Legal Section
QUANTUMPAY
COMPLETE LEGAL CENTER & CUSTOMER POLICIES
Effective Date: September 29, 2026
Last Updated: September 29, 2026
QuantumPay
2243 E Connecticut Ave
Southern Pines, NC 28387
Phone: (984) 405-1961
Legal & Compliance: legal@quantumpay.cloud
1. PURPOSE & ACCEPTANCE
Welcome to QuantumPay.
This Legal Center establishes the policies, terms, disclosures, conditions, privacy practices, compliance standards, and customer protections applicable to QuantumPay’s websites, software, digital products, consulting services, financial infrastructure services, auditing services, AML compliance services, communications, and other products and services.
By accessing our website, creating an account, requesting services, submitting information, purchasing a product, engaging QuantumPay, accessing software, downloading digital materials, or otherwise using our services, you acknowledge the policies applicable to your interaction with QuantumPay.
If you are using QuantumPay on behalf of a company, organization, partnership, or other legal entity, you represent that you have appropriate authority to act on behalf of that entity.
Nothing contained in these policies is intended to waive any right or protection that cannot lawfully be waived.
2. ABOUT QUANTUMPAY
QuantumPay is a non-monetary financial technology, financial infrastructure, compliance-support, auditing, consulting, and software-development company serving new and established businesses.
QuantumPay’s services may include:
● Financial technology consulting
● Financial infrastructure consulting
● Financial institution research
● Financial portfolio development assistance
● Accounting software evaluation
● Accounting technology implementation assistance
● Financial audits and reviews
● Operational financial reviews
● AML compliance reviews
● Comprehensive AML compliance audits
● AML policy development
● Compliance gap assessments
● KYB/KYC process consultation
● Payment policy development
● Payment-processing policy development
● Cash-handling and cash-management policy development
● Financial technology assessments
● Software and digital infrastructure products.
QuantumPay is developing an all-in-one financial infrastructure software solution intended to help businesses organize financial operations, accounting technology, reporting, compliance functions, payment infrastructure, and related business processes.
Unless expressly stated otherwise in writing, QuantumPay does not operate as a bank or depository financial institution and does not represent its consulting or audit services as governmental regulatory approval.
3. PRIVACY POLICY
QuantumPay respects the privacy and confidentiality of its customers, prospective customers, business representatives, website visitors, and users.
We seek to collect only information reasonably necessary to provide services, maintain security, administer our operations, comply with applicable requirements, and protect QuantumPay and its customers.
Information We May Collect
Depending upon the services requested, information may include:
● Individual name
● Business name
● Business address
● Email address
● Telephone or mobile number
● Account information
● Business formation information
● Ownership information
● Beneficial ownership information
● Authorized representative information
● Business industry
● Business activities
● Financial information supplied for an audit or consultation ● Accounting information
● Transaction information
● Payment confirmations
● Compliance documentation
● KYB/KYC documentation
● Identification information where reasonably required ● Source-of-funds documentation where appropriate ● IP address
● Browser information
● Device information
● Website activity
● Cookie information
● Customer-support communications
● SMS communications
● Email communications
● Audit documents
● Compliance records
● Documents voluntarily provided by customers. How Information Is Used
Information may be used to:
● Provide requested products and services
● Maintain customer accounts
● Process orders
● Provide customer support
● Authenticate customers
● Prevent fraud
● Maintain system security
● Conduct authorized audits
● Perform compliance reviews
● Perform financial infrastructure assessments
● Prepare requested policies or reports
● Communicate concerning services
● Maintain business records
● Improve products and software
● Investigate suspected misuse
● Comply with applicable legal obligations.
4. CUSTOMER INFORMATION NON-SALE POLICY
QuantumPay does not sell customer personal information, telephone numbers, mobile numbers, SMS consent records, email addresses, customer lists, or customer contact information to third parties for their independent marketing or solicitation.
QuantumPay does not rent customer contact information to marketers.
QuantumPay does not provide customer telephone numbers to unrelated businesses so those businesses can independently advertise to or solicit QuantumPay customers.
QuantumPay does not maintain its customer database for resale as a marketing list.
This policy specifically includes protection against the sale or disclosure of customer contact information for independent solicitation by parties such as:
● Marketing companies
● Advertising firms
● Lead-generation companies
● Telemarketing companies
● Solicitors
● Data brokers
● Unaffiliated sales organizations
● Unrelated creditors or debt marketers seeking leads
● Promotional mailing companies
● Unrelated SMS marketing companies.
This restriction does not prevent QuantumPay from using vendors that process information on QuantumPay’s behalf to operate services, such as communications, hosting, cybersecurity, payment, professional, or technology providers, provided such processing is for legitimate service purposes and subject to applicable contractual or legal protections.
Information may also be disclosed where required by valid legal process, applicable law, regulatory requirements, fraud investigations, security obligations, or other circumstances permitted or required by law.
5. TERMS OF SERVICE
Customers must use QuantumPay services lawfully and provide information that is materially accurate to the best of their knowledge.
Customers may not knowingly use QuantumPay services to facilitate:
● Fraud
● Identity theft
● Money laundering
● Terrorist financing
● Sanctions evasion
● Unauthorized transactions
● Payment fraud
● False business identities
● Forged documentation
● Deceptive financial practices
● Unauthorized access to computer systems
● Other unlawful conduct.
QuantumPay may decline, restrict, suspend, or terminate services when reasonably necessary because of suspected fraud, unlawful activity, sanctions concerns, material misrepresentation, security threats, nonpayment, abuse, or unacceptable compliance risk.
6. PROFESSIONAL SERVICES
QuantumPay may provide consulting, auditing, compliance, financial infrastructure, policy-development, accounting-technology, and related professional services.
The exact scope of an engagement may be established through a service description, invoice, order, statement of work, engagement agreement, subscription, or other written agreement.
Customers are responsible for providing complete and accurate information necessary to perform requested services.
A customer remains responsible for business decisions made following receipt of QuantumPay recommendations.
