Terms & Conditions

Purpose of the Document

The purpose of this document is to define the contractual relationship between the User and IMPRONICS regarding the use of the IMPROPAY front-end interface. It establishes the legal boundaries for liability related to data transmission, defines the governing law as Dubai/UAE Federal law, and sets forth the user's obligations when interacting with the technology stack.

1. INTRODUCTION AND ACCEPTANCE

• 1.1. These Terms of Service (“Terms”) constitute a legally binding agreement between you, individual customer (“User”, “you”, or “your”), and Impronics Digitech L.L.C-FZ (“Impronics”, “we”, “us”, or “our”), a company established in the United Arab Emirates.
• 1.2. These Terms govern your access to and use of the front-end user interface, mobile application provided by Impronics (the “Impropay”) which facilitates access to remittance services provided by Lulu International Exchange L.L.C (“Lulu”).
• 1.3. By accessing or using the impropay, you acknowledge that you have read, understood, and agree to be bound by these Terms & Services. If you do not agree to these Terms, you must immediately reject using the Partner Application.
• 1.4. You acknowledge that Impronics is a technology provider and not a financial institution. All regulated financial services, including but not limited to remittance, currency exchange, and payment processing, are provided exclusively by Lulu.

2. DEFINITIONS

• 2.1. “AML/CFT Laws” means the UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations, and its executive regulations.
• 2.2. “CBUAE” means the Central Bank of the United Arab Emirates.
• 2.3. “Customer Data” means any personal data, identification documents, or financial information provided by the User through the Partner Application.
• 2.4. “Lulu” means Lulu International Exchange L.L.C, a limited liability company licensed by the CBUAE to conduct exchange and remittance business.
• 2.5. “Impropay” means the digital interface, UI/UX, and technology platform developed and maintained by Impronics.
• 2.6. “PDPL” means UAE Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data.
• 2.7. “Remittance Services” means the regulated financial activity of transferring funds, currency conversion, and settlement performed solely by Lulu.

3. ROLE OF IMPRONICS (TECHNOLOGY PROVIDER ONLY)

• 3.1. Impronics acts strictly as a technology partner for Lulu.
• 3.2. The scope of Impronics’ services is limited to:
  • 3.2.1. Providing the front-end UI/UX for Impropay;
  • 3.2.2. Facilitating the minimal capture and secure transmission of Customer Data to Lulu;
  • 3.2.3. Providing system integration and Tier-1 technical support related to UI/UX issues; and
  • 3.2.4. Maintaining the SDK/API integration with Lulu’s backend systems.
• 3.3. Impronics does not:
  • 3.3.1. Hold, handle, or process any User funds;
  • 3.3.2. Perform KYC, eKYC, AML, or sanctions screening;
  • 3.3.3. Validate or verify identity documents;
  • 3.3.4. Approve or reject User registrations or transactions;
  • 3.3.5. Provide financial advice or determine regulatory requirements; or
  • 3.3.6. Access Lulu’s backend financial systems.

4. ROLE OF LULU (LICENSED REMITTANCE PROVIDER)

• 4.1. Lulu is the sole provider of Remittance Services. Lulu is a CBUAE-licensed entity and is exclusively responsible for:
  • 4.1.1. Validation and verification of Emirates ID and other identity documents;
  • 4.1.2. Performing all KYC, eKYC, AML, CFT, and sanctions screening;
  • 4.1.3. Transaction processing, FX conversion, and settlement;
  • 4.1.4. Regulatory reporting to the CBUAE and other authorities; and
  • 4.1.5. Compliance with all UAE financial regulations.
• 4.2. All financial transactions are subject to Lulu’s internal compliance policies and the laws of the UAE. Lulu reserves the right to reject any User or transaction at its sole discretion without liability to Impronics.

5. USER ELIGIBILITY

• 5.1. The Impropay is intended for use by individual customers only. Corporate or institutional use is strictly prohibited.
• 5.2. To be eligible to use the Impropay, you must:
  • 5.2.1. Be at least 18 years of age;
  • 5.2.2. Possess the legal capacity to enter into a binding contract;
  • 5.2.3. Be a resident of the United Arab Emirates with a valid Emirates ID; and
  • 5.2.4. Not be subject to any economic or trade sanctions under UAE law or international law applicable in the UAE.

6. CUSTOMER ONBOARDING DISCLAIMER

• 6.1. You acknowledge that the submission of your data through Impropay does not guarantee the opening of an account or the execution of a transaction.
• 6.2. Onboarding is subject to Lulu’s successful completion of eKYC and AML checks. Impronics has no influence over Lulu’s decision to approve or reject your application.
• 6.3. You agree to provide accurate, current, and complete information. Providing false or misleading information may result in the termination of your access and potential legal action under the UAE Cybercrime Law and AML/CFT Laws.

7. PROHIBITED ACTIVITIES

• 7.1. You agree not to:
  • 7.1.1. Use Impropay application for any fraudulent or illegal purpose;
  • 7.1.2. Attempt to bypass any security measures or API restrictions;
  • 7.1.3. Reverse engineer, decompile, or disassemble any part of the Impropay Application;
  • 7.1.4. Use the Impropay Application to transmit any viruses, malware, or harmful code;
  • 7.1.5. Impersonate any person or entity or misrepresent your affiliation with any person or entity; or
  • 7.1.6. Use the Impropay Application in a manner that violates the UAE Cybercrime Law (Federal Decree-Law No. 34 of 2021).

