These terms and conditions ("Terms") shall serve as your User Agreement with DIRECT AGENT 5, INC. ("DA5", “SurgePay”, “we”, “us”) its affiliates and/or subsidiaries, and shall apply to your visit and use of its online electronic money and virtual currency conversion SurgePay mobile app Platform: DA5ʼs SurgePay Mobile App (“DA5 App”) accessible via an application available for download with a website accessible at Google Play and Apple Store (collectively, “SurgePay Platform"), and its User Services, which are further defined below, as well as to all information, recommendations and/or services provided to you on or through the SurgePay Platform.
DA5 and its SurgePay Platform are subject to the Bangko Sentral ng Pilipinasʼ (“BSP”) Manual of Regulations for Non-Bank Financial Institutions (“MORNBFI”), as amended, the issuances of the BSP, the Anti-Money Laundering Act (“AMLA”), as amended, and its Implementing Rules and Regulations, the issuances of the Anti-Money Laundering Council (“AMLC”), the Terrorism Financing Prevention and Suppression Act, the Data Privacy Act of 2012 and its Implementing Rules and Regulations, and any other applicable laws and regulations (collectively, the “Law”).
Please read the Terms set out below before ordering or purchasing any item from the SurgePay Platform. By using the SurgePay Platform, and ordering or purchasing any item displayed therein, you agree to be bound by these Terms. If you do not agree to be bound by these T&Cs, you are required to immediately cease, exit, or stop accessing the SurgePay Platform.
You agree to abide by and be bound by this Agreement, which we may amend from time to time, by opening an account with SurgePay (an “Account”) through the DA5 or the SurgePay website, the SurgePay API, and/or any related websites or mobile applications (collectively, the "SurgePay site"). You are not permitted to use or make use of any SurgePay Services if you disagree with any of the conditions outlined in this Agreement or any future modifications to the Agreement.
This Agreement may be amended or modified at any time, and the updated Agreement will take effect when it is posted on the SurgePay site or emailed to you. We reserve the sole right to (a) change or eliminate any aspect of the SurgePay services, and (b) suspend or terminate your access to the SurgePay Services, at any time, and from time to time, without notice to you in certain circumstances described herein. You agree that we shall not be liable to you or any third party for any modification or termination of the SurgePay services, or suspension or termination of your access to the SurgePay Services, except to the extent otherwise expressly set forth herein.
You hereby acknowledge that DA5 is duly registered with the Bangko Sentral ng Pilipinas (BSP) as Remittance & Transfer Company (RTC) with Money Changing (MC)/ Foreign Exchange Dealing (FXD) & Virtual Asset Service Provider (VASP) service, and all such activity is subject to the rules and regulations of the Bangko Sentral ng Pilipinas and the Anti-Money Laundering Act (AMLA), as amended. As such we may be required by the BSP and other relevant regulatory authorities to abide by their regulatory issuances and enforcement actions, among others.
By continuing to use the SurgePay services, you hereby expressly acknowledge that you are aware of the following risks:
SurgePay Platform – means the DA5 Payment System, including Over-The-Counter (“OTC”) channels, wherein a customer (you) can access our Services (as identified below) through an application to run on a mobile device or a tablet computer or via OTC channels available to you.
DA5 – ay isang entity na nararapat na lisensyado ng Bangko Sentral ng Pilipinas bilang Electronic Money Issuer (“EMI”) at Virtual Asset Service Provider (“VASP”);
Cash-in – means the process of exchanging Philippine Peso cash for e-money which will be added to your e-Wallet
Cash-out – means the process of exchanging e-money for Philippine Peso cash
E-Wallet – Refers to the electronic wallet that is used to store electronic money (e-Money) to make cashless, digital transactions. Each user can only own one (1) e-Wallet account at any time.
E-Money – Refers to electronic money that is used in your SurgePay Platform transactions (e.g., pay bills, scan to pay, cash in). It may only be redeemed at face value. It shall not earn interest nor rewards and other similar incentives convertible to cash, nor be purchased at a discount. It is not a deposit account. Hence, it is not insured by the Philippine Deposit Insurance Corporation (“PDIC”).
One Time Pin (OTP) – A one-time password (OTP) is an automatically generated numeric or alphanumeric string of characters that authenticates the user for a single transaction or login session.
Know-Your-Customer or KYC – the process of obtaining information to identify and verify the identity of the User.
