DIGITTPAY SOLUTIONS LLP

This Policy establishes a risk-based framework for setting, monitoring, reviewing and enforcing transaction and exposure limits for DIGITTPAY SOLUTIONS LLP's gift card, gift voucher and related digital commerce activities.

• Reduce exposure to fraud, misuse, operational errors and financial loss.
• Apply proportionate transaction and velocity controls.
• Define approval and override requirements.
• Identify unusual transaction patterns through monitoring.
• Protect customers, partners and Company funds.

This Policy applies to relevant customer, merchant, partner, gift card/voucher, purchase, issuance, redemption, refund, reversal, settlement and account activity processed through Company systems or relevant third-party platforms.

Transaction limits shall be determined using factors such as product characteristics, customer risk, transaction history, fraud indicators, voucher value, redemption behaviour, partner requirements, operational capacity and applicable contractual or legal requirements.

• Per-transaction limit
• Daily / weekly / monthly cumulative limit
• Account or customer-level exposure limit
• Gift card / voucher denomination or issuance limit
• Redemption limit
• Refund / reversal limit
• Velocity limit
• Partner / channel limit
• Temporary incident-based limit

Limits shall be documented in approved business or technical configurations. Changes to material limits shall be subject to appropriate risk assessment, approval and change-management controls.

The Company may monitor transaction count, value, frequency, device/account patterns, repeated failures, repeated redemptions and other indicators to identify abnormal activity.

• Control issuance and purchase exposure.
• Monitor repeated high-value purchases.
• Monitor rapid purchase-and-redemption patterns.
• Monitor multiple accounts or instruments associated with common activity where lawful and technically available.
• Apply redemption restrictions or temporary holds where fraud risk is identified.

Refunds and reversals may be subject to transaction, account or operational limits and appropriate verification to reduce refund abuse and unauthorised activity.

Transactions may be monitored through automated rules, thresholds, behavioural analytics, alerts, manual review or partner controls. Monitoring shall be proportionate to risk and system capability.

• Unusually high transaction value
• Rapid repeated transactions
• Multiple transactions just below configured thresholds
• High-frequency voucher redemption
• Repeated failed authentication or payment attempts
• Unusual refund or reversal activity
• Sudden change in customer behaviour
• Activity associated with known fraud indicators

Where risk controls identify material concerns, authorised systems or personnel may place transactions on hold, require enhanced verification, reduce limits or decline transactions, subject to applicable terms and partner requirements.

Material alerts may be reviewed by authorised Risk, Fraud, Operations or Compliance personnel. Review decisions shall be documented where appropriate.

Overrides shall be restricted to authorised personnel, supported by a legitimate business or customer-service reason, and recorded where material. Overrides shall not be used to bypass mandatory legal, security or partner controls.

Limit controls shall operate alongside the Fraud Prevention & Transaction Monitoring Policy and, where applicable, AML-CFT and KYC controls. A limit breach alone does not establish fraud or money laundering; additional assessment is required.

Controls shall be designed to reduce unauthorised use, fraud and excessive exposure while minimising unnecessary disruption to legitimate customers. Where a transaction is restricted, appropriate customer communication may be provided subject to security considerations.

Where banks, processors, payment networks, merchants or other partners impose transaction or exposure limits, the Company shall configure and operate within applicable contractual or network requirements.

Material limits shall, where practical, be enforced through system controls rather than relying solely on manual processes. Changes shall follow approved technology change-management procedures.

• Limit breaches
• Override volumes
• Declined or held transactions
• High-risk alerts
• Fraud losses and prevented losses
• Refund/reversal anomalies
• Customer complaints relating to limits
• Partner or network limit exceptions

Limits shall be reviewed periodically using transaction trends, fraud patterns, customer behaviour, operational capacity, partner requirements and loss experience. Material changes shall be approved through the appropriate governance process.

During significant fraud, cyber incidents or operational events, temporary restrictions may be applied to protect customers and Company assets. Such emergency controls shall be documented and reviewed after the event.

Limit configurations, approvals, overrides, monitoring results, material alerts and related decisions shall be retained according to applicable requirements and the Company's record-retention framework.

Relevant personnel shall be trained on applicable transaction limits, risk indicators, escalation procedures, override controls and customer-protection requirements.

Exceptions shall be documented, risk-assessed and approved by authorised management. Mandatory legal, regulatory, network, contractual or security requirements shall not be bypassed.

This Policy shall be reviewed at least annually and following material fraud events, significant product or partner changes, audit findings or changes in applicable requirements.