Sales Agency Disclosure and Compliance Policy

Effective June 1, 2026 · Version 1.0 · Governing law: Texas

1. Purpose and Scope

This Sales Agency Disclosure and Compliance Policy (“Disclosure”) explains:

The limited role performed by AltirasPay.
The role of AltirasPay’s sales representatives.
The independent role of each bank and processor.
The responsibility of merchants to provide truthful information.
The process through which merchant applications are collected and submitted.
The party responsible for underwriting, approval, account setup, monitoring, funding, reserves, suspension, and termination.
The standards governing AltirasPay’s sales and marketing activities.

This Disclosure applies to:

The AltirasPay website.
Merchant inquiries and pre-applications.
Merchant application and document-submission portals.
Sales calls, emails, text messages, and other communications.
AltirasPay employees and contractors.
Independent sales representatives.
Referral partners and authorized subagents.
Consultants acting under AltirasPay’s authority.
Merchant introductions and provider submissions.
AI-assisted sales and business-support tools.
Other sales, referral, and application-support services provided by AltirasPay.

This Disclosure does not replace a merchant-processing agreement, acquiring agreement, processor agreement, gateway agreement, or other agreement issued by an independent provider.

2. AltirasPay’s Status as a Sales Agency

AltirasPay is a sales and marketing agency that introduces prospective merchants to independent payment-service providers.

AltirasPay may act as a sales agent, referral agent, independent contractor, marketing representative, or merchant-introduction source under separate agreements with different providers.

AltirasPay’s position in the payment-services process is limited to merchant origination and application support.

AltirasPay may:

Locate prospective merchants.
Present available provider programs.
Communicate provider-published requirements.
Collect merchant-provided documents.
Organize application materials.
Submit merchant files to providers.
Relay provider questions and requests.
Communicate provider-issued decisions and conditions.

AltirasPay does not independently provide the underlying merchant-acquiring or payment-processing service.

A merchant’s payment-processing relationship is established directly with the provider identified in the merchant’s final written agreement.

3. Independent Banks, Processors, and Providers

AltirasPay works with multiple independent providers.

For purposes of this Disclosure, “Provider” means any acquiring bank, sponsor bank, payment processor, payment facilitator, gateway, financial-technology company, acquiring partner, or other payment-service provider to which AltirasPay introduces or submits a merchant.

Each Provider is independently owned and operated.

Each Provider controls its own:

Programs and services.
Merchant eligibility standards.
Documentation requirements.
Underwriting procedures.
Risk appetite.
Restricted and prohibited-business policies.
Legal and compliance review.
Merchant category coding.
Card-network registration.
Pricing and fees.
Reserve requirements.
Processing limits.
Funding schedules.
Account-setup procedures.
Fraud controls.
Transaction monitoring.
Chargeback monitoring.
Account restrictions.
Suspension and termination decisions.

AltirasPay does not own, operate, supervise, or control a Provider merely because AltirasPay markets the Provider’s services or introduces merchants to the Provider.

No Provider is responsible for another Provider’s rules, programs, underwriting decisions, or merchant accounts.

4. Provider-Specific Programs

Each Provider may apply different requirements to the same merchant or business category.

A merchant accepted by one Provider may be declined by another Provider. A rate, reserve, processing limit, registration, or account condition offered by one Provider does not automatically apply to any other Provider.

Provider requirements may vary based on:

Business category.
Products and services.
Ownership.
Jurisdiction.
Customer location.
Processing history.
Financial condition.
Transaction volume.
Average transaction amount.
Chargeback history.
Fraud exposure.
Fulfillment model.
Website content.
Marketing practices.
Licenses and registrations.
Card-network classification.
Provider risk appetite.
Applicable law.

AltirasPay may describe general program requirements, but only the applicable Provider may confirm its final requirements and terms.

5. Services AltirasPay Provides

AltirasPay’s services may include:

5.1 Sales and Marketing

Identifying and contacting businesses that may be interested in applying for payment-processing services.

5.2 Merchant Introductions

Introducing merchants to one or more Providers that have indicated a willingness to consider the merchant’s general business category.

5.3 Program Information

Communicating general information concerning Provider programs, application procedures, documentation requirements, estimated pricing, and expected underwriting processes.

5.4 Application Support

Providing merchant applications, intake forms, pre-applications, questionnaires, checklists, and document-request lists.

5.5 Document Collection

Collecting information and documents voluntarily supplied by the merchant.

5.6 File Organization

Organizing merchant-provided information into the general intake format requested by a Provider.

