1 - NAME OF THE POLICY

The name of the Policy will be Inactive & Dormant Wallet Treatment Policy.

2 - PURPOSE

The purpose of this policy and procedure is to ensure that the inactive wallet accounts are deactivated and disabled and in a timely fashion to minimize the risk of unauthorized user access to such wallet accounts thus preventing intended fraud, together with providing necessary guidelines to the customers on how to deactivate their wallet accounts

3 - DEFINITIONS

3.1 - Active Wallet

A wallet shall be deemed Active, if it has no restrictions to login, and is able to perform transactions.

3.2 - Dormant Wallet

A Wallet shall be deemed Dormant, if there is no transaction within a specified period of time. The time period can be different as per the role of the User / Wallet. The maximum dormant period for a wallet account shall not exceed more than 10 years.

3.3 - Inactive Wallet

A Wallet shall be deemed Inactive, if both the login and transaction access has been disabled.

3.4 - Archived Wallet

A Wallet shall be deemed Archived, if there is no claim until the end of the dormant period.

4 - POLICY

This policy document shall comprise separate policies for treatment of Dormant Wallets and Inactive Wallets. Each policy covers the scope as : - Dormant Wallet Policy - This policy comprises the measures followed when a wallet account has no performance for a significant number of consecutive months - Inactive Wallet Policy - This policy comprises the measures followed when a wallet account has been disabled (deactivated) either voluntarily or involuntarily by the wallet customer

5 - DORMANT WALLET POLICY

5.1 - Definition

  • An account having no transactions within the last consecutive months shall be marked as dormant. The number of months for each category shall be as follows
  • Consumer - 18 months
  • POS/Dealer/SuperDealer - 6 months
  • Merchant - 6 months
  • An SMS / Email shall be sent to the user fifteen days (15 days) prior to the account becoming dormant.
  • A Dormant account shall be locked and login shall be disabled for such accounts.
  • An SMS / Email shall be sent to the user immediately after the account is marked dormant and locked for future logins.
  • A message shall be displayed as an acknowledgement for the user while trying to login.
  • No payments shall be received to or made from a dormant account thereafter.
  • Any automated payments, linked payments, merchant payments etc shall be disabled automatically, if an account gets dormant

5.2 - Dormant Period

The Dormant Period is defined to be 10 years plus 90 days from the day a wallet was marked as dormant.

5.3 - Reinstating a Dormant Wallet ?

In order to reinstate a dormant wallet account, following measures should be followed. Any claims after the period end shall not be considered eligible for reinstatement. (Ref. 5.4 Archived Wallet Policy)

5.3.1 - KYC Verified User

  • A written letter shall be required to re-enable a dormant account.
  • Along with the letter, the user must send each of the following
  • Photo of the account holder, holding their original ID
  • Proof of current residential address

5.3.2 - KYC Unverified User

  • User needs to verify mobile number with the OTP
  • User needs to provide at least two matching details of the transaction activity like Source of Load Funds, Some transactions, service payments made etc.
  • User needs to verify KYC and proceed other steps similar to the KYC Verified user.

5.3.3 - Deceased Person’s Wallet

  • Death Certificate issued from the Local Government Authority is mandatory.
  • Order of Claim shall be as per the following :
  • Nominee Information (if available in the wallet account);
  • Spouse;
  • Children;
  • Parents;
  • Siblings;
  • Any claims from individuals having a relationship within three generations and proof of relationship from Ward Office (First Come First Serve). The claim should also include a written disclaimer of unavailability of any other beneficiaries in the order mentioned above

5.4 - Archived Wallet Policy

If any claim is not made within 90 days after end of the Dormant Period, - The fund shall be transferred to the Company CSR or as per the policy of Nepal Rastra Bank if mentioned otherwise. - The Company shall be no more liable for any claim for funds by any individual consumer, agents/POS/Dealer, Merchant after the wallet is archived.

5.5 - Publication / Disclosure

The company shall publish a notice of reminder for appeal for reinstatement of a Dormant Wallet for those wallet accounts that have just crossed the dormant period. A grace period of 90 days shall be provided for the submission of reinstatement application.

The list of Dormant Wallet accounts within the 90 days grace period shall be provided through the company website.

6 - INACTIVE WALLET POLICY

A Wallet account shall be marked Inactive after deactivated voluntarily or involuntarily. In order to deactivate a wallet account upon owner’s request, following considerations are required.

6.1 - Voluntarily Deactivating a Wallet Account

A User can request for deactivation of an account through email or through our call center. Requirements are : - Application to deactivate the account and a Selfie with official ID shall be required in order to proceed with the deactivation. - A deactivation form shall be provided, if the user visits the head office (Note: Photocopy of a Government Issued Identity shall be required to be affixed along with the application form.)

6.2 - Automatic Deactivation

An account shall be deactivated automatically if - Any user who is identified as suspicious while using Khalti services by involving in any activities considered illegal as per prevailing law, regulatory bodies and any other government entities while investigating. - In case of Fraud, Scam attempt being reported by Banks, CIB, NRB, Police and any other regulatory authorities through written, oral or by using online platform which must be made by their official domain or sent through letterhead of their respective office along with the stamp and signature of authorized personnel, such account shall be deactivated in following manner - Official letter received from one of the following - Regulatory Authority identified by the Government of Nepal - Rule of Law enforcement authorities viz. Nepal Police, CCB, CIB, etc - Bank and Financial Institution (BFI) if the mentioned account has performed any transaction concerned to the particular BFI - In case a user is found to be involved in suspicious transactions detected by some irregular patterns of activities through his / her account. - If an account is dormant as per the Dormant Wallet Policy (Ref. 5), such an account shall remain inactive, and the user can’t login unless reinstated

6.3 - Reinstating a deactivated account

A deactivated account shall never be activated, if it was previously deactivated for following reasons: - Requested by a government authority. - Requested by a court in Nepal - Requested by a regulatory body in Nepal - If the user is found to be involved in activities deemed illegal as per prevailing Nepalese laws.

However, an Inactive Wallet account may be reinstated if, - User had deactivated the Wallet account by themselves earlier, - If any claim to deactivate the Wallet account is nullified by the previous authority, regulator, bank, etc. - If any activity deemed suspicious earlier was no longer found to be suspicious.

7 - DATA RETENTION

Transactions and other information for the account shall be retained for minimum 10 years or as per the regulatory requirements then after that it will be deleted.

If any account is deactivated, another account with the same Khalti ID can never be created again unless reinstated.

8 - DATE OF EXECUTION AND AMENDMENT

This procedure relating to the Inactive and Dormant Wallet Treatment Policy shall be effective after approval by the directors from 1st Bhadra, 2078. Any amendment to any of this procedure shall be approved by the Board of Directors.