Empowering Digital
Finance Innovation

1. Introduction

GOOSEPAY SDN. BHD. ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website goosecard.cn and use our services. Please read this policy carefully. By accessing or using our services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

Personal Information: We may collect personally identifiable information such as your name, email address, phone number, date of birth, government-issued identification documents, bank account details, and mailing address when you register for an account, make a transaction, or contact us.

Financial Information: Transaction data, payment card details, bank account numbers, and digital wallet information necessary for processing your transactions.

Technical Information: IP address, browser type, operating system, device identifiers, access times, pages viewed, and referring URLs collected automatically through cookies and similar technologies.

KYC Information: As required by Nigerian financial regulations, we collect identity verification documents, proof of address, and other documentation necessary for Know Your Customer compliance.

3. How We Use Your Information

We use the information we collect to: (a) provide, operate, and maintain our services; (b) process transactions and send related information; (c) verify your identity and comply with KYC/AML regulations; (d) communicate with you about updates, security alerts, and support; (e) monitor and analyze usage patterns to improve our services; (f) detect, prevent, and address fraud and security issues; (g) comply with legal obligations and regulatory requirements.

4. Data Storage and Security

We implement industry-standard security measures including encryption (AES-256 for data at rest, TLS 1.3 for data in transit), access controls, regular security audits, and secure data centers. Your personal data is stored on secure servers with restricted access. We retain your data for as long as your account is active and for a period thereafter as required by applicable law.

5. Information Sharing

We do not sell your personal information. We may share your information with: (a) service providers who assist in our operations (payment processors, cloud hosting, identity verification services); (b) regulatory authorities and law enforcement as required by law; (c) financial institutions necessary for transaction processing; (d) professional advisors including lawyers, auditors, and insurers.

6. Your Rights

Under the Nigeria Data Protection Regulation (NDPR), you have the right to: (a) access your personal data; (b) rectify inaccurate data; (c) request deletion of your data (subject to legal retention requirements); (d) restrict processing of your data; (e) data portability; (f) object to processing. To exercise these rights, contact us at support@goosecard.cn.

7. Cookies

We use cookies and similar tracking technologies to collect and track information and to improve our service. You can instruct your browser to refuse cookies; however, some features of our service may not function properly without them.

8. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child without verification of parental consent, we take steps to remove that information from our servers.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. Your continued use of our services after changes constitutes acceptance of the revised policy.

10. Contact Us

If you have questions about this Privacy Policy, please contact us at:
Email: support@goosecard.cn
Address: S-07-03, Setia Triangle, Persiaran Kelicap, 11900 Bayan Lepas, Pulau Pinang, Malaysia

1. Acceptance of Terms

By accessing or using the services provided by GOOSEPAY SDN. BHD. ("Company," "we," "us," or "our") through our website goosecard.cn and any associated applications, you agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, you must not access or use our services.

2. Eligibility

You must be at least 18 years of age and have the legal capacity to enter into a binding agreement to use our services. By using our services, you represent and warrant that you meet these eligibility requirements. You must not be a resident of any jurisdiction where the use of our services would be prohibited by law.

3. Description of Services

GOOSEPAY SDN. BHD. provides digital financial technology services including, but not limited to, digital gift card trading, digital payment solutions, and enterprise API services. Our services are subject to change, and we reserve the right to modify, suspend, or discontinue any aspect of our services at any time.

4. User Accounts

To access certain features, you must create an account. You are responsible for: (a) providing accurate and complete registration information; (b) maintaining the confidentiality of your account credentials; (c) all activities that occur under your account; (d) notifying us immediately of any unauthorized use. We reserve the right to suspend or terminate accounts that violate these Terms.

5. Fees and Payments

Certain services may be subject to fees, which will be clearly disclosed before you complete a transaction. All fees are non-refundable unless otherwise stated. We reserve the right to modify our fee structure with reasonable notice. You are responsible for all applicable taxes related to your use of our services.

6. Prohibited Activities

You agree not to: (a) use our services for any illegal purpose, including money laundering, terrorist financing, or fraud; (b) provide false or misleading information; (c) interfere with or disrupt our services or servers; (d) attempt to gain unauthorized access to any part of our services; (e) use automated systems to access our services without permission; (f) engage in any activity that violates applicable laws or regulations; (g) trade stolen, fraudulently obtained, or counterfeit gift cards.

7. Intellectual Property

All content, features, and functionality of our services, including but not limited to text, graphics, logos, icons, software, and the compilation thereof, are the exclusive property of GOOSEPAY SDN. BHD. or its licensors and are protected by international copyright, trademark, and other intellectual property laws.

8. Limitation of Liability

To the fullest extent permitted by applicable law, GOOSEPAY SDN. BHD. shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, or use, arising out of or related to your use of our services. Our total liability shall not exceed the fees paid by you in the twelve (12) months preceding the claim.

9. Indemnification

You agree to indemnify, defend, and hold harmless GOOSEPAY SDN. BHD. and its officers, directors, employees, and agents from any claims, damages, losses, liabilities, and expenses arising from your use of our services or violation of these Terms.