5.7 Submission Support

Transmitting merchant applications and supporting documents to the applicable Provider.

5.8 Communication Assistance

Relaying Provider questions, document requests, status updates, approval conditions, decline notices, and other communications.

5.9 Business Technology

Providing optional AI-assisted tools, sales tools, marketing systems, communication systems, customer-service tools, intake tools, document-organization tools, or business workflow technology.

These services do not give AltirasPay control over a Provider’s underwriting or merchant-account decisions.

6. Services AltirasPay Does Not Provide

AltirasPay does not perform or control the following Provider functions:

Merchant underwriting.
Final legal or compliance determinations.
Credit approval.
KYC or beneficial-ownership approval.
AML determinations.
OFAC or sanctions determinations.
MATCH determinations.
Background approval.
Merchant category code assignment.
Card-network registration.
Merchant-account boarding.
Merchant identification number issuance.
Gateway provisioning.
Processing-account configuration.
Transaction authorization.
Transaction settlement.
Merchant funding.
Reserve administration.
Transaction monitoring.
Fraud monitoring.
Chargeback monitoring.
Website monitoring.
Account suspension.
Account termination.

AltirasPay may collect or transmit information associated with these functions, but the Provider performs and controls the substantive review and decision.

7. Authorized Sales Representatives

AltirasPay may conduct sales through:

Employees.
Independent contractors.
Independent sales representatives.
Referral partners.
Authorized agents.
Consultants.
Other persons expressly authorized by AltirasPay.

An “AltirasPay Representative” means a person who has been expressly authorized to promote AltirasPay’s services or facilitate merchant introductions.

Authorization to represent AltirasPay is limited to the authority expressly provided by AltirasPay.

A representative is not automatically authorized to:

Bind AltirasPay to a contract.
Bind a Provider.
Approve a merchant.
Change Provider requirements.
Guarantee pricing or reserves.
Collect money.
Establish merchant accounts.
Make legal determinations.
Interpret card-network rules for a Provider.
Use Provider or card-network logos.
Appoint additional subagents.

Independent representatives are not necessarily employees of AltirasPay. Their classification depends on their written agreement and applicable law.

8. Representative Identification Requirements

AltirasPay Representatives must accurately identify:

Their name.
Their relationship with AltirasPay.
AltirasPay’s role as a sales and referral agency.
The fact that AltirasPay is not the underwriting bank or processor.
The fact that all applications are subject to independent Provider review.

A representative may not falsely claim or imply that the representative is:

A bank employee.
A processor employee.
A card-network employee.
A government official.
A regulator.
An underwriter.
A compliance officer for the Provider.
An attorney.
Authorized to issue final approval.

Merchants may contact AltirasPay directly to verify whether a person is authorized to represent the company.

9. Limits on Representative Authority

No AltirasPay Representative has authority to:

Approve or decline a merchant.
Guarantee approval.
Guarantee processing activation.
Guarantee a particular Provider.
Promise a merchant category code.
Promise card-network registration.
Guarantee rates or fees.
Guarantee a reserve percentage.
Guarantee a reserve-release date.
Guarantee funding speed.
Guarantee processing limits.
Promise uninterrupted processing.
Waive Provider requirements.
Override a Provider decision.
Order a Provider to release funds.
Reverse a suspension or termination.
Bind a Provider to an oral statement.
Modify a Provider’s written agreement.

Only the Provider’s authorized personnel and final written documents may establish binding merchant-processing terms.

Any unauthorized oral or written statement by a representative is not binding on AltirasPay or a Provider.

10. Prohibited Sales Statements

AltirasPay Representatives must not state or imply that:

AltirasPay is a bank or processor.
AltirasPay controls underwriting.
Merchant approval is guaranteed.
An account is approved before written approval is issued.
A merchant may begin processing before account activation.
Visa, Mastercard, or another card network has endorsed AltirasPay without documented authorization.
A card network has approved a merchant when no approval has been issued.
AltirasPay has declared a regulated product lawful.
A Provider will ignore its underwriting rules.
A merchant may avoid card-network registration.
A merchant may conceal products or websites.
Offshore processing eliminates applicable laws or card-network requirements.
AltirasPay can prevent a Provider from monitoring the merchant.
AltirasPay can prevent lawful regulatory or law-enforcement disclosure.
A quoted rate is final before Provider approval.
Funds or reserves will be released on a guaranteed date unless confirmed by the Provider in writing.

Representatives must communicate material limitations and conditions clearly and must not create a misleading overall impression.

11. Prohibited Representative Conduct

AltirasPay Representatives may not knowingly:

Submit false or misleading merchant information.
Alter or fabricate documents.
Conceal products, services, websites, or sales channels.
Misstate a merchant’s business model.
Misstate merchant ownership.
Inflate or reduce processing volumes to influence underwriting.
Present consumer activity as institutional activity when the merchant disclosed otherwise.
Assist with merchant-account sharing.
Assist with transaction laundering.
Submit transactions or applications for undisclosed third parties.
Encourage a merchant to evade Provider requirements.
Use unauthorized rate sheets.
Use outdated application forms after being instructed to stop.
Charge an unauthorized fee.
Collect merchant funds into a personal account.
Request gift cards, cryptocurrency, cash, or personal payments as a condition of approval.
Collect cardholder account information.
Request passwords or processing credentials without written authorization.
Make unauthorized legal, regulatory, or compliance representations.
Retaliate against a merchant for making a good-faith complaint.
Interfere with a Provider, card-network, regulatory, or law-enforcement inquiry.

Violation of these requirements may result in termination of the representative’s authority and referral to the appropriate Provider or authority.

12. Authorized Marketing Materials

Representatives must use current and authorized AltirasPay materials.

This requirement applies to:

Websites.
Landing pages.
Email campaigns.
Text messages.
Telephone scripts.
Social-media content.
Advertisements.
Presentations.
Proposals.
Rate sheets.
Application forms.
Provider descriptions.
Testimonials.
AI-generated content.
Use of Provider or card-network names and logos.

A representative may not create a website, domain, social-media profile, email address, or advertisement that falsely appears to be operated directly by AltirasPay or a Provider.

Provider names, logos, trademarks, and program details may be used only with the required authorization.

AltirasPay may require the removal or correction of inaccurate, outdated, misleading, unauthorized, or noncompliant marketing materials.

13. Merchant Information and Representations

The merchant is solely responsible for providing information that is:

Complete.
Accurate.
Current.
Authentic.
Authorized.
Not misleading.

Merchant information remains the merchant’s own representation to the applicable Provider.

AltirasPay’s receipt, organization, or transmission of merchant information does not mean AltirasPay has independently:

Verified the information.
Authenticated the documents.
Approved the merchant.
Approved the products.
Approved the website.
Certified legal compliance.
Certified card-network compliance.
Endorsed a legal opinion.
Confirmed a license.
Guaranteed the merchant’s eligibility.

Merchants must promptly correct inaccurate information and disclose material changes.

14. Merchant Application and Submission Process

The ordinary submission process is as follows:

A Provider establishes the requirements for its program.
AltirasPay or an authorized representative communicates those requirements to the merchant.
The merchant prepares and supplies its own application, documents, explanations, and representations.
AltirasPay organizes the merchant-provided materials.
AltirasPay submits the file to the applicable Provider.
The Provider conducts its own due diligence and underwriting.
The Provider may request additional information.
AltirasPay may relay the request to the merchant.
The merchant supplies its response.
AltirasPay may transmit the response to the Provider.
The Provider approves, conditions, restricts, or declines the application.
If approved, the Provider or its authorized partners establish and configure the merchant account.

AltirasPay does not control how long underwriting takes or what decision the Provider reaches.

15. Provider-Controlled Due Diligence, Underwriting, and Compliance

15.1 Provider Due Diligence

Each Provider independently determines the due diligence appropriate for a merchant application.

The Provider’s review may include:

Identity verification.
Beneficial-ownership verification.
Business verification.
Bank-account verification.
Financial review.
Credit review.
Processing-history review.
Chargeback and refund review.
Sanctions screening.
MATCH screening.
Background review.
Website review.
Product review.
Licensing review.
Legal-opinion review.
Customer and sales-channel review.
Fulfillment review.
Supplier review.
Geographic review.
Regulatory review.
Any other review the Provider considers necessary.

AltirasPay does not determine whether the Provider’s review is sufficient.

15.2 Provider Underwriting Authority

The Provider exclusively determines:

Whether it will accept an application.
Whether the application is complete.
Whether additional information is required.
Whether enhanced due diligence is required.
Whether legal review is required.
Whether the merchant fits the Provider’s risk appetite.
Whether products or websites may be approved.
Whether geographic restrictions are required.
Whether approval should be conditional.
Whether the merchant should be approved or declined.

AltirasPay cannot waive or override a Provider requirement.

15.3 Reliance on Provider Judgment

AltirasPay relies on the independent judgment of each Provider and its underwriting, legal, risk, compliance, fraud, operations, and account-management personnel.

