Security Policy — Pasele

Last updated: 01-09-2026

Pasele is designed to provide fast, trusted and secure everyday payments. Because Pasele handles financial transactions, user identity information, bank account data and payment activity, security is a core part of the service.

This Security Policy describes the measures, rules and responsibilities that apply to the use of Pasele. It also explains how Pasele may prevent, detect, investigate, restrict or block activity that creates a risk to users, merchants, partners, banks or the Pasele ecosystem.

Pasele follows the following security principles:

1. protect user accounts and payment activity;
2. prevent unauthorized access;
3. reduce fraud, scams, abuse and misuse;
4. detect suspicious transactions and behavior;
5. protect personal and financial data;
6. comply with legal, banking, AML/CFT and regulatory obligations;
7. act quickly when there is a security risk;
8. preserve evidence where necessary;
9. cooperate with banks, payment partners and competent authorities when required;
10. maintain the integrity and trust of the Pasele platform.

Pasele applies a strict security-first approach. Any account, transaction, user, merchant, device or activity that creates a security, fraud, legal, AML/CFT, sanctions or abuse risk may be reviewed, limited, blocked, suspended or terminated.

Each user is responsible for keeping their Pasele account secure.

Users must:

• use their own real identity;
• keep their phone, PIN, password and authentication methods secure;
• never share their account with another person;
• never allow another person to use their Pasele account;
• never sell, rent, lend or transfer access to their account;
• immediately report suspicious activity;
• keep their phone number, e-mail address and bank account information up to date;
• use only their own verified bank account;
• comply with all security checks requested by Pasele.

Pasele may require users to complete one or more security steps before using the service, including phone verification, PIN verification, biometric verification, device verification, bank account verification, identity verification or additional KYC checks.

Pasele may require users to set and use a mobile PIN to access the application or approve certain actions.

Pasele may also use or require:

• SMS verification;
• e-mail verification;
• biometric verification;
• device binding;
• one-time passwords;
• transaction confirmation;
• bank account verification;
• additional security checks for high-risk activity.

Pasele may block or restrict access when authentication fails, when a device appears suspicious, when multiple failed login attempts occur, or when there is a risk of unauthorized access.

Pasele may collect and analyze technical security data to protect accounts and transactions. This may include device identifiers, IP address, operating system, app version, login activity, approximate location, network signals, failed access attempts and suspicious behavior patterns.

Pasele may restrict or block access when:

• a device appears compromised;
• a device is linked to fraud or suspicious activity;
• multiple accounts are linked to the same device in a suspicious way;
• a user tries to bypass security controls;
• access occurs from unusual or high-risk locations;
• there are signs of automation, scraping, malware, emulator abuse or unauthorized tools.

Users must not attempt to bypass, disable, reverse engineer, manipulate or interfere with Pasele’s security systems.

Pasele monitors transactions to detect suspicious, unusual, fraudulent or prohibited activity.

Pasele may review, delay, reject, reverse, limit or block a transaction when there is a reasonable suspicion of:

• fraud;
• scam activity;
• identity misuse;
• money laundering;
• terrorist financing;
• sanctions risk;
• unauthorized account use;
• money mule activity;
• use of funds from an unclear source;
• attempts to bypass limits;
• suspicious transaction patterns;
• threats, coercion or abuse;
• illegal or prohibited goods or services;
• activity that violates Pasele’s Terms and Conditions.

Pasele is not required to disclose its internal fraud detection rules, security logic, monitoring thresholds or risk scoring models when disclosure could weaken security, assist fraudsters or compromise investigations.

Pasele may request identity documents, proof of address, proof of bank account, proof of source of funds, proof of income, business information, transaction explanations or any other information required for security, KYC, AML/CFT, fraud prevention or regulatory compliance.

Users must provide accurate, complete and authentic information.

Pasele may block or close an account if the user:

• refuses to provide requested information;
• provides false or misleading information;
• submits forged or altered documents;
• fails identity verification;
• uses someone else’s identity;
• uses someone else’s bank account;
• acts as a money mule;
• receives or transfers funds for unknown third parties;
• shows suspicious or high-risk behavior;
• creates multiple accounts to avoid controls;
• attempts to hide the true payer, beneficiary or source of funds.

Pasele applies a zero-tolerance policy toward threats, intimidation, harassment, blackmail, coercion, abusive behavior and pressure against users, employees, support agents, merchants, banks, partners or service providers.

If Pasele detects or reasonably suspects threats, intimidation or abusive conduct, Pasele may:

• immediately restrict the account;
• block transactions;
• suspend access;
• close the account;
• preserve evidence;
• notify banks or partners;
• report the matter to competent authorities where necessary or legally required.

Security is not limited to technical protection. User conduct that threatens the safety, trust or integrity of the Pasele ecosystem may result in immediate action.

Pasele may temporarily or permanently block, suspend, limit or close an account when necessary to protect users, prevent fraud, comply with the law, respond to security threats or preserve the integrity of the platform.

This may happen without prior notice when prior notice could:

• compromise an investigation;
• increase the risk of fraud;
• allow funds to be moved unlawfully;
• endanger users or employees;
• violate legal or regulatory duties;
• weaken security controls;
• interfere with reporting obligations.

