Zil Money is a financial technology company, not a bank or an FDIC member. Zil Money offers banking services through partnership with FDIC member banks Silicon Valley Bank, Texas National Bank, and East-West Bank.

CAN-SPAM Policies & Procedures Manual

POLICY STATEMENT:

At Zil Money Corporation (“Zil Money” or the “Company”), we are committed to maintaining the highest standards of regulatory compliance and upholding the integrity of our business practices. This “CAN-SPAM Policies & Procedures Manual” (the “Manual”) serves as a comprehensive guide outlining our commitment to complying with the CAN-SPAM Act and associated regulations.

The primary purpose of this Manual is to establish clear policies and procedures governing our email marketing practices, specifically the opt-in/out process, in strict accordance with CAN-SPAM requirements. As a leading fintech company providing B2B payment processing services, we recognize the significance of fostering a secure and transparent environment for our customers.

This Manual delineates the scope of our CAN-SPAM compliance efforts, encompassing all relevant aspects necessary for legal and ethical email marketing practices. By adhering to international best practices and industry standards, we demonstrate our dedication to maintaining trustworthy relationships with our customers, regulators, and banking partners.

All Zil Money personnel involved in email marketing and communication activities are expected to follow the principles set forth in this Manual, which forms the foundation of our CAN-SPAM compliance program. We prioritize the security of our services and strive to protect recipients from deceptive or misleading messages.

As a policy document, this Manual will undergo periodic review and updates to align with changes in laws and industry standards. Our commitment to accountability and continuous improvement reinforces our position as a trusted partner in the world of modern banking and payment processing.

By adhering to the policies outlined in this Manual, we aim to enhance customer trust, safeguard data privacy, and preserve the reputation of our valued partners. At Zil Money, we remain steadfast in our commitment to regulatory compliance and ethical business practices, as we continue to provide innovative and reliable financial services.

CAN-SPAM OVERVIEW:

The CAN-SPAM Policies & Procedures Manual provides a comprehensive understanding of the CAN-SPAM Act and its significance in governing email marketing practices. This section serves as an overview of the Act, outlining its key requirements and principles while emphasizing the consequences of non-compliance.

1. Understanding the CAN-SPAM Act:

The CAN-SPAM Act, enacted in 2003, stands for “Controlling the Assault of Non-Solicited Pornography And Marketing.” It is a federal law in the United States that regulates commercial email messages. The Manual elucidates the Act’s purpose, scope, and how it affects Zil Money’s email marketing practices. By comprehending the Act’s intricacies, we reinforce our commitment to complying with its provisions.

2. Key Requirements and Principles:

In this section, we outline the essential elements and core principles of the CAN-SPAM Act. These key requirements encompass providing accurate header information, truthful subject lines, proper identification of advertisements, inclusion of a physical address, and clear instructions for recipients to opt-out from receiving future emails. By incorporating these principles into our email marketing practices, we ensure transparency and trustworthiness in our communications.

3. Consequences of Non-Compliance:

The Manual addresses the potential consequences of non-compliance with the CAN-SPAM Act. These consequences may include significant financial penalties and reputational damage to Zil Money. By emphasizing the importance of adhering to the Act’s provisions, we underscore the necessity of maintaining a strong compliance framework to mitigate risks and safeguard our business reputation.

By incorporating the CAN-SPAM Act’s principles and requirements into our policies and procedures, we demonstrate our commitment to maintaining lawful and ethical email marketing practices. This section serves as a fundamental overview, laying the groundwork for the comprehensive policies and procedures that follow in this Manual. Our dedication to adhering to the CAN-SPAM Act and industry-wide best practices underscores our commitment to customer trust, regulatory compliance, and ethical business conduct.

REGULATORY COMPLIANCE FRAMEWORK:

Zil Money upholds a robust regulatory compliance framework to ensure adherence to international best standards and industry-applicable regulations. This section of the Manual outlines the Company’s commitment to maintaining a comprehensive regulatory compliance program, encompassing all relevant aspects of the framework.

1. International Best Standards and Industry Applicable Regulations:

Zil Money places paramount importance on aligning its operations with international best standards and industry-applicable regulations. We recognize that the landscape of regulatory requirements is continually evolving, and staying abreast of these changes is crucial. This section highlights our dedication to benchmarking our compliance efforts against recognized global best practices and relevant regulations in the fintech and payment processing industries.