AltirasPay relies on the Provider to determine:

Whether the Provider is permitted to support the merchant.
Whether the merchant fits the Provider’s program.
Whether sufficient due diligence has been completed.
Whether the merchant’s documents are sufficient.
Whether the products and services are acceptable.
Whether registration or enhanced review is required.
Whether the account should be approved, restricted, suspended, or terminated.

AltirasPay does not conduct a parallel underwriting process intended to replace the Provider’s judgment.

15.4 Card-Network Rules

The applicable Provider is responsible for understanding, interpreting, and applying the Visa, Mastercard, and other card-network rules governing its acquiring or processing program.

The Provider determines:

Merchant eligibility.
Product acceptability.
Merchant classification.
Merchant category coding.
Card-network registration.
Enhanced due-diligence requirements.
Transaction controls.
Geographic restrictions.
Monitoring requirements.
Whether processing may begin or continue.

AltirasPay does not independently certify that a merchant complies with card-network rules.

15.5 Merchant Category Codes

AltirasPay does not assign, select, negotiate, approve, or change merchant category codes.

The Provider determines the appropriate code based on its review of the merchant’s actual business activity.

15.6 Card-Network Registration

AltirasPay does not determine whether card-network registration is required and does not independently register merchants.

The Provider determines:

Whether registration is required.
Which registration category applies.
What documents are required.
Whether legal verification is required.
Whether the Provider will sponsor the merchant.
Whether network approval must be obtained.
Whether registration must be renewed or updated.

15.7 Merchant Documents

AltirasPay may transmit licenses, registrations, financial records, Certificates of Analysis, legal opinions, processing statements, website materials, and other documents supplied by a merchant.

AltirasPay does not independently certify the authenticity, accuracy, legal sufficiency, or regulatory effect of those documents.

The Provider determines whether verification is required and whether the documents satisfy its requirements.

15.8 Truthful Transmission

AltirasPay will not knowingly falsify, disguise, or conceal material merchant information.

AltirasPay will not knowingly:

Present one business as another.
Remove a disclosed product to obtain approval.
Conceal a known website at the merchant’s request.
Submit false ownership information.
Misstate customer types.
Misstate fulfillment locations.
Assist with merchant-account sharing.
Assist with transaction laundering.
Claim an approval that has not been issued.

This obligation does not make AltirasPay the underwriter or final compliance decision-maker.

15.9 No Independent Product-Legality Determination

AltirasPay does not independently determine whether a product is legal, regulated, approved, unapproved, misbranded, adulterated, prescription-only, Research Use Only, intended for human use, or otherwise acceptable for payment processing.

The merchant is responsible for obtaining qualified legal advice.

The Provider determines whether it will review, approve, restrict, or decline the merchant’s products.

15.10 No Guarantee Regarding Provider Decisions

AltirasPay does not guarantee that a Provider will:

Approve a merchant.
Maintain an approval.
Interpret every legal or card-network issue in a particular manner.
Continue accepting a particular business category.
Maintain existing pricing.
Maintain existing reserve requirements.
Continue processing indefinitely.

Each Provider remains responsible for its own decisions and obligations.

15.11 No Circumvention

AltirasPay does not knowingly structure merchant submissions to avoid accurate underwriting, classification, registration, or monitoring.

A merchant may not use AltirasPay to conceal:

Ownership.
Products.
Websites.
Customers.
Sales channels.
Fulfillment locations.
Processing history.
Prior terminations.
Third-party processing.
Material business activity.

15.12 Exclusive Provider Authority

The Provider has exclusive authority to approve, condition, restrict, decline, establish, monitor, suspend, or terminate the merchant account.

AltirasPay cannot compel a Provider to accept an application, activate an account, release funds, or continue processing.

16. Provider-Controlled Pricing and Account Terms

AltirasPay or its representatives may communicate preliminary or estimated:

Rates.
Transaction fees.
Monthly fees.
Gateway fees.
Setup fees.
Registration fees.
Reserve estimates.
Funding estimates.
Processing limits.
Program terms.

Unless expressly confirmed in a final binding written agreement, these terms are preliminary and subject to Provider review.

The Provider determines the final:

Pricing.
Fees.
Reserves.
Funding schedule.
Processing limits.
Transaction limits.
Contract term.
Approval conditions.
Termination provisions.

A representative’s oral statement does not override the Provider’s written agreement.

17. Provider-Controlled Account Setup

AltirasPay does not establish, board, configure, provision, activate, or operate merchant accounts.