8. DATA PROTECTION AND PDPL COMPLIANCE

• 8.1. Impronics is committed to protecting the privacy in accordance with the PDPL.
• 8.2. Impronics acts as a "Processor" on behalf of Lulu for the limited purpose of capturing and transmitting Customer Data. Lulu acts as the "Controller" of the data including the personal data for the purpose of providing Remittance Services.
• 8.3. Impronics stores and retains, the minimal User Data. And transmit successfully to Lulu.
• 8.4. By using the Impropay Application, you provide your express consent for the collection and transmission of your data to Lulu and its authorized third-party service providers for the purpose of identity verification and transaction processing.

9. CUSTOMER DATA HANDLING (FRONT-END ONLY)

• 9.1. The Impropay Application serves as a secure conduit for ID&V (Identity and Verification) data capture.
• 9.2. All identity verification, including Emirates ID checks and Electronic Facial Recognition (EFR), is performed by Lulu or its designated regulated partners.
• 9.3. Impronics employs industry-standard encryption protocols to ensure the secure transmission of data from the Impropay Application to Lulu’s backend system.

10. NO FINANCIAL SERVICES DISCLAIMER

• IMPRONICS IS NOT A BANK, AN EXCHANGE HOUSE, OR A STORED VALUE FACILITY.
• IMPRONICS DOES NOT PROVIDE FINANCIAL ADVICE, INVESTMENT ADVICE, OR TAX ADVICE.
• ANY INFORMATION PROVIDED WITHIN THE IMPROPAY APPLICATION REGARDING EXCHANGE RATES OR TRANSACTION FEES IS PROVIDED FOR INFORMATIONAL PURPOSES ONLY AND IS SOURCED DIRECTLY FROM LULU. THE FINAL RATE APPLICABLE TO YOUR TRANSACTION IS DETERMINED EXCLUSIVELY BY LULU AT THE TIME OF EXECUTION.

11. API DEPENDENCY AND THIRD-PARTY SERVICES

• 11.1. The functionality of the Impropay Application is dependent on APIs and WebViews provided by Lulu and other third-party service providers.
• 11.2. Impronics shall not be liable for any service interruptions, delays, or failures caused by Lulu’s backend systems, API downtime, or issues with third-party telecommunications providers.

12. LIMITATION OF LIABILITY

• 12.1. To the maximum extent permitted by UAE law, Impronics shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, or funds, arising out of or related to:
  • 12.1.1. Your use or inability to use the Impropay Application;
  • 12.1.2. Any transaction rejected, delayed, or cancelled by Lulu;
  • 12.1.3. Any error in the Remittance Services provided by Lulu;
  • 12.1.4. Any unauthorized access to or use of Lulu’s backend systems; or
  • 12.1.5. Any regulatory action taken by the CBUAE or other authorities.

13. SUSPENSION AND TERMINATION

• 13.1. Impronics may suspend or terminate your access to the Partner Application immediately and without notice if:
  • 13.1.1. You breach these Terms;
  • 13.1.2. We suspect fraudulent or illegal activity;
  • 13.1.3. We are required to do so by Lulu or any regulatory authority; or
  • 13.1.4. The agreement between Impronics and Lulu is terminated.
• 13.2. Upon termination, your right to use the Impropay Application will cease immediately. Termination shall not affect the validity of any transactions already processed by Lulu.

14. COMPLIANCE WITH UAE AML, SANCTIONS, AND CYBERCRIME LAWS

• 14.1. You agree to comply with all applicable UAE laws, including but not limited to AML/CFT Laws and the UAE Cybercrime Law.
• 14.2. You acknowledge that Lulu is required to report suspicious transactions to the UAE Financial Intelligence Unit (FIU).
• 14.3. Any attempt to use the Impropay Application for money laundering, terrorist financing, or to circumvent UAE sanctions will result in immediate termination and reporting to the relevant authorities.

15. INTELLECTUAL PROPERTY

• 15.1. All intellectual property rights in the Impropay Application, including but not limited to software, code, UI/UX design, logos, and trademarks, are owned by or licensed to Impronics.
• 15.2. You are granted a limited, non-exclusive, non-transferable, and revocable license to use the Impropay Application for your personal, non-commercial use in accordance with these Terms.

16. GOVERNING LAW AND JURISDICTION

• 16.1. These Terms shall be governed by and construed in accordance with the laws of the Emirate of Dubai and the federal laws of the United Arab Emirates applicable therein.
• 16.2. Any dispute, difference, controversy, or claim arising out of or in connection with these Terms, including any question regarding its existence, validity, interpretation, performance, or termination, shall be subject to the exclusive jurisdiction of the Dubai Courts (Onshore).

17. SEVERABILITY

• 17.1. If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect.

18. FORCE MAJEURE

• 18.1. Impronics shall not be liable for any failure or delay in performing its obligations under these Terms due to circumstances beyond its reasonable control, including but not limited to acts of God, war, terrorism, pandemic, strikes, or failure of public utilities or the internet.

19. NOTICES

• 19.1. All notices to Impronics shall be sent in writing to the contact information provided below. Notices to the User may be sent via the Partner Application.

20. CONTACT INFORMATION