Compliance · Albert Connect

Compliance

Version 2.0

20 October 2026

Reviewed every year

What Albert Connect does, what it does not do, and how a payment is collected, held and paid out.

Every payment is processed by Tazapay, a licensed payment provider, into Albert Connect Company's own account with Tazapay. Albert collects as the agent of the partner who is paid, holds the funds until the deal is delivered, then pays that partner out.

01 · Purpose and scope

What this document is. And what it is not.

This document describes the procedures Albert Connect Company ("Albert") applies to know who uses its marketplace, to keep a record of what is traded on it, and to detect and escalate suspicious activity. It applies to every partner account, every listing and every deal on Albert Connect, and to every member of Albert's team.

Albert is not a financial institution. Albert is not a bank and does not take deposits. Payments are processed by a licensed payment provider, Tazapay. This document is not a regulated anti-money laundering program of the kind required of financial institutions. It is the set of controls Albert applies to its own platform and to the funds it collects for its partners.

02 · What Albert is

A marketplace. That collects for its partners.

Albert Connect is a closed, business-to-business marketplace for concierges and luxury service professionals. A partner posts what a client needs, or what they have to offer; other partners answer with a price; the two agree in writing. Albert earns a commission on a deal concluded on the platform, 3% at the date of this document.

Albert is not a financial institution. Albert is not a bank and does not take deposits. Payments are processed by a licensed payment provider, Tazapay. Albert collects the price of a deal only as the agent of the partner who is paid, holds it only until that deal is delivered, and pays it out only to that partner.

What Albert does

Operates the marketplace software: accounts, listings, offers, agreements between two professionals.

Reviews and approves every partner before they can trade, and can suspend an account.

Collects the price of each deal through Tazapay into its own account with Tazapay, as the agent of the partner who is paid.

Holds the funds until delivery is confirmed, the holding period has passed and no dispute or refund request is open.

Calculates its commission and fees, deducts them at release, and pays the partner out through Tazapay.

Sends every payout with its documents: the invoices for the deal and the records of the partner's approval.

Keeps the written record of each deal: listing, offers, agreement, quote, payment, payout, invoices.

Monitors activity on the platform for the warning signs listed in section 6 and escalates them.

What Albert does not do

It does not sell the service. Albert is an intermediary between two professionals, never the seller, and has no relationship with the partners' end clients.

It does not keep an account, a balance or a wallet for partners or for their clients, does not take deposits and does not pay interest.

It does not use the funds collected for a deal for anything other than paying the partner, refunding the payer, and taking its commission and fees.

It does not process cards or see card details: a card is entered in Tazapay's secure form.

It does not pay out to an individual in a personal capacity: only to a company or another legally registered business, in its own name.

It does not refund a payment once the payout for it has been sent: any claim is then between the payer and the partner.

03 · Payments

Collected, held and paid out through Tazapay.

Collection

Every payment is processed by Tazapay, a licensed payment provider, and paid into Albert Connect Company's own account with Tazapay. Albert collects as the agent of the partner who is paid, under the collection mandate in section 9.1 of the Terms of Use. Payment to Albert is payment to the partner. The payment is not split at checkout and is not taken in the partner's name.

Holding and release

Albert releases the funds when the receiving partner has confirmed delivery, the holding period shown on the deal has passed (72 hours after the date of the service unless the deal shows otherwise), and no dispute or refund request is open. Where the payer paid by card or another local payment method, Albert may keep back up to 10% of the sum for up to 45 days, matching the rolling reserve Tazapay keeps on Albert's account. A payment can be refunded only while Albert still holds it.

Commission and fees

Albert calculates its commission (3% at the date of this document) and any platform fees, and deducts them at release. The cost of processing a payment is carried by the payer: it is added to the amount charged and shown before payment, inside the price on an all-in quote. Tazapay's fee for sending a payout is deducted from the payout.

Payouts

Albert sends each payout from its account with Tazapay, by bank transfer, to the bank account of the partner's company. Every payout carries its documents: the invoices for the deal, and the records of the partner's approval, including acceptance of the Terms of Use, the offer accepted, and the payment and delivery records.

Partners and Tazapay

Partners are not customers of Tazapay, and Tazapay does not verify them on Albert's behalf. Albert registers each paid partner's company with Tazapay as a payout beneficiary: legal name, registered address, registration number, trade licence or tax identification number, and bank details. Tazapay screens beneficiaries and payouts on its side, including against sanctions lists, and Albert follows its decisions.

Tazapay's licences

Tazapay US Corp. is registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury, and Tazapay Pte. Ltd. holds a Major Payment Institution licence from the Monetary Authority of Singapore. The current list is published by Tazapay at tazapay.com/licenses.

04 · Onboarding of partners

A closed network. A person reads every application.

Closed network

Nobody can trade on Albert Connect without an approved account. There are no anonymous or guest accounts for trading.

Application

Each applicant states who they are, their company, their role, their city and country, and a contact number.

Human review

Every application is read and decided by a member of Albert's team. Who may approve which kind of application is fixed by role in the system and enforced by it, not left to the reviewer.

Terms of Use

Before using the marketplace, each partner accepts the Albert Connect Terms of Use. The version accepted, the date and the account are recorded. When a new version is published, every partner must accept it again before continuing. The Terms set out what may and may not be traded and require partners to act lawfully in their own jurisdiction.

Professional profile

Each partner completes a professional card (activity, places covered, what they can provide) before taking part in a deal.

Company and bank details

Before being paid, a partner gives the company's legal name, its registration, trade licence or tax identification number, its registered address, an invoicing email, and a bank account held in the company's own name. Albert may ask for documents that support them, such as a certificate of incorporation, a trade licence, a tax registration or a bank letter, and may hold a payout until it is satisfied.

05 · Records of activity

Every step, written and kept.

Every step of a deal is written and kept: the listing, each offer and counter-offer with its amounts, the agreement between the two partners, the quote, the payment, the payout, the invoices, each numbered, and each acceptance of the Terms of Use. Amounts used for documents and fees are read from the agreed terms held by the system, not from what a user's device sends. Changes to requests are logged. These records are kept for at least five years after the end of the relationship with a partner.

06 · Monitoring

Warning signs. What makes us look closer.

Designated team members with an oversight role can see all listings, offers and deals. Listings pass an automated content check when they are posted. Partners can report or block another partner from within the product, and reports are reviewed by the team. The team treats the following as warning signs that call for a review of the account and of the deal:

A deal whose price bears no relation to the service described, or a service that cannot plausibly be delivered.

A request to pay or be paid by a third party unrelated to the deal, or in a country unrelated to either partner.

Repeated deals between the same two accounts with no visible service, or deals cancelled and re-created at different amounts.

A partner who refuses to say who they are, who gives information that does not match, or who appears to act for somebody else without saying so.

Pressure to move a payment off the record, to split it without reason, or to use cash or crypto-assets.

A link to a person, entity or country subject to sanctions.

07 · Sanctions and escalation

Who we refuse. What we do when something is wrong.

Albert does not knowingly admit or keep as a partner any person or entity that is subject to United States, United Nations, European Union or United Kingdom sanctions, or that is resident in a comprehensively sanctioned country or territory. The country of each applicant is recorded at application and checked by the reviewer. Albert screens accounts and transactions against those lists and for signs of financial crime, and may suspend an account or hold funds where a result requires it. Tazapay screens payments, beneficiaries and payouts on its side.

Report

Any team member who notices a warning sign reports it to the compliance lead the same day.

Review and suspend

The compliance lead reviews the account and the deal, and may suspend the account immediately. A suspended account cannot post, answer or conclude deals.

Payment provider

Where a payment or a payout is concerned, Albert holds the funds, informs Tazapay and follows its instructions.

Authorities

Albert cooperates with lawful requests from competent authorities and keeps a written record of each review and of its outcome.

08 · Team and document

Who answers for it.

Access to partner data and to oversight functions is granted by role and limited to those who need it. Every team member with such access reads this document when they join and after each revision.

Company

Albert Connect Company, a Delaware corporation (file number 10768163), 131 Continental Dr, Suite 305, Newark, Delaware 19713, United States.

Compliance lead

Arthur Dimeglio, Co-Founder and Chief Technology Officer.

Approved by

Romain Sihou, Co-Founder and Chief Executive Officer.

Version

2.0, 20 October 2026. Reviewed at least once a year, and whenever the payment arrangements or the business model change.

Questions

Through the contact form.