AltirasPay may facilitate communication with an onboarding or technical-support team but does not control account setup.

18. Provider-Controlled Funding and Reserves

AltirasPay does not receive, hold, settle, freeze, release, reserve, redirect, or control merchant-processing proceeds.

The Provider controls:

Settlement.
Batch funding.
Rolling reserves.
Fixed reserves.
Chargeback reserves.
Funding delays.
Settlement holds.
Account offsets.
Refund deductions.
Chargeback deductions.
Reserve releases.

AltirasPay may relay a merchant’s funding question but cannot order a Provider to release funds or change a reserve.

19. Provider-Controlled Monitoring

AltirasPay does not operate the Provider’s formal transaction, fraud, chargeback, merchant, website, or compliance-monitoring systems.

The Provider determines the scope and frequency of monitoring, which may include:

Transaction activity.
Processing volume.
Transaction velocity.
Fraud.
Chargebacks.
Refunds.
Card testing.
Customer complaints.
Billing descriptors.
Merchant websites.
Restricted website areas.
Product changes.
Marketing claims.
Affiliate activity.
Customer locations.
Fulfillment.
Transaction laundering.
Undisclosed aggregation.
Third-party processing.
Licensing or regulatory changes.

AltirasPay may relay a monitoring request but does not make the underlying monitoring or enforcement decision.

20. Restrictions, Suspension, and Termination

The Provider controls whether a merchant account remains active.

The Provider may:

Decline transactions.
Restrict products.
Restrict websites.
Restrict jurisdictions.
Reduce processing limits.
Increase reserves.
Delay funding.
Suspend processing.
Terminate the account.
Report activity when required.

AltirasPay cannot prevent, override, or reverse these decisions.

21. Regulated, Specialized, and High-Risk Merchants

AltirasPay may introduce regulated, specialized, or high-risk merchants to Providers that have indicated a willingness to independently evaluate the general business category.

Categories may include, without limitation:

Adult content or adult services.
Alcohol.
Coaching, consulting, creator, influencer, or education programs.
Continuity billing businesses.
Cosmetics.
Credit repair.
Cryptocurrency, digital assets, card-to-crypto, or blockchain-related services.
Debt collection.
Firearms, weapons, tactical, or survival products.
Foreign exchange, trading platforms, signals, or trading-education services.
Gaming, gambling, iGaming, sweepstakes, skill games, fantasy sports, or prize-based promotions.
Healthcare services.
High-ticket ecommerce.
Import and export businesses.
Insurance lead generation.
International or offshore merchants.
Lead generation.
Medical devices.
Money services.
Nutraceuticals and nootropics.
Peptides, research chemicals, laboratory products, or similar products.
Pharmacy-related services.
Precious metals.
Subscription businesses.
Supplements.
Tax resolution.
Telemedicine.
Ticketing and ticket brokerage.
Tobacco, vape, nicotine, or smoke-shop products.
Travel.

This list does not mean that AltirasPay or any Provider accepts every listed category.

A Provider’s willingness to review an application is not:

Merchant approval.
Product approval.
Legal approval.
Card-network approval.
Registration approval.
Permission to begin processing.
A guarantee of continued processing.

22. Domestic and International Provider Programs

AltirasPay may introduce merchants to U.S. and non-U.S. Providers.

Each Provider independently determines:

The legal entities it will accept.
The countries it will support.
Permitted cardholder locations.
Permitted products and services.
Processing currencies.
Settlement currencies.
Geographic restrictions.
Fulfillment requirements.
Import and export documentation.
Cross-border processing requirements.
Customer-location controls.

International or offshore processing does not eliminate laws, Provider requirements, card-network rules, import restrictions, export restrictions, or customer-jurisdiction requirements.

The merchant is responsible for obtaining legal advice concerning every jurisdiction in which it operates, advertises, sells, ships, fulfills, processes transactions, or serves customers.

23. Merchant Obligations After Approval

Approval does not eliminate the merchant’s continuing responsibilities.

The merchant must:

Operate lawfully.
Comply with the merchant agreement.
Follow Provider requirements.
Process only approved products and services.
Use only approved websites and sales channels.
Maintain required licenses and registrations.
Keep website information current.
Protect payment and customer information.
Respond to chargebacks and disputes.
Cooperate with monitoring.
Notify the Provider of material changes.

Material changes may include:

Ownership changes.
New legal entities.
New websites.
New products or services.
New customer types.
New sales channels.
New fulfillment locations.
New suppliers.
New countries.
Licensing changes.
Regulatory changes.
Increased processing volumes.
Increased transaction amounts.

Notice to an AltirasPay Representative does not itself constitute Provider approval of a change.

24. AI and Business Technology

AltirasPay may offer or use AI-assisted tools for:

Sales support.
Merchant communications.
Document organization.
Intake assistance.
Customer service.
Workflow management.
Marketing.
Business automation.

AltirasPay’s AI systems do not independently:

Underwrite merchants.
Approve accounts.
Decline accounts.
Determine product legality.
Assign merchant category codes.
Register merchants with card networks.
Establish merchant accounts.
Control Provider monitoring.
Guarantee processing approval.

AI-generated content may contain errors and must be reviewed before reliance or submission.

AI tools may not be used to create false records, fabricate documents, impersonate another person, generate fake reviews, conceal material information, or facilitate unlawful conduct.

25. Advertising and FTC Compliance

AltirasPay intends to conduct its own sales and marketing activities in accordance with applicable federal and state advertising and unfair-or-deceptive-practices requirements.

AltirasPay and its Representatives must not knowingly make materially false, misleading, deceptive, or unsubstantiated statements concerning:

AltirasPay’s identity.
Provider relationships.
Merchant approval.
Card-network approval.
Rates and fees.
Reserves.
Funding.
Processing limits.
Account setup.
Legal compliance.
Expected earnings.
Savings.
AI capabilities.
Business results.

Material limitations and conditions necessary to prevent a statement from being misleading must be disclosed clearly.

Representatives may not impersonate or falsely claim affiliation with:

A government agency.
A government official.
A bank.
A processor.
A card network.
A Provider.
Another business.
An authorized official of any such organization.

Testimonials, reviews, endorsements, and success stories must not be fabricated or presented in a materially misleading manner.

26. Telephone, Email, and Text Communications

AltirasPay and its authorized representatives may communicate with merchants through telephone calls, email, text messages, and other business channels, subject to applicable law and consent requirements.

Representatives must not knowingly misrepresent:

Caller identity.
The purpose of the communication.
The nature of the services.
Provider relationships.
Approval status.
Pricing.
Fees.
Material conditions.
Cancellation rights.
Expected results.

Commercial email must use accurate sender information and must provide legally required opt-out mechanisms.

Marketing text messages must include required consent and opt-out procedures where applicable.

A merchant’s consent to receive communications does not guarantee approval or require a Provider to accept an application.

27. Privacy and Information Sharing

Information submitted to AltirasPay may be transmitted to prospective or existing Providers and authorized parties for:

Merchant introductions.
Application review.
Due diligence.
Underwriting.
Identity verification.
Ownership verification.
Bank-account verification.
Product and website review.
Legal and compliance review.
Fraud prevention.
Card-network classification or registration.
Account setup.
Account administration.
Monitoring.
Investigation.
Enforcement of agreements.

Information will be handled subject to applicable law, the AltirasPay Privacy Policy, and applicable agreements.

Merchants should not submit full payment-card numbers, cardholder security codes, personal passwords, or processing credentials unless specifically requested through an authorized secure process.

28. Provider, Card-Network, Regulatory, and Law-Enforcement Cooperation

AltirasPay intends to comply with laws, regulations, contractual requirements, and lawful card-network and Provider obligations that apply directly to AltirasPay’s activities.

AltirasPay may cooperate with legally valid or contractually authorized:

Provider reviews.
Card-network inquiries.
Audits.
Examinations.
Investigations.
Subpoenas.
Court orders.
Preservation requests.
Regulatory demands.
Governmental requests.
Law-enforcement requests.

To the extent permitted or required by law, cooperation may include:

Preserving applications and documents.
Preserving communications.
Preserving submission histories.
Preserving access or activity records.
Providing records in AltirasPay’s possession or control.
Identifying the source or recipient of a submission.
Providing merchant-supplied documents.
Relaying requests for information.
Reporting suspected fraud or material misrepresentation.
Reporting suspected transaction laundering or account sharing.
Referring matters to a Provider, card network, regulator, or law-enforcement agency.
Suspending AltirasPay’s own services.
Withdrawing a submission that remains under AltirasPay’s control.

AltirasPay may act without prior notice when notice is prohibited, is not legally required, could compromise an investigation, could facilitate destruction or concealment of evidence, or could interfere with lawful compliance or security activity.

29. No Expectation of Absolute Confidentiality

Merchants and representatives must not submit information to AltirasPay with the expectation that it will remain confidential from persons or organizations legally or contractually authorized to receive it.