7. PAYMENT POLICY
Customers agree to pay the price disclosed at the time of purchase or contained in an applicable quote, invoice, subscription, service agreement, or statement of work.
Payment may be required:
● In advance
● At checkout
● By deposit
● Through milestones
● By subscription
● Through a retainer
● Upon invoice
● According to another written payment schedule.
Customers represent that they are authorized to use the payment method submitted.
Taxes, government charges, bank fees, processor fees, or third-party expenses may be separately applicable when properly disclosed.
8. PAYMENT PROCESSING POLICY
QuantumPay may use third-party payment processors to facilitate payments.
Payment processors maintain their own terms, security standards, compliance requirements, underwriting requirements, transaction limits, and risk controls.
QuantumPay cannot guarantee approval of a transaction by an independent processor or financial institution.
Customers may not knowingly submit:
● Fraudulent payments
● Unauthorized transactions
● Stolen payment information
● Misrepresented transactions
● Payments designed to conceal unlawful activity.
QuantumPay may request reasonable supporting documentation when investigating payment discrepancies, fraud, chargebacks, unauthorized transactions, or compliance concerns.
9. DIGITAL SHIPPING, HANDLING & DELIVERY
QuantumPay primarily offers digital software, electronic products, professional services, reports, policies, compliance documentation, digital deliverables, and electronically accessible services.
Therefore, traditional physical shipping and handling generally do not apply. Digital fulfillment may occur through:
● Immediate software access
● Account activation
● Electronic download
● Customer dashboard
● Secure electronic transmission
● Online portal
● Software licensing
● Other electronic delivery methods.
Where a product is designated for immediate delivery, fulfillment may begin immediately following successful purchase or authorization.
A digital product is generally considered delivered when access has been provided, activated, transmitted, or otherwise made available to the customer through the designated electronic delivery method.
10. REFUND, RETURN & EXCHANGE POLICY
ALL SALES ARE FINAL
Because QuantumPay provides digital products, software, electronically delivered materials, professional services, customized documentation, financial audits, AML reviews, policy development, consulting, and services that may begin immediately after purchase, QuantumPay generally does not offer refunds, returns, or exchanges.
Once digital access has been provided or professional work has begun, the transaction is considered final unless QuantumPay expressly agrees otherwise in writing or applicable law requires another result.
QuantumPay does not generally issue refunds for:
● Change of mind
● Failure to use a purchased product
● Digital products already delivered
● Software access already activated
● Completed consultations
● Completed financial audits
● Completed AML audits
● Completed compliance reviews
● Customized policies
● Completed reports
● Work already performed.
Nothing in this policy eliminates rights concerning unauthorized transactions, fraudulent charges, materially undelivered purchases, or other rights that cannot legally be waived.
11. COOKIE POLICY
QuantumPay may use cookies and similar technologies to support website functionality, authentication, security, fraud prevention, preferences, analytics, performance measurement, and service improvement.
Cookies may include necessary cookies and, where applicable, analytics or other optional technologies.
Where required by applicable law, users will be provided appropriate choices regarding non-essential cookies.
Browser settings may also allow users to restrict or delete cookies.
Disabling necessary cookies may prevent portions of the website or software from functioning correctly.
12. INTERNET & ACCEPTABLE USE POLICY
QuantumPay’s website, software, systems, and digital products may not be used to:
● Violate applicable law
● Conduct fraud
● Spread malware
● Circumvent security
● Obtain unauthorized system access
● Steal information
● Misrepresent identity
● Misrepresent business ownership
● Facilitate unlawful financial activity
● Violate intellectual-property rights
● Interfere with QuantumPay systems
● Abuse payment systems
● Conduct unauthorized automated extraction
● Engage in activity that threatens QuantumPay, customers, systems, or third parties. QuantumPay may take reasonable security action when misuse is detected.
13. SMS & TEXT MESSAGING PRIVACY POLICY
QuantumPay considers customer telephone numbers, mobile numbers, SMS communications, and SMS consent information to be customer information requiring appropriate protection.
NO SALE OF MOBILE INFORMATION
QuantumPay does not sell customer mobile telephone numbers or SMS consent information to third parties for their independent marketing or solicitation.
NO MARKETING-LIST DISTRIBUTION
QuantumPay does not rent, trade, distribute, or provide customer mobile numbers to unrelated third parties for their independent advertising, marketing, lead generation, or solicitation.
This includes unrelated:
● Marketing firms
● Advertising agencies
● Lead generators
● Telemarketers
● Solicitors
● Data brokers
● Promotional organizations
● Unaffiliated sales companies
● Unrelated creditors seeking marketing leads
● Third-party SMS marketers.
SMS CONSENT DATA
A customer’s consent to receive text messages from QuantumPay applies to communications authorized under that consent.
SMS opt-in information and consent are not sold or provided to unrelated third parties for their independent marketing purposes.
QuantumPay will not treat consent to communicate with QuantumPay as blanket permission for unrelated companies to market to the customer.
SERVICE PROVIDERS
QuantumPay may use technology providers, telecommunications providers, SMS delivery platforms, hosting companies, security providers, and other processors when reasonably necessary to transmit or administer QuantumPay communications.
Any such access is for providing services on behalf of QuantumPay rather than giving the provider independent permission to market to QuantumPay customers.
LEGALLY REQUIRED DISCLOSURES
Nothing in this policy prevents disclosure when QuantumPay is legally required to respond to valid legal process or when disclosure is otherwise required or permitted by applicable law, including appropriate fraud, security, regulatory, or law-enforcement matters.
TYPES OF MESSAGES
Customers who appropriately consent may receive:
● Account notifications
● Customer-service messages
● Security alerts
● Appointment reminders
● Requested service updates
● Transaction-related notifications
● Compliance communications
● Authorized promotional communications.
Message frequency may vary.
Message and data rates may apply.
SMS OPT-OUT
Customers may withdraw consent to applicable recurring SMS communications through recognized opt-out methods, including replying STOP where supported.
