Compensation Policy for Fraudulent Transactions

Article 1. Purpose

The Compensation Policy for Fraudulent Transactions (hereinafter referred to as “the Policy”) is based on Article 3 of the Internal Regulations on Compensation for Fraudulent Transactions, and shall be in accordance with the Payment Services Act, the Cabinet Office Ordinance on Funds Transfer Service Providers and relate guidelines. The purpose of the Policy is to formulate a policy for compensation and other measures for loss caused by fraudulent transactions, to implement appropriate and prompt compensation.

Article 2. Compensation details, scenes / requirements, etc.

2.1. When a loss occurs to a Member of the funds transfer service that the Company provides (hereinafter referred to as “the Service”) due to an instruction from a person who does not have authority against the will of the Member, the Member who is a victim of such fraudulent transactions when using the Service is eligible for compensation, subjected to various investigations that may be conducted into the fraudulent event.

2.2. However, in the event of any of the following, the Member may not be compensated, or only eligible for reduced compensation:

when the Member’s actions are "intentional", or has "serious negligence", or "negligence";
when the Member neglect to provide the Company or the police with sufficient explanation of events and/or circumstances;
when the Member fail to provide prompt notification to the Company, within 60 days after the damage occurs;
when the Member provide a false explanation to the Company about important matters;
when the Member have not updated their antivirus software, OS, browser, etc. to the latest version;
when the Member store IDs, passwords, etc. in relation to our Services on computers, mobile phones, etc.;
when the Member inadvertently enters his/her ID, password, etc., such as by being deceived by email-type phishing, despite the Company having informed and alerted the Member of such risks;
when other events that are considered to be intentional, gross negligence or negligence are found in the Member; or
in the case of damages that take advantage of social order, such as wars and riots.

2.3. The Company will consider specific compensation contents on a case by case basis, taking into consideration the usage status of each Member, the status of security measures introduced, the results of investigations by police authorities, etc.

Article 3. Contents of compensation procedure

3.1. The Member must take the following actions to be eligible for compensation:

the Member must immediately contact us via email when he/she becomes aware of “illegal transactions that he/she has no memory of”;
the Member must promptly report to the police; and
the Member must cooperate with the investigations conducted by the Company and the police.

3.2. The Member must also provide the following contents to the Company with the necessary documents or supporting materials attached.

the amount of loss;
loss date;
background of the loss; and
other matters as requested by the Company.

3.3. Compensation will not be provided if

the Member fail to provide the items required in Clause 3.2;
false facts are stated in the documents or materials provided; or
the Member fail to cooperate with the investigations conducted by the Company and/or the police.

Article 4. Matters concerning the sharing of compensation with partners

4.1. Where the Company has a partner for which the Member has a deposit account, etc. and the Member requests compensation for a case where there are fraudulent transactions, the Company will cooperate with the partner to investigate and provide compensation. The Company will also be the contact point for inquiries with the Member.

4.2. Any requests for compensation from victims of fraudulent transactions that are not Members of the Service will be outside the scope of our compensation. The Company will assist our partners by directing these victims to their Policy.

Article 5. Assignment of rights after compensation

If the Company makes compensation pursuant to the Policy, all rights regarding unauthorized use that brought about the compensation shall be transferred from the Member to the Company.

Article 6. Consultation desk for compensation and its contact information

The consultation desk for compensation will be the Operation Division, and the following consultation desk and application method for compensation will be established and posted on the website.
Consultation desk for compensation:
Customer Consultation Desk, Operation Division, CURFEX JAPAN, Inc.
Floor 4, Otemachi Building, 1-6-1 Otemachi, Chiyoda-ku, Tokyo
Customer Care business hours: 10:00 – 18:00 (JST; excludes weekends and public holidays.)
Email: hello@curfex.com

Article 7. Cancellation and suspension of the Policy

The Company may suspend or revise the Policy in whole or in part without prior notice to the Member if there is necessary due to system maintenance, failures in communication lines and computers or any other operational reason deemed by the Company. The Company assumes no liability with respect to damage suffered by the Member during the period in which the Policy is terminated or suspended.

Article 8. Disclosure criteria for fraudulent transactions

In the event that fraudulent transactions has occurred or is likely to occur, the Company will promptly publish the necessary information in cooperation with the partner (where there is a partner, etc.) when we determine that there’s necessity to prevent the spread of damage (secondary damage), benefit to avoid the occurrence of similar cases, or large social impact in terms of the amount of damage and the number of cases.

Article 9. Establishment, Revision and Abolition

The establishment, revision and abolition of the Policy shall be made by the Operation Division due to changes in economic conditions, revision and abolition of laws and regulations, changes in the Company’s terms and conditions and other circumstances, and shall be resolved by the Board of Directors.