Sanctions and Restricted Jurisdictions Policy

KAINET WAVE LTD

A private company limited by shares, incorporated in England and Wales.

Company number: 17180527

Registered office: Flat 30, Kew Court, Richmond Road, Kingston upon Thames, England, KT2 5BF, United Kingdom

Website: https://farvia.online

Support email: support@farvia.online

Complaints email: complaints@farvia.online

Legal notices and compliance contact: legal@farvia.online

Customer support phone: Pending / being set up

WhatsApp support: Pending / being set up

Complaints web form: https://farvia.online/complaints

In this Policy, “Kainet”, “Kainet Wave”, “we”, “us” and “our” mean KAINET WAVE LTD.

KAINET™ is used as a trade mark of KAINET WAVE LTD. A UK trade mark application for the word mark KAINET has been filed. Until registration is completed, the mark should be treated as a pending trade mark application and not as a registered trade mark.

KAINET™ is a prepaid app-based international calling service for consumers. Customers purchase calling credit directly from KAINET WAVE LTD and use the Kainet app to place ordinary person-to-person international voice calls to saved contacts in supported destinations. The service is designed as a saved-contact click-to-call international calling service.

Kainet does not currently provide VPN access services, internet access services, broadband services, general connectivity services, inbound customer telephone numbers, UK telephone numbers for customers, number porting, a replacement mobile phone service, a replacement landline service, enterprise PBX services to customers, call-centre services to customers, wholesale telecom resale by customers, money transfer, remittance, customer wallets, e-money, cash-equivalent stored value, telecom equipment, interception technology, monitoring technology, surveillance technology, restricted network technology, restricted technical assistance, or a public emergency calling service.

Kainet operates a consumer-facing international calling service and must manage legal, sanctions, payment, banking, card network, telecom supplier, app platform, and operational risk. The purpose of this Policy is to make clear that Kainet does not provide services, accept payments, make payouts, or support usage where doing so would breach sanctions, restricted-jurisdiction rules, payment processor requirements, banking requirements, telecom supplier requirements, app platform requirements, or applicable law.

This Policy also explains that destinations, accounts, payments, routes, products, or features may be refused, blocked, restricted, suspended, reviewed, or removed where required or appropriate for compliance or risk-control reasons.

You must not create an account, buy calling credit, make payment, or use the Kainet service if:

• you are located in a sanctioned or restricted jurisdiction;
• you are resident in a sanctioned or restricted jurisdiction;
• you are ordinarily operating from a sanctioned or restricted jurisdiction;
• you are subject to sanctions imposed by the United Kingdom, United Nations, European Union, United States, or any other authority relevant to the service;
• you are acting for or on behalf of a sanctioned person or entity;
• you are using a payment method from a sanctioned or restricted jurisdiction;
• your use would make funds or economic resources available to a sanctioned person or entity; or
• your use would create legal, sanctions, payment, banking, supplier, card network, app platform, or regulatory risk for Kainet.

Kainet may require confirmation that you are not located in, resident in, or ordinarily operating from a sanctioned or restricted jurisdiction and that you are not subject to sanctions.

Kainet does not normally collect citizenship information as part of standard customer registration unless a legal, regulatory, payment, risk, sanctions, or compliance requirement makes additional checks necessary.

Kainet does not accept payments from sanctioned or restricted jurisdictions.

Kainet may reject, block, refund, reverse, review, or delay a transaction where the payment method, billing country, IP country, payment method country, account information, transaction pattern, or risk signal indicates a sanctioned or restricted jurisdiction or another compliance concern.

Kainet may also reject or review payments where required or recommended by a payment processor, bank, card network, fraud-prevention provider, telecom supplier, app platform, or regulator.

Kainet does not make payouts to sanctioned or restricted jurisdictions.

Kainet does not provide cash withdrawal, money transfer, remittance, customer wallets, e-money, gift cards, cash-equivalent stored value, or general stored-value services.

Kainet calling credit can only be used for eligible Kainet calling services. It cannot be transferred to another person, withdrawn, redeemed for cash, used as a wallet, used for remittance, or used outside the Kainet service.

Kainet may offer calls to supported international destinations where legally, technically, commercially, operationally, and contractually available. The fact that a destination is technically listed, previously available, or visible in a customer interface does not guarantee that it will always remain available.

Kainet may block, restrict, suspend, remove, review, or reclassify destinations, routes, number types, products, or calling patterns where required or appropriate because of:

• sanctions;
• legal restrictions;
• telecom regulation;
• payment processor rules;
• bank requirements;
• card network requirements;
• telecom supplier requirements;
• app platform requirements;
• supplier route withdrawal;
• fraud risk;
• artificial traffic risk;
• security risk;
• operational risk;
• reputational risk;
• destination network restrictions;
• pricing or rating changes;
• abuse prevention; or
• other compliance or risk-control reasons.

Destination restrictions do not automatically create a refund right, especially where calling credit remains usable for other supported destinations. Refunds or credits, where applicable, are handled under the Kainet Cancellation and Refund Policy and mandatory consumer law.

Kainet does not provide telecom equipment, network equipment, interception technology, monitoring technology, surveillance technology, restricted network technology, restricted software, or restricted technical assistance to sanctioned or restricted jurisdictions.

You must not use Kainet to provide, support, enable, or facilitate:

• unlawful interception;
• unlawful monitoring;
• unlawful surveillance;
• traffic inspection for unlawful purposes;
• unlawful call recording;
• network intelligence gathering;
• spyware;
• unlawful investigative activity;
• restricted telecom technology;
• restricted technical assistance;
• sanctions circumvention;
• export-control circumvention; or
• any activity that may breach sanctions, export controls, privacy law, telecom law, or human rights-related restrictions.