By identifying and incorporating international best standards and industry-specific regulations, we proactively ensure that our CAN-SPAM compliance program remains robust and in line with current regulatory expectations. This includes leveraging guidance from authoritative bodies and industry associations, fostering a culture of compliance that prioritizes the protection of customer data and privacy.

2. Compliance Responsibilities and Accountability:

The success of our regulatory compliance framework hinges on clear responsibilities and accountability throughout the organization. This section outlines the roles and responsibilities of key personnel involved in the Company’s email marketing and communication activities. It establishes a system of checks and balances to ensure that all compliance measures are effectively implemented and monitored.

Zil Money fosters a culture of accountability, where compliance is a shared responsibility across the organization. Team members understand their role in upholding the principles of the CAN-SPAM Act and related regulations through ongoing training and awareness programs. The company establishes reporting channels to address compliance concerns, promptly identifying and remediating any issues within its comprehensive compliance framework. By embedding a robust regulatory compliance framework, Zil Money demonstrates its commitment to ethical conduct, customer protection, and maintaining a trusted position in the fintech industry. This commitment remains steadfast as the company adapts to changing regulatory landscapes, guiding its pursuit of excellence and customer-centric services.

OPT-IN/OPT-OUT PROCESS ADMINISTRATION:

The Opt-In/Opt-Out Process Administration section outlines Zil Money’s approach to managing recipient preferences in compliance with relevant laws, rules, and regulations. This fundamental guide emphasizes the definitions of opt-in and opt-out, along with clear procedures for obtaining consent and respecting recipients’ choices. Our commitment to transparency and accountability ensures recipients have control over their communication preferences, building trusting relationships with our valued customers.

1. Opt-In and Opt-Out Definitions:

At Zil Money, we adhere to clear and concise definitions of opt-in and opt-out processes in line with relevant laws, rules, and regulations. An “opt-in” signifies a recipient’s explicit consent to receive commercial email communications from us, demonstrating their interest in our services. Conversely, an “opt-out” denotes the recipient’s choice to unsubscribe from our email communications, thereby discontinuing future marketing messages.

2. Opt-In Procedures:

Our opt-in procedures are designed to provide recipients with a transparent and straightforward process for expressing their consent to receive marketing emails. Zil Money ensures that opt-in requests are obtained in a compliant manner, such as through explicit checkbox consent or double opt-in verification, in accordance with the applicable regulations. The opt-in process is designed to be user-friendly and easily accessible, empowering recipients to control their communication preferences.

3. Opt-Out Procedures:

To respect recipients’ choices and preferences, we implement efficient and immediate opt-out procedures. Our opt-out process is clearly stated in all marketing communications, providing recipients with easy-to-follow instructions to unsubscribe from future emails. Zil Money promptly processes opt-out requests, ensuring recipients’ preferences are respected without delay.

4. Frequency and Timing of Communications:

Zil Money is committed to responsibly managing the frequency and timing of our marketing communications. We adhere to best practices to prevent excessive or intrusive email outreach. Our communication frequency is determined with due consideration to the recipient’s preferences and the relevance of the content being shared. We respect recipients’ time and privacy by sending communications at appropriate intervals and avoiding sending emails outside of normal business hours.

By administering our opt-in/opt-out processes meticulously, Zil Money maintains compliance with relevant regulations and ensures transparency and accountability in our email marketing practices. This section serves as a fundamental guide for our personnel, fostering a culture of respecting recipients’ preferences and building trusting relationships with our valued customers.

ENSURING TRUTHFUL AND ACCURATE INFORMATION:

Zil Money upholds the highest standards of integrity and transparency in its email communications to ensure truthful and accurate information is conveyed to recipients. This section of the Manual encompasses essential aspects of maintaining compliance with relevant laws, rules, and regulations.

1. Use of False or Misleading Header Information:

Zil Money strictly prohibits the use of false or misleading header information in its email communications. The sender’s name, domain, and routing information will always accurately reflect the Company’s identity. By ensuring transparency in the header information, we uphold recipients’ trust and comply with CAN-SPAM regulations.