Top-up – to add money, value, or credits to an existing account to avail of the services provided by the merchant available on the SurgePay Platform.
VC – Any type of digital unit that can be digitally traded, or transferred, and can be used for payment or investment purposes. It can be defined as a "property", "proceeds", "funds", "funds or other assets", and other "corresponding value".
When you accept these Terms, you are creating your DA5 SurgePay Mobile App account associated with your mobile number. You will be asked to provide your information in accordance with the Law’s Know-Your-Customer (“KYC”) requirements which will be used to determine your eligibility to use the SurgePay Platform.
By registering an account, you represent that you are at least 18 years old. You also represent that you have legal capacity, power, and authority to consent to these Terms and that you are registering for your own account and capacity. You are responsible for providing the correct registration information. We reserve the right to request additional information to aid in account verification, as well as close, suspend or limit your access to the SurgePay Platform in the event of incomplete or incorrect information provided.
You may only have one (1) Account associated with one (1) mobile number.
You understand and agree that your failure to provide and maintain accurate, complete, and updated information required by these Terms may result in your inability to access or use your Account.
Each Account has its own e-Wallet. The e-Wallet stores your e-Money. Your e-Money may only be redeemed at face value. It shall not earn interest nor rewards and other similar incentives convertible to cash, nor be purchased at a discount. It is not a deposit account. Hence, it is not insured by the Philippine Deposit Insurance Corporation (“PDIC”). Your e-Money stored in your e-Wallet may be used to transfer to another User or purchase goods and services with our partner merchants.
DA5 is the issuer of all e-Money in your e-Wallet. In compliance with the Law, DA5 undertakes to protect its Users to ensure that e-Money redemptions are adequately met at all times, with sufficient liquid assets equal to the amount of the outstanding e-Money issued.
You shall not abuse or misuse your Account in any manner, including but not limited to:
You shall be responsible for regularly checking your account and keeping your personal details up to date. You shall notify us of any changes, omissions, or incorrect details as soon as you become aware of any of them. DA5 shall not be responsible for any failure by you to notify us of any such changes, omissions, incorrect details, or any incorrect information notified to us. You hereby release and waive any rights or causes of actions against DA5 from any injury or damages arising from your failure to provide accurate and updated information.
To maintain confidentiality and security of your Account and data therein, you agree that:
You, hereby irrevocably and unconditionally agree to give consent to DA5, to:
Our Privacy Statement shall form an integral part of these Terms and can be viewed at da5.com.ph.
You acknowledge that the SurgePay Platform may be subject to interruptions, limitations, delays, and other problems inherent in the use of the internet and electronic communications, including the device used by you being faulty, not connected, out of range, switched off, or not functioning. DA5 is not responsible for any delays, delivery failures, damages, or losses resulting from such problems.
Subject to the Law, you use this service entirely at your own risk and acknowledge that DA5 is not responsible for any and all damages, losses, or expenses which you may suffer because the service is unavailable or does not operate as expected, or causes loss or damage to any data.
Further, subject to the Law, any responsibility arising from any unauthorized access or use of your Account due to your failure to comply with your responsibilities under these Terms shall be borne by you.
The services available on the SurgePay Platform are:
Cash-in – exchanging Philippine Peso cash for the e-money which will be added to your e-Wallet;
Cash-out – exchanging e-money to Philippine Peso cash through our cash-out partners;
Bills Payment – instantly pay bills with our partner merchants online;
Intra-bank fund transfer – Withdrawal option that allows you to transfer funds from your e-Wallet account to your bank account;
VC Conversion – Exchange VC to Philippine Peso (and vice versa).
6.1 Virtual asset purchases or sales that could be considered to be high-risk, particularly those conducted utilizing reversible payment methods, may be canceled or reversed by SurgePay.
6.2 As long as the transaction is accepted and verified on the blockchain network, SurgePay does not cancel or reverse virtual assets to virtual asset transfers.
6.3 All customer money is stored by SurgePay in full. SurgePay doesn't take part in lending using fractional reserves.
6.4 In the event SurgePay needs to retrieve funds from offline storage, there can be a delay in sending virtual assets of up to 72 hours.
