DIGITAL SERVICE DELIVERY & NON-APPLICABILITY POLICY

Effective Date: November 1, 2025

1. Preamble, Purpose & Policy Mandate

This Digital Service Delivery & Non-Applicability Policy ("Policy") articulates the Company’s official stance regarding service fulfillment, transaction characterization, and the non-existence of any physical shipping, logistics, or warehousing infrastructure in connection with the services provisioned by Expert Trade ("Company"). The Policy serves to provide unambiguous assurances to regulatory authorities, payment aggregators, acquiring banks, and Clients that the Company’s commercial operations are exclusively digital and intangible in nature.

2. Exclusive Digital Service Model — Definitive Declaration

2.1. Business Model Clarification

Expert Trade operates solely as a provider of business-to-business digital services, including but not limited to Verified Buyer Lead Sourcing, Export Platform Design & Development, Digital Branding & Marketing, and Market Intelligence reporting. All consideration received by the Company constitutes payment for digital services, intellectual property licensing, and professional labour; no transaction executed by the Company contemplates or effects the transfer of tangible goods.

2.2. Non-Applicability of Physical Commerce

Under no circumstances does Expert Trade sell, ship, consign, store, broker, or otherwise facilitate the freight, warehousing, or couriering of physical merchandise, industrial chemicals, controlled substances or any other regulated commodities. Any representation or inference to the contrary shall be deemed incorrect and non-binding.

3. Transaction Labeling & Payment Integrity

3.1. Transaction Descriptor Policy

The Company shall ensure that all charge descriptors, invoice line items and gateway metadata accurately reflect the digital nature of the transaction (e.g., "Subscription — Verified Leads", "Digital Service Fee", "Website Creation — Annual"). No transaction processed through the Company’s merchant accounts shall include descriptors such as "Shipping", "Freight", "Courier", or comparable logistics nomenclature.

3.2. Gateway & Acquirer Compliance

All payments are processed through PCI-DSS compliant gateway partners and RBI-authorized acquiring banks. The Company will furnish acquiring partners with truthful transaction metadata, contract copies, client onboarding documentation, and any additional information required for AML, KYC or merchant risk assessment.

4. Digital Delivery Protocols & Service Channels

4.1. Delivery Mechanisms

  • Lead Data: Delivered through secure Client Dashboards, encrypted export files, or authenticated API endpoints; access is controlled via unique credentials and two-factor authentication where applicable.
  • Platform & Site Deliverables: Access credentials, repository privileges (Git/VCS), and hosting account handovers are provisioned electronically; physical media or shipments are never used.
  • Consultancy & Reporting: Delivered as downloadable PDFs, encrypted attachments, or via scheduled secure video conferences and archived in the Client Success Dashboard.

4.2. Service Activation & Confirmation

Service activation occurs upon successful payment settlement and the completion of applicable KYC/Onboarding checks. The Company will issue an electronic Service Activation Notice that documents the service start date and the Service Delivery Timeline (SDT). Such notices constitute prima facie evidence of provisioning and delivery commencement.

5. Auditability, Record Retention & Disclosure

5.1. Transaction & Delivery Audit Logs

The Company will maintain auditable logs for all financial transactions, access grants, file provisioning, and service activations. Audit trails include timestamps, user identifiers, IP addresses, and digital proof of delivery (e.g., download receipts). These records are retained in accordance with regulatory obligations and the Company’s Data Retention schedule.

5.2. Retention Period & Regulatory Disclosure

The Company retains transaction and onboarding records for a minimum period required by applicable law and by its acquirers (typically not less than seven (7) years), and may disclose such records to regulatory authorities, acquirers, or law enforcement upon lawful request or in the case of a bona fide compliance investigation.

6. No Shipping Charges & Billing Prohibitions

Given the Company’s 100% digital delivery model, any invoice or payment record indicating a discrete "Shipping" or "Freight" charge is invalid and shall not be reconciled by the Company. The Company will not accept or remit payments labeled as logistics or cargo charges through its merchant accounts.

7. Security, Confidentiality & Data Protection

7.1. Data Security Standards

Expert Trade implements industry-standard technical and organisational measures to protect Client data, including encryption at rest and in transit, role-based access control, and regular security audits. Where personal data is processed, the Company endeavors to comply with applicable data protection laws (including, where relevant, GDPR, IT Act provisions and associated rules).

7.2. Confidentiality & IP

All proprietary datasets, creative deliverables, and strategic recommendations provided to Clients are treated as confidential and are subject to the confidentiality and intellectual property provisions within the Master Terms of Service.

8. Remedies, Enforcement & Non-Compliance

Any Client attempt to utilize Company infrastructure for the sale, shipment or facilitation of physical goods or regulated materials shall constitute a material breach. In such circumstances, the Company reserves the right to immediately suspend services, withhold funds subject to acquirer instructions, and report the conduct to relevant banking and regulatory authorities. The Client shall remain liable for all fees and costs incurred up to suspension.

9. Liaison with Payment Gateways & Acquirers

The Company cooperates with payment gateways, acquiring banks, and other third-party processors in order to ensure accurate merchant MCC classification and to respond to compliance inquiries. The Company may be required to provide documentation or to take remedial steps (including transaction reversals or temporary holds) when requested by an acquirer.

10. Contact, Grievance & Effective Date

For any transaction queries, compliance clarifications, or data provisioning confirmations, Clients should contact our Compliance & Client Success desk at support@thexpertrade.cloud. This Policy is effective as of November 1, 2025.