
4. Remittance Transfer Disclosures and Rights
Before payment: An applicable transaction disclosure should identify the transfer amount, applicable fees and taxes, total amount, exchange rate, and amount expected to be received, using approved labels and estimates where legally permitted.
After payment: A receipt or combined disclosure should include the transaction details, expected availability date, recipient information, provider contact information, and applicable cancellation, error, and complaint rights.
Transaction-specific controls: The values displayed in the app and receipt for an accepted transfer control over examples on this general webpage.
Cancellation and refund
For a covered remittance transfer, you generally have the right to cancel for a full refund within 30 minutes after payment, unless the funds have already been picked up or deposited into the recipient's account. Contact the provider using the channel printed on the final receipt and provide enough information to identify the transfer. Scheduled transfers may be subject to different cancellation timing under applicable law.
Error resolution
For a covered remittance transfer, submit an oral or written error notice no later than 180 days after the availability date disclosed on the receipt. Include your name and contact information, the recipient's information, the transfer amount, and a description of the suspected error. The responsible provider generally investigates and determines whether an error occurred within 90 days and reports results within three business days after completing the investigation. Available remedies depend on the error and applicable law.
Request the full rights notice
The final provider must make a long-form error-resolution and cancellation notice available upon request using the applicable CFPB model language or substantially similar language.
5. Fees, Exchange Rates, Recipient Amounts, and Delivery Estimates
- Fees, exchange rates, taxes, recipient amounts, and delivery estimates must be presented before payment in the transaction-specific disclosure.
- Quotes may expire. If a quote changes before authorization, the updated disclosure must be presented for review.
- Rates may include a spread and may be supplied or approved by the licensed provider or payout partner.
- Examples, prototypes, and screenshots are not live quotes and must not be relied upon.
- No service should be advertised as “free,” “instant,” “guaranteed,” or “best rate” unless the claim is accurate, substantiated, and approved.
6. Complaints, Refunds, and Support
You may submit a complaint or support request by email. Include your name, preferred contact method, transaction reference if applicable, a description of the concern, relevant dates, and the result you are requesting. Do not email passwords, one-time codes, or full bank-account numbers.
Submit a complaint Request transfer support
We will assign or communicate a case reference when the support process is operational, classify potential errors promptly, investigate using appropriate records, communicate the outcome, and provide escalation or appeal information when applicable. The final receipt must identify the responsible remittance provider and applicable regulator complaint contacts.
7. Account Deletion and Privacy Requests
You may request deletion of a Qarshi Pay account through the in-app deletion control when available or through this external webpage using the request link below. We may verify your identity and ask for limited information needed to locate the account.
Deleting an account is different from temporarily disabling it. Eligible account data will be deleted or de-identified, but some records may be retained when reasonably necessary for AML, sanctions, fraud prevention, security, disputes, tax, legal hold, recordkeeping, or other lawful obligations. We will explain applicable retention exceptions and provide confirmation when the request is completed.
8. Partner and Licensing Disclosure
Before live transfers are offered, Qarshi Pay must publish the accurate legal entity, provider-of-record, applicable NMLS and state-license information, regulator contacts, funding and payout roles, and approved territories. Third-party names and logos must not be displayed as active without permission. Provider and regulator information printed on a final transaction receipt will control for that transfer.
9. Contact Us
Qarshi Pay App - Pre-Launch Legal and Privacy Contact
Email: support@qarshiapp.com
Mailing address: To be added after Minnesota entity registration and before public launch.
Telephone and operating hours: To be added before transfer services are enabled.
10. Required Review Before Launch
This Legal Center is a consolidated pre-launch draft, not a license, production approval, or substitute for transaction-specific disclosures. Before launch, Minnesota fintech counsel, privacy counsel, the licensed remittance provider, funding bank, and applicable partners must reconcile it with the registered entity, executed contracts, licensing model, actual data flows, retention schedule, customer-support channels, CFPB disclosures, app configuration, and Google Play declarations. Confidential AML rules, sanctions procedures, security controls, contracts, Board records, investigations, and internal operating manuals must not be posted publicly.