Draft for legal and processing-partner review. This document is not in effect, has not been approved by counsel or any payment provider, and does not create binding obligations. Bracketed items are unresolved and are tracked in the Launch Decision Register.

Acceptable Use Policy

Version 0.1 — Effective date: not set

1. Purpose and structure

1.1 This policy describes what merchants and users may not do with Orion Payments. It forms part of the Merchant Services Agreement.

1.2 It separates three kinds of restriction, because they have different sources:

  • Part A — Legal prohibitions: activities that are unlawful. These apply regardless of any provider.
  • Part B — Orion platform rules: conduct Orion does not permit on its platform.
  • Part C — Provider restrictions: categories, products or practices a specific provider does not accept. These vary by provider and are shown in each Provider Connection's Approved Scope.

1.3 A category that is lawful may still be restricted by a provider. A category a provider accepts may still be unlawful in a particular jurisdiction. Both must be satisfied.

Part A — Legal prohibitions

2.1 You must not use the Services in connection with any activity that is unlawful in Canada or in any jurisdiction where you sell, ship or market, including:

(a) sale of products or services that are illegal to sell, possess, market or ship to the destination; (b) fraud, deceptive marketing or misleading representations about products, prices or terms; (c) money laundering, terrorist financing or evasion of reporting obligations; (d) dealings with persons or jurisdictions subject to Canadian sanctions or, where applicable, other sanctions regimes; (e) use of stolen, compromised or unauthorized payment credentials or identities; (f) infringement of intellectual property rights; (g) sending commercial electronic messages without consent where consent is required.

Part B — Orion platform rules

3.1 Hidden merchants. You may only accept payments for your own approved business. You must not process payments for undisclosed third parties, aggregate other sellers' sales, or let others use your account or credentials.

3.2 Misdescription. You must describe your actual products, websites, fulfilment and business model accurately in applications, to providers and to customers. Using labels to disguise the nature of products is prohibited.

3.3 Sham transactions. You must not create transactions that do not represent a genuine sale, including transactions to move funds, test stolen credentials, inflate volume or obtain cash.

3.4 Circumventing underwriting. You must not:

(a) use a website, product category, payment method or country outside your Approved Scope; (b) split transactions to avoid limits; (c) re-apply under a different identity after a decline or termination without disclosing it; (d) ask for, or use, routing of transactions to another provider to avoid a decline, restriction or prohibition; or (e) misstate the merchant category or transaction model to a provider.

3.5 Unapproved categories. Categories not in your Approved Scope are not permitted until reviewed and approved.

3.6 Security abuse. No attempts to access other merchants' data, probe the API beyond your own resources, or bypass rate limits or authentication.

3.7 Customer harm. No refusing refunds that are owed under law or your own published policy, and no relying on a payment method (for example, blockchain transfers) as a blanket reason to refuse refunds.

Part C — Provider restrictions

4.1 Each provider publishes or contractually imposes its own prohibited and restricted lists and its own approval conditions. These apply to Transactions through that provider and are reflected in its Approved Scope.

4.2 Research-use-only products. Many providers restrict or prohibit research chemicals, peptides and similar products. A research-use-only label does not establish eligibility. Applications in this category are disclosed as such to providers and are approved only where a provider expressly accepts the specific merchant, products and marketing.

5. Enforcement

5.1 Orion may request information, restrict features, suspend a Provider Connection or terminate under the Merchant Services Agreement where it reasonably believes this policy has been breached. Orion may be required to inform providers.

5.2 Where lawful and practicable, Orion will give reasons and an opportunity to respond. Appeals are handled under the Complaints Policy.

6. Reporting

6.1 Report suspected misuse to [Support email to be confirmed] or security issues to [Security contact to be confirmed].