6.5 A virtual assets’ value is not guaranteed by SurgePay. You understand that the value or price of the virtual asset may fluctuate quickly, drop, and possibly even become zero. You admit that there is a substantial risk involved with holding virtual assets or digital currencies. Regardless of fluctuations in the value of the virtual asset, you consent to deliver the agreed-upon payment for the order upon confirmation.
6.6 SurgePay maintains the right, as we see fit, to modify the buy/sell limits and/or halt trading activity on your account.
6.7 The only virtual assets or currencies that SurgePay services are compatible with are those that SurgePay, in its sole discretion, chooses to support. SurgePay may from time to time modify the virtual currencies it supports. Visit the Da5 website (https://da5.com.ph/) if you have any queries concerning the virtual assets that the service currently accepts. Under no circumstances should you attempt to store, transfer, request, or receive virtual assets in any format that SurgePay does not support using the SurgePay services. Any attempt to utilize SurgePay services for digital currencies that SurgePay does not support is not something for which SurgePay is responsible or liable.
6.8 Operation of Virtual Asset Protocols. The underlying software protocols that manage the operation of the virtual assets supported by and/or accessible for purchase/sale through our platform are not owned by or under the control of SurgePay. The underlying protocols are typically open source and available for anybody to use, copy, alter, and distribute. By utilizing SurgePay, you consent and recognize.
(i) that SurgePay does not guarantee the functionality, security, or availability of the underlying protocols and is not responsible for their operation; and (ii) that the underlying protocols are subject to sudden changes in operating rules (a/k/a "forks"), and that such forks might have a significant impact on the name, value, or even functionality of the virtual asset you purchase or sell using SurgePay. You acknowledge that SurgePay may briefly halt operations in the case of a fork (with or without advance notice to you) and that SurgePay may later, in its sole discretion, (a) adjust or reconfigure its systems or (b) choose not to support (or discontinue supporting) the forked protocol completely, provided, however, that you will have the option to withdraw money from the platform. You understand and agree that SurgePay takes absolutely no responsibility for a forked protocol's unsupported branch. SurgePay will only support the fork of any virtual asset protocol that best, in our exclusive judgment, matches the consensus strategy.
6.9 Virtual Asset transactions: SurgePay follows the instructions provided by its users and clients when processing purchases and/or sells of supported virtual assets, but we cannot guarantee the identity of any user, recipient, or another party. Before sending instructions to SurgePay, you should double-check all transaction details. A virtual asset transaction that has been submitted to a network of digital currencies will remain unconfirmed for a while until the network of virtual assets has sufficiently validated the transaction. A transaction is not complete while it is pending. Your SurgePay Account balance will not reflect the number of funds linked with transactions that are in the pending status, and they won't be accessible for transactions. To perform a virtual asset transaction on your behalf, SurgePay may incur network fees (miner fees). Although SurgePay will always inform you of the network cost at or before the moment you authorize the transaction, SurgePay will compute the network fee at its discretion.
6.10 SurgePay uses a combination of online and offline storage to safely keep all virtual asset private keys under our management. To accomplish a virtual asset Transaction in accordance with your instructions, SurgePay might need to retrieve specific information from offline storage. This could cause a delay of at least 72 hours in the start or credit of such virtual asset Transactions. You understand and accept the possibility of a delay in a SurgePay-facilitated virtual asset transaction.
6.11 Sending virtual assets to your PHP wallet that accepts fiat currency: If a customer receives a virtual asset directly to their PHP wallet using their bitcoin address, SurgePay reserves the right to refuse to process the conversion (for example, if the transaction exceeds our system limits). In this case, the funds will still be credited to the customer's digital currency wallet and will retain their value in virtual assets.
DA5 reserves the right to automatically suspend or block an account in the event that DA5 has reason to believe that your Account is being used for fraudulent or suspicious activities (as defined under the Anti Money Laundering Act) or by an unauthorized person. You shall hold DA5 free from liability for such suspension or blocking or any loss or damage which you may suffer as a result thereof.
If DA5 has a good faith suspicion that you are violating the User Agreement or if further personal identifying information is required to prove your identity, DA5 may postpone an order if you have not submitted personal identifying information or KYC requirements, or such other necessary documentation which DA5 may require based on the circumstances. You may encounter a delay in the processing of virtual currency transactions or conversion service transactions if any, until these verification processes are finished. Any such postponed transaction will be labeled as "pending" by DA5, and the funds won't be accessible until the pending transaction is finished. DA5 reserves the right to refuse to process, cancel, or reverse any customer transaction (i) as required by law, (ii) in response to a facially valid subpoena, court order, or other government order, or (iii) if DA5 reasonably suspects that the transaction is erroneous, or is in violation of these Terms or any relevant regulation.