2. Use of Deceptive Subject Lines:

We are committed to using subject lines that precisely reflect the content of our emails. Deceptive subject lines are strictly prohibited, as they undermine recipients’ expectations and may mislead them into opening the message. Zil Money ensures subject lines are accurate, relevant, and aligned with the email’s purpose, thereby fostering a trustworthy sender-recipient relationship.

3. Identifying Messages as Advertisements:

To enhance transparency, all marketing emails sent by Zil Money will be clearly identified as advertisements. We ensure that recipients can easily recognize promotional content and differentiate it from non-commercial or transactional messages. By prominently labeling advertisements, we demonstrate our commitment to open communication and compliance with relevant regulations.

4. Displaying Physical Address or PO Box in Messages:

Each email communication from Zil Money includes a physical address or PO Box, in accordance with CAN-SPAM requirements. By providing a valid postal address, we afford recipients the opportunity to contact us or request information regarding our business. This practice enhances trust and demonstrates our compliance with the Act.

Ensuring truthful and accurate information in our email communications is a cornerstone of our commitment to regulatory compliance and ethical business practices. By strictly adhering to these principles, Zil Money maintains its reputation as a reliable and trustworthy partner in the fintech industry. Our dedication to compliance instills confidence in our recipients and reinforces our position as a leader in responsible email marketing practices.

OPT-OUT MECHANISM:

Zil Money is committed to providing recipients with a seamless and user-friendly opt-out mechanism in strict compliance with relevant laws, rules, and regulations. This section of the Manual outlines our diligent approach to ensuring recipients’ control over their email preferences.

1. Providing Clear and Prominent Opt-Out Instructions:

In all marketing communications, Zil Money includes clear and prominent opt-out instructions, enabling recipients to easily unsubscribe from future emails. These instructions are concise, user-friendly, and accessible, ensuring that recipients can exercise their choice to opt-out without difficulty.

2. Honoring Opt-Out Requests Promptly:

Upon receiving an opt-out request, Zil Money promptly honors the recipient’s choice to unsubscribe from our email communications. Our compliance team diligently monitors opt-out requests and ensures that recipients are removed from the relevant email lists without delay. We respect recipients’ preferences and strive to promptly implement their choices.

3. Unsubscribing and Removal Process:

The process of unsubscribing from Zil Money’s marketing emails is straightforward and efficient. Recipients can utilize the opt-out mechanism provided in each communication or contact our customer support for assistance. Once an opt-out request is received, the recipient’s email address is promptly removed from our marketing lists, ensuring that no further promotional messages are sent.

By establishing a robust opt-out mechanism, Zil Money demonstrates its commitment to transparency and recipient empowerment. Our dedication to promptly honoring opt-out requests reflects our respect for recipients’ preferences and their right to control their email communication. Through this section, we ensure compliance with relevant regulations while fostering trust with our valued recipients.

THIRD-PARTY SERVICE PROVIDERS:

Zil Money diligently manages its relationships with third-party service providers in compliance with relevant laws, rules, and regulations. This section of the Manual outlines our approach to vendor selection, due diligence, and ongoing compliance monitoring.

1. Vendor Selection and Due Diligence:

Zil Money conducts a comprehensive vendor selection process, ensuring that third-party service providers align with our commitment to regulatory compliance and ethical business practices. During vendor onboarding, we perform thorough due diligence to assess their capabilities, reputation, and compliance track record. Our stringent selection criteria enable us to partner with reputable vendors that share our commitment to maintaining the highest standards.

2. Monitoring Compliance of Third-Party Service Providers:

Once onboarded, Zil Money continuously monitors the compliance practices of our third-party service providers. We establish clear contractual obligations related to regulatory compliance and routinely evaluate their adherence to these requirements. Regular compliance reviews and audits help ensure that our vendors maintain alignment with relevant laws and industry standards.

3. Handling Non-Compliance Issues with Vendors:

In the event of non-compliance issues with a vendor, Zil Money takes prompt and decisive action to address the matter. We work collaboratively with the vendor to rectify any non-compliant practices and enforce corrective measures. If necessary, termination of the vendor relationship is considered to protect the integrity of our compliance program and safeguard customer interests.

