KYC Terms

Last updated: 12 January 2026 Status: Informational — Pre-Launch

⚠️ Important Notice

These Know Your Customer Terms (the “KYC Terms”) are provided for informational purposes only and describe a prospective identity verification framework.

At the time of publication:

No identity verification, KYC, AML, or biometric processing is conducted by ItisPay LLC.
No regulated onboarding is active through ItisPay.
These KYC Terms do not constitute the provision of regulated financial services.

These KYC Terms only apply if and when identity verification functionality is activated by a third-party platform in connection with licensed service providers and applicable regulatory approvals.

1. Role and Status of ItisPay

AIGEN LLC (“ItisPay”) is a technology provider that develops software infrastructure for third-party platforms and regulated financial institutions.

For the avoidance of doubt, ItisPay:

is not a bank, payment institution, electronic money institution, or virtual asset service provider;
does not hold itself out as providing regulated financial services;
does not independently perform identity verification, KYC, AML, or sanctions screening.

Any regulated activities, if enabled in the future, will be performed exclusively by licensed third-party service providers under their own regulatory obligations.

2. Conditional Applicability

These KYC Terms apply only if all of the following conditions are met:

The platform through which you access services (the “Platform”) enables identity verification functionality;
Such functionality is activated following regulatory onboarding; and
Identity verification is required under applicable law or the Platform’s compliance framework.

If identity verification is not enabled, these KYC Terms do not apply.

3. Prospective Personal Information Requirements

If identity verification is enabled in the future, users may be required to provide certain information for verification purposes, which may include, without limitation:

full legal name;
date of birth;
residential address;
government-issued identification documents;
selfie photo and/or video;
additional information reasonably required to satisfy regulatory obligations.

(collectively, “Personal Information”)

The exact scope of Personal Information will depend on:

the applicable Service Provider;
jurisdictional regulatory requirements; and
the Platform’s compliance obligations.

4. Third-Party Identity Verification Providers

Identity verification, if enabled, will be performed solely by licensed third-party identity verification providers (the “Service Providers”).

Service Providers may:

process Personal Information for identity verification and compliance purposes;
conduct KYC, AML, counter-terrorist financing, and fraud prevention checks;
provide verification results to the Platform and, where technically necessary, to ItisPay in a limited and purpose-bound manner.

All identity verification services will be governed by the separate terms, privacy policies, and regulatory disclosures of the applicable Service Providers.

5. Biometric Data (Conditional Disclosure)

If required by a Service Provider, identity verification may involve biometric data, such as facial images derived from selfie photos or videos (“Biometric Data”).

Biometric Data, if processed:

will be used solely for identity verification purposes;
will be processed by the applicable Service Provider in accordance with applicable law, including GDPR;
will not be stored or retained by ItisPay, unless required by law or regulatory obligation.

Prior to activation of any biometric processing, additional disclosures and safeguards may apply, including data protection impact assessments where required.

6. Data Retention

Data retention periods, if identity verification is enabled, will be determined by:

applicable legal and regulatory requirements;
the retention policies of the relevant Service Provider;
contractual obligations of the Platform.

ItisPay does not independently define statutory retention periods for KYC or biometric data.

7. Platform Responsibilities

You acknowledge that:

the Platform is responsible for determining whether identity verification is required;
the Platform controls how verification results are used within its services;
the Platform’s collection, use, and retention of Personal Information are governed by its own agreements and privacy policies.

8. User Representations

If identity verification is enabled, you represent and agree that:

all Personal Information provided is accurate, complete, and relates solely to you;
you will not submit information relating to another individual;
submission of false or misleading information may result in denial of access to services.

9. No Guarantee of Access

Successful identity verification, if conducted, does not guarantee access to any services. Access decisions may be based on regulatory, risk, or compliance considerations of the Platform or Service Provider.

10. Updates and Activation

These KYC Terms may be updated from time to time to reflect:

activation of identity verification functionality;
engagement of licensed Service Providers;
applicable legal or regulatory requirements.

Any materially updated version will be made available prior to mandatory identity verification.

11. Informational Nature

These KYC Terms are provided for transparency and informational purposes only and do not constitute an agreement to provide regulated services.