Pasele may not provide full details of a security decision if doing so could reveal internal detection methods, compromise an investigation, assist fraudsters or breach legal obligations.

Businesses using Pasele must comply with enhanced security and verification requirements.

Pasele may require merchants to provide:

• company registration documents;
• tax information;
• owner, director and UBO information;
• business bank account details;
• proof of business activity;
• licenses or permits where required;
• website, product or service information;
• transaction explanations;
• refund and customer support information.

Pasele may apply transaction limits, payout delays, rolling reserves, additional reviews or account restrictions to merchants that present a higher risk.

Pasele may suspend or terminate merchant access in cases of fraud, excessive complaints, suspicious volume spikes, prohibited goods or services, consumer deception, illegal activity, unclear ownership, sanctions risk or refusal to cooperate with compliance checks.

Pasele uses technical and organizational measures to protect personal data, financial information and transaction data.

These measures may include:

• encryption;
• access controls;
• authentication controls;
• monitoring and logging;
• fraud detection systems;
• secure cloud infrastructure;
• internal permission management;
• separation of duties;
• vulnerability management;
• audit trails;
• backup procedures;
• staff confidentiality obligations;
• vendor security reviews;
• incident response procedures.

No system can be guaranteed to be completely secure. Pasele works to reduce risk, but users must also take reasonable steps to protect their own devices, accounts and authentication credentials.

Users must:

• use Pasele only for lawful and legitimate purposes;
• protect their phone, PIN, password and authentication methods;
• never share access to their account;
• verify payment details before confirming transactions;
• avoid sending money to unknown or suspicious persons;
• report suspicious requests or scams;
• keep their contact and bank details updated;
• cooperate with security and compliance checks;
• immediately report lost phones, stolen credentials or unauthorized access.

Users must not:

• use Pasele for illegal transactions;
• use Pasele on behalf of unknown third parties;
• accept money from unknown sources;
• hide the true source or destination of funds;
• split transactions to avoid limits;
• create multiple accounts to bypass controls;
• threaten, harass or intimidate others;
• use fake documents or false identities;
• attempt to bypass security systems.

Users must contact Pasele immediately if they notice:

• unauthorized access;
• unknown transactions;
• lost or stolen phone;
• suspected account takeover;
• suspicious payment requests;
• fake Pasele messages;
• phishing attempts;
• fraud or scam activity;
• security vulnerabilities;
• abuse or threats.

Security contact: security@pasele.com
Customer support: service@pasele.com

When reporting a security issue, users should include relevant information such as the date, time, transaction reference, screenshots, phone number, e-mail address, description of the issue and any suspicious messages received.

Pasele will never ask users to share their PIN, password, full authentication code or sensitive security credentials through unofficial channels.

Users should be careful with messages, calls, links or social media accounts claiming to represent Pasele.

Users must not click suspicious links or share account information with anyone claiming to be Pasele support outside official channels.

Pasele may warn users, block suspicious links, restrict accounts or investigate activity related to phishing, impersonation or fake support channels.

If a person discovers a security vulnerability in Pasele’s systems, they must report it responsibly to Pasele through the official security contact.

The person must not:

• exploit the vulnerability;
• access, copy, modify or delete data;
• disrupt the service;
• perform social engineering;
• attack users, employees or partners;
• publicly disclose the vulnerability before Pasele has reviewed it;
• demand payment through threats or extortion.

Pasele may investigate reported vulnerabilities and take appropriate action. Unauthorized testing, exploitation or access may lead to legal action.

If Pasele detects a security incident, Pasele may take immediate action to protect users and the platform.

Actions may include:

• blocking accounts;
• resetting authentication;
• disabling certain features;
• delaying transactions;
• notifying affected users;
• notifying banks or payment partners;
• preserving logs and evidence;
• reporting to competent authorities where required;
• updating security controls;
• conducting internal investigations.

Pasele will communicate with users when required or appropriate, taking into account legal obligations, security risks and the need to avoid compromising investigations.

Pasele may retain security logs, transaction records, fraud alerts, KYC records, compliance decisions, access logs, device data, investigation records and related evidence for as long as necessary to:

• comply with legal and regulatory obligations;
• prevent fraud;
• investigate suspicious activity;
• respond to authorities;
• resolve disputes;
• protect users;
• defend Pasele’s rights;
• maintain the security and integrity of the platform.

Pasele may refuse to delete certain security-related records where retention is legally required or necessary for fraud prevention, AML/CFT compliance, security investigations or dispute resolution.

Pasele uses reasonable and appropriate measures to protect the service, users and transactions. However, no digital system, financial service, mobile application or communication network can be guaranteed to be completely secure or free from risk.

Pasele is not responsible for losses caused by user negligence, shared credentials, compromised devices, scams, false information provided by users, unauthorized third-party access resulting from user action, force majeure, third-party service failures or circumstances outside Pasele’s reasonable control, except where liability cannot be excluded under applicable law.

Pasele may update this Security Policy to reflect changes in technology, law, regulation, security practices, business operations, banking requirements, payment partner requirements or risk conditions.

Users may be notified of important changes through the application, website, e-mail or another appropriate communication channel.

Continued use of Pasele after the updated Security Policy becomes effective means that the user accepts the updated policy, where permitted by applicable law.

For security-related questions, reports or concerns, users may contact: