General Structure Of Terms And Conditions On Websites

General Structure of Terms and Conditions on Websites E-Wallet Apps and Websites generally have terms prescribing the general use of the website along with the nature of information which may be uploaded by the user. It also prescribes the requirement of adhering to the site’s privacy policy, preservation of copyrights and prohibited conduct. It also portrays the safety norms followed by the site for the purposes for account creation and its maintenance. These sites then have the standard disclaimer, termination of account, limitation of liability and dispute resolution clauses.

Unique Clauses in E-Wallet Sites • 1. Single Sign-On Clause -Need to log in only once and whether it shall apply to affiliates of the site. • 2. Telecommunication Service Clause - Charges of the carrier will apply wherever texts/mobile services are needed. • 3. Refund Policy -No refunds on bill payments, or other transactions for which the site/app is used as a payment facilitator. • 4. Site Specific/ Coupon Redemption - Conditions relating to the same/their limited applicability. • 5. KYC -Explains what KYC is, and the requirement of compliance with RBI Guidelines in order to upgrade/open an account. • 6. Minimum Balance/Dormant Account -Certain minimum amount or activity to keep the account active.

Rarity of Unique Clauses

15 13 11 9 7 5 3 1 -1

Best Practices

Worst Practices

Suggestions • 1. All sites should have RBI limits displayed in the terms and conditions. • 2. The wallets should disclose the names of all of its affiliates where the user can use the wallets, and helps determine the user whether to opt for its service or not. • 3. All e-wallets, if accessible by users in India, should explicitly state whether they are RBI compliant or not and consequently whether any limits apply on the users’ accounts or not.