Information may be disclosed, as permitted or required, to:

Providers.
Acquiring banks.
Sponsor banks.
Processors.
Payment facilitators.
Gateways.
Card networks.
Underwriters.
Legal and compliance personnel.
Fraud and monitoring vendors.
Auditors.
Insurers.
Professional advisers.
Courts.
Regulators.
Governmental authorities.
Law-enforcement agencies.

AltirasPay does not promise secrecy, anonymity, protection from investigation, or immunity from legally authorized disclosure.

Marking information “confidential,” “privileged,” “proprietary,” or with similar language does not create an attorney-client privilege or prevent legally permitted or required use or disclosure.

Nothing in this section authorizes AltirasPay to disregard privacy, data-security, contractual, or confidentiality obligations that legally apply to AltirasPay.

30. Representative Verification and Complaints

Merchants should verify representatives who:

Use an unfamiliar email domain.
Request payment to a personal account.
Promise guaranteed approval.
Claim to control a Provider.
Ask the merchant to conceal information.
Request passwords or cardholder data.
Use unauthorized documents.
Make unusual or inconsistent claims.

Complaints may be submitted regarding:

Misleading sales statements.
Unauthorized guarantees.
False affiliation claims.
Improper fees.
Document alteration.
Pressure to conceal information.
Unauthorized use of Provider or card-network names.
Misuse of merchant information.
Suspected fraud.
Suspected transaction laundering.
Other representative misconduct.

AltirasPay may investigate complaints and may share relevant information with the appropriate Provider, card network, regulator, or authority.

31. AltirasPay’s Right to End Sales Assistance

AltirasPay may decline, discontinue, suspend, or terminate its own sales, referral, application, technology, or communication assistance when:

A merchant provides false or misleading information.
Material information is withheld.
A merchant requests concealment or falsification.
A representative violates AltirasPay policy.
A Provider declines the application.
A Provider stops accepting the category.
The merchant fails to cooperate with reasonable requests.
Continued assistance creates unacceptable contractual, legal, security, operational, or reputational risk.
AltirasPay is required to do so by law or agreement.

This is a decision concerning AltirasPay’s own services. It is not a final legal determination concerning the merchant.

32. No Approval or Processing Guarantee

AltirasPay and its Representatives do not guarantee:

Application acceptance.
Underwriting approval.
Legal approval.
Regulatory approval.
Card-network approval.
Merchant registration.
Account setup.
Processing activation.
Particular rates.
Particular fees.
Particular reserves.
Particular processing limits.
Particular funding schedules.
Uninterrupted processing.
Continued Provider support.
Release of held funds.
Release of reserves.
Reversal of a Provider decision.

Submission through AltirasPay means only that AltirasPay has facilitated the merchant’s request for independent Provider consideration.

33. No Legal or Regulatory Advice

AltirasPay and its Representatives do not provide:

Legal advice.
Regulatory advice.
Tax advice.
Accounting advice.
Pharmaceutical advice.
Medical advice.
Independent compliance certification.
A legal opinion regarding products or services.
A guarantee of card-network eligibility.

Merchants must consult qualified independent legal, regulatory, tax, accounting, financial, and industry professionals.

Provider approval is a payment-processing decision. It is not a government authorization or legal opinion.

34. Controlling Agreements

This Disclosure does not replace or modify:

A merchant-processing agreement.
A Provider application.
An acquiring agreement.
A processor agreement.
A payment-facilitator agreement.
A gateway agreement.
A reserve agreement.
A pricing schedule.
A card-network requirement.
Applicable law.

The merchant’s final processing relationship is governed by the applicable Provider’s written agreements and lawful requirements.

Provider-specific written terms control over general AltirasPay sales descriptions regarding the Provider’s services.

35. Updates to This Disclosure

AltirasPay may update this Disclosure to reflect changes in:

AltirasPay’s services.
Representative policies.
Provider relationships.
Technology.
Applicable law.
Card-network requirements.
Sales and marketing practices.
Privacy or security requirements.

The revised version will be posted with an updated effective date.

Continued use of AltirasPay’s services after an update constitutes acceptance to the extent permitted by applicable law.

36. Contact Information

Questions, representative-verification requests, and compliance complaints may be directed to:

AltirasPay, LLC
2560 King Arthur Blvd., Suite 124-12
Lewisville, Texas 75056

Website: AltirasPay.ai
General Support: [Insert Support Email]
Compliance and Complaints: [Insert Compliance Email]
Representative Verification: [Insert Verification Email or Form]
Telephone: [Insert Telephone Number]

Do not send full payment-card numbers, card security codes, passwords, or sensitive processing credentials through ordinary email.