10. Termination

We may terminate or suspend your account and access to our services immediately, without prior notice, for any reason, including breach of these Terms. Upon termination, your right to use our services ceases immediately. Provisions that by their nature should survive termination shall survive.

11. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, without regard to conflict of law principles. Any disputes arising from these Terms shall be resolved through binding arbitration in accordance with the Arbitration and Conciliation Act of Nigeria.

12. Changes to Terms

We reserve the right to modify these Terms at any time. We will provide notice of material changes by updating the "Last updated" date and, where appropriate, providing additional notification. Your continued use of our services following changes constitutes acceptance of the revised Terms.

13. Contact

For questions about these Terms, contact us at:
Email: support@goosecard.cn
Address: S-07-03, Setia Triangle, Persiaran Kelicap, 11900 Bayan Lepas, Pulau Pinang, Malaysia

1. Commitment

GOOSEPAY SDN. BHD. is fully committed to complying with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations. We maintain a comprehensive AML program designed to prevent our services from being used for money laundering, terrorist financing, or other illicit activities. Our program is developed in accordance with the Money Laundering (Prohibition) Act 2011 (as amended), the Terrorism (Prevention) Act 2011, guidelines issued by the Central Bank of Nigeria (CBN), and the Nigeria Financial Intelligence Unit (NFIU) regulations.

2. Know Your Customer (KYC)

We implement robust KYC procedures for all users including: (a) Customer Identification: Collection of government-issued photo ID (National ID, International Passport, Driver's License), proof of address (utility bill, bank statement dated within 3 months), and biometric verification where applicable; (b) Customer Due Diligence (CDD): Verification of identity information against independent sources, assessment of the customer's risk profile, and understanding the nature and purpose of the business relationship; (c) Enhanced Due Diligence (EDD): Additional verification measures for high-risk customers, including politically exposed persons (PEPs), customers from high-risk jurisdictions, and unusual transaction patterns; (d) Ongoing Monitoring: Continuous review of customer information and transaction activity to ensure consistency with our knowledge of the customer.

3. Transaction Monitoring

We employ sophisticated transaction monitoring systems to detect suspicious activities including: (a) automated monitoring of all transactions against predefined risk indicators; (b) real-time screening against international sanctions lists (UN, OFAC, EU, UK); (c) pattern analysis to identify structuring, layering, or other suspicious behaviors; (d) velocity checks to detect unusual transaction volumes or frequencies; (e) cross-referencing of transaction data with known typologies of money laundering and terrorist financing.

4. Suspicious Activity Reporting

When suspicious activity is identified, we: (a) file Suspicious Transaction Reports (STRs) with the Nigeria Financial Intelligence Unit (NFIU) within the prescribed timeframe; (b) file Currency Transaction Reports (CTRs) for transactions exceeding the prescribed threshold; (c) maintain detailed records of all reports filed; (d) ensure that no employee tips off a customer about a filed or pending STR. Our designated compliance officer oversees all reporting obligations.

5. Record Keeping

We maintain comprehensive records in accordance with regulatory requirements including: (a) customer identification and verification records for a minimum of five (5) years after the business relationship has ended; (b) transaction records for a minimum of five (5) years from the date of the transaction; (c) STR and CTR filing records indefinitely; (d) training records for all employees. All records are stored securely with appropriate access controls.

6. Employee Training

All employees receive comprehensive AML/CTF training including: (a) initial training upon hiring covering AML laws, regulations, and company policies; (b) annual refresher training on current trends, typologies, and regulatory updates; (c) role-specific training for employees in compliance, customer service, and operations; (d) documentation and testing to ensure comprehension and retention.

7. Sanctions Compliance

We screen all customers and transactions against applicable sanctions lists including: (a) United Nations Security Council sanctions lists; (b) US Office of Foreign Assets Control (OFAC) lists; (c) European Union sanctions lists; (d) UK HM Treasury sanctions lists; (e) Nigerian national sanctions designations. Matches result in immediate transaction blocking and reporting to the appropriate authorities.

8. Risk Assessment

We conduct regular risk assessments to identify and evaluate money laundering and terrorist financing risks including: (a) annual enterprise-wide risk assessments; (b) product and service risk evaluations; (c) geographic risk analysis; (d) customer segment risk profiling; (e) third-party and partner risk assessments. Risk assessment findings inform our control framework and resource allocation.

9. Compliance Officer

Our designated Chief Compliance Officer is responsible for: (a) overseeing the implementation of this AML policy; (b) ensuring compliance with all applicable laws and regulations; (c) reporting to the Board of Directors on AML matters; (d) liaising with regulatory authorities and law enforcement; (e) managing the filing of STRs and CTRs.

10. Contact

For questions about our AML policy or to report suspicious activity, contact:
Email: support@goosecard.cn
Address: S-07-03, Setia Triangle, Persiaran Kelicap, 11900 Bayan Lepas, Pulau Pinang, Malaysia