TERMS & CONDITIONS

Sky Exchange Company (Private) Limited – Mobile Application
Effective Date: September 14, 2026
Last Updated: September 14, 2026

1. INTRODUCTION
These Terms & Conditions (“Terms”) govern your access to and use of the Sky Exchange mobile application (“App”) and the services made available through the App by Sky Exchange Company (Private) Limited (“Sky Exchange”, “**Company”, “we”, “us” or “our”).
By downloading, installing, registering for, accessing or using the App, you acknowledge that you have read, understood and agreed to be bound by these Terms, together with the Company’s applicable Privacy Policy, Refund, Cancellation and Reversal Policy, and any specific terms, disclosures or conditions displayed to you in connection with a particular transaction or service.
If you do not agree with these Terms, you must not use the App.

2. ABOUT SKY EXCHANGE
Sky Exchange Company (Private) Limited is an exchange company authorized by the State Bank of Pakistan (SBP) under License No. 31.
Registered Office:
Office No. 19-23, First Floor,
Mall Plaza, The Mall,
Rawalpindi, Pakistan.

Subject to its authorization, applicable laws and SBP regulations and instructions, Sky Exchange conducts permissible foreign exchange and remittance-related activities, including purchase and sale of foreign currency, inward remittances and outward remittances.

The Company’s services are subject to applicable foreign exchange laws, SBP regulations, AML/CFT/CPF requirements, sanctions requirements and other applicable laws and regulatory instructions.

3. ACCEPTANCE OF TERMS
By using the App, you confirm that:
1. You have legal capacity to enter into these Terms;
2. The information provided by you is true, accurate, complete and current;
3. You will use the App only for lawful purposes;
4. You will comply with all applicable laws and regulations;
5. You will comply with the transaction-specific requirements communicated by Sky Exchange; and
6. You understand that certain transactions may be subject to verification, approval, documentation and regulatory requirements.

Where a customer is unable to meet the applicable legal, regulatory or transaction requirements, Sky Exchange may refuse, suspend, delay or cancel the relevant service or transaction.

4. ELIGIBILITY
Use of the App and its services is subject to applicable laws and regulatory requirements.
Sky Exchange may restrict or refuse access to any service where:
• The customer does not satisfy applicable eligibility requirements;
• Required identification or verification cannot be completed;
• The requested transaction is not permissible under applicable foreign exchange regulations;
• The transaction exceeds an applicable regulatory or internal limit;
• Required supporting documents are not provided;
• The transaction presents an unacceptable AML/CFT/CPF, sanctions, fraud or other compliance risk; or
• Sky Exchange is otherwise prohibited from providing the requested service.

5. APP REGISTRATION
To use certain services, you may be required to create an account on the App.
You agree to provide accurate and complete information and to update such information whenever it changes.
Sky Exchange may require additional information or documentation at any time where required for customer due diligence, transaction processing, regulatory compliance, fraud prevention or other legitimate purposes.
Registration or account creation does not guarantee approval or execution of any transaction.

6. CUSTOMER IDENTIFICATION AND KYC
As a regulated exchange company, Sky Exchange is required to comply with applicable Know Your Customer (KYC), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), AML/CFT/CPF and sanctions-screening requirements.
You agree to provide all information and documents reasonably required by Sky Exchange for:
• Identification and verification;
• Customer risk assessment;
• Verification of source of funds or source of wealth, where applicable;
• Verification of the purpose of the transaction;
• Identification of the beneficial owner, where applicable;
• Sanctions and screening checks;
• Transaction monitoring; and
• Compliance with applicable laws and regulatory requirements.

Sky Exchange may request additional information even after your account has been registered.
Failure to provide satisfactory information may result in refusal, suspension, delay or cancellation of a transaction or restriction of access to certain services.

7. ACCURACY OF CUSTOMER INFORMATION
You are responsible for ensuring that all information submitted through the App is accurate and complete.
This includes, where applicable:
• Your name;
• CNIC/NICOP/passport or other identification information;
• Mobile number;
• Email address;
• Bank account details;
• Beneficiary information;
• Remittance purpose;
• Transaction amount;
• Source of funds information; and
• Any other information requested by Sky Exchange.

Sky Exchange will not be responsible for delays, failed transactions, rejected transactions or losses resulting from incorrect, incomplete or outdated information supplied by you.

8. BENEFICIAL OWNERSHIP OF FUNDS
You confirm that funds used or received in connection with a transaction belong to you or that you are otherwise legally authorized to conduct the transaction.

You must not use the App or Sky Exchange services on behalf of another person where such activity is prohibited or where the actual beneficial owner has not been properly disclosed and verified.

Sky Exchange may require information regarding the beneficial owner of funds and may refuse or suspend a transaction where beneficial ownership cannot be satisfactorily established.

9. SERVICES AVAILABLE THROUGH THE APP
Depending on availability and regulatory authorization, the App may provide facilities including:
• Foreign currency deal booking;
• Purchase or sale of foreign currency;
• Inward remittance transaction information;
• Requesting receipt/credit of inward remittances into eligible bank accounts;
• Outward remittance requests;
• Transaction tracking;
• Transaction receipts;
• Customer support and complaint submission; and
• Other services introduced by Sky Exchange from time to time.

The availability of any particular service may vary according to customer eligibility, regulatory requirements, transaction limits, operational arrangements and technical availability.

10. FOREIGN CURRENCY DEAL BOOKING
Where the App allows you to book a foreign currency transaction, the exchange rate, currency, amount and other applicable transaction details will be displayed or communicated before confirmation, where applicable.

A deal booking submitted through the App may be subject to confirmation, verification and execution by Sky Exchange.

A quotation or indicative exchange rate displayed before final confirmation does not necessarily constitute a completed transaction.

A transaction becomes binding only when it has been accepted and executed by Sky Exchange in accordance with the applicable process.

11. EXCHANGE RATES
Foreign exchange rates may change frequently due to market conditions and other factors.

The applicable exchange rate for a transaction will be the rate communicated or displayed by Sky Exchange for that transaction at the applicable stage of processing.

An indicative rate, market rate or rate displayed before confirmation may change before the transaction is finally confirmed or executed.

Sky Exchange reserves the right to correct an obvious technical or system error in a displayed exchange rate, subject to applicable law and regulatory requirements.

12. TRANSACTION CONFIRMATION
A transaction request submitted through the App does not automatically mean that the transaction has been completed.

A transaction may require:
• Customer confirmation;
• Availability of funds;
• Successful payment;
• KYC/CDD verification;
• Supporting documentation;
• Sanctions screening;
• Compliance approval;
• Beneficiary verification;
• Bank/intermediary processing; or
• Other regulatory or operational checks.

The transaction reference number, electronic confirmation, receipt or other system-generated record issued by Sky Exchange should be retained by the customer.

13. INWARD REMITTANCES
Where the App provides an inward remittance receipt or bank-account credit facility, Sky Exchange may process the request after verification of the relevant remittance and completion of applicable requirements.

Credit to a bank account may depend on:
• Receipt of funds by Sky Exchange;
• Accurate beneficiary information;
• Verification of the beneficiary;
• Banking arrangements;
• Successful bank processing;
• Applicable SBP requirements;
• AML/CFT/CPF and sanctions screening; and
• Other applicable requirements.

Sky Exchange does not guarantee that every inward remittance request will result in immediate account credit.

14. OUTWARD REMITTANCES
Outward remittance services are subject to the applicable foreign exchange regulations, SBP instructions, transaction limits, permissible purposes, documentation requirements and other applicable requirements.

You may be required to provide:
• Identification documents;
• Purpose and supporting documents;
• Beneficiary details;
• Source of funds information;
• Tax-related information, where applicable;
• Bank account information; and
• Any other information required by Sky Exchange or applicable regulations.

Sky Exchange may decline an outward remittance where the transaction does not satisfy applicable legal, regulatory or compliance requirements.

15. TRANSACTION LIMITS
Transactions through the App are subject to applicable SBP limits, foreign exchange regulations, transaction-specific limits and Sky Exchange’s approved internal controls.

The Company may impose additional limits where required for risk management, operational, fraud-prevention or compliance purposes.

Applicable limits may change without prior notice where such change is required by law, SBP instructions, regulatory requirements or operational considerations.

16. PAYMENT OF FUNDS
Where you are required to provide funds for a transaction, you must use only the payment method or channel authorized and communicated by Sky Exchange.

Sky Exchange may refuse funds received through unauthorized channels or from accounts or persons that cannot be satisfactorily verified.

Where required by applicable regulations, transactions must be funded from an account or source belonging to the customer or otherwise appropriately verified.

17. THIRD-PARTY BANKS AND PAYMENT CHANNELS
Certain services may involve banks, correspondent banks, Money Transfer Operators (“MTOs”), payment service providers, clearing systems or other authorized intermediaries.

Sky Exchange may rely on such institutions for processing, settlement, account credit, payment or transmission of funds.

Sky Exchange is not responsible for delays caused solely by a third-party institution, provided Sky Exchange has complied with its applicable obligations and has taken reasonable steps to process the transaction.

18. TRANSACTION DELAYS
A transaction may be delayed because of:
• Banking or intermediary processing;
• System or network issues;
• Compliance review;
• Sanctions screening;
• Additional KYC/CDD requirements;
• Incorrect customer or beneficiary information;
• Regulatory requirements;
• Public holidays or banking holidays;
• Technical failures;
• Fraud investigations; or
• Circumstances beyond the Company’s reasonable control.

Sky Exchange will make reasonable efforts to process transactions within applicable service timelines but does not guarantee a specific completion time where processing depends on a third party or regulatory review.

19. CANCELLATION, REVERSAL AND REFUND
Cancellation, reversal and refund of transactions are governed by Sky Exchange’s Refund, Cancellation and Reversal Policy, as amended from time to time.

A customer does not have an unconditional right to cancel a transaction after it has been executed, settled or transmitted.

Where cancellation or reversal is permitted, it may be subject to:
• Transaction status;
• Applicable SBP requirements;
• Availability and return of funds;
• Third-party processing;
• Exchange-rate differences;
• Applicable charges; and
• Completion of required compliance checks.

The Refund, Cancellation and Reversal Policy forms part of these Terms.

20. FRAUD AND UNAUTHORIZED TRANSACTIONS
You must immediately notify Sky Exchange if you believe that:
• Your App account has been compromised;
• Your credentials have been disclosed;
• A transaction was not authorized by you; or
• Fraudulent activity has occurred.

Sky Exchange may suspend or restrict the account or transaction while an investigation is conducted.

You are responsible for protecting your login credentials, PINs, passwords, OTPs and other security information.

You must never share your password, PIN, OTP or authentication credentials with another person.

21. SECURITY OF THE APP
You agree to:
• Maintain the confidentiality of your login credentials;
• Use an appropriately secured device;
• Keep your operating system and App updated;
• Avoid using the App on compromised or unauthorized devices;
• Immediately report suspected unauthorized access; and
• Log out or secure the App where appropriate.

Sky Exchange may implement security controls including device verification, OTP authentication, transaction authentication, biometric authentication or other security mechanisms.

No electronic system can be guaranteed to be completely secure. Sky Exchange will maintain reasonable security controls in accordance with its applicable policies and regulatory requirements.

22. PROHIBITED USE
You must not use the App:
1. for any unlawful purpose;
2. to facilitate money laundering or terrorist financing;
3. to evade sanctions or regulatory restrictions;
4. for fraudulent or deceptive activities;
5. to provide false or misleading information;
6. to impersonate another person;
7. to conduct transactions for undisclosed beneficial owners;
8. to interfere with the operation or security of the App;
9. to introduce malware, viruses or malicious code;
10. to reverse engineer or attempt to obtain unauthorized access to the App;
11. to exploit technical vulnerabilities;
12. to use automated systems to access the App without authorization; or
13. in any manner that violates applicable laws or regulations.

23. AML/CFT/CPF AND SANCTIONS
Sky Exchange is required to comply with applicable laws and regulations relating to:
• Anti-Money Laundering;
• Countering Financing of Terrorism;
• Countering Proliferation Financing;
• Targeted financial sanctions;
• Sanctions screening;
• Customer due diligence;
• Transaction monitoring; and
• Reporting to competent authorities.

Sky Exchange may monitor, review, delay, suspend, reject or report transactions where required by law, regulation or instructions of a competent authority.

The Company may be legally prohibited from informing a customer about certain investigations, reports or regulatory actions.
Nothing in these Terms requires Sky Exchange to disclose information where disclosure is prohibited by law or regulation.

24. TRANSACTION MONITORING
Transactions conducted through the App may be subject to automated and/or manual monitoring.
Monitoring may include review of:
• Transaction patterns;
• Transaction amounts;
• Frequency;
• Source and destination of funds;
• Customer information;
• Beneficiary information;
• Geographic information;
• Sanctions screening results; and
• Other relevant risk indicators.

Sky Exchange may request additional information or supporting documentation where required.

25. TRANSACTION RECORDS AND RECEIPTS
Sky Exchange will maintain transaction records in accordance with applicable laws, SBP regulations and its record-retention requirements.

Where applicable, customers will receive a system-generated transaction receipt, confirmation or reference number.

Customers should retain transaction receipts and reference numbers for future correspondence, complaints or dispute resolution.

The SBP RFEC requires appropriate transaction recording and record retention controls for exchange companies.

26. ELECTRONIC COMMUNICATIONS
You consent to receiving communications electronically through:
• The App;
• SMS;
• Email;
• Push notifications;
• Telephone;
• Other electronic channels; or
• Other communication channels provided by Sky Exchange.

Electronic communications may include:
• Transaction confirmations;
• Transaction status;
• Security alerts;
• Account notifications;
• Service announcements;
• Compliance requests;
• Complaint updates; and
• Amendments to applicable terms or policies.

Where legally permissible, electronic records may be used as evidence of communications and transaction instructions.

27. APP AVAILABILITY
Sky Exchange will make reasonable efforts to keep the App available.

However, access may occasionally be unavailable due to:
• Scheduled maintenance;
• Technical failures;
• Telecommunications or internet failures;
• Banking or payment-system outages;
• Cyber-security incidents;
• Regulatory requirements;
• Force majeure events; or
• Other circumstances beyond the Company’s reasonable control.

Sky Exchange does not guarantee uninterrupted or error-free operation of the App.

28. INFORMATION DISPLAYED THROUGH THE APP
Sky Exchange endeavours to ensure that information displayed through the App is accurate and current.

However, information such as:
• Exchange rates;
• Transaction status;
• Processing times;
• Service availability;
• Limits; and
• Third-party processing information may change or may be subject to external factors.

Where there is an inconsistency between information displayed in the App and the Company’s official transaction records, Sky Exchange may rely on its authenticated transaction records, subject to applicable law and regulatory requirements.

29. CUSTOMER RESPONSIBILITY FOR TRANSACTION DETAILS
You are responsible for reviewing transaction information before confirming a transaction.
This includes:
• Currency;
• Amount;
• Exchange rate;
• Beneficiary name;
• Account number/IBAN;
• Bank details;
• Purpose;
• Charges, where applicable; and
• Other transaction information.

Once a transaction has been confirmed or executed, correction or cancellation may not be possible or may be subject to applicable charges and regulatory restrictions.

30. FEES AND CHARGES
Applicable fees, service charges and other costs, if any, will be communicated or displayed to the customer before or during the applicable transaction process, where required.

Third-party charges may apply where a transaction involves banks, correspondents, MTOs or other service providers.
Sky Exchange will not knowingly impose charges contrary to applicable laws, regulations or SBP instructions.

31. PRIVACY AND CUSTOMER INFORMATION
Sky Exchange may collect, process, use, retain and disclose customer information for purposes including:
• Providing services;
• Processing transactions;
• Customer identification;
• KYC/CDD;
• AML/CFT/CPF compliance;
• Sanctions screening;
• Fraud prevention;
• Transaction monitoring;
• Regulatory reporting;
• Complaint handling;
• Customer support;
• Security;
• Legal compliance; and
• Improving the App and services.

Customer information may be disclosed to banks, MTOs, payment service providers, regulators, law-enforcement agencies and other authorized parties where necessary or permitted by applicable law.
Use of customer information is further governed by Sky Exchange’s Privacy Policy.

32. INTELLECTUAL PROPERTY
The App, including its software, design, graphics, logos, trademarks, text, interfaces and other content, is owned by or licensed to Sky Exchange and is protected by applicable intellectual property laws.

You are granted a limited, non-exclusive, non-transferable and revocable right to use the App for its intended lawful purpose.
You must not:
• Copy;
• Reproduce;
• Modify;
• Distribute;
• Sell;
• Lease;
• Sublicense;
• Reverse engineer;
• Decompile;
• Create derivative works from; or
• Commercially exploit
any part of the App without Sky Exchange’s prior written authorization, except where permitted by law.

33. THIRD-PARTY SERVICES
The App may interact with or rely upon third-party services, including banks, payment systems, MTOs, technology providers and other service providers.

Third-party services may be governed by separate terms and privacy policies.

Sky Exchange does not control the policies or systems of third parties and cannot guarantee their continuous availability.

34. DISCLAIMER
To the maximum extent permitted by applicable law, Sky Exchange does not guarantee that:
• The App will always be available;
• The App will be completely error-free;
• Transactions will always be completed within a particular period;
• Third-party systems will operate without interruption; or
• Every requested transaction will be approved or executed.

Nothing in these Terms excludes any liability or customer right that cannot lawfully be excluded under applicable law.

35. LIMITATION OF LIABILITY
To the extent permitted by applicable law, Sky Exchange will not be liable for losses arising solely from:
• Inaccurate information supplied by the customer;
• Unauthorized disclosure of customer credentials by the customer;
• Failure of the customer’s device or internet connection;
• Delays caused by banks, MTOs, correspondent banks or other third parties;
• Regulatory or legal restrictions;
• Sanctions or compliance requirements;
• Events beyond the Company’s reasonable control; or
• Fraudulent or unauthorized activity resulting from the customer’s failure to protect account credentials.

Nothing in these Terms limits liability where such limitation is prohibited by applicable law or arises from the Company’s own unlawful conduct, fraud or willful misconduct.

36. INDEMNITY
To the extent permitted by applicable law, you agree to indemnify and hold Sky Exchange harmless against claims, losses, liabilities, costs or expenses arising from your:
• Breach of these Terms;
• Unlawful use of the App;
• Submission of false or misleading information;
• Unauthorized use of another person’s information;
• Violation of applicable law;
• Misuse of the App; or
• Fraudulent or negligent conduct.
This clause does not apply to the extent that the relevant loss is caused by Sky Exchange’s own unlawful conduct or negligence.

37. SUSPENSION OR TERMINATION OF ACCESS
Sky Exchange may suspend, restrict or terminate your access to the App or particular services where:
• Required by law or SBP;
• Required by a competent authority;
• KYC/CDD requirements cannot be completed;
• Suspicious or fraudulent activity is identified;
• Sanctions concerns arise;
• False information has been provided;
• The App has been misused;
• Security has been compromised;
• These Terms have been breached; or
• Continued access creates a legal, regulatory, operational or security risk.

Where legally permissible, Sky Exchange may notify the customer of the relevant action.
Suspension or termination does not affect rights or obligations relating to transactions already initiated.

