know your customer policy (KYC)

1. Introduction

At Mcubes Online (a division of Hellobugs Entertainment), we value the trust and safety of our customers, tutors, and partners.
As part of our ongoing commitment to maintaining transparency, security, and integrity within our platform, we implement Know Your Customer (KYC) and Fraud Prevention measures for all users engaging in purchases, payments, and identity-related interactions on our websites and mobile applications.

This policy outlines how Mcubes Online collects, verifies, processes, stores, and secures customer identity data in accordance with Indian Information Technology Laws, RBI guidelines, and international data protection standards like GDPR.

2. Objective

The primary objectives of the Mcubes KYC & Fraud Prevention policy are:

• To prevent fraud, identity theft, and payment abuse.
• To ensure authenticity of all transactions, protecting both customers and merchants.
• To comply with legal requirements, including the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and Reserve Bank of India (RBI) Guidelines on Digital Payments.
• To identify, verify, and monitor user accounts, ensuring that all transactions are performed by verified and genuine individuals.

3. When KYC Verification is Required

KYC verification may be required in the following scenarios:

First time purchase, abnormal activity, high value purchase and other reasons.

4. Type of Data Collected

During KYC verification, we may collect and verify the following details:

5. Verification Methods

Mcubes Online utilizes automated and manual KYC verification systems through licensed third-party identity verification partners such as:

• IDfy (Bureau IDfy Technologies Pvt. Ltd.) – For real-time ID document verification and face matching.
• Cloudflare – For bot mitigation and proxy detection.
• Payment Gateway Providers (Razorpay, Stripe) – For 3D Secure, device fingerprinting, and risk scoring.

These tools collectively ensure that both users and transactions are validated against a combination of:

• IP location tracking
• Browser fingerprinting
• Device identification
• KYC document validation
• Payment pattern recognition

6. Purpose and Legal Basis for Data Processing

We collect and process KYC data for the following legitimate purposes:

1. To validate user identity and ensure authenticity of accounts.
2. To comply with RBI and Indian Financial Laws.
3. To investigate suspicious or fraudulent activity.
4. To enable secure refund and payout processes.
5. To maintain internal risk management and fraud analysis databases.

Data is collected under the following lawful bases:

• Consent (Section 43A of IT Act, 2000) – Explicit consent from the user before verification.
• Legal Obligation – To comply with digital transaction laws and anti-money laundering guidelines.
• Legitimate Interest – To prevent misuse, chargebacks, and platform fraud.

7. Data Handling and Retention

• KYC data is stored only as long as required for verification and audit purposes.
• Raw ID images or biometric data are never permanently stored on Mcubes Online servers.
• Data shared with third-party verification partners (e.g., IDfy) is handled under encrypted channels (AES-256/SSL).
• Upon completion, verification data is securely purged after 30 days unless legally required to retain for disputes.
• All records are processed under ISO 27001-compliant security frameworks.

8. Fraud Detection Rules

To enhance payment security, Mcubes Online enforces the following fraud screening rules (via FraudLabs & internal algorithms):

1. IP & Billing Country Mismatch: Transaction placed from outside billing country triggers review.
2. High Threat Score: Orders above a predefined risk score undergo manual review.
3. Proxy/VPN Detection: If proxy is detected, order is automatically held.
4. Multiple Orders from Same IP: Orders from same IP within 24 hours undergo verification.
5. Email or Phone Mismatch: Disposable or unverified contact information triggers manual KYC.

9. Failed or Rejected KYC

If your KYC submission fails or appears suspicious, the following policies apply:

• The order will remain on hold until verification is successfully completed.
• If verification fails permanently, the order will be cancelled and a refund processed within 30 working days after deducting administrative charges of ₹50 or payment gateway fees (whichever is higher).
• If fraudulent or forged documents are submitted:
  • The account will be permanently banned.
  • A penalty of ₹500 (or USD $5) will apply for misuse.
  • The user may be reported to relevant law enforcement authorities under Sections 420 and 468 of the Indian Penal Code.

10. Refunds in Case of KYC Failure

Refunds in case of failed or refused verification will follow these conditions:

• Refunds will be initiated only after deduction of payment processing fees.
• Refunds will be credited to the original payment method within 30 business days.
• Orders under manual review or flagged for fraud will not be shipped or activated until approved.
• Refunds are processed only if no course access or product dispatch has occurred.

11. Data Security and Confidentiality

We maintain strict administrative, technical, and physical safeguards to protect user data:

• All data transmissions are encrypted via SSL/TLS 1.3.
• User identity data is accessible only to authorized verification officers.
• Our service providers are bound by NDA (Non-Disclosure Agreements) and Data Protection Addendums (DPA).
• Mcubes Online complies with:
  • Information Technology Act, 2000 (India)
  • IT Rules 2011 – Sensitive Personal Data
  • GDPR (EU Regulation 2016/679) for global data processing.

12. Third-Party Disclosure

Mcubes Online does not sell, rent, or trade user data.
We share information only with trusted and legally compliant entities for verification or payment processing purposes, including:

• IDfy (Identity Verification)

Each partner is subject to its own data protection compliance and contractual confidentiality obligations.

13. Dispute & Legal Liability

If a transaction dispute arises after KYC verification:

• Mcubes Online will share verified KYC data with the payment gateway for dispute resolution.
• Users initiating false or fraudulent disputes after delivery or course access will be banned permanently.
• As per the RBI Guidelines, any verified transaction through 3D Secure or UPI is considered final and non-reversible.

Even if a dispute is closed in Mcubes’ favor, a chargeback handling fee may still apply per the payment gateway’s policy.

14. Customer Responsibilities

Users are required to:

• Provide accurate and up-to-date identity details.
• Refrain from using false documents, shared accounts, or VPN connections during transactions.
• Complete KYC verification within the stipulated timeframe when requested.
• Use payment instruments legally owned by them.

Failure to adhere to these conditions may lead to account suspension or permanent restriction.

15. Enforcement and Penalties

To safeguard our business and community:

• Fake or mismatched KYC submissions will lead to account blacklisting.
• Repeat fraud attempts will result in penalty with minimum amount of 500 INR and permanent ban.
• We reserve the right to pursue civil or criminal action under:
  • Section 66D of the IT Act, 2000 (Cheating by Impersonation)
  • Section 420 of IPC (Cheating and Dishonesty)
  • Section 468 of IPC (Forgery for Purpose of Cheating)

16. User Consent

By registering, purchasing, or using Mcubes Online’s platform, users explicitly agree to:

• Provide accurate identity information when requested.
• Allow Mcubes to verify identity through authorized partners.
• Permit temporary storage and secure processing of KYC data for fraud prevention.

Users who disagree with this policy should not proceed with purchases or account creation.

17. Policy Updates

Mcubes Online reserves the right to update or modify this policy at any time to comply with evolving legal, technological, or security standards.
Users will be notified of any material changes via email or website updates.

18. Contact Information

📧 Email: howdy@themcubes.in