QuantumPay will process valid opt-out requests as required.
Consent to receive marketing text messages is not a condition of purchasing QuantumPay products or services unless otherwise permitted by applicable law.
14. AML/CFT COMPLIANCE POLICY
QuantumPay maintains a policy against the misuse of its services for money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful financial activity.
QuantumPay may use risk-based procedures appropriate to its business and may request information concerning:
● Customer identity
● Business identity
● Business ownership
● Beneficial owners
● Authorized representatives
● Business activities
● Transaction purpose
● Source of funds
● Financial activity
● Supporting documentation.
QuantumPay may refuse or discontinue services where required information cannot reasonably be verified or unacceptable financial-crime risk is identified.
15. AML COMPLIANCE SERVICES
QuantumPay may provide professional AML compliance services to new and established businesses.
Services may include:
● Standard AML compliance reviews
● Comprehensive AML compliance audits
● AML risk assessments
● AML program reviews
● Internal-control reviews
● Compliance gap assessments
● AML policy reviews
● AML policy development
● AML procedure development
● KYB/KYC process consultation
● Payment compliance reviews
● Cash-management reviews
● Compliance remediation recommendations
● Independent testing or reviews when appropriate to the engagement.
QuantumPay may assess whether a client’s documented controls appear consistent with the requirements and risk framework identified for the engagement.
However, a QuantumPay audit or review does not constitute certification by FinCEN, another federal agency, a state regulator, a bank, or another governmental authority.
Clients remain responsible for determining the legal requirements applicable to their businesses and implementing legally required compliance programs.
16. PAYMENT & PAYMENT-PROCESSING COMPLIANCE
QuantumPay may assist businesses with developing internal policies concerning:
● Payment acceptance
● Payment authorization
● Payment documentation
● Transaction reconciliation
● Refund procedures
● Payment-processing controls
● Fraud prevention
● Chargeback management
● Recordkeeping
● Internal approvals
● Payment security.
Policies developed by QuantumPay should be implemented and maintained by the client according to the client’s actual operations and applicable obligations.
17. CASH-HANDLING &
CASH-MANAGEMENT POLICY SERVICES
QuantumPay may assist businesses in developing controls concerning:
● Cash receipt
● Cash custody
● Employee access
● Deposit procedures
● Reconciliation
● Dual controls
● Recordkeeping
● Cash discrepancies
● Internal reporting
● Fraud prevention.
QuantumPay does not assume responsibility for a client’s employees, physical cash, bank accounts, or implementation of internal procedures merely because QuantumPay developed or reviewed a policy.
18. NDA & CONFIDENTIALITY POLICY
QuantumPay recognizes that customers may provide sensitive and proprietary business information during professional engagements.
Confidential information may include:
● Financial statements
● Banking information
● Accounting records
● Business plans
● Customer records
● Supplier records
● Pricing
● Internal procedures
● AML programs
● Audit findings
● Technology
● Software
● Security information
● Trade secrets
● Proprietary methods
● Non-public business information.
QuantumPay will use reasonable measures to protect confidential information received through an engagement.
QuantumPay will not knowingly disclose confidential customer information except as authorized, reasonably necessary to perform contracted services, or required or permitted by applicable law.
Customers must likewise protect QuantumPay’s proprietary information.
A separately executed NDA may impose additional confidentiality requirements.
19. DATA SECURITY
QuantumPay uses reasonable administrative, organizational, and technical safeguards intended to protect customer information.
However, no website, telecommunications network, email system, internet service, cloud platform, or electronic storage environment can be guaranteed completely secure.
Customers must maintain appropriate password security, device security, access controls, backups, cybersecurity practices, and authorized-user procedures.
Customers should immediately notify QuantumPay of suspected unauthorized access involving their QuantumPay account or services.
20. FINANCIAL INSTITUTION RESEARCH DISCLAIMER
QuantumPay may help businesses identify or evaluate financial institutions and financial service providers.
Research or recommendations do not constitute approval by the institution. Each financial institution maintains its own:
● Eligibility requirements
● Underwriting criteria
● Compliance standards
● Risk appetite
● Pricing
● Account restrictions
● Approval processes.
QuantumPay cannot guarantee account approval, continued account availability, credit approval, payment-processing approval, or another institution’s decision.
21. ACCOUNTING SOFTWARE
DISCLAIMER
QuantumPay may evaluate accounting and financial-management software based on a customer’s stated requirements.
Software recommendations represent professional assessments based on information available during the engagement.
Third-party software companies independently control their products, pricing, availability, functionality, security, integrations, and terms.
22. SOFTWARE & DIGITAL PRODUCT LICENSE
Purchasing QuantumPay software or digital products does not automatically transfer ownership of QuantumPay intellectual property.
Unless expressly stated otherwise, customers receive a limited right to use purchased software or materials according to the applicable license or service terms.
Customers may not unlawfully:
● Copy proprietary software
● Resell licensed materials
● Distribute proprietary templates
● Reverse engineer protected software
● Remove intellectual-property notices
● Claim QuantumPay intellectual property as their own.
23. PROFESSIONAL DISCLAIMER
QuantumPay provides financial technology, business infrastructure, compliance-support, auditing, consulting, and software services.
Unless specifically provided under a separate engagement by an appropriately licensed professional, QuantumPay’s ordinary services should not be interpreted as legal, tax, investment, securities, or individualized regulated financial advice.
Clients should retain appropriately licensed professionals when their circumstances require those services.
24. REGULATORY DISCLAIMER
QuantumPay is not a government regulatory agency.
QuantumPay does not issue governmental licenses, governmental certifications, regulatory approvals, or guarantees of regulatory compliance.
A compliance review represents an assessment performed within the agreed scope using information available at the time of review.
Changes in law, regulations, guidance, business operations, customer activity, or risk may affect future compliance.
25. NON-LIABILITY DISCLOSURE
To the fullest extent permitted by applicable law, QuantumPay is not responsible for losses resulting solely from independent decisions or conduct of third parties outside QuantumPay’s reasonable control.