By establishing a framework for managing third-party service providers, Zil Money demonstrates its commitment to maintaining a compliant ecosystem. This section ensures that our vendors uphold the same high standards of regulatory adherence and ethical conduct as Zil Money, fostering a network of trusted partners dedicated to safeguarding customer interests and maintaining a responsible email marketing environment.

RECORDKEEPING AND REPORTING:

Zil Money maintains robust recordkeeping and reporting practices to ensure compliance with relevant laws, rules, and regulations. This section of the Manual outlines our diligent approach to preserving accurate and comprehensive records, conducting internal audits, and fulfilling reporting and documentation requirements.

1. Maintaining Records of Opt-In/Opt-Out Requests:

Zil Money diligently maintains records of opt-in and opt-out requests received from recipients. These records include timestamps, opt-out methods, and any additional information necessary for compliance verification. By preserving accurate and up-to-date records, we demonstrate our commitment to respecting recipients’ preferences and complying with the CAN-SPAM Act.

2. Internal Audits and Assessments:

Regular internal audits and assessments are integral to our compliance program. Zil Money conducts periodic reviews to evaluate the effectiveness of our email marketing practices and ensure alignment with relevant regulations. These assessments identify potential areas for improvement and reinforce our commitment to continuous compliance enhancement.

3. Reporting and Documentation Requirements:

Zil Money fulfills all reporting and documentation requirements mandated by applicable laws and regulatory bodies. We maintain comprehensive documentation of our compliance activities, including policies, procedures, training records, and audit findings. Our reporting processes ensure timely and accurate submissions, reinforcing our transparency and accountability to regulatory authorities.

By maintaining diligent recordkeeping and reporting practices, Zil Money demonstrates its commitment to regulatory compliance and ethical business conduct. This section of the Manual serves as a guide for our personnel, underscoring the importance of meticulous documentation and reporting to support our compliance efforts. Through these practices, we uphold the trust of our customers, partners, and regulatory authorities, reinforcing our position as a responsible leader in the fintech industry.

TRAINING AND AWARENESS:

Zil Money prioritizes training and awareness initiatives to ensure its employees stay well-informed and compliant with CAN-SPAM regulations. This section of the Manual outlines our comprehensive approach to employee training and periodic awareness programs.

1. Employee Training on CAN-SPAM Compliance:

Zil Money conducts regular training sessions to educate employees on the intricacies of CAN-SPAM compliance. These training sessions cover essential topics such as opt-in/opt-out procedures, truthful information dissemination, identifying advertisements, and displaying physical addresses in messages. By providing our personnel with in-depth knowledge of CAN-SPAM requirements, we empower them to play an active role in maintaining regulatory compliance.

2. Periodic Awareness Programs and Updates:

To ensure ongoing compliance, Zil Money conducts periodic awareness programs and updates on relevant regulatory developments. These programs inform employees of any changes to CAN-SPAM laws, rules, and industry best practices. By staying abreast of evolving regulations, our workforce remains equipped to uphold compliance standards and implement changes effectively.

Through training and awareness initiatives, Zil Money fosters a culture of compliance and accountability. Employees understand their role in maintaining regulatory adherence and are encouraged to report any concerns or potential compliance issues promptly. By prioritizing continuous education, Zil Money reinforces its commitment to responsible email marketing practices, safeguarding customer interests and reinforcing its position as a trusted leader in the fintech industry.

ENFORCEMENT AND REMEDIATION:

Zil Money maintains a strong commitment to enforcing CAN-SPAM compliance and promptly addressing any instances of violations or non-compliance. This section of the Manual outlines our approach to handling such incidents and implementing remedial actions and corrective measures.

1. Handling Violations and Non-Compliance Incidents:

In the event of a violation or non-compliance incident, Zil Money takes immediate and decisive action. Our compliance team thoroughly investigates the matter to determine the root cause and extent of the issue. We closely collaborate with relevant stakeholders, including the responsible parties and third-party service providers, to understand the factors contributing to the incident.

2. Remedial Actions and Corrective Measures:

Once the investigation is complete, Zil Money implements appropriate remedial actions and corrective measures. These actions are designed to rectify the non-compliance, prevent its recurrence, and mitigate any potential harm to recipients or the company’s reputation. Remedial measures may include updating policies and procedures, enhancing employee training, implementing additional safeguards, or terminating vendor relationships if necessary.