DA5 reserves the right to refuse to process any transactions, including purchases or sales of virtual assets, or to cancel or reverse them in its sole discretion if it believes they involve (or have a high risk of involving) money laundering, terrorist financing, fraud, or any other type of financial crime; in response to a subpoena, court order, or other government order; or such other circumstances where DA5 deems it a necessity to do so. In these instances, DA5 will reverse the transaction. In the cases of virtual currency transactions, we are under no obligation to allow you to reinstate a purchase or sale order at the same price or on the same terms as the canceled transaction.
Users are not permitted to utilize any SurgePay services, services offered to or related to other users, and related third-party services for or in connection with any "Unauthorized Uses" that violate the Agreement. This ban is intended to safeguard our Customers from misbehavior and guarantee adherence to national legislation and international standards.
These classifications are not all-inclusive and are mostly intended to serve as examples. Use of the services for any Unauthorized Uses may result in service interruptions, service changes, account deletion, or reporting to law enforcement if you facilitate, participate in, or act in connection with any such Unauthorized Uses. If you are unsure if your usage or intended use may be a Prohibited Use, you may contact SurgePay Support for clarification if you think you are using SurgePay services for one of the purposes listed below or are seeking to use SurgePay services for that reason.
The following transactions or behaviors are prohibited:
In case of a compromised account, you shall immediately inform DA5 through our customer care touchpoints of such concern. Suspension of your Account shall be processed only upon proper authentication by DA5. All transactions made prior to the successful reporting of loss to DA5 shall continue to be your liability.
The proof of purchase after every transaction is presumed correct unless you report any dispute within fifteen (15) days from the date of the transaction. If no dispute is reported within the said period, the transaction is considered valid. Disputed transactions will be properly investigated and once DA5 determines its validity, only then will the amount be credited back to your e-Wallet or VC-Wallet, as may be applicable. Erroneous transactions done such as incorrect amount inputted, incorrect mobile number inputted, the incorrect product selected, and alike, shall not be valid for reversal. It is your responsibility to ensure that correct details are inputted or selected prior to confirming your transaction.
You can opt to cancel your Account at any time through a request addressed to our customer support team, subject to your right to cash out all of your remaining balance in your Account. Once your account is canceled, you can no longer log in to your canceled Account.
Failure to comply with the Terms and Conditions shall be a basis for the termination of the Account. Further, your Account will be considered inactive if there are no client-initiated transactions for a period of one (1) year from the last transaction. Should the account be declared dormant, applicable fees may be charged to the account until it becomes zero.
We recommend that you Cash Out your e-Wallet prior to your cancellation request through the means provided under the Cash-in and Cash-out features in the SurgePay Platform. Please note that the outgoing monthly transaction limit will be observed. We will not be able to process cancellation requests if there is still a balance in your e-Wallet.
DA5 grants you a limited, personal, non-exclusive, and non-transferable right and license to use the SurgePay Platform. Unless otherwise specified in writing, The SurgePay Platform is for your personal and non-commercial use. The SurgePay Platform, including, without limitation, the content, metadata, design, organization, compilation, look and feel, the source, object, and HTML code, and all other protectable intellectual property available through The SurgePay Platform (the “Proprietary Materials”) are the property of DA5 and are protected by copyright and other intellectual property laws. All rights regarding the Proprietary Materials not expressly granted in this T&Cs are reserved by DA5.
Unlessyou have our written consent, you may not copy, reproduce, sell, publish, distribute, display, retransmit or otherwise provide access to the Proprietary Materials to anyone. You agree not to rearrange, modify, create derivative works, or reverse engineer the Proprietary Materials. You agree not to create, scrape or display our content for any purpose.
You agree not to post any content from the SurgePay Platform to blogs, news groups, mail lists, or electronic bulletin boards, without our written consent.