Examples include:
● Bank application denials
● Account closures by third-party institutions
● Payment-processor decisions
● Credit decisions
● Government decisions
● Regulatory actions
● Third-party software outages
● Third-party service interruptions
● Customer failure to follow recommendations
● Customer misuse of reports or policies
● Inaccurate information supplied by a customer
● Unauthorized access caused by compromised customer credentials.
Nothing in this policy excludes or limits liability where exclusion or limitation is prohibited by applicable law.
26. LIMITATION OF LIABILITY
To the fullest extent permitted by applicable law and applicable contractual terms, QuantumPay will not be responsible for indirect, incidental, special, exemplary, punitive, or consequential losses arising from the use or inability to use QuantumPay products or services.
Any limitation of liability is subject to rights and remedies that cannot lawfully be excluded.
27. NO GUARANTEE OF BUSINESS RESULTS
QuantumPay does not guarantee:
● Business profitability
● Revenue
● Financing
● Banking approval
● Credit approval
● Processor approval
● Account longevity
● Regulatory approval
● Investment performance
● A specific financial result.
Customers retain responsibility for their own business decisions.
28. INTELLECTUAL PROPERTY
QuantumPay retains its rights in its:
● Brand
● Name
● Logos
● Software
● Systems
● Templates
● Reports
● Proprietary methodologies
● Website content
● Graphics
● Documentation
● Original policy materials
● Other intellectual property.
Unauthorized reproduction or commercial exploitation may violate contractual or intellectual-property rights.
29. THIRD-PARTY SERVICES
QuantumPay may integrate with, recommend, research, or link to third-party products and services.
Third-party services maintain independent terms, privacy policies, security practices, pricing, eligibility requirements, and operating procedures.
QuantumPay does not control those independent businesses.
30. ELECTRONIC COMMUNICATIONS
Customers consent to conducting transactions and receiving documents electronically where permitted.
Electronic communications may include:
● Website notices
● Customer portal messages
● Electronic agreements
● Electronic invoices
● SMS where consent has been provided
● Digital reports
● Compliance documentation.
Customers are responsible for maintaining current contact information.
31. POLICY UPDATES
QuantumPay may revise these policies when reasonably necessary to reflect changes in:
● Law
● Regulation
● Technology
● Security
● Business operations
● Products
● Services
● Compliance requirements.
The current effective date will be displayed on the Legal Center.
Where legally required, appropriate notice of material changes will be provided.
32. SEVERABILITY
If a provision of these policies is found unenforceable, that provision should be interpreted or limited to the extent necessary under applicable law while preserving the remaining provisions whenever legally possible.
33. NO WAIVER
Failure by QuantumPay to enforce a contractual provision on one occasion does not automatically waive the right to enforce that provision later.
34. CUSTOMER RESPONSIBILITY
Customers are responsible for reviewing applicable policies before purchasing or using QuantumPay services.
Customers are also responsible for ensuring that information supplied to QuantumPay is accurate and that their use of QuantumPay products and recommendations complies with laws applicable to their own businesses.
35. LEGAL & PRIVACY CONTACT
For questions concerning privacy, legal notices, compliance, customer information, SMS privacy, these Terms, or other QuantumPay policies, contact:
QUANTUMPAY
2243 E Connecticut Ave
Southern Pines, NC 28387
Phone: (984) 405-1961
Legal & Compliance: legal@quantumpay.cloud
QUANTUMPAY LEGAL CENTER
Privacy Policy • Terms of Service • Customer Information Non-Sale Policy • Payment Policy • Payment Processing Policy • Digital Shipping & Handling Policy • Refund, Return & Exchange Policy • Cookie Policy • Internet & Acceptable Use Policy • SMS/Text Messaging Privacy Policy • AML/CFT Compliance Policy • AML Audit Policy • Payment Compliance Policy • Cash-Management Policy • NDA & Confidentiality Policy • Data Security Policy • Professional Disclaimer • Regulatory Disclosure • Financial Institution Disclosure • Software Disclaimer • Non-Liability Disclosure • Intellectual Property Policy • Electronic Communications Policy
PRIVACY COMMITMENT
QuantumPay does not sell customer telephone numbers, mobile numbers, SMS consent records, email addresses, or customer contact lists to unrelated third parties for their independent marketing or solicitation.
Your consent to communicate with QuantumPay is not consent for unrelated companies to market to you
QUANTUMPAY PAYMENT SOLUTIONS LLC
ANTI-MONEY LAUNDERING (AML) POLICY & COMPLIANCE GUIDELINES
Version 2.0 | Effective October 16, 2026
1. PURPOSE AND SCOPE
QuantumPay Payment Solutions LLC (“QuantumPay”) is a consulting, software development, compliance advisory, and financial technology advisory company.
QuantumPay provides professional advisory services, compliance program development, risk assessments, technology consulting, and software solutions to business clients.
This policy establishes QuantumPay’s internal compliance standards and the principles governing its advisory services.
QuantumPay does not provide payment processing, money transmission, customer fund custody, cryptocurrency exchange, wallet custody, merchant settlement, or third-party payment execution.
The AML policies and procedures QuantumPay develops for clients are advisory deliverables. Each client remains responsible for adopting, implementing, and operating its own compliance program.
2. BUSINESS OPERATING MODEL
QuantumPay exclusively provides:
- AML and financial crime compliance consulting.
- Know Your Customer (KYC) and Know Your Business (KYB) program development.
- Financial technology consulting and advisory services.
- Software development and technology infrastructure consulting.
- Corporate financial compliance assessments.
- Internal compliance audits and risk reviews.
- Transaction-monitoring framework design and advisory services.
- Financial institution and payment provider selection consulting.
- Compliance documentation, policy development, and employee training.
- Financial technology integration guidance and software configuration assistance.
All services are performed on a consulting, advisory, or software-development basis.
3. AML POLICY APPLICABILITY
This policy governs QuantumPay’s internal business conduct, client due diligence, engagement risk assessments, employee responsibilities, and professional advisory activities.