By promptly addressing violations and non-compliance incidents, Zil Money demonstrates its commitment to maintaining the highest standards of regulatory adherence and ethical conduct. Our proactive enforcement approach ensures that our CAN-SPAM compliance program remains effective and responsive to changing circumstances. Through this section, we emphasize our dedication to continuous improvement and accountability, safeguarding the interests of our customers, partners, and stakeholders, and reinforcing our position as a trusted leader in the fintech industry.

SAMPLE OPT-IN LANGUAGE:

Thank you for subscribing to Zil Money’s exclusive email updates! By opting in, you agree to receive occasional marketing communications, promotions, and updates related to our cutting-edge financial and banking services products. Rest assured, we value your privacy and will only send you relevant and valuable information. You can opt-out at any time by clicking the “Unsubscribe” link provided in our emails. Your choice matters to us, and we are committed to providing a seamless and secure email experience. Welcome to our trusted community!

SAMPLE OPT-OUT LANGUAGE:

We’re sorry to see you go! If you no longer wish to receive marketing emails and updates from Zil Money, simply click the “Unsubscribe” link provided below. We understand that preferences change, and we respect your decision. Opting out will remove your email address from our marketing list, and you won’t receive any further promotional communications. Thank you for being a part of our journey, and we hope you’ll consider reconnecting with us in the future. If you have any feedback or questions, feel free to contact our support team at support@zilmoney.com. Goodbye for now!

DEFINITIONS AND GLOSSARY:

This section provides a comprehensive list of all significant terms relevant to the CAN-SPAM Policies & Procedures Manual. It serves as a definitive glossary to ensure a clear understanding of key terminology used throughout the manual. By defining essential terms, we aim to facilitate better comprehension and consistent interpretation of our email marketing practices and regulatory compliance requirements.

CAN-SPAM Act: The Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 is a federal law in the United States that sets forth rules and regulations for commercial email communications.
Opt-In: An explicit and affirmative action taken by a recipient to grant consent for receiving commercial email communications from Zil Money.
Opt-Out: The process by which a recipient indicates their preference to unsubscribe from Zil Money’s marketing email communications.
Header Information: The information in the email’s “From,” “To,” “Reply-To,” and routing information fields that accurately identifies the sender and facilitates email transmission.
Deceptive Subject Line: A subject line that misrepresents the content or purpose of the email message, potentially misleading recipients.
Advertisements: Commercial messages promoting Zil Money’s products, services, or business interests.
Physical Address: The valid physical mailing address or PO Box of Zil Money that is included in all marketing email communications.
Third-Party Service Providers: External vendors or partners engaged by Zil Money to assist with email marketing or related services.
Compliance Program: Zil Money’s comprehensive framework of policies, procedures, and practices designed to ensure adherence to CAN-SPAM regulations and industry best practices.
Recordkeeping: The practice of maintaining accurate and detailed records of opt-in/opt-out requests, compliance activities, and audit findings.
Remedial Actions: Corrective measures and actions taken by Zil Money in response to non-compliance incidents to rectify and prevent recurrence.

This glossary clarifies the meanings of significant terms used in this Manual, promoting a shared understanding among Zil Money personnel and stakeholders. Clear definitions contribute to effective regulatory compliance and reinforce our commitment to transparent and responsible email marketing practices.

WRAP-UP AND COMMITMENT:

In closing, this comprehensive CAN-SPAM Policies & Procedures Manual reflects Zil Money’s unwavering commitment to maintaining the highest standards of ethical conduct and regulatory compliance in our email marketing practices. By adhering to the relevant laws, rules, and regulations, including the CAN-SPAM Act and international best practices, we prioritize the security, privacy, and preferences of our recipients. This manual serves as a guiding framework for our employees, emphasizing the importance of transparency, accountability, and continuous improvement in our email communication efforts. We remain dedicated to fostering a culture of compliance, ensuring the responsible dissemination of information, and preserving the trust and confidence of our valued customers, partners, and stakeholders. As we embark on our journey towards excellence in the fintech industry, this manual reinforces our promise to uphold ethical email marketing practices and remain a trusted leader in the realm of modern banking and payment processing.

Effective as of July 19, 2023.

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SABEER NELLIPARAMBAN

CEO