Effective date: July 22, 2024

Wingspan Networks, Inc. Acceptable Use Policy

This Acceptable Use Policy ("AUP") outlines the activities and practices that are not permitted by merchants using services provided by Wingspan Networks, Inc. ("Wingspan"). Wingspan is committed to ensuring a safe, secure, and compliant environment for all users. Merchants and users must adhere to this policy to maintain their accounts in good standing.

Prohibited Activities

Merchants and other users using Wingspan's services are prohibited from engaging in the following activities:

Illegal Activities

  1. Unlawful Transactions: Selling, purchasing, or facilitating illegal goods, services, or activities.
  2. Fraud: Engaging in deceptive practices, providing false or misleading information, or attempting to defraud Wingspan or any other party.
  3. Money Laundering: Engaging in or facilitating money laundering or terrorist financing activities.

Unacceptable Content and Products

  1. Adult Content and Services: Selling or distributing adult content, pornography, or adult services, including escort services.
  2. Hate Speech and Discrimination: Promoting or engaging in hate speech, discrimination, or harassment based on race, ethnicity, religion, gender, sexual orientation, or other protected characteristics.
  3. Violence: Promoting or facilitating violence, including the sale of weapons or explosives.

Intellectual Property and Privacy Violations

  1. Infringement: Selling or distributing products or services that infringe on intellectual property rights, including copyrights, trademarks, patents, or trade secrets.
  2. Privacy Violations: Collecting, storing, or sharing personal data without proper consent or in violation of applicable privacy laws and regulations.

Financial Activities and Products

  1. Unregulated Financial Services: Offering unregulated financial services, including but not limited to, payday loans, debt collection services, and investment schemes.
  2. Cryptocurrency: Facilitating the sale or exchange of cryptocurrencies or other digital currencies without proper authorization and compliance with relevant regulations.

High-Risk Activities

  1. Gambling and Betting: Engaging in or facilitating gambling, betting, or lottery activities, unless expressly permitted by law and authorized by Wingspan.
  2. Pyramid and Ponzi Schemes: Promoting or operating pyramid schemes, Ponzi schemes, or other get-rich-quick schemes.

Miscellaneous

  1. Malware and Hacking: Distributing malware, spyware, viruses, or engaging in hacking or other activities that harm or interfere with Wingspan's services or infrastructure.
  2. Fake Products and Counterfeits: Selling counterfeit goods or unauthorized replicas of brand-name products.
  3. Spam and Unsolicited Communications: Sending unsolicited communications, including spam emails or messages.
  4. Non-Compliance with Laws: Non-compliance with relevant laws, sponsor bank requirements, and card or payment association (e.g., VISA, MasterCard, American Express, NACHA) rules and policies.
  5. Prohibited Industry or Country: Operating in, or transacting with individuals or entities located or based in, a prohibited country or prohibited industry.
  6. Third-Party Processor: Using a merchant account of another business to process credit card transactions or allowing another business to process transactions on your approved account.

Prohibited Industries

Wingspan is prohibited from providing services to merchants and users in the following industries:

  1. Shell banks
  2. Sexual encounter firms
  3. Businesses that sell illegal drug paraphernalia
  4. Delta-8 THC retailers (online/retail)
  5. Illegal Internet gambling
  6. Issuers of bearer shares
  7. Payable through accounts
  8. Binance and Binance US

Restricted Industries

The following industries are restricted from using Wingspan's services:

  1. Investment & Credit Services MCCs: 6010, 6011, 6211, 6300
  2. Money and Legal Services MCCs: 9211, 9222, 9223, 9399
  3. Virtual Currency or Stored Value MCCs: 6051, 6540
  4. Intellectual Property or Proprietary Rights Infringement MCCs: 8111
  5. Counterfeit or Unauthorized Goods MCCs: 5937
  6. Gambling MCCs: 7995
  7. Regulated or Illegal Products or Services Various MCCs depending on the product
  8. Adult Content and Services MCCs: 5967, 7273, 7841
  9. Get Rich Quick Schemes No specific MCC, but often related to high-risk transactions
  10. Mug Shot Publication or Pay-to-Remove Sites MCCs: 8999
  11. No-Value-Added Services MCCs: 7399
  12. Aggregation MCCs: 7399
  13. High Risk Businesses Various MCCs across high-risk categories
  14. Multi-Level Marketing MCCs: 5960, 5962
  15. Pseudo Pharmaceuticals MCCs: 5912
  16. Social Media Activity MCCs: 7311
  17. Substances Designed to Mimic Illegal Drugs MCCs: 5999
  18. Video Game or Virtual World Credits MCCs: 7994
  19. Use of the Payment Processing Services in a Manner Inconsistent with its Intended Use Various MCCs depending on the transaction nature
  20. Firearms sales MCCs: 5941
  21. Cannabis related businesses MCCs: 5912
  22. Third-party payment processors MCCs: 6012
  23. Non-US entities Various MCCs depending on the transaction nature
  24. Non-bank financial institutions MCCs: 6051
  25. Foreign NGO relationships No specific MCC, varies by the specific services provided
  26. Private ATM owner/operators MCCs: 6051
  27. Foreign investment entities No specific MCC, varies by specific activities
  28. Armored courier services No specific MCC, varies by specific activities
  29. Military contractors No specific MCC, varies by specific activities
  30. Adult entertainment MCCs: 7297, 7995, 7841
  31. Precious metals/gems MCCs: 5094
  32. Foreign correspondent banks No specific MCC, typically fall under general banking MCCs

Merchant Decline Codes

Wingspan employs a system of decline codes to enforce this Acceptable Use Policy:

  1. DC01: Transaction declined due to suspected illegal activity
  2. DC02: Transaction declined due to prohibited content or product
  3. DC03: Transaction declined due to intellectual property infringement
  4. DC04: Transaction declined due to privacy violations
  5. DC05: Transaction declined due to unregulated financial services
  6. DC06: Transaction declined due to high-risk activity
  7. DC07: Transaction declined due to miscellaneous prohibited activity

Prohibited Countries

Wingspan will not provide services to merchants and users that are residents of the following countries, or initiate transactions to or from residents of such countries:

  1. Afghanistan
  2. Albania
  3. Belarus
  4. Central African Republic
  5. Congo, the Democratic Republic
  6. Cuba
  7. Eritrea
  8. Ethiopa
  9. Gaza Strip
  10. Iran, Islamic Republic of
  11. Iraq
  12. Kenya
  13. Kosovo
  14. Lebanon
  15. Libya
  16. Mali
  17. Myanmar
  18. Nicaragua
  19. Niger
  20. Democratic People's Republic of Korea
  21. North Macedonia
  22. Pakistan
  23. Aatar
  24. Russian Federation
  25. Slovenia
  26. Somalia
  27. South Sudan
  28. Sudan
  29. Syria
  30. Ukraine
  31. Venezuela
  32. West Bank (Palestinian Territory, Occupied)
  33. Yemen
  34. Zimbabwe

High-Risk Countries

Users and merchants in the following countries are not prohibited from using Wingspan services, but will be monitored and designated as high-risk:

  1. Algeria (digital assets banned)
  2. Bangladesh (digital assets banned)
  3. Barbados
  4. Bhutan
  5. Bosnia-Herzegovina
  6. Botswana
  7. Burkina Faso
  8. Burundi
  9. Cambodia
  10. Cameroon
  11. China (digital assets banned)
  12. Ecuador
  13. Gambia
  14. Grenada
  15. Guinea
  16. Guinea Bissau
  17. Haiti
  18. Jamaica
  19. Jordan
  20. Liberia
  21. Madagascar
  22. Morocco
  23. Mozambique
  24. Nepal
  25. Nigeria
  26. Senegal
  27. Seychelles
  28. Solomon Islands
  29. South Africa
  30. Suriname
  31. Tnazania
  32. Togo
  33. Tonga
  34. Trinidad & Tobago
  35. Turkey
  36. Turks & Caicos
  37. Uganda
  38. Vanuatu
  39. Vientam
  40. Western Sahara

Compliance and Enforcement

Wingspan reserves the right to take appropriate action, including but not limited to, suspending or terminating merchant accounts, blocking transactions, and reporting to relevant authorities for violations of this Acceptable Use Policy. Merchants are expected to comply with all applicable laws and regulations and cooperate with Wingspan's compliance efforts.

Amendments

Wingspan may amend this Acceptable Use Policy from time to time. Wingspan will publish any changes on its platform and will become effective five (5) business days after publication. Wingspan will notify you by email once the changes are published.