QuantumPay may also prepare customized AML compliance frameworks for financial institutions, fintech businesses, and other commercial clients.
Such frameworks are recommendations and contractual consulting deliverables. They do not constitute transaction-monitoring or enforcement activities performed by QuantumPay on behalf of a financial institution unless separately agreed and lawfully authorized.
Responsibility for operating a client’s AML program remains with the client and its designated compliance personnel.
4. CLIENT IDENTIFICATION AND DUE DILIGENCE
QuantumPay maintains risk-based procedures for identifying and evaluating prospective consulting clients.
Depending on the engagement and associated risks, due diligence may include:
- Verification of legal business names and registration information.
- Identification of authorized representatives.
- Review of beneficial ownership information.
- Assessment of business activities and geographic exposure.
- Sanctions screening where appropriate.
- Identification of potential conflicts of interest.
- Evaluation of the services requested.
Enhanced due diligence may be applied when client activities, ownership structures, or jurisdictions present elevated compliance risks.
QuantumPay maintains appropriate confidentiality and data-protection safeguards for information collected.
5. TRANSACTION MONITORING AND RESTRICTIONS
QuantumPay does not directly monitor, approve, reject, suspend, freeze, or release customer financial transactions.
Where QuantumPay advises clients on transaction-monitoring systems, its responsibilities are limited to consulting, policy design, software development, technical recommendations, and related support.
Actual transaction restrictions, account suspensions, payment rejections, and asset freezes are performed by the responsible financial institution, regulated service provider, or other legally authorized party.
QuantumPay does not possess independent authority to freeze or restrict customer accounts or financial assets.
6. HANDLING OF CLIENT FUNDS
QuantumPay does not receive, hold, safeguard, control, transfer, or settle third-party client funds.
The company does not operate custodial accounts, merchant collection accounts, payment settlement accounts, or customer money transmission services.
QuantumPay may receive payments into its own business bank accounts for legitimate consulting, software development, compliance advisory, and technology services.
These payments represent QuantumPay’s own business revenue and do not constitute the custody or transmission of third-party funds.
7. DIGITAL ASSET AND CRYPTOCURRENCY ADVISORY
QuantumPay may provide consulting services concerning digital-asset technology, blockchain systems, cryptocurrency compliance requirements, and financial technology infrastructure.
These services are strictly advisory or software-related.
QuantumPay does not:
- Custody cryptocurrency or digital assets belonging to clients.
- Hold or control customer private keys.
- Initiate cryptocurrency transfers on behalf of clients.
- Operate custodial or noncustodial wallets for customers.
- Exchange cryptocurrency for fiat currency.
- Execute digital-asset trades or settlements.
- Exercise signing authority over customer wallets.
Clients and their independently selected service providers retain responsibility for their own digital-asset operations.
8. FIAT AND DIGITAL-ASSET FUND FLOWS
A. Consulting fee payments
Client → Client’s Financial Institution → QuantumPay Business Account
QuantumPay receives its contractual consulting or software service fees through its own business banking arrangements.
B. Client payment operations
Client → Client’s Authorized Financial Provider → Intended Recipient
QuantumPay does not enter the movement-of-funds chain and does not execute the transaction.
C. Client digital-asset operations
Client-Controlled Wallet → Client-Authorized Provider or Blockchain Network → Intended Recipient
QuantumPay may advise on technology or compliance matters but does not initiate, authorize, custody, or control the transfer.
9. THIRD-PARTY FINANCIAL PROVIDERS
QuantumPay may advise clients on selecting financial institutions, software vendors, and other technology providers.
Any provider selected by a client remains responsible for the financial services it performs under its own contractual and regulatory obligations.
QuantumPay does not represent itself as the provider of those financial services merely because it recommends or assists with a technology solution.
Where QuantumPay has a separate commercial relationship with a provider, the agreement must accurately describe the parties’ responsibilities and permissions.
10. INTERNAL COMPLIANCE GOVERNANCE
QuantumPay maintains internal standards covering:
- Ethical business conduct.
- Client and engagement risk assessment.
- Protection of confidential business information.
- Sanctions and financial crime risk awareness.
- Employee compliance training.
- Recordkeeping and document integrity.
- Escalation of suspected misconduct.
- Periodic compliance policy reviews.
The designated compliance officer or authorized management representative oversees the implementation and review of these internal controls.
11. RECORDKEEPING
QuantumPay maintains records appropriate to its business activities and applicable legal requirements.
Records may include executed consulting agreements, genuine invoices, proof of payment, client due diligence documentation, software development deliverables, compliance assessments, and advisory reports.
Records must accurately reflect actual business transactions and services performed.
No sample, illustrative, or unexecuted document may be represented as evidence of a completed client transaction.
12. SUSPICIOUS ACTIVITY AND ESCALATION
Employees must promptly escalate suspected fraud, sanctions concerns, identity misrepresentation, or other potentially unlawful conduct to designated management or compliance personnel.
QuantumPay will evaluate concerns, take appropriate action within its contractual authority, and cooperate with lawful requests from competent authorities.
Any legally required reporting will be determined according to the company’s actual activities and applicable obligations.
QuantumPay does not claim authority to file regulatory reports on behalf of clients without an appropriate legal basis and authorization.
13. REGULATORY CLASSIFICATION
QuantumPay’s stated business model is limited to consulting, software development, compliance advisory, and financial technology advisory services.
QuantumPay does not represent itself as a bank, money transmitter, cryptocurrency exchange, payment processor, or custodial financial institution.
The company evaluates its regulatory obligations based on the services actually performed and the jurisdictions in which it operates.
Any material expansion into regulated financial activities must undergo legal and compliance review before commencement.
14. WEBSITE AND MARKETING ACCURACY
QuantumPay’s website, promotional materials, client agreements, and compliance documentation must consistently describe its actual services.
References suggesting that QuantumPay independently processes payments, holds customer assets, freezes accounts, or executes cryptocurrency transfers must not be used unless those activities are genuinely performed and legally authorized.
