1. Introduction

Welcome to ThinkTerns (www.thinkterns.com). We are committed to protecting your personal and financial data. This Privacy Policy outlines how we collect, use, and safeguard information when you use our payment gateway solutions in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data We Collect

To provide secure payment processing, we collect:

• Merchant Data: Business name, registration numbers, director details, and bank account information.
• Transaction Data: Cardholder names, billing addresses, tokenized primary account numbers (PANs), and transaction values.
• Technical Data: IP addresses, browser types, and device identifiers used for fraud monitoring.

3. How We Use Your Data

We process your data to:

• Authorize and settle payment transactions.
• Conduct Know Your Customer (KYC) and fraud prevention checks.
• Comply with legal and regulatory obligations set by the FCA.

4. Data Security & PCI-DSS

ThinkTerns handles all payment data in strict accordance with the Payment Card Industry Data Security Standard (PCI-DSS). Card details are encrypted and tokenized. We do not store raw magnetic stripe, card validation code, or PIN block data.

5. Your Data Rights

Under UK GDPR, you have the right to access, rectify, or erase your personal data (subject to our legal retention requirements for financial records). To exercise these rights, contact our Data Protection Officer at privacy@thinkterns.com.

1. Overview

These Terms govern the use of ThinkTerns' payment gateway services. By integrating our API or utilizing our checkout solutions at www.thinkterns.com, you agree to these binding terms.

2. Provision of Services

ThinkTerns provides a platform for capturing, routing, and processing digital payments. We rely on acquiring banks and card networks (e.g., Visa, Mastercard). Service availability is subject to network uptime and scheduled maintenance.

3. Settlement and Fees

Funds processed through ThinkTerns will be settled to the merchant's designated bank account minus applicable transaction fees, rolling reserves, and chargeback penalties, as defined in your specific pricing schedule.

4. Chargebacks and Disputes

Merchants are solely responsible for all chargebacks, fraud, and disputes arising from their transactions. ThinkTerns reserves the right to withhold funds or suspend accounts exhibiting excessive chargeback ratios (typically exceeding 1% of total transaction volume).

5. Limitation of Liability

To the maximum extent permitted by UK law, ThinkTerns is not liable for indirect, incidental, or consequential damages, including lost profits, arising from service interruptions or third-party network failures.

1. Policy Statement

ThinkTerns maintains a zero-tolerance approach to money laundering and terrorist financing. We strictly adhere to the UK Money Laundering Regulations (MLRs) and the Proceeds of Crime Act 2002.

2. Merchant Onboarding (KYC)

Before granting access to our payment gateway, all merchants must undergo rigorous identity verification. We require:

• Certificate of Incorporation.
• Proof of business address.
• Government-issued ID and proof of address for all Ultimate Beneficial Owners (UBOs) holding 25% or more of the company.
• Detailed descriptions of goods/services sold.

3. Transaction Monitoring

ThinkTerns utilizes automated monitoring systems to detect suspicious payment patterns. We are legally obligated to report suspicious activity to the National Crime Agency (NCA) via Suspicious Activity Reports (SARs) without notifying the merchant ("tipping off").

1. Prohibited Activities

You may not use the ThinkTerns payment gateway to process transactions for the following categories:

• Illegal drugs, narcotics, or related paraphernalia.
• Counterfeit goods or intellectual property infringements.
• Unlicensed gambling, betting, or lotteries.
• Adult content and services.
• Weapons, firearms, and munitions.
• Any product or service that violates UK law or the laws of the jurisdiction in which your customers reside.

2. High-Risk Businesses

Certain business models require pre-approval and may be subject to higher rolling reserves. These include travel services, ticketing, and subscription-based software.

3. Enforcement

Violation of this AUP will result in immediate suspension of payment processing capabilities, freezing of account funds, and termination of the Merchant Agreement.