Kainet may use third-party B2B telecom, VoIP, SIP, cloud communications, hosting, payment, fraud-prevention, support, analytics, and technical service providers to operate the service.

Kainet expects suppliers and routing partners to comply with applicable sanctions, export-control, telecom, payment, and legal requirements.

Kainet may change, restrict, suspend, or remove suppliers, routes, destinations, or service features where necessary or appropriate for compliance, risk control, supplier availability, payment processing, legal requirements, or operational continuity. Customers contract with KAINET WAVE LTD and not directly with Kainet’s suppliers unless expressly stated otherwise.

Kainet may use manual or automated checks to identify restricted-jurisdiction, sanctions, payment, fraud, security, supplier, or regulatory risk.

These checks may include review of:

• account country;
• billing country;
• IP country;
• payment method country;
• payment processor signals;
• bank or card network signals;
• destination country;
• destination number type;
• usage patterns;
• account history;
• support or complaint history;
• chargeback or dispute history;
• risk flags;
• customer confirmations; and
• other relevant operational or compliance information.

Kainet may request additional information where reasonably necessary for compliance, fraud prevention, payment review, sanctions screening, or service eligibility.

Kainet is not required to disclose internal sanctions-screening rules, fraud-prevention rules, payment-risk criteria, supplier criteria, routing logic, security thresholds, or operational risk signals where withholding that information is reasonably necessary to protect the service, prevent abuse, or comply with law.

Where required or appropriate for compliance or risk-control reasons, Kainet may:

• refuse account registration;
• delay activation;
• request further information;
• reject payment;
• block a payment method;
• refund or reverse a transaction;
• suspend an account;
• restrict account functions;
• block destinations;
• restrict routes;
• remove products;
• freeze usage review;
• cancel orders;
• close accounts;
• refuse further service;
• report suspected unlawful or fraudulent activity; or
• cooperate with banks, payment processors, card networks, suppliers, regulators, ADR bodies, law-enforcement bodies, or legal authorities.

Kainet may act without prior notice where necessary for legal compliance, sanctions compliance, payment integrity, fraud prevention, supplier protection, security, or service continuity.

Kainet may be unable to provide a refund where doing so would breach sanctions, payment rules, fraud controls, bank requirements, card network rules, supplier requirements, or legal obligations. Refunds may be delayed, blocked, reversed, or subject to further review where required for sanctions compliance, payment processor requirements, bank requirements, fraud prevention, or legal compliance. Where a refund is permitted, Kainet will normally refund to the original payment method, subject to the Kainet Cancellation and Refund Policy and applicable law.

You must:

• provide accurate account, billing, and payment information;
• use only payment methods that you are authorised to use;
• not use payment methods from sanctioned or restricted jurisdictions;
• not use the service while located in, resident in, or ordinarily operating from a sanctioned or restricted jurisdiction;
• not use the service for or on behalf of sanctioned persons or entities;
• not attempt to bypass restrictions, screening, location checks, payment checks, destination controls, or route controls;
• not use the service for unlawful, abusive, artificial, automated, or restricted purposes;
• notify Kainet promptly if you believe your account has been misused; and
• comply with the Kainet Terms and Conditions, Acceptable Use Policy, and this Policy.

Kainet may rely on account records, payment records, checkout confirmations, invoices, authentication records, activation records, customer-interface records, billing records, routing logs, call detail records, technical logs, traffic or communication metadata, supplier status messages, connection records, fraud-screening results, sanctions-screening results, support records, complaint records, and other operational data as evidence. These records may be used to assess whether service was ordered, activated, delivered, restricted, blocked, routed, billed, refunded, or affected by legal, sanctions, payment, supplier, technical, or operational limitations. Kainet will handle personal data in accordance with the Kainet Privacy Policy and applicable data protection law.

If you are unhappy with a decision involving sanctions, restricted jurisdictions, blocked payments, refused activation, destination restrictions, account suspension, refund review, or compliance checks, you may raise a complaint under the Kainet Complaints Code.

You can complain using:

• Complaints email: complaints@farvia.online
• Complaints web form: https://farvia.online/complaints
• Phone: Pending / being set up
• Post: KAINET WAVE LTD, Flat 30, Kew Court, Richmond Road, Kingston upon Thames, England, KT2 5BF, United Kingdom

If your complaint remains unresolved after six weeks from the date it was first raised with Kainet, or if Kainet issues a deadlock letter before that time, you may be able to refer the complaint to Kainet’s approved Alternative Dispute Resolution scheme once membership is active.

ADR scheme: CISAS – membership pending / being set up.

ADR is free for eligible customers.

Kainet may not be able to disclose all internal sanctions-screening, payment-risk, fraud-prevention, supplier, routing, or security information in a complaint response.

Kainet may update this Policy from time to time. Updates may be made to reflect changes in law, sanctions rules, payment processor requirements, bank or card network rules, supplier arrangements, route availability, destination availability, service features, compliance processes, or operational needs.The version and date at the top of this Policy show when it was last updated.Before paid public service availability begins, this Policy should be reviewed to ensure that the customer support phone number, WhatsApp support number, CISAS membership details, Terms and Conditions, Privacy Policy, Complaints Code, Cancellation and Refund Policy, Acceptable Use Policy, checkout wording, and public website information are consistent and up to date.