Verification & Trust Policy

Effective Date: 1 July 2026Last Updated: 1 July 2026

This Verification & Trust Policy (the “Policy”) forms part of the contractual framework governing the use of the OXLY platform (the “Platform”) operated by IN SPOT SLU, a company organized under the laws of the Principality of Andorra, with registered office at Carretera d’Engolasters 27A 2-1, Andorra, tax / registration number L-919089-T (“OXLY,” “Company,” “we,” “us,” or “our”).

This Policy applies to any verification, identity, business, trust, badge, KYC, KYB, document review, account review, category review, or related trust and safety process made available by or through the Platform.

This Policy supplements the Terms of Platform Use, the Provider Terms, the Payments & Payout Terms, the Privacy Policy, the Acceptable Use & Prohibited Activities Policy, the Community Standards, and any other applicable OXLY policies. If there is a conflict between this Policy and a more specific feature-level or category-level rule, the more specific rule will control for that feature or category to the extent permitted by law.

By creating an account, applying for a badge, completing any verification flow, submitting documents, enabling payment functionality, or otherwise using any trust-related feature of the Platform, you agree to this Policy.

1. Purpose of This Policy

The purpose of this Policy is to explain:

• what verification and trust features may exist on the Platform;
• what a “verified” badge or other trust signal means;
• what information or documents the Company may request;
• how risk-based verification may work;
• what KYC and KYB checks may include;
• when a badge may be granted, limited, removed, or re-reviewed;
• what the Company does not guarantee.

The Platform may use trust and verification tools to improve transparency, reduce fraud, support safer transactions, comply with legal or payment-provider requirements, and protect users and the Platform. However, verification is not a guarantee of legality, quality, safety, performance, or suitability.

2. Definitions

For the purposes of this Policy:

“Verification” means any process used by the Company or its third-party providers to collect, review, validate, compare, or assess information relating to a User, Provider, Employee, business, service category, or activity.

“KYC” means any know-your-customer, identity verification, or individual verification process used to assess a natural person.

“KYB” means any know-your-business, legal entity verification, or business verification process used to assess a company, legal entity, sole trader, or business profile.

“Verification Badge” means any label, badge, icon, marker, or trust signal displayed on the Platform indicating that a User, Provider, account, business, category, or profile has completed a particular verification flow or review process determined by the Company.

“Risk Tier” means the category assigned by the Company to a user type, service type, business category, or activity for trust, safety, verification, payment, moderation, or compliance purposes.

“Verification Provider” means any third-party service provider used by the Company to support identity checks, document review, business verification, liveness checks, sanctions screening, fraud prevention, or related verification functions.

3. General Nature of Verification

The Platform may offer one or more trust and verification features, including without limitation:

• email verification;
• phone verification;
• identity verification;
• business verification;
• tax or payout-related verification;
• category-specific or enhanced review;
• document review;
• risk-based re-verification;
• badge display on profile or service pages.

Verification may be mandatory, optional, conditional, staged, category-specific, country-specific, feature-specific, or dependent on risk, regulation, or payment-provider requirements.

The Company may choose whether to offer any badge, verification flow, or trust signal at all.

4. What “Verified” Means

A Verification Badge means only that the relevant User, Provider, business, or account has completed a particular verification flow or review process designated by the Company or its Verification Provider at a given time.

Unless the Company expressly states otherwise in writing for a specific badge type, “verified” does not mean that the Company guarantees:

• the person is exactly who they claim to be in all circumstances;
• the business is legally compliant in all respects;
• a license, permit, or insurance remains valid at all times;
• a provider is trustworthy, safe, competent, or suitable for every customer;
• a provider’s services are lawful in every jurisdiction;
• the quality, timing, or outcome of any service;
• the absence of fraud, misconduct, or future changes in status.

A badge reflects a limited verification scope only.

5. Verification Badge Types

The Company may display different badges, statuses, or trust signals, including for example:

• email verified;
• phone verified;
• identity verified;
• business verified;
• category reviewed;
• document reviewed;
• enhanced verification completed;
• trusted provider;
• another label chosen by the Company.

The Company may add, rename, remove, combine, redesign, limit, or discontinue any badge or trust signal at any time.

Different badges may reflect different scopes of review. A User must not assume that all badges imply the same level of validation.

6. Risk-Based Verification Model

The Company may apply a risk-based verification model to Users, Providers, business types, service categories, payout access, or other Platform activity.

Without limiting the Company’s discretion, the Platform may use a structure broadly similar to the following:

6.1 Low Risk

Low-risk categories may include, for example:

• design;
• copywriting;
• software or IT development;
• language tutoring;
• marketing and similar digital services.

Low-risk review may include basic KYC measures such as:

• email verification;
• phone verification;
• account consistency checks;
• identity confirmation where required.

6.2 Medium Risk

Medium-risk categories may include, for example:

• electronics repair;
• delivery;
• business consulting;
• B2B services;
• accounting or similar business services.