By using the SurgePay SurgePay Platform, you agree that your use:
For any concerns, you may get in touch with the following DA5 customer support channels: customer.support@da5.com.ph
The SurgePay Platform is provided on an “as is” basis. DA5 makes no warranties that the SurgePay Platform’s services shall be uninterrupted, bug, or error-free. DA5 disclaims all representations and warranties to the Application including but not limited to the warranties of merchantability and fitness for a specific purpose. Further, DA5 does not represent that the information or content accessible through the SurgePay Platform is accurate, complete, and current and all information, including applicable fees and availability, shall be subject to change without prior notice to you. Subject to the limits provided by law, you acknowledge and agree to assume all risks associated with the use of the SurgePay Platform, any information available and/or accessed through the SurgePay Platform, and any security features provided for the SurgePay Platform.
Further, you agree that DA5 makes no warranties as regards the products and/or services provided by the Merchants, it is acknowledged that all warranties thereto shall be solely exercised by and charged against the Merchant.
You acknowledge that, except as expressly provided herein, DA5 shall not be liable for any claim, liability, or damage for whatever direct, indirect, consequential, and/or other damages including loss of opportunity, anticipated profits or, another economic gain as a result of the ineffective use or non-use of the SurgePay Platform, and/or of the partner merchant’s services or products.
Upon acceptance of these Terms, you agree to abide by the KYC requirements set forth by DA5 in accordance with the Law’s requirements. DA5 may also ask for valid ID/s or other documentation to verify the accuracy of the KYC Information provided. Likewise, in line with the submitted KYC Information, you agree to provide consent to DA5 to share the information with third-party vendors, remittance partners, and third-party databases, as necessary, for the purpose of fulfilling the requirements of the Law. Likewise, you represent and warrant that you are not violating any applicable laws or regulations through your use of the SurgePay Platform. You are responsible to ensure the information you supply is accurate. You will be responsible for keeping the confidentiality of your User ID and Password. In any event of unauthorized use of the service, DA5 shall not be liable for any inconvenience and damage caused to the DA5 SurgePay Mobile App user, or a third party. DA5 may suspend or terminate the use of the service for whatever legal reasons it deems proper. In the event of any suspension, termination, or confiscation of the service, the DA5 SurgePay Mobile App user agrees to hold DA5 free and harmless from any claim, damages, loss, expenses, suit, or liability whatsoever, arising from such suspension, or termination.
DA5 shall not be liable for any loss or damage of whatever nature in connection with the implementation of transactions coursed through the SurgePay Platform in the following instances:
In the event of a claim or dispute, you agree to observe good faith and exert your best efforts towards an amicable resolution of any claim or dispute. In case of any litigation arising from the use of the SurgePay Platform, the DA5 user shall pay the cost and expenses of litigation and attorney’s fees and any legal actions arising hereunder shall be adjudicated before a court of competent jurisdiction located in Makati City, to the exclusion of all other courts. You shall indemnify DA5 against all claims, demands, actions, and proceedings that may be made against DA5 and in respect of any and all damages, liabilities, losses, costs, and expenses (including legal costs on a full indemnity basis) that may be incurred, sustained or suffered by us, directly or indirectly, due to the use or misuse of the SurgePay Platform, negligence, misconduct or breach of any of these Terms by you and/or any other act, thing or matter arising out of or in connection with these Terms and Conditions. These terms and conditions shall be governed by and interpreted pursuant to the laws of the Republic of the Philippines.
These Terms and any amendments thereof shall constitute the entire agreement between you and DA5 relating to the subject matter hereof and supersedes in full any and all prior agreements. Thus, if any of the provisions of these Terms is declared or found to be unenforceable, or illegal, then that provision shall be deemed removed from these Terms without affecting the validity of all other provisions. DA5 may change these Terms and Conditions or any features of the DA5 SurgePay Mobile App as it may deem necessary. You understand that DA5 may add, remove, and modify features, functionalities, and products that comprise the Service at any time without prior notice to you.
16.1 Limitations of Liability. In an event shall we, our related companies, the officers, directors, agents, joint ventures, employees, and suppliers of SurgePAy or our related companies be liable for loss of profits or any special, incidental, or consequential damages arising out of or in connection with our website, SurgePay services, features, or this agreement (however arising, including negligence). Our liabilities and the liability of our related companies, officers, directors, agents, joint ventures, employees, and suppliers, to you or any third parties in any circumstance are limited to the actual amount of direct damages.