The phrase “primarily non-custodial” should be replaced with the more precise description:
“QuantumPay operates exclusively as a non-custodial consulting, software development, compliance advisory, and financial technology advisory company. It does not receive, hold, control, transfer, or settle third-party client funds or digital assets.”
15. POLICY REVIEW AND APPROVAL
This policy shall be reviewed periodically and whenever there are material changes to QuantumPay’s services, operating model, or applicable legal requirements.
QuantumPay Payment Solutions LLC
Company Registration: 1556638
Authorized Representative: Dianne Allen Title: CEO
Date: Oct 16,2026
Document Status: Revised policy for management review and formal adoption.
SMS/Texting Separate Policy
SMS, TEXT MESSAGING & MOBILE INFORMATION PRIVACY POLICY
QuantumPay respects the privacy and confidentiality of customers who provide telephone numbers, mobile numbers, SMS consent, or other contact information.
Customers may voluntarily provide a mobile telephone number to QuantumPay for communications related to requested services, customer support, account activity, security notifications, appointments, transactions, service updates, and other communications authorized by the customer.
SMS & MOBILE INFORMATION NON-SHARING POLICY
QuantumPay does not sell, rent, trade, give away, release, disclose, or otherwise provide customers’ mobile telephone numbers, SMS consent information, SMS opt-in records, or text-message subscription information to third parties for their independent marketing, advertising, solicitation, debt-collection, or promotional purposes.
This includes, but is not limited to, disclosure for such purposes to:
- Marketing or advertising companies
- Lead-generation companies
- Telemarketing companies
- Solicitors
- Promotional companies
- Data brokers
- Mailing-list providers
- Creditors or third-party debt collectors
- Unaffiliated financial institutions
- Unaffiliated sales organizations
- Social-media marketing companies
- Affiliate marketers
- Other third parties seeking customer information for their own commercial solicitation or marketing activities.
SMS consent is not sold or transferred to third parties for their own marketing or solicitation purposes.
A customer’s decision to provide a telephone number to QuantumPay does not constitute permission for QuantumPay to sell or distribute that number to outside organizations for independent marketing.
INFORMATION COVERED BY THIS POLICY
The protections described in this SMS policy apply, as appropriate, to:
- Mobile telephone numbers
- Telephone numbers
- SMS and text-message consent
- SMS opt-in information
- Opt-in dates and records
- Opt-out requests
- Communication preferences
- Message history maintained by QuantumPay
- Customer names associated with mobile numbers
- Account information associated with SMS communications
- Customer contact information
- Information submitted through SMS enrollment forms.
LIMITED SERVICE-PROVIDER ACCESS
QuantumPay may use telecommunications carriers, SMS platforms, hosting providers, security providers, or other technical vendors strictly as necessary to transmit, secure, authenticate, or administer communications on QuantumPay’s behalf.
Where such access is necessary, information is provided only for the limited purpose of performing services for QuantumPay and not for the provider’s independent marketing, solicitation, advertising, or resale purposes.
Such operational access does not constitute permission for a service provider to sell or independently exploit QuantumPay customer information.
LEGALLY REQUIRED DISCLOSURES
Nothing in this policy prevents QuantumPay from disclosing information when disclosure is required by applicable law, valid subpoena, court order, governmental demand, regulatory requirement, or other legally enforceable process.
QuantumPay may also disclose information when reasonably necessary to investigate or prevent fraud, abuse, security incidents, threats, or unlawful activity, or to protect the rights, property, systems, customers, or security of QuantumPay.
These limited disclosures are not considered marketing or commercial sales of customer SMS information.
NO SALE OF SMS CONSENT
QuantumPay specifically states that:
Mobile information, telephone numbers, SMS consent, and text-message opt-in data will not be sold or shared with third parties or affiliates for their own marketing or promotional purposes.
Consent obtained by QuantumPay applies only to communications authorized under the applicable QuantumPay consent process.
A third party may not rely upon a customer’s consent to QuantumPay as consent for that third party to independently market or solicit the customer.
SMS CONSENT
Where appropriate consent has been provided, QuantumPay may send messages concerning:
- Customer service
- Requested consultations
- Account activity
- Security notifications
- Transaction information
- Appointments
- Service-status notifications
- Requested documentation
- Compliance communications
- Billing or payment information
- Product or software updates
- Other communications authorized by the customer.
Marketing or promotional text messages will only be sent where QuantumPay has an appropriate legal basis or consent to send them.
Consent to receive marketing text messages is not a condition of purchasing QuantumPay products or services unless otherwise permitted by applicable law.
MESSAGE FREQUENCY & CARRIER CHARGES
Message frequency may vary according to the customer’s relationship with QuantumPay and the services requested.
Message and data rates may apply according to the customer’s wireless service agreement.
Wireless carriers are not responsible for delayed or undelivered messages.
OPTING OUT
Customers may withdraw consent from applicable recurring SMS communications at any time by using a supported opt-out method, including replying STOP to an applicable message.
Where supported, other recognized opt-out requests may include:
CANCEL, END, QUIT, REVOKE, OPT OUT, or UNSUBSCRIBE.
QuantumPay will process valid opt-out requests in accordance with applicable requirements.
An opt-out from marketing messages does not necessarily prevent QuantumPay from sending communications that are legally required or otherwise permitted without marketing consent, including certain security, authentication, transactional, account-servicing, or requested customer-support communications.
CUSTOMER RESPONSIBILITY
Customers are responsible for providing a telephone number that they own, control, or are otherwise authorized to use.
Customers should promptly notify QuantumPay if their telephone number changes, is transferred to another person, or is no longer under their control.
SMS PRIVACY COMMITMENT
QuantumPay considers customer telephone numbers and SMS consent information confidential customer information.
QuantumPay’s policy is simple:
**We do not sell your mobile number. We do not provide your SMS consent to marketing firms. We do not give your telephone number to solicitors. We do not release your mobile information to creditors or debt collectors for their independent collection.