Medium-risk review may include:

• KYC for the individual account holder;
• business information review;
• company registration review;
• tax or VAT/TIN-related review where relevant;
• payout-related verification.

6.3 High Risk

High-risk categories may include, for example:

• healthcare-related services;
• legal services;
• finance or investment-related services;
• services involving children or vulnerable persons;
• construction or other heavily regulated or safety-sensitive categories.

High-risk review may include:

• enhanced KYC;
• KYB;
• professional license review;
• insurance review;
• category-specific compliance review;
• enhanced manual checks or document requests;
• feature restrictions pending review.

The Company may change risk classifications, category groupings, verification thresholds, or onboarding requirements at any time.

7. Individual Verification (KYC)

Where KYC is used, the Company or its Verification Providers may request information or documents relating to an individual User or account holder, including without limitation:

• legal name;
• date of birth;
• address or residence information;
• email address;
• phone number;
• government-issued identification;
• photo of ID document;
• back side of ID document where relevant;
• selfie, liveness check, or manual photo comparison where relevant;
• tax or payout-related information;
• sanctions, fraud, or watchlist screening information where permitted by law.

The exact KYC process may vary by jurisdiction, category, feature, risk level, payment setup, and Verification Provider.

8. Business Verification (KYB)

Where KYB is used, the Company or its Verification Providers may request information or documents relating to a business, legal entity, or business operator, including without limitation:

• registered business name;
• registration number;
• tax number;
• business address;
• country of incorporation or operation;
• legal representative information;
• beneficial ownership information;
• directors, controllers, or associated parties;
• proof of legal existence;
• company documents;
• tax status or VAT/TIN data;
• bank or payout-related information;
• professional or category-specific authorizations where relevant.

The Company may also request information about ownership and control structure where relevant to compliance, fraud prevention, payout enablement, or category risk.

9. Additional Documents and Enhanced Review

The Company may request additional information or documents at any time where reasonably necessary for trust, safety, verification, legal compliance, fraud prevention, payment-provider requirements, risk review, or operational integrity.

This may include, without limitation:

• updated identity documents;
• updated business registration documents;
• proof of address;
• proof of ownership or control;
• proof of tax registration;
• proof of insurance;
• professional licenses;
• permits or authorizations;
• supporting explanations;
• source-of-funds or business-purpose information where legally required;
• any additional documents reasonably needed to assess risk or eligibility.

The Company may also require manual review or category-specific review for sensitive or restricted services.

10. Re-Verification and Ongoing Review

Verification is not necessarily permanent.

The Company may require re-verification or updated documents where reasonably necessary, including for example when:

• laws or regulations change;
• payment-provider requirements change;
• the User changes jurisdiction or service category;
• account information changes materially;
• a document expires;
• a complaint, dispute, fraud signal, or safety issue arises;
• the User seeks access to a higher-risk category or feature;
• the Company reasonably believes that previous verification is no longer sufficient.

A badge may be removed, downgraded, paused, or hidden during re-verification.

11. Verification Outcomes

After a verification process, the Company may decide, in its sole discretion and subject to applicable law, to:

• approve the relevant verification step;
• grant a badge;
• grant partial or limited verification status;
• request additional information;
• deny a badge;
• restrict access to certain categories or features;
• delay or deny payout functionality;
• remove an existing badge;
• suspend or terminate relevant functionality or the account.

A User does not acquire a right to a badge merely by submitting documents or entering a verification flow.

12. If Verification Is Not Completed or Not Passed

If a User does not complete, fails, abandons, or does not pass a verification process:

• the User may lose access to certain features;
• the User may remain unverified;
• the User may be restricted from using certain categories, payment flows, or trust-sensitive features;
• payout access may be delayed or blocked where relevant;
• badge display may be denied or removed.

Unless the Company decides otherwise, failure to obtain a Verification Badge does not automatically mean the User is banned from the Platform. However, the Company may impose restrictions based on category, feature, jurisdiction, law, or risk.

13. Verification Providers and Third Parties

The Company may use third-party Verification Providers to support verification and trust functions.

The Company may share relevant personal or business data with such providers where reasonably necessary and lawful, subject to the Privacy Policy and applicable data protection law.

The Company does not guarantee the uninterrupted availability, timing, or outcomes of third-party verification systems. Verification Providers may apply their own technical and operational rules, error thresholds, fraud signals, and document acceptance logic.

14. Verification Does Not Replace User Judgment

Users remain solely responsible for evaluating whether another user, provider, or service is suitable for their needs.

Even where a badge is displayed, the User must exercise independent judgment and caution.

The Company does not guarantee that:

• a verified person will act honestly;
• a verified provider will perform properly;
• a verified business is financially sound;
• a reviewed license will remain valid after the review date;
• a user will remain compliant after verification.

Verification is one signal, not a guarantee.

15. Prohibited Conduct in Verification Processes

Users must not misuse verification or trust features.

Prohibited conduct includes, without limitation:

• submitting forged or altered documents;
• submitting someone else’s documents without authorization;
• using fake identities or synthetic identities;
• impersonating a company, legal representative, or beneficial owner;
• providing misleading business data;
• hiding beneficial ownership where disclosure is required;
• using false addresses, phone numbers, or tax data;
• manipulating selfies, liveness checks, or image-based verification processes;
• misusing badges in listings, messages, or off-platform materials;
• falsely claiming to be verified when the Platform does not show such status.

Such conduct may result in immediate badge removal, feature restrictions, payout restrictions, suspension, termination, and referral to competent authorities where appropriate.

16. Display and Visibility of Trust Signals

The Company may decide where and how badges or trust signals are displayed, including for example:

• on a profile;
• on a business page;
• on a service card;
• in search results;
• in a booking flow;
• in messages;
• in a dashboard or internal review tool.

The Company may also choose not to display certain internal verification outcomes publicly.

Internal trust review, fraud scoring, compliance status, or risk classification may exist without being shown to other users.

17. Badge Removal, Suspension, and Downgrading

The Company may remove, suspend, downgrade, or hide any Verification Badge at any time where reasonably necessary, including where:

• the underlying data becomes outdated;
• a document expires;
• a complaint or fraud alert arises;
• the account is under investigation;
• the verification was incomplete, mistaken, or no longer reliable;
• the User changes category, structure, or operating model;
• the law, payment framework, or internal policy changes.

The Company is not required to maintain a badge for any minimum period.

18. Enforcement and Protective Measures

Where the Company reasonably believes that a User has violated this Policy or that a trust, fraud, compliance, payment, or safety issue exists, the Company may take one or more actions, including without limitation:

• request clarification or documents;
• pause a verification flow;
• deny a badge;
• remove a badge;
• restrict category access;
• disable booking, messaging, or visibility features;
• delay, reserve, offset, freeze, or withhold payouts where permitted by law and the applicable payment terms;
• suspend or terminate a role, profile, or account;
• preserve records and evidence;
• cooperate with competent authorities, payment providers, or service providers where lawful and reasonably necessary.

Where reasonably practicable, the Company will generally seek to issue a warning first. However, immediate action may be taken where necessary for fraud prevention, legal compliance, safety, payment risk, or urgent trust and safety reasons.

19. Appeals and Requests for Review

If a badge is denied, removed, suspended, or downgraded, or if access to a verification-gated feature is restricted, the affected User may request review or appeal through the process made available by the Company.

Submitting an appeal does not guarantee reversal. The Company may uphold, modify, or reverse its original decision in its sole discretion, subject to applicable law.

The Company may request additional documents or explanations as part of the review.

20. Privacy and Data Protection

Verification data may include personal data, business data, and sensitive compliance-related materials.

Such data will be processed in accordance with the Privacy Policy, applicable law, and the operational requirements of the relevant verification, payment, fraud-prevention, or trust and safety flow.

Verification documents and related data may be retained for as long as reasonably necessary for:

• verification decisions;
• re-verification;
• fraud prevention;
• payout enablement;
• legal compliance;
• dispute resolution;
• defense of rights;
• recordkeeping obligations.

21. No Warranty and Limitation of Reliance

To the maximum extent permitted by law, the Company disclaims all warranties, representations, and conditions relating to verification, badges, or trust signals, whether express, implied, statutory, or otherwise.

In particular, the Company does not warrant that:

• any verification process is error-free;
• any badge reflects complete or permanent compliance;
• any document submitted is genuine in all respects;
• any verification result eliminates fraud or safety risk;
• any badge guarantees legal eligibility, licensing, insurance, quality, honesty, or service performance.

Users must not rely on badges as a substitute for their own judgment, due diligence, or risk assessment.

22. Indemnity

You agree to defend, indemnify, and hold harmless the Company, its affiliates, officers, directors, employees, contractors, agents, licensors, and Verification Providers from and against any claims, proceedings, liabilities, damages, losses, costs, and expenses, including reasonable legal fees, arising out of or related to:

• false or misleading verification submissions;
• forged, altered, or unauthorized documents;
• misuse of badges or trust signals;
• your breach of this Policy;
• your violation of law in connection with verification, business status, licensing, or regulated activity.

23. Changes to This Policy

The Company may update this Policy from time to time.

If material changes are made, the Company may notify users by:

• posting the updated version on the Platform;
• updating the Effective Date or Last Updated date;
• email notice;
• in-app notice;
• account notice; or
• another reasonable communication method.

Continued use of the Platform after the effective date of the revised Policy constitutes acceptance of the updated version.

24. Governing Law and Jurisdiction

This Policy is governed by and shall be interpreted in accordance with the laws of the Principality of Andorra, without regard to conflict-of-law principles.

Any dispute arising out of or in connection with this Policy shall be submitted to the competent courts of Andorra, unless mandatory consumer protection law requires otherwise.

25. Contact

IN SPOT SLU

Carretera d’Engolasters 27A 2-1, Andorra

Tax / Registration No.: L-919089-T

Legal contact: a.samoylov@inspot.ad

Support contact: help@oxly.eu