38. CUSTOMER COMPLAINTS
Customers may lodge complaints through the customer support and complaint channels provided by Sky Exchange.

Sky Exchange maintains a customer support and complaint-handling mechanism in accordance with applicable SBP requirements.

The SBP RFEC requires exchange companies to properly record, resolve and communicate complaints and to resolve complaints expeditiously within 7 working days.

Customers should provide their transaction/reference number and relevant details when submitting a complaint.

39. REFUND AND CANCELLATION POLICY
The Company’s Refund, Cancellation and Reversal Policy forms an integral part of these Terms.

Customers should review that policy before initiating transactions through the App.

A copy of the current policy will be made available through the App and/or the Company’s official website.

40. CHANGES TO THESE TERMS
Sky Exchange may amend these Terms from time to time to reflect:
• Changes in law;
• SBP regulations or instructions;
• Regulatory requirements;
• Changes to the App;
• Changes to services;
• Security requirements; or
• operational requirements.

Updated Terms will be made available through the App and/or the Company’s official website.

Where required by law or regulation, Sky Exchange will provide appropriate notice of material changes.

Your continued use of the App after the effective date of amended Terms constitutes acceptance of the revised Terms, to the extent permitted by law.

41. GOVERNING LAW
These Terms shall be governed by and interpreted in accordance with the laws of the Islamic Republic of Pakistan, including applicable foreign exchange laws and regulations and applicable rules, regulations and instructions issued by the State Bank of Pakistan.

Nothing in these Terms prevents a customer from exercising any statutory or regulatory right available under applicable law.

42. REGULATORY OVERRIDING PROVISION
If any provision of these Terms conflicts with:
• The Foreign Exchange Regulation Act, 1947;
• Applicable SBP regulations or instructions;
• AML/CFT/CPF requirements;
• Sanctions requirements;
• An order or direction of a competent authority; or
• Any other mandatory applicable law, the applicable mandatory legal or regulatory requirement shall prevail to the extent of the conflict.

Sky Exchange may amend, suspend or restrict any service where necessary to maintain regulatory compliance.

43. SEVERABILITY
If any provision of these Terms is determined to be invalid, unlawful or unenforceable, the remaining provisions shall continue to remain effective to the extent permitted by applicable law.

44. NO WAIVER
Failure by Sky Exchange to exercise or enforce any right under these Terms shall not constitute a waiver of that right.

45. ENTIRE AGREEMENT
These Terms, together with the applicable Privacy Policy, Refund, Cancellation and Reversal Policy, transaction-specific terms and other policies displayed through the App, constitute the agreement between you and Sky Exchange concerning your use of the App and its services, subject to applicable law.

46. CONTACT INFORMATION
Sky Exchange Company (Private) Limited
Registered Office:
Office No. 19-23, First Floor,
Mall Plaza, The Mall,
Rawalpindi, Pakistan.
License No.: 31
Regulator: State Bank of Pakistan
Customer Support: +92 51 5585302
Email: ho@skyexchange.com.pk
Website: www.skyexchange.com.pk

47. CUSTOMER ACKNOWLEDGEMENT
By registering for or using the Sky Exchange App, you acknowledge that:
☐ I have read and understood these Terms & Conditions.
☐ I agree to comply with applicable laws, SBP requirements and Sky Exchange policies.
☐ I confirm that the information provided by me is accurate and complete.
☐ I understand that transactions may be subject to KYC/CDD, AML/CFT/CPF, sanctions screening and regulatory verification.
☐ I understand that submission of a transaction request does not necessarily mean that the transaction has been accepted or completed.
☐ I understand that cancellation, reversal and refund are subject to the Company’s Refund, Cancellation and Reversal Policy and applicable regulatory requirements.
☐ I understand that I am responsible for protecting my App credentials and authentication information.
By selecting “I Agree”, registering or continuing to use the App, you confirm your acceptance of these Terms & Conditions.

Effective Date: September 14, 2026
© Sky Exchange Company (Private) Limited. All Rights Reserved.