QairoPay is a product of UpLevel Technologies LLC. We are not a bank and are not registered as a Money Services Business. Payment, card, and fiat conversion services are provided through licensed partners and are currently in test or pilot. Identity verification runs through Persona, and the USDC on-ramp runs through Bridge (by Stripe). We do not hold customer fiat directly.
Regulatory status
UpLevel Technologies LLC is a technology provider. It is not a bank, it is not registered with FinCEN as a Money Services Business, and it does not hold money-transmission licenses. Regulated activities are carried out by licensed partners under their own licenses and programs.
- Payments and fiat conversion: provided by licensed partners. These features are in test or pilot and are not generally available.
- Card issuance: the Spend Card is issued by a sponsor bank through a card-issuing partner. The program is in pilot.
- Future licensing: as the product grows, we will assess whether any registration or license is required for UpLevel Technologies LLC itself and will pursue it where it is.
QairoPay does not provide investment advice, brokerage services, or fiduciary custody.
KYC and KYB
Businesses that use payment or card features complete Know Your Business (KYB) checks before getting production access to those features. Where end users hold balances or cards, they complete Know Your Customer (KYC) verification first.
- KYB: entity documents and beneficial-ownership information, collected and checked through our verification partner.
- KYC: identity-document verification performed by Persona. We receive a verification result and audit trail.
- Review: verification outcomes that would lead to a denial or suspension are reviewed by a person.
BSA / AML and sanctions
Our licensed payment and card partners run anti-money-laundering and sanctions programs under their own licenses. We support those programs and comply with U.S. sanctions law in how we operate.
- Our Terms prohibit use of QairoPay by, or for, sanctioned persons and jurisdictions.
- We share information with our partners as needed for their monitoring and reporting obligations.
- We are working toward our own documented compliance program as payment features move beyond pilot.
Card program (PCI DSS)
The QairoPay Spend Card is issued by a sponsor bank through a regulated card-issuing partner and is currently in pilot.
- Our approach: we follow PCI DSS 4.0 practices and intend to complete the assessment that applies to our role before the card program leaves pilot. We do not currently hold a PCI DSS Report on Compliance or Attestation of Compliance.
- Primary Account Numbers (PANs) are not stored on systems we operate. Card data is handled by the card-issuing partner, and we store tokens in its place.
- Customer scope: integrators who handle a PAN on their own systems are responsible for their own PCI scope.
Stablecoin and on-chain compliance
QairoPay is building settlement of eligible flows in USD Coin (USDC) on the Aptos network. This feature is in test or pilot.
- On-ramp: fiat-to-USDC conversion runs through Bridge (by Stripe). Bridge holds the relevant licenses and performs its own KYC. We do not directly hold fiat in connection with the on-ramp.
- USDC: USDC is issued by Circle, not by us. USDC balances are not bank deposits and are not FDIC-insured.
Privacy regulation
We design our privacy practices around the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act as amended by the CPRA, and similar laws where they apply. See the Privacy Policy for full detail, including the lawful bases on which we process personal data and the rights available to data subjects.
- A Data Processing Addendum (DPA) is available to customers.
- Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum are used for cross-border transfers where required.
Consumer protection
Where the QairoPay Spend Card is issued to consumers, the program is designed to operate under Regulation E (electronic fund transfers) and applicable state laws. Cardholder agreements, error-resolution procedures, and disclosures are provided by the issuing bank.
Regional coverage
Our initial market is the United States. Payment and card features are in pilot and are not available in every state or country. Availability for any program is confirmed in the order form.
Audit and assurance
We have not yet completed any independent audit or certification. We follow the practices of the frameworks below and intend to pursue formal audits as the platform moves out of pilot:
- SOC 2 — we intend to pursue a SOC 2 examination.
- ISO/IEC 27001 — we intend to pursue certification.
- PCI DSS 4.0 — we intend to complete the assessment that applies to our role in the card program.
Contacting compliance
For diligence requests, regulatory inquiries, or compliance documentation, email [email protected]. For security questionnaires and vendor reviews, email [email protected].
Law-enforcement requests are handled at [email protected], subject to applicable law and our customer notice obligations.
This page summarizes QairoPay's compliance approach as of the date above. It is not legal advice and does not create rights beyond those granted in your executed contract. Where this page conflicts with executed contract language, the contract governs.