Customer Safeguard Policy
Standards for protecting customer money, information, access, and the right to seek help.
This policy sets required company standards. A product may be offered only when its applicable controls and provider arrangements are in place. It does not replace product-specific agreements or mandatory legal rights.
Purpose and scope
Turi Ventures LLC requires safeguards proportionate to the products offered through TuriPay. This policy covers accurate customer records, lawful handling of funds, access security, sensitive information, provider oversight, and fair treatment when something goes wrong. It sets standards for relevant company activities and for the arrangements required from product providers.
Understand who provides the service
The applicable product agreement must identify the entity responsible for card issuance, custody, payment processing, or other regulated financial activity. TuriPay is not represented as a bank. A USD balance shown in an app does not, by itself, establish a bank deposit, a trust, insurance coverage, or protection against insolvency. No product may claim deposit insurance or statutory safeguarding solely because a provider or intermediary has a banking relationship.
Customer-money arrangements
Before a product accepts customer funds, the company must document the responsible holder, flow of funds, customer entitlements, applicable segregation or equivalent protections, settlement process, access rights, and treatment on termination or insolvency. Required customer funds must not be used as company operating money or to cover another customer’s shortfall. The legal structure and any limitations must be disclosed for the particular product; this policy does not assert that an unconfirmed custody or trust arrangement already exists.
Reconciliation and transaction integrity
The company requires complete records that distinguish available amounts, pending deposits, reserved payments, completed settlements, reversals, refunds, and disputes. Reconciliation against appropriate provider or banking evidence must be performed at a frequency suited to the product’s risk, with daily checks where customer-fund flows warrant them. Differences must receive an owner, investigation, escalation, and documented correction. Unsupported credits or silent balance changes are prohibited.
Information security and confidentiality
Sensitive information must be protected using appropriate access controls, encryption, stronger authentication, secure development, monitoring, and vendor controls. Collection and use must be limited to legitimate purposes and applicable law. Staff must not request passwords, one-time codes, or full card security details through support. Security controls must be tested and incidents handled through an assigned response process. Where the FTC Safeguards Rule applies, the company must meet the applicable written-program and related requirements.
Fair controls and access to money
A review or restriction must have a lawful and documented reason, be proportionate to the risk, and be reassessed when new information is available. Customer communications must explain the issue and available next steps to the extent permitted. Remaining funds must be returned or otherwise handled under the applicable agreement and law when an account closes. Sanctions-blocked property must not be returned or released without lawful authority.
Provider failure, continuity, and exit
Provider contracts and contingency plans must address outages, security incidents, access to records, dispute cooperation, continuity, and the return or lawful transfer of customer entitlements. If a provider fails or service is suspended, the company must preserve records, stop affected new activity when appropriate, assess customer impact, and communicate known facts. Recovery timing depends on the arrangement and legal process; the company must not promise guaranteed or immediate recovery.
Complaints, disputes, and vulnerable customers
Customers must have accessible ways to report missing funds, unauthorized activity, data concerns, and service problems. Requests must be routed without unnecessary barriers, with assistance where accessibility or vulnerability creates a reasonable need. The Chargeback, Refund, and Complaints Policies apply alongside mandatory consumer protections. A good-faith complaint must not result in retaliation or a requirement to give up an applicable legal right.
Oversight and contact
Management must assign responsibility for customer protection, review reconciliations and incident trends, challenge provider performance, and track corrective actions. This policy must be reviewed at least annually and after material changes. Report an urgent concern through official in-app support or support@turipay.com using a transaction or account reference and a clear description, without sending sensitive credentials.
Company and contact
Turi Ventures LLCRegistered in Wyoming, United States30 North Gould StreetSheridan, WY 82801, United Statessupport@turipay.comFor sensitive evidence, request an approved secure channel before sharing documents.
Reference materials
These official resources provide background. Requirements depend on the product, activity, and applicable law.
Management is responsible for assigning policy ownership, maintaining supporting procedures, reviewing these standards at least annually, and updating them when material requirements change.