Anti-Money Laundering, Counter-Terrorist Financing & Financial Crime Compliance Policy and Protocol
Effective Date: September 30, 2026
Policy Owner: QuantumPay Payment Solutions
Review Cycle: At least annually and upon material regulatory, operational, product, geographic, or risk changes
Applies To: Directors, officers, employees, contractors, compliance personnel, and relevant third-party service providers
1. Purpose and policy statement
QuantumPay Payment Solutions maintains a risk-based Anti-Money Laundering and Counter-Terrorist Financing program designed to prevent its products, services, systems, and business relationships from being used to facilitate money laundering, terrorist financing, sanctions evasion, fraud, financial crime, or other unlawful activity.
The program is designed around recognized U.S. BSA/AML principles, including internal controls, designated compliance responsibility, appropriate personnel training, independent testing, customer identification, risk-based customer due diligence, and ongoing monitoring. These are core elements identified in federal BSA/AML guidance.
QuantumPay will not knowingly process or facilitate transactions involving proceeds of crime, sanctioned persons or prohibited transactions, fictitious businesses, fraudulent activity, identity theft, terrorist financing, or transactions designed to conceal the origin, ownership, destination, or purpose of funds.
2. Risk-based approach
QuantumPay evaluates financial-crime risk based on the characteristics of each customer and relationship rather than treating every customer identically.
Risk factors include the customer’s business type, ownership structure, geographic exposure, products and services used, anticipated transaction activity, payment methods, source of funds, transaction volume, counterparties, and other relevant information.
CDD should establish the nature and purpose of the relationship and expected transaction profile so subsequent activity can be compared against that baseline. Federal guidance similarly emphasizes risk-based CDD and ongoing monitoring.
Customers may be classified internally as low, standard, elevated, or high risk. Risk classifications determine the level of due diligence, monitoring, approval, and periodic review required.
3. Customer identification and verification
Before activating an eligible customer relationship, QuantumPay will collect information reasonably necessary to establish and verify the customer’s identity.
For individuals, this may include legal name, residential address, date of birth, taxpayer or government identification number, government-issued identification, telephone number, email address, and other verification information appropriate to the risk.
For businesses, QuantumPay may collect:
- Legal and trade names;
- EIN or other tax identification number;
- Formation jurisdiction and principal business address;
- Articles of incorporation/organization or equivalent records;
- Business licenses where applicable;
- Website and business contact information;
- Nature and purpose of the business;
- Expected transaction activity;
- Ownership and control information;
- Authorized representatives;
- Source of funds;
- Principal customers or suppliers where relevant; and
- Supporting contracts, invoices or other commercial records when necessary.
QuantumPay may use documentary and non-documentary verification methods and approved identity/KYB technology providers.
4. Beneficial ownership
QuantumPay will identify and verify relevant beneficial owners and controlling persons of business customers according to applicable legal requirements and its risk-based procedures.
Ownership information will be reviewed when material changes occur, including changes in ownership, control, corporate structure, authorized representatives, or other circumstances affecting the customer’s risk profile.
Federal guidance emphasizes written procedures for identifying and verifying beneficial owners and risk-based maintenance of ownership information.
5. Customer Due Diligence
CDD establishes a reasonable understanding of:
Who the customer is; what the customer does; why the customer requires QuantumPay’s services; expected transaction amounts and frequency; expected origin and destination of funds; expected counterparties; geographic exposure; source of funds; and expected use of the relationship.
Information obtained during onboarding becomes part of the customer’s expected activity profile.
Actual transaction activity may subsequently be compared against this profile.
6. Enhanced Due Diligence
Enhanced Due Diligence may be required when a customer, transaction, jurisdiction, ownership structure, product, or activity presents elevated risk.
EDD may include additional identity or corporate verification, source-of-funds documentation, source-of-wealth information when relevant, financial statements, contracts and invoices, explanation of transaction purpose, counterparty information, additional beneficial ownership verification, adverse-media review, sanctions review, senior compliance approval, and increased transaction monitoring.
EDD does not automatically mean rejection. It means QuantumPay requires sufficient information to understand and appropriately manage the identified risk.
7. Sanctions screening
QuantumPay will maintain risk-based procedures intended to prevent prohibited dealings involving sanctioned persons, entities, vessels, jurisdictions, or other restricted parties.
Screening may be performed during onboarding, following material customer-information changes, and in connection with transactions where appropriate.
Potential matches will be reviewed before a final determination is made. Transactions may be held, rejected, blocked, escalated, or reported when required by applicable law.
OFAC recommends a tailored, risk-based sanctions compliance approach and notes that appropriate measures can include sanctions-list screening.
8. Politically Exposed Persons
PEP status is treated as a risk factor rather than automatic evidence of wrongdoing.
Where warranted by the overall risk assessment, QuantumPay may perform additional review concerning a PEP’s identity, position, ownership interests, source of funds, geographic exposure, and transaction activity.
U.S. supervisory guidance likewise describes PEP due diligence as risk-based rather than requiring a unique mandatory procedure simply because someone is a PEP.
9. Transaction monitoring
QuantumPay will monitor activity using manual and/or automated controls appropriate to its products, transaction volume, customer base, and risk exposure.
Monitoring may identify:
unusual increases in transaction volume; transactions materially inconsistent with stated business activity; unexplained third-party payments; rapid movement of funds; unusual transaction patterns; potential structuring; unexplained geographic changes; repeated transactions lacking an apparent commercial purpose; activity involving sanctioned or high-risk parties; account takeover indicators; suspected identity fraud; unusual digital-asset activity; excessive reversals or refunds; and activity inconsistent with known source of funds.
Federal examination guidance describes effective suspicious-activity systems as incorporating detection, alert management, investigation/decision-making, reporting where required, and continuing-activity monitoring.
10. Alert investigation protocol
When an alert is generated, designated personnel should:
Alert → Initial Review → Customer/Transaction Research → Supporting Documentation → Risk Analysis → Compliance Decision → Escalation/Reporting Where Required → Case Closure → Continued Monitoring
Investigators should document the alert reason, transactions reviewed, customer profile, counterparties, supporting evidence, explanation obtained, conclusions reached, and disposition.
An alert alone does not establish wrongdoing.
11. Suspicious activity escalation
Employees and contractors must promptly escalate suspected money laundering, terrorist financing, fraud, sanctions evasion, identity manipulation, structuring, or other suspicious financial activity to designated compliance personnel.
Customers must not be informed of confidential regulatory reporting or investigations where disclosure is prohibited.
If QuantumPay is operating in a capacity subject to FinCEN’s MSB SAR requirements, applicable MSBs generally must file a SAR for qualifying suspicious transactions of $2,000 or more, generally within 30 days after detection, and retain the SAR and supporting documentation for five years.
Whether those particular requirements apply to QuantumPay depends on its actual regulatory status and activities.
12. Source of funds
QuantumPay may require customers to establish the legitimate origin of funds.
Acceptable supporting evidence may include bank statements, invoices, executed contracts, sales records, financial statements, payroll records, tax documents, investment records, loan documentation, corporate records, or other reliable evidence appropriate to the circumstances.
A customer’s stated source of funds should be reasonably consistent with its business operations and anticipated transaction activity.
13. Prohibited and restricted activity
QuantumPay will not knowingly support transactions involving unlawful goods or services, fraudulent businesses, identity theft, terrorist financing, sanctions evasion, proceeds of crime, deceptive payment activity, shell entities established primarily to conceal ownership or illicit activity, or transactions intended to circumvent AML controls.
QuantumPay may also designate additional industries, jurisdictions, products, or transaction types as restricted based on regulatory requirements, banking-partner requirements, or its own risk tolerance.
14. Payment and counterparty controls
Payment instructions should contain sufficient information to identify the relevant customer and beneficiary.
QuantumPay may review sender and beneficiary information, payment purpose, amount, jurisdiction, transaction history, customer risk profile, counterparty relationship, supporting invoice or contract, and consistency with expected business activity.
Transactions that cannot be satisfactorily explained may be delayed, rejected, returned where legally permissible, escalated, or otherwise restricted.
15. Digital-asset controls
Where QuantumPay supports transactions involving digital assets through authorized providers, enhanced controls may include wallet screening, blockchain analytics where available, counterparty review, sanctions screening, transaction tracing, source-of-funds review, and restrictions on wallets or services presenting unacceptable risk.
Digital assets will not be treated as inherently suspicious. Controls will be proportionate to the actual transaction and associated risks.
16. Ongoing monitoring and periodic review
Customer information and risk profiles will be maintained on a risk-sensitive basis.
Reviews may be triggered by significant changes in transaction activity, ownership, business model, products, geography, source of funds, sanctions exposure, adverse information, law-enforcement inquiries, or other material events.
Federal guidance specifically recognizes significant unexplained account changes, ownership changes, suspicious-activity red flags, law-enforcement inquiries, and material customer-information changes as potential review triggers.
17. Record retention
QuantumPay will maintain AML/KYC records for periods required by applicable law and contractual obligations.
Records may include identification documents, verification results, beneficial ownership information, risk assessments, EDD records, transaction records, monitoring alerts, investigations, supporting documentation, compliance approvals, training records, audit findings, and regulatory filings.
Records must be protected against unauthorized access, alteration, destruction, or disclosure.
18. AML Compliance Officer
QuantumPay will designate an appropriately qualified individual responsible for administration and oversight of the AML program.
Responsibilities include maintaining policies and procedures, overseeing KYC/KYB and EDD, monitoring regulatory developments, supervising suspicious-activity investigations, coordinating required regulatory reporting, maintaining compliance records, overseeing training, managing remediation, and reporting material AML matters to senior management.
19. Employee training
Relevant personnel will receive AML and financial-crime training appropriate to their responsibilities.
Training will cover customer identification, KYC/KYB, beneficial ownership, suspicious-activity indicators, sanctions, escalation procedures, confidentiality, fraud indicators, transaction monitoring, and changes to applicable requirements.
Training completion will be documented.
20. Independent testing and audit
QuantumPay’s AML framework will undergo periodic independent testing appropriate to the company’s size, complexity, regulatory status, products, customers, and transaction volume.
Testing may be conducted by qualified independent internal personnel or an external compliance professional who is sufficiently independent from the activities being tested.
Reviews should assess policy implementation, customer files, risk assessments, KYC/KYB controls, sanctions controls, monitoring, case management, regulatory reporting where applicable, recordkeeping, training, and remediation.
Independent testing is one of the established pillars of a BSA/AML compliance framework.
21. No circumvention
No director, employee, contractor, customer, or third party may knowingly bypass, disable, manipulate, or circumvent QuantumPay’s AML, sanctions, KYC/KYB, fraud-prevention, transaction-monitoring, or compliance controls.
Attempts to circumvent controls may result in transaction rejection, account restriction or termination, internal investigation, and regulatory or law-enforcement reporting where legally required.
22. Management oversight
Senior management is responsible for supporting an effective compliance environment, providing adequate resources, addressing material deficiencies, and ensuring corrective actions are implemented.
Material compliance issues should be documented and escalated to appropriate management.
23. Policy review
This policy will be reviewed at least annually and sooner when there are material changes to QuantumPay’s services, transaction volumes, jurisdictions, customer base, regulatory obligations, payment partners, risk profile, or applicable law.
Updates must be documented and appropriately approved.
24. Certification
QuantumPay Payment Solutions maintains a risk-based financial-crime compliance framework designed to identify, assess, monitor, mitigate, and appropriately escalate money-laundering, terrorist-financing, sanctions, fraud, and related financial-crime risks. QuantumPay requires customers and transactions to undergo controls proportionate to the risks presented and reserves the right to decline, suspend, restrict, investigate, or terminate activity presenting unacceptable financial-crime or compliance risk.