37. Final Allocation of Responsibility

AltirasPay and Its Representatives

AltirasPay and its authorized representatives provide sales, marketing, merchant introductions, document collection, submission support, and communication assistance.

The Merchant

The merchant provides truthful and complete information, obtains independent professional advice, complies with applicable law and agreements, discloses material changes, and operates only within the scope approved by its Provider.

The Provider

The Provider conducts due diligence and underwriting, interprets and applies its card-network obligations, classifies the merchant, assigns merchant category coding, completes any required registration, determines final account terms, establishes and configures the account, monitors activity, controls settlement and reserves, and determines whether processing may begin or continue.

AltirasPay relies on each Provider’s independent judgment and does not substitute its own judgment for the Provider’s underwriting, legal, compliance, risk, setup, monitoring, funding, suspension, or termination decisions.

Sales Agency Disclosure and Compliance Policy

1. Purpose and Scope

This Sales Agency Disclosure and Compliance Policy (“Disclosure”) explains:

The limited role performed by AltirasPay.

The role of AltirasPay’s sales representatives.

The independent role of each bank and processor.

The responsibility of merchants to provide truthful information.

The process through which merchant applications are collected and submitted.

The party responsible for underwriting, approval, account setup, monitoring, funding, reserves, suspension, and termination.

The standards governing AltirasPay’s sales and marketing activities.

This Disclosure applies to:

The AltirasPay website.

Merchant inquiries and pre-applications.

Merchant application and document-submission portals.

Sales calls, emails, text messages, and other communications.

AltirasPay employees and contractors.

Independent sales representatives.

Referral partners and authorized subagents.

Consultants acting under AltirasPay’s authority.

Merchant introductions and provider submissions.

AI-assisted sales and business-support tools.

Other sales, referral, and application-support services provided by AltirasPay.

This Disclosure does not replace a merchant-processing agreement, acquiring agreement, processor agreement, gateway agreement, or other agreement issued by an independent provider.

2. AltirasPay’s Status as a Sales Agency

AltirasPay is a sales and marketing agency that introduces prospective merchants to independent payment-service providers.

AltirasPay may act as a sales agent, referral agent, independent contractor, marketing representative, or merchant-introduction source under separate agreements with different providers.

AltirasPay’s position in the payment-services process is limited to merchant origination and application support.

AltirasPay may:

Locate prospective merchants.

Present available provider programs.

Communicate provider-published requirements.

Collect merchant-provided documents.

Organize application materials.

Submit merchant files to providers.

Relay provider questions and requests.

Communicate provider-issued decisions and conditions.

AltirasPay does not independently provide the underlying merchant-acquiring or payment-processing service.

A merchant’s payment-processing relationship is established directly with the provider identified in the merchant’s final written agreement.

3. Independent Banks, Processors, and Providers

AltirasPay works with multiple independent providers.

For purposes of this Disclosure, “Provider” means any acquiring bank, sponsor bank, payment processor, payment facilitator, gateway, financial-technology company, acquiring partner, or other payment-service provider to which AltirasPay introduces or submits a merchant.

Each Provider is independently owned and operated.

Each Provider controls its own:

Programs and services.

Merchant eligibility standards.

Documentation requirements.

Underwriting procedures.

Risk appetite.

Restricted and prohibited-business policies.

Legal and compliance review.

Merchant category coding.

Card-network registration.

Pricing and fees.

Reserve requirements.

Processing limits.

Funding schedules.

Account-setup procedures.

Fraud controls.

Transaction monitoring.

Chargeback monitoring.

Account restrictions.

Suspension and termination decisions.

AltirasPay does not own, operate, supervise, or control a Provider merely because AltirasPay markets the Provider’s services or introduces merchants to the Provider.

No Provider is responsible for another Provider’s rules, programs, underwriting decisions, or merchant accounts.

4. Provider-Specific Programs

Each Provider may apply different requirements to the same merchant or business category.

A merchant accepted by one Provider may be declined by another Provider. A rate, reserve, processing limit, registration, or account condition offered by one Provider does not automatically apply to any other Provider.

Provider requirements may vary based on:

Business category.

Products and services.

Ownership.

Jurisdiction.

Customer location.

Processing history.

Financial condition.

Transaction volume.

Average transaction amount.

Chargeback history.

Fraud exposure.

Fulfillment model.