16.2 No Warranty. The officers, directors, agents, joint venturers, employees, and suppliers of SurgePay and our related companies specifically disclaim any implied warranties of title, merchantability, fitness for a particular purpose, and non-infringement. The Surgepay services are provided "as is" and without any representation or warranty, whether express, statutory, or otherwise. The goods or services that are purchased using SurgePay services are not under SurgePay's control, and SurgePay cannot guarantee that a buyer or a seller you are dealing with will complete the transaction or is qualified to do so. The operation of our website may be hampered by a variety of factors that are beyond our control, and SurgePay makes no guarantees regarding continuous, uninterrupted, or secure access to any SurgePay services. In order to ensure that requests for electronic debits and credits involving bank accounts, credit cards, and check issuances are processed promptly, SurgePay will use commercially reasonable efforts. However, SurgePay makes no guarantees or representations regarding the length of time it will take to process a request because SurgePay services depend on numerous factors that are beyond our control, such as delays in the banking system or the U.S. or international mail service. The aforementioned disclaimers may not apply to you since certain states do not permit the exclusion of implied warranties. You might not be covered by the aforementioned disclaimers since certain states do not
permit the exclusion of implied warranties. In addition to the legal rights mentioned in this paragraph, which may differ from state to state, you may also have other legal rights.
16.3 Force Majeure. We will not be held responsible for any delays, failures, or interruptions of service that are caused directly or indirectly by events or circumstances that are out of our reasonable control, such as delays or failures brought on by acts of God, the actions of civil or military authorities, terrorist acts, civil unrest, war, strikes or other labor disputes, fire, interruptions in telecommunications, Internet, or network provider services, or failures in equipment or software.
16.4 Arbitration. Any dispute arising under this Agreement shall be finally resolved by arbitration in accordance with the Arbitration Rules of the Singapore International Arbitration Center ("SIAC Rules") then in effect, which rules are deemed to be incorporated by reference in this clause. The only exceptions to this rule are claims for injunctive or equitable relief or claims regarding intellectual property rights, which may be brought in any competent court without the posting of a bond. If a single arbitrator cannot be chosen by the consent of the Parties, the Tribunal shall be composed of one or more arbitrators constituted in accordance with the aforementioned rules. Singapore will serve as the arbitration's location, while English will serve as the language of the proceedings. The arbitral award will be final, enforceable in any court with jurisdiction, and binding on the Parties. Any successful party in a lawsuit or other legal action to enforce this agreement is entitled to costs and attorneys' fees.
16.5 Time Limitation on Claims. You acknowledge that you have one year from the date on which a claim first arises to pursue any lawsuit you may have against SurgePay; otherwise, that lawsuit will be permanently barred.
16.6. Export Controls & Sanctions. The Philippines and international export controls and economic sanctions regulations apply to the delivery of virtual assets and the SurgePay services through the SurgePay website. By purchasing any such things through the SurgePay website, you guarantee that both your purchase and the intended usage of the item comply with the aforementioned conditions. Without limiting the aforementioned, you are prohibited from purchasing virtual assets or any of the SurgePay services via the SurgePay website if: (1) if you are a citizen or resident of Cuba, Iran, North Korea, Sudan, Syria, or any other nation subject to UN sanctions, HM Treasury's financial sanctions regime, the United States embargo, or if you are on the U.S. Specially Designated Nationals List maintained by the Treasury Department or the U.S. financial sanctions imposed by the HM Treasury under the Commerce Department's Denied Persons List, Unverified List, and Entity List; or (2) If a person is listed on the Specially Designated Nationals List, the Denied Persons List, the Unverified List, the Entity List, or the HM Treasury's financial sanctions regime, then you intend to supply the acquired virtual asset or SurgePay Services to that person. This also applies to any nationals or residents of Cuba, Iran, North Korea, Sudan, Syria, or any other country subject to the United States embargo or UN sanctions.
You understand and agree that if you are not a Filipino citizen, you may be subject to additional requirements pursuant to our KYC program and procedures. If you are a citizen of the United States of America, you may be required to make all necessary and applicable disclosures, including those related to the Foreign Account Tax Compliance Act.
The following types of enterprises, commercial activities, and products cannot use SurgePay services: ("Prohibited Businesses"). By creating a SurgePay account, you attest that you won't use the service in conjunction with any of the following enterprises, practices, things, or activities:
Following activities are not permitted when using your SurgePay Account: ("Prohibited Use"). By creating a SurgePay Account, you attest that you won't use it for any of the following things:
