VSMP Handbook
TEL.mobi Group 2
INTRODUCTION AND FOREWORD
This document has been drawn up to assist persons at Eligible Entities who wish to Establish a VSMP.
The objective of this document is to describe all aspects of the TEL.mobi Group’ Products, Services and Facilities, and all aspects of the TEL.mobi Group’s VSMP Program clearly. This is to inform persons at Eligible Entities, and is to assist, on an ongoing basis, Contact Persons at Eligible Entities that have Established VSMPs (because it can always be referred back to by Eligible Entities’ Contact Persons).
This document can be read online or a copy printed out – at any interested party’s choice. It is available as a PDF, to view or download, at the top right of the “Apply for an Affiliate (VSMP)” Facility page on any TEL.mobi Group or VSMP site.
This Document has all necessary information on all aspects of the TEL.mobi Group, its Product Suite and the VSMP Program. It is indexed in the Table of Contents. To enable immediate access to the subject / topic of interest directly.
The TEL.mobi VSMP Program is one of the most popular and fastest-growing Programs internationally. This is because it:
1. Does not require any cost or investment to Establish a VSMP.
2. Generates substantial additional revenues (via Commission Donations) for Eligible Entities at zero cost to them.
3. Enables Eligible Entities to significantly broaden their existing Product / Services offering, and/or to cut their own costs within their own business activities.
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4. Provides the Eligible Entities’ existing clients / members / users with a set of high-quality Products, Services and Facilities that substantially reduces their costs for equivalent services elsewhere.
The TEL.mobi Group’s VSMP Program has previously been called the world’s largest high-revenue multi-product Franchise Group – that gives all of the Franchises and Franchise equipment, stock and administration & management tools to the Franchisees for free.
This is not, however, how Webtel.mobi – the Driver of the TEL.mobi Group – sees it. We see it merely as an example of how all persons and entities within the TEL.mobi Group – being the Driving Company Webtel.mobi, the Independent Agents and the Eligible Entities that receive VSMPs – work together to pool their resources as a Team, in order to bring the highest-quality service to TEL.mobi Group Members at the lowest possible cost. In other words, a real example of what responsible and ethical business can produce.
The TEL.mobi Group has structured its VSMP Program to be as inclusive and helpful as possible. There are no costs, equipment or other arduous requirements for Eligible Entities to establish and start utilizing their VSMPs.
Other than this, a comprehensive range of easy-to-use online tools and resources are provided to and for Eligible Entities’ Contact Persons at no cost, specifically to make all the processes, administration, management and monitoring of their VSMPs intuitive and easy.
Furthermore, there is no pressure on VSMPs to achieve any minimums or maximums of anything. The Program is structured so as to cater for all Eligible Entities – whether they wish to promote and drive it robustly or in a more relaxed manner, at their own choice.
Having read this VSMP Handbook, all that you need to do now to become part of one of the fastest- growing and most inclusive Programs in the world, and provide and additional broad range of high- quality and revenue-generating Products, Services and facilities to your existing clients / members / users / other is just go to the “Apply to for an Affiliate (VSMP)” facility on your TEL.mobi Account, and click the Green Button.
The Management Team of the TEL.mobi Group thanks you for your interest in Establishing a TEL.mobi Group VSMP, and we look forward to welcoming your Eligible Entity’s VSMP as part of the TEL.mobi group whenever it suits you to do so.
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TEL.MOBI GROUP VSMP HANDBOOK
The content of this Handbook is indicative information. The TEL.mobi Group environment is dynamic, and this information and/or situations described herein may alter at short notice, prior to the TEL.mobi Group being able to update this document. In such cases, until the document is updated, the situation as altered will be applicable and supersede the information in this document.
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Table of Contents
Section and Chapter Page
SECTION 1 – PRODUCTS, FACILITIES AND SERVICES 24
OVERVIEW OF WEBTEL.MOBI AND THE TEL.MOBI GROUP 25 Overview of Webtel.mobi and the TEL.mobi Group 26 A. Webtel.mobi – Overview of the Company and Service 26 B. The TEL.mobi Group – Overview 27
DESCRIPTION OF THE TEL.MOBI GROUP’S PRIMARY TELEPHONY SERVICES 28 Description of the TEL.mobi Group’s Primary Telephony Services 29 A. Mobile Calling and Texting Services 29 B. Landline Calling Services 30 C. Satellite Phone Calling Services 30 D. Specialized Calling and Texting Facilities 31 E. Universal Number Calling Facility 33 F. Switchboard Facility 35
UNIQUE ADVANTAGES AND ATTRIBUTES OF THE TEL.MOBI GROUP’S PRIMARY 36 TELEPHONY SERVICES Unique Advantages and Attributes of the TEL.mobi Group’s Primary Telephony Services 37 A. Unique Advantages of the TEL.mobi Primary Services 37 B. Unique Attributes of the TEL.mobi Group’s Primary Services 39 C. Summary of the TEL.mobi Group’s Primary Services 44 D. The TEL.mobi Group’s Internet-Initiated Telephony Services 45
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DESCRIPTION OF THE TEL.MOBI GROUP’S TELEPHONY-SUPPORT SECONDARY SERVICES 46 Description of the TEL.mobi Group’s Telephony-Support Secondary Services 47 A. TEL.mobi Group Top-Up Voucher and Top-Up Facility 48 B. TEL.mobi Group Currency Wallets Facility 50 C. TEL.mobi Group Currency Conversions Facility 51 D. TEL.mobi Group Top-Up Transfers Facility 53 E. TEL.mobi Group ITAN Number Facility 55 F. TEL.mobi Group Refund Transfers Facility 56 G. TEL.mobi Group Multi-Number Account Facility 57 H. TEL.mobi Group Itemized Per-Second Billing Records in Real Time 57 I. TEL.mobi Group Transactions History Facility 58 J. TEL.mobi Group Account Blocking and Unblocking Facility 59 K. TEL.mobi Group “Know Your Client” (KYC) Upload Facility 60 L. TEL.mobi Group Secure Contacts Storage Facility 60
FLOW, USE & SWAP OF STORED CREDIT – THE “MEMBERS-ONLY” AND “CLOSED LOOP” 61 STRUCTURE Flow, Use & Swap of Stored Credit – The “Members-Only” and “Closed Loop” Structure 62 A. Overview 62 B. TEL.mobi Group Stored Credit Inward Flow 1 of 2 64 Loading of Account by a TEL.mobi Group Member
C. TEL.mobi Group Stored Credit Inward Flow 2 of 2 66 Acquiring of Electronic Top-Up Vouchers by TEL.mobi Group IAs / VSMPs
D. TEL.mobi Group Stored Credit Use 1 of 1 68 Members Mobile and Landline Calling / Mobile Text Sending
E. TEL.mobi Group Stored Credit Swaps 1 of 2 69 “Mobile Operator Stored Credit Swaps” / “MOSCS” between Members
F. TEL.mobi Group Stored Credit Swaps 2 of 2 75 Currency Conversions between Member’s Currency Wallets
G. TEL.mobi Group Stored Credit Outward Flows 1 of 1 77 Members’ Stored Credit Refund Transfer System 7
STANDARD DIRECT CARRIER BILLING SERVICES & DIRECT-TO-MOBILE-BILL SERVICES – 80 OVERVIEW Standard Direct Carrier Billing Services & Direct-to-Mobile-Bill Services – Overview 81
THE TEL.MOBI GROUP’S VIEW OF STANDARD DIRECT CARRIER BILLING & DIRECT-TO- 85 MOBILE-BILL SERVICES The TEL.mobi Group’s View of Standard Direct Carrier Billing & Direct-to-Mobile-Bill 86 Services
OVERVIEW OF THE TEL.MOBI GROUP’S FIRST-MOVER “ICLM” DIRECT-TO-MOBILE-BILL 88 SERVICE AND “TITAN” SYSTEM Overview of the TEL.mobi Group’s First-Mover “ICLM” Direct-to-Mobile-Bill Service and 89 “TITAN” System A. ICLM Service Overview 89 B. ICLM Transactions Overview 91 C. The “TITAN System” Overview 92 D. Setup and Advantages of the TITAN System for ICLM Transactions 94
COMPARISON – STANDARD TELCOS’ DIRECT-TO-MOBILE-BILL SERVICES, VERSUS THE 95 TEL.MOBI GROUP’S FIRST-MOVER ICLM DIRECT-TO-MOBILE-BILL SERVICES Comparison – Standard Telcos’ Direct-to-Mobile-Bill Services, Versus the TEL.mobi 96 Group’s First-Mover ICLM Direct-to-Mobile-Bill Services A. Background – “Stored Credit” 96 B. Loading Stored Credit onto a Prepaid Telephone Account 97 C. Primary Services Provision for Stored Credit and/or Funds 99 D. Secondary Services Provision for Stored Credit and/or Funds 100 E. Stored Credit Limits 102 F. Stored Credit Refunds 103 G. Summary 106
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THE ICLM SERVICE IS A BETTER ALTERNATIVE AND/OR ADDITION TO MANY COMMERCIAL 107 PRODUCTS AND SERVICES The ICLM Service is a Better Alternative and/or Addition to many Commercial Products 108 and Services A. The ICLM Service is an Alternative to Debit Cards / Prepaid Cards 108 B. The ICLM Service is an Alternative to “Cards on Phones” 110 C. The ICLM Service is an Alternative to many “FinTech” Companies 112 D. The ICLM Service is an Alternative to Remittances Companies 114 E. The ICLM Service is an Alternative to Money Transfer Companies 116 F. The ICLM Service is an Alternative to Payment Gateways 117 G. The ICLM Service is an Alternative to Forex Conversion Companies 118 H. The ICLM Service is an Alternative to Travel Money Cards 119 I. The ICLM Service is an Addition to Travel Money Card Companies 119 J. The ICLM Service is an Alternative to Bureaus de Change 120 K. The ICLM Service is an Addition to Bureaus de Change 120 L. The ICLM Service is an Addition for Letter of Credit Companies 121 M. The ICLM Service is an Addition for Escrow Companies 123 N. Other Uses 125
EXAMPLES OF THE ICLM SERVICE’S NUMEROUS ADVANTAGES OVER MANY COMMERCIAL 126 PRODUCTS & SERVICES Examples of the ICLM Service’s Numerous Advantages over many Commercial Products 127 & Services A. Website and eCommerce Transactions – An Instant Payment Gateway 127 B. Commercial and Business Transactions – Retail and Wholesale 131 C. Remittances Sending and Receiving 134 D. Payroll Transactions 139 E. Trade and Commodity Trading Transactions 142 F. Oil Purchases/Sales Transactions 144 G. Examples of Other ICLM Transactions 145 H. Example of Alternative ICLM Uses on the TITAN System 149 I. Summary 152 9
COMPARISON – ICLM AND TITAN SYSTEM CAPABILITIES VERSUS “LEGACY SYSTEM” 153 CAPABILITIES Comparison – ICLM and TITAN System Capabilities Versus “Legacy System” Capabilities 154 A. Legacy Systems Overview 154 B. Comparison of the TEL.mobi TITAN System with Legacy Systems 156 C. Illustration of a Legacy System Transaction Flow versus an ICLM Transaction Flow 159 on the TITAN System, for Exactly the Same Transaction D. Illustration of the High Hidden Costs within Legacy System Transactions 160 E. How “Legacy Attitudes” Retard or Stop Modernization of Legacy Systems 161 F. Susceptibility of Legacy Systems to Money Laundering 163 G. Comparison – Legacy System Transaction Flow versus an ICLM Transaction Flow 165 on the TITAN System H. Summary of the Advantages of the ICLM Service over Legacy Systems 172
SOME OF THE MULTIPLE COMMERCIAL AND FINANCIAL ADVANTAGES OF THE ICLM 174 SERVICE FOR MEMBERS AND MERCHANTS
Some of the Multiple Commercial and Financial Advantages of the ICLM Service for 175 Members and Merchants
A. Advantages for Retail, Wholesale, Trade, eCommerce and other Merchants 175 B. Notification and Display of ICLM / TITAN Transactions Acceptance 183
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THE TEL.MOBI GROUP’S STREAMLINED AND SECURE REFUND TRANSFER RULES AND 184 LIMITS
The TEL.mobi Group’s Streamlined and Secure Refund Transfer Rules and Limits 185
A. Rules and Limits if all Stored Credit is Loaded from Member’s own Bank 188 Refund Request/s of over Euro 9 999.00* per month
B. Rules and Limits if all Stored Credit Loaded from Member’s Top-Up Voucher 189 Refund Request/s of over Euro 9 999.00* per month
C. Rules and Limits if all Stored Credit is not Loaded by the Member 190 Refund Request/s of over Euro 9 999.00* per month from Ad-Hoc ICLMs
D. Rules and Limits if all Stored Credit is not Loaded by the Member 191 Refund Request/s over Euro 9 999.00* per month from Regular Business ICLMs
E. Rules and Limits if all Stored Credit is not Loaded by the Member 192 Refund Request/s of under or up to Euro 9 999.00 per month
F. Full Visibility of the entire flow of ICLM Transactions prior to Refund 193
G. Refund Transfer Request Review prior to Actioning 193
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SECTION 2 – THE VSMP OPPORTUNITY 194
COMPARISON OF THE STANDARD TELCO “MVNO PROGRAM” WITH THE UNIQUE 195 TEL.MOBI GROUP “VSMP PROGRAM” Comparison of the Standard Telco “MVNO Program” with the Unique TEL.mobi 196 Group “VSMP Program” A. Overview 196 B. Comparison 197
THE VSMP OPPORTUNITY – WHAT AN “ELIGIBLE ENTITY” IS 199 The VSMP Opportunity – What an “Eligible Entity” is 200 A. Eligible Entities’ Characteristics 200 B. Eligible Entities’ Legal Status as VSMPs 201 C. Examples of Eligible Entities that have applied for TEL.mobi VSMPs 202
THE VSMP OPPORTUNITY – WHY IT EXISTS AND HOW IT WORKS 203 The VSMP Opportunity – Why it Exists and How it Works 204 A. Overview 204 B. The Webtel.mobi, Independent Agent, VSMP and Member Flow 205 C. The Webtel.mobi, Independent Agent, VSMP and Member Interaction 205 D. The TEL.mobi Group Value Constellation System 206
THE VSMP OPPORTUNITY – THE PRIMARY REQUIREMENT FOR ELIGIBLE ENTITIES 207 The VSMP Opportunity – The Primary Requirement for VSMPs 208 A. Eligible Entities’ Requirements to Establish a VSMP 208 B. Primary Requirement – Forwarding Marketing Messages 209 C. Forwarding Marketing Messages – Important Points 211
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THE VSMP OPPORTUNITY – ELIGIBLE ENTITIES’ COMMISSION DONATIONS 212 The VSMP Opportunity – Eligible Entities’ Commission Donations 213 A. Overview 213 B. Flow of Commission Donations to Eligible Entities 214
THE VSMP OPPORTUNITY – SITUATIONS WHERE ONE ELIGIBLE ENTITY SHOULD HAVE 215 MULTIPLE VSMPs The VSMP Opportunity – Situations where one Eligible Entity should have Multiple VSMPs 216 A. Overview 216 B. Situations where one Eligible Entity should have Multiple VSMPs 217 C. Structuring in cases when one Eligible Entity has Multiple VSMPs 218 D. Changing VSMPs from a Global VSMP to an Agent VSMP 220
THE VSMP OPPORTUNITY – OTHER SIGNIFICANT ADVANTAGES FOR ELIGIBLE ENTITIES 221 The VSMP Opportunity – Other Significant Advantages for Eligible Entities 222 A. Easy and Immediate Commencement at No Cost, with Peace of Mind 223 B. Gain Additional Revenues and Advantages at Zero Cost 224 C. Utilize the VSMP’s Services to Reduce their Own Company Costs 224 D. Gain a Competitive Advantage over Competitors 225 E. Summary 225
THE VSMP OPPORTUNITY – RESTRICTIONS 226 The VSMP Opportunity – Restrictions 227 A. VSMP Restrictions – Names 227 B. VSMP Restrictions – Persons and Entities 229 C. VSMP Restrictions – Activities 230
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SECTION 3 – VSMP TYPES, USES AND ESTABLISHMENT 231
THE WIDE RANGE OF TEL.MOBI GROUP GLOBAL VSMPS THAT CAN BE FORMED AND 232 THEIR USES The Wide Range of TEL.mobi Group Global VSMPs that can be Formed and their Uses 233 A. Global VSMPs – Overview 234 B. Global VSMPs – Types 235 C. Agent VSMPs 236
STREAMLINED AND RAPID PROCESS FOR EASY ESTABLISHMENT OF TEL.MOBI GROUP 237 GLOBAL VSMPs WITHIN 24 HOURS Streamlined and Rapid Process for Establishment of TEL.mobi Group Global VSMPs 238 Within 24 Hours A. Establishment by an Eligible Entity Directly 238 B. Establishment by an Eligible Entity Directly via an Unassigned VSMP 239 C. Establishment by an Independent Agent on behalf of an Eligible Entity 240
SPECIAL CUSTOMIZED TEL.MOBI GROUP VSMPS THAT CAN BE FORMED AND THEIR USES 242 Special Customized TEL.mobi Group VSMPs that can be Formed and their Uses 243 A. SMS / Text Voting VSMPs 244 B. Premium Rate SMS/Text Payments VSMPs 246 C. Restricted VSMPs 248 D. Closed and Restricted VSMPs 249
IMPORTANT CONSIDERATIONS DURING TEL.MOBI GROUP GLOBAL VSMP ESTABLISHMENT 250 Important Considerations During TEL.mobi Group Global VSMP Establishment 251 A. Choosing a Free VSMP name 251 B. The Free Unique VSMP url, and Free Hosting 252 C. The Free VSMP Template and 360+ Free Color-variation Templates 253 D. Standalone VSMP url 254 14
SECTION 4 – ADDITIONAL REVENUE-GENERATION 257
ADDITIONAL OPTIONAL REVENUE-GENERATING OPPORTUNITIES FOR ELIGIBLE ENTITIES 258 Additional Optional Revenue-Generating Opportunities for Eligible Entities 259 A. Discounted Redemptions of ICLM Transactions for TMG Members 259 B. Reselling Electronic Top-Up Vouchers to TEL.mobi Group Members 259 C. Assisting TMG Members to obtain Substitute KYC at Attorneys / Notaries 260 D. Obtaining and Placing of TMG Stored Credit Refund Machines (SCRMs) 260 E. Distribution of Additional TMG Services and/or Products in the future 260
TOP-UP VOUCHER ACQUISITION AND RESALE BY ELIGIBLE ENTITIES 261 Easy and Secure Top-Up Voucher Acquisition and Resale by Eligible Entities 262 A. Top-Up Voucher Order and Acquisition 262 B. Top-Up Voucher Resale 264
DISCOUNTED REDEMPTIONS OF ICLM TRANSACTIONS BY ELIGIBLE ENTITIES 267 Discounted Redemptions of ICLM Transactions by Eligible Entities 268 A. Overview 268 B. Rules – Appropriate Situations 269 C. Rules – Specific Process for First-Time Discounted Redemptions 270 D. Rules – Specific Process for Follow-Up Discounted Redemptions 279 E. Rules – Amount Limits 281 F. Rules – ICLM Descriptions, Special Circumstances and Field Trips 286 G. Support for TEL.mobi Group VSMPs 287 H. Cautionary Comments for TEL.mobi Group VSMPs 288
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SECTION 5 – ROLE OF THE INDEPENDENT AGENTS 290
ELIGIBLE ENTITY ASSISTANCE FROM AND VSMP MONITORING BY INDEPENDENT AGENTS 291 Eligible Entity Assistance From and VSMP Monitoring By Independent Agents 292 A. Each VSMP has its own Independent Agent 292 B. Eligible Entity Assistance from Independent Agents 293 C. VSMP Review and Monitoring by Independent Agents 294 D. Eligible Entities can become Independent Agents 296
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SECTION 6 – AML, KYC AND SECURITY 297
COMPARISON BETWEEN STANDARD TELCOS’ AML & KYC PROCEDURES AND THE 298 TEL.MOBI GROUP’S 30-LAYER-DEEP AML & KYC PROCEDURES
Comparison between Standard Telcos’ AML & KYC Procedures and the TEL.mobi 299 Group’s 30-Layer-Deep AML & KYC Procedures
A. Standard Telephone Company / Aggregator AML and KYC procedures 300 For their Standard Direct Carrier Billing / Direct-to-Mobile-Bill services
B. The Webtel.mobi / TEL.mobi Group KYC and AML procedures 302 For its “ICLM” Direct-to-Mobile-Bill services
C. General comment on TEL.mobi Group KYC and AML procedures 316
SECURITY OF COMMISSION DONATIONS CONTINUITY FOR VSMPS AND SECURITY OF 318 MEMBERS’ STORED CREDIT Security of Commission Donations Continuation for VSMPs, and Security of Stored 319 Credit of Members A. Overview 319 B. Continuity of Commission Donations for VSMPs 320 C. Security of Stored Credit for Members 322 D. Electronic Tagging of Accounts for Commission Donations Consistency 324 E. Procedure if url is Blocked or Non-Functional 325
SAFETY REQUIREMENTS AND RESTRICTIONS – TEL.MOBI GROUP VSMP AND ELIGIBLE 326 ENTITY ACTIVITIES Safety Requirements and Restrictions – TEL.mobi Group VSMP and Eligible Entity Activities 327
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SAFETY REQUIREMENTS AND RESTRICTIONS – TEL.MOBI GROUP MEMBER ACTIVITIES 329 Safety Requirements and Restrictions – TEL.mobi Group Member Activities 330
MULTIPLE SAFE METHODS FOR TEL.MOBI GROUP MEMBER ACCOUNT LOADING 332 Multiple Safe Methods for TEL.mobi Group Member Account Loading 333 A. Overview 333 B. Loading via Payment Gateway 334 C. Loading via Top-Up Voucher 334
TEL.MOBI GROUP DATA SECURITY AND INFORMATION SECURITY – PROTECTING MEMBERS 335 AND VSMPS WHILE UPHOLDING THE LAW TEL.mobi Group Data Security and Information Security – Protecting Members and VSMPs 336 while Upholding the Law
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SECTION 7 – TEL.MOBI GROUP IMPENDING SERVICES 338
OVERVIEW OF THE TEL.MOBI GROUP’S SIGNIFICANT IMPENDING SERVICES 339 Overview of the TEL.mobi Group’s Significant Impending Services 340 A. TEL.mobi Group Multilingualization Facility 341 B. TEL.mobi Group Loyalty Card Facility 342 C. TEL.mobi Group Stored Credit Refund Machines (SCRMs) 343 D. TEL.mobi Group Global Business Pages Facility 346 E. TEL.mobi Group Global Marketplace Facility 348 F. TEL.mobi Group Targeted Pay Per Click Marketing (PPC) Facility 350 G. TEL.mobi Group Global Emergency System Facility 354
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SECTION 8 – TEL.MOBI GROUP RESTRICTED SERVICES 357
VOLUNTARILY RESTRICTED TEL.MOBI GROUP SERVICES 358 Voluntarily Restricted TEL.mobi Group Services 359 A. Global Lottery 360 B. Global Bulk SMS/Text Sending 363
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SECTION 9 – IMPORTANT ADMINISTRATIVE CONSIDERATIONS 364
COMPREHENSIVE FACILITIES FOR ELIGIBLE ENTITIES TO ESTABLISH AND MONITOR 365 THEIR OWN VSMPs IN A NON-COMPLEX AND RAPID MANNER Comprehensive Facilities for Eligible Entities to Establish and Monitor Their Own 366 VSMPs in a Non-Complex and Rapid Manner A. Overview 366 B. Preparation, Application and Establishment 367 C. Familiarization – VSMP Administration Console 369
FREE “T-OPS” ADMINISTRATION CONSOLE, FOR EASY AND EFFECTIVE, LEADING-EDGE 371 & COMPREHENSIVE MANAGEMENT Free “T-OPS” Administration Console, for Easy and Effective, Leading-Edge and 372 Comprehensive Management A. Overview 372 B. Snapshot of the VSMP Administration Console (the T-OPS System) 375
FAIR, OPEN AND TRANSPARENT TEL.MOBI GROUP VSMP TERMS, TERM AND 376 TERMINATION Fair, Open and Transparent TEL.mobi Group VSMP Terms, Term and Termination 377 A. Terms – Establishment and Commission Donations 377 B. Term 378 C. Termination 378 D. Voluntary Retirement of a VSMP 379 E. Other 379
ADDITIONAL HELPFUL INFORMATION FOR ELIGIBLE ENTITIES 380 Additional Helpful Information for Eligible Entities 381
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THE TEL.MOBI GROUP VSMP ASSOCIATION – TO ASSIST AND SUPPORT TEL.MOBI GROUP 383 VSMPs AND ELIGIBLE ENTITIES The TEL.mobi Group VSMP Association – To Assist and Support TEL.mobi Group VSMPs 384 and Eligible Entities
APPLICATION TO ESTABLISH A TEL.MOBI GROUP VSMP 385 Application to Establish a TEL.mobi Group VSMP 386
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SECTION 10 – APPENDIXES 388
APPENDIX 1 – TEL.MOBI GROUP TERMINOLOGY, ACRONYMS AND ABBREVIATIONS 389 Appendix 1 - TEL.mobi Group Terminology, Acronyms and Abbreviations 390 A. Services Acronyms and Abbreviations 390 B. Facilities Acronyms and Abbreviations 398
APPENDIX 2 – COPIES OF REQUIRED KYC CERTIFICATION DOCUMENTS 403 Appendix 2 – Copies of Required KYC Certification Documents 404 Personal KYC Confirmation Document 405 Personal KYC Substitute Document 409 Corporate KYC Confirmation Document 413
APPENDIX 3: COPIES OF ICLM REDEMPTION DOCUMENTS 418 Appendix 3: Copies of ICLM Redemption Documents 419 ICLM Redemption A 420 ICLM Redemption B 426 ICLM Redemption C 432 ICLM Redemption D 438 ICLM Photo and Fingerprint Confirmation Document 444
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SECTION 1
PRODUCTS, FACILITIES
AND SERVICES
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OVERVIEW OF
WEBTEL.MOBI
AND
THE TEL.MOBI GROUP
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OVERVIEW OF WEBTEL.MOBI AND THE TEL.MOBI GROUP
The TEL.mobi Group comprises the Group’s driving company Webtel.mobi – which is a Specialized Mobile Provider company – combined with all its Virtual Specialized Mobile Provider (VSMP) affiliates and all its Independent Agents. Together they comprise the TEL.mobi Group, which has the following characteristics that its Members can make use of:
A. Webtel.mobi – Overview of the Company and Service:
1. Webtel.mobi is a Global Telephony Provider, of a type that is formally referred to as a Specialized Mobile Provider.
2. Webtel.mobi is formally classified as an Internet Telephony Service Provider (ITSP). This because its Calls and Texts are internet-Initiated (that is, the calls or texts are initiated from the internet, but as soon as they are initiated, they leave the internet and are on the global
telephony infrastructure. It is not a VoIP service).
3. Webtel.mobi is a Closed-Loop, Members Only, System and Service.
4. Webtel.mobi’s full name is Webtel.mobi (Holdings) Limited. Its business is run from Guernsey.
5. Webtel.mobi has been providing Global Telephony Services worldwide since 2009.
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B. The TEL.mobi Group – Overview:
1. Webtel.mobi carries out its worldwide operations through a system of Affiliates, which Webtel.mobi appoints itself and through the activities of Independent Marketing Agents that source Affiliates for it.
2. The Affiliates are known as VSMPs. This acronym stands for “Virtual Specialized Mobile Provider”. They are called this because Webtel.mobi is a Specialized Mobile Provider (“SMP”), and the Affiliates are Virtual versions of Webtel.mobi, rebranded for the Affiliates.
3. The Independent Marketing Agents that provide Independent Services to Webtel.mobi to source VSMPs are known as “Independent Agents”.
4. Because the Global Business Model of Webtel.mobi includes its close co-operation with its VSMPs and Independent Agents, all of these entities and persons function together closely.
5. The collective association of Webtel.mobi, its VSMPs and its Independent Agents worldwide is cumulatively referred to as “The TEL.mobi Group”.
6. It is called this because all of its VSMPs’ websites / urls end with the suffix “tel.mobi”.
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DESCRIPTION OF THE
TEL.MOBI GROUP’S PRIMARY
TELEPHONY SERVICES
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DESCRIPTION OF THE TEL.MOBI GROUP’S PRIMARY TELEPHONY SERVICES
The TEL.mobi Group’s Primary Services comprise Global Telephony and Texting services, in the Mobile and Landline Sectors, and in some Satellite Phone Sectors. It is the most comprehensive Telephony Provider Internationally, in terms of Geographic Coverage (in which it has Global Dominance) and also in terms of Types of Telephony Services. It provides a full range of Mobile telephony Services and Landline Telephony Services – as well as a suite of additional services for both Mobile Calls & Texts and Landline calls that are unique to Webtel.mobi and the TEL.mobi Group. More information on these aspects can be seen in the Frost & Sullivan Comments Video, in the Corporate Video within the “Videos” link on TEL.mobi Group Sites and in the Documents at the “Research” link on TEL.mobi Group Sites. A list of the TEL.mobi Group’s consolidated Telephony Services is as follows:
A. Mobile Calling and Texting Services:
1. Local Calls – Mobile to Mobile 2. Local Calls – Mobile to Landline 3. Local Texts – Mobile to Mobile
4. Long Distance Calls – Mobile To Mobile 5. Long Distance Calls – Mobile to Landline 6. Long Distance Texts – Mobile to Mobile
7. International Calls – Mobile To Mobile 8. International Calls – Mobile to Landline 9. International Texts – Mobile to Mobile
10. Roaming Calls – Mobile To Mobile 11. Roaming Calls – Mobile to Landline 12. Roaming Texts – Mobile to Mobile
13. Premium Rate Calls – Mobile to Mobile (On arrangement, in certain circumstances) 14. Premium Rate Calls – Mobile to Landline (On arrangement, in certain circumstances) 15. Premium Rate Texts – Mobile to Mobile (On arrangement, in certain circumstances)
All of the above at average costs of up to 80% less than standard providers’ costs 30
B. Landline Calling Services:
1. Local Calls – Landline to Mobile 2. Local Calls – Landline to Landline
3. Long Distance Calls – Landline to Mobile 4. Long Distance Calls – Landline to Landline
5. International Calls – Landline To Mobile 6. International Calls – Landline to Landline
7. Premium Rate Calls – Landline to Mobile (On arrangement, in certain circumstances) 8. Premium Rate Calls – Landline to Landline (On arrangement, in certain circumstances)
All of the above at average costs of up to 80% less than standard providers’ costs
C. Satellite Phone Calling Services:
1. Satellite Phone to Satellite Phone Calls (Selected Providers) 2. Satellite Phone to Mobile Phone Calls (Selected Providers) 3. Satellite Phone to Landline Phone Calls (Selected Providers) 4. Landline Phone to Satellite Phone Calls (Selected Providers) 5. Mobile Phone to Satellite Phone Calls (Selected Providers)
All of the above at average costs of up to 50% less than standard providers’ costs
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D. Specialized Calling and Texting Facilities:
1. Computer-Initiated Mobile Calls
Computer-Initiated Mobile Calls – Local Computer-Initiated Mobile Calls – Long Distance Computer-Initiated Mobile Calls – International Computer-Initiated Mobile Calls – Roaming
Calls from Mobile Phones can be initiated from the TEL.mobi Online application on Computers or Personal Electronic Devices (“PEDs”), all at the very low TEL.mobi Group rates
2. Computer-Initiated Mobile Texts
Computer-Initiated Mobile Texts - Local Computer-Initiated Mobile Texts – Long Distance Computer-Initiated Mobile Texts - International Computer-Initiated Mobile Texts – Roaming
Texts from Mobile Phones can be initiated from the TEL.mobi Online application on Computers or PEDs. All texts sent this way are at the same cost, whether Local, Long Distance, International or Roaming
3. Mobile-Initiated Landline Calls
Mobile-Initiated Landline Calls – Local Mobile-Initiated Landline Calls – Long Distance Mobile-Initiated Landline Calls – International
Calls from Landline Phones can be initiated from the TEL.mobi Online application on Mobile Phones, all at the very low TEL.mobi Group rates
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4. Computer-Initiated Landline Calls
Computer-Initiated Landline Calls –Local Computer-Initiated Landline Calls –Long Distance Computer-Initiated Landline Calls –International
Calls from Landline Phones can be initiated from the TEL.mobi Online application on Computers or PEDs, all at the very low TEL.mobi Group rates
5. Restricted for Outgoing/International Phones
Restricted Phone to Mobile Calls – Local Restricted Phone to Mobile Calls – Long Distance Restricted Phone to Mobile Calls – International Restricted Phone to Landline Calls – Local Restricted Phone to Landline Calls – Long Distance Restricted Phone to Landline Calls – International
Calls from Phones that are Restricted for Outgoing/International Calls can be initiated to that Phone from a Computer, Tablet or any other internet-enabled PED, all at the very low TEL.mobi Group rates
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E. Universal Number Calling Facility:
The TEL.mobi Calling product has a unique feature, which enables Members to make calls from any Mobile or Landline telephone number, from their accounts, at any time. Calls can be initiated from the TEL.mobi Online Application on a Member’s own Mobile Phone, or any computer or PED. Examples of how this is used are as follow:
1. Hotel Phone Calls
Hotel Phone to Mobile Calls – Local Hotel Phone to Mobile Calls – Long Distance Hotel Phone to Mobile Calls – International Hotel Phone to Mobile Calls – Roaming Hotel Phone to Landline Calls – Local Hotel Phone to Landline Calls – Long Distance Hotel Phone to Landline Calls – International
Local, Long Distance or International Calls to Mobiles or Landlines can be initiated from Hotel Room telephones at any hotels anywhere in the world, via a Member’s TEL.mobi Account. The costs of such calls are TEL.mobi Landline costs – which are a fraction of standard Hotel Phone costs. This Facility is often used by Business or Leisure travelers.
2. Public Phone Calls
Public Phone to Mobile Calls – Local Public Phone to Mobile Calls – Long Distance Public Phone to Mobile Calls – International Public Phone to Mobile Calls – Roaming Public Phone to Landline Calls – Local Public Phone to Landline Calls – Long Distance Public Phone to Landline Calls – International
Local, Long Distance or International Calls to Mobiles or Landlines can be initiated from Public Telephone Booths anywhere in the world, via a Member’s TEL.mobi Account. The costs of such calls are TEL.mobi Landline costs – which are a fraction of International Landline or Mobile costs. This Facility is often used by Students traveling on Gap years.
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3. External Office Phone Calls
Ex-Office Phone to Mobile Calls – Local Ex-Office Phone to Mobile Calls – Long Distance Ex-Office Phone to Mobile Calls – International Ex-Office Phone to Mobile Calls – Roaming Ex-Office Phone to Landline Calls – Local Ex-Office Phone to Landline Calls – Long Distance Ex-Office Phone to Landline Calls – International Local, Long Distance or International Calls to Mobiles or Landlines can be initiated from Telephones at External Offices (i.e. Offices that Members are visiting Internationally or Nationally) anywhere in the world, via a Member’s TEL.mobi Account. The costs of such calls are TEL.mobi Landline costs – which are a fraction of standard National or International Landline costs. This Facility is often used by Business travelers.
4. Roaming SIM Calls
Roaming SIM to Mobile Calls – Local Roaming SIM to Mobile Calls – Long Distance Roaming SIM to Mobile Calls – International Roaming SIM to Mobile Calls – Roaming Roaming SIM to Landline Calls – Local Roaming SIM to Landline Calls – Long Distance Roaming SIM to Landline Calls – International Local, Long Distance or International Calls can be initiated from Local SIM Cards / Local Mobile Phones obtained while travelling anywhere in the world, via a Member’s TEL.mobi Account. The costs of such calls are TEL.mobi Mobile – which are a fraction of International Mobile costs. This Facility is often used by Business and Leisure travelers.
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F. Switchboard Facility:
Another one of the TEL.mobi Group’s unique Telephony Facilities is the Switchboard facility. Through this Facility, a person is able to connect a call between two other person’s telephones – or two different telephones other than his or her own phone – either over the TEL.mobi online application on his or her Mobile Phone or any internet-connected PED.
This is most often used by small businesses that sell telephone calling services from shops to people who do not have their own telephones, or who want to save costs when calling.
Applying this Facility requires only placing the two other telephones’ numbers in the Member’s own “My Number” and “Number I’m calling” fields in his or her own TEL.mobi Account, and clicking the “Call” button. This facility again enables Switchboard connection of:
Switchboard Mobile to Mobile Calls – Local Switchboard Mobile to Mobile Calls – Long Distance Switchboard Mobile to Mobile Calls – International Switchboard Mobile to Mobile Calls – Roaming
Switchboard Mobile to Landline Calls – Local Switchboard Mobile to Landline Calls – Long Distance Switchboard Mobile to Landline Calls – International Switchboard Mobile to Landline Calls – Roaming
Switchboard Landline to Mobile Calls – Local Switchboard Landline to Mobile Calls – Long Distance Switchboard Landline to Mobile Calls – International
Switchboard Landline to Landline Calls – Local Switchboard Landline to Landline Calls – Long Distance Switchboard Landline to Landline Calls – International
All of the above at average costs of up to 80% less than standard providers’ costs
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UNIQUE ADVANTAGES
AND ATTRIBUTES
OF THE
TEL.MOBI GROUP’S
PRIMARY TELEPHONY SERVICES
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UNIQUE ADVANTAGES AND ATTRIBUTES OF THE TEL.MOBI GROUP’S PRIMARY TELEPHONY SERVICES
A. Unique Advantages of the TEL.mobi Primary Services:
The TEL.mobi Group’s Primary Services are unique in many respects. This is why the Central Node from which all of these services are provided – Webtel.mobi – has been characterized as a “First Mover” and “Potential Sector Influencer” in the Global Telephony Sector (a US$ 2.2. Trillion per annum sector). Other than the breadth, scope and unique aspects of its service-provision, other unique advantages of the TEL.mobi Group’s Primary Services are as follow:
1. TEL.mobi Group Members can join and open Accounts on the TEL.mobi Group’s service free of charge, and use it only as and when they want to without any contract fee or monthly fee.
2. TEL.mobi Group Members can use their existing Phones, and Mobile and Landline Phone Numbers, and do not have to change or port their contracts or numbers.
3. TEL.mobi Group Members do not have to enter into a monthly or annual contract to pay any fixed amounts at all. It is a fully pre-paid / pay-as-you-go system.
4. TEL.mobi Group Members can carry out the full-spectrum of Mobile Calls, Mobile Texts, Landline Calls, Specialized Service Calls & Texts and Satellite Phone calls, in, to and from any country, at an average cost of up to 80% less than standard providers’ costs.
5. TEL.mobi Group Primary Services work on all Smart Phone Operating Systems, worldwide (Android, iOS, Symbian, Blackberry, Windows Mobile OS, EMUI, FlyMe OS, HTC Sense, Palm OS, Open WebOS, Indus OS, LG UX, LineageOS, MII, OxygenOS, Pixel UI, Replicant OS, Samsung Experience, Xperia UI, Zen UI, Chrome OS, Tizen, Ubuntu Touch, KaiOS, Maemo, MeeGo, BADA and others).
6. TEL.mobi Group Primary Services work on all Pre-Smart Phones – Basic Mobile Phones and Feature Phones that use WAP - worldwide. Pre-Smart Phones still comprise almost 60% of all Mobile Phones in use – worldwide.
7. TEL.mobi Group Primary Services work on all Makes and Models of Mobile Phones – worldwide.
8. TEL.mobi Group Primary Services work on all Browsers and Mobile Browsers – worldwide.
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9. TEL.mobi Group Primary Services work on all Mobile and Landline Networks – worldwide.
10. TEL.mobi Group Primary Services work on all PCs, MACs, Tablets and other internet-enabled Personal Electronic Devices – worldwide.
11. TEL.mobi Group Primary Services have the same low cost structure internationally, and at all times of the day or night – worldwide.
12. TEL.mobi Group Services can be used for Outgoing Calls or Texts on Mobile Phones – or Outgoing Calls on Landline Phones – that are “locked” for Outgoing Calls (by using the Specialized Calling and Texting Services).
13. TEL.mobi Group Services can be used for International and Long Distance Calls or Texts on Mobile Phones – or International and Long Distance Calls on Landline Phones – that are “locked” for International or Long Distance Calls (by using the Specialized Calling and Texting Services).
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B. Unique Attributes of the TEL.mobi Group’s Primary Services:
The TEL.mobi Group’s Product Suite is unique and custom-built. The end-use requirements were planned before it was built and constructed, so the Product Suite was built according to specification to cater for multiple requirements (6 320 Top-Level Technical, Software, Hardware, Corporate, Administrative, Legal, Jurisdictional, Regulatory and other requirements).
1. The Services are delivered by Online Applications, not Downloadable Apps
Downloadable Mobile Applications do not run on pre-Smart Mobile Phones – such as basic Mobile Phones and feature Phones. These Phones still comprise approximately 60% of Mobile Phones in use worldwide, and any product that provides a Downloadable Mobile Application immediately starts out by excluding 60% of its potential market.
Downloadable Mobile Applications need to be Operating System-specific, and any product wanting to cover all Smart Phone Mobile Operating Systems would need to build 11+ separate Downloadable Mobile Applications – and these would still not work on computers and other PEDs worldwide (for which further multiple Downloadable Desktop Applications would have to be built).
Downloadable Mobile Applications, once downloaded, are legally able to be reverse- engineered by the Mobile Network Operator on whose handsets they are downloaded – so this is an unnecessary security risk.
Downloadable Mobile Applications are also able to be legally reverse-engineered by App Stores on which they are placed, and are subject to very high charges by the App Stores. This represents an unnecessary security risk and an unnecessary and unjustified cost.
If a Mobile Application is downloaded to a handset, the Company that owns the downloaded App can be declared as having a physical presence in the jurisdiction where it has been downloaded. This introduces legal and jurisdictional ambiguity.
For these reasons, the TEL.mobi Group’s Product Suite is delivered via a number of sophisticated Online Mobile and Desktop Applications. This ensures security, cost- effectiveness, availability to all Smart Phones and all pre-Smart phones and all computers and all internet-enabled PEDs worldwide, as well as clarity of jurisdictional and legal domicile. Moreover, if the TEL.mobi Icon is saved onto a Smart Phone’s Home Screen as an icon, it provides one-click opening and operation – in exactly the same manner as a Downloaded Mobile Application.
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2. The TEL.mobi Group’s Primary Services are accessed via an Online Portal
Although there are varying views and definitions of the differences between “Portals” and “Websites”, the general view taken by the TEL.mobi Group is the following –
A Website is a venue where the popularity / interest / sale of goods or services will depend not just on the quality and cost-effectivity thereof, but also on the appearance of the website itself. As such, if it is beautiful, striking or unusual as well as being effective and user-friendly, it may well have more success in attracting clients than those that are not as beautiful, striking or unusual.
A Portal is an online venue where the landing page and pages only represent a gateway or portal through which a User or Member gains access to the information and/or service that he/she is searching for. In other words, the most important aspect is not the appearance on arrival. It is the knowledge and confidence of the User or Member that the information and/or service that will be accessed from the Portal is reliable, high quality and cost-effective (and user-friendliness is also required). A good example of what many people consider to be a form of Portal is the Google home Page – which has just one field, but is one of the most used Search Engines internationally, because the information accessed from the field is considered to be reliable and high quality.
The online presence of the TEL.mobi Group is a Portal. As such, it is not the appearance of the landing page that is of interest to its Members. It is the knowledge and confidence that once logged in, they can access and use the full product Suite of its high-quality facilities easily, and that they are reliable, effective and cost-effective to use. The beauty in the TEL.mobi Product Suite is rather in its effective and reliable service, its global inter- operability and application across all possible platforms, its ease of use and reliability, its security, and its very high-quality at very low cost.
Other considerations for the TEL.mobi online presence to make it a Global product were that it had to be usable and accessible on all mobile and desktop browsers, on all Smart Phones and pre-Smart phones, on all Computers and PEDs. It also had to be easily accessible in high and low internet bandwidth countries, to Prepaid and Postpaid service users, on varying mobile and internet networks with varying firewalls, with ASCII and Unicode and other code capacity. It had to be understandable to potential Members with varying degrees of online capability, with font types and sizes that render properly on all devices, in every country worldwide. Moreover, colors and symbols that carried negative connotations in varying countries had to be avoided. Finally, the entire TEL.mobi Group Product Suite is constructed without JavaScript – because pre-Smart Phones cannot work with JavaScript.
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It is for these reasons that the layout of the landing page of the TEL.mobi Group’s Online Portals is virtually color-free and image-free, with a simple font that will render clearly and in-position on all devices, and with limited and clear wording. This is to cater for all degrees of market sophistication in terms of online products, because 60% of the world does not yet have internet on desktops and uses only Mobile Internet, there are high rates of only partial literacy in multiple countries, and bandwidth is extremely expensive – with very slow page-loading speeds – in many countries. It is merely the landing page that is built to ensure that all users from all countries using all possible devices can with equal ease and reliability access the service, by logging on from the fit-for-its-specific-purpose Landing Page.
3. TEL.mobi Group Calls & Texts are “Internet-Initiated” - not VoIP
The TEL.mobi Group’s telephony Structure and Process is – as are all of its other facilities in-toto – custom built to fulfill a specific function in a specific way.
When the TEL.mobi Group’s Calling Facility is being looked at on a Phone or PED, what one is actually looking at is the product on the TEL.mobi Group’s servers.
When the “Call” button is clicked on the TEL.mobi Calling Facility, a very small amount of data (approximately 48 bytes) is sent from the TEL.mobi Group’s server banks to Next Generation Telephone Switches, which connect and route the call over the Global
Telephony Infrastructure.
This is why all TEL.mobi Group Members are able to Call and Text to the telephones of any persons worldwide – not just to or within Members of the TEL.mobi Group; and why the
TEL.mobi Group is able to be a Global Telephony Provider.
From the moment the “Call” button is clicked (or the “Text” button if sending a Text), no action related to the carrying out of the call takes place on or over the internet, and the internet connection could even be shut down and the call will continue as normal.
This is particularly relevant – as is the fact that the TEL.mobi Group pages render on Mobile Phones and other PEDs using extremely low bandwidth – because in many countries, and for “Prepaid” Mobile Phone users (70%+ of all Mobile Phones in use) – the cost of internet or Mobile Internet bandwidth is very expensive.
The correct definition for TEL.mobi Group Calls and Texts is therefore that they are “Internet-Initiated”, because the only role that the internet plays in them is the Call or text initiation. 42
There were various methodologies that Webtel.mobi could have implemented for their Calling and Texting solutions. This methodology was chosen due to cost-effectivity (low cost), high degree of service quality (call clarity), ease-of-access for Members globally, and ease of use for Members in that they would not have to buy new SIM cards or phones, or change or port their providers to use the TEL.mobi Group service.
4. Webtel.mobi and VSMPs have total inter-operability
Although each VSMP is a stand-alone entity, the TEL.mobi Group system has been built to have 100% interoperability and access between all VSMPs and all TEL.mobi Group Members. This has been done for multiple reasons.
One of the reasons is to enable seamless centralized review and management of the entire TEL.mobi Group ecosystem – and all of its VSMPs, Independent Agents and Members – from a central point.
A second reason is to enable seamless communication and management of Sub-Agents and VSMPs by Independent Agents, regardless of where other Agents and VSMPs are located.
A third reason is to enable Members of Webtel.mobi and all VSMPs to interact seamlessly with Members in other VSMPs.
A fourth reason is that if a VSMP is ever taken down by the TEL.mobi Group, it will not affect the Members of that removed VSMP at all. This is because all Members can log in through any VSMP, and still have all of their credit and data displayed and ready to use in exactly the same way that they do over their own VSMP. Their Stored Credit, History, Data and everything else remains exactly as it is, unchanged, via all and any VSMPs. As such, if their VSMP has been taken down (which only happens if the VSMP’s Eligible Entity has contravened TEL.mobi Group Terms), the Members of that VSMP will simply be redirected
to another VSMP.
There are multiple other reasons for this construction, but these relate to considerations that are not necessary or relevant for the purposes of this Handbook.
Despite the centralized functionality of the TEL.mobi Group facilities and infrastructure, it is delivered from multiple geolocations, with multiple backup and mirroring server banks, to ensure continuance of service and retention of all real-time information and records in the event of any hardware failures and/or cyber attacks.
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5. TEL.mobi Group Security
The TEL.mobi Group has applied a great deal of attention to Member-side security and security in general on its Product Suite. A summary of some of the Security Features are as follow:
The TEL.mobi Group integrated the services of the global online security companies “Inauth” (for Mobile) and “Accertify” (for Desktop) anti-fraud reviews over its Payment Gateway. These are two of the world’s leading companies in this sector.
The TEL.mobi Group has also applied its own Security Features, including its own self- developed “ITAN Number” system (described in the next section of this Handbook) to ensure positive identification of Members in conjunction with their Registered Mobile Numbers.
The TEL.mobi Group has also implemented its own self-developed Five-Factor to Six-Factor “Multi-Factor Authentication” systems within its Facilities to protect Members and their activities / transactions to as high a level as possible (note: international standards usually only utilize Three-factor Multi-Factor Authentication).
As the TEL.mobi Group is a Telephone Company, these Multi-Factor Authentication (MFA) systems were not only developed in-house, they are also run in a fully self-contained manner, with the Transaction Authentication Numbers (“TAN Numbers”) that are part of an MFA system also being generated and sent from in-house.
There are additionally multiple other Security elements within the TEL.mobi Group Product Suite. Summary details of these elements can be seen by reviewing the document at the “Security” static link on the top of TEL.mobi Group Online Portals.
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C. Summary of the TEL.mobi Group’s Primary Services:
The TEL.mobi Group’s Primary Services comprise the most comprehensive services of any telephony Provider worldwide. They encompass the full range of both Mobile and Landline Telephony providers for Calling and Texting services – all in one Company. Moreover, the Primary Services additionally encompass Satellite Phone calling services and unique Calling and Texting services that do not exist in other standard Telephony Companies. These include the Specialized Calling and Texting Services, the Universal Number Calling Facility and the Multi-Number Account Facility. Other than providing this unique range of Calling and Texting facilities, the TEL.mobi Group provides these Primary Services to its Members at costs that are on average up to 80% lower than the costs of standard calls or texts from other providers.
Moreover, the TEL.mobi Group’s product presents a compelling value-proposition across all market-sectors in all countries. This is due to its low rates, easy access and universal workability on all makes and models of the 6+ Billion Mobile Phones in use worldwide (including all Smart Phone Systems, and the 60% of Mobile Phones in use that are pre-Smart Phones). Added to this is the fact that it is also available on and to all internet-enabled computers and all PEDs worldwide, and can be joined for free in all 195 Countries / 241 Countries and Territories worldwide.
It is for this reason that the Global Information and Communications Technologies Practice of Frost & Sullivan declared Webtel.mobi – and thereby the TEL.mobi Group – to be a “First Mover” and “Potential Sector Influencer” in the US$ 2.2 Trillion per Annum Global Telephony Sector
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D. The TEL.mobi Group’s Internet-Initiated Telephony Services:
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DESCRIPTION OF
THE TEL.MOBI GROUP’S
TELEPHONY-SUPPORT
SECONDARY SERVICES
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DESCRIPTION OF THE TEL.MOBI GROUP’S TELEPHONY-SUPPORT SECONDARY SERVICES
In order to support the TEL.mobi Group’s Primary Services in its Product Suite, and to additionally provide a helpful, streamlined and effective service to its Members, and ensure equality of access- opportunity to all Members across various socio-economic sectors in multiple locations, a variety of Secondary and Support facilities were custom-built by Webtel.mobi for use across the TEL.mobi Group.
Although more details of the uses of the Primary Facilities and Secondary/Support Facilities will be provided later in the Handbook, an overview of the Secondary and Support facilities in the TEL.mobi Group Product Suite are as follow overleaf:
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A. TEL.mobi Group Top-Up Voucher and Top-Up Facility:
1. As the TEL.mobi Group’s Global Telephony Service follows a Prepaid model, Members load their telephone accounts with Stored Credit prior to being able to use them – as with all prepaid Models of all Mobile and Landline telephone companies worldwide.
2. However, in order to load their prepaid Telephone Accounts with their Stored Credit, TEL.mobi Group Members have to do so via a Payment Gateway, loading their credit with Credit or Debit Cards, or from online wallets connected to their Bank Accounts.
3. Although this represents a seamless and easy process for many people, it does not, at all, cater for the 30% of Unbanked People in the world (more than 2.2 Billion people). They are unable to access services that require payment from Credit or Debit cards, or facilities linked to a Bank Account.
4. These people have, to a very great extent, been bypassed in respect of 21st Century online products and services, and consequently very often pay much higher costs for their goods and services.
5. To cater for this market, Webtel.mobi developed – in-house – a Globally-Applicable and Multicurrency Top-Up Voucher system. It is the only Globally valid and Multicurrency Top-Up Voucher system in the world that can function in the way that it does, and seamlessly. These Vouchers use a Blockchain system for security, are Encrypted, and each has a Unique Key.
6. TEL.mobi Group Electronic Top-Up Vouchers are pre-purchased by TEL.mobi Independent Agents and VSMPs, for resale to Members.
7. This is easily done by Independent Agents and/or VSMPs using the Payment Gateway (or a bank transfer, or Stored Credit in their TEL.mobi Telephone Accounts – as Webtel.mobi does not accept cash) to purchase Electronic Top-Up Vouchers in any denominations and any quantities that they choose (as appropriate to and for their market).
8. The Top-Up Voucher system is totally in-house developed by the TEL.mobi Group and is totally managed and implemented via the Agents and VSMPs Administration Console. No other equipment is required to be bought, rented or maintained by Independent Agents or VSMPs to enable their safe and secure acquisition – and issue – of these Electronic Top-Up Vouchers.
9. Once the payment for the Electronic Top-Up Vouchers is received by Webtel.mobi, the Voucher Codes are generated, and placed into the relevant part of the Agent’s or VSMP’s Administration Console for retrieval.
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10. The Agent or VSMP then resells the Electronic Top-Up Vouchers to its Members, either at face value (because they will derive revenue from the usage of the Vouchers by their Members in any event), or at whatever mark-up their particular situation merits (as decided by the Independent Agent / VSMP, and the local market demand & supply realities).
11. The Member can then load the Top-Up Voucher onto his or her TEL.mobi Account, and will immediately have electronic Stored Credit available in his/her online account.
12. The Member will therefore be able to participate in the online / 21St Century economy, with Stored Credit in electronic format, and make use of the TEL.mobi Group’s online low-cost and high-quality products in the same way that a Banked Person can – in a fair equality-of-access opportunity situation.
13. Multiple Security aspects have been built in to the TEL.mobi Top-Up Voucher system, including a unique facility for Members to check the validity of the voucher and the amount that it is worth prior to paying for it.
14. Moreover, the Top-Up Voucher system and process includes delivery of not just a unique 16- digit Top-Up Voucher Code (which contains encoded details of the Voucher Currency and denomination), but also a unique 5-digit KEY which is only able to be matched with its unique Voucher Number in order to be able to redeem the Top-Up Voucher.
15. This results in a fully secured, securitized and controllable system, which functions according to classic Blockchain principles, and is a hybrid of centralized and decentralized systems. This is because Voucher recipients are able to change the KEY on purchase of the Top-up Voucher – in order to protect the integrity of the Top-Up Voucher if there is going to be a lead-time between their purchasing the Top-Up Voucher and loading it onto their TEL.mobi Accounts.
16. This Service and Facility is provided free to TEL.mobi Group Members, in that there is no charge by the TEL.mobi Group for the issue of a Top-Up Voucher (other than the Stored Credit amount that was purchased).
17. This is another world-first and unique product within the TEL.mobi Group Product Suite.
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B. TEL.mobi Group Currency Wallets Facility:
1. As TEL.mobi Group Members are in various countries, and because many of them travel or work in countries other than those in which they live, they often load their accounts with Stored Credit in different currencies – either over the Payment Gateway or through buying Electronic Top-Up Vouchers in different currencies in different countries.
2. In order to assist Members so that they do not suffer under the notorious “Double Billing” system (whereby they are effectively “billed” a second time through the forced conversion of one currency to another over which they have no control), the TEL.mobi Group has applied a “Currency Wallet” system within its Members’ Prepaid Telephone Accounts.
3. Although they are called “Currency Wallets”, these “Wallets” are not, in fact, Wallets as known or referred to in Financial Services Models. They are only termed as “Wallets” in the TEL.mobi Group environment to indicate to Members the nature of their potential Storage use. They are in fact only sub-divisions of the Member’s existing Prepaid Telephony Account, which enables the Member to retain his or her Stored Credit in different currencies in the Prepaid Account – without being forced to convert them all into one currency without his or her control or input.
4. They are additionally structured so that Members can choose from which “Currency Wallet” the billing for their Calls and Texts takes place at any time.
5. These “Currency Wallets” for their Accounts are able to be immediately and automatically selected by Members within their own Prepaid Telephone Accounts, at any time.
6. This Service and Facility is provided free to TEL.mobi Group Members.
7. This is a world-first and unique Facility within the Global Telephony Sector.
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C. TEL.mobi Group Currency Conversions Facility:
1. As a further refinement to the Currency Wallet system, and also to ensure that TEL.mobi Group Members are protected from “Double Billing” system and process, the TEL.mobi Group has also built a customized Currency Conversion system within the TEL.mobi Product Suite.
2. Unlike all other TEL.mobi Facilities, this system includes integration with an external party, which has modified its existing systems to build a customized solution that could integrate harmoniously with the TEL.mobi Group Product Suite.
3. Initially, the TEL.mobi Group applied its own custom-built Currency Conversion system. However, because the TEL.mobi Group is a Telephony Company and not a Currency Trading company or Financial Services company, it took the decision to rather let a leading sector- specialist company in Currency Trading that was capable of integrating with the TEL.mobi Product Suite execute these activities on behalf of the TEL.mobi Group.
4. What was therefore done was to integrate the TEL.mobi Group’s online and instant live Currency Conversion system with that of the (customized to TEL.mobi requirements) Currency Conversion company’s systems.
5. This has brought about a system whereby all TEL.mobi Members worldwide can – from a mobile phone in a rural area or a sophisticated computer terminal in a capital City – immediately carry out online and real-time Currency Conversions, at extremely favorable rates.
6. The purpose of this is to assist Members who have online Stored Credit in one or some of their “Currency Wallets” to convert and consolidate these remaining funds back into one currency if they are finished with their travels.
7. Alternatively, they can convert from one currency to another before travelling, to have some of the “local” currency from whatever countries they are travelling to in their Currency Wallets, and be able to monitor and evaluate what the costs are in relation to local norms.
8. This will also – as with the Currency Wallets – alleviate TEL.mobi Group Members’ exposure to the notorious “Double-Billing” system of enforced currency conversions over which they have no control, as the control of any currency conversions is now placed firmly in their control, and at extremely favorable and equitable live currency rates.
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9. This facility enables any Member to immediately carry out live-rate currency from any location 24/5/365 (it is available five days a week, when Global Forex Markets are open), to consolidate their own Stored Credit themselves.
10. This Service and Facility is provided to TEL.mobi Group Members at Conversion rates that are more favorable than many Bank Rates.
This is a unique and world-first product in the Global Telephony sector.
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D. TEL.mobi Group Top-Up Transfers Facility:
1. As with all Prepaid Telephony Companies, the TEL.mobi Group provides the facility for Members to Top-Up one another’s Prepaid Telephony Accounts with Stored Credit.
2. The first Primary Market for this facility is Members who are “Banked”, who Top Up their dependents, employees or business associates’ TEL.mobi accounts for them. Examples of this are Parents who Top-Up their children’s accounts when the children are travelling or at University, employees of companies or business partners who are travelling on business for a company, and similar situations. In this case, the motivation for Topping Up another person’s account is that they are dependents or employees of the person/entity doing the Topping-Up.
3. The second Primary Market for this facility is Members who are “Unbanked”. In this case, it is not possible for family members or friends / associates of Members who are also Unbanked to credit their Prepaid Telephone Accounts with electronic Stored Credit if they are not able to obtain TEL.mobi Electronic Top-Up Vouchers. In such cases, Unbanked Members who have already credited their Accounts through purchasing TEL.mobi Group Electronic Top-Up Vouchers, are able to Top-Up the TEL.mobi Prepaid Telephone Accounts of other Unbanked Members through Top-Up Transfers, to enable them to also enter into a the 21st Century market, and utilize the Global Telephony Facilities of the TEL.mobi Group.
4. The TEL.mobi Group Top-Up Transfer service is a custom-built and unique service internationally, and it has many unique attributes.
5. Included among these attributes is that a Top-Up Transfer can be done from any Currency Wallet of any Member to any other Currency wallet of any other Member – in any VSMP and across & between all VSMPs – internationally.
6. Members can also use the Currency Conversion facility to do a Currency Conversion from their currency to the currency of the recipient – online, instantly and at market leading favorable rates.
7. Thereafter, they can implement the Top-Up Transfer to the other Member, and the Top-Up Transfer will be completed within 1/100th of a second – whether the recipient Member is sitting right next to the transferee, or is on the other side of the world.
8. This can be done directly by all and any Members, 24/7/365.
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9. Moreover, as with the “Currency Wallets”, although this facility is called a “Top-Up Transfer” Facility, this is only to illustrate its use to Members, because it is, in fact, not a “Transfer” at all as understood in Financial Services terms.
10. As is standard Best Practice, all Members’ Stored Credit is held in the same Bank Account. Therefore, when a Member does a Top-Up Transfer of his/her Stored Credit from his/her TEL.mobi Group Prepaid Telephone Account to another Member’s TEL.mobi Prepaid Telephone Account, no actual Transfer of any sort occurs, because no Stored Credit moves out of the Bank Account, at all.
11. All that in fact happens – again as Standard Best Practice – is that the Ledger Entry record of Stored Credit in the Bank Account is immediately adjusted to reflect X amount instantly debited from the “Sending Member’s” TEL.mobi Prepaid Telephone Account, and the same X amount instantly credited to the “Receiving Member’s” TEL.mobi Group Prepaid Telephone Account.
12. Therefore, there is an instantaneous Top-Up “Transfer” of Stored Credit from one Member to another, which takes 1/100th of a second to complete whether the Members are next to each other or halfway across the world, without any actual physical “Transfer” of funds occurring, because they remain static in one Bank Account.
13. Because the Bank Account is a Multicurrency Account, even if the Transfer is done from one currency to another, the funds in the Bank Account similarly do not move in any “Transfer”. They are just reallocated from one currency sub-account to another currency sub-account within the same Bank Account, with, again, only a ledger-entry change required.
14. Through this, the TEL.mobi Group has achieved that which was previously considered to be an impossible task – that of enabling real Peer-to-Peer Top-Up Transfers, on demand and under the control of the Members, globally and instantaneously, in a fully self-sustaining matrix, from and to any currencies, 24/7/365. Moreover, it is a system whereby although the Stored Credit owned by various Members alters, no actual “Transfer” of any funds from one place to another or from one Bank Account to another ever takes place.
15. This Service and Facility is provided to TEL.mobi Group Members at extremely low cost, which are on average up to 90% less than other “Top-Up” services
16. In the way that it is configured and functions, ii is a world-first and unique Facility in the Global Telephony Sector.
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E. TEL.mobi Group ITAN Number Facility:
1. In order to increase the level of security of and for TEL.mobi Group Members’ Accounts, account management and Transactions, the TEL.mobi Group developed the Inter-Tel.mobi Account Number or ITAN system.
2. The ITAN system functions in the same manner as the International IBAN system, but it is just more widespread – being worldwide in applicability and operation, as opposed to being limited to a comparatively small geographic area.
3. The ITAN Numbers are 20-digit account numbers, with a unique ITAN Number assigned to every TEL.mobi Group Member’s account.
4. The ITAN Numbers are also specifically constructed, so that they indicate the Region and Country in which the Member whose account it is resides, as well as other aspects.
5. Most Transactions on the TEL.mobi Group Product Suite require the inserting of a Member’s ITAN Number to proceed.
6. The Member-unique ITAN Number combined with the Member-unique Mobile Phone Number (which must match) brings about a totally unique verification methodology, which must match in order for Member Transactions to proceed. This resolves any issues to do with – for the simplest considerations – incorrect or duplicate Member names, misspellings, etc; as well as more substantial considerations.
7. The ITAN Numbers – together with texted TAN Number and other security features – also enhance the security for TEL.mobi Group Member Accounts and activities to Five-Factor or Six- Factor Multi factor Authentications.
8. This Service and Facility is provided free to TEL.mobi Group Members.
9. The ITAN Number system is another unique and world-first feature in the Global Telephony Sector.
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F. TEL.mobi Group Refund Transfers Facility:
1. In all situations where clients or members of a company or organization prepay for a service – which prepayment they will draw down on progressively as they use the service – this pre- payment (with all Companies) – is known as “Stored Credit”.
2. It is termed “Stored Credit” because such prepayments represent the client’s or member’s intended future use of it to acquire – in one go or progressively – the service. However, until the client or member actually uses this “Stored Credit” for the service, it remains the legal property of the client or member, who retains ownership of it.
3. As such, and as with all items that remain the legal property of an owner, the owner may request the return of such property on demand. This is especially the case with Stored Credit of a financial nature (i.e. money).
4. In such cases, not only is it the right of the owner of the property to be able to request a return of his/her legal property, it is a legal obligation for the company or organization that is holding that property to return it. Again, this is especially the case where the property is of a financial nature (i.e. money, in the form of “Stored Credit”).
5. Although many companies and organizations try to make it difficult for clients or members to obtain their Stored Credit in refunds, or try to drag the process out for as long as possible, Webtel.mobi and the TEL.mobi Group have always had a policy of complying with such requests as rapidly as possible.
6. This is because it is assumed that if a person requires such a refund, there will have arisen an event in the person’s life that is of an urgent nature, and it will therefore potentially seriously inconvenience the person to wait overly long for the refund.
7. It is also best practice to comply rapidly with a client or member request if one is running an efficient and professional business.
8. Whereas previously the procedure for Members to apply for a refund of Stored Credit with the TEL.mobi Group, and have the procedure to send the refund, both required manual processes, the TEL.mobi Group has now optimized the process to place the control of their own affairs once more in the hands of the Members themselves.
9. To do this, the TEL.mobi Group has developed a Member-controlled “Refund Transfer” process, which enables any TEL.mobi Group Member to implement a Refund Transfer of all or part of their Stored Credit in their own TEL.mobi Prepaid Telephone Accounts back to their own Bank Accounts. 57
10. For security and best practice reasons, such Refund Transfers can only be made to a Bank Account in the name of the TEL.mobi Group Member, and only once the TEL.mobi Group Member has uploaded his or her authenticated KYC documentation to the TEL.mobi Group.
11. There are some additional security and best practice requirements applied to this process (described later in this document) if all of the Stored Credit in the TEL.mobi Group Member’s Account did not originate from him/her (i.e. if it originated from another TEL.mobi Group Member in a Top-Up Transfer), but they are easily adhered-to verification processes.
12. As such, in this instance too, the TEL.mobi Group has once again placed control of a Member’s affairs in the Member’s own hands, and enables Members to have full access to that which is, in any event, legally theirs, and which they have a legal right to do with as they see fit without delay, let or hindrance.
13. This Service and Facility is provided free to TEL.mobi Group Members, in that there is no cost or penalty levied for refunding their Stored Credit. The only occasional charge is that the transferring Bank may levy a transfer fee (a standard Bank Charge) when transferring the Stored Credit to the Member’s Bank Account.
14. This is a unique and world-first Facility in the Global Telephony Sector.
G. TEL.mobi Group Multi-Number Account Facility:
TEL.mobi Group Online Telephone Accounts enable Members to save and store multiple Telephone Numbers (i.e. Mobile 1, Mobile 2, Home, Office, etc) from which they can call from using their TEL.mobi Accounts, with one-click selection. This can also include numbers in and from multiple countries. This Service and Facility is provided free to TEL.mobi Group Members, and is a world first and unique Facility in the Global Telephony Sector.
H. TEL.mobi Group Itemized Per-Second Billing Records in Real Time:
Although the TEL.mobi Primary Telephony Service is a “Pay as you go” / “Prepaid” service, it nevertheless functions on per-second billing (not per minute or part thereof), and it also provides Members with Real Time Itemized Billing immediately after calls made or texts sent, which is immediately available in the Member’s History Facility. This is a very rare Facility in the Global Prepaid Telephony Sector, and it is provided free to TEL.mobi Group Members. 58
I. TEL.mobi Group Transactions History Facility:
The TEL.mobi Group also provides Members with a detailed “History” Facility, which provides Itemized Records in Real Time of all activities that they carry out on the TEL.mobi Group Product Suite. Many of these Itemized History Facilities are able to be clicked on to provide Transaction- Specific details, which are of a nature that they can be downloaded as they are for direct insertion into reconciliation or other accounting records or documents. These Itemized and or Detailed Itemized Records are available for all TEL.mobi Group:
1. Calls
2. Texts
3. Outgoing Top-Up Transfers
4. Incoming Top-Up Transfers
5. Currency Conversions
6. Stored Credit Loading via the Payment Gateway
7. Stored Credit Loading via Electronic Top-Up Vouchers
8. Refund Transfers
This Service and Facility is provided free to TEL.mobi Group Members, and is a world-first and unique Facility in the Global Telephony Sector.
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J. TEL.mobi Group Account Blocking and Unblocking Facility:
1. All parts of the TEL.mobi Product Suite are constructed with Members’ security in mind.
2. On all processes, Five-Factor Authentication or Six-Factor Authentication processes are in place to ensure maximum account, process and transaction security and integrity.
3. Although these processes have been constructed to function in an easy and streamlined manner for Members’ usage, they are nevertheless difficult to defeat.
4. They include simultaneous comparisons of Members’ Usernames, Passwords, ITAN Numbers, Mobile telephone Numbers – as well as the receipt of texted TAN Numbers and possession of the Member’s own Mobile Phone. These are simultaneous combinations of Authentication requirements that are very difficult to defeat.
5. Nevertheless, the TEL.mobi Group has gone the extra mile in elevating maximum security for Members to an even higher level for the case of Extraordinary Circumstances. Extraordinary Circumstances can include situations where disagreements occur between Members and people to whom they have provided all relevant details for their Accounts (which is not recommended), or any other extraordinary situation.
6. For the case of any such potential Extraordinary Circumstances, the TEL.mobi Group provides Members with an Account Blocking Facility for their TEL.mobi Accounts.
7. To be specific, this facility is a Member-controlled Account Blocking and Unblocking Facility.
8. Using this Facility, it is a simple two-click process for a Member to immediately block and freeze his or her TEL.mobi Account, immediately, at any time of the day or night, from any internet-enabled PED or mobile Phone.
9. This provides Members with the Peace of Mind to know that in the case of any Extraordinary Circumstances, their TEL.mobi Account will nevertheless be secured.
10. Similarly, if a Member then wishes to Unblock his or her Account, they can also do themselves at any time of the day or night, in a rapid process, which requires the Member to have his or her own Mobile Phone and other TEL.mobi details to hand.
11. Through this process, the Member’s control of this aspect of his or her Account is again placed into his or her own hands, instead of leaving the Member at the mercy of a long waiting line in a call center’s queue, or facing a situation where nothing can be done if such centers are closed.
12. This Service and Facility is provided free to TEL.mobi Group Members.
13. This Member-controlled Account Blocking and Unblocking Facility is a world-first and unique facility in the Global Telephony Sector. 60
K. TEL.mobi Group “Know Your Client” (“KYC”) Upload Facility:
1. In order to carry out Refund Transfers, to apply to be an Independent Agent or to apply for a VSMP, KYC Documents are required to be uploaded by TEL.mobi Members.
2. The KYC Upload facility is – like every TEL.mobi Group Facility and process – custom-built.
3. It enables Members to easily upload the required KYC Documents, as well as TEL.mobi-Specific KYC Authentications (as described in the “My KYC” Facility).
4. It similarly caters for the great many people worldwide – especially “Unbanked” persons, who do not have recognized KYC Documentation.
5. This is catered for by the provision of a very specific “Substitute KYC” document with Authentication – required to be completed and authenticated by a verified Attorney or Notary – which fulfills all of the international Legal and Regulatory requirements of Standard KYC documents.
6. Through this, the TEL.mobi Group is able to adhere to its “equality of access-opportunity” ethos, by ensuring that the generally-excluded 2.2 Billion “Unbanked” people internationally are also able to achieve equality-of-access opportunity insofar as access to use 21st Century online facilities is concerned.
7. This Service and Facility is provided Free to TEL.mobi Group Members.
8. The Member-controlled uploading of KYC with Authentication and the “Substitute KYC” with Authentication represent word-first and unique Facilities in the Global Telephony Sector.
L. TEL.mobi Group Secure Contacts Storage Facility:
TEL.mobi Online Telephone Accounts have a Contacts Facility that enables Members to Store all of their Contacts’ Names and Numbers online, for accessing and use at any time from any telephone device or number. They are also a backup for Members whose Phones are lost, as these Contact Numbers remain in the TEL.mobi Account and not on a Member’s telephone.
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FLOW, USE AND SWAP
OF STORED CREDIT
IN THE TEL.MOBI GROUP’S
“MEMBERS-ONLY”
AND
“CLOSED-LOOP”
SYSTEM
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FLOW, USE AND SWAP OF STORED CREDIT IN THE “MEMBERS-ONLY” AND “CLOSED LOOP” STRUCTURE
A. Overview:
1. All TEL.mobi Group Members are part of a “Members-Only” and “Closed Loop” Structure. Only Members can access and use the TEL.mobi Group Product Suite, and its Services and Facilities.
2. Consequently, other than its Primary Services (Calls and Texts) which can be used to call to or send texts to non-Members, all other TEL.mobi Group Secondary and Support services are restricted to inter-Members use only, and cannot be used outside of the TEL.mobi Group Members environment (the “Closed Loop”).
3. Some information on Closed Loops / Closed Systems containing Stored Credit / Stored Value are the following:
An E-Commerce article on Closed Loops/Closed Systems and Stored Value/Stored Credit (click here)
A Wikipedia article on Stored Value/Stored Credit (click here)
A US Treasury definition of Stored Credit/Stored Value (click here)
4. For an example of Closed Loop/Closed System using Stored Credit/Stored Value that is similar in some ways to the TEL.mobi Group System – only much smaller in scale, scope and footprint, and much more limited in terms of Services and Facilities – the example of “Eaglecash” can be reviewed (click here)
5. These are very important aspects, for TEL.mobi Group Members, of which the five primary aspects for consideration are the following:
The Product Suite, Services and Facilities function in, and are available in and to, only Members.
The Members – and the Product Suite, Services and Facilities – therefore function within a “Closed Loop” – also sometimes referred to as a “Closed System”. This means that it is not freely available, as non-Members cannot use any of these Services or Facilities, and – with the exception of Primary Service Calls and texts – non-Members cannot even derive any benefit from the Product Suite, Services and Facilities.
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The Credit loaded on TEL.mobi Member Account by Members represents “Stored Credit” – also sometimes referred to as “Stored Value”. Stored Credit always remains the property of the person who placed it into the TEL.mobi Prepaid Telephony Account, because it is theirs, which they have placed into their Prepaid Telephony Account only so as to be able to use it at a future date.
Webtel.mobi – which is also a Member of the “Closed Loop”, centrally monitors and controls all of the activities that take place within the Closed Loop / Closed System.
Because of the fact that TEL.mobi Group Members and VSMPs all join through a TEL.mobi Group online presence, all of the activities that are carried out on or from the TEL.mobi Group’s Product Suite are deemed to be present in – and carried out on or from – the location where the Webtel.mobi service is run from, which is Guernsey (see the “International Regulatory Confirmation” Document in the “Testimonials” Link on all TEL.mobi Group Sites).
6. The preceding facts and considerations provide a wide range of options to all Members of the TEL.mobi Members-only and Closed-Loop System, which will be illustrated in the next section of this document.
7. In this section, a description of, and an introduction to the options that they provide for TEL.mobi Group Members, is provided in respect of the following:
The Flow of Members’ Stored Credit into the Closed-Loop, Members-only TEL.mobi System
The Use of Members’ Stored Credit on the Closed-Loop, Members-only TEL.mobi System
The Swap of Members’ Stored Credit within the Closed-Loop, Members-only TEL.mobi System
The Flow of Members’ Stored Credit out of the Closed-Loop, Members-only TEL.mobi System
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B. TEL.mobi Group Stored Credit Inward Flow 1 of 2: Loading of Account by a TEL.mobi Group Member
1. Member instructs his/her bank to load Stored Credit onto his/her Tel.mobi Account (via a Payment Gateway or a Transfer) 2. Member’s Bank transfers funds to Bank holding TEL.mobi’s Members’ Stored Credit (via a Payment Gateway or a Transfer) 3. Webtel.mobi Credits Member’s TMG Balance Record with Stored Credit amount transferred into the Bank.
1. The above diagram illustrates the only possible way for Stored Credit to be loaded onto a TEL.mobi Group Member’s Account via electronic means (i.e. via a Payment gateway or Bank Transfer).
2. Webtel.mobi does not accept any inward flows of stored credit by cash – only from banks and/or other registered and regulated financial institutions. This is to keep even the entry- level standard for the loading of Stored Credit restricted to systems that already have Anti- Money-Laundering and other financial due diligence safeguards within them.
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3. Such Account loads of Stored Credit are standard eCommerce activities for online services (such as online services for acquiring airline tickets, for booking of hotels via sites like Hotels.com and similar sites, and/or for obtaining services from any variety of companies, in any sectors, worldwide. These loads of Stored Credit for discounted online Prepaid Telephony Services Accounts fall into that sector, and are not in the sector dealing with outward transfers of funds.
4. The TEL.mobi Group’s product is a service, not a product. No App is required to be downloaded to or in any country to utilize the service, or in return for the placing of Stored Credit into a TEL.mobi Group Prepaid Telephony Account, so there are no goods provided or exported to any Member.
5. All services provided by the TEL.mobi Group to its Members are deemed to take place in and from Guernsey, and so there is only one set of guidelines and regulations that are apply, which are those relevant to the location at where the services are accessed and used from / in.
6. There is no limit on the amount of Stored Credit that a Member can load onto his/her TEL.mobi Prepaid Telephony Account, because:
The Stored Credit remains the property of the Member, and
It is permanently held within a Closed Loop Members-Only environment, and cannot, in fact, be used for anything other than that which is available in that environment, and
It cannot be accessed or utilized for any other purpose or person other than a Member of the Closed-Loop, Centrally-Monitored and Centrally-Controlled TEL.mobi Group System, and
For various other reasons related to Global eCommerce Laws and WTO Laws and Regulations.
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C. TEL.mobi Group Stored Credit Inward Flow 2 of 2: Acquiring of Electronic Top-Up Vouchers by TEL.mobi Group IAs / VSMPs
1. IA or VSMP instructs his/her bank to load Stored Credit onto his/her Tel.mobi Account (Payment Gateway or Transfer) 2. IA’s or VSMP’s Bank transfer funds to Bank holding TEL.mobi’s IAs’ or VSMPs’ Stored Credit (Payment Gateway or Transfer) 3. Webtel.mobi places e-Top-Up Vouchers equal to transferred Stored Credit amount into TMG Balance Record of IAs or VSMPs
1. The above diagram illustrates the only possible way for IAs or VSMPs to obtain Electronic Top- Up Vouchers for resale to their Members (such as Unbanked Persons who need assistance to gain access to and/or use 21st Century Online Facilities). This is the only way that Members – via IAs or VSMPs – can obtain Stored Credit Electronic Top-Up Vouchers to be loaded onto a TEL.mobi Group Member’s Account (that being via electronic means such as a Payment Gateway or Bank Transfer).
2. This is because Webtel.mobi does not accept any inward flows of cash by Members in order to assign their Stored Credit to their TEL.mobi Prepaid Telephony Accounts. It will only accept inward transfers from banks and/or other registered and regulated financial institutions. This is to keep even the entry-level standard for the loading of Stored Credit restricted to systems that already have Anti-Money-Laundering and other financial due diligence safeguards within them. 67
3. Such acquisitions of Electronic Top-Up Vouchers for resale are standard eCommerce-related activities, for the acquisition by a person or company of a manner to assist people to access eCommerce-related and/or other service (such as selling international SIM cards, International Travel Insurance Vouchers, International Loyalty Card Services, International Affinity Program Services, etc). These Electronic Top-Up Vouchers for Stored Credit for discounted online Prepaid Telephony Services fall into that sector.
4. The TEL.mobi Group’s Top-Up Voucher is an electronic Stored Credit Facility, not a product. No App is required to be downloaded to or in any country to acquire or resell the Electronic Top- Up Vouchers, and no Terminal or other equipment is required to be purchased to acquire, produce or resell the Top-Up Voucher. Even the acquisition of the Top-Up Voucher is done exclusively over the TEL.mobi Group’s Administration Console. As such, there are no goods provided or exported to any Member who acquires or resells a TEL.mobi Group Top-Up voucher.
5. All services provided by the TEL.mobi Group to its Members are deemed to take place in and from Guernsey, and so there is only one set of guidelines and regulations that are apply, which are those relevant to the location at where the services are accessed and used from / in.
6. There is no limit on the amount of Stored Credit that a Member can load onto his/her TEL.mobi Prepaid Telephony Account, because:
The Stored Credit remains the property of the Member, and
It is permanently held within a Closed Loop Members-Only environment, and cannot, in fact, be used for anything other than that which is available in that environment, and
It cannot be accessed or utilized for any other purpose or person other than a Member of the Closed-Loop, Centrally-Monitored and Centrally-Controlled TEL.mobi Group System, and
For various other reasons related to Global eCommerce Laws and WTO Laws and Regulations.
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D. TEL.mobi Group Stored Credit Use 1 of 1: Members Mobile and Landline Calling / Mobile Text Sending
1. Member A uses $10 of Stored Credit in a month on Calls/Texts. Member B uses $20 of Stored Credit in a month on Calls/Texts. 2. Stored Credit amount used is deducted in real time from each Member’s Stored Credit in the Account as and when it is used. 3. As Stored Credit is used and deducted, the amount used and deducted is reflected in real time in each Member’s TMG Balance Record.
1. The above diagram illustrates the only possible way for TEL.mobi Group Members to use their Stored Credit on the TEL.mobi Group platform. That is the use of their Stored Credit to utilize the Primary Services provided by Webtel.mobi and the TEL.mobi Group – these being:
Local, and/or Long Distance, and/or International, and/or Roaming Call and Texts.
For and from Smart Phones, Feature Phones, Basic Mobiles, Landlines and PEDS.
At up to 80% lower cost than the standard costs of other providers.
With the same costs worldwide, regardless of the country one is in, or the time of day.
To TEL.mobi Group Members and/or non-Members.
And various other advantages, as listed previously in this Document.
2. As the Calls are made or the Texts sent, the cost for the Call or Text is deducted from the Members’ Stored Credit TEL.mobi Accounts in real time (with full and detailed usage and cost records also generated for Members in real time).
3. The Balance Records in Members’ TEL.mobi Online Accounts are updated as costs are deducted. 69
E. TEL.mobi Group Stored Credit Swaps 1 of 2: “Mobile Operator Stored Credit Swaps” / “MOSCS” between Members
th 1. Member A does a Top-Up Transfer of $10 to Member B via the TEL.mobi Group System – takes 1/100 of a second. 2. $10 of Member A’s Stored Credit in the Bank Account is swapped to Member B’s Stored Credit in the Bank Account. 3. $10 of Stored Credit swapped from Member A’s TMG Balance Record to $10 in Stored Credit in Member B’s TMG Balance Record.
1. Overview
The above diagram illustrates the only possible way for Stored Credit Swaps to occur between Members in the TEL.mobi Group’s Closed Loop System. That is, the Stored Credit belonging to Members does not, in fact, move at all. It remains static in the same Bank Account. Only the record of the amount of Stored Credit held by each of the Members – representing how much of the Stored Credit is in the Account he/she owns – is altered.
As such, no “Transfer” of any description occurs, because the Stored Credit remains static in exactly the same place in exactly the same Bank Account. All that occurs is that the electronic ledger-entries showing the amounts of Stored Credit owned by the Members alter.
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This is why it is possible to “Top-Up” another Member’s Account within 1/100th of a second 24/7/365 – whether the other Member is sitting next to you, or is on the other side of the world.
This process is, in fact, called a “Mobile Operator Stored Credit Swap” or “MOSCS”. It is only called a “Top-Up Transfer” in the TEL.mobi Group Members-Only Closed-Loop System in order to describe the Facility in a way that most people – including people whose First Language is not English – will understand more easily than the formal term of “Mobile Operator Stored Credit Swap”.
2. Differences between a Standard Top-Up Transfer and a “MOSCS” - Part 1
This Part 1 deals with standard Top-Up Transfers to the Prepaid Telephone Accounts of clients of standard Mobile Operators.
With the standard “Top-Up Transfers” done by/for/to other Mobile Operators internationally – which are real Top-Up Transfers in the sense of the word “Transfer” – the process is as follows:
An external Third Party person, who is not necessarily even a client of the mobile operator, elects to top-up the Pre-Paid telephone Account of a client of the Mobile Operator.
This external Third Party takes cash/money – which is not Stored Credit – and does the first actual money transfer to the external Bank Account of – or gives it in cash to – one of hundreds of external companies that do such Top-Ups for external Third Parties (this transferor company is the external Fourth Party).
This external Fourth Party transferor then takes his/her/its commission for providing this service, and takes the external Third Party’s cash/money. In some instances, the external Fourth Party is in a different country to the Third Party depositor, and deposits need to be converted to the currency of the place where the external Fourth Party is located. Therefore, besides the commission taken by the external Fourth Party, a “double-billing” occurs here too, with a currency conversion having to be done, often at a very unfavorable rate.
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The external Fourth Party then does a second actual money transfer – of funds, not Stored Credit – from its external Bank Account or a money-transfer company’s account. This second actual money transfer is done either to the Mobile Operator’s Bank Account or to an external Fifth Party’s Bank Account (if the Fifth Party is going to do the Voucher Purchase for the Fourth Party in a different country – which is often the case). Moreover, in such cases, a second currency conversion needs to be done to convert the funds from the external Fourth Party’s currency of use to the currency of use in the ultimate destination country. As such, a “triple-billing” situation occurs.
The Fifth Party then either buys a local Top-Up Voucher, or does an electronic Voucher purchase and load into the Prepaid Telephone Account of the recipient.
In summary, what has occurred in such a standard Top-Up Transfer situation is that:
Up to three external parties – with which the Mobile Operator on whose system the Prepaid Account is held has no relationship at all – have been involved with the transaction. Moreover, the Pre-Paid Mobile Account holder will also have no relationship at all with at least one – possibly two – of the people/entities involved in this transaction.
Up to four external bank accounts – external to that of the Mobile Operator – will have had funds passing through them, which are unrecorded and unverifiable in origin. Cash-exchanges may also have formed part of these transactions.
There will be no records at the Mobile Operator of any of the above parties, or their bank accounts, or the flow of funds – all of which comprise actual money transfers between different banks and different unknown (to the Mobile Operator and/or the prepaid Account Holder) parties.
Multiple charges may have been levied in commissions, bank transfer fees and potentially up to two currency conversions.
It is for the above reasons – which are clearly unsafe in respect of many considerations relating to Anti Money Laundering and related considerations – that standard Top-Up Transfers on/for/to Prepaid Accounts on standard Mobile Operators Systems are sometimes restricted in some countries as to the amounts and/or frequency that they can be applied.
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3. Differences between standard Top-Up Transfer and a “MOSCS” - Part 2
This Part 2 deals with TEL.mobi Group “Mobile Operator Stored Credit Swaps / MOSCSs”, which are only described as “Top-Up Transfers” in order to make the process and name easily understandable for Members.
With the TEL.mobi Group’s MOSCS, or “Top-Up Transfer”, no “Transfer” of any sort occurs, and no funds move physically or at all.
This process is as follows:
Only Registered Members within the Closed-Loop and Members-Only TEL.mobi Group Community can ever carry out a TEL.mobi Group MOSCS / Top-Up Transfer.
TEL.mobi Group MOSCSs / Top-Up Transfers can only be made to other Registered Members of the TEL.mobi Group.
All TEL.mobi Group details are recorded in the TEL.mobi Group System. The fact that Members already had to have had a Registered Mobile Number to join means that a form of due diligence on them already exists. This is because they will have had to show KYC documents to get their SIM Cards – or that there will be another way to identify them through the use of that Mobile Number (various safeguards exist in the system to prevent use of other people’s Mobile Numbers). As such, the Member’s details are known and recorded.
Members have already loaded their Stored Credit into the Bank Account that holds all TEL.mobi Group Members’ Stored Credit. This Stored Credit can only enter the Closed Loop System by Bank Transfer (directly or via a Payment Gateway), with all inward flows being recorded. As such it is known with clarity who transferred the Stored Credit in, and that it comes from a Bank, which would have (should have) already done KYC and due diligence on the account holder. As such, all parties and all details are known and recorded.
All Members’ Stored Credit in the TEL.mobi Group System therefore resides in the same (Multicurrency) Bank Account, and it is only electronically segmented between owners as a ledger-entry, in that the amount of the total of the Stored Credit in the Account that is owned by each Member is recorded in their Account balance on their personal TEL.mobi Group Accounts.
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If TEL.mobi Group Member A wants to do a MOSCS / Top-Up Transfer to TEL.mobi Group Member B, he/she carries out a MOSCS via the TEL.mobi Group System. The process to carry out the MOSCS / Top-Up Transfer on the system is very thorough, but once it is executed, the only thing that happens is that the electronic ledger-entry on each Member involved in the MOSCS is altered – debiting the total of the transferor, and crediting the ledger-entry balance of the recipient.
No Stored Credit – which is all in the same account – moves at all.
Other than that, all Stored Credit that is in the TEL.mobi Group Closed Loop System can only be used for the Primary Services in the TEL.mobi Group Product Suite, or refunded to its owner (and only to its owner – not to any other party – and specifically only to its owner’s Bank Account).
In summary, what has occurred in a TEL.mobi Group MOSCS / Top-Up Transfer is that:
Two Members who are known to the TEL.mobi Group,
Whose details are recorded by the TEL.mobi Group,
Whose functioning Mobile Numbers are recorded by the TEL.mobi Group,
Whose Stored Credit has been placed into the TEL.mobi Group’s Bank Account (which is in a secure and well-regulated jurisdiction),
Through an interbank transfer from/by another Bank (details of which are recorded by the TEL.mobi Group),
Decide to swap some of their Stored Credit that is held in the same Bank Account,
And do so over the TEL.mobi Group system so that this Stored Credit Swap is fully recorded in terms of the identities of the two Members, and the amount of Stored Credit Swapped, and the date and the time of the Swap,
With the record of the Stored Credit Swap being stored in a distributed ledger manner through recording on the TEL.mobi Group System, and the “History” within the two Members’ accounts, and by instant email to the two Members, and by Text message to the two Members,
With the Stored Credit Swap and all distribution of all confirmations and ledger-entry balance alterations occurring in real time,
With both of the Members – and Webtel.mobi – being able to see, verify and confirm the details of the Stored Credit Swap independently and instantly; in a combination of Centralized and Distributed verification 74
As such:
No actual Transfer of funds from one place to another takes place at all.
Members of a Closed Loop Members Organization simply agree to Swap some of their secure Stored Credit. This Swap Results in an electronic alteration of the Ledger-Entry Balance in each of their personal TEL.mobi Group accounts, to show the new totals of their ownership of the total of the Stored Credit in the Bank Account where Members’ Stored Credit is held.
Moreover,
There is only an extremely small fee applied for the Members to be able to carry out the MOSCS / Top-Up Transfer. There can be no “double-billing” or “triple-billing” due to hidden currency conversion fees and costs, because the Members are able to do their own Currency Conversions between Currency Wallets in their own Accounts at good rates, to transfer to other Members’ different Currency Wallets in the same currency.
There is Five-Factor Multi factor Authentication in the MOSCS / Top-Up Transfer to ensure Members’ security of Stored Credit.
There is a combination of centralized and distributed confirmation of all aspects of the transaction – at Webtel.mobi and at the Sending Member and at the Receiving Member– instantaneously, by record on the Account and email and text, for full Stored Credit Swap security of and for all parties.
With the entire Stored Credit Swap, and the notifications and records, occurring instantly 24/7/365, whether the Transferring Member and Receiving Member are next to each other or on other sides of the world.
It is for these reasons that there is no limit on the amount of Stored Credit that can be swapped between Members on the TEL.mobi Group System. This is because it is not a transfer or payment or any other such transaction, and there is only one Bank Account involved in which all the Stored Credit already resides, and it does not move. It is only an electronic ledger-entry balance between two Members of a Closed-Loop System that alters.
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F. TEL.mobi Group Stored Credit Swaps 2 of 2: Currency Conversions between Member’s Currency Wallets
1. Member A does a Currency Conversion of $10 from $ Currency Wallet to £ Currency Wallet, and receives £8 in the Conversion. 2. $10 in Member A’s Stored Credit in the Bank Account is swapped to £8 in his/her Stored Credit in the Bank Account. 3. $10 of Member A’s Stored Credit in his/her TMG $ Balance Record is swapped to £8 Stored Credit in his/her TMG £ Balance Record.
1. The above diagram illustrates the only other possible way for Stored Credit Swaps to occur on the TEL.mobi Group’s platform, which is for TEL.mobi Group Members to do a Stored Credit Swap from one currency to another within his/her own TEL.mobi Account, through an in- house Currency Conversion.
2. This is for use in cases where:
A TEL.mobi Group Member may wish to make a Top-Up Transfer to another Member who has a different currency as his/her Primary Currency.
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A TEL.mobi Member who is travelling may acquire a TEL.mobi Electronic Top-Up Voucher in the currency of the country that he/she has travelled to, in order to avoid having to do a currency conversion, and/or may have done that previously and then wishes to change whatever remains when he/she returns home to the home currency.
3. In such situations, the TEL.mobi Group Member simply carries out a Swap of his/her Stored Credit from one currency to another; within his/her own TEL.mobi Account.
4. Although the TEL.mobi Group has partnered with a world-leading Currency Conversions specialist to carry out the actual currency conversions for TEL.mobi Group Members, this takes place on a segregated system in the Currency Conversions Partner’s System, reserved only for TEL.mobi Group Members’ Currency Conversions, to keep it within the totally Closed Loop TEL.mobi Group System.
5. As such, when a Currency Conversion is carried out by a TEL.mobi Group Member, all that occurs is that the Stored Credit that he/she has in his/her TEL.mobi Account Balance is altered within the Closed Loop System, to reflect the amount of Stored Credit in one currency that he/she has swapped for Stored Credit in another currency.
6. This is able to be done instantly, at extremely favorable rates (that are often unavailable to the public), in a secure system, with instant notification by insertion of all records of the Stored Credit Swap from one currency to another in the Member’s own Account History, and centrally recorded at Webtel.mobi.
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G. TEL.mobi Group Stored Credit Outward Flows 1 of 1: Members’ Stored Credit Refund Transfer System
1. Member A sends a Refund Transfer Request for $10 of his/her Stored Credit. 2. System checks Stored Credit Balance and History; Webtel.mobi Verifies. If all OK, System sends request to Bank to Refund. 3. Bank where TMG Members’ Stored Credit is held does a Refund Transfer of $10 Stored Credit to Bank Account of Member. 4. $10 of Stored Credit is removed from Member’s TMG Balance Record.
1. The above diagram illustrates the only possible way for Stored Credit can leave the TEL.mobi Group’s Closed Loop System other than being utilized to access and use the Primary Services – being Mobile and Landline Telephony and texts.
2. Because Stored Credit always remains the property of its owner (the Member), the Member can request a Refund of the Stored Credit at any time, and Webtel.mobi / the TEL.mobi Group is legally obliged to comply. This applies in all situations where Prepaid Credit has been provided to a Service Provider as Stored Credit. In many cases, Service Providers do not respond rapidly, but Webtel.mobi has always done so, and has upgraded its system to place the control of Members’ own Stored Credit back in their hands.
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3. As such, TEL.mobi Group Members can initiate a Refund Transfer themselves, from within their own Accounts, to have their Stored Credit in their Accounts returned to them. However, with this aspect, there are various considerations and processes that are applied.
4. Stored Credit in a TEL.mobi Group Member’s Account always remains the property of the TEL.mobi Member. However, because Stored Credit that did not originate from the Member’s own Bank Account may have entered into his/her TEL.mobi Account as a result of a Stored Credit Swap, Webtel.mobi has implemented various checks and balances to ensure that a clear situation is maintained in respect of such matters.
5. Consequently, even though Webtel.mobi is a telephony company, and not a Financial Services Company, and even though the Stored Credit Swaps do not represent Financial Services transactions, Webtel.mobi has proactively applied the same regimes in respect of Refund Transfers as are applied in the Financial Services sector – and more. An overview thereof is as follows in the points below:
6. Any TEL.mobi Group Member who wishes to carry out a Refund Transfer must have his/her details registered on the TEL.mobi System. These must include a Registered Mobile Number – which is already a form of “Know Your Client” / “KYC” confirmation. Moreover and added to this, he/she must also have first uploaded full KYC documents to his/her Account prior to being able to request a Refund Transfer. To assist Unbanked People – who often do not have any recognizable KYC documentation or the ability to obtain them – a legally compliant “Substitute KYC” Document completed by a Registered Notary or Attorney (and with Photo Identification) must be uploaded to the Member’s account.
7. Refund Transfers may only be made to a Bank Account that is held by the Member and that has the Member’s name as the account holder.
8. The Member may only do a unrestricted Refund Transfer of an amount of Stored Credit less than or up to the amount of Stored Credit that he/she had loaded into his/her TEL.mobi Account directly himself/herself – whether it is in the same currency as uploaded or a different currency that he/she may have swapped it into.
9. If an amount of Stored Credit in excess of the amount of Stored Credit that was personally loaded into the TEL.mobi Group’s Closed Loop system by the client himself/herself is requested to be refunded (i.e. Stored Credit that was received in a MOSCS), then the following restrictions and requirements apply:
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Only a maximum of Euro 9 999.00 (Nine Thousand Nine Hundred and Ninety Nine Euros) of Stored Credit – or the equivalent amount of Stored Credit in another currency – may be refunded, per month, in an unrestricted Refund Transfer.
If amounts of Stored Credit above Euro 9 999.00 per month are requested to be refunded in a single Refund Transfer – or amounts of Stored Credit over Euro 9 999.00 are requested to be refunded more than once per month – the Member has to upload all relevant documents regarding the source and use of that Stored Credit. These documents must satisfactorily show the legal and verifiable origination and purpose for the Stored Credit Swap that resulted in that increase in a Member’s Stored Credit from another source prior to the Refund Transfer being approved.
When a Refund Transfer is initiated, the TEL.mobi Group System records, batches and prepares the Refund Transfer details completely and instantly. However, the instruction to transfer is not provided to the Bank in which the Stored Credit is held until the request has been reviewed and verified as complying with the relevant requirements as listed here, and as clearly shown on the Refund Transfer Facility, and the “How it Works” page on the Refund Transfer Facility. If all requirements have been adhered to, the Refund Transfer is put through and the Stored Credit is immediately Refunded. If requirements have not been adhered to, or if there are inconsistencies or a lack of satisfactory documentation, Refund Transfers are not put through until the situation has been satisfactorily resolved.
In general, these requirements are easily complied with for all persons and entities that conduct open and legal activities, and Stored Credit can therefore be rapidly refunded to the Members on request.
For specific and detailed information on the Refund Transfer process, please see the section of this Document entitled “THE TEL.MOBI GROUP’S STREAMLINED AND SECURE REFUND TRANSFER RULES AND LIMITS”
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STANDARD
DIRECT CARRIER BILLING SERVICES
AND
DIRECT- TO-MOBILE-BILL SERVICES
OVERVIEW
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STANDARD DIRECT CARRIER BILLING SERVICES AND DIRECT-TO-MOBILE-BILL SERVICES – OVERVIEW
The entire TEL.mobi Group System is a Closed-Loop and Members-Only System and services, with multiple safeguards within it. Moreover, it is an advanced System, with an advanced and full Product Suite of Services and Facilities.
As a Telephony Company, Webtel.mobi – and through it, the TEL.mobi Group – are able to provide all Standard Telephony Services. One of these is the Premium Rate Text Messages service, which has been used for decades as a means to facilitate payments and billing internationally, for non- Telephony goods and/or services.
The Primary Difference between Premium Rate Text messages as a means of Payment and/or Billing by Standard Telephony Providers and Webtel.mobi / the TEL.mobi Group, is that Standard Telephony Providers charge up to 60% of the cost of the Premium Rate Text to provide the service, whereas Webtel.mobi / the TEL.mobi Group charges less than 1%.
Moreover, Webtel.mobi / the TEL.mobi Group is able to provide the service in, to and from all countries worldwide at the same cost (not just in, to or from one country – as is the case with Standard Telephony Providers).
There are, however, two other Telephony-based Payment and Billing Facilities that Webtel.mobi has not incorporated into its system – although it would be simple and extremely rapid to do so, and to achieve global coverage with them. These two excluded facilities are:
1. A Direct Carrier Billing Facility
Direct Carrier Billing services are services that enable people to make purchases / pay bills – usually online and usually through a mobile phone interface with often various intermediary entities facilitating the flow of the transaction and/or payment. This service is primarily used for people to purchase online / digital / similar goods or services.
2. A Direct-to-Mobile-Bill Payments and Billing Facility
Direct-to-Mobile-Bill Payments and Billing services are services that enable people to charge purchases directly to their own mobile telephone bills – whether through their Prepaid Stored Credit already in their Mobile Telephone Accounts or through their Postpaid Monthly Bills to their Mobile Phone Accounts. This service is primarily used for people to purchase retail and/or hard goods, although it can be used for the purchase / payment for any transaction. 82
Almost all Mobile Telephone Companies – and even some Landline Telephone Companies – provide these Direct Carrier Billing and Direct-to-Mobile-Bill services. This is because, for many years already, peoples’ Stored Credit in their Prepaid Telephone accounts – or Mobile Telephone Bill billing – has been able to be used by mobile phone users to buy or pay for non-Telephony goods and/or services, worldwide.
Source: https://www.amdocs.com/
These services have become such standard and widespread services for Telephone Companies to provide that there are already large Aggregator Companies internationally, that sign up multiple Telephone Companies to establish international coverage for Direct Carrier Billing and/or Direct- to-Mobile Payments.
Two such Aggregator Companies are Fortumo, and Boku, which have signed up hundreds of Telephone Companies / Carriers to their Aggregator Platforms, in order to provide Direct Carrier Billing Services / Direct-to-Mobile-Bill Payment and Billing services in and to multiple countries. (although both of them, combined, do not even come close to the TEL.mobi Group’s potential in terms of global reach, market reach, client reach, pricing or any other sector aspect).
Moreover, these Direct Carrier Billing and Direct-to-Mobile-Bill services have for many years been used for most types of transactions that exist. These include purchases of Digital and related Products and Services, as well as for eCommerce Payments and Transactions, Retail / Enterprise / B2B / Other Goods and Services Payments and Transactions, National and International Remittances, Point-of-Sale Transactions with Retailers and Wholesalers, Payments to all Vendor types for Services Provision, Payments over Payment Gateways, and multiple other uses.
These Direct Carrier Billing and Direct-to-Mobile-Bill services comprise pure Telephony Company / Mobile Telephony Company services. They are not related to services such as “Apply Pay” and other so-called “Mobile Wallets”, which represent only the simple placement of an existing Credit Card’s or Debit Card’s details onto a Smart Phone platform, and have nothing to do with Mobile or other telephony (i.e. they are just existing Credit / Debit Cards placed onto a Smart Phone).
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Fortumo
Source: https://fortumo.com/
Boku
Source: https://www.boku.com/ 84
Source: www.fintechnews.ch
Source: https://www.mobilepaymentstoday.com/
Source: https://www.boku.com/
Source: https://bitcoinist.com/
Direct Carrier Billing and Direct-to-Mobile-Bill services are considered to be the next big driver of global innovation. This is why many of the most advanced Tech and FinTech companies are starting to integrate these services into their platforms.
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THE TEL.MOBI GROUP’S VIEW
OF STANDARD
DIRECT CARRIER BILLING SERVICES
AND
DIRECT-TO-MOBILE-BILL SERVICES
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THE TEL.MOBI GROUP’S VIEW OF STANDARD DIRECT CARRIER BILLING & DIRECT-TO-MOBILE-BILL SERVICES
The TEL.mobi Group is, in fact, able to implement both Direct Carrier Billing and Direct-to-Mobile-Bill services immediately itself, and could do so very easily and very successfully. Moreover:
1. As this is a Standard Telephony service, the TEL.mobi Group is able to implement it immediately, and is fully equipped to offer both of these services to its Members with the flick of a switch.
2. The TEL.mobi Group has overwhelming Geographic Dominance – with coverage that is factors larger and wider than even the largest Aggregators with hundreds of Telephone Companies within them – within all countries worldwide, and between all countries worldwide, in one unified entity.
3. Whereas standard Direct Carrier Billing and/or Direct-to-Mobile-Bill services usually charge consumers a premium of up to 40% for the service, the TEL.mobi Group can provide an unmatchable, better and unified service in this sector at only a 1% (or lower) cost.
4. The TEL.mobi Group VSMPs represent a fully-integrated platform, that any Merchant (Eligible Entity) can have up and running within 8 to 24 hours of application – free of charge, and with a zero integration requirement in terms of time, cost, equipment or personnel.
5. Whereas it is claimed by large Aggregators that their services offer access to the Global Market of Mobile Phone users – a market of 6 Billion persons – this cannot possibly be the case. The reason for this is that only a company that has saturation coverage in every country worldwide can do this. The only company – in the world – that has this capacity in and to every country worldwide, and which has total Geographic Dominance globally in the Mobile Phone sector, is Webtel.mobi; and thereby, the TEL.mobi Group.
6. Furthermore, almost 60% of all mobile phones in use worldwide are pre-Smart Phones, and the systems offered by these other parties all reply on the users having Smart Phones. The only company in the world that provides a platform on which pre-Smart Phones as well as Smart Phones can interact – and can thereby in reality provide access to the entire 6+ Billion mobile Phone users worldwide – is Webtel.mobi; and thereby the TEL.mobi Group
Despite these absolutely overwhelming and crystal clear Market Advantages in the Direct Carrier Billing and/or Direct-to-Mobile-Bill sectors, Webtel.mobi – and thereby the TEL.mobi Group – has elected not to enter into this market sector with Standard Direct Carrier Billing services or Standard Direct-to-Mobile-Bill services.
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The reason for this is that Webtel.mobi / the TEL.mobi Group provides “Intra-Closed-Loop Members” Direct-to-Mobile-Bill services (“ICLM Services”) which achieve the same results; and they are also safer, quicker, much less costly and instantaneous.
These ICLM Services are furthermore REALLY available to all of the 6+ Billion Mobile Phone users worldwide, and they are able to be used by all TEL.mobi Group Members instantly and worldwide, in every and any possible environment and/or situation.
In short, they do not just better the Standard Direct Carrier Billing and/or Direct-to-Mobile-Bill Billing/Payment services in every respect – they render them redundant.
The differences between Standard Telephone Companies’ or Aggregators’ provision of Direct Carrier Billing and/or Direct-to-Mobile-Bill services on one hand; and the TEL.mobi Group’s ICLM Direct-to- Mobile-Bill Services on the other hand; are as described in the next two sections.
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OVERVIEW OF
THE TEL.MOBI GROUP’S
FIRST- MOVER “ICLM“
DIRECT-TO-MOBILE-BILL SERVICE
AND
“TITAN” SYSTEM
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OVERVIEW OF THE TEL.MOBI GROUP’S FIRST-MOVER “ICLM” DIRECT-TO-MOBILE-BILL SERVICE AND “TITAN” SYSTEM
A. ICLM Service Overview:
1. The Term “ICLM” stands for “Intra-Closed-Loop Member”. It means that all such Transactions can only be carried out within the sealed-off “Closed Loop” of the TEL.mobi System, and that they can only be carried out by verified Members of the TEL.mobi Group.
2. As such, it is a sealed service, available only to and from TEL.mobi Group Members who are within the “Closed Loop” System, and all such Transaction are inaccessible to all and any persons or parties that are external to the “Closed Loop” System.
3. The mechanism used in the TEL.mobi Group’s ICLM Direct-to-Mobile-Bill Service is the same one that is used in the TEL.mobi Group’s “Top-Up Transfer” service.
4. That is, it is a Mobile Operator Stored Credit Swap (“MOSCS”), where two or more Members within the Closed-Loop TEL.mobi Group system simply swap Stored Credit between one another.
5. As such, there is, in fact, no “Transfer” in the traditional sense of the word – because the Stored Credit that is swapped does not even move out of the Bank Account in which Members’ Stored Credit is kept, and no transfer between different Banks or different Bank Accounts occurs. The Stored Credit remains static, and just the electronic ledger-entry of the amount of Stored Credit owned by the parties in the MOSCS is instantly altered.
6. With an ICLM Direct-to-Mobile-Bill transaction, it is similarly not a “Payment” in the traditional sense of the word. This is because, again, although the electronic ledger balances of Stored Credit in the Accounts of the two or more Members are instantly altered to reflect a debit on one side and a credit on the other, no Stored Credit moves out of the Account where Members’ Stored Credit is held.
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7. As such, both the “Top-Up Transfer” and the “ICLM Direct-to-Mobile-Bill” Transactions in fact represent merely a Mobile Operator Stored Credit Swap (“MOSCS”) between Members of the Closed-Loop system, and the only differences are that:
“Top-Up Transfers” are used to top up other Members’ Accounts for making telephone calls.
“ICLM Direct-to-Mobile-Bill” Transactions are used as a substitute payment method for non-Telephony goods or services.
8. Moreover, due to the fact that:
Stored Credit loaded onto TEL.mobi Group accounts remains the property of the Account Holder until used, and
Falls completely within the international eCommerce Sector, and
Because the Stored Credit can never leave the Closed-Loop system unless Refunded, and
Because no third parties outside the Intra-Closed-Loop Member are involved, no third party-Bank Accounts are involved, and no transfer of money between Bank Accounts is involved – at all, and
All that therefore occurs in an ICLM Transaction is a that Stored Credit is swapped in an MOSCS between Members of, on and in a Closed-Loop system, which Stored Credit remains static before, during and after a swap, and
This ICLM Transaction done by means of a MOSCS represents only an electronic ledger- entry alteration of Stored Credit ownership in Members’ TEL.mobi Accounts and there is therefore no “Transfer” of anything, ever;
There are therefore no limits to the amount of Stored Credit that can be loaded by a Member or swapped between Members in an ICLM Transaction by means of a MOSCS – whether for a Top-Up Transfer or ICLM Direct-to-Mobile-Bill transaction.
9. The only limits applied are when Stored Credit leaves the Closed Loop system for a Refund Transfer, and these are the limits that are outlined in the Refund Transfer Rules.
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B. ICLM Transactions Overview:
1. All that is needed for any person or entity to immediately begin using the TEL.mobi Group’s ICLM Direct-to-Mobile-Bill Services (“ICLM Services”) is to join the TEL.mobi Group as a Member. Nothing more is required, because the system has been built to automatically take care of the myriad other integration requirements present in other similar services.
2. As such, all integration, notification, confirmation, records and other actions that usually take a great deal of time, and are costly and unwieldy, have been totally removed for TEL.mobi Group Members, because the ICLM System does all of this automatically and immediately.
3. Moreover, it does this all with an extremely high level of security, and completion of all transactions within 1/100th of a second.
4. Carrying out an ICLM Direct-to-Mobile-Bill Transaction uses the same facility as topping up another TEL.mobi Group Member’s Prepaid Telephone account – that is, the “Top-Up Transfer” facility. Both of those actions represent, in fact, simply an MOSCS Stored Credit Swap between Members within the TEL.mobi Group Closed Loop system.
5. All that any Member – whether a private entity or a large organization – needs to be able to receive an ICLM Service Transaction is to provide or advertise their/its ITAN number + Registered Mobile number.
6. All that any Member – whether a private entity or a large organization – needs to be able to send an ICLM Service transaction is to know the ITAN number + Registered Mobile number of the person/entity that the Member wants to do an ICLM service transaction to.
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C. The “TITAN” System Overview:
1. The TEL.mobi Group’s ICLM Transactions – and all other TEL.mobi Secondary Services related to ICLM Direct-to-Mobile-Bill Services – function on and through the Webtel.mobi and TEL.mobi Group’s “TITAN” System.
2. The name “TITAN” System stands for the TEL.mobi ITAN System (with “ITAN” standing for Inter-TEL.mobi Account Number). The Webtel.mobi System generates and allocates every Member a unique ITAN Number when they join the TEL.mobi Group.
3. The TITAN System is a proprietary Webtel.mobi and TEL.mobi Group system, which is similar to the SWIFT and SEPA systems.
4. The TEL.mobi Group generates, assigns and issues a unique and permanent ITAN Number for each Member automatically on joining the TEL.mobi Group.
5. The Member’s unique ITAN Number is linked to the Member’s unique Registered Mobile Number and the Member’s Name.
6. The combination of unique ITAN Number of each Member together with the unique Registered Mobile Number of each Member ensures that an ICLM transaction will go to the exact Member to which it is intended.
7. For added security, when a Member’s ITAN Number and Registered Mobile Number are entered, the person carrying out the transaction is prompted too click a “Verify” button, which instantly checks that the specific ITAN Number matches with the specific Registered Mobile Number.
8. If the unique ITAN Number is correct and if it matches exactly with the Registered Mobile Number to which it is connected (and it is only possible for one such combination to exist on the entire system) then the name of the person / entity is displayed and the Transaction can continue.
9. If there is any error in inserting (wrong ITAN/Mobile numbers or mismatched ITAN/Mobile numbers), the Transaction cannot proceed, and the Member is prompted to check and revise the ITAN and/or Mobile numbers.
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10. As such, Transactions can only ever go to the intended person/entity; and the possibility for Transactions going to the wrong Member due to the insertion of wrong ITAN Numbers, wrong Member names or the right names but wrong person (in the case of multiple Members having the same name) is completely removed.
11. The TEL.mobi system has been constructed to ensure that the correct ITAN Numbers and Registered Mobile Numbers are sent to any Member wanting to do an ICLM. From the “My ITAN” facility, a recipient’s Mobile Phone Number and/or Email address can be inserted, a “Send” button clicked on, and the correct ITAN Number and Registered Mobile Number will be automatically sent. This is to ensure that the correct number is easily sent, without the possibility of mistakes in writing the number down manually. It is recommended that this is sent by email, to enable a “copy & paste” of the number by the recipient.
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D. Setup and Advantages of the TITAN System for ICLM Transactions:
1. The full ability to make or receive ICLM Transactions is available to all TEL.mobi Group Members, instantly and Free, as soon as they join as Members of the TEL.mobi Group and verify their Mobile Phone Numbers.
2. All that is required for Members to be able to send and/or receive ICLM Transactions is to join as a Member of the TEL.mobi Group, and then display their ITAN Number and Registered Mobile Number or send them to other Members – nothing more.
3. All other Members can – once they have joined – instantly send or receive ICLM Transactions from any other Member of any TEL.mobi Group VSMP; instantly, 24/7/365.
4. This facility is immediately available to all Members once they have joined.
5. Members do not have to apply for their own VSMPs or apply to be to be Independent Agents to fully utilize the complete ICLM system, and accrue all the advantages of using it.
6. No equipment, devices or actions at all – other than Membership of the TEL.mobi Group and possession of a Mobile Phone – is required.
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COMPARISON –
STANDARD TELCOS’
DIRECT-TO-MOBILE-BILL SERVICES,
VERSUS
THE TEL.MOBI GROUP’S
FIRST-MOVER “ICLM”
DIRECT-TO-MOBILE-BILL SERVICES
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COMPARISON – STANDARD TELCOS’ DIRECT-TO-MOBILE-BILL SERVICES, VERSUS THE TEL.MOBI GROUP’S FIRST-MOVER “ICLM” DIRECT-TO-MOBILE-BILL SERVICES
The following is a comparison between relevant aspects of Standard Telephone Companies’ Direct Carrier Billing and/or Direct-to-Mobile-Bill services; and the Webtel.mobi / TEL.mobi Group’s “Intra- Closed-Loop Members” Direct-to-Mobile-Bill services.
A. Background – “Stored Credit”:
The funds in the Bank Account that holds them for TEL.mobi Group Members are called “Stored Credit”. Stored Credit has this classification because it does not comprise a “Payment”. No goods or services have been provided in return for the funds, so no “payment” is required or even possible. Stored Credit merely comprises funds that belong to a person, which the person has placed into his/her account at an entity, with the anticipation that he/she will utilize the funds in the future, usually incrementally, for the service that the entity provides. However, until the person has used the Stored Credit for that service, it remains – unlike a payment provided in return for a good or service already received/used – solely and exclusively his/her property. This is why it is formally referred to and classified as “Stored Credit”.
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B. Loading Stored Credit onto a Prepaid Telephone Account:
1. Standard Telephone Companies
Initial KYC already done on Mobile Phone / SIM owners in order for them to get their Mobile Phone Number / SIM.
The clients of Standard Telephone Companies can load Stored Credit onto their Prepaid Telephone Accounts using the following methods:
Bank Transfer
Online Payment Gateway
Cash (for Top-Up Vouchers, with the provenance of these funds not possible to establish)
There are multiple initial entry points for funds, via multiple parties, including cash, with funds received initially held in a large number of diverse Bank Accounts / Ledgers (i.e. the Bank Accounts / Ledgers of an extremely wide and diverse range of Retail Outlets, sub- stores of the Telco, etc).
A thorough “cleared funds” check on these funds by one Bank according to one set of standards therefore cannot be done, due to provision of cash, as well as the diverse variety of initial entry points.
There is no differentiation/separation of Stored Credit for Prepaid phone accounts, and funds/payment for handsets, SIMs, postpaid accounts, etc.
The actual funds comprising Stored Credit and Payments are often only remitted to the Telephone Company’s central Bank Account after 7 days or 30 days from the Retail Outlets and sub-stores.and Telco outlets, etc).
The TEL.mobi Group does not accept Payments – only Stored Credit – and does not accept inward transfers or integrations with multiple external parties. This is because to do so would break the TEL.mobi Group’s Closed-Loop nature and structure. It would also necessitate the inclusion of cash payments without the possibility of provenance identification, and would necessitate the inclusion of a great number of external parties and their processes. It would additionally require the acceptance of funds from multiple entities and locations, and require the actual transfer of funds to and from multiple accounts of unknown entities. This always has the consequence of unknown provenance of the funds, and unknown status of / KYC on the external entities and/or persons. 98
2. Webtel.mobi / the TEL.mobi Group
Initial KYC has already been done on Mobile Phone / SIM owners by the Telco issuing their Mobile Phones / SIMs in order for them to get their Mobile Phone Number / SIM.
The Members of the TEL.mobi Group can load Stored Credit onto their Prepaid Telephone Accounts using the following methods:
Bank Transfer
Online Payment Gateway
Vouchers acquired from by VSMPs or Independent Agents (who have Prepaid for the Vouchers through a Bank Transfer / Online Payment Gateway / TEL.mobi Stored Credit only. No cash is accepted by Webtel.mobi / TEL.mobi Group).
There is only one entry point for Stored Credit – being the Bank Account in which the Stored Credit is held, into which Stored Credit may only enter via Bank Transfer directly or through an Online Payment Gateway. A thorough “cleared funds” check on these funds by the receiving Bank is therefore able to be done according to one set of standards.
Only Stored Credit is able to enter into the Bank Account. There is no possibility for “Payments” or any other funds to enter the Bank Account, as the entire system operates solely on and with Stored Credit.
The actual funds comprising Stored Credit are remitted directly to the TEL.mobi Group’s central Bank Account for Stored Credit.
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C. Primary Services Provision for Stored Credit and/or Funds:
1. Standard Telephone Companies
Standard Telephone Companies receive, and mix, both Stored Credit and Payments/Funds from their clients for provision of their Primary Services. The Primary Services provided by Standard Telephone Companies in return for Stored Credit and Payments/Funds from their clients are:
Telephony services.
Postpaid Telephone services with monthly billing and Payments in arrears.
Prepaid Telephone Services with Top-Ups of Prepaid Telephony Accounts (which can be topped up by the Account Owner or a third-party, by cash or a variety of other means, and which can be topped up from/via a very wide variety of external entities / payment gateways / payment services / companies / Bank Accounts worldwide, over a multitude of platforms)
Payment for Mobile Data / Mobile Internet.
(Note: The TEL.mobi Group does not provide Postpaid or any other services because to do so would require the acceptance of Payments – not just Stored Credit. It also does not allow inward transfers of Stored Credit through cash payments without the possibility of provenance identification, or allow actual transfer of inward funds from unknown persons or entities – with unknown provenance of the funds or status of / KYC on the external entities and/or persons. This is because to do so would break the TEL.mobi Group’s Closed-Loop nature and structure,)
2. Webtel.mobi / the TEL.mobi Group
Webtel.mobi / the TEL.mobi Group can only receive Stored Credit for its Prepaid Telephony Services. The Primary Services provided by Webtel.mobi / the TEL.mobi Group in return for Stored Credit from its Members are:
Telephony services.
Prepaid Telephone Services with Top-Ups of Prepaid Telephony Accounts (which can only be topped up over the Webtel.mobi / TEL.mobi Group Closed-Loop system, by TEL.mobi Group Members, through and to a single Bank Account, in a Mobile Operator Stored Credit Swap (“MOSCS”) only, in which none of the already-cleared Stored Credit in the Bank Account actually moves or is transferred at all). 100
D. Secondary Services Provision for Stored Credit and/or Funds:
1. Standard Telephone Companies
Standard Telephone Companies receive, and mix, both Stored Credit and Payments/Funds from their clients for provision of their Secondary Services. The Secondary Services provided by Standard Telephone Companies in return for Stored Credit and Payments/Funds from their clients are:
Payments for non-Telephony goods and services.
Billing for non-Telephony goods and services.
Via Standard Direct Mobile Billing / Standard Direct-to-Mobile-Bill Billing (Done through external third-party platforms / external payment gateways / external applications / external integrations / external aggregators / external Bank Accounts / external Bank transfers / external money transfers. Done with multiple Banks involvement / multiple Telcos’ involvement / multiple other external parties’ involvement / multiple external peoples’’ involvement. With varying degrees of security among different external parties / no way to reliably check origin of funds / no way to reliably check destination of funds / no way to check or record flow of funds / extremely high transaction charges. Including high integration and/or service fees / delays in settlement / potential hidden “double-billing” through forced Forex conversions at unfavorable rates / expensive integration / time-consuming integration / no control of process / various and multiple other issues).
The TEL.mobi Group does not provide Standard Direct Mobile Billing / Standard Direct-to- Mobile-Bill Billing services because to do so would break the Closed-Loop nature and structure, necessitate the inclusion of a great number of external parties and their processes, and require the actual transfer of funds to and from unknown entities with unknown provenance of the funds or status of / KYC on the external entities and/or persons.
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2. Webtel.mobi / the TEL.mobi Group
Webtel.mobi / the TEL.mobi Group can only receive Stored Credit for its Prepaid Telephony Services. The Secondary Services provided by Webtel.mobi / the TEL.mobi Group in return for Stored Credit from its Members are:
Payments for non-Telephony goods and services.
Billing for non-Telephony goods and services.
Through the MOSCS variant of Direct-to-Mobile-Bill Billing, known as “Intra-Closed-Loop Member Direct-to-Mobile-Bill Services” or “ICLM Services”. (Through one unitary system worldwide and at the same extremely low costs worldwide. With full Multi-Factor Authentication Security, and no actual transfer of Stored Credit occurring / no physical transfer occurring / no external “origin” or “destination” of Stored Credit being possible because it does not move. With the full provenance of “already- cleared” Stored Credit being always known / the exact Intra-Closed-Loop movement of Stored Credit always being known / no external Banks or Aggregators or Payment Gateways or Apps or any other Entities or persons involvement at all. With MOSCSs taking 1/100th of a second to implement / with instant debit of buyer and credit of seller / at extremely low cost / with Member-controlled currency conversion before transaction to eradicate hidden “double billing”. With virtually no potential for chargebacks or fraud / with no requirement for terminals or any other equipment. With instant notifications to all parties by text and email / with instant documentary record in detail to all parties on-site / instantly available to all TEL.mobi Group Members at no cost, as a Standard TEL.mobi Group Support Service. With various and multiple other advantages).
The TEL.mobi Group is currently the only entity in the world that can provide these ICLM Services which – as a Direct-to-Mobile-Bill service through means of a MOSCS – is a fully internal, secure, verifiable and safer Intra-Closed-Loop variation of Direct-to-Mobile-Bill services.
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E. Stored Credit Limits:
1. Standard Telephone Companies
For Stored Credit amount loaded onto a client’s account, there is no limit. (Limits are sometimes applied by smaller MNOs and/or by MVNOs due solely or primarily to their systems not being able to monitor all transactions from a unitary platform, and due to their mixing Stored Credit and Payments, and not being able to easily or readily identify which is which).
For amounts used for Direct Carrier Billing / Direct to Mobile Bill services, there are no limits for Direct-to-Mobile-Bill Billing/Payments in theory, but varying limits are sometimes applied due to internal considerations. (Limits vary due to Telcos’ (or Aggregators’) internal considerations. This is due to their not being able to tell which payments are made using Stored Credit or funds from Payments. It is also due to it not being possible for one entity to manage and control the entire process itself. This necessitates the participation of a wide variety and diversity of multiple external entities and persons in the process, and results in actual funds transfers to, from and between multiple entities with disparate profiles, processes, management, security and KYC policies. Limits are also often imposed as a internal Risk-Prevention strategy; with the ceiling of the limits based primarily on the internal risk assessment profiles of the multiple various entities involved in the process, in respect of the capacity of their own internal processes and their assessment of the capacities and processes of their external cooperative entities). .
2. Webtel.mobi / the TEL.mobi Group
For Stored Credit amounts loaded onto a Member’s account, there is no limit. (This is because it is all Stored Credit, loaded into a Closed Loop system, from “cleared- funds” Bank Accounts, directly).
For amounts used for an MOSCS variant of Direct-to-Mobile-Bill billing/Payments (the “ICLM Service”), there is no limit. (This is because no Stored Credit moves at all. It remains absolutely static in the same Bank Account, with only the electronic ledger balances of the Members’ Stored Credit being altered. As such, there is no actual transfer or movement of Stored Credit at all).
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F. Stored Credit Refunds:
1. Overview
Stored Credit specifically means funds loaded onto a Prepaid Telephone Account (and some other Prepaid accounts).
It is called “Stored Credit” because it does not comprise a “Payment”. No goods or services have been provided in return, so no “payment” is possible or required. Stored Credit merely comprises funds that belong to a person, which the person has placed into his/her account at an entity, with the anticipation that he/she will use it in the future, usually incrementally, for the service that the entity provides. However, until the person has used the Stored Credit for that service, it remains – unlike a payment provided in return for a good or service already received/used – solely his/her property. This is why it is referred to, formally, as his/her “Stored Credit”.
As such, the person who placed the Stored Credit onto his or her Account can request the Refund of this Stored Credit at any time, because it remains his/her legal property, over which he/she retains ownership, at all times – until it is used.
For these reasons, it is the legal obligation of any entity at which Stored Credit is held to refund it, on request or demand by its owner, to its owner.
2. Standard Telephone Companies
Standard Telephone Companies generally do not separate the Deposits of Stored Credit received from their Prepaid Clients from the Payments of Funds received from their Postpaid Clients and/or the sale of telephones and telephony equipment.
Moreover, the sale of Standard Telephone Companies’ Prepaid Vouchers is carried out from/by a very wide range of disparate Retailers or their own Telco shops. This includes Voucher sales for cash. This cash and other forms of Payment and/or Stored Credit is initially deposited into the external Bank Accounts of (or kept on the balance sheets of) this extremely wide and disparate range of entities.
For the above reasons, the possibility for concise and rapid identifications and reconciliations between deposits of Stored Credit and Payments of funds received can take a long time to investigate and find by Standard Telephone Companies.
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This is exacerbated by their being no direct method for client communication directly with most Standard Telephone Companies for any activities other than buying items/services or paying for items/services. Support for refunds is usually done through outsourced call centers and similar arms-length entities that have no executive authority to authorize anything.
Added to the above are several further layers of complexity in respect of Standard Direct Carrier Billing / Direct to Mobile Bill services. This is because other than the issues at the Telco as described above, further process layers / levels of process flow complexity exist due to intervening Payment Gateways / Payment Companies / Aggregators / Merchants / Multiple banks and/or Bank Accounts / Other External Parties being involved along the process-flow.
For this reason, although it is the legal obligation of Standard Telephone Companies to refund a client’s Stored Credit on request/demand, many to most of them either:
Will not refund it (which is illegal in most countries, but the client has little to no recourse).
Refund it only after a period of anything from 30 to 180 days (which is also illegal in most countries, but again the client has little to no recourse).
Refund it partially, but retain up to 60% (or more) of the Stored Credit for (unspecified) processing fees / administration costs / other unspecified costs to multiple parties along the long process chain (which is also illegal in most countries, but once again, the client has little to no recourse).
Such Refunds by Standard Telephone Companies are implemented either by a transfer to a client’s Bank Account, crediting of a Client’s Debit or Credit card, or giving to the client a Voucher for the value of the refund amount. .
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3. Webtel.mobi / the TEL.mobi Group
TEL.mobi Group Members can request a Refund Transfer of their Stored Credit at any time 24/7/365. They are enabled to do so directly to Webtel.mobi from their own TEL.mobi Accounts, totally under their own control. The Refund Transfer will be implemented immediately and directly to their own Bank Account after a rapid review to confirm its compliance with the Refund Transfer Rules* (See later in this Document). Any amount up to the full amount of their remaining Stored Credit remaining will be refunded without any charges, fees or costs at all – less only the standard Transfer Fee levied by the Bank doing the actual transfer back to the Member’s Bank Account. This is able to be done because:
Webtel.mobi / the TEL.mobi Group deals only with Stored Credit – there are no “Payments” or “Funds” possibilities in the Webtel.mobi / TEL.mobi Group system.
All Stored Credit comes in exclusively via Bank Transfers / Payment Gateway to the Bank Account where TEL.mobi Members’ Stored Credit is held, and all details of its entry date, means, route and amount is immediately recorded on a per-Member basis. There is absolute clarity as to the provenance, routing and ownership of the Stored Credit at all times per Member.
There is also an instant record of all MOSCS (Stored Credit Swaps) between Members – also on one unitary platform – so there is always a 100% detailed record of the flow of Stored Credit between TEL.mobi Group Members.
Refund Transfers may only be done by and to Members who have uploaded full Know Your Client “KYC” documentation, and according to the Webtel.mobi / TEL.mobi Group “Refund Transfer Rules”.
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G. Summary:
For the services of:
1. Stored Credit loading
2. Stored Credit separation from Payments.
3. Direct-to-Mobile-Bill Billing and Payments process
4. Direct-to-Mobile-Bill Billing and Payments limits
5. Refunds of Stored Credit
The TEL.mobi Group’s uniquely-structured “Intra-Closed-Loop Members Direct-to-Mobile-Bill services” (“ICLM Services”) offer a superior system in terms of -
1. Security of Funds
2. Security of Transactions
3. Speed of Transactions
4. Cost of Transactions
5. Availability of Service
6. Ease of Use
7. Ease of Integration
8. Market Penetration
9. Geographic Coverage and Mobile Device Accessibility
Than any other Standard Direct Carrier Billing / Direct-to-Mobile-Bill services of any other Provider or Aggregator, worldwide.
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THE ICLM SERVICE
IS A BETTER ALTERNATIVE
AND/OR ADDITION TO
MANY COMMERCIAL
PRODUCTS & SERVICES
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THE ICLM SERVICE IS A BETTER ALTERNATIVE AND/OR ADDITION TO MANY COMMERCIAL PRODUCTS AND SERVICES
A. The ICLM Service is an Alternative to Debit Cards / Prepaid Cards:
Debit Cards and Prepaid Cards work on the same Legacy System platforms and systems as Credit Cards. These systems were first introduced in the 1960s – very long before the advent of the Internet and Mobile Telephony. The foundation system and structure for these Legacy Systems is – in terms of 21st Century Technology and Possibilities – Ancient.
Moreover, as with all Legacy Systems, current Debit Card Systems are in the situation where, because of the nature of the Foundation Structuring:
1. Their Systems cannot effectively compete with modern technology and products,
2. And can therefore only apply ad-hoc fixes and upgrades to their existing Legacy Structure,
3. But cannot rebuild in totality (which is needed) because if doing so they will lose their existing clients and revenues while doing so.
4. As such, they cannot effectively modernize as is required.
The ICLM service is a complete and superior Alternative to Debit Cards. The Stored Credit is retained in the Member’s TEL.mobi Account (just as it is held in a Debit Card’s account), but that is where the similarities end, because the ICLM Service:
1. Is more secure than a Debit Card Service.
2. Is much lower in cost than Debit Card services.
3. The Service is free to join and use – there are no “Card Fees”.
4. Allows Members to carry out Currency Conversions at very favorable rates at their choice instead of – as with Debit Cards – enforcing unfavorable rate Currency Conversions.
5. Is impossible to clone.
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6. Cannot be lost – because if the Member’s Phone is lost the Member’s complete TEL.mobi Account is still immediately accessible with another phone.
7. Cannot be stolen – because even if a Member’s Phone is stolen, the Member’s complete TEL.mobi Account is still immediately accessible with another phone. 8. Is almost impossible to suffer fraud due to the Multi-Factor Authentication and TAN Number sent to Members’ Phones prior to a Transaction being authorized.
9. Can be used and is accepted in places where there are no Card Terminals or ATMs.
In short, it is a much lower cost, more convenient, safer and far more multifunctional product that renders Legacy System Debit Cards redundant.
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B. The ICLM Service is an Alternative to “Cards on Phones”:
1. Various Products and Services that call themselves “Mobile Payments” have come onto the market. These products are, however, neither “Mobile” nor “Payments”, and nor are they “new” products or services at all. They are simply “Cards on Phones”.
2. They are just a Digital Version of a Debit/Credit Card, saved onto a Smart Phone. This is like saving a Paper Address Book as a Digital Address Book onto a Smart Phone, and is simply a Data Capture and Replication exercise, that can be done on any Electronic Device.
3. This does not represent a new business type or model any more than carrying a Card in a card pouch inside a Purse could constitute making the Purse a new business type, which the Purse Makers could can call by a business name (i.e. “Purse Pay”).
4. Moreover, these “Cards on Phones” versus ICLM Services have even more disadvantages than those already incurred by Standard Cards, including:
They only work on Smart Phones. However, 60% of the Mobile Phones in the world are pre-Smart Phones, so they can never achieve proper penetration.
They require the owner to have a Debit/Credit Card, or to qualify to obtain a Debit/Credit Card. They are therefore inaccessible to the 2.5 Billion Unbanked Persons internationally.
They do often do not function in countries outside the issuing country.
They only work on contactless systems, which are less than 1% of all outlets worldwide.
They are highly susceptible to fraud. If the Phone is lost or stolen – or the Card is cloned or stolen Card data obtained and placed onto another Phone – fraudulent contactless payments up to GBP 30 can be carried out without ID. This means that either the owner will lose a great deal of money, or the Merchants where it is used will receive a great many Chargebacks.
Often these products state that they do not apply charges. This is misleading, They receive a Percentage of the Charges to Merchants, Charges to Clients and Hidden Proceeds from Unfavorable Forex Conversions back from the Card Companies.
Other than this, every single one of the disadvantages of Debit Cards as previously listed applies to these “Cards on Phones”.
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5. The TEL.mobi Currency Conversion Facility and ICLM Service completely outclasses this “Card on a Phone” product in every way – from extremely favorable Live Currency Rates, to instant Pure Peer to Peer ICLM Transactions anytime and anywhere to any Member in 1/100th of a Second, using any Smart Phone or pre-Smart Phone, worldwide, 24/7/365.
6. All these done at rates and speeds that are unmatchable by even the Legacy Card Companies issuing the Cards – whether the Cards are on Mobile Phones or in peoples’ pockets or anywhere else.
7. The actual business is the Card Service, not the Phone or Purse, or Pocket or Hand on/in which the Card is simply carried. The carrying method is not a New Business, a Business Type or a Business Model. It is simply a way to carry a Card.
8. Carrying a Card in one’s hand does not make one’s hand a New Business, Business Type or Business Model (i.e. “Hand Pay” or “Hand Wallet”). It is simply a means of carrying of a card. Similarly, carrying the Card on a Smart Phone does not make the Smart Phone anything more than just a simple carrying or transport mechanism – as a “Card on a Phone” – whatever it is called in Marketing Language.
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C. The ICLM Service is an Alternative to many “FinTech” Companies:
1. “FinTech” Companies that deal with Funds Transfers do not have unique products or services of their own. This is because in order for them to function, they have to piggyback off the infrastructure of a Bank, Financial Institution or Card Company.
2. As such, all that they really represent is a methodology for feeding clients into these existing Bank, Financial Institution or Card Companies’ pipelines for their existing services.
3. Their products therefore represent only the provision of a new type of feeding mechanism into these pipelines, accompanied by marketing.
4. They still have to charge their clients the fees that these Principal Entities whose infrastructure they use charge, as well as their own fees. Their lead times are also added on to the lead times of the Principal Entities.
5. If they advertise that their services are at no cost or low cost, it only means that the Principal Entities are paying them a percentage of the transaction fees, or the hidden cost embedded in Unfavorable Forex Conversion rates.
6. Those that function off Mobile Phone platforms in reality only function off Smart Phone Platforms – thereby excluding the 60% of Mobile Phones in circulation that are pre-Smart Phones. They also usually function only off two Smart Phone platforms, thereby excluding many of the other platforms.
7. Moreover, the only thing that they can offer over and above the existing Legacy System Banks, Financial Institution or Card Companies whose infrastructure they need to function and whose pipelines they feed their clients into is, perhaps, the convenience of the client carrying out the activity on a Smart Phone.
8. They are not, however, New Products or New Services. They are just Banks, Financial Institutions or Card Companies on a Phone.
9. As such, they carry with them all the disadvantages of these entities – as listed previously in this Section and as listed in the later “Legacy Systems” Section – in comparison to the TEL.mobi Platform and the ICLM Service.
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10. The TEL.mobi Group Platform and ICLM Service outclasses them in terms of Security, Versatility, Low Costs, very favorable Forex Conversion Rates, Ease of Use and MOSCS Transfers in 1/100th of a Second in a Pure Peer to Peer Transaction.
11. Moreover, the TEL.mobi Platform and ICLM Service is available to all persons with any Mobile Phone – Smart phone on any Platform and pre-Smart Mobile Phones – worldwide.
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D. The ICLM Service is an Alternative to Remittances Companies:
1. Remittance Companies are, essentially, the same as Money Transfer Companies, and function in exactly the same way. They are almost exclusively white-labels which only have a Branding Presence, but use the Infrastructure and Facilities of other Principal Entities to do Forex Conversions and Transfers.
2. They have to add their own additional costs to the existing costs of the Principal Entities’ whose services and infrastructure they use. They also add their own processing time onto the existing processing time of the Principal Entities whose services they use. They are really just more expensive and slower versions of their Principal Entities’ services.
3. This is an old business model, functioning off Legacy Systems.
4. Remittances Companies often advertise low costs or no costs or better costs than others, but this is not possible in reality, because they have to charge the costs of the Principal Entities plus their own. Usually in the small print of their agreements they have many more Costs and more Transfer Time than they advertise in their marketing material.
5. They also often hide their high costs in very unfavorable Currency Conversion rates (See the “Legacy Systems” section for an example).
6. Such companies also only work in “Office Hours” and on “Weekdays”, and even if they have online systems to key in Transaction Data after hours or over weekends / holidays, these Transactions are only actioned later during “Working Hours” and/or “Weekdays”.
7. A Primary Market for Remittances Companies is Migrant Workers and Unbanked Persons, who often have very little option due to having to deal with cash (which also makes remittances companies susceptible to Money Laundering).
8. This business model is old, and it functions off the backbone of outdated Legacy Systems.
9. The ICLM System renders this type of Remittance Company business model redundant.
10. Unbanked / Migrant Worker Members can acquire TEL.mobi Top-Up Vouchers to convert cash to Digital Stored Credit on the TEL.mobi Platform, and then utilize all its Facilities.
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11. The TEL.mobi Currency Conversion Facility provides extremely favorable Live Currency Rates, 24/5/365, totally under the Member’s control, requiring just a Mobile Phone.
12. The ICLM Service then enables Members to do an instant Transfer of their Stored Credit in an MOSCS, in 1/100th of a second – also just by having a Mobile Phone – in a Pure Peer to Peer Transaction to any other TEL.mobi Group Member, anywhere, 24/7/365.
13. The Recipient can then redeem his or her Stored Credit with a TEL.mobi Group VSMP or Independent Agent at low rates.
14. Once the TEL.mobi Group’s “Stored Credit Refund Machines” (“SCRMs”) come into operation, Refund Withdrawals from the SCRMs to a maximum of GBP 300 – or the equivalent in another currency – per day will also be able to be carried out.
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E. The ICLM Service is an Alternative to Money Transfer Companies:
1. There are two types of Money Transfer Company.
2. The first type is a de facto white-label entity for a Principal Entity Bank or Financial institution. It just uses the infrastructure of The Principal Entity to carry out its business, simply adding more cost and time onto to the Transaction than if the Principal Institution had done it. If it advertises that there is “no transfer cost” or a “low transfer cost”, this simply means that the mark-up is hidden in the very unfavorable Currency Conversion Rate (see the “Legacy Systems” section for an example). This situation also applies to Online Money Transfer Companies. The Primary Uses for such companies are for Unbanked Persons or Cash Transfers (which makes them susceptible to money laundering activities).
3. The second type of Money Transfer Company is one that has its own Bank Accounts in different countries. It receives funds into one of its accounts in one country, and then makes a related amount available from one of its other bank accounts in another country. When doing this, no money is, in fact, transferred. The company just does an arbitrage between its own two accounts. When doing so it applies its own “Conversion Rate”, which is very unfavorable, because it has to have high margins to make this business model profitable. Again, the Primary Uses for such Money Transfer companies are for unbanked persons or Cash Transfers (which make them susceptible to money laundering activities).
4. Both of these business models are very old, expensive and slow Legacy Systems.
5. They provide very unfavorable Currency Conversion Rates, and charge very High Costs.
6. In the case of the first type of Money Transfer Company, they are as slow as the services offered by the Principal Legacy Entity – taking three to five days.
7. In the case of the second type of Money Transfer Company, transfers can be done in one hour to one day, but the costs are extremely high – up to 15% or more due to a combination of Transaction Costs, Commission and unfavorable Forex Conversion Rates.
8. These Companies are also only open for business in “Office Hours” or on “Weekdays”. Even if their online systems allow people to input Transaction Data “After Hours” or “Over Weekends”, they are only actioned when the office is open.
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9. The ICLM System renders both of these old Legacy systems completely redundant.
10. Unbanked Members can acquire TEL.mobi Top-Up Vouchers to convert cash to Digital Stored Credit on the TEL.mobi Platform, and then utilize all of its Facilities.
11. The TEL.mobi Currency Conversion Facility provides extremely favorable Live Currency Rates, 24/5/365, totally under the Member’s control, requiring just a Mobile Phone.
12. The ICLM Service then enables Members to do an instant Transfer of their Stored Credit in an MOSCS, in 1/100th of a second – also just by having a Mobile Phone – in a Pure Peer to Peer Transaction to any other TEL.mobi Group Member, anywhere, 24/7/365.
F. The ICLM Service is an Alternative to Payment Gateways:
The ICLM Service is an effective, comprehensive and immediate alternative to Payment Gateways. Merchants and eCommerce site owners who become TEL.mobi Group Members or open TEL.mobi Group VSMPs are able to instantly accept ICLM Transactions, with the equivalent of “settlement” in all currencies, and receipt of the full Transaction amount in 1/100th of a second. A detailed description of this aspect can be found in the next section of this document, in the paragraph entitled “Website and eCommerce Transactions – An Instant Payment Gateway”.
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G. The ICLM Service is an Alternative to Forex Conversion Companies:
Only Specialist and Dedicated Online Forex Conversion Companies with their own Liquidity Providers are able to provide the same Currency Conversion rates as the TEL.mobi Group. Most Forex Conversion Companies are not Dedicated Forex Conversion Companies. They are white- label resellers of Dedicated Forex Conversion Companies’ services, and cannot provide rates that are as favorable as those provided by the TEL.mobi Group and its Dedicated Forex Conversion Partner. Furthermore, even Dedicated Online Forex Conversion Companies cannot provide services to the 2.5 Billion persons in the Unbanked Market. They also do not provide 24/5/365 services to clients because although their systems may be available online – apart from very few of them worldwide – they work only during Office Hours and Weekdays. Therefore, they will not process the Forex Conversions until after they come in, even if the details have been keyed into their online systems. By that time, the rates may have changed. TEL.mobi Members can, however, access the Currency Conversion Facility 24/5/365 from anywhere at any time simply by having a Mobile Phone, and do an immediate Currency Conversion with live rates, which is immediately executed. As such, the TEL.mobi Group’s Services in this regard are not easy to beat even by Dedicated Forex Conversion Companies, and the facility to instantly carry out a live Forex conversion, and then implement an ICLM Transaction in 1/100th of a second, cannot be matched by any Forex Conversion Company in the world.
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H. The ICLM Service is an Alternative to Travel Money Cards:
A Travel Money Card is just a Debit Card / Prepaid Card that has had Stored Credit loaded onto it in a foreign currency. This Stored Credit is loaded on at universally unfavorable Rates of Exchange. Moreover, once one currency is swapped for another at Y Rate and loaded onto the Card, the Card Holder will potentially incur a huge additional currency loss thereafter if the currency’s value then becomes 2 X Y, because the exchange has already been done
The TEL.mobi ICLM Service enables Members to only Convert Currencies when they want to or need to, at any time, themselves, at very favorable live rates. As such, they will always only need to Convert Currencies when they need to, can Convert Currencies at any time 24/5/365, and do so using very favorable Live Rates. All they need to be able to do this immediately is to be a TEL.mobi Group Member, and to have a Mobile Phone. The ICLM Service completely removes and negates the need, purpose or function of any Travel Money Card. (Note: When the TEL.mobi Group’s “Stored Credit Refund Machines” (“SCRMs”) come into operation, travelers will be able to carry out Currency Conversions to do Refund Withdrawals from the SCRMs to a maximum of GBP 300 – or the equivalent in another currency – per day).
I. The ICLM Service is an Addition to Travel Money Card Companies:
Travel Money Card Companies (and Travel Agents who issue Travel Money Cards) may also become VSMPs, and provide their clients with an easy and cost-effective method to top-up their Travel Money Card Accounts through ICLM Transaction to the VSMP of the Travel Money Card Company, for which they can charge a fee (set by them, for their sole retention).
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J. The ICLM Service is an Alternative to Bureaus de Change:
Bureaus de Change provide even more unfavorable Currency conversion Rates than do Debit Card, Travel Money Cards or other Legacy System entities. This is because their essential Business Model and structuring has remained unchanged for more than a Century. As such, when compared to modern 21st Century Services and Products – especially since the advent of the Internet and Mobile Telephony – they are so outdated and unfit-for-purpose as to be in the Stone Age. Bureaus de Change are the retail front-doors of existing Legacy System entities, and their characteristic is that they load more charges onto the already-unfavorable rates that they get from their Legacy System Providers, making their rates extremely unfavorable. They have no redeeming factors in terms of Currency Conversions other than that they provide a means through which to do a Currency Conversion from Cash to Cash (which also carries significant potential for money laundering), or Currency Conversions from Card to Cash.
The TEL.mobi Platform and ICLM Service render Bureaus de Change redundant. Insofar as Currency Conversions are concerned, there is no comparison possible due to the TEL.mobi Platform’s total outclassing of Bureaus de Change Currency Conversion rates through the provision of instant Live Rate Currency Conversions to all of its Members at – compared to Bureaus de Change – extremely favorable rates. For conversions of currency that is held in cash, the TEL.mobi Group similarly renders Bureaus de Change redundant through the ability for TEL.mobi Group Members to buy Stored Credit on Top-Up Vouchers. Members are then able to load this Stored Credit onto the TEL.mobi Account, and then carry out an instant Currency Conversion at much more favorable rates that will even be obtained from a Bureau de Change (and also with no chance of anonymous Money Laundering). The Stored Credit on the Member’s TEL.mobi Account can then be used in ICLM Transactions. Moreover, once the TEL.mobi Group’s “Stored Credit Refund Machines” (“SCRMs”) come into operation, Refund Withdrawals from the SCRMs to a maximum of GBP 300 – or the equivalent in another currency – per day will also be able to be carried out.
K. The ICLM Service is an Addition to Bureaus de Change:
Bureaus de Change can also become TEL.mobi Group VSMPs, and can then provide Redemptions of ICLM Transactions for a fee (set by them, for their sole retention) in the event that TEL.mobi Group Members are travelling on Business or Leisure trips, and want to pick up different currencies in non-electronic format. They can also provide Discounted Redemptions of ICLM Transactions to Unbanked Persons or for Remittances Markets in their areas of operation.
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L. The ICLM Service is an Addition for Letter of Credit Companies:
1. Companies that specialize in obtaining Letters of Credit for clients and Managing Trade or Sales/Purchase Transactions between Clients usually broker Letters of Credit for these Transactions.
2. However, Letters of Credit sometimes take a long time to issue. Additionally, the entities that issue and redeem Letters of Credit do not work over “Weekends” / “After Hours” / during “Holidays” (which vary per country and Time Zone). They also often provide very unfavorable Forex Exchange Rates and, furthermore, charge up to 16% or more of the Face Value of the Letter of Credit as the Service Fee for providing it.
3. This is an extraordinarily old Legacy System, which has remained essentially unaltered for Centuries – let alone predating the advent of the internet and Modern Mobile Phone services. All that has changed in that time is that the costs have increased from High to Astronomic.
4. The ICLM Service is an Additional Resource for such Companies for their Transactions that require Letters of Credit, as follows:
The Company forms its own VSMP.
The Company’s Management establishes their own Accounts on their VSMP.
The Company’s personnel receive the Stored Credit for the Transaction into their Account from the TEL.mobi Member who is the Buyer, and Retains it there until the Commodity is Delivered.
Once the Commodity is Delivered, Accepted and Signed Off on, the Stored Credit in the Company Management Member’s account is sent to the TEL.mobi Member who is the Seller.
5. The advantages for Companies of this system over Standard Methods include:
Transactions can be set up instantly instead of taking weeks.
Transactions can be implemented 24/7/365 with no blocks “After Hours” / “Weekends” / “Holidays”.
Transactions take 1/100th of a Second to complete, as opposed to days.
Transactions provide very Favorable Forex Conversion Rates instead of Unfavorable Rates.
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Transactions cost a total of 0.5% instead of 16% or more (ICLM Transactions cost 0.25% when of Letter-of-Credit-size Transactions – therefore 2 X 0.25% Transactions).
This system speeds up the implementation and completion of such Transactions exponentially, provides better Forex Rates (i.e. saves money), costs exponentially less, provides very high security, and works 24/7/365.
All Agreements, Standards, terms and other Security, Control, Management and other Control Aspects of such Transactions can remain as they are, only modified to reflect the Alternative Method for swapping of Stored Credit.
6. All aspects of these Transactions are Transparent, and – even more than with the Standard Method – are under the control of the TEL.mobi Members who are the Company Managing the Transaction and the two other Parties to the Transaction – with full visibility of all aspects at all times.
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M. The ICLM Service is an Addition for Escrow Companies:
1. Companies that specialize in providing Escrow Services for clients often provide or set-up Escrow Accounts for their clients, and manage these services.
2. However, these services – functioning off Legacy Systems as they do – result in Transfers taking a long time to arrive in Accounts. Moreover, the entities where the Escrow Accounts are held do not work over “Weekends” / “After Hours” / during “Holidays” (which vary per country and Time Zone). They also often provide very unfavorable Forex Exchange Rates and, furthermore, charge significant fees for providing the Escrow Facility.
3. This is also an extraordinarily old Legacy System, which has remained essentially unaltered for Centuries – let alone predating the advent of the internet and Modern Mobile Phone services. All that has changed in that time is that the costs have increased substantially.
4. The ICLM Service is an Additional Resource for such Companies for their Transactions that require Escrow Accounts, as follows:
The Company forms its own VSMP.
The Company’s Management establishes their own Accounts on their VSMP.
The Company’s personnel receive the Stored Credit for the Transaction into their Account from the TEL.mobi Member who is the Buyer, and Retains it there until the Transaction is completed.
Once the Transaction is Completed, Accepted and Signed Off on, the Stored Credit in the Company Management Member’s account is sent to the TEL.mobi Member who is the Seller.
5. The advantages for Companies of this system over Standard Methods include:
Transactions can be set up instantly instead of taking weeks.
Transactions can be implemented 24/7/365 with no blocks “After Hours” / “Weekends” / “Holidays”.
Transactions take 1/100th of a Second to complete, as opposed to days.
Transactions provide very Favorable Forex Conversion Rates instead of Unfavorable Rates.
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Transactions cost a total of 0.5% instead of the very much higher fees levied for standard Curated Escrow Services (Transactions requiring Escrow Facilities – such as Property Transactions – are high. ICLM Transactions cost 0.25% for this type of Transaction – therefore 2 X 0.25% Transactions).
This system speeds up the implementation and completion of such Transactions exponentially, provides better Forex Rates (i.e. saves money), costs exponentially less, provides very high security, and works 24/7/365.
All Agreements, Standards, terms and other Security, Control, Management and other Control Aspects of such Transactions can remain as they are, only modified to reflect the Alternative Method for swapping of Stored Credit.
6. All aspects of these Transactions are Transparent, and – even more than with the Standard Method – are under the control of the TEL.mobi Members who are the Company Managing the Transaction and the two other Parties to the Transaction – with full visibility of all aspects at all times.
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N. Other Uses:
The TEL.mobi Platform is merely that – a Platform.
The TEL.mobi Group itself does not provide any of the services previously listed in this Section. It only provides its Telephony Services.
However, the Platform itself is available to all TEL.mobi Group Members – whether they are Private or Corporate/Business Members.
Moreover, all of the Facilities within the TEL.mobi Group’s Platform are available to all of its Members, to utilize as they wish to as long as they adhere to the Rules of using the Services, and the laws applicable to them in their countries / industries / sectors.
There are many and multiple uses for the Platform and the Services, which people, companies and organizations are able to work out for themselves – because they know their own industries and businesses well themselves. They are therefore able to establish whether or not the TEL.mobi Group’s Platform and/or any of its products may be useful, helpful or applicable, and if so, where and how.
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EXAMPLES OF
THE ICLM SERVICE’S
NUMEROUS ADVANTAGES
OVER MANY
COMMERCIAL
PRODUCTS & SERVICES
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EXAMPLES OF THE ICLM SERVICE’S NUMEROUS ADVANTAGES OVER MANY COMMERCIAL PRODUCTS & SERVICES
All of the advantages listed in the preceding Section E apply to all Business / Commercial entities. However, over and above those, there are even more advantages for different specific Business / Corporate / Other sectors. Summaries of some of these additional advantages are as follow:
A. Website and eCommerce Transactions – An Instant Payment Gateway:
ICLM Transactions are an alternative to Standard Payment Gateways in every way. Moreover, they can be put up and be running instantly on any Website or eCommerce site instantly and free – with no integration time, cost or other requirements – because the full ICLM Service is available to every TEL.mobi Group Member immediately upon Joining. A summary of many of the advantages of using ICLM Transactions as an alternative to Standard Payment Gateways are as follow:
1. Long Integration Time versus No Integration Time
Standard Payment Gateways can take from one week to six weeks to integrate their Payment Gateway into a website or eCommerce site.
With ICLM Transactions, there is no integration requirement at all. ICLM Transactions can be used by the Website or eCommerce site immediately by simply by displaying the ICLM Acceptance Notification.
2. Integration Cost versus No Integration Cost
Standard Payment Gateways often charge – sometimes significantly – to integrate their Payment Gateway with a Website or Ecommerce site.
With ICLM Transactions, there is no integration cost at all. The total ICLM System is already integrated into a Member’s TEL.mobi Account, free.
3. Monthly Gateway Fees versus No Monthly Gateway Fees
Standard Payment Gateways often charge monthly Gateway Fees.
To join as a TEL.mobi Group Member and immediately use the ICLM Transaction Service on a Website or eCommerce site is completely free.
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4. High Transaction + % Fees versus No Transaction Fees and Low % Fees
Standard Payment Gateways often charge a Transaction Fee as well as a Transaction Percentage Fee of up to 2% or 3% (or more) per transaction.
With ICLM Transaction there is no Transaction Fee at all (they are free), and there is only a flat Transaction Percentage Fee of 0.25% to 1%.
5. Cannot Accept Foreign Currencies versus Can Accept All Foreign Currencies
Standard Payment Gateways are often unable to accept many different currencies, limiting the market of Websites and eCommerce sites, or otherwise subjecting them to unfavorable Forex rates and currency risk for settlement.
With ICLM Transactions, Websites and eCommerce sites can accept any currency with settlement in that currency – opening their market to worldwide currencies and completely removing Forex conversion losses and currency risk.
6. Unfavorable Forex Conversions versus Very Favorable Forex Conversions
If Standard Payment Gateways accept payments in many currencies, they still often settle to the Websites and eCommerce sites in limited currencies – often at unfavorable Forex conversion rates to the Websites and eCommerce sites and the clients of those sites.
With ICLM Transactions, any currency can be accepted, and Websites and eCommerce sites – and their clients – can do their own Forex conversions within their own TEL.mobi Accounts at very favorable rates, to completely remove the “hidden double costs” of forced unfavorable Forex conversion rates.
7. Limited to Local Market versus Access to an Unlimited Global Market
Many Standard Payment Gateways are limited to one country or region, thereby significantly limiting the Website’s or eCommerce site’s potential market.
With ICLM Transactions, the potential market opened up is that of all of the billions of Mobile Phone Owners worldwide; thereby providing websites and eCommerce sites with the largest potential market in the world – the entire Global Market.
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8. No Settlement “After-Hours” & Weekends versus Full Settlement 24/7/365
Standard Payment Gateways do not provide Settlement “after working hours” or over weekends.
ICLM Transactions provide Full Settlement 24 hours per day, seven days per week, 365 days of the year.
9. No Access to 2.5 Billion Unbanked versus Full Access to 2.5 Billion Unbanked
Standard Payment Gateways can only be used by Banked Persons, who have Bank Cards or use Alternative Payment Methods / Wallets that are linked to Bank Accounts. This therefore totally excludes the 2.5 Billion Unbanked Persons internationally from being potential clients of Websites and eCommerce Sites.
The TEL.mobi Group’s Global Top-Up Vouchers bring all Unbanked People into the 21st Century Digital Economy by enabling them to obtain digital Stored Credit and carry out ICLM Transactions. The ICLM Service therefore instantly adds the 2.5 Billion Unbanked Persons internationally as potential clients for Websites and eCommerce Sites.
th 10. Settlement Delays of 2 – 30 Days versus Full Settlement in 1/100 of a Second
Standard Payment Gateways delay Settlement to Websites and eCommerce sites from two days to 30 days.
ICLM Transactions provide Websites and eCommerce Sites with instant Settlement in 1/100th of a second.
11. Chargeback Risk and Losses versus No Chargeback Risk or Losses
Standard Payment Gateways – and the Websites and eCommerce Sites that use them – are susceptible to potentially large-scale losses due to Chargebacks.
ICLM Transactions render Chargebacks impossible, and totally remove the potential for Websites and eCommerce Sites to suffer losses from Chargebacks.
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12. Retention of funds versus No Retention of Funds
Standard Payment gateways retain various percentages and sums of funds from Websites’ and eCommerce Sites’ Revenues to guard against Chargebacks and fraud costs.
ICLM Transactions provide 100% of Websites and eCommerce Sites’ Revenues to them in full, instantly in 1/100th of a second; due to the removal of chargeback and other risk factors by the ICLM System and process.
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B. Commercial and Business Transactions – Retail and Wholesale:
1. Payment Systems Cost & Time versus No Payment Systems Cost & Time
For New Businesses there is a substantial cost involved in acquiring the Equipment and Systems required for them to accept Payments, and a lead-time required for installing and preparing them / training on them. For existing Businesses, the same applies when they add additional Payment Systems to their existing ones.
ICLM Transactions can be accepted immediately, with no Systems or Equipment cost or lead-time required at all. All that is required is a Mobile Phone and the display of the “ICLM Acceptance Notification”.
2. High Card and Terminal Fees versus No Card or Terminal Fees
Businesses accepting payment by Cards incur a Card Fee of 2% to 3% or more, as well as Terminal Fees. They are also subject to the Card Service going offline / Terminal breaking and Cards being declined.
With ICLM Transactions, there is no Terminal required, so that expense is saved. There are not fees of 2% to 3% or more – only a flat fee of 0.25% to 1% per ICLM Transaction. The only things required for clients or business owners are that each party has a Mobile Phone.
3. No Settlement “After-Hours” & Weekends versus Full Settlement 24/7/365
Card Companies do not provide Settlement “after working hours” or over weekends.
ICLM Transactions provide Full Settlement 24 hours per day, seven days per week, 365 days of the year.
th 4. Settlement Delays of 2 – 30 Days versus Full Settlement in 1/100 of a Second
Card Companies and some other forms of payment often delay Settlement to businesses from two days to 30 days.
ICLM Transactions provide businesses with instant Settlement in 1/100th of a second.
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5. Chargeback Risk and Losses versus No Chargeback Risk or Losses
Businesses are susceptible to potentially large-scale losses due to Chargebacks.
ICLM Transactions render Chargebacks impossible, and totally remove the potential for Businesses to suffer losses from Chargebacks.
6. Retention of funds versus No Retention of Funds
Card Companies and other forms of Payment often retain various percentages and sums of funds from Businesses’ Revenues to guard against Chargebacks and fraud costs.
ICLM Transactions provide 100% of Businesses’ Revenues to them in full, instantly in 1/100th of a second; due to the removal of Chargeback and other risk factors by the ICLM System and process.
7. Cannot Accept Foreign Currencies versus Can Accept All Foreign Currencies
Some Businesses are unable to accept many different currencies, limiting their market.
With ICLM Transactions, Businesses can choose to accept multiple currencies, or request their clients to do Currency Conversions on their TEL.mobi Accounts and do an ICLM Transaction in the Business’s preferred currency.
8. Limited to Local Market versus Access to an Unlimited Global Market
Many Businesses operating with standard payment equipment are limited to one country or region, thereby significantly limiting their potential market.
With ICLM Transactions, the potential market opened up to Businesses is that of all of the billions of Mobile Phone Owners worldwide; thereby providing Businesses with the largest potential market in the world – the entire Global Market.
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9. Unfavorable Forex Conversions versus Very Favorable Forex Conversions
If Businesses’ clients pay from different currency jurisdictions, standard currency conversions for them are generally very unfavorable, and can result in either the business losing funds because of the unfavorable conversion rate, or the client paying more because of the unfavorable conversion rate.
With ICLM Transactions, Businesses and their clients can do their own Forex Conversions within their own TEL.mobi Accounts at very favorable rates, to completely remove the “hidden double costs” of forced unfavorable Forex Conversion rates.
10. Admin / Receipts / Shrinkage Costs vs No Admin / Receipts / Shrinkage Costs
Businesses incur costs due to the requirement to implement detailed Administration / Receipt / Records, and/or Shrinkage from failure to implement detailed Administration / Receipt / Records processes.
With ICLM Transactions, every Transaction is recorded in detail, and instantly placed in the Business’s and Client’s “History” Facility, and email and by text – free of charge. This provides a free full Administration / Receipt / Records process for every Transaction; thereby removing the cost for such, processes and/or the personnel required to implement them.
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C. Remittances Sending and Receiving:
Remittances sent by persons in Expatriate Positions or Migratory Work Positions are subject to extreme cost and lose large amounts of their money in the remitting. Moreover, the Recipients of remitted funds are – in some countries – subject to extortion. Other than this, because much of the sending of funds in this market entails movements of cash, this sector is also vulnerable to Money Laundering activities. The TEL.mobi Group’s ICLM Service removes all of these unfavorable circumstances, and also negates the propensity for potential Money Laundering activities. A summary of some of the top-level advantages provided by the ICLM Service is as follows:
1. Risky Cash Carrying/Transactions versus Safe Digital Stored Credit Transactions
Using Legacy Methods, people who are in Migratory Work situations are often compelled to receive and use cash due to being Unbanked. The carrying of cash is risky for both theft and loss, and the transfer of cash (especially Unbanked Recipients) is limited to using Money Transfer companies and “Remittances” companies, which are very expensive. Transactions using cash are also susceptible to Money Laundering activities.
The TEL.mobi Facilities enable people in Migratory Work situations to immediately and easily exchange their cash for Digital Stored Credit on the TEL.mobi Platform by acquiring TEL.mobi Top-Up Vouchers from TEL.mobi Independent Agents or VSMPs, and loading their Stored Credit onto their TEL.mobi Account. This renders their Stored Credit unable to be lost or stolen, provides them with the high levels of security on the TEL.mobi Group Platform, and also allows them to use the ICLM Transaction Facility for ICLM Transaction to Recipient Members. It also exponentially reduces the possibilities for Money Laundering.
2. Forex Rates Extremely Unfavorable versus Forex Rates Very Favorable
Because people in Migratory Work situations are absolutely limited in choice in respect of money transfer to Recipients, they are subject to mandatory and very unfavorable Currency Conversion Rates from the few entities that provide services to and for them. These unfavorable rates can cost the Sender up to 10% or more of their money, and there is no effective escape from this situation.
By using the TEL.mobi Platform, people in Migratory Work situations have access to very favorable Currency Conversion Live Rates, 24/5/365, at their election. This saves them a very large amount of their money.
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3. Money Transfers costing 15%+ versus ICLM Transactions costing 1%
Using Standard Money Transfer companies (or “Remittances” companies) is very costly, with the total of costs incurred when sending remittances of up to an effective 15%. Even if lower costs are advertised, there are many hidden costs – including in the unfavorable Currency Conversion rates, which can bring the costs up to an effective 15% (or more) of the funds being transferred. These entities are also closed “After Hours” / during “Weekends” / over “Holidays” and funds cannot be sent at those times. Moreover, Senders have to travel into Towns or Cities to offices to send these funds. Additionally, as these transactions are often made with cash, there is a susceptibility to Money Laundering.
Using an ICLM Transaction, the total of Stored Credit can be instantly sent by the Sender Member to the Recipient Member at a flat rate of only 1%. They can also be sent at any time of the day or night 24/7/365, and can be sent from any location – wherever the Sender is, using just his/her Mobile Phone. Once Stored Credit is in the TEL.mobi System. Money Laundering activities are almost impossible to carry out undetected.
4. Cash Couriers cost 40% versus ICLM Transaction at 1%
Because there is often physical danger for Recipients of Remittances in some countries (see Point 6 below), and because Money Transfer Companies are not available in some locations, many people in Migratory Work situations make use of the services of “Cash Couriers” to transport funds to Recipients. Such services effectively cost the Sender up to 40% of his/her funds in fees and extraordinarily unfavorable Currency Conversion rates, take days or weeks to be completed, and are often lost or stolen. As large amounts of cash are being transported, this method is also susceptible to Money Laundering activities.
Using an ICLM Transaction, the total of Stored Credit can be instantly swapped with the Receiving Member at a flat rate of only 1%. Once Stored Credit is in the TEL.mobi System. Money Laundering activities are almost impossible to carry out undetected.
5. Long Transfer Times versus Transaction in 1/100th of a Second
People in Migratory Work situations using Money Transfer Companies or Remittances Companies can experience lead times of hours to over a week before the funds arrive at their destination for the Recipient. In the case of cash couriers, the lead-time can be from days to weeks, and is insecure, with no fixed arrival date given.
In the case of people in Migratory Work situations using an ICLM Transfer to a Recipient, this is able to be done in 1/100th of a second.
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6. Receipt only at Branches in Cities / Towns / Villages versus Receipt Anywhere
In many cases, the Recipients of funds sent by people in Migratory Working situations have to travel very far – to an office or location in a Village/Town/City – to pick up these funds, and these offices are not open “After Hours” / over “Weekends” / during “Holidays”. This introduces another layer of expense and difficulty for Recipients to obtain such funds if they are sent via Money Transfer companies or Remittances companies.
In the case of people in Migratory Working situation using an ICLM Transaction, the Recipient Member receives it instantly no matter where they are – be it in a rural area or a large city – at any time of the day or night 24/7/365.
7. Extortion at place of Receipt versus Completely Safe Receipt
In many countries where noticeable sections of the population receive Funds from Remittances, this situation is taken advantage of by criminal elements. The majority of those who are Recipients of such Remittances Funds are Women or young Adults. This is because it is primarily Men – and to a lesser extent Adult Women – who travel abroad to undertake Migratory Work. Because this is known, and general receipt periods are known and the limited locations where Remittances Funds can be received are known, these locations are permanently staked out by criminal elements, which extort percentages of the received Remittance Funds from Recipients in return for not harming them (or not taking all of the Funds). As a result of this situation up to 50% of the amount of Remitted Funds received are usually lost by the Recipient through this extortion (this is over and above the 15% to 40% of the Remitted Funds already lost to the Senders in the transfer of these Funds).
With ICLM Transactions, all of the Funds are safely, discreetly and confidentially received by the Recipient as Digital Stored Credit on her/his TEL.mobi Account, which is received wherever they are, securely, with the full security of the TEL.mobi Account protecting the Member’s Account. They are therefore not susceptible to extortion and loss of Funds.
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8. Unfavorable / Unsafe Redemption versus Favorable / Safe Redemption
In some instances, people who are in Migratory Work situations will send their Paychecks or another Instrument of Value to the Recipients for them to hand in to a local Money- Changer for discounting, and provision to the Recipient of a Discounted amount of Funds. Similarly, some people in Migratory Work situations will transfer their wages to the Bank Account of a local Money-Changer for discounting, and provision to the local Recipient of a discounted amount of Funds. These systems uniformly result in the discounts being very high, the Currency Conversion Rates being very unfavorable towards the Recipient, and also instances of failure or refusal to pay out Funds. This system is also susceptible to Money Laundering due to Instruments of Value and/or Funds ending up with people that the Instrument / Funds were not provided to, and which are not formally recorded as being in their possession.
With ICLM Transactions, Recipients can redeem their Stored Credit at multiple TEL.mobi Group Independent Agents and VSMPs. The Independent Agents and VSMPs are part of the Communities that they serve and live in. Moreover, any Independent Agents and VSMPs who are reported to Webtel.mobi as engaging in any incidents of extortionate redemption activities losing their positions immediately. Due to these factors, extortionate Redemption Rates are very low. Other than this a full and detailed record of Transaction Flows exists on the TEL.mobi Group’s system. This includes the fact that full and detailed records exist of the exact Route/s, Recipient/s, Conversion/s and all other activities with every ICLM from inception to the end. Additionally, the Independent Agents and VSMPs have themselves uploaded full KYC Documentation. Consequently the chances of Money Laundering attempts being able to be carried out undetected – and/or or directly and specifically traced / attributed / followed-up on directly – are zero.
9. Recipients have to Redeem versus Recipients can use ICLM Transactions
In cases where a Sender in a Migratory Working situation has sent a Paycheck or another Instrument of Value to a Recipient, the Recipient has no alternative but to redeem it, at whatever rates and/or terms it is redeemed at.
In the case of an ICLM Transaction, the Recipient does not necessarily have to redeem it, because the Recipient can retain the Stored Credit in her/his TEL.mobi Account to carry out ICLM Transactions directly with other local TEL.mobi Group Members who provide goods or services instead of redeeming the Stored Credit.
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10. “Stored Credit Refund Machines” (“SCRMs”)
When the TEL.mobi SCRMs are introduced, Remittances Recipients will also be able to withdraw GBP 300 (or the equivalent in any other currency) per day from SCRMs. This will include the specialized “Travelling SCRMs” in vehicles that are being prepared specifically to travel into and provide services to rural areas, and also the “Marine SCRMs” that are being prepared to travel to and provide services to shipping company personnel.
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D. Payroll Transactions:
ICLM Transactions have advantages in respect of (especially) international and multinational payroll transactions, as follow:
1. Indirect Transactions + Intermediaries vs Direct Transactions + No Intermediaries
With Standard Methodologies, Bulk Amounts often need to be transferred to central institutions in varying countries of operations, for further onward administration and transfer to local institutions in-country, because transfers cannot be done directly to recipients. This doubles the already-high transfer costs and doubles the already-high transfer time.
With ICLM Transactions for Local, National, International or Multinational Payroll Transactions, the Transaction can be carried out directly to all Recipients, anywhere, at any time, simultaneously, 24/7/365, in 1/100th of a second, at very low cost.
2. Long Admin Preparation + Activities versus One Simple and Easy-to-Use Page
With Standard Methodologies, due to the varying regime and requirements in multiple countries of operations, different and often cumbersome administration and processes needs to be carried out every month, necessitating multiple persons and a lot of time.
With ICLM Transactions, all Transactions can be done directly to Recipients, in all and any locations, instantly in 1/100th of a second, requiring just one person using just one page on the TEL.mobi System.
3. Unfavorable Currency Conversion Fees versus Favorable Conversion Fees
With Standard Methodologies, entities are subjected to mandatory Currency Conversions to the end-destination currencies. These are done by third parties, outside of the control of the transferring entity, and vary between unfavorable to very unfavorable.
With ICLM Transactions, the transferring entity is totally in control of its own Currency Conversions, and can do them anytime 24/5/365, at very favorable rates that suit them.
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4. Transaction Fees versus No Transaction Fees
With Standard Methodologies, entities are usually charged significant Transaction fees for preparing and initiating transactions to various countries, using various entities, and the significant documentation and preparation required. There can also be wide and disparate amounts of other fees, some of them very high (either directly or hidden in the Currency Conversion). This is especially as there will be different charges for transfers to different end-destinations.
With ICLM Transactions, there are no Transaction fees, because the entire process for all persons can be done simply, by one person, on one page, on one platform. Moreover, the Transfer Fees are very low, varying from 0.25% to 1% of the amount transferred.
5. Long Transfer Times versus Instant Transactions in 1/100th of a Second
With Standard Methodologies, transfers can take three to five days – or longer depending on the end-destination, and with funds unable to be received “after Hours”, over “weekends” or during “holidays” (all of which vary in different countries and time zones), and this can also add to the time-lag between transfer and receipt.
With ICLM Transactions, transfers to all parties anywhere, can be completed in 1/100th of a Second, 24/7/365, with instant confirmation to the Sending and Receiving Parties by Text, Email and in Sender’s and Recipient’s “History” Facility on their TEL.mobi Accounts.
6. Varying Processing Times versus One Simultaneous and Instant Process
With Standard Methodologies, transfers to different end-destinations take varying amounts of time to arrange, send and arrive. This necessitates long processing times and multiple persons and entities to implement, with these processes beginning and ending at different times – and taking different amounts of time – even though they are for the same payments at the same time. This necessitates a great deal of work and is expensive.
With ICLM Transactions, transfers to all parties, anywhere, can be completed in 1/100th of a Second, with instant confirmation to the Sending and Receiving Parties by Text, Email and in Sender’s and Recipient’s “History” Facility on their TEL.mobi Accounts.
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7. Manual Documentation Preparation vs All Documentation System-Prepared
With Standard Methodologies, given the disparity of systems and processes that have to be managed with multi-country payments, a great deal of documentation has to be prepared and recorded. This requires time and personnel, and results in unnecessary cost.
With ICLM Transactions, all documentation is prepared and created instantly, and is placed into the History Facility of the Sender and Receivers’ TEL.mobi Accounts simultaneously, instantly and at no cost.
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E. Trade and Commodity Trading Transactions:
Trade and Commodity Transactions of all variations often require transfers of varying amounts of funds between sellers and buyers. Of critical importance in such Transactions are the rates of conversion able to be obtained, as well as the speed of the Transaction. ICLM Transactions are an alternative to most other forms of settlement between parties in Trade and Commodity Trading Transactions. A summary of many of the advantages of using ICLM Transactions for such Transactions are as follow:
1. Unfavorable Forex Conversions versus Very Favorable Forex Conversions
With Standard Transactions where payment for Commodities or Trades need to be made in a different currency to the home currency, the currency conversions are often done at standard commercial conversion rates, or on rare occasions, at rates which are rates which are only slightly better than standard commercial conversion rates. This can mean obtaining values of hundreds to thousands lower for smaller Transactions – or values of hundreds of thousand to millions lower for larger Transactions – for exactly the same starting amount than can be obtained at better conversion rates.
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With ICLM Transactions, currency conversions are done at very favorable live rates, which can often result in values of hundreds to thousands more for smaller Transactions – or values of hundreds of thousand to millions more for larger Transactions – for exactly the same starting amount that yields much lower values in standard commercial transactions.
2. Clearance Delays of 3 Days or More versus Clearance in 1/100th of a Second
With Standard Methods, clearance of a transfer from an account in one country to an account in another country can take three to five days. During this period, the money has effectively “disappeared”, because it is not in the seller’s or buyer’s accounts, and is collecting interest for some other party, somewhere. Additionally, in this period, currency values can increase or decline, both of which events can seriously affect the baseline of the Trade / Commodity. It can also have an effect on the availability or scarcity of Commodities. Moreover, clearance times can be the deciding factor in a bid or a Trade.
With ICLM Transactions, the Stored Credit Swap from one Member’s account to another occurs in 1/100th of a second. As such, there is no chance of currency value fluctuations or availability/scarcity of Commodity or time lags interfering with bids or transactions.
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3. No Transactions “After Hours” or Weekends versus Transactions 24/7/365
With Standard Transactions, transfers and clearances are not available “after hours” or over weekends. However, in a global economy, there is no “after hours”, because “after hours” in one part of the world is “working hours” in another. Moreover, for large parts of the world, “weekend” is Friday and Saturday – with Sunday as a working day. The inability to carry out Transactions, Trading, Transfer or Settlement “after hours” and over “weekends” from one country when the same situation does not apply in another country can lead to loss of trades, variations in prices and various other negative outcomes.
With ICLM Transactions, there are no “after hours” times or “weekends”. The full ICLM Service of ICLM Transactions from one currency to another is available 24/7/365, making Transactions, Trading, Transfer and Settlement available and possible 24 hours a day, seven days a week, 365 days of the year, in 1/100th of a second.
4. Comparison of a Standard Transaction versus An ICLM Transaction
The Trader has to work through a third party entity to get a standard currency conversion rate and convert (which he/she is not in control of). They also have to work through a third party to do the funds transfer (which he/she is not in control of). Thereafter, their funds “disappear” from his/her account and do not “reappear” in the recipient’s account for three to five days. The Trade / Rate / Cost / Deal is able to be affected by these delays and potential currency rate fluctuations, and no conversion, transfer or settlement is able to be done “after hours” or on “weekends”.
With an ICLM Transaction, the Trader selects and carries out the currency conversion himself/herself at a favorable conversion rate under his/her control, then does an ICLM transaction himself/herself at his/her control – whether in an office in a Capital City or in a Rural Area with a Mobile Phone – with the Transaction being completed within 1/100th of a second, so there is no chance of affecting the Trade / rate / Cost / Deal; and this whole process being able to be done anytime on a 24/7/365 basis.
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F. Oil Purchases/Sales Transactions:
Oil Purchases and Sales need to be carried out in US Dollar currency, and many oil-producing entities or entities that engage in large-scale oil purchases and sales often do not obtain good currency conversion rates from their home currencies to or from US Dollars. Using ICLM Transactions for Oil Sales and Purchases provides such entities with currency conversion rates that are very favorable, on a 24/5/365 basis.
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G. Examples of Other ICLM Transaction Advantages:
1. Unbanked Persons’ Digital Economy Entrance
Unbanked Persons are forced to function in a cash-only economy. In the first place, this means that goods and services that they pay for cost them on average a great deal more. In the second place, they are completely cut out of the digital economy, and cannot acquire any goods or services online. This not only prevents them from acquiring lower- cost goods and services, in many instances it prevents them from obtaining certain goods and services at all. It also leaves them vulnerable to loss or theft of their cash, or to robbery.
By becoming TEL.mobi Members and swapping their cash for Stored Credit through the acquisition and loading of TEL.mobi Group Top-Up Vouchers, Unbanked Persons are able to leave the cash-only economy, and enter the 21st Century Digital Economy. They are then fully able to carry out Digital Economy Transactions with Merchants via ICLM Transactions, and are also fully able to acquire goods and services online from Websites and eCommerce entities that have added the ICLM Service to their Payment Gateways. Besides being a much safer and more secure way for them to hold their Stored Value, this enables Unbanked People to save a great deal by being able to acquire goods and services online, and also allows them to acquire goods and services that were previously unavailable to them. This will especially be the case when the TEL.mobi Group’s Global Marketplace is made live, because it will function primarily with ICLM Transactions. They are furthermore placed in a safer position in terms of the risks of loss, theft or robbery of their cash being removed.
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2. International Organization Field Activities Transactions
International Organizations often conduct Field Work in Developing Country environments or in Unstable Areas / War-torn Areas. In locations and situations such as those, it is difficult to pay Field Staff, because there are little to no functioning entities through which to transfer funds for salaries, remunerations of volunteers, payments for goods and services, etc. For this reason, large quantities of cash are shipped in – often by container load – usually in a Foreign “Hard Currency”, and this cash is used to pay for all of these various services. There are multiple issues related to such activities. The cost of shipping cash is very high. The cost for protection and security of cash stores is high, with extreme and continual risk of armed robbery. The delivery of cash to personnel is risky and requires protection. The carrying of cash by the personnel, volunteers and others presents a risk to them and promotes crime and robbery in the areas where they are present. Such activities carry a very high risk of Money Laundering and/or counterfeiting activities being introduced along the process, and for theft and/or misappropriation of funds, and it promotes a Black Market in Currency Conversions that can damage a Local Currency status and the local economy.
By using ICLM Transactions, International Organizations are able to remit Stored Credit for goods and services, and to their Staff, Volunteers and other entities. They can do ICLM Transactions in both Hard Currency and Local Currency from their various Currency Wallets in the International Organization’s TEL.mobi Account or VSMP, which are received in 1/100th of a Second – with all documentation being automatically and immediately generated for every Transaction. No cash has to be transported or used in-situ. It completely removes the possibility of armed robbery, theft, robbery, Money Laundering, counterfeiting, misappropriation, undermining of the Local Currency / Local Economy through Black Market Currency Conversions, risk to Staff and Volunteers. It also exponentially reduces costs through removal of the cost of cash transportation, cash guarding and security, unfavorable Currency Conversions and extreme reduction of personnel requirements for guards / security / cash administration / back-office payroll activities & personnel, etc. All Transactions can be done via ICLM Transactions and – when the TEL.mobi Group “Stored Credit Refund Machines” (“SCRMs”) are rolled out, cash amounts of up to GBP 300 per day (or the equivalent in other currencies) will also be able to be withdrawn.
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3. Social Security / Benefits Payments Transactions
Vulnerable People who are on Social Security/Benefits Payments face the same challenges as Unbanked People – and sometimes even more challenges. They experience all the same downsides – often being Unbanked and having to pay more for goods and products, and are often unable to access lower-cost online products and services – or any online products at all – due to being Unbanked. Often their Social Security/Benefits Payments are given either in the form of a cheque/instrument that needs to be cashed at a Bank or other entity. This entails their travelling to fetch these instruments/this cash – which travel costs them money and eats into their Social Security/Benefits money. The provision to them of cash or instruments of value also places them at risk of loss, theft or robbery of their Social Security / Benefits money – especially Women and Young Adults. Moreover, the high number of administration personnel required to administer such Legacy Systems for dispensing Social Security/Benefits Payments is extremely costly and inefficient, and because cash is being dealt with, there is the potential for waste, misappropriation and Money Laundering. In some cases, Social Security/Benefits entities have begun providing payments to Recipients on pre-Paid Debit Cards. However, this can actually makes the situation worse, because it exponentially increases the costs to provide Payments of Social Security/Benefits due to the cost of card production and delivery. Cards can also be lost / stolen / cloned, and there are hidden costs for all Transactions (to either the Social Security / Benefits Payments entity, or the Recipient, or both). Also, when Card or ATM systems go down the Recipients are without any Funds. Many merchants providing low- cost goods or services do not accept card payments, so cash has to be drawn at ATMs, which costs money – and the situation is back to the vulnerabilities related to cash. Moreover, subcontracting a Social Security / Benefits out to a Card Company Contractor means that Recipients have no recourse to help if they experience a problem with the card “After Hours”/ over “Weekends”/ during “Holidays”. These Legacy Systems cause enormous unnecessary waste of Funds at/by the entities paying Social Security/Benefits and unnecessary enforced wastage of the small amounts of Social Security/Benefits paid to Recipients. They also bring about multiple circumstances of risk and/or loss and/or theft and or other negative outcomes for the Recipients.
Using ICLM transactions for Social Security/Benefits payments exponentially reduces the costs/administration/personnel required for delivery of Funds to Recipients. It also provides instant/complete/detailed documentation for the Social Security/Benefits entity and the Recipient. It provides the Recipients with Stored Credit on a secure Digital Platform, and enables Recipients to enter the Digital Economy and obtain goods and services at lower cost with ICLM Transactions or funds from SCRMs. It reduces the potential for theft/loss, and enables monitoring of Social Security/Benefits usage. It provides many more advantages over all other current Legacy Systems being utilized. 148
4. Additional ICLM Transaction Situations
Financing of Small Businesses in Developing Countries It is difficult to provide finance to Small Businesses / Micro Businesses in Developing Countries due to many of the people carrying out such business being Unbanked, being in areas where there is no infrastructure and/or many other difficulties. ICLM Transactions enable this to be done immediately, and provide the Recipient person/s or organization/s with all of the advantages of ICLM Transactions and access to SCRMs.
Internationalization of Donations to Charities / Disaster Relief / Similar Causes ICLM Transactions enable Donations to be made directly to Charities, Humanitarian Organizations, Disaster Relief and other similar organizations / situations internationally (instead of this being restricted to being done on a National or Regional basis). It also ensures that donations go directly to such entities, without intermediary costs or delays.
Alternative to Wages Payments in Cash ICLM Transactions enable Companies and/or Organizations to provide wages by either TEL.mobi Top-Up Vouchers or ICLM Transactions. This significantly reduces costs to the Payee/s and Recipient/s, improves administration and records, and provides all of the other advantages that ICLM transactions bring with them (as well as access to SCRMs if and when required).
Alternative “Proof of Funds” Documents Presentation of Members TEL.mobi Group History Documents evidencing Incoming ICLM Transactions can act as an Alternative “Proof of Funds” Document.
Refunds by Companies / Other Entities to Clients Companies / Entities can carry out Refunds to clients via ICLM Transactions for instant refunding, and full, complete and detailed duplicate records instantly provided to the Refunder and the Recipient, that leaves no room for dispute.
Crowdfunding / “Patreon” Payments Companies, Organizations or Individuals that engage in Crowdfunding or “Patreon” Payments can use ICLM Transactions for immediate and cost-effective implementation of their activities.
Third-Party Payments and Private Use ICLM Transactions can be used for Payments of Hotel Bills and/or other Third-Party Payments for other people, as well as for private use in remittances of funds or private Payments in general. All of these save costs, are immediate, are safe & fully documented. 149
H. Example of Alternative ICLM Uses on the TITAN System:
ICLM Transactions are one of many and various uses for the ICLM Service on the TITAN System.
The ICLM Service on the TITAN System represents a Closed-Loop System, functioning on Blockchain principles for both Security and KYC requirements, which is fully customizable for almost any type of audit-required activity; that can be implemented rapidly, effective, cost- effectively and reliably.
As an example the ICLM Service on the TITAN System can be very rapidly customized (using a “Closed and Restricted VSMP” Model) with which to implement Local, Regional and National Election Voting and/or Referendum Voting. It can be implemented at extremely low cost, for a completely reliable and auditable process, which eliminates all possibility of fraud, maximizes participation and turnout, allows for central control and monitoring, preserves total confidentiality, and can be done without any noticeable costs or requirements in terms of premises, equipment, personnel or other logistics, as follows:
Voting in a National Election or Referendum
A Closed and Restricted VSMP is established for the Election / Referendum Entity.
All potential Voters in the country (whether already TEL.mobi Group Members or joining on that Closed and Restricted VSMP) upload their KYC Documents and/or Substitute KYC Documents (thereby proving their identity and eligibility to Vote, without the need for ID Card issue).
Voters Lists are compiled by the personnel of the Closed and Restricted VSMP according to Membership and KYC Documents (Election Officials can nominate where KYC documents can be verified and certified, and – if necessary – arrange lower costs or zero cost to the Voters for KYC Verification by Nominated Attorneys/Notaries/ Commissioners of Oaths).
It is not possible for fraudulent Voting to occur from this stage onward. This is because every ITAN Number of each Member is unique, and every ITAN Number is attached to a specific Member’s Unique Mobile Phone Number and Name, and every Member has uploaded verified and certified KYC Documentation which has been checked to confirm his/her eligibility to Vote (first Fraud-Potential Removal Process).
For the Vote itself, a Page is prepared on the Closed and Restricted VSMP’s site (Desktop and Mobile), which has the relevant Voting Options (i.e. Party Names / Persons’ Names / Referendum Questions) with Tick Boxes next to appropriate names.
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Voters have to tick an appropriate box or boxes per page. This also removes the possibility for Spoiled Votes, because the Page can be set not to proceed (with “Error” and/or “Help” messages shown) if the appropriate number of Tickboxes per section have not been ticked (this removes / reduces “Spoiled Ballots” potential).
When the relevant Tickbox selections have been made, the Member clicks on the “Send” button, and the Member’s selection is sent by Text Message to the Central Repository. This removes the requirement and costs for voting ballots, voting booths / voting machines / voting station personnel / voting premises / voting premises security / postal votes from abroad (because Texts can be sent from abroad) / vehicles for transportation of ballot boxes / security for transportation of ballot boxes nationwide / personnel to count and verify ballots.
The TITAN System will have already been set according to the Election Commission Entity’s specifications – generally along the lines that Members will not be able to send their Text Vote if they have not previously uploaded their KYC and consequently been validated on the Voters List (second Fraud-Potential Removal process), and unless it is sent from their Registered Mobile Number (third Fraud-Potential Removal process).
The TITAN System can also be set so that Members can only send one Text to the relevant stand-alone Voting Number (fourth Fraud-Potential Removal Process).
The TITAN System can also be set so that when the Vote is sent in, attached to it is only the Member’s ITAN Number (and even that can be hidden) – with the Member’s name removed. This allows for Multiparty Verification of results without Compromising of Voter Confidentiality.
In the event of any queries or disputes, a full audit of every aspect of every Member and every Vote is immediately possible. Immediate verification can be done of KYC Documents and the eligibility of the person to vote by using the Voter’s ITAN Number (without the Voter’s name – to preserve Voter Confidentiality). The Text from the Voter’s Mobile Number (with some numbers obscured to preserve Voter Confidentiality) can also be immediately confirmed.
Voters can also be reminded or encouraged to Vote by the sending of a Text or Texts to them through the day. This – combined with the highly increased efficiency and convenience of this process over Standard Processes – will significantly increase Voter Participation.
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Voters can Vote from anywhere, anytime, on the Voting day using just their Mobile Phones, with results in / collated / shown immediately by the System, in real time, with zero potential for error or fraud. There is no requirement for people to queue, or possibility for ballot papers to run out / intimidation / ballot box losing or stuffing / spoiled ballots. There is no requirement for ballot machines / premises / voting booths / Polling Personnel / Security / vehicles / etc. As such, it can be done at a fraction of the cost of standard systems, much more rapidly, much more conveniently for Voters and the Voting / Referendum Commission Entity, and with no chance of post-election / post-referendum challenges.
There are many such Alternative Uses for the ICLM Service on the TITAN System. All that is required is for Persons / Entities to think through how they can utilize the Service and System, and then implement the Alternative Use themselves via a Global VSMP, or request from Webtel.mobi that a “Closed VSMP” and/or a “Closed and Restricted VSMP” be set up for them to do it over.
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I. Summary:
The examples listed in this section are only a few of the methods that the ICLM Service can be utilized by TEL.mobi Group Members, and there are many more applications for the TEL.mobi Suite of Services.
The reason that more examples are not given is that none of these activities or services – even those described in this section – are provided by Webtel.mobi or the TEL.mobi Group. Webtel.mobi and the TEL.mobi Group only provide Telephony Services.
However, Members of the TEL.mobi Group are able to use the full suite of TEL.mobi Group Products and Services when they are Members – provided that they are used for legal purposes and according to the Terms of Use of Webtel.mobi and the TEL.mobi Group.
As such, if Members are able to utilize the various TEL.mobi Group Facilities to improve or benefit their own business or personal activities, and to reduce their costs/expenses, make their businesses or personal activities more secure or efficient, then they are welcome to do so.
As the owners of businesses, members of organizations or private persons know best what their own requirements are, and how the use of the TEL.mobi Suite of Services is best applied to their own situations. They are able to examine the uses thereof – whether it be the ICLM Service or any other – and apply them to their own businesses or private circumstances in the best and most appropriate manner that they choose.
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COMPARISON –
ICLM & TITAN SYSTEM
CAPABILITIES
VERSUS “LEGACY SYSTEM” CAPABILITIES
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COMPARISON – ICLM & TITAN SYSTEM CAPABILITIES VERSUS “LEGACY SYSTEM” CAPABILITIES
A. Legacy Systems Overview:
1. A “Legacy System” refers to a system that is built at a certain period in time. At that period in time, it may be built according to the most modern structures / systems / capabilities that exist, and be “modern”.
2. However, with the passage of time, most man-made products and/or services become old and outdated, and not competitive against more modern man-made products and/or services.
3. Generally, such old and outdated products and/or services are discarded for newer ones – except, sometimes, for those that have many clients and/or are used by many businesses.
4. These products and/or services types find themselves in the position where they know that their product or service is outdated and no longer really fit-for-purpose, but to modernize it properly they will have to rebuild it from scratch. However, to rebuild it from scratch will interfere with their ongoing revenues from existing clients.
5. As such, in order not to lose their existing revenues, they try to modernize parts of their outdated system, in a patchwork of ad-hoc processes. Generally, what keeps their clients static in such below-par / substandard Legacy Systems is purely force of habit, and/or the lack of a viable alternative.
6. However, such patchwork attempts to keep an outdated Legacy System are never successful in the medium to long term (the “Legacy” being the old structure that cannot be changed as it will result in loss of revenue).
7. This is because the point is always reached where – despite all of the ad-hoc add-ons and patchwork fixes – the entire foundation and method of operation is so outdated and unfit for a more modern world, that it will always eventually collapse. It will collapse in the face of the appearance of a product or service that is conformant with modern structures, requirements, facilities and methods of operation, and that provides a better service at a lower cost.
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8. The TEL.mobi Telephony System, TITAN System and ICLM Service (all part of the same platform) is such a new product and service. It effectively, reliably, securely and cost- effectively replaces many existing Legacy Systems, some of which have been in existence for over 50 years (long before even the advent of the Internet and Mobile Telephony), which Legacy Systems are totally unfit-for-purpose in a 21st Century world.
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B. Comparison of the TEL.mobi TITAN System with Legacy Systems:
1. The TITAN System Compared to The “SWIFT” Legacy System
Although the TITAN system is a Telephony Direct-to-Mobile-Bill system (a proprietary TEL.mobi Group in-house System), it has many advantages over – and is a superior product & service to – the International “Society for Worldwide Interbank Financial Telecommunication” or “SWIFT” Financial Services system – a Private Company that functions Worldwide.
https://en.wikipedia.org/wiki/Society_for_Worldwide_Interbank_Financial_Telecommunication
This is because the SWIFT system (an International Clearing House system) is – in terms of modern technological, digital and 21st Century products – a completely outdated and ancient product – having been constructed and built in the 1970s. It is an extraordinarily old Legacy System, which was built long before the advent of the internet, let alone the convergence of 21st Century Online Technologies, Mobile Telephony systems and an interconnected world.
The SWIFT system is therefore totally unable to be altered to conform with modern digital possibilities and standards at all, and completely unable to compete at all with modern 21st century Mobile Telephony-based products and services. Furthermore, because the SWIFT system was built at such a technologically ancient time, it can never be altered to upgrade to the standard of modern technology and telecommunications (known as a “Legacy System” / “Legacy Problems”).
Some of the advantages that the TITAN System enjoys over the SWIFT Legacy System are that it:
Is more robust in Security and Know-Your-Client and Anti-Money-Laundering systems, and
Is much more resistant to accidental transactions to wrong recipients, and
Is much more rapid, and
Is much lower in cost, and
Provides instant transaction notifications to Members by text + email, and
Enables transactions to be carried out globally in 1/100th of a second, and
Provides instant accounting records in Members “History” sections, and
Has a Total Global Footprint – being available to all TEL.mobi Members worldwide, and
Is available to Members and fully-operational 24/7/365, and
Enables Members to do their own Forex exchanges at good rates prior to transactions, and
Is much more widely and easily accessible – from any internet-enabled Smart Phone, pre- Smart Mobile Phone, Computer, Tablet or PED worldwide.
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2. The TITAN System Compared to The “SEPA” Legacy System
Although the TITAN system is a Telephony Direct-to-Mobile-Bill system (a proprietary TEL.mobi Group in-house System), it has many advantages over – and is a superior product and service to – the Regional “Single Euro Payments Area” or “SEPA” Financial Services system – a Privately-Owned System that functions within Western Europe.
https://en.wikipedia.org/wiki/Single_Euro_Payments_Area
This is because the SEPA system (a Regional Clearing House system) is an old Legacy System, which was built in the early 2000s before the convergence of 21st Century Online Technologies and Telephony Systems. Technology and Telephony has advanced to an extreme degree since the development of the SEPA system, and because the system was built at such an early stage, it cannot now be altered to upgrade to the standard of modern technology and telecommunications (known as a “Legacy System” / “Legacy Problems”).
It would have to be completely rebuilt from scratch to conform to modern technology and other requirements – just to compete with Telephony products such as the TITAN System, let alone modern Financial Services possibilities.
The SEPA system is therefore unable to be altered to conform to modern digital possibilities and standards, and unable to compete with modern 21st century Mobile Telephony-based products and services.
Some of the advantages that the TITAN System enjoys over the SEPA Legacy System are that it:
Is more robust in Security and Know-Your-Client and Anti-Money-Laundering systems, and
Is much more resistant to accidental transactions to wrong recipients, and
Is much more rapid, and
Is much lower in cost, and
Provides instant transaction notifications to Members by text + email, and
Enables transactions to be carried out globally in 1/100th of a second, and
Provides instant accounting records in Members “History” sections, and
Has a Total Global Footprint – being available to all TEL.mobi Members worldwide, and
Is available to Members and fully-operational 24/7/365, and
Enables Members to do their own currency exchanges at good rates prior to transactions, and
Is much more widely and easily accessible – from any internet-enabled Smart Phone, pre- Smart Mobile Phone, Computer, Tablet or PED worldwide.
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3. The TITAN System Compared to Other Similar “Legacy Systems”
Although the TITAN system is a Telephony Direct-to-Mobile-Bill system (a proprietary TEL.mobi Group in-house System), it has many advantages over – and is a superior product and service to – multiple other similar Legacy Systems worldwide.
This is because all of these systems (National Clearing House systems) were established and built in the 1960s, 1970s and 1980s, and are all – in terms of modern technological, digital and 21st Century products – completely outdated and ancient products. They are extraordinarily old legacy systems, which were built long before event the advent of the internet, let alone the convergence of 21st Century Online Technologies, Mobile Telephony systems and an interconnected world.
Examples of some of these Privately-Owned “Legacy Systems” are at the urls below:
BACS https://en.wikipedia.org/wiki/BACS
CHAPS https://en.wikipedia.org/wiki/CHAPS
CHIPS https://en.wikipedia.org/wiki/Clearing_House_Interbank_Payments_System
NACHA https://en.wikipedia.org/wiki/NACHA
CHATS https://en.wikipedia.org/wiki/Clearing_House_Automated_Transfer_System
LVTS https://en.wikipedia.org/wiki/Large_Value_Transfer_System
SIX https://en.wikipedia.org/wiki/SIX_Interbank_Clearing
NACH https://en.wikipedia.org/wiki/National_Automated_Clearing_House
BankservAfrica https://en.wikipedia.org/wiki/BankservAfrica
And most others, worldwide.
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C. Illustration of a Legacy System Transaction Flow vs an ICLM Transaction: Flow on the TITAN System, for Exactly the Same Transaction
1. A Transaction via Legacy Systems
Receiving Side’s National Clearing System
** Sending Client 3rd Party Cash Deposit or Sending Entity’s Correspondent’s Central/National Branch
Sending Entity’s Local Branch
SWIFT / SEPA Receiving Entity’s SYSTEM Central/National Branch
Sending Entity’s Central/National Branch
Receiving Entity’s Local Branch
Sending Side’s National Clearing System
Receiving Client
2. Exactly the Same Transaction via the ICLM Service on the TEL.mobi TITAN System
ICLM Service Sending Member Receiving Member on the TEL.mobi TITAN System
** Cash Deposits by 3rd Parties are not possible on the TEL.mobi System
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D. Illustration of the High Hidden Costs within Legacy System Transactions:
Besides Settlement Delays of three to five days, the “Disappearance” of funds for three to five days, Severe AML Vulnerabilities and Multiple other Negative Consequences + Vulnerabilities + Costs that come with the continued use of hopelessly outdated Legacy Systems, one of the major consequences is that of the stratospheric costs levied on users. These costs are imposed in order to feed the long chain of entities and persons that do not, in fact, add any value or provide any real service at all – other than just existing. Very often, these stratospheric costs are hidden in the currency conversions, to present one scenario (i.e. “low transfer fees”) when in reality the fees – hidden in the conversion rates – are extraordinarily and stratospherically high, and they are levied for the provision of no service at all. An example of this situation appears here below:
1 2
If funds are transferred from one Currency Jurisdiction to another, then a mandatory Currency Conversion is carried out by the Legacy System entities along the Transaction Flow. For this example – including Conversion Costs – the following Transaction is completed:
GBP 10 000 000 = € 10 528 000 (Figure 1)
A rate of exchange is provided, but with no real data as to what is being charged. However, if one does an immediate reverse transaction, the stratospheric scale of the hidden costs can be seen.
For example, if GBP 10 000 000 = € 10 528 000, then the reverse should be similar. In other words, approximately € 10 528 000 = GBP 10 000 000 or close to it.
However, if one does exactly the same EUR to GBP Conversion, immediately, the following occurs: € 10 528 000 = GBP 9 021 070 (Figure 2)
Suddenly – and for no reason – GBP 978 930 (almost GBP 1 000 000) has just vanished!
This is an example of the absolutely astronomic hidden costs – levied for no reason or purpose or service at all other than just existing – that Transactions via Legacy Systems carry with them. 161
E. How “Legacy Attitudes” Retard/Stop Modernization of Legacy Systems:
The Legacy Systems illustrated in the preceding examples are Ancient and unfit-for-purpose by any modern measurement. They are so outdated that although they are in the Financial Services Sector, they have now been overtaken and superseded by products and services in the Telephony Sector. The reason for this is that they have remained Static, and not modernized with the times.
The First Causal Factor of this situation is due to the impossibility of upgrading Legacy Systems without the requirement to fully rebuild them. This clashes with their resistance to rebuilding – because to do so will require temporary closing, and thereafter moving of clients onto the rebuilt platform – and Legacy System companies are reluctant to do that in case they lose revenues.
The Second Causal Factor of this situation is the existence of “Legacy Attitudes”, which almost always exist and prevail among the Owners and Management of Legacy System entities.
“Legacy Attitudes” are attitudes that arise when the persons involved with a System that was once new, and was once a Unique, First-Mover or Indispensible System when it was first made, assume that it will retain these characteristics forever. They therefore take the status quo – and their clients – for granted, assuming that nothing will ever be able to replace them, and there is therefore no choice for anyone but to keep following the same process in the same way with the same standards, forever. However, nothing lasts forever.
The Legacy Attitudes prevalent in the Financial Services Sector that have allowed the situation to arise where their Systems and Products are no longer fit-for-purpose in the modern 21st Century World – and are eclipsed and rendered redundant even by Telephony Sector Systems and Products – are not unique to the Financial Services Sector. It is just the latest Sector to experience the consequences of failure to move with the times due to Legacy Attitudes.
To illustrate how Legacy Attitudes permeate and prevail in various Business, Commercial and Other Sectors (and the uniformly negative consequences that ensue when they take root), please see overleaf examples of some historical Legacy Attitudes.
From these examples, the way that Legacy Attitudes cause people/entities to refuse to modernize with the times and rather cling to the past – as well as the inevitability that these processes and systems will change regardless of these Legacy Attitudes – can be clearly seen:
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"The Americans have need of the telephone, but we do not. We have plenty of messenger boys." Sir William Preece, chief engineer of the British Post Office, dismissing the viability of telephones
"We do not want now and we shall never want the human voice with our films." D.W. Griffiths, famous Movie Director, dismissing the replacement of silent movies by talking movies
"The horse is here to stay but the automobile is only a novelty – a fad.” President of the Michigan Savings Bank, dismissing the replacement of horses by motor vehicles
"Airplanes are interesting toys but of no military value." Marshal Ferdinand Foch, Professor of Strategy, French Military College, dismissing the viability of aircraft
The situations as sketched above are the same as the situation that the Legacy Systems described previously in this Section find themselves in with regard to the TEL.mobi Group’s ICLM Service and TITAN System.
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F. Susceptibility of Legacy Systems to Money Laundering:
There are thousands of Banks and Financial Institutions internationally. Each of them has from Hundreds to Thousands of Branches, Sub-Branches and/or places from where transactions can be initiated. The total of all of these is in the millions – and that is just the Branches and Sub-Branches, and does not include the hundreds of Accounts held by people at each Branch. To count these one will reach a number of individual Accounts in the Billions.
The way that the Legacy Financial Services System is set up, any one of these Billions of Account Holders can carry out a Transaction to any one of the other Billions of Account holders – for a Transaction Variables number that is in the number range of Billions X Billions. Moreover, these Billions X Billions of Transaction Variables originate or flow through:
1. 245 different countries and territories – all with differing National standards, rules, laws and systems, none of which are uniformly conformant with those of other countries’.
2. Cumulatively thousands of different sets of laws and/or regulations – none of which is uniformly the same as those in other countries, and which are differently enforced or unenforced.
3. Through millions of Branches and Sub-Branches, which have different standards of employment, training, competence, security and oversight.
4. Through tens-of-millions of staff at these Branches and Sub-Branches, all of whom have different standards and levels of competence in training, security, vetting, etc.
5. Originating from Billions of different Account-holders – which will include multiple criminal enterprises and their enablers.
To adequately implement a system that can identify layering and other forms of Money Laundering from an uncoordinated network that comprises billions of different Accounts, overseen by tens-of- millions of different people, from millions of Branches and Sub-Branches, functioning according to thousands of different processes / structures / standards / oversight, in hundreds of countries, is simply not possible, and it never will be.
In comparison, the TEL.mobi ICLM Service over the TITAN System functions:
On one platform.
With one set of rules and standards.
With oversight (and automated detection) from the system.
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And additional oversight from only one set of people working according to one set of standards.
An early-warning from a global set of local people in every country all working on the same system.
With full oversight of all transactions in-toto and all participants in-toto, from inception to end.
And zero possibility of layering.
And is a much safer and more secure system.
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G. Comparison – Legacy System Transaction Flow vs an ICLM Transaction Flow on the TITAN System:
1. Exclusion of 2.5 Billion Unbanked versus Inclusion of All People Worldwide
Legacy Financial Services Systems automatically and irrevocable exclude the 30% of the world’s population (2.5 Billion people) who are Unbanked from participation in Transaction Flows over their Systems.
The Modern Telephony ICLM Service over the TITAN System enables everyone who has a Mobile Phone to participate in Transaction Flows over its System.
2. Only Possible from a Physical Branch versus Possible from Anywhere
Legacy Financial Services Systems can only be accessed by going to a physical branch of the entity in a village, town or city (less than 10% of banked people worldwide have access to – or use – internet banking).
The Modern Telephony ICLM Service over the TITAN System is able to be accessed from literally anywhere – be it a rural paddy field or an office in Manhattan – by anyone who has a Mobile Phone; including the pre-Smart Phone “Feature Phones” and “Basic Mobile Phones” (that still make up 60% of Mobile Phones in circulation).
3. Only Possible in Office Hours and Weekdays versus Possible Anytime 24/7/365
Legacy Financial Services Systems can only be used and only function during “Office Hours” and “Weekdays” – and cannot be used and do not function “After Hours”, on “Weekends” and during “Holidays”. Besides the fact that “Weekend” days differ according to Religion, “After Hours” differs according to Geographic Location and “Holidays” differ according to Country (so it is not a globally valid model), this means that for vast amounts of time, people have no access to the service.
The Modern Telephony ICLM Service over the TITAN System is fully available, fully operational and fully functional 24 hours per day, seven days per week, 365 days of the year.
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4. Up to 11 Separate Entities involved versus All on One Closed-Loop Platform
Legacy Financial Services Systems require up to (and sometimes more than) Eleven Separate Entities to carry out a Transaction Flow from beginning to end. This entails large numbers of different persons and different entities being involved with the Transaction Flow. Moreover, these Systems also allow for the introduction of cash from parties who are often not able to be identified. They are therefore de-facto Open and Vulnerable Systems.
The Modern Telephony ICLM Service over the TITAN System is a Unitary and Centrally- Controlled Closed-Loop Platform. It is the only Entity involved in the entire (Direct) Transaction Flow. No cash is allowed into the system, and every single participant is identified and has multiple KYC and AML procedures applied on him/her. It is a Single Closed and Closed-Loop System, which is not a Vulnerable System.
5. Multiple and Variable Mixed Security Systems vs One Tight Security System
Because of the large number of different and disparate entities that are required by Legacy Financial Services Systems to carry out a Transaction Flow from beginning to end, there are extremely large variables in their Administration / Vetting / Appointment / Oversight / and other standards and norms. This in turn results in highly varying standards of Security along the long Transaction Flow, and Oversight is impossible along the entire Transaction Flow.
The Modern Telephony ICLM Service over the TITAN System is a Unitary and Centrally- Controlled Closed-Loop Platform, with only one set of Administration / Vetting / Appointment / Oversight and other standards and norms. This results in one unitary and high standard of Security and Oversight.
6. Multiple People, Entities & Systems Required vs One P2P Automated System
Legacy Financial Services Systems require a large number of separate entities to complete their Transaction Flows.
The Transaction Flows on the Modern Telephony ICLM Service over the TITAN System require no other entities. The entire process takes place on its own platform, and it is a 100% Pure Peer to Peer Flow. It is the only Pure Peer to Peer Transaction Flow of this nature on or by any entity in the world.
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7. Severe Risk of Layering versus Zero Risk of Layering
One of the greatest facilitators of Money Laundering is the process of “Layering”. This requires establishing a Multi-Transaction flow of money to be laundered, with multiple different parties in different locations involved, to hide the origin and path of Funds. Because of the number of different and disparate entities and people that are required by Legacy Financial Services Systems to carry out a Transaction Flow from beginning to end – and the fact that cash can enter the Transaction Flow – the potential for “Layering” to occur is high.
Transaction Flows using the Modern Telephony ICLM Service over the TITAN System are carried out only over a Unitary and Centrally-Controlled Closed-Loop Platform, restricted to KYC’d Members, with every single phase of every single (direct) Transaction Flow instantly and permanently visible and recorded by the same system and the same persons. “Layering” is therefore not possible.
8. Identified Activities Impossible versus Unidentified Activities Impossible
Because Legacy Financial Services Systems require multiple different and disparate entities’ and peoples’ participation to function, it is not possible to rapidly (or sometimes ever) identify which entity or person carried out specific activities. This is exacerbated due to cash being allowed to be deposited by third parties in such Transaction Flows.
The Modern Telephony ICLM Service over the TITAN System is a Unitary and Centrally- Controlled Closed-Loop Platform, with only KYC’d Members able to participate in it, and with every step of every Transaction Flow permanently visible. Unidentified Activities are therefore impossible.
9. Very Vulnerable to Laundering versus Virtually Invulnerable to Laundering
Because of the requirement for the participation of multiple different and disparate entities and persons, the ability to introduce cash into the Transaction Flows, and the potential for Layering to occur, Legacy Financial Services Systems are very vulnerable to Money Laundering activities.
Because the Modern Telephony ICLM Service over the TITAN System is a Unitary and Centrally-Controlled Closed-Loop Platform, it is virtually Invulnerable to Money Laundering activities. Only KYC’d Members able to participate in it, with every step of every Transaction Flow permanently visible, and additional Full and Verified and Certified KYC Documentation required for any person wishing to Refund Stored Credit.
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10. Funds “Disappear” for 3 to 5 Days versus Stored Credit Always Visible
With Legacy Financial Services Systems’ Transaction Flows, the Funds in the Flow effectively “disappear” for three to five days (or sometimes longer). During this period, they are not in the Account of the Sender, not in the Account of the Receiver, and no person in the long chain of Legacy Financial Services Systems Transaction Flows can provide a coherent or authoritative response as to where the funds are or why they are “disappeared”.
With the Modern Telephony ICLM Service over the TITAN System, all Stored Credit is always visible to its owner, and an ICLM Transaction from one Member is instant – so their Stored Credit is permanently visible to either the Sender or Receiver, and is never “disappeared”.
11. Transaction Time of 3 to 5 Days versus Transaction time of 1/100th of a Second
With Legacy Financial Services Systems Transaction Flows, the Transaction Time for Funds to leave the Sender’s account and arrive in the Recipient’s account is three to five days – or longer. If the Transaction Time is intersected by a weekend, it can be a Transaction Time of five to seven days.
With the Modern Telephony ICLM Service over the TITAN System, the Transaction time for Stored Credit to leave the Sender’s Account and arrive in the Recipient’s Account is 1/100th of a Second, 24/7/365.
12. High Transaction and Transfer Fees vs No Transaction Fees & Low Transfer Fees
Because of the large number of different entities that are required by Legacy Financial Services Systems to carry out a Transaction Flow, there are high Transaction Fees and Transfer Fees applied in and to Legacy Financial Services Systems Transaction Flow. Every one of these entities takes money from the Sender’s and/or Receiver’s Funds just for passing them on to one another. Sometimes these fees/charges are shown, but often they are hidden in the Forex Conversion that Legacy Financial Services Systems impose.
The Modern Telephony ICLM Service over the TITAN System does not apply or charge any Transaction Fees at all. It is free to join and use the TEL.mobi System, and the ICLM Transactions Service is also provided free. ICLM Transactions are charged very low Transfer Fees, ranging from 0.25% to 1%.
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13. Very Unfavorable Forex Rates versus Very Favorable Forex Rates
Because of the large number of different entities that are required by Legacy Financial Services Systems to carry out a Transaction Flow – and because every one of these entities takes money from the Sender’s and/or Receiver’s Funds just for passing them on to one another – very unfavorable Forex (i.e. Currency Conversion) Rates are applied. These are applied Mandatorily by the Legacy Financial Services Systems, and because all entities in their Transaction Flow chain profit from it and divide the profits, they all provide the same or very similar unfavorable rates – with no explanation as to why these rates are so high – to present an impenetrable barrier to better rates.
The Modern Telephony ICLM Service over the TITAN System provides access to its Members directly to Live Market Rates, which are extremely favorable in comparison to Legacy Financial Services Systems’ Rates, with only a very small mark-up for the TEL.mobi Group. Moreover, conversion from one currency to another is not Mandatory with an ICLM Transaction, and the Forex Conversion is placed totally in the hands of the Member, and is not retained by the TEL.mobi Group.
14. High Administration Fees versus No Administration Fees
Because of the large number of different entities that are required by Legacy Financial Services Systems to carry out a Transaction Flow, there are high Administration Fees applied in and to Legacy Financial Services Systems Transaction Flows. Every one of these entities takes money from the Sender’s and/or Receiver’s Funds just for passing them on to one another. Sometimes these are shown but often they are hidden in the Forex Conversions that Legacy Financial Services Systems impose.
The Modern Telephony ICLM Service over the TITAN System does not apply or charge any Administration Fees at all. It is free to join and use the TEL.mobi System, and the Detailed Administration provided by the System is also free.
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15. No Process Transparency versus Complete Process Transparency
With Legacy Financial Services Systems Transaction Flows, there is absolutely no transparency of process to or for the Sender or Receiver. The closest that they come to the Transaction Flow is if there is a Branch of their entity or a Call Centre. None of the personnel at any of those entities can provide them with any information as to where their Funds are at any time. They also cannot provide information as to who is in possession of the Funds while they are “disappeared”, or who is earning interest on those Funds while they are “disappeared”. They also cannot provide any specific information what the costs are for, who is levying the costs and what the costs are per entity. They cannot provide information on what entities are involved with the Transaction Flow, or any other information of any nature. There is a zero return of any meaningful information, and the entire Transaction Flow is obscured and hidden, with zero Transparency.
With the Modern Telephony ICLM Service over the TITAN System, all Members know exactly what is occurring at every moment, have their Transactions done in 1/100th of a Second, receive instant detailed Administration and Reports on all and any Transactions. As such, there is, at all times, 100% Transparency.
16. Client Totally Dependent on 3rd Parties versus Member Totally in Control
With Legacy Financial Services Systems Transaction Flows, there is a total loss of control by a client of his/her own Funds and any action associated with the Funds. The clients are totally dependent on multiple third party processes, multiple different and disparate people that they do not know and multiple entities that they know nothing about. They similarly do not know what any of these third parties that they are totally dependent on are, or where they are, or what they are actually doing, or why they are doing it, or how much money they are charging for doing whatever it is that they are doing.
With the Modern Telephony ICLM Service over the TITAN System, all Members are permanently and totally in control of their own Stored Credit, and all Transaction Flows, all the time. There are no other entities involved – only Pure Peer to Peer Transactions under the total control of the Sender. All aspects of who is involved, what is being done, why and how it is being done is not only known, it is under the control of the Member himself / herself.
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17. Disparate Admin & Reporting Standards vs One Admin & Reporting Standard
Because of the large number of different and disparate entities that are required by Legacy Financial Services Systems to carry out a Transaction Flow – and their differing Administrative and Reporting Systems – it is often not possible for a Sender or Recipient to obtain detailed or clear Administrative Documents. It is also often not possible to obtain detailed Transaction Reporting from entities involved in these processes during or after a Transaction. This is especially if there have been (or are) problems with the Transaction.
The Modern Telephony ICLM Service over the TITAN System providers all Members with instant and highly-detailed Administrative Documents and Reporting, containing detailed information on all aspects of their Transaction, in their History Facility on their Account, by Email and by Text Message, instantly, and to a one (high) standard.
18. Summary
Although there are many and various other advantages that the TEL.mobi Group’s ICLM Service over its proprietary TITAN System has over Legacy Financial Services Systems, these preceding ones are some of the significant ones.
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H. Summary of the Comparison of the ICLM Service to Legacy Systems:
For all of the preceding examples comparing these Legacy Financial Services Systems with the TEL.mobi Group’s Modern Telephony ICLM Service over the TITAN System; it can be vividly and clearly seen that people utilizing Legacy Financial Services Systems find themselves in situations where:
1. Third Party Entities and people are in control of the clients’ actions,
2. Which Third Party Entities and people do not provide any actual value-added service,
3. And provide very unfavorable currency conversion rates,
4. And take a very long time to do that which could be done instantly,
5. And “disappear” clients’ money for three to five days at a time,
6. And provide little to no transparency of process,
7. But take extremely significant amounts of money in fees – effectively just for existing,
8. And at the same time are highly susceptible to Money Laundering activities.
In other words, they are not so much service providers as they are “Gatekeepers” – who take vast amounts of clients’ money not for providing a service, but rather just for existing.
Moreover, they maintain their position simply by forcing clients to use their outdated and unfit- for-purpose Legacy Systems; which Legacy Systems do not and cannot improve or change or keep up with the modernization of systems.
They therefore just take vast amounts of other people’s money and waste vast amounts of other people’s time – just for existing as middlemen.
As all of these entities are Private Companies – or ultimately owned by Private Companies – there is a profit-motive for their wanting to maintain and retain the status quo; hence the “Legacy Attitude” that permeates them. This is unlikely to be voluntarily altered until a product or service that renders them redundant comes into being – just as the automobile rendered the horse redundant.
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Utilizing the possibilities that the advancement of mobile telephony systems has brought with it, the TEL.mobi Group’s ICLM Service on its proprietary TITAN System returns control of people’s own affairs to them.
Although the TEL.mobi Group is a Telephony Company and provides only Telephony Services, its Members are able to utilize the Facilities and Services on its platform for any legal service which can improve their business or personal efficiency, productivity, cost-saving or revenue-generation.
The ICLM Service on the TEL.mobi TITAN System enables people to obtain better services and better results than Legacy Financial Services Systems, in a manner whereby they are in control of their own affairs, make their own decisions, keep much more of their own money, save their time and are kept secure and informed at all times, 24/7/365.
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SOME OF THE MULTIPLE
COMMERCIAL AND FINANCIAL
ADVANTAGES
OF
THE ICLM SERVICE
FOR
MEMBERS AND MERCHANTS
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SOME OF THE MULTIPLE COMMERCIAL AND FINANCIAL ADVANTAGES OF THE ICLM SERVICE FOR MEMBERS AND MERCHANTS
A. Advantages for Retail, Wholesale, Trade, eCommerce and other Merchants:
The use of the ICLM System carries with it significant advantages for every type of Retail, Wholesale, Trade, eCommerce and other Business and/or Merchant. A summary of some of the immediate advantages for all of these entities is as follows:
1. Immediate Setup of Full System at No Cost with No Integration Requirement
The entire integrated system to send or receive ICLM Transactions from any other TEL.mobi Group Member is created as soon as a person Joins as a Member and verifies his/her Registered Mobile Number. It is an instant process, at no cost other than the cost of one low- cost Text Message to verify the Registered Mobile Number. There is no requirement for any integration or integration cost in order to acquire and use the system.
2. Immediate Complete Functionality at No Cost with No Equipment Requirement
As soon as a Member has joined, the entire ICLM Service / TITAN System – and all other Facilities within the TEL.mobi Group System – are fully functional for the Member (Merchant). The Member (Merchant) can instantly make or receive ICLM Transactions to and from any other TEL.mobi Group Member. There is no requirement for buying, renting or leasing any equipment or terminals to be able to use the system fully, and there are no monthly System Rental costs or Monthly System Usage costs at all.
3. Extremely Low Transaction Costs
The ICLM Transactions are provided at extremely low cost on a Sliding Scale – from 1% of the ICLM Transaction Amount at the highest end of the Sliding Scale, down to 0.25% of the ICLM Transaction Amount at the lowest end of the Sliding Scale. Moreover, details of all costs are clearly available prior to any ICLM Transaction in the “Rates” section on TEL.mobi sites. The receiving Member (Merchant) is able to decide whether the ICLM Transaction Costs are for the account of the Sender or the Recipient.
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4. Immediate Receipt of All Funds
An ICLM Transaction takes 1/100th of a second to complete between Members, and, once completed, the full amount of funds (Stored Credit) is available in the receiving Member’s (Merchant’s) TEL.mobi Account immediately – with no waiting period at all.
5. No possibility of chargebacks
Due to the TEL.mobi System being a Closed-Loop Members-Only service, with all Stored Credit coming into the system as “cleared funds” from Banks, and Five-Factor Multi-Factor Authentication security and a TAN Verification Number by Text prior to a Member being able to complete an ICLM Transaction, there is no possibility for Chargebacks, because:
With the 6 steps that each require confirmation before Sending ICLM Transactions, and
The Five-Factor Multi-Factor-Authentication required to Send an ICLM Transaction, and
The requirement to receive a unique Transaction Verification number on the Senders own Mobile Phone and input it into his/her TEL.mobi Account prior to the ICLM Transaction being Sent
There is no possibility for a Member to do so accidentally, and unless someone has:
Successfully stolen all of the Sender’s TEL.mobi Credentials, and
Has possession of the Sender’s own Mobile Phone, and
Has possession of the Sender’s own unlocking code for the Sender’s Mobile Phone, and
The Sending Member has not Blocked his/her own TEL.mobi Account.
Because the possibility of:
All of these situations occurring simultaneously, and
The Sender having had his/her Username, Password, ITAN Number stolen, and
That the Sender’s Mobile Phone would also have to be simultaneously stolen to receive the Verification Number of the ICLM Transaction, and
That the Sender’s unique own unlock code for his/her Mobile Phone would also have to be simultaneously stolen so as to be able to view the Verification Number for the ICLM Transaction by text,
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And that the Member’s Account would still, under all of these virtually impossible circumstances remain unblocked; despite Members being warned to block their TEL.mobi Accounts immediately if they suspect they have let their credentials be stolen, and Members being able to block their accounts immediately from any Mobile Phone or internet-enabled PED,
Is close to zero, once the cleared funds (Stored Credit) have been sent in an ICLM Transaction, they are definitively sent, and cannot be refunded without the consent of the Recipient.
6. Immediate Refund Transfer Request Possibility
All Members (Merchants) may initiate immediate Refund Transfer Requests (according to the Refund Rules and Limits) for the Stored Credit in their TEL.mobi Accounts according to their business requirements. As long as the Refund Rules and Limits (which are structured to ensure efficient Refunding to the Bank Account of the Member, or Merchant, while at the same time adhering to Anti-Money Laundering considerations) are adhered to, Refund Requests may be initiated 24/7/365. The actual Refund Transfers to the Bank Accounts of Members (Merchants) are implemented 24/5/365 (Mondays to Fridays).
7. Use of Onward ICLMs instead of Refund Transfers
The TEL.mobi Group’s VSMP and Member numbers are continuously increasing, and it is becoming easier to simply implement ICLM Transactions between Members (Merchants) for stock and services payments, as an alternative / add-on to carrying out Refund Transfers. This is increasing the convenience factor of ICLM Transactions between Members.
8. Immediate selection of ICLM Currency (no more “hidden costs”/“double costs”)
Members (Merchants) displaying that they accept ICLM Transactions can specify the currency in which they accept the Transactions. Because all TEL.mobi Group Members have the ability to do Forex conversions immediately between their Currency Wallets, this means that even for ICLM Transactions originating from Members whose Primary Currencies may be different, they can convert them to the currency of the Member (Merchant), and do the Transaction in his/her currency. As such, there are no more losses incurred by Members (Merchants) due to the hidden costs and/or effective double billing applied by standard providers through unfavorable Forex conversions.
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9. Immediate Automatic Confirmation of Transaction In Wallet, History and Email
An ICLM Transaction is completed in 1/100th of a second. Moreover, the incoming Stored Credit is immediately able to be seen in the TEL.mobi Wallet of the Receiving Member (Merchant) – and is also reflected as having been debited from the Sender’s TEL.mobi Account. Added to this, full details and confirmation of every ICLM Transaction are immediately emailed to both the ICLM Sender and the ICLM Recipient, and also inserted into the Sender’s and Recipient’s “History” facility on their TEL.mobi Accounts. There is therefore instant, complete, verifiable, unambiguous and clear confirmation and evidence of every single unique ICLM Transaction immediately and clearly available in both the Receiver’s and Sender’s TEL.mobi Accounts, in multiple locations.
10. Immediate Additional Confirmation of Transaction by Text Message (Optional)
Other than the immediate and automatic notifications and records of an ICLM Transaction to both the Receiver and Sender in their Wallets, History Facilities and Email, the Receiver may also request the Sender to additionally send a confirmation by immediate Text Message. If this option is applied, a Text Message confirming the successful conclusion of the ICLM Transaction – including the unique Transaction Number, Reference, Amount, Sender and Recipient – is sent to both the Receiver’s and the Sender’s Mobile Phone. This provides an additional instant, complete, verifiable, unambiguous and clear confirmation and evidence of every single unique ICLM Transaction immediately to both the Receiver’s and Sender’s Mobile Phone in a Text Message.
11. Immediate and Automatic Completion of Accounting Documentation
Simultaneously with the completion of an ICLM Transaction, the Transaction is recorded in the “History” facility of both the Sender and Receiver of the ICLM Transaction. The recording is both in a Summary Format, and – when the Summary Format is clicked on – a Detailed Format. Members (Merchants) can do a one-click emailing of the Detailed Format of all Transactions to their registered email address directly from the system. The Detailed Format contains all information on every ICLM Transaction, including the Transaction Sender, Reference Number, Reference, Date, Time, Amount Transferred, Amount Received, Currency Conversion rate (if applicable), and Status. It is in a suitable format to be directly included into accounting systems or records of Members (Merchants).
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12. Immediate Compatibility with all Mobile Phones (and internet-enabled PEDs)
The ICLM / TITAN System is immediately compatible with all Mobile Phones, and internet- enabled Personal Electronic Devices (Tablets / Laptops / Computers / Other). Members (Merchants) can begin to fully utilize all facilities of the ICLM Service and the entire TEL.mobi Group System immediately upon Joining just by having, and with, a Mobile Phone.
13. Immediate Exponential Market Increase to anyone with a Mobile Phone Worldwide
Becoming a Member (Merchant) on the TEL.mobi Group System immediately opens up markets to any person worldwide who has a Mobile Phone, in any and all countries worldwide, and regardless of the home currency of the Member. This exponentially increases potential markets to and for Members (Merchants) by factors, and also provides Members (Merchants) with access to markets that would otherwise be impossible for them to enter.
14. No Third Party Persons or Entities involved – Pure Peer-to-Peer between Members
Any and every person on, or using, the TEL.mobi Group Facilities – including ICLM Transactions – is a vetted TEL.mobi Group Member, functioning within the Closed-Loop system. There is no possibility for a person or entity external to the Closed-Loop to access or use the TEL.mobi Group systems. As such, all ICLM Transactions are from internal vetted Members, with available Stored Credit. Moreover, all ICLM Transactions are Pure Peer-to-Peer Transactions, and they are the only true immediate and direct Peer-to-Peer Transactions – without any intermediary – of any entity or system worldwide. The absence of a “middleman” entity in these Pure and Direct Peer-to-Peer Transactions ensure the lowest possible cost, and ensures that the decision-making and control empowerment rests with the Member, not with a middleman entity and/or broker entity.
15. Total and Seamless Inter-VSMP and Member interoperability and interaction
All TEL.mobi Group Members of all VSMPs – and all VSMPs – have seamless and total interoperability and interaction possibilities between one another’s TEL.mobi accounts. This is for all TEL.mobi Group Facilities, including ICLM Transactions, in an all-encompassing Closed- Loop System with a Global Footprint. As such, although it is a Closed-Loop Members-Only System, it nevertheless simultaneously provides a Borderless Global Market for and to Members (Merchants).
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16. Security of Account and Security of Funds
The Five-Factor Multi-Factor Authentication, six confirmations and additional Verification Number required to implement an ICLM Transaction provides security for all Members, be they Recipients (Merchants) or Senders (Clients of the Merchant). This is because Senders cannot realistically dispute their decision to make the ICLM Transaction, and Recipients are secure in the knowledge that if the ICLM Transaction has been successfully carried out, the funds (Stored Credit) are safely in their TEL.mobi Accounts. Furthermore, the same security makes it almost impossible for the Member’s (Merchant’s) TEL.mobi Account to be accessed and funds withdrawn by any other party. The only theoretical circumstance in which this could occur would be if the Member (Merchant) provides a third party with his/her Username, Password, ITAN Number, Mobile Phone, and Mobile Phone password/code – and does not block his/her account thereafter. This is not a credibly possible situation unless it is done under duress. However, even if that were to happen, there is still a complete record of all and any transactions on the account. Moreover, as Stored Credit can only be Refunded to a Bank Account of a Member who has provided full, verified and certified KYC Documents, there is always a record of exactly where – and to who, by individual and Bank Account – the funds (Stored Credit) have gone. Finally, Refund Requests are Requested by Members, but are implemented by Webtel.mobi. Therefore, even in the absolutely extraordinary circumstances where the unlikely events described above have occurred, it is also possible for Webtel.mobi to not implement a Refund Transfer to a Bank even if it is requested, if a Member contacts Webtel.mobi with a Request for Assistance, or if an unusual Transaction is requested. This system is more secure than even that of most financial institutions internationally.
17. Currency Conversions between Wallets 24/5/365 from Anywhere
Currency Conversions between Members’ Currency Wallets are able to be done 24/5/365 (from 00:01 UTC on Mondays until 21:59 UTC on Fridays). This is because TEL.mobi Group Members are provided with Live Rates that are close to Interbank / Spot rates, and so this facility is only available when the global Currency Exchange markets are open. This means that Currency Conversions can be done easily by Members who are clients when doing an ICLM Transaction to a Member that is a Merchant, thereby facilitating easy and favorable Transactions, and driving up potential sales. It also means that Members who are Merchants can use this Currency Conversion facility when paying for supplies / paying suppliers in other currencies, which ensures retention of more value by the Member due to him/her receiving much more favorable conversion rates. These Currency Conversions can also be done immediately and from anywhere – whether from a highly sophisticated Smart Phone / Tablet / Computer in a First-World Capital City, to a Basic Mobile Phone in a Rural Area in the Developing World.
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18. ICLM Transactions can be Implemented 24/7/365 from Anywhere to Anywhere
The TEL.mobi System is permanently active. This allows ICLM Transactions to be instantly and reliably implemented 24/7/365. Regardless of the time of day, day of the week, or location in the world of a Sender or Receiver or the Phone or PED used, the ICLM Transaction will be completed in 1/100th of a second, with all of its advantages, security, reliability, convenience and cost-effectivity for both the Sender and the Receiver.
19. ICLM Transactions are a Substitute for Card Transactions
ICLM Transactions are a far more effective, cost effective and safer substitute for Card Transactions. Some of the advantages that ICLM Transaction offer over Card Transactions are as follow:
No Card Charges of 2% to 3%.
No Retention of a Percentage of Funds (Stored Credit) for margin reasons.
No waiting time for Settlement of Funds to the Member (Merchant).
All funds (Stored Credit) Received Instantly by the Member (Merchant).
No Card Terminals and/or Equipment need to be Bought or Leased.
No Monthly Card Terminal / Card Services Fees.
No Unfavorable Forex Exchange Rates on Foreign Card Payments.
No Possibility for “Card Declined” Events due to Faulty Terminals or Faulty Cards.
No Possibility of Chargebacks.
No Possibility of Stolen Cards being used.
Instant Full Setup with all System Requirements already built-in.
Full Service Management and Operation with just a Mobile Phone.
Immediate Transaction Success Notification in Wallet and by Text and Email and in History.
Unique Transaction Code for Immediate Confirmation by Sender and Receiver.
Immediate Accounting Documentation in History.
Entire Transaction and Settlement In Total done in 1/100th of a Second.
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20. ICLM Transactions are a Safer Substitute for Cash Transactions
ICLM Transactions are a Safer Substitute for cash transactions, as the receipt of Stored Credit in an ICLM Transaction provides a Member (Merchant) with the equivalent value, in as instant a format as cash, but in a much more reliable, less risky, more secure and Anti-Money Laundered manner. It also completely removes the possibility for counterfeit and/or Money- Laundering cash to be inadvertently accepted.
21. Summary
There are, in fact multiple other advantages. They are too numerous to list, because for each of the very many separate business types and sectors and/or private uses there are specific advantages, and the list would therefore run into the hundreds of points. However, the advantages listed here represent top-level advantages that cut across all business types and sectors.
More Sectors and Advantages are not listed because none of these are, in fact, Services provided by the TEL.mobi Group. The TEL.mobi Group only provides Telephony Services. It is just the TEL.mobi Group Platform that enables these add-on advantageous uses by its Members. As they know their businesses and requirements best, it is up to them to decide if, how and why the Services on the TEL.mobi Group’s Platform – like the ICLM Service – can be used by or integrated into their own business and/or other activity.
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B. Notification and Display of ICLM / TITAN Transactions Acceptance:
1. Merchants, Websites, eCommerce entities and other entities can inform their clients / users that they can accept instant ICLM Transactions, by simply displaying their ITAN Number and Registered Mobile Number to potential clients on their websites or in/on other point-of-sale documents and/or positions.
2. All that is necessary for any TEL.mobi Group Member to instantly accept ICLM Transactions is to join as a Member, and then display notification that they accept ICLM / TITAN Transactions (Both names refer to the same Service).
3. It is strongly recommended that when displaying the ITAN Number and Registered Mobile Number that a second Mobile Number is obtained, verified and saved into the displayer’s TEL.mobi Account, and set as the Primary Registered Mobile Number for display purposes. This is because publicly displayed mobile numbers are not conducive to privacy.
4. Examples of how to display the capacity to accept ICLM Transactions are as appear below:
Detailed ICLM Acceptance Notification
We Accept TEL.mobi ICLM Direct-to-Mobile-Billing
ITAN: WM01020304050607080901
Mobile: +00 01010 010 010
Description: Whatever is relevant
Transfer Fee: For your Account
Transfer Currency: GBP
Confirmation by Text: Yes
or
We Accept TEL.mobi ICLMs
ITAN: WM01020304050607080901
Mobile: +00 01010 010 010
Description: Whatever is relevant
Transfer Fee: For your Account
Transfer Currency: GBP
Confirmation by Text: Yes
Displayer decides on Description, Transfer Fee “For our Account” or “For your Account”, Currency and Confirmation by Text or not 184
THE TEL.MOBI GROUP’S
STREAMLINED AND SECURE
REFUND TRANSFER
RULES AND LIMITS
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THE TEL.MOBI GROUP’S STREAMLINED AND SECURE REFUND TRANSFER RULES AND LIMITS
As with the AML and KYC Procedures, and the entire ICLM system, IT and Mobile Telephony has advanced to that stage where methods that are far more effective can be applied to cater for both Member convenience and orderly and effective control (including AML control) than current Legacy Systems.
As Webtel.mobi – and through it the TEL.mobi Group – is a Telephony Company in the Telecommunications Sector and not a Financial Services Company in the Financial Services Sector, it is nevertheless as proactive in its application of Anti Money Laundering activities as it is in its application of Member services.
Moreover, the advances in Mobile Telephony, internet and technology products and systems currently enable Mobile Telephony and IT companies such as Webtel.mobi to apply more robust, rigorous and reliable “Know Your Client” (“KYC”) and “Anti Money Laundering” (“AML”) procedures than most Financial Services Sector companies can provide; due to most Financial Services Companies’ reliance on outdated Legacy Systems and products.
Webtel.mobi – being very proactive insofar as KYC and AML considerations are concerned – has applied these robust systems in and to the Refund Transfer Rules and Limits, making this Facility both efficient and reliable for Members, while at the same time ensuring that KYC and AML considerations are very strongly adhered to.
A description of the TEL.mobi Group’s Refund Transfer Rules and Limits appear on the pages overleaf.
As a baseline, to become a TEL.mobi Group Member and use the system in general has already entailed de-facto KYC being applied to Members three times, through:
1. Their already having a Mobile Phone Number (meaning that they have already provided KYC in order to obtain a Mobile Phone with SIM Card, or a SIM Card), and
2. Their having to have their Mobile Numbers Verified before being able to use the system (meaning that it is confirmed as being their Phone Number and in their possession), and
3. Their Stored Credit having to be loaded from a Bank Account (a KYC and AML procedure – because this means that Members have already provided KYC to a Bank to open their Account, and that the Stored Credit that they transfer in to the system represent already-AML’d “cleared funds”).
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Moreover, in order to be able to initiate Refund Transfers, all Members must additionally upload KYC Documents (a fourth KYC and AML procedure), which have been Verified and Certified by a Registered Attorney or Notary (a fifth KYC and AML procedure).
Additionally, Stored Credit can only be refunded to a Bank Account belonging to the Member himself/herself (a sixth KYC and AML procedure).
Finally, as the seventh pillar of the TEL.mobi Group’s effective KYC and AML process, specific and clear Rules and Limits on Refund Transfers have been applied.
These Rules and Limits have been applied according to a procedure that enables a streamlined and efficient process for Members, while at the same time adhering to beyond Best Practice from an AML perspective.
As a baseline for a trigger amount for the application of more stringent AML Limits and Rules, the low amount of Euro 9 999.00 per month has been applied. This is in conformance with “The Cash Controls (Bailiwick of Guernsey) Law, 2007”.
This law permits people to leave the States of Guernsey with Euro 10 000.00 in cash – which they may theoretically do every day.
To go the extra mile, and although –
1. All value in Members’ TEL.mobi Accounts represents Stored Credit – not cash, and
2. All Stored Credit in the TEL.mobi Accounts has entered from Bank Accounts, and is therefore already “Cleared Funds” which have been AML’d and cleared by a Bank, and
3. All Incoming and Outgoing ICLM Transactions can only be from Member to Member in the TEL.mobi Group Closed Loop, and because Members can only load Stored Credit from Bank Accounts, all Stored Credit has already been declared “Cleared Funds” by Banks, and
4. All Incoming and Outgoing ICLM Transactions can only be from Member to Member in the TEL.mobi Group Closed Loop, the TEL.mobi Group is in possession of the data on who has Swapped Stored Credit, and the full details of all and any Incoming ICLM Transactions, as well as the details of which Member/s have carried out the ICLM Transactions to another Member, and
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5. All Stored Credit can only leave the TEL.mobi Group System to the Bank Account of the Member whose Stored Credit it is, and is therefore again verified by the Bank to which it is transferred
– Webtel.mobi has nevertheless applied more rigorous terms than it needs to, in that the Euro 9 999.00 can only be Refunded once per month before mandatory heightened AML procedures, rules and limits kick in.
The relevant law applicable to the minimum amount allowed prior to the mandatory application of heightened AML procedures can be seen at the link below:
http://www.guernseylegalresources.gg/article/93997/Cash-Controls-Bailiwick-of-Guernsey-Law-2007
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A. Rules and Limits if all Stored Credit is Loaded from Member’s own Bank: Refund Request/s of over Euro 9 999.00* per month
1. If all of the Stored Credit in a Member’s Account has been loaded directly onto the Member’s Account by the Member himself/herself from his/her Bank Account in a Bank Transfer or via a Payment Gateway or via an Online Wallet connected to his/her Bank Account, or via a Bank Card,
2. And the Member has uploaded his/her Verified and Certified Personal KYC Documents (if the Member is a Private Person), or
3. The Member has uploaded his/her Verified and Certified Personal KYC and Corporate KYC Documents (if the Member is a Business/Company/Entity),
4. Then:
The Member may initiate a Refund of any amount/s of Stored Credit over Euro 9 999.00* per month, in one tranche or several tranches, from his/her TEL.mobi Account to his/her Bank Account.
The Member may initiate a Refund in any currency or currencies, regardless of the original currency uploaded, as long as the amount requested in the Refund reflects the same amount as originally loaded by the Member.
The Member may have the Refund transferred to a different Bank Account from the one used to load the currency provided that it is a Bank Account held by the Member. In this case, a Verified and Certified letter from the Bank at which the account is held – confirming that the Member is the holder of the account – must be uploaded prior to the Refund taking place. This is necessary because the Bank will have done the necessary legal and KYC checks to ensure that the Bank Account is legally held by the Member.
Regardless of the fact that the Member may have uploaded all of the Stored Credit himself/herself from his/her own Bank Account, the Member consents that Supporting documentation detailing the source of funds and/or purpose of the funds use must be provided and uploaded. This will be on an ad-hoc basis, as determined by and as requested by Webtel.mobi. This Documentation (the Proforma of which is on the “Refund Transfer” Facility) will be either a Pay Slip, Invoice from Member with Confirmation of Payment letter from invoiced person/entity, etc.
Note: All Refund Transfer Requests over Euro 100 000.00 (in any currency) MUST upload all required Supporting Documentation together with the Refund Transfer Request.
* = or the equivalent of Euro 9 999.00 in any currency 189
B. Rules and Limits if all Stored Credit Loaded from Member’s Top-Up Voucher: Refund Request/s of over Euro 9 999.00* per month
1. If any of the Stored Credit in a Member’s Account has been loaded onto the Member’s Account by the Member himself/herself using a TEL.mobi Group Top-Up Voucher,
2. And the Member has uploaded his/her Verified and Certified Personal KYC Documents (if the Member is a Private Person), or
3. The Member has uploaded his/her Verified and Certified Personal KYC and Corporate KYC Documents (if the Member is a Business/Company/Entity),
4. Then:
The Member will be required to upload documentation confirming the source of the funds used to acquire the Top-Up Voucher.
This Documentation (the Proforma of which is on the “Refund Transfer” Facility) will be either a Pay Slip, Invoice from Member with Confirmation of Payment letter from invoiced person/entity, etc.
The Member may initiate a Refund of any amount/s of Stored Credit over Euro 9 999.00* per month, in one tranche or several tranches, from his/her TEL.mobi Account to his/her Bank Account.
The Member may request a Refund in any currency or currencies, regardless of the original currency uploaded, as long as the amount requested in the Refund reflects the same amount as originally loaded by the Member.
The Member may have the Refund transferred to a different Bank Account from the one used to load the currency provided that it is a Bank Account held by the Member. In this case, a Verified and Certified letter from the Bank at which the account is held – confirming that the Member is the holder of the Account – must be uploaded prior to the Refund taking place. This is necessary because the Bank will have done the necessary legal and KYC checks to ensure that the Bank Account is legally held by the Member.
* = or the equivalent of Euro 9 999.00 in any currency
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C. Rules and Limits if all Stored Credit is not Loaded by the Member: Refund Request/s of over Euro 9 999.00* per month from Ad-Hoc ICLMs
1. If some or all of the Stored Credit in a Member’s Account has been loaded onto the Member’s Account through receipt of Private or Business ICLM Transactions on an Ad-Hoc / Non-Regular basis,
2. And the Member has uploaded his/her Verified and Certified Personal KYC Documents (if the Member is a Private Person), or
3. The Member has uploaded his/her Verified and Certified Personal KYC and Corporate KYC Documents (if the Member is a Business/Company/Entity),
4. Then:
The Member will be required to upload documentation confirming the source and reason for the preceding three largest Incoming ICLMs for that month (or, if there is only one preceding ICLM Transaction for the month, the source and reason for the single Incoming ICLM).
This documentation (the Proforma of which is on the “Refund Transfer” Facility) will be either a Pay Slip, Invoice from Member with Confirmation of Payment letter from invoiced person/entity, confirmation letter from ICLM Transferor if a Remittance or Private Money Transfer, etc.
The Member may initiate a Refund of any amount/s of Stored Credit over Euro 9 999.00* per month, in one tranche or several tranches, from his/her TEL.mobi Account to his/her Bank Account.
The Member may request a Refund in any currency or currencies, regardless of the original currency uploaded or received in ICLMs.
The Member may have the Refund transferred to a different Bank Account from the one used to load the currency provided that it is a Bank Account held by the Member. In this case, a Verified and Certified letter from the Bank at which the Account is held – confirming that the Member is the holder of the account – must be uploaded prior to the Refund taking place. This is necessary because the Bank will have done the necessary legal and KYC checks to ensure that the Bank Account is legally held by the Member.
The Member consents that additional Verified and Certified supporting documentation on his/her/its business and/or any ICLM Transactions can be requested on an ad-hoc basis by Webtel.mobi at any time, and must then be uploaded.
* = or the equivalent of Euro 9 999.00 in any currency 191
D. Rules and Limits if all Stored Credit is not Loaded by the Member: Refund Request/s over Euro 9 999.00* per month from Regular Business ICLMs
1. If some or all of the Stored Credit in a Member’s Account is being loaded onto the Member’s Account through receipt of Business ICLM Transactions on a Regular basis,
2. The Member has uploaded his/her Verified and Certified Personal KYC and Corporate KYC Documents,
3. Then:
The Member will be required to upload documentation describing his/her business, the anticipated average ICLM amount per Transaction, and the anticipated average total of monthly ICLM Transactions (the Proforma of which is on the “Refund Transfer” Facility).
The Member will additionally be required to upload Invoices corresponding with five Incoming ICLM Transactions (one invoice per working day of the week) on the last day of each week of the month (the Proforma of which is on the “Refund Transfer” Facility).
The Member may initiate a Refund of any amount/s of Stored Credit over Euro 9 999.00* per month, in one tranche or several tranches, from his/her TEL.mobi Account to his/her Bank Account.
The Member may request a Refund in any currency or currencies, regardless of the original currency uploaded or received in ICLMs.
The Member may have the Refund transferred to a different Bank Account from the one used to load the currency provided that it is a Bank Account held by the Member. In this case, a Verified and Certified letter from the Bank at which the Account is held – confirming that the Member is the holder of the Account – must be uploaded prior to the Refund taking place. This is necessary because the Bank will have done the necessary legal and KYC checks to ensure that the Bank Account is legally held by the Member.
The Member consents that additional Verified and Certified supporting documentation on his/her/its business and/or any ICLM Transactions can be requested on an ad-hoc basis by Webtel.mobi at any time, and must then be uploaded.
* = or the equivalent of Euro 9 999.00 in any currency
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E. Rules and Limits if Stored Credit is not Loaded by the Member: Refund Request/s of under or up to Euro 9 999.00* per month
1. If some or all of the Stored Credit in a Member’s Account has been loaded onto the Member’s Account through receipt of Private or Business ICLM Transactions, or by Top-Up Vouchers from the Member,
2. And the Member has uploaded his/her Verified and Certified Personal KYC Documents (if the Member is a Private Person), or
3. The Member has uploaded his/her Verified and Certified Personal KYC and Corporate KYC Documents (if the Member is a Business/Company/Entity),
4. Then:
The Member may initiate a Refund of any amount/s of Stored Credit under or up to Euro 9 999.00* per month, in one tranche or several tranches, from his/her TEL.mobi Account to his/her Bank Account.
The Member may request a Refund in any currency or currencies, regardless of the original currency uploaded or received in ICLMs.
The Member may have the Refund transferred to a different Bank Account from the one used to load the currency provided that it is a Bank Account held by the Member. In this case, a Verified and Certified letter from the Bank at which the Account is held – confirming that the Member is the holder of the Account – must be uploaded prior to the Refund taking place. This is necessary because the Bank will have done the necessary legal and KYC checks to ensure that the Bank Account is legally held by the Member.
The Member consents that Verified and Certified supporting documentation on his/her/its business and/or any ICLM Transactions can be requested on an ad-hoc basis by Webtel.mobi at any time, and must then be uploaded.
* = or the equivalent of Euro 9 999.00 in any currency
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F. Full Visibility of the entire flow of ICLM Transactions prior to Refund:
Other than the Refund Transfer Rules and Limits, Webtel.mobi in any event has full visibility of the entire flow of every single ICLM Transaction within the TEL.mobi Group’s Closed-Loop Members- Only System.
As such, every person making and receiving an ICLM Transaction is known, has had various levels of KYC done on them, and all “to” and “from” ICLM Transactions, and their entire flow prior to a Refund Request, are fully recorded, visible, identifiable, back-traceable and verifiable along their entire route, from inception to Refund, to their original source/s.
G. Refund Transfer Request Review prior to Actioning:
1. When a Member has initiated a Refund Transfer, the Transfer itself is not immediately carried out. It is queued for review prior to implementation.
2. Random Reviews are carried out on longstanding Members’ Refund Transfer requests.
3. Reviews are carried out on Refund Transfer Requests by New Members, Refund Transfer Requests for Large Amounts and Refund Transfer Requests that are in any other way deemed
by Webtel.mobi to be unusual in nature.
4. If Webtel.mobi requires further information to validate e Refund Transfer Request, the Refund Transfer will be delayed until such additional information has been provided to Webtel.mobi
by the Member requesting the Refund Transfer.
5. If satisfactory Additional Information is unable to be provided to Webtel.mobi by the Member requesting the Refund Transfer, Webtel.mobi will refer the matter to the Financial Investigation Unit of the Guernsey Border Agency for review, and their guidance on the matter
will thereafter be followed.
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SECTION 2
THE VSMP
OPPORTUNITY
195
COMPARISON OF
THE STANDARD TELCO
“MVNO PROGRAM”
WITH
THE UNIQUE TEL.MOBI GROUP
“VSMP PROGRAM”
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COMPARISON OF THE STANDARD TELCO “MVNO PROGRAM” WITH THE UNIQUE TEL.MOBI GROUP “VSMP PROGRAM”
A. Overview:
The TEL.mobi Group’s Global “Virtual Specialized Mobile Provider” (“VSMP”) Program – provided by Webtel.mobi which itself is a Specialized Mobile Provider (“SMP”) – is a Program whereby Eligible Entities can apply for – and be given – their own version of the Webtel.mobi Specialized Mobile Provider (“SMP”) platform.
They can thereafter utilize the VSMP as an additional service provision to their existing clients / members / personnel of their own companies or entities – or to the public.
The VSMP Program is similar in some ways to the “Mobile Virtual Network Operator” (“MVNO”) Program provided to Eligible Entities by Mobile Network Operators (“MNOs”).
The VSMP Program is the provision of a Virtual system to Eligible entities by an SMP (Webtel.mobi), and the MVNO Program is the provision of a Virtual system to Eligible Entities by an MNO.
As an example, MVNOs include Virgin Mobile, BT Mobile, Lebara Mobile, Lyca Mobile, TracFone, US Mobile, The People’s Operator, etc.
In fact, more than 90% of all Mobile Operators in the world are MVNOs – not MNOs – and they function off the MNO’s infrastructure to provide the Virtual service that the MNO provides them with. See these two links for examples of just some of the MVNOs in two countries, the UK and USA:
UK MVNOs: https://en.wikipedia.org/wiki/List_of_United_Kingdom_mobile_virtual_network_operators
USA MVNOs: https://en.wikipedia.org/wiki/List_of_United_States_mobile_virtual_network_operators
MVNOs: https://en.wikipedia.org/wiki/Mobile_virtual_network_operator
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B. Comparison:
The Primary Differences between the TEL.mobi Group’s VSMP Program and traditional MNOs’
standard MVNO Programs are as follow:
1. MNOs provide MVNOs with the ability to provide Coverage / services in one country. Webtel.mobi provides VSMPs with the ability to provide Coverage / Services in 193 countries (240 Countries and Territories).
2. MNOs provide MVNOs with the ability to provide (usually) Basic Mobile Calling & Texting Services or (sometimes) Full Mobile Calling & Texting Services. Webtel.mobi provides VSMPs with the ability to provide Full Mobile Calling & Texting Services as well as Specialized Mobile Calling & Texting Services (which neither MNOs nor MVNOs can provide).
3. MNOs cannot provide – and cannot provide their MVNOs with the ability to provide – Landline Calling Services. Webtel.mobi provides VSMPs with the ability to provide Full Landline Calling Services.
4. MNOs cannot provide – and cannot provide their MVNOs with the ability to provide – the Secondary and Support Services as provided by Webtel.mobi. Webtel.mobi provides VSMPs with the ability to provide the Full Range of Secondary and Support Services in its Product Suite.
5. MNOs cannot provide – and cannot provide their MVNOs with the ability to provide – the Members’ Closed Loop Ancillary Services as provided by Webtel.mobi. Webtel.mobi provides VSMPs with the ability to provide the Full Range of Members’ Closed Loop Ancillary Services.
6. MNOs charge Eligible Entities tens-of-millions of dollars to hundreds-of-millions of dollars to establish an MVNO. Webtel.mobi charges Eligible Entities zero to establish a VSMP – they are established for free.
7. MNOs require Eligible Entities to have or acquire extensive premises, equipment and personnel to establish an MVNO. Webtel.mobi does not require Eligible Entities to acquire any additional premises, equipment or personnel to establish a VSMP.
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8. MNOs require minimum guarantees of revenue-generation, investments, marketing spend and other high start-up costs and running costs from Eligible Entities to establish an MVNO. Webtel.mobi requires no guarantees of revenue generation, no investment, no marketing
spend, no start-up costs and no running costs from Eligible Entities to establish a VSMP.
9. MNOs and other entities require Eligible Entities to go through significant and time-consuming processes to secure multiple administrative and licensing requirements – which can take months or years – to establish an MVNO. Webtel.mobi requires Eligible Entities to upload their KYC documents and pass a review by Webtel.mobi – which takes from 8 hours to 24 hours – to
establish a VSMP.
10. MNOs require Eligible Entities to be a large company, a large corporation or a large consortium to establish an MVNO. Webtel.mobi will establish a VSMP for any Eligible Entity – regardless of its size or sector of operation, anywhere in the world.
It is for these reasons that Webtel.mobi and the TEL.mobi Group have received applications from existing MVNOs for VSMPs to be established for them.
It is also for these reasons that Webtel.mobi and the TEL.mobi Group have received VSMP Applications from Eligible Entities totaling almost ten times the combined total of all MVNOs in the world – from over 180 countries.
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THE VSMP OPPORTUNITY –
WHAT AN “ELIGIBLE ENTITY” IS
200
THE VSMP OPPORTUNITY – WHAT AN “ELIGIBLE ENTITY” IS
The TEL.mobi Product Suite has been built to be of value and use to every single market sector, in every country, and in/to every cultural and/or socio-economic sector, throughout the world. The primary Characteristics and Requirements for entities to be Eligible Entities to be given Consent to establish a TEL.mobi Group VSMP are as follow:.
A. Eligible Entities’ Characteristics:
In order to qualify for Consent to establish a TEL.mobi Group VSMP, an entity should have the following characteristics:
1. It must be an entity that is carrying out activities that are legal, above board and inoffensive.
2. It must have a central point or person that can communicate with multiple persons (be they employees, members, clients, shoppers, students, alumni, fans, supporters or any other collective group of persons).
3. It must be prepared and able to receive and send out the TEL.mobi Group’s weekly Marketing Messages to its existing employees, members, clients, shoppers, students, alumni, fans, supporters or any other collective group of persons.
4. There is no requirement for a minimum or maximum number of persons within an Eligible Entity in order for it to be given Consent to establish a TEL.mobi Group VSMP (The largest Eligible Entity that has to date obtained a TEL.mobi Group VSMP has more than 200 Million members. The smallest Eligible Entity that has to date obtained a TEL.mobi Group VSMP has 10 members).
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B. Eligible Entities’ Legal Status as VSMPs:
1. The business of the TEL.mobi Group is run from Guernsey, and all TEL.mobi Member Accounts are legally classified as being in Guernsey – with all activities and Transactions legally classified as taking place in and from Guernsey – regardless of where any TEL.mobi Member, Independent Agent or VSMP is physically located.
2. All TEL.mobi Group VSMPs are legally classified as independent marketers of the Webtel.mobi service. They therefore do not have any requirement to register companies, carry out any other form of registration, or request any consent to function – regardless of where they are geographically located. More Information on this aspect can be seen on Page 4 of the “International Regulatory Confirmation” Document, which can be found on the “Testimonials” Static Page link on all TEL.mobi Group Sites.
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C. Examples of Eligible Entities that have applied for TEL.mobi VSMPs:
The type of Eligible Entity for a TEL.mobi Group VSMP is virtually limitless. As such, to list them all will take many pages, and is unnecessary. Therefore, the list below represents only a very small cross-section of the types of Eligible Entities that have successfully applied for and/or established TEL.mobi Group VSMPs to date: Affinity Organizations Loyalty Groups Aid Agencies Magazines and Newspapers Airlines Marketing Organizations Alumni Organizations Mobile Telephone Companies Apartment Blocks Online Retailers Blogs Radio Stations Call Centers Residential Complexes Charities Restaurants Companies (wide sector range) Retailers Competitions Ships Condominiums Shopping Malls Conservation Organizations Shops Cruise liners Special Events Entities Cultural Organizations Sporting Clubs Events Companies Taxi Companies Ferries Television Stations Firms (wide sector range) Travel Agents
Garages Unions
Guest Houses Universities Hobby Clubs University Student Unions Hospitals Utilities Companies Hotels Websites Humanitarian Organizations Wholesale outlets Import / Export Entities Youth Organizations Landline Telephone Companies Etcetera
THE VSMP OPPORTUNITY –
WHY IT EXISTS
AND
HOW IT WORKS
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THE VSMP OPPORTUNITY – WHY IT EXISTS AND HOW IT WORKS
A. Overview:
The purpose of the activities of IAs (and VSMPs) is to implement the TEL.mobi Group’s Global Member-Acquisition process in a manner that is:
1. Cost-effective and practical for the TEL.mobi Group to implement on a worldwide basis, in all languages, in all communities, through local, trusted and competent persons in all countries, communities and languages internationally.
2. In order to be able to keep the cost of Member-Acquisition low.
3. To thereby be able to keep the TEL.mobi Group’s costs as low as possible to its Members.
4. While at the same time contributing to job-creation within communities and income generation within communities.
5. On a total “equality of opportunity” and “equality of access-opportunity” basis.
6. That rewards personal excellence and personal endeavor as the primary factors for success.
An illustration of how the TEL.mobi Group IA (and VSMP) process brings this situation about – and how it differs from conventional models –- is as shown below and over the page.
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B. The Webtel.mobi, Independent Agent, VSMP and Member Flow:
C. The Webtel.mobi, Independent Agent, VSMP and Member Interaction:
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D. The TEL.mobi Group Value Constellation System:
The TEL.mobi Group functions according to a “Win-Win-Win-Win” Value-Constellation System. All participants in the TEL.mobi Group Global Ecosystem – Members, Eligible Entities/VSMPs, Independent Agents and Webtel.mobi – participate as integral parts of the Value Constellation, as follows:
1. End-Users (TEL.mobi Group Members) Win: Because they are able to access world-class services from a local and trusted entity (their own Eligible Entity’s VSMP), through which they can cut their Telephony and Texting usage costs, their Top-up Transfer costs, their Currency Conversion costs – and also obtain these services on a reliable, secure and rapid basis. This therefore leaves them with far more disposable income for themselves every month due to the savings that they have made by using the TEL.mobi Group’s System and Facilities.
2. Eligible Entities (through their VSMPs) Win: Because the Eligible Entities are awarded VSMPs, their VSMPs enable them to offer their existing clients / members / users / etc. with the full range of TEL.mobi System Facilities directly. This will significantly reduce the costs of the Eligible Entities’ existing clients / members / users / students / etc for Telephony, Texting, Top-up Transfers, Currency Conversions and other costs. It will also – while reducing costs for the Eligible Entities’ end- users – simultaneously generate a significant additional Commission Donation revenue stream for the Eligible Entity, that it cannot otherwise obtain, and at no cost to the Eligible Entity.
3. Independent Agents Win: Because they are able to provide entities in their own cities / towns / communities with VSMPs, which means that they increase the levels of commercial activities in their own cities / towns / communities; and they also obtain significant Commission Donations for obtaining VSMPs.
4. Webtel.mobi Wins: Because it is able to send its global marketing out to existing client / member / user bases of Eligible Entities that have qualified to obtain VSMPs. It therefore saves the costs of global marketing, and obtains the input of local and known specialists in the form of its local Independent IAs and Eligible Entities that are awarded VSMPs.
The TEL.mobi Group system does away with the traditional structures whereby in order for one party to “win”, another party has to “lose”. In the TEL.mobi Group structure, all people and entities that participate in it win – with no party at all having to “lose” – by working together in a mutually supportive and mutually beneficial structure. 207
THE VSMP OPPORTUNITY –
THE PRIMARY REQUIREMENT
FOR
ELIGIBLE ENTITIES
208
THE VSMP OPPORTUNITY – THE PRIMARY REQUIREMENT FOR ELIGIBLE ENTITIES
A. Eligible Entities’ Requirements to Establish a VSMP:
The following are the requirements for Eligible Entities to establish a TEL.mobi Group VSMP:
1. They must provide at least one person – preferably two persons – at the Eligible Entity who will be listed as the Contact Persons for the VSMP. These persons must be available by email and mobile telephone for any queries that may arise from the VSMP’s Establishing Agent or the TEL.mobi Group.
2. The Contact Persons – or persons at the Eligible Entity who report to the Contact Persons – must make themselves familiar with the TEL.mobi Group Product Suite and the VSMP Administration Console.
3. The Eligible Entity must establish its own VSMP either over a TEL.mobi Group Global VSMP or (preferably) an Agent VSMP, or must request the Establishing Agent to establish its Global VSMP with its consent.
4. Once its Global VSMP is established, the Eligible Entity must receive the TEL.mobi Group’s weekly Marketing Messages every week and send these out to its existing employees, members, clients, shoppers, students, alumni, fans, supporters or any other collective group of persons.
5. The Eligible Entity will be required to join the TEL.mobi Group Global VSMP Association (TGVA) when it is formed. There are no requirements to or for the Eligible Enmity once it has joined, other than that if the Eligible Entity wins an award for outstanding achievements, it will be eligible to send its Contact Persons (at its election) to attend any event where such awards are presented. It will also, through this Association, receive regular updates, advice and recommendations in respect of its VSMP and the VSMP Program in general.
6. There are no other requirements, because this structure and process has been specifically designed to be non-invasive, non-arduous, cost-free and easy for Eligible Entities to apply.
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B. Primary Requirement – Forwarding Marketing Messages:
1. The Primary Requirement for Eligible Entities once their VSMP has been established is to receive the TEL.mobi Group’s Call-to-Action Marketing Messages (sent once per week by email and placed in the VSMP Administration Console), and to send that Marketing Message out to the Eligible Entity’s existing client / member / user / other base.
2. The Marketing Messages will direct the Eligible Entity’s existing client / member / user / other base to the Eligible Entity’s own VSMP, to use the Products, Services and facilities on its own VSMP.
3. The TEL.mobi Group’s VSMP Program has been specifically constructed to be able to be implemented by Eligible Entities without any requirement for any cost, expense, personnel or change of their usual or standard operating procedures.
4. Webtel.mobi provides all Technical Assistance that is required by the Eligible Entities for their VSMPs, and Administrative Assistance to the Eligible Entities or their Contact Persons is provided by the TEL.mobi Group Independent Agents.
5. This structuring to ensure no cost requirements extends to the weekly TEL.mobi Group Marketing Messages that Eligible Entities are required to send out to their existing member / user / client / personnel / student / other collective grouping is concerned.
6. The Weekly Marketing Messages are provided to the Eligible Entities’ Contact Persons through placement thereof in the VSMP Administration Console that they have access to, as well as by email to them. The identical Weekly Marketing Messages are placed in all Independent Agents’ Administration Consoles and sent by email to them.
7. This results in zero-cost delivery of the Weekly Marketing Messages to the Eligible Entities’ Contact Persons and to their Establishing Agents.
8. Eligible Entities are similarly not expected to incur any cost in or for the distribution of these Weekly Marketing Messages.
9. Instead, all that is required is for the Eligible Entity to attach or incorporate the Weekly Marketing Messages – which will refer to their own VSMP and their own VSMP’s url, and will be short and concise – to whatever form or medium they already use to communicate with their existing collective grouping.
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10. Examples of the mediums in or to which existing VSMPs attach the weekly Marketing Messages are as follow:
Insertion into emails Placement onto leaflets and flyers Placement on websites Placement onto notice boards Placement in blogs Placement in newspaper copy Placement on hard-copy letters Announcement over radio stations Placement on the back of till slips Announcement on TV broadcasts
11. The preceding examples are just some of the mediums used by Eligible Entities that have VSMPs to transmit the Weekly Marketing Messages for their VSMPs at no additional cost to themselves.
12. In short, whatever medium is currently used by an Eligible Entity to communicate with its existing collective grouping should be utilized to incorporate the Weekly Marketing Messages, to preclude any additional cost or inconvenience being incurred.
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C. Forwarding Marketing Messages – Important Points:
1. The TEL.mobi Group’s Weekly Marketing Messages must be received and then sent out unaltered in wording by the Eligible Entities / VSMPs.
2. All wording of all Weekly Marketing Messages is specifically written so as not to be misleading or ambiguous, and so as not to make false or misleading claims/statements, or make unsupported claims.
3. For this reason, it is very important that the wording of the Weekly Marketing Messages is never summarized, embroidered on or altered in any way, and is re-sent as it was received.
4. Similarly, if any verbal or written information on the TEL.mobi System or anything to do with it should be stated or sent out by Eligible Entities exactly as it is written on the TEL.mobi Group sites, with no summarizing or altering or wording, names or terms.
5. Eligible Entities must strictly adhere to these requirements.
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THE VSMP OPPORTUNITY – ELIGIBLE ENTITIES’
COMMISSION DONATIONS
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THE VSMP OPPORTUNITY – ELIGIBLE ENTITIES’ COMMISSION DONATIONS
A. Overview:
The TEL.mobi Group’s VSMP Program provides Eligible Entities with the opportunity to generate an additional and significant revenue-stream immediately, and at zero cost.
This is because the Eligible Entity is able to provide its existing clients / members / users / other with all of the TEL.mobi Group’s Facilities, Products and Services from its own VSMP. These reduce the clients / members / users / others costs and provide them with an extremely cost-effective and efficient service.
Although the existing clients / members / users / others cost are reduced substantially, they usage of the Facilities, Products and Services nevertheless generates revenues, and Webtel.mobi provides the Eligible Entity with a percentage of these revenues as a Commission Donation to it.
Eligible Entities receive a Commission Donation of 10% of the Net Revenue from all activities over their own VSMP.
This includes Net Revenues from every transaction throughout the entire suite of services on their own VSMP. This includes all Net Revenues from all Mobile Calls, Mobile Texts, Landline Calls, Top- Up Transfers, ICLM Transactions, Currency Conversions and, in the future, Global Marketplace Transactions, SCRM Transactions, PPC Marketing Clicks, and all other revenue-generating activities conducted over their VSMP.
Eligible Entities receive, in addition to the abovementioned 10%, a Commission Donation of 1% of the Net Revenue from every additional VSMP established for an Eligible Entity that signs up through their own VSMP site. This is because they are providing a Platform on their site through which additional Eligible Entities can sign up.
All of an Eligible Entity’s Commission Donations are automatically placed into the TEL.mobi Account of the Eligible Entity’s “Contact Person 1”, in real-time, as they are generated.
Additional Optional Revenue-Generation opportunities are available to Eligible Entities, are described in the Section of this handbook entitled “Additional Optional Revenue-Generating Opportunities for Eligible Entities”.
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Eligible Entities do not need to incur any start-up costs, incur any running costs, buy any airtime or anything else from Webtel.mobi, sell anything, acquire any additional equipment, appoint any additional personnel or alter any of their activities.
Webtel.mobi provides all support and assistance – directly and/or via Independent Agents – at zero cost to the Eligible Entity.
The only thing that the Eligible Entity is required to do is to receive Webtel.mobi’s Weekly Marketing Messages and send them out to its existing clients / members / users / other. This should also be done at no cost, through the Eligible Entity including the Weekly Marketing Messages in its existing communication methods to its clients / members / users / other.
Other than these current Direct Commission Donations, Eligible Entities will additionally and automatically also receive Direct Commission Donations from all TEL.mobi Group Impending Services when they come online (see the Section of this Handbook on “Impending Services”).
B. The Flow of Commission Donations to Eligible Entities:
The image below shows the Flow of Commission Donations to an Eligible Entity – from the Eligible Entity’s own VSMP, and from VSMPs which have been established through the Eligible Entities own VSMP:
10%
ELIGIBLE ENTITY ELIGIBLE ENTITY’S OWN VSMP (A)
VSMP ESTABLISHED VSMP ESTABLISHED VSMP ESTABLISHED VSMP ESTABLISHED
VIA VSMP (A) VIA VSMP (A) VIA VSMP (A) VIA VSMP (A)
1% 1% 1% 1%
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THE VSMP OPPORTUNITY –
SITUATIONS WHERE
ONE ELIGIBLE ENTITY
SHOULD HAVE MULTIPLE VSMPs
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THE VSMP OPPORTUNITY – SITUATIONS WHERE ONE ELIGIBLE ENTITY SHOULD HAVE MULTIPLE VSMPs
A. Overview:
1. In general, an Eligible Entity should have one VSMP, in order to direct, with clarity, its existing clients / members / users / other to one specific location.
2. This assists the Eligible Entity to effectively maximize its potential, while at the same time provide a focused specific venue for its members.
3. There are, however, situations – only for specific types of Eligible Entity – where having one VSMP will be potentially counter-productive.
4. These specific types of Eligible Entities – and the optimum methodology for them to follow – are as described below>
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B. Situations where one Eligible Entity should have Multiple VSMPs:
1. Any Eligible Entity that has Multiple outlets (i.e. Hotel Groups, Franchise Operations, Holding Companies with Subsidiaries), should have one VSMP for each or its Hotels / Franchises / Subsidiaries / other.
2. If it has just one VSMP for the Head Office / Central Point, this is often counter-productive from a point-of-view of maximization of potential.
3. If there is just one VSMP for the Head Office / Central Point, there is no incentive for the various Hotel Managers / Franchisees / Subsidiaries / branches / etc to promote the service, because it means nothing to their own bottom line, and there is no way to assess their promotion or the service - or lack thereof.
4. However, if each of the Hotels / Franchises / Subsidiaries / Other has its own VSMP, there is a definite incentive for each of them to promote the service to their guests / clients / other – because the revenues from the Commission Donations reflect directly on that Hotel’s / Franchise’s / Subsidiary’s / Other’s bottom line. There is also a way then to assess the effectivity – or lack thereof – of promotion of the service.
5. In such circumstances, whereas the Head Office / central Point can also have its own VSMP, it is far more productive for each subsidiary entity to also have its own VSMP too.
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C. Structuring in cases when one Eligible Entity has Multiple VSMPs:
In a situation where an Eligible Entity that has Multiple outlets (i.e. Hotel Groups, Franchise Operations, Holding Companies with Subsidiaries), has multiple VSMPs, there are two ways for the Eligible Entity to structure this, which are as follow:
1. Option 1 – A Global VSMP through which subsidiaries establish VSMPs
In this case, the Head Office / Central Point will establish its own Global VSMP (or have its own Global VSMP established by an Independent Agent).
It will thereafter instruct / direct all of its subsidiary entities to establish their own VSMPs through its own VSMP.
Through using this methodology, the Eligible Entity will obtain not only the 10% Commission Donation from the revenues of its own VSMP, it will also obtain a Commission Donation of 1% of the revenues of all of these other VSMPs that have signed up through its own VSMP (and they will also still obtain 10% Commission Donations from their own VSMPs’ activities).
The Head Office / central Point will also be able to Monitor the activity / member numbers / Revenues of all of these subsidiaries’ VSMPs through its VSMP Administration Console (because they signed up through it, so their activities are visible to it within its Administration Console).
2. Option 2 – An Agent VSMP through which subsidiaries establish VSMPs
In this case, the Head Office / Central Point will Apply to be an Independent Agent, and establish an Agent VSMP as its own Agent VSMP.
It will thereafter instruct / direct all of its subsidiary entities to establish their own VSMPs through its own Agent VSMP.
Through using this methodology, the Eligible Entity will obtain not only the 10% Commission Donation from the revenues of its own VSMP, it will also obtain a Commission Donation of 1% of the revenues of all of these other VSMPs that have signed up through its own VSMP (and they will also still obtain 10% Commission Donations from their own VSMPs’ activities).
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Moreover – as it is an Independent Agent – the Eligible Entity will furthermore obtain additional Commission Donations from all and any other VSMPs that are established through all and any of its subsidiaries’ VSMPs (which it does not obtain if it is not an Agent).
The Head Office / central Point will also be able to Monitor the activity / member numbers / Revenues of all of these subsidiaries’ VSMPs through its VSMP Administration Console – and also the activities of all other VSMPs that have signed up through them (because the Eligible Entity – as an Independent Agent – will have an Independent Agent’s Administration Console, which provides visibility on the activities of all VSMPs’ associated with the Agent).
This option does, however, require Administrative Activities to be applied by the Eligible Entity in terms of the Management and Administration of all the VSMPs assigned to it as an Agent. Due to this, some Eligible Entities prefer to apply Option 1, as no Administration or management is required in that structure.
Whether to apply Option 1 or Option 2 is at the sole discretion of each Eligible Entity that falls into the category where multiple VSMPs (one for each subsidiary entity) are preferable to one VSMP only for the Head Office / Central Point.
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D. Changing VSMPs from a Global VSMP to an Agent VSMP:
1. It is not possible for a Global VSMP to be changed to an Agent VSMP, or vice versa.
2. This is not done because – although it is technically possible to do this – it is not done so for AML and Security reasons.
3. In the case where an Eligible Entity has initially established a Global VSMP and want to alter it to an Agent VSMP, it is preferable for the Eligible Entity to just establish an additional Agent VSMP (after it has joined as an Agent), and leave the original Global VSMP up too.
4. Because VSMP Names and the details of the Eligible Entities that formed them cannot be changed, if an Eligible Entity no longer requires or wants its VSMP to be live, it is, in fact, closed down.
5. When a VSMP is closed down, it members Accounts remain completely valid, and can be used on any other TEL.mobi Group VSMP. However, the Eligible Entity will no longer receive the Commission Donations from these persons’ use of the system.
6. In situations where a significant Eligible Entity – that has multiple subsidiaries – wishes to alter its Global VSMP to an Agent VSMP, Webtel.mobi will consider doing this. This will not be an alteration, it will rather be the transference of existing members accounts to a new Agents VSMP – primarily for the continuance of receipt of Commission Donations from these Members activities by the Eligible Entity*. This is, however, rarely done, but will be done if there is a clear and understandable business motivation for it.
* All TEL.mobi Group Member Accounts are electronically tagged to the VSMP that they sign up through. Therefore, whatever VSMP they log in from (because TEL.mobi members can log in via any TEL.mobi Group VSMP) the Commission Donation always goes only to the VSMP through which they originally joined.
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THE VSMP OPPORTUNITY –
OTHER SIGNIFICANT ADVANTAGES
FOR
ELIGIBLE ENTITIES
222
THE VSMP OPPORTUNITY – OTHER SIGNIFICANT ADVANTAGES FOR ELIGIBLE ENTITIES
The TEL.mobi Group VSMP program is unique in many respects. It is a program which can be used for generating additional revenue by any entity internationally, at zero cost and with an immediate “plug & play” from a standing start to full operation within a day, with all of the sophisticated tools needed to keep track on their revenues also provided to them free in the VSMP Administration Console.
Moreover, the Eligible Entities will not only be generating potentially significant revenue for themselves at zero cost and with no additional infrastructure, equipment, personnel or administration requirements; they will be also simultaneously be providing a service to their existing member/client other base that reduces their members’/ clients‘/ other costs for the equivalent services.
A list of some of the multiple motivations that causes the TEL.mobi Group VSMP Program to be so popular with Eligible Entities is as follows overleaf:
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A. Easy and Immediate Commencement at No Cost, with Peace of Mind:
1. The TEL.mobi Group’s services are well-established, and Webtel.mobi has been providing these services worldwide since 2009. Eligible Entities therefore have the security of knowing that they are dealing with proven and reliable services, provided by an established and blue- chip entity.
2. A VSMP is free to obtain, and requires no additional equipment, infrastructure, personnel or other costs to run.
3. No technical integration is required for Eligible Entities to have their VSMP up and running within a day of their making their Application, and receiving Consent for their VSMP.
4. The Technical Maintenance of the VSMP is fully managed by Webtel.mobi, and administrative assistance – if required – is provided by TEL.mobi Group Independent Agents and/or Webtel.mobi, at no cost.
5. A full Administration Console is provided to Eligible Entity Contact Persons for complete oversight of Commission Donations, and all other relevant statistics on their VSMP.
6. A VSMP is classified as a white-label marketing version of Webtel.mobi, and is accessed from the internet. As such, Eligible Entities require no licenses, or permissions, or registrations, or consent of any nature or any other administration or structural requirements – other than their Application to and Consent from Webtel.mobi – for their VSMP to commence its activities.
7. The only requirement for Eligible Entities is to receive the TEL.mobi Group Marketing message once per week, and distribute it to their exiting clients / members / personnel by adding it on to whatever communication they already use to communicate with their existing clients / members / personnel (i.e. email, letters, flyers, blogs, online posts, back of till slips, etc).
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B. Gain Additional Revenues and Advantages at Zero Cost:
Eligible Entities are able to generate a completely new and additional revenue-stream via the Commission Donations that they receive for activity over their VSMPs. Moreover, this new and additional revenue stream is able to be obtained with:
1. No start-up costs.
2. No running costs.
3. No additional personnel requirements.
4. No equipment or infrastructure requirements.
5. Immediate availability.
6. Commencement within 1 hour to 24 hours of Application and Consent.
C. Utilize the VSMP’s Services to Reduce their Own Company Costs:
Eligible Entities are able to use their own VSMP’s Facilities in the Product Suite, by gaining access to Services that they did not previously have, or replacing existing services that are less efficient and/or more costly. Moreover, by utilizing their own VSMP, they also make revenue on their own savings. This is because, through using the services on their VSMP they can lower their own entity’s operating and/or business costs, for a multitude of purposes, a few examples of which are:
1. Companies using the Landline Service for their outgoing Company call costs.
2. Call Centers utilizing the Landline Calling Service to lower their costs of doing business.
3. Companies using the Mobile Calling Service to lower their personnel’s phone bills.
4. Companies applying Value-Added Uses to lower their costs of doing business.
5. Multiple other cost-lowering / cost-efficiency services.
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D. Gain a Competitive Advantage over Competitors:
Eligible Entities also use the TEL.mobi Group facilities in the Product Suite to gain Competitive Advantages over competitors. A few of the many examples in this regard are as follow:
1. Mobile Operators using it to gain clients in other countries, clients who are on other Mobile Providers’ Networks and to offer a wider range of Calling Services and Landline Services.
2. Landline Operators using it to gain clients in other countries, clients who are on other Landline Providers’ networks, and to offer a wider range of Calling Services and Mobile Services.
3. Hotels using it to provide their guests with low-cost Calling Services from their rooms.
4. Other Eligible Entities use it to provide services to their clients that their competitors do not and cannot provide, both as service-type enlargement, and/or as a bonus or motivation for joining or belonging to that entity.
5. Multiple other uses by which Eligible Entities can gain competitive advantages in their sectors.
E. Summary:
Every Eligible Entity will have its own preferred reasons for obtaining a VSMP, and one, some or all of the TEL.mobi Group Facilities can be of use for virtually every entity that exists. Although the purposes that Eligible Entities use the Facilities and the Product Suite platform are extremely widespread and varied, a summary of the primary Top-Level motivations for their acquisition of a VSMP are as follow:
1. To generate a new Revenue Stream at No Cost.
2. To monetize a resource that they already have – but cannot monetize themselves – that is the use of these services by their existing client / member / other base.
3. To provide a significant service and/or add-on benefit to their clients / members / other by providing these services to them and cutting their costs.
4. To utilize and/or Integrate these services to their existing services, to improve their business offering and/or reduce their operating costs.
5. To gain a competitive edge over their competitors. 226
THE VSMP OPPORTUNITY – RESTRICTIONS
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THE VSMP OPPORTUNITY – RESTRICTIONS
A. VSMP Restrictions – Names:
The following VSMP Names and/or Categories of Names are Restricted –
1. Names of Countries, Cities or Towns – unless applied for by Countries’ Formal Authorities (with documentary proof of their eligibility to make such decisions) and/or City/Town formal Authorities (with documentary proof of their eligibility to make such decisions).
2. Names of Well-Known and Formal/Registered Companies and/or Brands – unless applied for by Companies’ and/or Brands’ Formal Representatives (with documentary proof of their eligibility to make such decisions).
3. Names of Formal/Registered Companies and/or Brands that do not belong to the Eligible Entity acquiring the VSMP – unless written consent from the owner of the Company and/or Brand is provided.
4. Names of Well-Known and Formal/Registered Sporting Events, Sporting/Sport Clubs or Teams.
5. Names of Well-Known and Formal/Registered Events – unless applied for by Events’ Formal Representatives (with documentary proof of their eligibility to make such decisions).
6. Names of Well-Known and Formal/Registered Landmarks – unless applied for by Landmarks’ Formal Representatives (with documentary proof of their eligibility to make such decisions).
7. Names of Well-Known and/or Formal/Registered Organizations – unless applied for by Organizations’ Formal Representatives (with documentary proof of their eligibility to make such decisions).
8. Names of Well-Known People – unless applied for by these people, with KYC Documentation to prove their identities.
9. Names of Sanctioned Persons and/or Entities.
10. Names containing profane, racially-discriminatory, openly pornographic, extremist, inciting, violent, criminal, narcotics, or any harmful / anti-social words or acronyms.
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11. Any name that could reasonably be viewed as belonging to another person and/or entity, and/or any name that could reasonably be viewed as offensive or anti-social.
Webtel.mobi is the final and sole arbiter or what is and is not acceptable. If an Eligible Entity is unsure of whether or not a VSMP Name is acceptable, the Eligible Entity should contact the TEL.mobi Group Independent Agent assigned to it to enquire from him/her as to the suitability of the name.
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B. VSMP Restrictions – Persons and Entities:
The following Persons and Entities – and Persons or Entities carrying out any of the below- mentioned activities – are restricted from forming a VSMP –
1. Sanctioned Persons and/or Entities, who/which have been declared as Sanctioned Persons and/or Entities by the States of Guernsey. The list of Persons and/or Entities declared as Sanctioned by the Bailiwick of Guernsey can be seen in the documents at these links:
https://www.gov.gg/sanctions
http://guernseyfiu.gov.gg/article/113887/Sanctions-Updates
https://www.gfsc.gg/news/category/sanctions
2. Persons and/or Entities on the “Wanted” list of any Formal Law-Enforcement Entity internationally that is recognized by and in the States of Guernsey, details of which can be seen in the document at this link:
http://www.guernseylegalresources.gg/article/97878/Criminal-Justice-International-Co- operation-Bailiwick-of-Guernsey-Law-2001
3. Persons and/or Entities that are engaged in any criminal or harmful / anti-social activities.
4. Persons and/or Entities that have been previously Banned from the TEL.mobi Platform.
5. Any other Persons and/or Entities as declared by Webtel.mobi at its sole discretion.
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C. VSMP Restrictions – Activities:
Although Webtel.mobi and its Independent Agents are primarily responsible for monitoring the TEL.mobi Group Platform and VSMPs; activities to ensure that any attempted restricted / illegal activities are detected and dealt with appropriately, Eligible Entities should assist with “Early Warning” detection of potentially suspicious activities – within reason and according to a “best efforts” standard.
As such, Eligible Entities should always remain vigilant in respect of noticing – and reporting to their assigned Independent Agent or to Webtel.mobi – any actions / activities / processes / other attributes that appear to be suspicious to them in respect of transactions/processes on or over their VSMPs.
Indicators that suspicious events are occurring often include breaks from or anomalies to established patterns and norms of the transaction flows on the VSMP, or in/for a local area, examples of which include the following:
1. Sudden high-value Transactions on the VSMP where such high-value Transactions have not occurred before or do not generally occur.
2. Sudden high-value Transactions from an area where the Membership of the VSMP is not in the socio-economic bracket to undertake Transactions of high-value.
3. Transactions from or to Currency Wallets in or for currencies that are not the currencies of the area in which the VSMP is located.
4. Sudden increases in the quantity, number or frequency of Transactions from a VSMP (i.e. sudden peaks) – especially if they occur on a regular basis.
5. Any and all Transactions that are of exceptionally high value.
6. An extremely high number of Transactions to one Account in a short period (unless the Account is for a Business).
7. Any other Transaction, activity, process that is unusual, sudden, out-of-the-ordinary, or not in keeping with the general profile of the Membership of a VSMP in a specific area.
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SECTION 3
VSMP TYPES, USES
AND ESTABLISHMENT
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THE WIDE RANGE
OF
TEL.MOBI GROUP
GLOBAL VSMPs
THAT CAN BE FORMED
AND
THEIR USES
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THE WIDE RANGE OF TEL.MOBI GROUP GLOBAL VSMPS THAT CAN BE FORMED AND THEIR USES
Although specific and uniquely-structured VSMPs can be formed by the TEL.mobi Group management under specific circumstances (and only on request, under very rare circumstances), there are two Primary Types of Standard VSMPs that can be formed. They are Agent VSMPs and Global VSMPs, a description of these VSMPs and their roles being as follows overleaf:
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A. Global VSMPs – Overview:
These are the VSMPs that are established for Eligible Entities. They are established either by Eligible Entities Signing Up by themselves to establish their own Global VSMP, or by an Establishing Agent Signing Up to establish the Global VSMP on behalf of the Eligible Entity. The most popular VSMP Option among Eligible Entities worldwide is the Global VSMP. The Global VSMP’s characteristics are as follow:
1. It can be Established and up & running within 24 hours of Application.
2. It has a zero start-up cost, zero equipment cost, zero personnel requirement, zero running costs and zero marketing costs for the Eligible Entity making the application.
3. Full Technical Support is provided for the Eligible Entity’s VSMP by Webtel.mobi at zero cost to the Eligible Entity.
4. Administrative Support is provided to the Eligible Entity by TEL.mobi Group Independent Agents at zero cost to the Eligible Entity.
5. The Eligible Entity’s VSMP obtains a full Webtel.mobi Platform Product Suite, Services and Facilities, which it can brand as it wants to – with its existing branding or another – at zero cost to the Eligible Entity.
6. The Eligible Entity’s VSMP will provide:
All the Primary telephony Services of the TEL.mobi Platform. All the Telephony-Support Secondary Services of the TEL.mobi Platform.
All of the Intra-Closed-Loop Member (“ICLM”) Services of the TEL.mobi Platform. Access to people to join as an Independent Agents / to Eligible Entities to Acquire VSMPs
7. The Eligible Entity can provide the services of its VSMP to its existing clients / members / personnel / other grouping – as well as offering its services to the public – at zero cost to it.
8. The Eligible Entity’s VSMP will be able to provide the full range of Services and Facilities within the TEL.mobi Group’s Product Suite and Platform at the same cost price to Members as the Webtel.mobi Platform and/or any other VSMP – worldwide – at zero cost to it.
9. The Eligible Entity will receive its Retail Marketing messages at zero cost from Webtel.mobi – and can distribute this Retail Marketing to its clients / members / other at zero cost.
10. The Eligible Entity will receive 10% of the entire Net Revenue from all services on its VSMP, in real time, and will receive 1% of the Net revenue from each additional VSMP that signs up through its site 235
B. Global VSMPs – Types:
There are two types of Global VSMP, as follow:
1. Agent-assigned Global VSMPs
These are Global VSMPs that have been established by:
Eligible Entities establishing their own VSMP directly, through a VSMP that is already assigned to an Independent Agent.
An Independent Agent establishing a VSMP on behalf of an Eligible Entity.
These Global VSMPs have the Agent Number of the Assigned Agent (known as the “Establishing Agent”) in their VSMP Administrative Profile, and it is the responsibility of the Establishing Agent to provide Administrative Support to this VSMP.
2. Unassigned Global VSMPs
These are Global VSMPs that have been established by Eligible Entities signing up through the Webtel.mobi Site directly, or through one of the stand-alone VSMP Sites established by Webtel.mobi. These VSMPs have no Agent Numbers in their VSMP Administrative Profiles, and no Establishing Agent to provide them with Administrative Support. Webtel.mobi will assign such Unassigned VSMPs to Independent Agents, on a case-by-case basis, and at its discretion, to act as their Establishing Agents.
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C. Agent VSMPs:
These are Global VSMPs that are established by Independent Agents for their own use. They are primarily used by Independent Agents for practical purposes to do with the carrying out of their Primary Tasks (to form Global VSMPs).
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STREAMLINED AND RAPID
PROCESS
FOR EASY ESTABLISHMENT OF
TEL.MOBI GROUP
GLOBAL VSMPs WITHIN 24 HOURS
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STREAMLINED AND RAPID PROCESS FOR EASY ESTABLISHMENT OF TEL.MOBI GROUP GLOBAL VSMPs WITHIN 24 HOURS
The TEL.mobi Group system has been structured to enable independent VSMP creation by Independent Agents or by Eligible Entities directly. This is done via the TEL.mobi Group Administration Console. VSMPs are established either by Independent Agents on behalf of Eligible Entities that they have liaised with (at the request of the Eligible Entities), or by the Eligible Entities themselves.
An overview of these processes is as follows below:
A. Establishment by an Eligible Entity Directly:
This is the process followed when the Contact Persons at an Eligible Entity have established a VSMP for their own entity, either via an Agent VSMP, or via a Global VSMP that is tagged to a specific Independent Agent.
1. Decision by an Eligible Entity to establish its own VSMP
An Eligible Entity decides to establish its own VSMP.
The Eligible Entity’s Contact Persons – or people within the Eligible Entity instructed to do so by its Contact – go through the process to establish the VSMP.
2. Establishment via the VSMP Administration Console
The Eligible Entity’s Contact Persons / their nominees go through the process of VSMP Establishment via the VSMP Administration Console.
When doing so, the Eligible Entity’s Contact Persons / their Nominees pay specific attention to the important factors listed in the “Important Considerations during VSMP Establishment” Section of this Handbook.
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3. Approval of New VSMP by the Responsible Agent
Once the New VSMP has been established, the TEL.mobi Group System automatically informs the Responsible Agent (the Agent whose Agents VSMP – or Global VSMP tagged to him/her – was used to establish the New VSMP).
The Responsible Agent must then review the New VSMP within 8 hours of its establishment, to either Approve it, Request an Edit of it by the Contact Persons (for subsequent review by the Agent), or – in rare cases –Ban it.
Once that has been completed, the VSMP creation process has been successfully completed.
B. Establishment by an Eligible Entity Directly, via an Unassigned VSMP:
In the case where the Contact Persons at an Eligible Entity have established a VSMP for their entity via an Unassigned VSMP (i.e. a VSMP not tagged to an Independent Agent – such as the Webtel.mobi platform), the New VSMP will be assigned to an Independent Agent by Webtel.mobi after its creation. In such a situation, the procedures as described in the preceding “Establishment by an Eligible Entity Directly” sub-section will apply.
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C. Establishment by an Independent Agent on behalf of an Eligible Entity:
This is the process followed when the Contact Persons at an Eligible Entity have indicated their wish to establish a VSMP for their entity, but requested the Independent Agent to create the VSMP for them on their behalf:
1. Request for Agent-Creation of VSMP by Eligible Entity
The Independent Agent interacts with the Eligible Entity.
The Contact Persons (who must be persons authorized by the Eligible Entity to proceed with VSMP establishment) confirm the Eligible Entity’s request to establish a VSMP.
2. Establishment via the Independent Agents Administration Console
The Independent Agent goes through the process of VSMP Establishment via the Independent Agents Administration Console – usually from his/her own Agents VSMP.
When doing so, the Independent Agent pays specific attention to the important factors listed in the “Important Considerations during VSMP Establishment” Section of this Handbook.
3. Review of the New VSMP by Eligible Entity Contact Persons
Once the New VSMP has been established, the TEL.mobi system will automatically inform the Contact Persons at the Eligible Entity of its creation and url. The Independent Agent should also inform the Contact Persons at the Eligible Entity of this independently.
The Contact persons should then review the New VSMP, and confirm to the Independent Agent – in writing, by email or text – whether they are satisfied with –
the VSMP’s Name, and
the VSMP’s url and
the VSMP’s Color Template.
If they are satisfied, the New VSMP is left as it is. If they require editing of any of the three above aspects, they should inform the Independent Agent, and he/she should edit it, and then go through this review process again.
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4. Approval of New VSMP by Establishing Agent
Once the Contact Persons at the Eligible Entity have approved the VSMP, the Independent Agent must carry out the formal review and Approval Process on his/her Administration Console, and approve the VSMP in the TEL.mobi Group system.
Once that has been completed, the VSMP creation process has been successfully completed.
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SPECIAL CUSTOMIZED
TEL.MOBI GROUP VSMPS
THAT CAN BE FORMED
AND
THEIR USES
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SPECIAL CUSTOMIZED TEL.MOBI GROUP VSMPS THAT CAN BE FORMED AND THEIR USES
Other than the Standard VSMPs that can be established by IAs and/or Eligible Entities via the Administration Console, there also exist other types of Customized VSMPs.
These Customized VSMPs cannot be established by IAs and/or Eligible Entities themselves, and require Customization by Webtel.mobi. IAs on behalf of Eligible Entities – or Eligible Entities themselves – may contact Webtel.mobi to motivate and request the establishment of a Customized VSMP. Such motivations and/or requests will be reviewed on a case-by-case basis.
A description of the Customized VSMP types can be seen overleaf:
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A. SMS / Text Voting VSMPs:
1. These are VSMPs that are established for Competition Shows / Events and similar Shows / Events internationally, that provide – or have as part of their Show / Event structure – the opportunity for the public to Vote for X or Y in the Show / Event by means of Premium SMS/text.
2. Generally-speaking, the Premium Rate SMS/Text facility that such Competition Shows / Events and similar Shows / Events are provided with by Standard Mobile Providers have characteristics whereby:
The Standard Mobile Provider will retain up to 60% of the amount of the Premium Rate SMS/Text sent by each sender.
The Standard Mobile Provider will only remit the balance of the amount of the Premium Rate SMS/Text to the Competition Shows / Events or similar Shows / Events after 30, 60 or 90 days.
3. In comparison, the TEL.mobi Group provides the full amount of the cost of the Premium Rate SMS/Text to the Competition Show / Events – less only the standard SMS/Text costs as shown in the “Rates” page – and it remits this to the Competition Show / Event or similar Show / Event in real-time.
4. For such SMS/Text Voting VSMPs, they also have all of the other characteristics of a Global VSMP, with the addition of a specific TEL.mobi-assigned Premium Rate SMS/Text Number Range for their particular SMS/Text Voting VSMP, and a “Vote by SMS/Text” Facility in the “Member’s Account” section. This means that besides obtaining a new method by which to facilitate easier and higher payouts for its Competition Shows / Events or similar Shows / Events voting, the Eligible Entity also obtains the additional revenue-generation facilities on its TEL.mobi Group VSMP on an ongoing basis.
5. With such SMS/Text Voting VSMPs, the TEL.mobi Group always suggests that the Competition Show / Events or similar Show / Events keep their existing Standard Providers’ facilities in place initially, and gradually transfer their Members to their own VSMP’s SMS/Text Voting system to ensure uninterrupted business.
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6. Because the TEL.mobi Group’s system does not – like Standard Mobile Providers – keep up to 60% of the cost of the Premium Rate Text, but provides the Eligible Entity with all of the entire cost of the Premium Rate Text (less only the TEL.mobi Group’s ultra low costs), such Competition Shows / Events and other Similar Shows / Events are therefore able to:
Substantially lower the costs of the Voting by Premium Rate SMS/Text for their Shows / Events when using their TEL.mobi VSMP; but nevertheless get a substantially higher payout themselves from the reduced rate SMS/Text.
Enormously increase the number of people able to vote in their Shows / Events, because utilizing the TEL.mobi Group’s Premium Rate SMS/Text Facility enables them to structure and offer international voting in or for their Competitions / Shows. This is because the TEL.mobi Group’s Premium rate SMS/Text messages cost the same whether sent Locally, Nationally or Internationally.
As a result of the preceding two considerations, very significantly raise the amount of revenue that they generate from the TEL.mobi Group Premium rate SMS/Text messages.
7. For these reasons, the SMS/Text Voting VSMPs are popular in the Competition Shows / Events and similar Shows / Events sectors worldwide.
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B. Premium Rate SMS/Text Payments VSMPs:
1. These are VSMPs that are established for Eligible Entities that provide services to clients, that want to expand the methods that their client have to pay for services – usually on an ad-hoc and/or real-time basis (such as Parking in Parking Garages, and other forms of ad-hoc or real- time payments).
2. Many Eligible Entities that could utilize such systems do not do so because their own systems cannot integrate with Standard Mobile Providers’ services well or at all. However, the TEL.mobi Group VSMP system provides them with an already fully functional system that is very easy to integrate with any system at all which they currently have, to record and validate such payments by Premium Rate SMS/Text in real time.
3. Other Eligible Entities already have such services in place, but they face a similar situation to that faced by Competition Shows / Events and similar Shows / Events in that the terms for such services as provided by Standard Mobile Providers have characteristics whereby:
The Standard Mobile Provider will retain up to 60% of the amount of the Premium Rate SMS/Text sent by each sender.
The Standard Mobile Provider will only remit the balance of the amount of the Premium Rate SMS/Text to the Eligible Entity after 30, 60 or 90 days.
4. In comparison, the TEL.mobi Group provides the full amount of the cost of the Premium Rate SMS/Text to the Eligible Entity’s VSMP – less only the standard SMS/Text costs as shown in the “Rates” page – and it remits this to the Eligible Entity in real-time.
5. For such “Premium Rate SMS/Text Payments VSMPs”, they also have all of the other characteristics of a Global VSMP, with the addition of a specific TEL.mobi-assigned Premium Rate SMS/Text Number Range for their particular SMS/Text Voting VSMP, and a “Pay by SMS/Text” Facility in the “Member’s Account” section. This means that besides obtaining a new method by which to facilitate easier and higher payment for its services, the Eligible Entity also obtains the additional revenue-generation facilities on its TEL.mobi Group VSMP on an ongoing basis.
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6. With such “Premium Rate SMS/Text Payments VSMPs”, the TEL.mobi Group always suggests that Eligible Entities keep their existing Standard Providers’ facilities in place initially (if they have them), and gradually transfer their Members to their own VSMP’s SMS/Text Payment system to ensure uninterrupted business. Similarly, if they do not have a similar facility in place already, it is suggested that they retain their other payment systems / methods in place, and add this Facility as an additional payment Facility (because it is free for them to acquire).
7. The TEL.mobi Group’s system does not – like Standard Mobile Providers – keep up to 60% of the cost of the Premium Rate Text, but provides the Eligible Entity with all of the entire cost of the Premium Rate Text (less only the TEL.mobi Group’s ultra low Standard Text costs). Because of this, Eligible Entities that currently use Standard Mobile Providers’ facilities to provide such services are able to substantially lower their costs while simultaneously getting a substantially higher payout themselves – for exactly the same service.
8. For these reasons, the “Premium Rate SMS/Text Payments VSMPs” are popular in many sectors that utilize such services – or could utilize such services – worldwide.
9. Such VSMPs are also popular among Charities, Charitable Organizations, Humanitarian Organizations and similar Eligible Entities for fundraising drives and donations – worldwide.
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C. Restricted VSMPs:
1. These are VSMPs that are established for Eligible Entities that do not want persons outside of their own Eligible Entities to be able to join or use the services on their own VSMP.
2. For Restricted VSMPs, the Contact Persons of the Eligible Entity are given a facility to approve or deny a join-up to the VSMP.
3. People who then join do not immediately become Members of that VSMP. Their Application to Join is held as Pending until the relevant Contact Persons at the VSMP either “Accept” or “Deny” Membership.
4. In all other respects, they function in the same manner as all other Global VSMPs.
5. These VSMPs are rare, and they are only established for an Eligible Entity if there is a compelling motivation provided for such a structure, and if the size of the Eligible Entity merits Webtel.mobi customizing a VSMP for it.
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D. Closed and Restricted VSMPs
1. These are VSMPs that are established for Eligible Entities that:
Do not want persons outside of their own Eligible Entities to be able to join or use the services on their own VSMP. They require either that people who join have their Applications to Join held as Pending until a nominated Contact Person/s at the Eligible Entity either “Accepts” or “Denies” Membership; or that the nominated Contact Person/s actually sign up people themselves.
Do not want to have their Members load their own Member Accounts with Stored Credit. Instead, a nominated Contact Person/s at the Eligible Entity (such as a CFO or Finance Director) can assign Stored Credit to the Members’ Accounts in the VSMP / deduct Stored Credit from the Members’ Accounts in the VSMP (who will be staff / member of the Eligible Entity only) from a central Stored Credit balance loaded by him/her.
2. The above is able to be implemented, and then only the Nominated Person/s can load Stored Credit to their own Member Account on the VSMP, and assign it from there to other Members’ Accounts on the VSMP.
3. The Terms of Use for such Closed and Restricted VSMPs are slightly different to that of standard Global VSMPs. This is because the Contact Person must comply with various undertakings / requirements to be allowed to view the other Members’ Accounts on that VSMP, and the other Members must consent to that when being added to the VSMP.
4. Such VSMPs are rare, and they are only established for an Eligible Entity if there is a compelling motivation provided for such a structure, and if the size of the Eligible Entity merits Webtel.mobi customizing a VSMP for it.
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IMPORTANT CONSIDERATIONS
DURING
TEL.MOBI GROUP GLOBAL VSMP ESTABLISHMENT
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IMPORTANT CONSIDERATIONS DURING TEL.MOBI GROUP GLOBAL VSMP ESTABLISHMENT
A. Choosing a Free VSMP Name:
The VSMP’s name will be the Primary Identifier that a VSMP is associated with a Particular Eligible Entity. In the case where an Eligible Entity does not want a direct association between a VSMP’s Name and the Eligible Entity’s Name, this is not a major consideration. However, if a link in names is desired, then the VSMP name must be carefully chosen. The following are the important considerations when choosing a VSMP Name.
1. All VSMP Names end with the suffix “tel.mobi”
Whatever name is chosen, the suffix “tel.mobi” will be automatically added to it by the system.
For example, if the name “EXAMPLE” was chosen, the VSMP’s name that will be shown once it goes live will be “EXAMPLEtel.mobi”
The Name will always be in Upper Case Letters, and the “tel.mobi” suffix will always be in Lower Case letters.
This is a parameter set by the system, and cannot be altered.
2. VSMP Names are a minimum of 3 characters and a maximum of 11 characters
The VSMP Names – excluding the “tel.mobi” suffix, must be a minimum of 3 characters in length, and can only be a maximum of 11 characters in length.
If an Eligible Entity’s name is more than 11 characters in length, it should use an abbreviation, acronym or shortened version of its name for the VSMP’s name.
If using an abbreviation of a long name, it is recommended that an easy-to-remember abbreviation be used.
For example, if an Eligible Entity’s name is “JOHN SMITH AND SONS” (19 Characters – because spaces also count as characters), it would be 8 characters too long. Choosing to shorten it can therefore be represented as “JSS” (for “JSStel.mobi”), “JOHNSMITH” (for JOHNSMITHtel.mobi”), “SMITH&SONS” (for “SMITH&SONStel.mobi”), etc. 252
B. The Free Unique VSMP url, and Free Hosting:
Every VSMP site is given a Free Unique url by Webtel.mobi, and the VSMP site is also hosted and maintained free by Webtel.mobi. The following are important considerations for this aspect of VSMP creation:
1. The Free TEL.mobi url for the VSMP will have the VSMP name in it
Webtel.mobi provides a Free and Unique TEL.mobi Group url to each VSMP, and hosts this url for free.
The Free Unique url is a sub-url of Webtel.mobi, containing the VSMP’s name in it.
For example, if the VSMP Name “EXAMPLE” is chosen, then the Free Unique TEL.mobi url for that VSMP will be www.example.webtel.mobi
As another example, if the name “SMITH&SONS” is chosen, then the Free Unique TEL.mobi url for that VSMP will be www.smith&sons.webtel.mobi
2. Once made live, the VSMP Name and Free TEL.mobi Group url cannot be edited
For security reasons, once the VSMP has been made live, its name – and thereby its Free and Unique TEL.mobi Group url – cannot be edited.
This is for security reasons, is automatically regulated by the TEL.mobi System, and cannot be altered.
For this reason, it is very important during the VSMP Creation Process to review the New VSMP’s name and appearance in the Review section of VSMP Creation, make any edits of the name there before clicking the button to make it live.
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C. The Free VSMP Template and 360+ Free Color-variation Templates:
1. Webtel.mobi provides a VSMP Free Template for the Eligible Entity, which is a replica of the Webtel.mobi structure, with full functionality in every Facility and Service, as well as a direct Login to the VSMP Administration Console.
2. Webtel.mobi also provides more than 300 Three-layer Color Variation Templates for each Eligible Entity to be able to choose the color themes that best suit it for its VSMP.
3. The Template and color templates are automatically integrated by the TEL.mobi Group System during the VSMP Creation process.
4. The Template with Color-variation can be reviewed by the VSMP Creator during the VSMP Creation process, and can be edited as many times as required until the preferred color template is found and selected.
5. The selected VSMP Color Template can be altered to a different one, at the election of the VSMP, after VSMP creation, at any time, via the VSMP Administration Console (for Eligible Entities) or the Independent Agent Administration Console (for Independent Agents).
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D. Standalone VSMP url:
Webtel.mobi will host every VSMP site for free, and provide a Free and Unique url for each VSMP. However, other than the Webtel.mobi-assigned Free and Unique url (a sub-url of Webtel.mobi), each Eligible Entity may also elect to obtain its own Standalone url, as follows:
1. The Standalone url is separate from the Webtel.mobi sub-url
Whereas the Free Unique url given to each Eligible Entity’s VSMP by Webtel.mobi is a sub- url of Webtel.mobi, the Standalone url is a completely separate url.
For example if a VSMP’s name is EXAMPLE, then
The Webtel.mobi assigned Free and Unique url will be: www.example.webtel.mobi
The Standalone url would be: www.exampletel.mobi
2. The Standalone url is not free and is not issued by Webtel.mobi
The Standalone url is not a free url, is not issued by Webtel.mobi, and is not hosted by Webtel.mobi.
To acquire a Standalone url, during the VSMP Creation process, the person creating the VSMP will be given the opportunity to select to acquire a Standalone url from an external company to Webtel.mobi.
If he/she does so, he/she will be redirected – during the process – to a url-acquisition site of the external company, where he/she will be able to select and pay for the Standalone url himself/herself.
This acquisition will be a separate agreement with the company providing the Standalone url.
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3. Restrictions regarding Standalone url selection
When selecting a Standalone url, only the company that the VSMP creator is redirected to may be used to acquire the Standalone url for a VSMP.
Webtel.mobi / the TEL.mobi Group has no commercial relationship with that external company. It is merely that integration work to point that url to the VSMP must be done after its creation, and this is why only that company can be used.
The Standalone url must end with the suffix “tel.mobi” (i.e. a “.mobi” domain must be selected).
The same conditions regarding the 3 character minimum length and 8-character maximum length of the VSMP name must be adhered to.
On top of the 3 character minimum length / 8-character maximum length, the letters “tel” must be added on to the url name, to be conformant with VSMP name requirements.
There are three components to a Standalone url selection. For example, if the Eligible Entity wants a standalone url for a VSMP for which it has already selected the VSMP name “EXAMPLE”, the procedure would be as follows:
Type of domain selected: It must always be a “.mobi” domain (not .com / .net / other)
The VSMP name is the partial name selected: “example”.
Add the suffix “tel” to the VSMP name: Therefore “exampletel” is selected as the name.
The selected name combined with the .mobi domain type will be: www.exampletel.mobi
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4. Other important considerations regarding Standalone urls
All VSMPs are issued with a Free and Unique Webtel.mobi sub-url, and have their VSMP hosted free by Webtel.mobi – regardless of whether or not they additionally acquire their own Standalone url for their VSMP. Therefore, if an Eligible Entity acquires a Standalone url, it will have two urls for its VSMP – the Free and Unique Webtel.mobi sub-url, and the Standalone url.
If an Eligible Entity loses its Standalone url through non-payment or for any other reason, this will not affect its VSMP on the Free and Unique Webtel.mobi sub-url, or the free hosting of the VSMP on the Webtel.mobi sub-url.
If an Eligible Entity does not acquire a Standalone url during the initial VSMP Creation process, this part of the VSMP can be it can edited to acquire a Standalone process at any time, via the VSMP Administration Console (for Eligible Entities) or the Independent Agent Administration Console (for Independent Agents).
The Eligible Entity is responsible for payment, upkeep and all other contractual requirements with the company from which it acquires the Standalone url.
Although the Standalone url is the property of the Eligible Entity that acquires it, the Eligible Entity will be required – as part of the VSMP Creation process – to agree to assign the Standalone url to Webtel.mobi on demand. This is because although the Standalone url belongs to the Eligible Entity, it points to a TEL.mobi Group VSMP (its only purpose), and back-end integration is done by the TEL.mobi Group for all Standalone urls to enable them to point to the VSMP. As such, for security reasons, this agreement to assign the Standalone url to Webtel.mobi must be done or the Standalone url will not be pointed to the VSMP. Webtel.mobi will not request assignation of the Standalone url unless there is a breach of the Terms & Conditions / other infraction by the Eligible Entity.
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SECTION 4
ADDITIONAL
REVENUE GENERATION
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ADDITIONAL OPTIONAL
REVENUE-GENERATING OPPORTUNITIES
FOR
ELIGIBLE ENTITIES
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ADDITIONAL OPTIONAL REVENUE-GENERATING OPPORTUNITIES FOR ELIGIBLE ENTITIES
Further Optional Opportunities for Revenue-Generation are available to TEL.mobi Group Eligible Entities that have VSMPs. These Optional Opportunities include the following:
A. Discounted Redemptions of ICLM Transactions for TMG Members:
TEL.mobi Group Members sometimes choose to redeem their Stored Credit from an ICLM Transaction at a discount from a TEL.mobi Group Eligible Entity’s VSMP. This is especially for persons receiving remittances. In such cases, the Members do a Stored Credit Swap with the Eligible Entity’s VSMP. The Eligible Entity / VSMP then provides the Members with the money equivalent of the Top-up Voucher amount, less a fee, which the Eligible Entity / VSMP keeps as a service charge. In areas or situations where applicable, Eligible Entities that have VSMPs may carry out Discounted Redemptions, and charge their own percentage fee for such Discounted Redemptions. In such cases, it must be made clear to Members that the fee is being charged by the Eligible Entity / VSMP, and is unrelated to the TEL.mobi Group. These percentage fees are for the Eligible Entity / VSMP only, and not for the TEL.mobi Group.
B. Reselling Electronic Top-Up Vouchers to TEL.mobi Group Members:
Although the TEL.mobi Group recommends resale of the Electronic Top-Up Vouchers at their face value, Eligible Entities that have VSMPs may purchase Electronic Top-Up Vouchers via their VSMP Administration Consoles for resale. They may resell them to TEL.mobi Group Members with a mark-up, in areas or situations where applicable. In such cases, the Eligible Entity / VSMP must make it clear to Members that the mark-up is being charged by the Eligible Entity / VSMP, and is unrelated to the TEL.mobi Group, or to the face value of the Top-up Voucher. These mark-ups are for the Eligible Entity / VSMP only, and not for the TEL.mobi Group.
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C. Assisting TMG Members to obtain Substitute KYC at Attorneys/Notaries:
On occasion, TEL.mobi Group Members may want to obtain Substitute KYC for their use of the TEL.mobi System in order to enable Refund Transfers and/or Discounted Redemptions of ICLM Transactions. In cases where Members find this difficult to do for reasons of Illiteracy, partial literacy or financial constraints, Eligible Entities that have VSMPs may – at their election – assist these Members to obtain their Substitute KYC Verified and Certified by Attorneys or Notaries. The methodology applied by Eligible Entity / VSMP in such circumstances will vary from situation-to- situation, and will be at the sole discretion and choice of the Eligible Entity / VSMP. Should a Member request such assistance, Eligible Entities / VSMPs may charge the Member for providing such assistance. All fees charged for this assistance are to be set by Eligible Entities themselves, and it should be made clear to Members that the Fees are being charged by the Eligible Entity / VSMP, and are unrelated to the TEL.mobi Group. These Fees are for the Eligible Entity / VSMP only, and not for the TEL.mobi Group.
D. Obtaining and Placing of TMG Stored Credit Refund Machines (SCRMs):
When the TEL.mobi Group makes its Loyalty Card Facility live, the Loyalty Cards will be linked to Stored Credit Refund Machines (SCRMs), from which Members can do Stored Credit Refund Withdrawals in cash, for limited amounts, from their online Stored Credit on their TEL.mobi Accounts. Eligible Entities that have VSMPs may apply to have SCRMs placed at their premises – or premises arranged by them – at which Members may do Stored Credit Refund Withdrawals. There is a small charge levied on Members for making such Stored Credit Refund Withdrawals from SCRMs, which charges are shared between the TEL.mobi Group and the Eligible Entities / VSMPs that have the SCRMs from which the Stored Credit Withdrawals are made.
E. Distribution of Additional TMG Services and/or Products in future:
In the future, the TEL.mobi Group may distribute additional goods and services internationally, and Eligible Entities that have VSMPs will have the option to participate in these distribution activities as they are rolled out.
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TOP-UP VOUCHER
ACQUISITION AND RESALE
BY
ELIGIBLE ENTITIES
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TOP-UP VOUCHER ACQUISITION AND RESALE BY ELIGIBLE ENTITIES
A. Top-Up Voucher Order and Acquisition:
1. Top-Up Vouchers can be acquired by any TEL.mobi VSMP through their Administration Console, from the “Order New Top-Up Voucher” Facility:
2. The ordering and delivery processes are secure, fully automated, and rapid.
3. Top-Up Vouchers must be pre-ordered from Webtel.mobi, and can only be ordered by TEL.mobi Independent Agents or VSMPs.
4. Webtel.mobi does not accept cash, so Top-Up Vouchers need to be acquired using one of these three methods:
Purchase via a Payment Gateway. If purchasing via a Payment Gateway, there is a 72 Hour “Clearance Period” before the Top-Up Vouchers are issued (sufficient time to eradicate the risk of a Chargeback to Webtel.mobi by the purchaser after Top-Up Vouchers have been bought and resold). The Top-Up Vouchers on order can be seen by the VSMP in the “Top- Up Vouchers in Process” Facility until the 72 hour “Clearance Period” has passed. Once this period has passed, the Top-Up Vouchers are automatically moved into the “Top-Up Vouchers in Stock” Facility, where the VSMP can access and resell them immediately.
Purchase via a Bank Transfer / Wire Transfer to Webtel.mobi. If purchasing via a Bank Transfer / Wire Transfer, the Top-Up Vouchers are issued upon clearance into Webtel.mobi’s Account of the funds for Top-Up Voucher acquisition. The Top-Up Vouchers on order can be seen by the VSMP in the “Top-Up Vouchers in Process” Facility until the transferred funds have cleared into Webtel.mobi’s Account. Once the funds have cleared into Webtel.mobi’s Account, the Top-Up Vouchers are automatically moved into the “Top- Up Vouchers in Stock” Facility, where the VSMP can access and resell them immediately.
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Purchase via existing Stored Credit in the VSMP’s own TEL.mobi Account. If purchasing via a Bank Transfer / Wire Transfer, the Top-Up Vouchers are issued immediately, and are instantly placed into the “Top-Up Vouchers in Stock” Facility, where the VSMP can access and resell them with immediate effect.
5. Top-Up Vouchers can be acquired in any Currency, in any Denominations of Value and for any Amount/s. The Denominations are automatically selectable in Denominations of Value from 5
up to 100. For higher Denominations of Value, the Denomination of Value must be written in:
6. The Top-Up Vouchers are Electronic Vouchers – each Voucher Number represents a Specific Value in a Specific Currency, which is clearly listed. Once the VSMP has them In Stock, they can
be retrieved and on-sold at any time.
7. Each Voucher Number has a Voucher Key attached to it. The Voucher Number with separate Voucher Key forms part of the Blockchain-based security system for Top-Up Vouchers. Without simultaneous insertion of the Voucher Key, the Top-Up Voucher cannot be redeemed. Similarly, after a Voucher has been acquired by a Member, he/she can alter the Voucher Key if he/she does not load the Voucher immediately, so that only he/she will be able to load the Voucher (this is to protect against double-sales of Vouchers and/or Sellers loading Vouchers onto their own accounts after they have sold them). 264
B. Top-Up Voucher Resale:
1. Resale Price
Webtel.mobi recommends that the Top-Up Vouchers be resold at their face value only.
However, it is up to each VSMP to set their own terms for resale of the Top-Up Vouchers. The Market Conditions and Circumstances differ from VSMP to VSMP, and each one is able to set his or her own resale terms.
Examples of some of the different resale terms provided by TEL.mobi Group VSMPs are as follow:
Vouchers are resold at their Face Value.
Vouchers are resold at their Face Value to a VSMP’s own Members, and with a mark-up to Members who are from other VSMPs.
Vouchers are resold with a mark-up of a flat fee mark-up per Voucher.
Vouchers are resold at a percentage value of the Voucher as a mark-up fee.
VSMPs are free to make their own choices regarding the Resale Price. They should bear in mind that there will be competition from other Independent Agents and VSMPs.
Mark-ups should not be unreasonably or exploitatively high – as this will trigger an intervention from and by Webtel.mobi.
2. Resale Method
VSMPs have a variety of options for the methodology used to transmit the Top-Up Vouchers to Members during resale.
The methods are as follow:
Printing the Voucher: The Voucher Number and Voucher Key can be Printed out onto paper type / quality / appearance of the Reseller’s choice, and handed to the Member on sale.
Emailing the Voucher: The Voucher Number and Voucher Key can be Emailed to a Member by the Reseller.
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Texting the Voucher: The Voucher Number and Voucher Key can be Texted to a Member by the Reseller.
Writing Out / Entering for Member: If selecting the “Manually View Voucher” option, Resellers can see the Voucher Number and Voucher Key in large size, and can either Write it Out for the Member, or Enter it for the Member in the Member’s Account (especially relevant in some Unbanked markets where there are low levels of literacy).
The selection of the method will vary according to the Market-Type and Circumstances of the VSMP / Member / Location of applicability. It will also depend on the relationship that the VSMP has with the Member/s to whom they are Reselling the Top-Up Voucher/s. The choice of which method to use is theirs.
3. Important and Cautionary Points
If Members wish to acquire large denomination Top-Up Vouchers (i.e. larger than the standard Denominations of up to 100), VSMPs must ask them why they need larger denomination Top-Up Vouchers.
If it is for Unbanked Persons who are engaged in Migratory Work, VSMPs should ask them to prove their status prior to providing the Members with large denomination Top-Up Vouchers (i.e. by pay slip, letter from employer or some other form of proof that they are working at the location and are being paid in cash).
If it is for a large ICLM Transaction from a Business to a Business, VSMPs should again ask for proof of this Transaction.
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If it is for a large value made up of a large number of small Denomination Top-Up Vouchers to/for one person and/or one entity, VSMPs should establish why this is being requested in this format. They should also establish what the purpose is of acquiring multiple small denomination Top-Up Vouchers as opposed to one large one (i.e. they are to be used as payments / prizes / etc; these are valid requests, but they must be proven).
If VSMPs are not satisfied with the answers or do not receive proof, they should not sell / resell Top-Up Vouchers under such circumstances. They do not have to sell or resell Top- Up Vouchers to any person or entity if they do not want to.
It is very important to realize that Webtel.mobi will monitor and see all and any such occurrences on the TEL.mobi Group Platform. If a Transaction arouses suspicion, and the VSMP is unable to provide a satisfactory answer (with proof) to Webtel.mobi regarding these matters in the event of a resulting enquiry, then the VSMP will run the risk that the TEL.mobi Account of the relevant Member could frozen and handed over to the GBA for investigation. Moreover, the TEL.mobi Account of the VSMP who made the sale of the Top- Up Vouchers may also be frozen and referred to the GBA for investigation.
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DISCOUNTED REDEMPTIONS
OF
ICLM TRANSACTIONS BY
ELIGIBLE ENTITIES
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DISCOUNTED REDEMPTIONS OF ICLM TRANSACTIONS BY ELIGIBLE ENTITIES
A. Overview:
TEL.mobi Group VSMPs can provide Discounted Redemptions of ICLM Transactions. This is not a Webtel.mobi and/or TEL.mobi Group Service, but rather an independent activity by VSMPs, as follows:
1. Discounted Redemptions are where a VSMP allows its Members to carry out an ICLM Transaction to the VSMP Contact Person’s (or other Nominated) TEL.mobi Accounts, and then provides the Transferring Member with money to the value of the ICLM Transaction, at a discount. That is, the VSMP gives the Member less money than the total of Stored Credit transferred – the difference being the VSMP’s mark-up for providing this service.
2. VSMPs set their own Discounting terms for such Discounted Redemptions, which are either a flat fee or a percentage of the Stored Credit transferred. They also set their own terms for the Currency in which the Member should implement the Top-Up / ICLM Transaction.
3. VSMPs in areas where a significant percentage of the local population is unbanked and/or a significant percentage of the local populations receive Remittances from family members working abroad and/or there are no infrastructural facilities usually provide this service.
4. Although this is an independent activity that VSMPs elect to do of their own volition because it is a very profitable business model – and simultaneously also a service to the local community – the fact that they are TEL.mobi Group VSMPs brings this activity firmly within the realm of Webtel.mobi’s oversight.
5. As such – regardless of the fact that VSMPs do this as an independent activity – the Rules regarding Top-Up / ICLM Transaction Discounted Redemptions as described in the next section overleaf apply, and must be adhered to:
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B. Rules – Appropriate Situations:
1. The only appropriate situations for such Discounted Redemptions are:
Appropriate Situation 1: For Unbanked Persons, especially Unbanked Persons who receive Remittances from family members working abroad.
Appropriate Situations 2: If other credible situations present themselves, the Members in such situations can be provided with this service – or not – depending on their compliance with the various Rules, and the sole decision of the VSMP (which service can be denied by the VSMP, at his/her sole discretion, even if Members comply with the Rules). The term “other credible situations” refers specifically and only to the following understandably credible situations:
Members who have recently immigrated and not yet set up a Bank Account in-country,
Electricity failures that temporarily shut down conventional systems to Members,
Members travelling abroad who have lost their wallets / cards or had them stolen,
Members travelling on a budget who wish to avoid unfavorable exchange rates,
Members caught up in an Emergency Situation / Natural Disaster Situation,
Lack of infrastructure in a rural area / developing country – that would otherwise necessitate long travelling distances to a standard retrieval system for Members.
2. If a Member does not fall into one of the “Appropriate Situations 2” categories listed above, and/or has a Bank Account, and/or is obviously / visibly wealthy or well-off; there is no credible reason for them to seek a Discounted Redemption. Such a situation should be regarded as suspicious, and such a Member should not be provided with a Discounted Redemption possibility.
3. Members who do fall into one of the “Appropriate Situations 2” categories, but who nevertheless arouse suspicion, should also not be provided with a Discounted Redemption
possibility.
4. Any Members – in either of the “Appropriate Situation” categories – who cannot comply with the Rules, or who otherwise arouse suspicion, should not be provided with a Discounted Redemption possibility.
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C. Rules – Specific Process for First-Time Discounted Redemptions:
When VSMPs carry out their first Discounted Redemption for a Member, there is a procedure that needs to be followed. This procedure is designed to:
1. Protect the VSMP.
2. Protect the Member.
3. Protect the TEL.mobi Group.
4. From the potential for Money Laundering attempts, fraud, loss and/or any claims or counterclaims by one party against another.
5. To ensure an efficient, safe and satisfactory experience for all parties involved.
As such, these First-Time Processes should be diligently adhered to.
Once the First-Time Processes have been successfully completed, Follow-Up Transactions entail fewer requirements, and are more rapid to implement.
The Rules for First-Time Discounted Redemptions are as follow overleaf:
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1. When Photo ID and a Utility Bill are Present
Members should be handed an Application Document (with the Member Information section also attached to it), informed of the Maximum Amount that they can Redeem and asked to complete it within sight of the VSMP Representative (Note: Hereinafter VSMP Representative = “VSMP”).
(This is because all required information in the Application Document can be obtained from the Member’s TEL.mobi Account on the spot. If the Member is not able to fill in the information on the spot, it indicates that he/she is unable to Log in to his/her TEL.mobi Account, which is a suspicious event, and the VSMP should refuse to carry out the Transaction).
Once the Application Document has been completed, it should be handed to the VSMP for review. During the First-Time process, the Application Document review will be carried out by comparing information on the Application Document with information on the Member’s TEL.mobi Account.
(This is to ensure that the Member is carrying out the Transaction from his/her own TEL.mobi Account).
Firstly, the VSMP should ask the Member to Log Out of their TEL.mobi Account in a way that the VSMP can see the Logout icon being clicked and the logout take place. Once that has been done, the VSMP should ask the Member to Login again while in sight of the VSMP. The Member should be advised to obscure the face of the Mobile Phone while logging in to protect his/her Password. If the VSMP has CCTV coverage, the Member must be made aware of this and advised to obscure the face of the Mobile Phone from above while logging in.
(This is done to ensure that the Member is using his/her TEL.mobi Account and not a stolen Mobile Phone / Account. If the Member is unable to login / does not know the Login Username and Password, this is suspicious, and the Transaction should be refused).
The VSMP should then review the Application Document with the Member standing in close proximity so that the VSMP can see the Member’s TEL.mobi Account details on his/her Mobile Phone. The VSMP should never take the Member’s Mobile Phone into their own hands, and should just ask the Member to navigate to pages as required so that the VSMP can see the relevant page for comparisons.
(The VSMP must never handle the Member’s Mobile Phone to protect the VSMP from any future claims of malfeasance on the Member’s TEL.mobi Account from/by the Member). 272
The VSMP should then review the Member’s Name / Surname / ITAN Number / Primary Mobile Number as provided in the Application Document against those in the “My Details” Facility of the Member’s TEL.mobi Account.
(This is to ensure that the Member is providing his/her own Account details, and will be carrying out the Transaction from his/her own Account. If the details in the Application Document and the “My Details” Facility do not match, this is suspicious, and the Transaction should be refused).
The VSMP should then review the Details of the Top-Up Transfer / ICLM Transaction made to the Member (i.e. the source of the Stored Credit that the member is Redeeming). This can be compared using the information in the Application Document (Sender’s Name / Surname / ITAN Number / Primary Mobile Number / Transaction Number) against the information in the “Incoming Top-Up Transfers / ICLM Transactions History” Facility of the Member’s TEL.mobi Account.
(This is to ensure that the Member has provided true details about the source of his/her Stored Credit that he/she wishes to Redeem. If the details in the Application Document and the “Incoming Top-Up Transfers / ICLM Transactions” Facility do not match, this is suspicious, and the Transaction should be refused).
If all of these actions proceed without any suspicious events until this point, the Member’s Photo ID and Utility Bill should be photocopied, and attached to the Application.
At that time, the VSMP should request the Member to carry out an ICLM Transaction to the VSMP’s TEL.mobi Account. This must be done while the Member is in sight of the VSMP. The Member should be instructed to carry out the Transaction with a Text Confirmation being sent to both the Member and the VSMP. This ICLM Transaction with Text Confirmation should then be carried out.
(The Member must remain in sight to ensure that he/she does this Transaction from his/her Mobile Phone himself/herself, from the TEL.mobi Account that has just been checked. The Text Message Confirmation is to be sent to both parties so that the VSMP can visually and audibly confirm that the Registered Mobile Number and Mobile Phone that is being used for the Transaction is the Number that is in the Application Document. The VSMP should also check that the ITAN Number and Member Name in the Confirmation Texts on his/her Text Message and the Text Message received by the Member are identical, and are the same as on the Application Document, and that the ICLM Amount is the amount that was agreed to. If the Sending Mobile Number that the VSMP receives in the Confirmation Text – or the Member Name or ITAN Number – are not the same as the one which is on the Application Document, this is suspicious. In this situation, the Transaction should be returned directly to the details from which they were sent in an ICLM Transaction 273
(Transaction Costs to the other party) and the Transaction refused. If either the VSMP or the Member do not receive a Confirmation Text, the procedure in the next point should be followed).
If the Member or the VSMP does not receive a Confirmation Text within a maximum of 5 seconds of the Transaction being carried out, this can be due to congestion in the local Mobile Provider’s systems, which are becoming increasingly clogged in many countries, and which consequently sometimes delay Text Delivery Transmission in a queue for long periods. In such a case, the VSMP should:
Review his/her “Incoming Top-Up Transfer / ICLM Transaction” Facility to ensure that the Sender’s Registered Mobile Number / ITAN Number / Member Name are the same as on the Application Document and the Amount is as agreed.
Check the Member’s “Outgoing Top-Up Transfer / ICLM Transaction” Facility on the Member’s Mobile Phone (without touching it himself/herself) to confirm that the mirror Transaction details are there.
(If the Sending Mobile Number that the VSMP views in his/her “Incoming Top-Up Transfer / ICLM Transaction” Facility – or in the Member’s “Outgoing Top-Up Transfer / ICLM Transaction” Facility – are not identical, and/or they differ from the details in the Application Document, this is suspicious. The Transaction should then be returned directly to the details from which they were sent in an ICLM Transaction (Transaction Costs to the other party) and the Transaction refused. If all is in order, continue).
At this stage, the Process as required under the TEL.mobi Group’s oversight – geared towards protecting Members / VSMPs / Anti Money Laundering requirements – is over.
The VSMP can continue with whatever his/her other personal procedures / requirements are, and then carry out the Discounted Redemption Transaction.
Any specific comments that the VSMP may have about Transactions for that particular Member should be recorded in the “Comments” section of the Application Document (see the Paragraph in this Section entitled “Special Circumstances & their Recording”).
All original Transaction Documentation is to be retained by the VSMP for a period of three years from the time of the Transaction.
Copies of all Transaction Documentation must be scanned into the VSMP’s PC, and selected copies of the Transaction Documentation must be regularly uploaded to the VSMP’s TEL.mobi Account as detailed in the “Refund Transfers” section.
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2. When Photo ID without Utility Bill is Present
The Procedure is almost the same as when Photo ID and Utility Bill are present.
The only differences are that:
The Amount that is able to be redeemed is lower (see the Paragraph in this section entitled Section entitled “Rules – Amount Limits”).
Only the Photo ID is photocopied and retained.
3. When “Substitute KYC” is Present
The Procedure is almost the same as when Photo ID and Utility Bill are present.
The only differences are that:
The Amount that is able to be redeemed is lower (see the Paragraph in this section entitled Section entitled “Rules – Amount Limits”).
The “Substitute KYC” Document is photocopied and retained.
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4. When No Photo ID, No Utility Bill and No “Substitute KYC” are Present
Members should be handed an Application Document (with the Member Information section also attached to it), informed of the Maximum Amount that they can Redeem and asked to complete it within sight of the VSMP Representative (Note: Hereinafter VSMP Representative = “VSMP”).
(This is because all required information in the Application Document is able to be obtained from the Member’s TEL.mobi Account on the spot. If the Member is not able to fill in the information on the spot, it indicates that he/she is unable to Log in to his/her TEL.mobi Account, which is a suspicious event, and the VSMP should refuse to carry out the Transaction).
Once the Application Document has been completed, it should be handed to the VSMP for review. During the First-Time process, the Application Document review will be carried out by comparing information on the Application Document with information on the Member’s TEL.mobi Account.
(This is to ensure that the Member is carrying out the Transaction from his/her own TEL.mobi Account).
Firstly, the VSMP should ask the Member to Log Out of their TEL.mobi Account in a way that the VSMP can see the Logout icon being clicked and the logout take place. Once that has been done, the VSMP should ask the Member to Login again while in sight of the VSMP. The Member should be advised to obscure the face of the Mobile Phone while logging in to protect his/her Password. If the VSMP has CCTV coverage, the Member must be made aware of this and advised to obscure the face of the Mobile Phone from above while logging in.
(This is done to ensure that the Member is using his/her TEL.mobi Account and not a stolen Mobile Phone / Account. If the Member is unable to login / does not know the Login Username and Password, this is suspicious, and the Transaction should be refused).
The VSMP should then review the Application Document with the Member standing in close proximity so that the VSMP can see the Member’s TEL.mobi Account details on his/her Mobile Phone. The VSMP should never take the Member’s Mobile Phone into their own hands, and should just ask the Member to navigate to pages as required so that the VSMP can see the relevant page for comparisons.
(The VSMP must never handle the Member’s Mobile Phone to protect the VSMP from any future claims of malfeasance on the Member’s TEL.mobi Account from/by the Member). 276
The VSMP should then review the Member’s Name / Surname / ITAN Number / Primary Mobile Number as provided in the Application Document against those in the “My Details” Facility of the Member’s TEL.mobi Account.
(This is to ensure that the Member is providing his/her own Account details, and will be carrying out the Transaction from his/her own Account. If the details in the Application Document and the “My Details” Facility do not match, this is suspicious, and the Transaction should be refused).
The VSMP should then review the Details of the Top-Up Transfer / ICLM Transaction to the Member (from which they obtained the Stored Credit that they are Redeeming) as provided in the Application Document (Sender’s Name / Surname / ITAN Number / Primary Mobile Number / Transaction Number). They should review and compare this information against the Details of the same Transaction in the Member’s “Incoming Top-Up Transfers / ICLM Transactions History” Facility of the Member’s TEL.mobi Account.
(This is to ensure that the Member has provided true details about the source of his/her Stored Credit that he/she wishes to Redeem. If the details in the Application Document and the “Incoming Top-Up Transfers / ICLM Transactions” Facility do not match, this is suspicious, and the Transaction should be refused).
If all of these actions proceed without any suspicious events until this point, the Member Should be asked to complete the “Photo Identification Form” (Available in Appendix 2). The Photo Identification Form is a form onto which the Member must write in large and Legible capital letters their
Name and Surname
Address
ITAN Number
Registered Mobile Number
The Member should then stand holding the “Photo Identification Form” at its bottom two corners, in front of the chest, with the Top of the form being just below the chin. The VSMP should then take a clear photograph of the Member holding the form, which photograph should show the Member’s face from the front, clearly, without spectacles or any hat / head / face covering – together with the “Photo Identification Form”. The Photo should be clear and visibly show the face as well as the Legible writing on the “Photo Identification Form”. Once this Photo has been taken, it should be printed out and attached to the Member’s Application Form.
(This is to have a record of the appearance of the Member in the event of any future enquiries, as well as the Member’s details – including the Member’s address – as he/she 277
provides it. This is to protect the VSMP in the future, because any false statement / details are then the responsibility of the Member, not the VSMP. For this reason, it is important that the Member – not the VSMP – fills out the information on the “Photo Identification Form”. It is preferable that – besides the Photo Identification Form – that the Member should have with him or her at least some form of Identification. This could be a Birth Certificate, letter from a Village Elder / Headman, etc. The TEL.mobi Group is aware of the fact that in many areas of the Developing World not even these documents are in the possession of persons in the “Highly Vulnerable Persons” category, and that there are high degrees of illiteracy. However, as VSMPs are local to the area, they will be aware of the occurrence – or not – of such documents / capabilities. If they are generally available or able to be obtained in the area where the Member resides, the VSMP should request that the Member obtain and bring with at least one of these documents for attachment to his/her Application Document. This is at the discretion of the VSMP).
Once the Photo Application Form photograph has been taken, the VSMP should request the Member to carry out an ICLM Transaction to the VSMP’s TEL.mobi Account. This must be done while the Member is in sight of the VSMP. The Member should be instructed to carry out the Transaction with a Text Confirmation being sent to both the Member and the VSMP. This ICLM Transaction with Text Confirmation should then be carried out.
(The Member must remain in sight to ensure that he/she does this Transaction from his/her Mobile Phone himself/herself, from the TEL.mobi Account that has just been checked. The Text Message Confirmation is to be sent to both parties to visually and audibly confirm that the Registered Mobile Number and Mobile Phone that is being used for the Transaction is the Number that is in the Application Document. The VSMP will be able to see this on the Confirmation Text that he/she receives, and from seeing and hearing the Member receive a Text simultaneously. The VSMP should also check that the ITAN Number and Member Name in the Confirmation Texts on both his/her Text Message and the Text Message received by the Member are identical, and are the same as on the Application Document, and that the Amount is that which was agreed to. If the Sending Mobile Number that the VSMP receives in the Confirmation Text – or the Member Names or ITAN Number – are not the same as the one which is on the Application Document, this is suspicious. In such a case, the Transaction should be returned directly to the details from which they were sent in an ICLM Transaction (Transaction Costs to the other party) and the Transaction refused. If either the VSMP or the Member does not receive a Confirmation Text, the procedure in the next point should be followed).
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If the Member or the VSMP does not receive a Confirmation Text within a maximum of 5 seconds of the Transaction being carried out, this can be due to congestion in the local Mobile Provider’s systems, which are becoming increasingly clogged in many countries, and which consequently sometimes delay Text Delivery Transmission in a queue for long periods. In such a case, the VSMP should:
Review his/her “Incoming Top-Up Transfer / ICLM Transaction” Facility to ensure that the Sender’s Registered Mobile Number / ITAN Number / Member Name are the same as on the Application Document and the Amount is as agreed.
Check the Member’s “Outgoing Top-Up Transfer / ICLM Transaction” Facility on the Member’s Mobile Phone (without touching it himself/herself) to confirm that the mirror Transaction details are there.
(If the Sending Mobile Number that the VSMP views in his/her “Incoming Top-Up Transfer / ICLM Transaction” Facility or in the Member’s “Outgoing Top-Up Transfer / ICLM Transaction” Facility are not identical – and/or they differ from the details in the Application Document – this is suspicious. In such a case, the Transaction should be returned directly to the details from which they were sent in an ICLM Transaction (Transaction Costs to the other party) and the Transaction refused. If all is in order, continue).
At this stage, the Process as required under the TEL.mobi Group’s oversight – geared towards protecting Members / VSMPs / Anti Money Laundering requirements – is over.
The Independent Agent / VSMP Representative can continue with whatever his/her other personal procedures / requirements are, and then carry out the Discounted Redemption Transaction.
Any specific comments that the Agent may have about Transactions for that particular Member should be recorded in the “Comments” section of the Application Document (see the Paragraph in this Section entitled “Special Circumstances & their Recording”).
All original Transaction Documentation is to be retained by the VSMP for a period of three years from the time of the Transaction.
Copies of all Transaction Documentation must be scanned into the VSMP’s PC, and selected copies of the Transaction Documentation must be regularly uploaded to the VSMP’s TEL.mobi Account as detailed in the “Refund Transfers” section.
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D. Rules – Specific Process for Follow-Up Discounted Redemptions:
The Rules and the Process for Follow-Up Discounted Redemptions are the same for all Members who have successfully completed a First-Time Discounted Redemption, and whose First-Time Application Document is retained by the VSMP. They are as follow:
1. Members should be handed an Application Document (with the Member Information section also attached to it), informed of the Maximum Amount that they can Redeem and asked to complete it within sight of the VSMP.
2. The VSMP should retrieve the Member’s First-Time Application Document, and compare it to the New Application Document.
3. If the details on the New Application Document are different to those on the First-Time Application Document, or if the Member does not resemble his/her appearance in the photo from the First-Time Application Document, this is suspicious, and the Transaction should be refused (The exception to this is if the Primary Mobile Number has changed, which is a possibility. In this case, the Transaction can go ahead – but it will have to go ahead in the format of a First-Time Transaction).
4. If the details on the New Application Document are the same as those on the First-Time Application Document, and the Member can be visibly recognized by the Photo ID / “Substitute KYC” Photo / “Photo Identification Document” Photo on the First-Time Application Document, the VSMP can proceed to the next step.
5. The VSMP should then review the Details of the Top-Up Transfer / ICLM Transaction to the Member (from which they obtained the Stored Credit that they are Redeeming) as provided in the Application Document (Sender’s Name / Surname / ITAN Number / Primary Mobile Number / Transaction Number). These should be reviewed against the Details of this Transaction in the Member’s “Incoming Top-Up Transfers / ICLM Transactions History” Facility of the Member’s TEL.mobi Account to ensure that they correspond.
6. At that time, the VSMP should request the Member to carry out an ICLM Transaction to the VSMP’s TEL.mobi Account. This must be done while the Member is in sight of the VSMP.
7. The VSMP can request the Member to include a confirmation by text – or not – at the VSMP’s discretion.
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8. The VSMP should then review either the text to him/her and to the Member – or his/her “Incoming Top-Up Transfer / ICLM Transaction” Facility and the Member’s “Outgoing Top-Up Transfer / ICLM Transaction” Facility – to ensure that the details replicate one another, and are the same as on the New Application Form.
9. At this stage, the Process as required under the TEL.mobi Group’s oversight – geared towards protecting Members / VSMPs / Anti Money Laundering requirements – is over.
10. The VSMP can continue with whatever his/her other personal procedures / requirements are, and then carry out the Discounted Redemption Transaction.
11. Any specific comments that the VSMP may have about Transactions for that particular Member should be recorded in the “Comments” section of the Application Document (see the Paragraph in this Section entitled “Special Circumstances & their Recording”).
12. The New Application Document is to be attached to the First-Time Application Document. All Transaction documentation is to be retained by the VSMP for a period of three years from the time of the Transaction. It may be scanned into a PC to save space.
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E. Rules – Amount Limits:
1. When Photo ID and a Utility Bill are Present
A Maximum of Euro 9 999.00 per month or equivalent in any currency is the limit (in one Transaction or multiple Transactions).
For a Maximum Period of three months, whether from one Independent Agent / VSMP or different Independent Agents / VSMPs.
After which the Recipients must provide credible written reason – with supporting documentation – that is accepted and supported by the Redeeming VSMP, as to why they are conducting Discounted Redemption activities instead of opening a Bank Account. If receiving Amounts of Euro 9 999.00 per month, it should be a compelling, credible and legal reason – to the satisfaction of the Redeeming VSMP – as to why a Bank Account is not being opened / used.
If an Amount higher than Euro 9 999.00 per month is requested to be done via a Top-Up Transfer / ICLM Transaction Discounted Redemption, full supporting documentation for any such Transaction, as well as a written motivation, must be provided by the Member and the Redeeming VSMP. With almost no exceptions, this would only credibly be potentially possible in the case of a foreign business with branches or business activities in- country, which has to remit payments to local staff. However, such requests must be rigorously examined, and should only be considered if they are able to be motivated with complete certainty and full – and fully verifiable – formal documentation from official entities.
The term “Photo ID and a Utility Bill” means specifically:
Photo ID = An original Government / State-issued Passport, ID Card / ID Book or Driver’s License, with a Photo, which Photo is a clearly obvious true likeness of the Member.
Utility Bill = A Physical Utility Bill, for Gas, Electricity, Water or Landline (not Mobile) Telephone, addressed to the Member’s Name and the Member’s Physical Address, less than two months old.
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2. When Photo ID without Utility Bill is Present
A Maximum of Euro 4 500.00 per month or equivalent in any currency is the limit (in one Transaction or multiple Transactions)
For a Maximum Period of three months, whether from one Independent Agent / VSMP or different Independent Agents / VSMPs.
After which the Recipients must provide credible written reason – with supporting documentation – that is accepted and supported by the Redeeming VSMP, as to why they are conducting Discounted Redemption activities instead of opening a Bank Account. It should be a compelling, credible and legal reason – to the satisfaction of the Redeeming VSMP.
In the event of dealing with Unbanked Persons and/or Unbanked Persons who are receiving Remittances from abroad and who are approaching a “Vulnerable Persons” socio-economic category, who generally do not have Utility Bills and are unlikely to ever be able to receive Utility Bills, and who are regularly receiving low-value Remittances, and wish to continue with this process for longer than a three-month period, then such persons should provide:
The written explanation of why they are not obtaining a Bank Account.
A written and signed confirmation from the person that sends the Remittances to them, sent by post or email to the Member for transmission to the Redeeming VSMP, or by email directly to the Redeeming VSMP, less than two weeks old (see the Documents in the Appendixes Section).
Should complete – and have verified and Certified – the “Substitute KYC” Document prior to being able to continue with such a Redemptions Process for longer than a three month period.
No amount higher than Euro 4 500.00 per month (in one Redemption or multiple Redemptions) can ever be provided if the Member only has Substitute KYC documents and a Photo ID without a Utility Bill.
The term “Substitute KYC” means specifically:
The specific “Substitute Personal Address and KYC” Document,
as available on the “Upload KYC” Facility on the TEL.mobi Group Sites,
which has been verified and Certified by an Attorney or Notary,
and which is presented in original,
which Attorney or Notary the Redeeming VSMP has personally telephoned to confirm the existence and bona fides of, and the bona fides of the Verified “Substitute Personal Address and KYC” Document to the Redeeming VSMP’s personal satisfaction. 283
3. When “Substitute KYC” is Present
A Maximum of Euro 4 500.00 per month or equivalent in any currency is the limit (in one Transaction or multiple Transactions).
For a Maximum Period of three months, whether from one Independent Agent / VSMP or different Independent Agents / VSMPs.
After which the Recipients must provide a credible written reason – with supporting documentation – that is accepted and supported by the Redeeming VSMP, as to why they are conducting Discounted Redemption activities instead of opening a Bank Account. It should be a compelling, credible and legal reason – to the satisfaction of the Redeeming VSMP.
In the event of dealing with Unbanked Persons and/or Unbanked Persons who are receiving Remittances from abroad and who are in a “Vulnerable Persons” socio-economic category, who generally do not have other KYC Documents and are unlikely to ever be able to acquire other KYC Documents, and who are regularly receiving low-value Remittances, and wish to continue with this process for longer than a three-month period, then such persons should provide:
The written explanation of why they are not obtaining a Bank Account.
A written and signed confirmation from the person that sends the Remittances to them, sent by post or email to the Member for transmission to the Redeeming VSMP or by email directly to the Redeeming VSMP, less than two weeks old (see the Documents in the Appendixes Section).
No amount higher than Euro 4 500.00 per month (in one Redemption or multiple Redemptions) can ever be provided if the Member only has Substitute KYC documents and not a Photo ID and Utility Bill.
The term “Substitute KYC” means specifically:
The specific “Substitute Personal Address and KYC” Document,
as available on the “Upload KYC” Facility on the TEL.mobi Group Sites,
which has been verified and Certified by an Attorney or Notary,
and which is presented in original,
which Attorney or Notary the Redeeming VSMP has personally telephoned to confirm the existence and bona fides of, and the bona fides of the Verified “Substitute Personal Address and KYC” Document to the Redeeming VSMP’s personal satisfaction.
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4. When No Photo ID, No Utility Bill and No Substitute KYC are Present
A Maximum of Euro 300.00 per week or equivalent in any currency is the limit (in one Transaction or multiple Transactions).
For a Maximum Period of three weeks (in-total – whether consecutively or staggered), whether from one Independent Agent / VSMP or different Independent Agents / VSMPs.
After which the Recipients must provide a credible written reason – with supporting documentation – that is accepted and supported by the Redeeming VSMP, as to why they are conducting Discounted Redemption activities instead of opening a Bank Account. It should be a compelling, credible and legal reason – to the satisfaction of the Redeeming VSMP.
In the event of dealing with Unbanked Persons and/or Unbanked Persons who are receiving Remittances from abroad and who are in the “Highly Vulnerable Persons” socio- economic category, who generally do not have other KYC Documents and are unlikely to ever be able to acquire other KYC Documents, who do not have the spare money to pay for an Attorney or Notary to Verify and Certify their “Substitute KYC”, and who wish to continue with this process for longer than a three-week period, then such persons should provide:
The written explanation of why they are not obtaining a Bank Account.
A written and signed confirmation from the person that sends the Remittances to them, sent by post or email to the Member for transmission to the Redeeming VSMP or by email directly to the Redeeming VSMP, less than two weeks old (see relevant Document in Appendix 2).
In such cases it is recommended that the Redeeming VSMP considers arranging a process with a local Attorney / Notary for Verification and Certification of “Substitute KYC” Documents for such persons, according to terms by which they can pay off the cost to the VSMP and/or the local Attorney / Notary (terms dependent on an agreement between the Member and the Redeeming VSMP, or between the Member and the Attorney / Notary).
In such cases, it is generally not possible for people in this socio-economic category to afford for “Substitute KYC” Documents to be Verified and Certified unless they are able to pay off the cost in small amounts over a period, As such, if Redeeming VSMPs wish to continue to provide this service to such Members over the three-week cut-off period, it will be in their interests to assist the Members to be able to do so.
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Once a Member has obtained a Verified and Certified “Substitute KYC” Document, he/she reverts to the Rules for Limits applicable to persons with “Substitute KYC” Documents, as described earlier in this section.
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F. Rules – ICLM Descriptions, Special Circumstances and Field Trips:
1. ICLM Descriptions
All ICLM Transactions from Members to IAs / VSMPs are to carry the description “REDEMPTION” in Capital letters, follow by the last six Numbers of the VSMP Number.
For example “REDEMPTION123456”
This is to be clearly displayed to the Member in a “Detailed ICLM Acceptance Notification” at the Location where the IA / VSMP carries out these activities, as follows:
We Accept TEL.mobi ICLMs
ITAN: WM11111111111111111111
Mobile: +00 01010 010 010
Description: REDEMPTION123456
Transfer Fee: For your Account
Transfer Currency: GBP
Confirmation by Text: Yes
2. Special Circumstances
In some areas of some Developing World countries there are high levels of illiteracy and low levels of tech/mobile-literacy. This is especially the case in circumstances where persons in the “Highly Vulnerable Person” socio-economic category are concerned.
In such situations, it is often customary practice that where an elderly person is the owner of the TEL.mobi Account but is not tech-literate, a younger person – often a family member – will be assisting this elderly person.
Similarly, it is also often customary practice that a young tech-literate person will be made the owner of the TEL.mobi Account, and will have an older person – often a family member – assigned to assist this young person.
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As VSMPs are local to the Member and/or know the market in which their Members function, they will be aware of such circumstances, and familiar with them. In such cases, as long as the VSMP has asked the necessary questions and made the necessary observations – to their satisfaction – that it is a case of assistance and not of coercion; then it will be acceptable for the one to assist the other during a Discounted Redemption Transaction.
3. Field Trips
In Developing Country situations where a large segment of the population lives in rural areas far away from towns or villages, and cannot afford to travel to the location of the VSMP, the VSMP’s Representatives may make Field Trips to such Rural Areas to assist the Local Population with Discounted Redemptions.
This is solely the choice of the VSMP, who will be responsible for his/her own decisions and security in such circumstances.
If doing so, the VSMP must nevertheless carry out the full procedures as listed previously in this section for First-Time Applications and/or Follow-Up Applications. This includes the requirement for taking “Photo Identification Document” Photographs, and affixing them to the relevant Application Documents when returning to his/her office.
G. Support for TEL.mobi Group VSMPs:
Although the Discounted Redemption service is not a TEL.mobi Group Service or Product, and is a private activity undertaken by VSMPs of their own volition, it is nevertheless acknowledged by the TEL.mobi Group that this service especially assists Members who are in the Vulnerable Persons and Highly Vulnerable Persons socio-economic categories. As such, Webtel.mobi will – on request – provide as much support as is appropriate to VSMPs in respect of their provision of these services.
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H. Cautionary Comment for TEL.mobi Group VSMPs:
A general cautionary comment on these matters is that it is recommended that any VSMP/s that wish to provide a Discounted Redemption service to TEL.mobi Group Members ensure that they comply with all and any laws and regulations applicable in their area.
Generally-speaking, this is a voluntary service, provided by VSMPs in a voluntary capacity, to co- Members of a Closed Loop system, where they are merely swapping value in terms of receiving a co-Member’s Stored Credit in return for providing the co-Member with money to the equivalent value of the Stored Credit, with a discount. It will therefore be considered a private activity in many jurisdictions. Nevertheless, VSMPs are advised to make such enquiries as they may deem relevant regarding their own particular circumstances.
Insofar as Webtel.mobi-related cautionary comments are concerned, the following is applicable:
1. Following of Procedure – Protection against Fraud and/or Money Laundering
VSMPs are advised to follow the procedures as described in this section completely, in order to protect themselves from incidences of potential fraud and/or attempted Money Laundering.
2. Following of Procedures – Protection
The Webtel.mobi / TEL.mobi Group System and Platform is a Unitary System.
This means that every Transaction that occurs on it can be seen, verified and followed – wherever, however and by whoever it is initiated, wherever, however and through whoever it is routed, and wherever, however and through whoever it ends.
It is not possible, on the Webtel.mobi / TEL.mobi Group Platform to ever hide, disguise, layer or otherwise obscure any person / action / process / event.
For this reason, it is extremely important that VSMPs apply the Procedures as previously described in the section most diligently.
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This is because if any Member is ever found to have engaged in an illegal activity, and the Stored Credit has exited the System via a Discounted Redemption but the processes have not been diligently followed (meaning that the relevant Member cannot be followed up with), then:
It will be the TEL.mobi Account and Stored Credit of the VSMP’s Representatives / Contact Persons who provided the Discounted Redemption that will be frozen and potentially seized.
It will be the VSMP’s Representative / Contact Persons who [provided the Discounted Redemption that will be reported to the GBA for investigation.
3. Attempted Money Laundering
No person or entity should attempt to utilize this system or these processes for attempted Money Laundering.
As has been extensively explained, the Webtel.mobi / TEL.mobi Group Platform is a Unitary Platform. No Transactions types / flows / persons / processes can be hidden or obscured.
Moreover, every single Transaction can be tracked by Member / Independent Agent / VSMP / Date / Time / Location from inception – be it via Bank Transfer / Payment Gateway / Top-Up Voucher – to its conclusion; no matter what is done with it or where / through whom it passes en-route. It is not possible to layer, obscure or hide these flows.
Other than this, Webtel.mobi has a global view of all Transactions, and is therefore able to see and establish patterns – and patterns that are unusual compared to others – either instantly or very rapidly.
As has also been extensively explained, although Webtel.mobi takes the Privacy Rights of its Members seriously, it also takes the maintenance of law seriously. As such, if the incidence of attempted Money Laundering is suspected, Webtel.mobi will hand the matter over to the GBA for investigation, and may freeze the Account of any Member – including VSMPs – in such a case. Moreover, Webtel.mobi will cooperate with any formal Government / Government-mandated law-enforcement / regulatory agency that provides the required formal legal documentation for information of a Member – including a Member who is a VSMP.
There is no need to attempt to engage in incorrect activities. The system is good enough to be profitable and of use to all parties purely by engaging in legal activities openly. 290
SECTION 5
ROLE OF THE
INDEPENDENT AGENTS
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ELIGIBLE ENTITY
ASSISTANCE FROM
AND
MONITORING BY
INDEPENDENT AGENTS
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ELIGIBLE ENTITY ASSISTANCE FROM – AND VSMP MONITORING BY – INDEPENDENT AGENTS
A. Each VSMP has its own Independent Agent:
1. Each VSMP has own Independent Agent assigned to it. This person is known as the VSMP’s “Responsible Agent”.
2. If the Independent Agent has interacted with the Eligible Entity and assisted it to form its VSMP, the Independent Agent will already be known to the Eligible Entity.
3. If the Eligible Entity has created its own VSMP, an Independent Agent will automatically be assigned to the VSMP, to act as its Responsible Independent Agent.
4. The roles of the Independent Agents are to provide advice and assistance to Eligible Entities regarding VSMP / TEL.mobi Group matters, and to provide assistance to Webtel.mobi for management of VSMP activities.
5. The Independent Agents are part of the TEL.mobi Group’s Value Constellation System, and receive a Commission Donation for carrying out these activities.
6. If Eligible Entities wish to obtain any further information on the role and activities of TEL.mobi Group Independent Agents, this can be found in the “Independent Agents handbook”, which can be reviewed or downloaded from the “Apply to be an Agent “IA)” Facility on all TEL.mobi Group sites.
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B. Eligible Entity Assistance from Independent Agents:
One of the roles and functions of the TEL.mobi Group Independent Agents is to provide assistance to the Contact Persons / Responsible Persons at Eligible Entities that have established VSMPs. It is the responsibility of TEL.mobi Group Independent Agents to do so, and to do so at no cost to the Eligible Entity.
If Eligible Entities establish their VSMPs via an Independent Agent, they will already be familiar with the Independent Agent who is assigned to their VSMP, and will be able to contact him/her directly.
If Eligible Entities establish their VSMPs themselves via the “Apply for an Affiliate (VSMP)” Facility on a TEL.mobi Group site, then Webtel.mobi will allocate an Independent Agent to be the Responsible Agent for the Eligible Entity’s VSMP.
Details and Contact Details of the Independent Agent who is Responsible for an Eligible Entity’s VSMP appear in the VSMP Administration Console of every VSMP, and can be seen and retrieved by the Contact Persons at the Eligible Entity at any time.
All and any questions and/or requests for assistance that the Contact Persons at an Eligible Entity may have regarding their VSMP can be addressed to their Responsible Agent. If the Responsible Agent is unable to assist with any particular enquiry, he/she will refer the enquiry to Webtel.mobi for further processing.
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C. VSMP Review and Monitoring by Independent Agents:
1. Overview
Other than their requirement to provide assistance to Eligible Entities/VSMPs, Independent Agents also have a requirement to assist Webtel.mobi in respect of the Review and Monitoring of VSMPs and their activities. An overview of these Review and Monitoring activities is as described in the following paragraphs.
2. Review of Newly-Established VSMPs
When a New VSMP has been established, the Independent Agent assigned to or responsible for that VSMP will review the New VSMP within eight to twenty-four hours of its establishment.
If, on review, there are no issues encountered in respect of the VSMP Restrictions, the Independent Agent will take no action.
If, on review, there are clear minor issues (such as a VSMP Name which is too close to a known brand or company name, but not an outright infringement of name policy; or a similar ambiguous situation where it is not absolutely clear that a Restricted name / Person / Activity is involved), then, the Independent Agent will liaise with the Eligible Entity and Webtel.mobi to rectify any minor issues.
If, on review, there is a direct and clear name infringement (i.e. a clearly Restricted name had been deliberately used), or it is clear that the Eligible Entity is one of the Restricted types of Eligible Entity, or a Restricted or Sanctioned Person or Entity is involved with the Eligible Entity; then the Independent Agent will immediately recommend the VSMP for Banning to Webtel.mobi. In such a situation, Webtel.mobi is the sole arbiter of whether to proceed with a banning or not. In the case of banning – the VSMP will be shut down by Webtel.mobi, and all names, mobile numbers, email addresses and any other specifically identifying attributes of the Eligible Entity and its Contact Persons will be locked out of the TEL.mobi Group System permanently.
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3. VSMP Monitoring
Once a VSMP has been formed and is functioning, Independent Agents will, on a continual basis, monitor the activities of the VSMPs that have been assigned to them / for which they are responsible.
This is primarily to ensure that:
If an Eligible Entity that has established an Eligible Entity becomes involved in Restricted activities, the Independent Agent is to recommend the VSMP for Banning.
Continual proactive and pre-emptive Anti Money Laundering Monitoring is carried out.
Any unusual and/or suspicious activity of or on a VSMP can be picked up and reported to Webtel.mobi.
The TEL.mobi Group’s Weekly Marketing Messages are sent out unaltered in wording by the Eligible Entities / VSMPs.
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D. Eligible Entities can become Independent Agents:
1. Overview
Eligible Entities are also able to act as Independent Agents if they wish to.
This is not a combination of their existing status as an Eligible Entity that has a VSMP.
If an Eligible Entity wants to additionally act as an Independent Agent, this is welcome, and is in fact very popular and occurs very often.
To do so, an Eligible Entity has to Apply to act as a TEL.mobi Group Independent Agent, either via their existing Responsible Agent, or directly over their VSMP site, from the “Apply to be an Agent (IA)” Facility.
They should also review the Independent Agents handbook, which can be reviewed or downloaded from the same “Apply to be an Agent (IA)” Facility on TEL.mobi sites.
2. Switch of existing Global VSMP to an Agent VSMP is not possible
As can be seen in the Section entitled “VSMP Types, Uses and Establishment”, there are two Primary Types of VSMP.
These are
Global VSMPs – These are VSMPs that are established for or by Eligible Entities.
Agent VSMPs – These are VSMPs that are established by Agents for their own use.
Once a VSMP has been established as a Global VSMP or an Agent VSMP, it cannot be changed from one to the other (for Security reasons).
As such, if an Eligible Entity has already had a Global VSMP formed for it / has formed a Global VSMP, and thereafter decides to also become an Independent Agent; it will not be able to change its existing Global VSMP to an Agent VSMP. It will rather need to establish a second Agent VSMP, Separate from its existing Global VSMP.
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SECTION 6
AML, KYC
AND SECURITY
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COMPARISON BETWEEN
STANDARD TELCOS’
AML & KYC PROCEDURES
AND
THE TEL.MOBI GROUP’S
30-LAYER-DEEP
AML & KYC PROCEDURES
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COMPARISON BETWEEN STANDARD TELCOS’ AML & KYC PROCEDURES, AND THE TEL.MOBI GROUP’S 30-LAYER-DEEP AML & KYC PROCEDURES
The Telephony Sector does not have the same requirements as the Financial Services industry in respect of “Know Your Client” (“KYC”) and “Anti Money Laundering” (“AML”) requirements and regulations.
Webtel.mobi’s – and thereby the TEL.mobi Group’s – structuring and processes for Direct-to-Mobile- Bill Billing and Payments are fully aligned with the standards and norms of all Telephone Companies in the Telephony Sector.
However, in order to be highly proactive in these arenas, Webtel.mobi – and thereby the TEL.mobi Group – has proactively and pre-emptively structured and implemented KYC and AML processes that are not only the most robust in the Global Telephony Sector, they are some of the most robust KYC and AML structures and processes of any entity worldwide. They are, in fact, more robust and thorough structures and processes than can even be found in most banks.
A summary of the KYC and AML processes that are applied by Standard telephone Companies for their Standard Direct Carrier Billing / Direct-to-Mobile-Bill services on one hand; and the Webtel.mobi / TEL.mobi Group “ICLM” Direct-to-Mobile-Bill services on the other, are as follow:
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A. Standard Telephone Company / Aggregator AML and KYC Procedures: For their Standard Direct Carrier Billing / Direct-to-Mobile-Bill services
When clients join their companies’ platforms, Standard Telephone Companies Conduct KYC checks on clients prior to selling them Mobile Phones with SIM cards in them, or SIM cards. These KYC procedures include checking and recording of Photo ID to verify the client’s Identity. In some cases, it includes checking and recording of a recent Utility Account in the client’s name in order to verify the client’s address. No other KYC information is ever requested or checked.
When the Telephone Accounts of Standard Telephone Companies’ Prepaid clients are Topped- Up, no KYC is done (or is possible to be done) by Standard Telephone Companies on who is Topping-Up their client’s Prepaid Telephone account. Similarly, no KYC or “cleared-funds” check is done (or is possible to be done) on the Funds being used to Top-Up the Stored Credit in their clients Prepaid Telephone accounts – especially when cash is used for these transactions. Finally, due to the proliferation of International Top-Up companies, external third party persons and entities who are not clients of the Standard Telephone Company are able to Top-Up the Prepaid Telephone Accounts of Standard Telephone Companies’ clients. They can do this using Cash / Money Transfer companies / Remittances companies / other methods. None of these are related to the Standard Telephone Company in any way, and no KYC has been done or can be done (and is not even possible to do), on either the external persons or external entities or the funds being transferred in / cash being taken in.
When Standard Direct Carrier Billing / Direct to Mobile Bill services are carried out by clients of a Standard Telephone Company, they are carried out through integration with either third- party Merchants, third-party Aggregators or other third-party entities. All of these different entities have varying degrees and/or processes for AML and KYC, and no unified way to tell the origination of funds or Stored Credit used in the payment process, or the actual end- destination of funds / Stored Credit used in the payments process. There is no real way to conduct accurate or meaningful KYC on either the payee or the recipient of funds being transferred using this system and process. This is because there are multiple actual transfers of funds between different bank accounts of different entities, by and to persons who are not known along the whole trajectory of the transfer process, and funds pass through multiple layers of client to Aggregator to Payment gateway to Telco – with no differentiation between Stored Credit and/or Funds. There is ample opportunity for the “Layering” and “Integration/Extraction” stages of Money Laundering in such a decentralized process, where multiple entities participate in the process, from multiple sources, without any way of following the process from beginning to end, or really knowing the origination or end- destination of funds being transferred.
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When Refunds are done to Standard Telephony Companies’ clients, no distinction for KYC purposes is made (or is possible to be made) between Funds which are Stored Credit Deposits and Funds which represent Payments in cash or money transfer – because all Funds received are mixed together. There is no ledger of balance connecting specific funds in the Standard Telephone Companies’ central Accounts even to its provenance or status (Stored Credit or Payment) – let alone to a specific client. The KYC on the recipient of the Refund is achieved by the Refund being transferred to a Bank Account in the client’s name, or by the Refund being placed onto the balance of a Credit Card or Debit Card of the client, or by the presentation of a Refund Voucher to a client on his or her presentation of a Photo ID which matches the details of the Photo ID on record.
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B. The Webtel.mobi / TEL.mobi Group KYC and AML Procedures: For its “ICLM” Direct-to-Mobile-Bill services
1. In-house 30-layer-deep inner-circle of AML and KYC
Webtel.mobi’s / the TEL.mobi Group’s KYC and AML procedures comprise a 30-layer-deep series of preventative defensive inner-circles of KYC and AML procedures, techniques, processes and systems, all of which are interconnected. It is one of the most robust KYC and AML systems in the world. A summary thereof is as follows:
Inner Circle 1: AML + KYC + Security – Closed-Loop Members-Only Unitary Platform
The entire System is a Closed-Loop, for Members-Only, on one unitary platform that is centrally managed and controlled. This means that:
The entire flow of all Stored Credit, from entry to departure, from and between and to all Members, is permanently recorded on and by the Platform. This in turn means that no “layering” or “integration” Money Laundering processes are ever possible, and all details of Bank Accounts from which Stored Credit is loaded are recorded at a central point.
The details of the Banks from which Stored Credit enters the system and the Banks to which Stored Credit exits the system, are permanently recorded on and by the Platform in a central point. This in turn means that the entry points and exit points of any Stored Credit is always recorded, and no Stored Credit can ever originate from or exit to an unknown point.
All Transactions of all types are permanently recorded on the TEL.mobi Platform, which means that any trends, unusual activities or suspicious activities can be picked up easily and rapidly through monitoring from a central point.
All and any TEL.mobi Accounts are able to be frozen immediately from a central point. This means that any suspicious activity can result in an immediate blocking of any further movement of Stored Credit until any required checks and/or verification has taken place.
All and any TEL.mobi Top-Up Vouchers are able to be frozen immediately from a central point. This means that any Top-Up Vouchers reported as having been stolen are able to be frozen and/or cancelled immediately before or after being loaded onto any account, and any Top-Up Vouchers that have been issued in a suspicious manner / with suspicious values are able to be monitored and – if necessary – frozen.
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Inner Circle 2: AML + KYC + Security – Mobile Phone Number required to join
No person can become a Member of the TEL.mobi Group without having his/her own Mobile Phone Number. Only one Mobile Phone Number per person is allowed by the system (the system refuses joining if the same Number is attempted to be used by a different person). This ensures that people do not attempt to join using other peoples’ Mobile Phone Numbers. Moreover, because to get a Mobile Phone Number in the first instance, KYC documents will have had to have been provided to the Telco issuing the Mobile SIM Card / Mobile Phone, KYC information on the owner of the Mobile Phone Number already exists at the issuing Telco.
Inner Circle 3: AML + KYC + Security – Verification of Mobile Number required to use
Once a person has joined, a Verification Text must be sent to his/her Registered Mobile Phone Number by the TEL.mobi Group system before he/she is able to use the system. Unless that Verification Number text is received and the Verification Number entered into a specific place on that person’s specific TEL.mobi account, he/she will not be able to use the TEL.mobi Group system. This is again to ensure that the Mobile Phone Number given on joining is in the person’s own physical possession, and is not a random Mobile Phone Number / a Mobile Phone Number of another person.
Inner Circle 4: AML + KYC + Security – Verification of Email required to join and use
Once a person joins the TEL.mobi Group, a Welcome Email is sent to the email address given on joining. If the email bounces back – indicating that a false email address has been used – the TEL.mobi Group system automatically permanently blocks that person’s account. This means that the person’s account is permanently blocked, and also that the Mobile Phone Number used by that person is permanently blocked from ever signing up on the TEL.mobi system again.
Inner Circle 5: AML + KYC + Security – Unique ITAN combined with Mobile Number
Once a person joins as a Member of the TEL.mobi Group, he/she is assigned a unique TEL.mobi Group ITAN Number, which is linked to his/her unique Registered Mobile Number. TEL.mobi Group ICLM Services transactions always require the insertion of the Member’s ITAN Number. This ensures a higher level of security for use of these ICLM Services, and also ensures that any such usage can only be done intentionally as a conscious decision – not by accident.
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Inner Circle 6: AML + KYC + Security – Stored Credit only in from a Bank Account
TEL.mobi Group Members may only load Stored Credit onto their TEL.mobi Accounts with “Already Cleared Funds” – meaning that the Funds used to acquire Stored Credit are already in a Bank Account. This means that the owner of the Account has already had KYC done on him/her by the Bank, and that AML checks have already been done on the Funds inside that Account. This Stored Credit can only enter the TEL.mobi Group system via Bank Transfer, or through a Payment Gateway via Bank Transfer, Wallet Transfer from a Bank Account, or Card Payment. Even Top-Up Vouchers are only issued by Webtel.mobi to TEL.mobi Group Agents and/or VSMPs against Inward Transfers of Stored Credit from a Bank Transfer, Wallet Transfer from a Bank Account, or Card Payment.
Inner Circle 7: AML + KYC + Security – Top-Up Vouchers only from KYC’d Members
TEL.mobi Group Top-Up Vouchers acquired by TEL.mobi Group Members can only be acquired from TEL.mobi Group Agents and/or VSMPs. All TEL.mobi Group Agents and/or VSMPs have already uploaded their full KYC Documentation in order to become Agents or VSMPs, and their KYC documentation, all relevant personal and professional details, and their Mobile Phone Numbers, are therefore known to Webtel.mobi. TEL.mobi Group Agents and VSMPs also have, as part of their responsibilities, the requirement to provide early-warning of any suspicious activities in respect of Top-Up Voucher acquisition to the TEL.mobi Group, and can lose their Agent or VSMP status if Webtel.mobi picks up suspicious activity regarding Top-Up Vouchers on-sold by them that they have not yet picked up themselves.
Inner Circle 8: AML + KYC + Security – Voucher acquisition linked to specific Member
Every TEL.mobi Group Top-Up Voucher initially acquired from Webtel.mobi is acquired by a specific Agent or VSMP, and the acquisition – and on selling – of every Top-Up Voucher is permanently linked to a specific TEL.mobi Group Agent or VSMP’s Responsible Persons, who can be contacted if there are any enquiries about a specific Top-Up Voucher.
Inner Circle 9: AML + Security – Standard Top-Up Vouchers are low denominations
Standard TEL.mobi Group Top-Up Vouchers that can be acquired by TEL.mobi Group Agents or VSMPs for resale – through a drop-down selection process – have a maximum value of GBP 100. If a Top-Up Voucher of a higher denomination is requested, this must be applied for with the amount being written in by the Agent or VSMP in a different process. The Standard Top-Up Vouchers are therefore kept to Low Denominations, and, unusual and/or suspicious activities (i.e. a huge quantity of Top-Up Vouchers being re-sold at once) are able to be easily picked up and monitored / checked on.
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Inner Circle 10: AML + Security – High value Top-Up Vouchers recorded and checked
TEL.mobi Group Top-Up Vouchers of higher than Standard Values have to have the amount written in by TEL.mobi Group Agents or VSMPs. Although such transactions are possible (i.e. in the case of Unbanked Persons converting their money into digital money for safety / security), these unusual Transactions are also recoded, checked and closely monitored on one platform. The Agent or VSMP must have first satisfied himself/herself of the bona fides of the request for a higher value Top-Up Voucher, in order to request it and on-sell it to a Member, as otherwise he/she is liable to lose his/her position in the TEL.mobi Group.
Inner Circle 11: AML + KYC + Security – Voucher end-use linked to a specific Member
Because the TEL.mobi Group functions from a Unitary Platform, TEL.mobi Group Top-Up Vouchers are immediately and permanently linked to the Member who redeems it onto his/her Account as soon as it is redeemed. This is a part of the AML process to ensure that there is always a full record as to the exact flow of Stored Credit within the system at all times, as well as a record of who the end-user of a Top-Up Voucher is.
Inner Circle 12: AML + KYC + Security – Key Change linked to specific Member
TEL.mobi Group Top-Up Vouchers are able to have their Security Keys changed by Members who have acquired them for security purposes. Because the TEL.mobi Group functions from a Unitary Platform, a change of the Top-Up Voucher Key is immediately and permanently linked to the Member who carries out the Security Key change. This is a part of the AML process to ensure that there is always a full record as to the exact flow of Stored Credit within the system at all times, and who has changed the Security Key of a Top-Up Voucher (and is therefore at that time in possession of it).
Inner Circle 13: AML + KYC + Security – 100% of Stored Credit inflow & use is recorded
The flow and use of all Stored Credit loaded into the TEL.mobi Group system is permanently recorded for every Transaction by every Member, and for all flows between all Members. Any and all transactions at all times and/or from any time periods are therefore able to be reviewed at any time to identify, track or review any suspicious flows or transactions from beginning to end.
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Inner Circle 14: AML + Security – Stored Credit cannot leave the closed loop
Once Stored Credit has been loaded into the TEL.mobi Closed-Loop Members-Only System, it can never leave this system unless it is used for Calling or Texting, or Refunded to a Bank Account belonging to a Member. This makes it a completely safe and sealed Closed-Loop, where the Stored Credit can only be used for calling, texting, swapping between Members within the Closed Loop, or refunding to a Member’s Bank Account. The fact that no Stored Credit can leave the Closed-Loop system prevents any Stored Credit from going to any non-Member and/or any unknown, unverified and un-KYC’d party outside of the Closed- Loop system.
Inner Circle 15: AML + Security – No physical transfer of Stored Credit possible
It is not possible for any of the Stored Credit in the TEL.mobi Group’s system to be physically transferred to any other person, account or entity, ever. It can only be used to Make Calls or Send Texts, or be swapped between Members of the TEL.mobi Group. Even the on-selling of Top-Up Vouchers does not represent a Transfer, because the Top-Up Voucher is just a representation of the Stored Credit in the TEL.mobi System. This makes it impossible for the Stored Credit to be transferred to any non-Member and/or any unknown, unverified and un-KYC’d party outside of the Closed-Loop system. In fact, it is also impossible for the Stored Credit to even be physically transferred to Members’ external accounts in ICLM Transactions.
Inner Circle 16: AML + Security Circle – No Stored Credit moves from account
No Stored Credit ever moves from the account where it is held. Even during an ICLM Transaction, only the ledger-entry balances of the parties involved in the Stored Credit Swap are altered. The Stored Credit itself remains static in the Account and does not move. This seals the Stored Credit in a totally Closed-Loop, from which it is impossible to leave – even during ICLM Transactions. It is therefore impossible for the Stored Credit to be acquired by external persons or entities – or even by Members during ICLM Transactions.
Inner Circle 17: AML + Security – No external entity or person can load Stored Credit
The TEL.mobi system is a completely Closed-Loop system. Only people who have joined as Members – meaning that initial KYC was done on them by the Telco issuing their Numbers, and whose Numbers used for joining have been Verified to ensure that it is their Number – can load Stored Credit. Moreover, this Stored Credit can only be loaded from a Bank Account or a Credit/Debit Card. This means that the Funds used to load the Stored Credit are already “Cleared Funds”, as cleared during KYC and AML procedures from the Bank or Credit/Debit Card company from which they originate (over and above the already done on the Member by the Telco issuing his/her Original Mobile Telephone / SIM). 307
Inner Circle 18: AML + Security – No external entity/ person can receive Stored Credit
No external person who is not a Member of the TEL.mobi Group can ever receive Stored Credit from the TEL.mobi Group’s system in an ICLM Transaction or in any other way. ICLM Transactions can only be done by Members on the TEL.mobi Group System, Stored Credit can only be used on the TEL.mobi Group System for calls or Texts, and Refund Transfers can only be done by TEL.mobi Group Members to their own Bank Accounts (according to the Rules and Limits). As such, it is impossible for the Stored Credit to go to any external entity or person, ever.
Inner Circle 19: AML + KYC + Security – ICLM only possible with all credentials
TEL.mobi Group Members can only initiate an ICLM Transaction if they are in possession of, and apply, all of their credentials, including Username, Password, ITAN Number, and Registered Mobile Number. This provides very tight security for Members. It also ensures that the initiation can only be done by a Member, who is in possession of all of his/her credentials, and the Member giving with multiple confirmations during the process. This consequently confirms that the Member has personally decided to carry out the ICLM Transaction, and has initiated it with the specific intention to carry it out (i.e. no mistaken or unintentional implementation of the ICLM Transaction is possible).
Inner Circle 20: AML + KYC + Security - ICLM only possible with TAN & phone
Even when a TEL.mobi Group Member has initiated an ICLM Transaction, the Transaction will still not be able to be completed until and unless the Member receives and inputs a unique TAN Number for that specific Transaction, sent by the TEL.mobi System to his/her Registered Mobile Phone by text. This means that the Member has to have his/her Mobile Phone with the Registered Mobile Number registered on the TEL.mobi system. The Member must also be able to access the Mobile Phone (i.e. have the code to unlock the phone to receive the text), and to be logged in to his/her own TEL.mobi Account to be able to receive and input the TAN Number. This confirms that the Member has personally initiated the ICLM Transaction (or otherwise he/she will not confirm it with the received TAN), and has thereafter personally completed the ICLM Transaction – with the specific intention to carry it out (i.e. no mistaken or unintentional implementation of the ICLM Transaction is possible).
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Inner Circle 21: AML + KYC + Security – ICLM only possible with Both Members ITANs
An ICLM Transaction can only be carried out from one TEL.mobi Group Member to another if the Member initiating the ICLM Transaction is in possession of both his/her ITAN Number and Registered Mobile Number, and the ITAN Number and Registered Mobile Number of the Member that he/she wants to carry out an ICLM Transaction to. This means that the Member carrying out the ICLM Transaction must have confirmed with the requirements Inner Circle 19 and 20. It also means that the Member to which the ICLM Transaction is being carried out to must have either openly advertised or directly provided his/her ITAN Number and Registered Mobile Number to the Member carrying out the ICLM Transaction. This confirms that both Members have personally decided to carry out the ICLM Transaction (one Transferring and one Receiving) with the specific intention to carry it out (i.e. no mistaken or unintentional implementation of the ICLM Transaction between these Members is possible).
Inner Circle 22: AML + KYC + Security – Refund only possible after uploading full KYC
Stored Credit Loaded into the TEL.mobi system cannot leave the system, and can only be used for Calls or Texts, unless it is Refunded to the Bank Account of a Member. A Refund Transfer to a Member’s own Bank Account can only be done if the Member has uploaded his/her full “Know Your Client” (KYC) documents (Photo ID and recent Utility Bill confirming address and name) For Unbanked Persons who often do not have KYC Documents, a TEL.mobi Group “Substitute KYC Document” must be uploaded. No Refund Transfer by a Member to his/her Account may be initiated without the Member’s full KYC Documents having been uploaded.
Inner Circle 23: AML + KYC + Security – KYC Docs only accepted if Verified
Members’ KYC Documents that are uploaded – including “Substitute KYC” Documents for Unbanked Persons – must be Verified and Certified as both True Copies of originals and (for Photo ID) a True Likeness of the person by a Registered Attorney or Notary to be acceptable as KYC Documentation in the TEL.mobi Group system. This ensures that full KYC details – over and above the KYC already done by the Telco issuing the Mobile Telephone number/SIM and the Bank that opened the account for a Member – including full KYC for Unbanked Persons, is complete.
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Inner Circle 24: AML + KYC + Security – Refund only to own Bank Account of Member
Refund Transfers can only be done by Members to their own Bank Accounts. As such, no Transfers to third parties outside of the Closed-Loop system can ever be done to any other person or entity – whether they are external parties or Members. Refund Transfers can only be done by a Member, to his/her own Bank Account. Moreover, Members can only carry out Refund Transfers once they have uploaded their full KYC Documents, and then only according to the Refund Rules and Limits. This ensures that the integrity, safety and security of the entire system – for Members’ security and for AML security – is permanently maintained.
Inner Circle 25: AML + KYC + Security – Refund only according to Refund Rules
Refund Transfers may only be carried out in accordance with the Refund Rules and Limits. The entire purpose of existence of the Refund Rules and Limits is for AML purposes. These Rules and Limits ensure that all Stored Credit ICLM Transactions to a Member’s TEL.mobi Account can be accounted for, and all Stored Credit sent or received has been proven to be for a legitimate reason, from a legitimate source (See “Refund Transfer Rules and Limits” for details).
Inner Circle 26: AML + Security – Refund Transfer can be denied pending clarifications
Even if Members have uploaded their KYC Documentation and have abided by the Refund Transfer Rules and Limits, Refund Transfers are still able to be delayed or denied pending clarifications if there are any suspicious trends apparent in the Stored Credit flow, documentation provided, or any other issues that are unusual or curious. In such cases, if matters are clarified satisfactorily, the Refund Transfer will be allowed to proceed. If not, they will be referred to an appropriate organization for review and guidance, after which action will be taken according to the guidance received.
Inner Circle 27: AML + Security – Accounts can be frozen pending clarifications
If any suspicious trends in Stored Credit flows, and/or Refund Transfer Requests are established, the Member’s Account is able to be frozen pending clarification. This means that the Stored Credit in the Member’s Account is kept safe in the Account for the Member, but cannot leave the Account in either an ICLM Transaction or any other way. This is only done if there is an outstanding query that has been referred to an appropriate organization for guidance (as described later in this section). After guidance has been received from the appropriate organization, the Member’s Account and his/her Stored Credit is able to be unfrozen immediately – or not – depending on the situation and the guidance received.
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Inner Circle 28: AML + Security – Record of Stored Credit flow from beginning to end
There is a complete record kept of all Stored Credit entering the TEL.mobi system, the entity through which it enters the system, the complete flow of usage on the system, the complete flow of ICLM Transaction transferors and recipients and the exit of any Stored Credit – including the destination Bank Account. It is the only unitary system in the world on which the exact flow of every single Transaction is able to be kept, in detail, on a centralized platform. As such, there is no possibility at all for layering, integration or hiding of any transaction or of Stored Credit, and a complete chain of beneficial ownership / origin / transaction purpose / etc is clear and kept. This renders the system extremely safe insofar as protection of Members, protection of Merchants and protection against Money Laundering attempts is concerned.
Inner Circle 29: AML + Security – Unusual patterns able to be easily detected
Due to the TEL.mobi System being on one Unitary Platform, all activities are able to be reviewed on the same platform, according to the same requirements. There are no intermediaries or external entities or considerations at all (and therefore all reviewing is able to be done to the same standards). Global and local reviews are able to be carried out, so any unusual patterns of Stored Credit flows are able to be picked up very rapidly. The TEL.mobi system is the only Unitary Platform in the world that enables this centrally verifiable and locally confirmable system to be implemented according to the same set of standards worldwide.
Inner Circle 30: AML + KYC – Member’s receiving Bank also KYCs Member and funds
Other than the fact that all Funds transferred into the TEL.mobi Group system must originate from Bank Accounts and/or Credit/Debit Cards (and therefore already represents “cleared funds”), Refund Transfers can only be made to a Bank Account belonging to the Member doing the Refund Transfer. As such Funds also have to be verified by the Receiving Bank, these Funds are effectively “double-verified”, once by Webtel.mobi prior to allowing the Stored Credit Refund to proceed, and once again by the receiving Bank on receiving Funds into an account. This brings about a de-facto “double-verification” of Stored Credit Refunded from the TEL.mobi System / Funds received into the Member’s Bank account, which represents, again, one of the most stringent and effective AML systems in the world.
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2. In-house “Worldwide Local Early-Warning and Reviews” for AML and KYC
The majority of TEL.mobi Members are Members of TEL.mobi Group VSMPs.
All TEL.mobi Group VSMPs are either local to their own Members, or know their Members’/local habits, norms and/or activities well, because they are locals themselves.
Moreover, All VSMPs have TEL.mobi Group Independent Agents assigned to them whose role it is to assist the VSMPs.
All of these TEL.mobi Group Independent Agents are similarly either local to their own Members, or know their Members’/local habits, norms and/or activities well, because they are locals themselves.
All TEL.mobi Group VSMPs and Independent Agents have access to an Administration Console from which they can monitor all activities of their VSMPs / the VSMPs that they are responsible for assisting (with personal Member data obscured, but with anonymized trends and transactions clearly visible, in detail).
The VSMPs’ Responsible Persons and the Independent Agents throughout the world are local to their Members. They are therefore able to additionally assess matters according to the local habits, norms and/or activities for their particular Countries, Provinces/States, Cities/Towns/Villages or Suburbs, and Economies. They are also able to assess multiple other local determining factors, which can indicate suspicious trends or trends that are not normal (i.e. Early-Warning).
Moreover, the local VSMPs’ Responsible Persons and/or Independent Agents are also able to carry out local confirmation checks on the validity of Registration of local Attorneys and/or Notaries. This includes whether actual Verification of KYC Documents has taken place at local Attorneys and/or Notaries, whether local clients businesses do carry out X or Y, whether locally issued documents for business or transactions are valid, etc (i.e. Confirmation and Verification).
The local VSMPs and Independent Agents are able to do this, are responsible for doing this and are motivated to do so. This is because if a suspicious trend or action is picked up by Webtel.mobi from the Central System before a local VSMP Responsible Person / Independent Agent, the Eligible Entity / Independent Agent can potentially lose its Consent to act as a TEL.mobi Group VSMP / Independent Agent.
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As such, the TEL.mobi Group does not only have a 30-leyer-deep Inner Circle of defense in respect of KYC and AML activities, it also has an In-house “Worldwide Local Early-Warning and Review” system for AML and KYC. It has this in every country, Province/State, City/Town/Village or suburb where its VSMPs function – for both Early Warning and Confirmation & Verification of KYC and AML factors, worldwide.
Moreover, as all VSMPs and Independent Agents are provided – via their Handbooks – with the details of Prohibited and Sanctioned Persons and Organizations applicable from a Guernsey perspective, which will be prohibited from becoming Members and/or utilizing the TEL.mobi System, there furthermore exists a “double-check” of adherence with such international requirements for AML and KYC.
3. Membership not available to Sanctioned/Prohibited Persons/Organizations
Membership of the TEL.mobi Group’s system is not open to Persons and/or Entities that are classified as Prohibited and/or Sanctioned Persons and/or Entities in or by the States of Guernsey.
As Membership is not open to such Persons and/or Entities, neither are the VSMP or Independent Agent opportunities – as these are dependent on the VSMPs’ Responsible Persons and/or Independent Agents first joining as Members.
The list of Prohibited and/or Sanctioned Persons and/or Organizations is used by Webtel.mobi to review the Persons and/or Organizations that attempt to become Members of the TEL.mobi Group, and it is also provided to all TEL.mobi Group VSMPs and Independent Agents.
Independent Agents are required to review new VSMPs within eight hours of their formation to confirm that they are acceptable, and if not they are suspended and/or shut down.
Similarly, when KYC documents are uploaded / when Members wish to carry out sizeable Refund Transfers, Independent Agents and VSMPs are required to double-check – amongst other things – the Members against these lists.
This is over and above the checks and reviews being done centrally by Webtel.mobi on the Unitary TEL.mobi Group Platform (i.e. it is a “double-check”).
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This is, again, the advantage of having not just a Unitary Platform on which all data is centrally recorded and managed from one place according to one set of standards, but also a “Worldwide Local” system in place for double-checking and/or reviews.
An example of the relevant lists of Prohibited/sanctioned Persons and/or Entities in respect of the States of Guernsey can be seen at the urls below:
https://www.gov.uk/government/collections/financial-sanctions-regime-specific- consolidated-lists-and-releases
https://www.gov.uk/financial-sanctions
http://hmt-sanctions.s3.amazonaws.com/sanctionsconlist.pdf
4. Any suspicious activity reported to Financial Investigation Unit of the GBA
Any activity on the TEL.mobi platform that appears suspicious and which cannot be satisfactorily resolved by a follow-up / review by Webtel.mobi and/or a local VSMP Responsible Person and/or a local Independent Agent; the suspicious activity will be reported to the Financial Investigation Unit of the Guernsey Border Agency; as the Competent Authority for such matters.
The TEL.mobi Group will then follow the guidance of this Competent Authority insofar as next steps to take – whether they be the freezing of the TEL.mobi Account and Stored Credit, or any other action as advised by this Competent Authority.
Details of the Financial Investigation Unit of the Guernsey Border Agency’s Cross Border Crime Division can be seen at the url below:
http://www.guernseyfiu.gov.gg/article/5982/Welcome-to-Guernseys-Financial-Investigation-Unit
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5. Refund Transfers are reviewed prior to being actioned
When a Member has initiated a Refund Transfer, the Transfer itself is not immediately carried out. It is queued for review prior to implementation.
Random Reviews are carried out on longstanding Members’ Refund Transfer requests.
Reviews are carried out on Refund Transfer Requests by New Members, Refund Transfer Requests for Large Amounts and Refund Transfer Requests that are in any other way
deemed by Webtel.mobi to be unusual in nature.
If Webtel.mobi requires further information to validate a Refund Transfer Request, the Refund Transfer will be delayed until such additional information has been provided to
Webtel.mobi by the Member requesting the Refund Transfer.
If satisfactory Additional Information is unable to be provided to Webtel.mobi by the Member requesting the Refund Transfer, Webtel.mobi will refer the matter to the GBA for
review, and their guidance on the matter will thereafter be followed.
6. Post Refund Action is possible Due to Records from the Unitary Platform
Even once a Refund Transfer has been carried out, Post-Refund action is possible. Post- Refund actions will be carried out if a post-facto enquiry – with relevant and required formal legal documentation – is received from the Competent Authority in the States of Guernsey (or, if from another entity, an enquiry with formal legal documentation that is agreed to by / supported by the Competent Authority of the States of Guernsey).
This is because all details of the flow of Stored Credit from its arrival to its departure from the Unitary Platform are permanently recorded.
Moreover, the Bank Account to which it is Refunded is also permanently recorded.
As such, a full and clear flow of the Stored Credit, as well as all and any documentation related to it, Members who have been involved in any Stored Credit Swaps and destination Bank Accounts are all available for review at any time by a Competent Authority that has the required formal legal documentation in place to do so.
Consequently, even after the effecting of a Refund Transfer, follow-up AML actions can be implemented in the event of a suspicious transaction being uncovered or reported.
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7. Integration of the world-leading “Inauth” Security Suite
On the TEL.mobi sites’ Payment Gateway page, a script from the world-leading Mobile Phone Security Company “Inauth” runs permanently. This has two purposes.
One of the purposes is Security for the TEL.mobi Group and its Members through identifying and preventing potential fraud.
The other purpose is pre-emptive AML. This is done through the utilization of “Inauth’s” proprietary and world-leading Mobile Phone Security Service, specifically designed to test 2000+ facilities on any Mobile Phone used to load Stored Credit on the TEL.mobi System.
Through this, the TEL.mobi Groups adds preventative / pre-emptive AML procedures to its other Real-Time and In-House AML procedures.
A video describing the “Inauth” Mobile Phone Security System can be seen at this url:
https://www.inauth.com/resources/why-inauth/
8. Integration of the world-leading “Accertify” Security Suite
On the TEL.mobi sites’ Payment Gateway page, a script from the world-leading Online Security Company “Accertify” runs permanently. This has two purposes.
One of the purposes is Security for the TEL.mobi Group and its Members through identifying and preventing potential fraud.
The other purpose is pre-emptive AML. This is done through the utilization of “Accertify’s” proprietary and world-leading Online Security Service, specifically designed to test multiple facilities on any Computer that is used to load Stored Credit onto the TEL.mobi System.
Through this, the TEL.mobi Group adds preventative / pre-emptive AML procedures to its other Real-Time and In-House AML procedures.
A video describing the “Accertify” Online Security System can be seen at the url below:
https://www.accertify.com/en/resources/video-gallery/accertify-fraud-management-video/
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C. General comment on TEL.mobi Group KYC and AML procedures:
The TEL.mobi Group is committed to maintenance of its Members’ rights to privacy, and is also committed to the maintenance of clean, orderly and legal activities on its platform.
As such, in the case of Members adhering to the Terms and Conditions of the use of the TEL.mobi Group’s services, the requirements for provision of required documentation (where applicable) for ICLM Transactions and the Rules and Limits of Refund Transfers; Members’ rights to privacy will be vigorously maintained and upheld by Webtel.mobi.
In the case of the Competent Authority of the States of Guernsey (itself or acting on behalf of another Competent Authority) presenting the required formal legal documentation – according to the standards and requirements of the States of Guernsey – Webtel.mobi will comply with such requests and/or requirements as contained within the formal legal documents.
However and moreover, it should be noted that although Webtel.mobi (and therefore the TEL.mobi Group) is a Telephony Company in the Telephony Sector, it is therefore not even required to implement the comprehensive AML and KYC regimes as found in the Financial Services Sector. It has, nevertheless, voluntarily and proactively implemented far more rigorous AML and KYC regimes than are even to be found in the Financial Services Sector internationally.
This is because Webtel.mobi and the TEL.mobi Group are fully on the side of Law-Enforcement and/or Regulatory and/or Other Competent Authorities in respect of the maintenance of law and order in business. It should also be noted that the Chairman of Webtel.mobi and the TEL.mobi Group is a former Staff Member of an Intelligence Organization and a former Special Forces Operator. He is therefore very familiar with AML regimes and with the organizations and personnel of AML and law-enforcement entities internationally, and is also committed to the maintenance of a stable, clean and lawful platform.
As such, the following should be noted with crystal clarity:
1. While legal and correct use of the platform for legal purposes – and in conformance with Terms and Conditions of the use of the TEL.mobi Group’s services – the requirements for provision of required documentation (where applicable) for ICLM Transactions and the Rules and Limits of Refund Transfers, will be protected, and the privacy of Members vigorously upheld and defended;
2. Similarly, any suspicious activity on the platform, and any suspected use of the TEL.mobi Group Unitary Platform and/or any of its Services for any illegal purposes – including attempted Money Laundering purposes – will be actively, and proactively, reported to the relevant Competent Authority.
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3. No attempt should be made to utilize the TEL.mobi Group Platform for the purposes of attempted Money Laundering, as such attempts will not be successful; and will lead to the freezing of TEL.mobi Accounts and Stored Credit, and passing of the matter on to the relevant Competent Authority.
4. Moreover, full and proactive cooperation with all and any relevant AML and/or law- enforcement organizations internationally will be proactively entered into in the event of suspected money laundering and/or any other illegal / prohibited / sanctioned activities, persons or entities being detected or suspected on the platform.
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SECURITY OF
COMMISSION DONATIONS
CONTINUATION
FOR VSMPs
AND
SECURITY OF MEMBERS’
STORED CREDIT
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SECURITY OF COMMISSION DONATIONS CONTINUATION FOR VSMPS, AND SECURITY OF MEMBERS’ STORED CREDIT
A. Overview:
The Continuity of the Commission Donations Allocations for TEL.mobi Group VSMPs – as well as the Security of the Stored Credit of TEL.mobi Group Members – is continued even in the event of Banning/Discontinuations of VSMPs. The Paragraphs in this Section describe the processes in each such situation.
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B. Continuity of Commission Donations for VSMPs:
1. In the event of Freezing/Discontinuation/Banning of a VSMP in a Stream
If a New VSMP that has signed up via an established VSMP is Frozen, the Established VSMP will cease to receive Commission Donations from all Member Accounts of the VSMP that are Frozen, but will continue to receive Commission Donations from all Member Accounts in/from the VSMP that are not Frozen. If, after investigation, the New VSMP is Restored, the Established VSMP’s Commission Donations structure from that New VSMP will be restored.
If a New VSMP that has signed up via an established VSMP is Banned or Discontinued, the Established VSMP will cease to receive Commission Donations from all Member Accounts of the VSMP that is Banned/Discontinued. The Established VSMP will continue to receive Commission Donations from all Member Accounts from that VSMP which were not Banned, and which have been moved (see the paragraph on “Security of Members Stored Credit” in this Section).
2. In the event of the Freezing/Discontinuation/Banning of your VSMP
If your VSMP Account is Frozen, you will cease to receive any Commission Donations from the Members of your VSMP and/or any New VSMPs attached to your VSMP. If your VSMP is Restored, your VSMP Commission Donations – including any amounts accrued during the Freezing period – will be Restored.
If your VSMP is Discontinued at your request, then:
You will lose the Commission Donations from your VSMP’s Members.
All Stored Credit in your TEL.mobi Account will be refunded to your Registered Bank Account.
All Member Accounts of your VSMP will be moved to another VSMP.
If your VSMP is Banned by the TEL.mobi Group, you will lose the Commission Donations from your VSMP’s Members and all possibility for future Commission Donations. In this case:
All Stored Credit in your TEL.mobi Account will be refunded to your Registered Bank Account (unless your VSMP is under investigation by the GBA, in which case the GBA will determine what will occur with the Stored Credit in the VSMP’s Representatives’ TEL.mobi Accounts).
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You will be unable to access, login to or join the TEL.mobi Group again – in any capacity – using any of the credentials previously provided (i.e. Mobile Numbers, email addresses, etc).
All Member Accounts of your VSMP that are not Banned will be moved to another VSMP.
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C. Security of Stored Credit for Members:
1. In the event of the Freezing of a Member’s TEL.mobi Account
If a Member’s TEL.mobi Account is Frozen, their Stored Credit will be Frozen in the Account. If the Account is Restored, the Stored Credit in it – including any Top-Up Transfers and/or ICLM Transactions made to it while it was Frozen – will be Restored and free to use.
2. In the event of the Banning of a Member
If a Member’s TEL.mobi Account is Banned by the TEL.mobi Group, all Stored Credit in the Member’s TEL.mobi Account will be refunded to his/her Registered Bank Account (unless the Member is under investigation by the GBA, in which case the GBA will determine what will occur with the Stored Credit in the Member’s TEL.mobi Account).
If the Member does not have a Registered Bank Account, the Refund should be done via a Discounted Redemption. In such a case, the Banned Member will have to request an Independent Agent or VSMP in his/her area to contact Webtel.mobi by email and request a Special Transaction – arranged on a case-by-case basis – of an ICLM Transaction of this Stored Credit to the IA or VSMP, for Discounted Redemption to the Member.
A Banned Member will be unable to access, login to or join the TEL.mobi Group again – in any capacity – using any of the credentials previously provided (i.e. Mobile Numbers, email addresses, etc).
3. In the event of the Freezing of the Member’s VSMP
The TEL.mobi Group’s system is fully inter-usable. Any TEL.mobi Group Member can login to any TEL.mobi Group VSMP and/or the Webtel.mobi site at any time, with the same Credentials that he/she uses to login to his/her own VSMP. All Member Data – including the Member’s Stored Credit, Records, Contacts and all other data is, in fact, retained on the Central and Mirrored Webtel.mobi Databases – not on the individual VSMPs’ Databases.
If a Member’s VSMP is Frozen, Members of that VSMP will be immediately informed by Email and Text to Login to the Webtel.mobi site from then on, but their service will remain completely uninterrupted, and their Data and Stored Credit will also remain completely as is. There will therefore not even be a possibility for loss of service, Data, Records or Stored Credit.
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If the Frozen VSMP is Restored, all Members of that VSMP will again be immediately informed by Email that they can again login at the original VSMP.
If the Frozen VSMP is banned, the procedure as shown in the relevant paragraph below will apply.
4. In the event of Discontinuation/Banning of a Member’s VSMP
The TEL.mobi Group’s system is fully inter-usable. Any TEL.mobi Group Member can login to any TEL.mobi Group VSMP and/or the Webtel.mobi site at any time, with the same Credentials that he/she uses to login to his/her own VSMP. All Member Data – including the Member’s Stored Credit, Records, Contacts and all other data is, in fact, retained on the Central and Mirrored Webtel.mobi Databases – not on the individual VSMPs’ Databases.
If a Member’s VSMP is Discontinued or Banned, Members of that VSMP will be immediately informed by Email and Text to Login to login to Webtel.mobi site from then on, but their service will remain completely uninterrupted, and their Data and Stored Credit will also remain completely as is. There will therefore not even be a possibility for loss of service, Data, Records or Stored Credit.
The TEL.mobi Group will then establish a Replacement VSMP for the Members of the Discontinued/Banned VSMP, so that the Independent Agents who are used to assisting the Members of the Discontinued/banned VSMP can be integrated into it. This is so that the Members who are used to doing so will be able to receive assistance from the Same Independent Agents as they previously did.
Thereafter, these Members will be informed by Email and Text of their Replacement VSMP’s url, and, if they choose to, they can Login at that url – or continue to use the Webtel.mobi site, at their own choice.
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D. Electronic Tagging of Accounts for Commission Donations Consistency:
1. The TEL.mobi Group’s system is fully inter-usable. Any TEL.mobi Group Member can login to any TEL.mobi Group VSMP and/or the Webtel.mobi site at any time, with the same Credentials that he/she uses to login to his/her own VSMP. All Member Data – including the Member’s Stored Credit, Records, Contacts and all other data is, in fact, retained on the Central and Mirrored Webtel.mobi Databases – not on the individual VSMPs’ Databases.
2. Therefore, in order to ensure that the VSMPs continue to receive Commission Donations from all of the Members who join specific VSMPs, the following procedure is operational across the entire TEL.mobi Group System:
3. Whenever a person joins via any VSMP on the TEL.mobi Group System, his/her Member Account is electronically tagged as belonging to the VSMP that that he/she joined on.
4. Thereafter, only that VSMP will receive Commission Donations from that Member’s activities, regardless of which VSMP or TEL.mobi Group site the Member logs in to or uses.
5. For example, if Member A joins the TEL.mobi Group via VSMP X, but thereafter always logs in and uses the services on VSMP Y. It will always only be VSMP X that receives Commission Donations from all and any Activities and/or Transactions of and by Member A.
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E. Procedure if URL is Blocked or Non-Functional:
1. Webtel.mobi and the TEL.mobi Group have numerous and multiple systems in place to ensure continuation of service for Members.
2. There are multiple Mirrored Server Banks in different locations, and the databases are – for Security and Member Security reasons – never placed in a “cloud” or online, but rather always retained in physical databases that are not accessible in/from a “Cloud” environment (which is always a potential security risk). Moreover, there are multiple Alternative urls of and for the Webtel.mobi site and for all VSMP Sites.
3. As such, if Members – at any time and for any reason – are unable to access a VSMP’s url or the Webtel.mobi url, the TEL.mobi Group has a large number of Alternative urls over which the Site, Platform and Services can always be accessed in the event of url access issues arising.
4. In the case of such an event ever arising, Members will simply be emailed the Alternative urls, or automatically redirected to them.
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SAFETY REQUIREMENTS AND RESTRICTIONS – TEL.MOBI GROUP VSMP
AND ELIGIBLE ENTITY
ACTIVITIES
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SAFETY REQUIREMENTS AND RESTRICTIONS – TEL.MOBI GROUP VSMP AND ELIGIBLE ENTITY ACTIVITIES
1. The Requirements of TEL.mobi Group VSMPs – and the Eligible Entities that establish them, in respect of VSMP matters – is to adhere to guidelines, requirements, restrictions and terms contained in:
The TEL.mobi Group’s VSMP Handbook (for Eligible Entities and VSMPs).
Information and Guidance on the Agents and IA Administration Console.
Information and Guidance as received in TEL.mobi Group emails and communications.
Any requirements and/or restrictions as contained in the various instructions and/or “How it Works” pages within the TEL.mobi Group Facilities Pages.
The “Terms of Use” and End User License Agreement “EULA” of the TEL.mobi Group.
2. Naturally, this includes the requirement not to utilize the TEL.mobi Group Product Suite and Facilities for any illegal activities, or any other activities prohibited in terms of the TEL.mobi Group’s “Terms of Use” and “EULA” – which are available on all TEL.mobi Group portals, on the bottom left of every page, from the “Terms of Use” link – as well as the laws of the States of Guernsey and aspects of international law that are recognized by the States of Guernsey
3. For the avoidance of doubt, it will be and is the sole prerogative of the TEL.mobi Group and Webtel.mobi Management to decide – at their sole discretion – whether any TEL.mobi Group VSMP (via its Eligible Entity) has contravened “Acceptable Use” of the TEL.mobi Group or Webtel.mobi Product Suite and/or Facilities.
4. If it is decided that a non-criminal / non-illegal contravention has occurred, then:
The TEL.mobi Group and/or Webtel.mobi can cancel the Eligible Entity’s VSMP.
Cancel the TEL.mobi Accounts of the Eligible Entity’s Contact Persons.
Block the Contact Persons of the Eligible Entity from rejoining the TEL.mobi Group’s services and/or forming another VSMP.
Refund all Stored Credit in the Eligible Entity’s Contact Persons cancelled accounts, at the time of cancellation.
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5. If it is decided that a criminal / illegal contravention has occurred, then:
The TEL.mobi Group and/or Webtel.mobi can freeze the Eligible Entity’s Contact Persons’ Accounts, and the Stored Credit in the Account/s.
Hand the matter over to an appropriate international law-enforcement and/or Regulatory entity – or an appropriate international law-enforcement and/or Regulatory entity in a particular country, or both.
Proceed with the reconciliation of the Stored Credit in such an Eligible Entity’s Contact Persons’ Accounts, as further advised by the relevant law-enforcement and/or regulatory entity.
6. For the avoidance of doubt, in the event that freezing of VSMP Contact Persons’ Accounts and Stored Credit has occurred at the request of a relevant law-enforcement or regulatory entity, then:
If the relevant law-enforcement or regulatory entity thereafter informs the TEL.mobi Group / Webtel.mobi in writing that it has no claims to the frozen Stored Credit, it will be refunded to the Eligible Entity’s Contact Persons.
if the relevant law-enforcement or regulatory entity informs Webtel.mobi in writing that it has a claim on the frozen Stored Credit, the Eligible Entity’s Contact Persons will be informed by the TEL.mobi Group / Webtel.mobi. They will then be provided with the contact details of the relevant law-enforcement / regulatory body, and the Stored Credit will be sent to the account of nomination of the law-enforcement or regulatory entity.
7. For further avoidance of doubt, if an action is not initiated by Webtel.mobi / the TEL.mobi Group, but a request for action is rather received by Webtel.mobi / the TEL.mobi Group from any recognized any formal Government / Government-appointed / Government-mandated law- enforcement or regulatory entity wishing to make an enquiry or request action in respect of a TEL.mobi Group Eligible Entity’s Contact Persons, this will only be applied if:
An enforceable warrant or subpoena or other equivalent formal document is delivered in original or certified copy to the Head Office of Webtel.mobi (Holdings) Limited in Guernsey.
That is valid in the States of Guernsey.
For an act that is deemed to be an offence in or by the States of Guernsey.
And that is not in contravention of any legal or common law rights of the IA or the Eligible Entity’s Contact Persons.
Together with direct contact to Webtel.mobi from a verifiable member of any such a law- enforcement and/or regulatory entity, who has been officially authorized in writing by an identifiable official at a recognized competent government entity to attend to this matter. 329
SAFETY REQUIREMENTS
AND RESTRICTIONS –
TEL.MOBI GROUP
MEMBER ACTIVITIES
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SAFETY REQUIREMENTS AND RESTRICTIONS – TEL.MOBI GROUP MEMBER ACTIVITIES
1. The Requirements of TEL.mobi Group Members are to adhere to the “Terms of Use” and End User License Agreement “EULA” of the TEL.mobi Group while using the Product Suite and Facilities.
2. Naturally, this includes the requirement not to utilize the TEL.mobi Group Product Suite and Facilities for any illegal activities, or any other activities prohibited in terms of the TEL.mobi Group’s “Terms of Use” and “EULA”. These are available on all TEL.mobi Group portals, on the bottom left of every page, from the “Terms of Use” link – as well as the laws of the States of Guernsey and aspects of international law that are recognized by the States of Guernsey.
3. It also includes the requirement to adhere to any requirements and/or restrictions as contained in the various instructions and/or “How it Works” pages within the TEL.mobi Group Facilities Pages.
4. For the avoidance of doubt, it will be and is the sole prerogative of the TEL.mobi Group and Webtel.mobi Management to decide – at their sole discretion – whether any TEL.mobi Group Member has contravened “Acceptable Use” of the TEL.mobi Group or Webtel.mobi Product Suite and/or Facilities.
If it is decided that a non-criminal / non-illegal contravention has occurred, then:
The TEL.mobi Group and/or Webtel.mobi can cancel the Member’s TEL.mobi Account.
Block the Member from rejoining the TEL.mob Group’s Services.
Refund all Stored Credit in the Member’s Account at the time of cancellation.
5. If it is decided that a criminal / illegal contravention has occurred, then:
The TEL.mobi Group and/or Webtel.mobi can freeze the Member’s Account and the Stored Credit in the Account.
Hand the matter over to an appropriate international law-enforcement and/or Regulatory entity – or an appropriate international law-enforcement and/or Regulatory entity in a particular country, or both.
Proceed with the reconciliation of the Stored Credit in such Member’s Account as further advised by the relevant law-enforcement and/or regulatory entity.
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6. For the avoidance of doubt, in the event that any freezing of Member’s Account and Stored Credit has occurred at the request of a relevant law-enforcement or regulatory entity, then:
If the relevant law-enforcement or regulatory entity thereafter informs the TEL.mobi Group / Webtel.mobi in writing that it has no claims to the frozen Stored Credit, it will be refunded to the Member.
if the relevant law-enforcement or regulatory entity informs Webtel.mobi in writing that it has a claim on the frozen Stored Credit, the Member will be informed by the TEL.mobi Group / Webtel.mobi. They will then be provided with the contact details of the relevant law-enforcement / regulatory entity, and the Stored Credit will be sent to the account of nomination of the law-enforcement or regulatory entity.
7. For further avoidance of doubt, if an action is not initiated by Webtel.mobi / the TEL.mobi Group, but a request for action is rather received by Webtel.mobi / the TEL.mobi Group from any recognized any formal Government / Government-appointed / Government-mandated law-enforcement or regulatory entity wishing to make an enquiry or request action in respect of a TEL.mobi Group Member, this will only be applied if:
An enforceable warrant or subpoena or other equivalent formal document is delivered in original or certified copy to the Head Office of Webtel.mobi (Holdings) Limited in Guernsey.
That is valid in the States of Guernsey.
For an act that is deemed to be an offence in or by the States of Guernsey.
And that is not in contravention of any legal or common law rights of the Member.
Together with direct contact to Webtel.mobi from a verifiable member of any such a law- enforcement and/or regulatory entity, who has been officially authorized in writing by an identifiable official at a recognized competent government entity to attend to this matter.
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MULTIPLE
SAFE METHODS
FOR TEL.MOBI GROUP
MEMBER ACCOUNT
LOADING
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MULTIPLE SAFE METHODS FOR TEL.MOBI GROUP MEMBER ACCOUNT LOADING
A. Overview:
1. When TEL.mobi Group Members load their online Accounts, they are “Acquiring Stored Credit”.
2. This is not a purchase of any good/s or service/s.
3. It is merely the placing of their funds into a repository of Stored Value / Stored Credit, on a Closed-Loop Members-Only System.
4. This Stored Credit remains the property of the Member at all times unless and until it is used for a TEL.mobi Group Telephony Service, or unless it is Swapped with another Member in an MOSCS (at which time it becomes the property of the Member with whom it is Swapped).
5. Moreover, a Member may leave his/her Stored Credit in his/her TEL.mobi Account without using it for any amount of time that he/she wishes to.
6. This is why a Member can, at any time, request the Refund of any of his/her Stored Credit on the TEL.mobi Group System – because until it is used, it never ceases to be his/her property.
7. It is for this reason the acquisition of Stored Credit does not attract any GST or VAT charges when it is first placed into the Member’s Account.
8. Thereafter, because Webtel.mobi / the TEL.mobi Group:
conducts its business and provides the Services from Guernsey,
and all activities and transactions from / by or on Members’ Accounts are legally deemed to take place from and in Guernsey,
and Guernsey is a no-tax jurisdiction,
no VAT or GST is charged on Members’ use of TEL.mobi Group Telephony Services or any other inter-Member activities or Transactions on the TEL.mobi platform.
9. More information on these facts, as reviewed during extensive Legal Due Diligence, Product Due Diligence and Market Due Diligence by the entire Global ICT Practice of Frost & Sullivan, and seven Firms of Attorneys, can be seen in the “Testimonials” section of TEL.mobi Sites. 334
B. Loading via Payment Gateway:
1. Members are able to load their Accounts with Stored Credit via Payment Gateways, which can be accessed at the “Buy Credit (Gateway)” Facility on TEL.mobi Group Sites.
2. The Payment Gateway options provided are account loading by Credit Card, Debit Card and Online Wallets.
3. For loads by Credit Cards and Debit Cards, there are limits applied on load Amounts until Members’ KYC documents are uploaded. This is to protect against the use of Stolen Card details, and/or “Friendly Chargebacks” (i.e. Member-implemented chargebacks) after Stored Credit has been obtained and either used or swapped.
4. If Independent Agents and/or VSMPs wish to offer more / other online wallets to Webtel.mobi for consideration for use on TEL.mobi Group Sites, they are welcome to do so.
C. Loading via Top-Up Voucher:
1. Members are able to load their Accounts with Stored Credit via the acquisition and loading of TEL.mobi Group Top-Up Vouchers.
2. This is probably the most cost-effective and rapid method for loading TEL.mobi Group Accounts.
3. This system is also secure in that Top-Up Voucher validity, currency and value is able to be independently checked and confirmed by a Member prior to purchase, and the integrity of the Voucher Number / value is able to be independently maintained by a Member after purchase through his/her independent alteration of the Top-Up Voucher Key.
4. TEL.mobi Group Top-Up Vouchers can only be obtained from TEL.mobi Group Independent Agents and VSMPs at this stage.
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TEL.MOBI GROUP
DATA SECURITY
AND INFORMATION SECURITY –
PROTECTING MEMBERS AND VSMPS
WHILE UPHOLDING THE LAW
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TEL.MOBI GROUP DATA SECURITY AND INFORMATION SECURITY – PROTECTING MEMBERS AND VSMPS WHILE UPHOLDING THE LAW
The only data and Information on or of Members that is retained by Webtel.mobi is the Data and Information in the Member Accounts. All Data and Information – current and historical – in Member Accounts is retained.
This is necessary to maintain in order to provide the Services in a safe and orderly manner, and it is necessary for Members’, VSMPs’ and Webtel.mobi’s security. It is also for the implementation and enforcement of Anti Money Laundering activities and activities geared towards prevention / follow-up of any other attempt at illegal activity on the System.
It is also retained to be able to be provided to any relevant Law-Enforcement / Regulatory Authority/ies – either proactively if an attempted illegal activity by a Member / Independent Agent / VSMP is suspected. Otherwise upon presentation to Webtel.mobi of the relevant formal documentation by any relevant formal Law-Enforcement / Regulatory entity requesting information in the event of a suspected illegal activity by a Member / Independent Agent / VSMP / Eligible Entity.
Other than this, Webtel.mobi does not collect or store or aggregate or sell – or permit any other entity to view or collect or store or aggregate or sell – any Member, Eligible Entity or VSMP data or information whatsoever.
Webtel.mobi also does not place any Tracking Cookies, Intelligent Cookies, Scripts or other invasive or harmful Cookies / Scripts / facilities on or within its sites. It additionally does not permit external entities to do so (which is why it does not allow placement of Social Media sites icons’ on its sites, as these are often tunnels through which Member Data is extracted).
The only exception to the above is the Payment Gateway Facility, on which the Facility and Scripts of the companies “Inauth” and “Accertify” run permanently. The purpose of these scripts is to proactively identify stolen Credit Card / Debit Card details, known fraudulent activity email addresses, suspicious Mobile Devices / PCs / other PEDS, or suspicious activity. The purpose of this is to limit and reduce the possibility for fraudulent Transactions over the Payment Gateway. Details of “InAuth” and Accertify can be seen at these urls:
Inauth: https://www.inauth.com/
Accertify: https://www.accertify.com/
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Webtel.mobi takes Member, Eligible Entity and VSMP privacy and their rights to privacy seriously. As such, it will protect its Members’, Eligible Entities’ and VSMPs’ rights to privacy vigorously, and will only provide relevant information – including proactively if the situation merits it – to relevant formal Government and/or Government-mandated Law-Enforcement and/or Regulatory Entities under specific circumstances.
These specific circumstances are:
1. If there is an attempt or a suspected attempt by a Member, Eligible Entity or VSMP to conduct any illegal activity on the TEL.mobi Group System. For the avoidance of doubt, the term “Illegal Activity” refers to any activity that would be classified as such under the Laws and/or Regulations applicable in and by the States of Guernsey, and/or any Laws and/or Regulations of any other jurisdictions that are recognized and applied/enforced by and in the States of Guernsey. In such a case, Webtel.mobi will – if suspecting or uncovering such an activity – proactively hand the details of any Member, Eligible Entity or VSMP details and Accounts over to the GBA for investigation.
2. If the GBA and/or any Government and/or Government-mandated Law-Enforcement and/or Regulatory Agency recognized by the Laws of the States of Guernsey and/or the GBA provides Webtel.mobi with formal and legal written documentation requesting information on a Member’s, Eligible Entity’s or VSMP’s TEL.mobi Account in the event of suspected or proven illegal activity, then the details of such Account will be handed over to the GBA, for further provision to the requesting entity.
The “GBA” refers to the “Guernsey Border Agency”, and specifically to the “Financial Investigation Unit” for Cross Border Crime, the details of which can be seen at this url: http://www.guernseyfiu.gov.gg/
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SECTION 7
TEL.MOBI GROUP
IMPENDING SERVICES
339
OVERVIEW OF
THE TEL.MOBI GROUP’S
SIGNIFICANT
IMPENDING SERVICES
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OVERVIEW OF THE TEL.MOBI GROUP’S SIGNIFICANT IMPENDING SERVICES
The preceding list of TEL.mobi Group Services and Facilities represents fully operational, tested, proven and popular Services and Facilities, which have been operational worldwide since 2009.
Services and Facilities represents fully operational, tested, proven and popular Services and Facilities, which have been operational worldwide since 2009.
However, prior to 2018, some of the TEL.mobi Group Services and Facilities were on the “back-end” of the Service – meaning that Members could not access them directly, and rather had to send requests into the TEL.mobi Group for these Services and/or Facilities to be applied. They would then be applied by the TEL.mobi Group personnel. An example of one of these facilities that was previously on the “back-end” of the Service is the “Refund Transfers”.
In order to upgrade the TEL.mobi Group Service – with the Primary Objective being to give the Members themselves control over most aspects of their accounts – the TEL.mobi Group temporarily suspended its services, as it was necessary to rebuild much of the Webtel.mobi System Structure (it is more rapid and cost-effective to build new than to upgrade old).
Consequently, now that the upgrade is completed, with the majority of the TEL.mobi Group Member Services and Facilities now on the “front-end” – meaning that they are under Members’ direct control, the TEL.mobi Group Services are once again being made live to Members.
In order to – as requested by its exiting Members – restart its Services at the earliest opportunity, the TEL.mobi Group has made its upgraded Service and Facilities live again before inserting various Service and Facility additions. However, these additional Services and Facilities have already had their foundational Structures built, and those are already in the current TEL.mobi Group system. As such, these additional TEL.mobi Group Services and Facilities will be rolled out to its Members, on an ongoing basis, over the next 18 months.
An Overview of these additional TEL.mobi Group Services and Facilities that are being rolled out over the next 18 months is as follows overleaf:
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A. TEL.mobi Group Multilingualization Facility:
1. The TEL.mobi Group’s Service and Facilities have always been provided on a Multilingual Platform.
2. This current Upgraded Platform has also been built to function – as the TEL.mobi Group always has – in a Multilingual format, with both ASCII and Unicode languages.
3. The languages used on the TEL.mobi Platform cater for First, Second or Third languages of over 90% of the world’s population. This is because even if a Company or product has global coverage, if the potential Members in most countries cannot read it, they cannot use it.
4. Although this English-language Sub-Platform of the upgraded TEL.mobi Group Services and Facilities has been made live first, the additional language Sub-Platforms will also be made live in the near future.
5. Other than these existing language Sub-Platforms that are due to be made live in the near future, additional Sub-Platforms in additional languages will also be released on an ongoing basis.
6. The initial languages in which the TEL.mobi Group Services and Facilities Sub-Platforms are being made live are as follow, in alphabetical order:
Arabic Indonesian Russian Chinese Italian Spanish Dutch Japanese Turkish Filipino Korean Urdu French Malaysian Vietnamese German Polish Hindi Portuguese
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B. TEL.mobi Group Loyalty Card Facility:
1. Multiple Companies and Organizations worldwide have contacted the TEL.mobi Group to request arrangements whereby they will be able to offer TEL.mobi Group Members various Discounts and Deals for utilizing their services.
2. The TEL.mobi Group follows-up on any arrangements that can provide benefit to TEL.mobi Group Members.
3. Due to the TEL.mobi Group’s Global Coverage, the number and scope of Companies and Organizations that have approached it is very wide, and it will be of substantial benefit to TEL.mobi Group Members to be able to have these advantages.
4. As such, the TEL.mobi Group is already in the process of Establishing its Loyalty Card program, which will link to these various Companies and Organizations, and enable TEL.mobi Group Members to enjoy various and multiple discounts and other favorable concessions worldwide.
5. The TEL.mobi Group Loyalty Card is a Digital Card, permanently stored in a Member’s personal TEL.mobi Account. It is displayed on a Member’s Mobile Phone – with a version that functions on pre-Smart Mobile Phones too. It has all of the high-level Security Features of all other TEL.mobi Group Products and Facilities built into it.
6. The TEL.mobi Group Loyalty Card is also integrated with Members’ ITAN Numbers, and as a subsidiary feature, it will be integrated to the TEL.mobi Group Stored Credit Refund Machines (SCRMs – see next paragraph).
7. TEL.mobi Group Loyalty Cards can already be applied for my Members from their TEL.mobi Group Accounts, and they will be automatically issued once this Facility is ready to be made live.
8. There are no fees or costs at all levied by the TEL.mobi Group on its Members for acquiring TEL.mobi Group Loyalty Cards.
9. This Facility is already fully-functional within the Webtel.mobi system (and the appearance of the Loyalty Cards can also be seen in Members’ TEL.mobi Accounts), and it will be rolled out to Members in the near future.
This is a world-first and unique Service and Facility in the Global Telephony Sector.
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C. TEL.mobi Group Stored Credit Refund Machines (SCRMs):
1. The TEL.mobi Group has created its Global Top-Up Voucher system specifically to cater for the 30%+ of the world’s population (more than 2.2 Billion people) who are “Unbanked”. Due only to the fact that they are “Unbanked”, this large percentage of the world’s population are de- facto denied access to the 21st Century Digital Economy and Digital Services. This is because, being “Unbanked”, they cannot place credit onto Online Businesses through Traditional Payment Gateways (which require a Debit or Credit Card, or a Bank Account, or an Online Wallet).
2. Although the development of the TEL.mobi Global Top-Up Voucher solved the requirement to facilitate – on a global basis – the bringing in to the 21st Century Digital Economy / Digital Services Arena, it still did not provide proper “equality of opportunity” and “equality of access- opportunity” in terms of the full cycle of placement of “Stored Credit” into an online account. This is because although the system that enables them to place Stored Credit onto an online Platform in digital format has been solved, a system that enables them to Refund their Stored Credit to themselves if they need or want to had not been solved.
3. This was because they could not carry out a TEL.mobi Group Refund Transfer, because Refund Transfers may only go to a Bank Account that belongs to the TEL.mobi Group Member himself / herself.
4. Because of this, two Interim Measures that began to be spontaneously implemented by Independent Agents and VSMPs. The first Interim Measure was that Members would do a Top- Up Transfer to an Independent Agent’s or VSMP’s TEL.mobi Accounts, and then receive the amount of the Stored Credit Top-Up Transfer back from the Independent Agent or VSMP in money – less a fee (all terms and fees as agreed directly between Members and these Independent Agents and/or VSMPs).
5. The second Interim Measure was the same as the first, with the only difference being that a Member would exchange his or her TEL.mobi Top-Up Voucher with an Independent Agent or VSMP in return for the value of the Stored Credit in money – less the agreed-upon fee.
6. Although these Interim Measures achieved a purpose, they did not conform with the TEL.mobi Group’s “equality of opportunity” and “equality of access-opportunity” approach.
7. Therefore, a TEL.mobi System was developed which does comply with these requirements, and which will provide all TEL.mobi Group Members – including “unbanked” Members who cannot effect Refund Transfers – with equal access to apply for refunds of their Stored Credit on demand.
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8. This process is the TEL.mobi Stored Credit Refund Machine (SCRM) process, which is as follows:
The TEL.mobi Group has identified relevant machines that are able to securely store and dispense money, in a similar manner to Automated Teller Machines.
These machines are able to be integrated into the TEL.mobi Group system on a worldwide basis, utilizing Mobile Phone SIM connections to the Online TEL.mobi System.
The TEL.mobi Group has arranged for the acquisition, transportation and installation of these machines at extremely low cost (under US$100 per machine).
The running costs of the machines are very low (the cost of one Prepaid SIM per month, and the electricity or battery to run them).
The machines are able to remotely and accurately calculate the amount (and authenticity) of money placed into them, and report it to the TEL.mobi system automatically and in real time. They are also able to – accurately – calculate the amount of money withdrawn from them and report it to the TEL.mobi System automatically and in real time.
TEL.mobi Independent Agents and VSMPs will be given the opportunity to acquire these machines and place them in venues selected by them.
The TEL.mobi Agents and VSMPs will stock the machines with Stored Credit money in-situ. Whenever a Stored Credit Refund is applied at one of these machines, the TEL.mobi Group system will automatically and in real time debit the account of the Member who is making a Stored Credit Withdrawal, and credit that amount of Stored Credit to the TEL.mobi Account of the Independent Agent or VSMP whose machine it is – together with a very small fee levied for this service.
As such, the TEL.mobi Independent Agent or VSMP who loads the machine is never out of funds for doing so, because when a TEL.mobi Member effects a Stored Credit Refund Withdrawal from the machine, the equivalent amount of Stored Credit refunded from the SCRM is simultaneously placed into the Independent Agent’s / VSMP’s TEL.mobi Account. Moreover, the Independent Agent or VSMP will – besides having any Stored Credit refunded by the SCRM immediately credited to his/her TEL.mobi Account – additionally be credited with a and additional usage fee for every Stored Credit Refund Withdrawal which is made.
9. These machines are known as “Stored Credit Refund Machines” (“SCRMs”), because their purpose is to enable TEL.mobi Group Members who are unable to utilize the Refund Transfer facility to nevertheless gain access to Refunds of their Stored Credit, on an equality of opportunity and equality of access-opportunity basis to all other Members.
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10. The TEL.mobi Group cannot utilize existing ATMs for this service, as they function according in a totally different sector – the Financial Services Sector – whereas Webtel.mobi and the TEL.mobi Group function in the Telephony Sector.
11. As such, the SCRMs usage is strictly restricted, to only Members of the TEL.mobi Group’s Closed Loop system, and only for Stored Credit Refund Withdrawals.
12. For Best Practice reason, equivalent limits on the amounts able to be Refunded to Members in Stored Credit Refund Withdrawals will be restricted to amounts that are equivalent to those applied in the Financial Sector to ATM machines.
13. All 5-Factor and 6-Factor Multi-Factor Authentication processes as are applied in and to all other TEL.mobi Group Services and Facilities are being applied with the SCRMs.
14. The TEL.mobi Group Loyalty Card has been structured to be the instrument through which Members will be able to access and use the SCRMs worldwide.
15. In response to requests from Independent Agents and VSMPs in rural and/or difficult-to-reach areas that lack any infrastructure, the TEL.mobi Group has – other than planning and structuring the delivery of Standard SCRMs for placement in standard premises – also structured the provision of Special Purpose SCRMs. These are Mobile SCRMs in vehicles that are equipped for rough conditions to be able to travel into rural areas, and Marine SCRMs that are equipped to be placed into small boats to travel between ships in harbors and ports (as well as SCRMs that can be placed in passenger and commercial ships and ferries).
16. This system is already built and functioning and the SCRM program will be rolled out to TEL.mobi Group clients worldwide in the near future.
17. There is no comparative service to this service in terms of a cost-comparison. However, if one were to take a totally different service and sector which has some similarities – that being withdrawals from ATMs – the extremely low fee for a Stored Credit Refund Withdrawals is on average 99% lower in cost.
This is a world-first and unique Service and Facility in the Global Telephony Sector.
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D. TEL.mobi Group Global Business Pages Facility:
1. The number and range of Eligible Entities that have applied for Consent to establish TEL.mobi Group Global VSMPs is considerable. In one eight-week period, TEL.mobi Group Independent Agents received VSMP Applications from Eligible Entities in over 180 countries, which Eligible Entities had a cumulative client / member / student / other basis in excess of 300 Million persons.
2. In fact, if one takes the geographic spread of just the current Eligible Entities that have applied for TEL.mobi Group VSMPs, and through which the TEL.mobi Group can distribute its Electronic Top-Up Vouchers, SCRMs and other facilities, The TEL.mobi Group already has a larger Global Distribution Coverage than Amazon. This excludes the Global Distribution Coverage when the Independent Agents are factored in – which more than doubles the coverage.
3. Consequently, there is already an extremely wide range of Eligible Entities within the TEL.mobi Group, almost all of which provides goods or services of their own.
4. Moreover, every TEL.mobi Group VSMP is inter-operable, runs from a centralized database, and all TEL.mobi Group VSMPs and Members have their one-click Calling and Texting facilities available in their Prepaid Telephone Accounts.
5. As such, the TEL.mobi Group has structured a Global Business Pages Facility, on which all Eligible Entities that have VSMPs – and/or the Members of TEL.mobi Group VSMPs – can advertise and describe their goods or services, and allow one-click and immediate contact directly to them for these goods or services, by and from all and any other TEL.mobi Group Members.
6. A company that provides a similar service internationally – and which derives most of its revenues from this service – is Alibaba. There are, however, significant differences between the service provided by Alibaba and the TEL.mobi Group’s Global Business Pages Facility, as follow:
The Global Business Pages Service and Facility will be provided free to all TEL.mobi Group Members. There are no costs, fees or charges to advertise on the Global Business Pages Facility.
The TEL.mobi Group Business Pages Facility will be open to all TEL.mobi Group Members to place their product or service details on, as well as their own contact details.
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Because this Facility will be viewed by other TEL.mobi Group Members, advertisers can place their contact telephone or text numbers in the advertisement, for immediate one- click contact by any other TEL.mobi Group Member at the ultra-low TEL.mobi Group costs.
The Taxonomy (categorization) of services is very clear and intuitive.
It is available in all 20 languages that cover 90% of the world’s population (in the near future).
It is available to all market-sectors, in all countries, worldwide, on all Smart Phone platforms, all pre-Smart Mobile Phones, and all internet-enabled PEDs.
In a manner that caters for all levels of internet-proficiency, and for low bandwidth speed, high-bandwidth cost and prepaid bandwidth / mobile internet markets worldwide.
7. This entire Service and Facility is a free service to TEL.mobi Group VSMPs and Members.
8. The infrastructure for this service is already built into the TEL.mobi Group’s System, and it will be rolled out to TEL.mobi Group Members and VSMPs in the near future.
This is a world-first and unique Service and Facility in the Global Telephony Sector.
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E. TEL.mobi Group Global Marketplace Facility:
1. The TEL.mobi Group has structured the “Global Business Pages” facility to enable the extremely wide variety of companies and organizations within the TEL.mobi Group Global Ecosystem to advertise one another’s services free of charge, and also to be able to initiate one-click contact with one another worldwide.
2. However, if the TEL.mobi Group’s “equality of opportunity” and “equality of opportunity- access” principles are taken into account, there are large numbers of TEL.mobi Members that are, or that have, small companies and organizations worldwide. These small companies and organizations are not always financially strong – especially in developing markets.
3. Therefore, although they will have the opportunity to advertise their goods and services free of charge, they may not have the resources to sell or deliver goods and services internationally – due to the high costs and complexities required to establish Payment Gateway services or delivery services.
4. To alleviate this situation, and provide the “equality of opportunity” and “equality of opportunity-access” to all its Members, the TEL.mobi Group has therefore structured a “Global Marketplace” facility, on which all TEL.mobi Group Members can advertise and sell their goods or services, to other TEL.mobi Group Members, in a manner that has unique characteristics.
5. A company that provides a similar service internationally – and which derives almost all of its revenues from this service – is Amazon. However, there are significant differences between the service provided by Amazon and the TEL.mobi Group’s Global Marketplace Facility, as follow:
The Global Marketplace Service and Facility will be provided free to all TEL.mobi Group Members. There are no costs, fees or charges to advertise on the Global Business Pages Facility.
The collection and delivery of products for sale is automatically arranged through the integration of a world-leading international Courier/Delivery company’s software into the Global Marketplace Facility. As such, the pickup at the seller and delivery to the buyer is automatically registered at the Courier/Delivery company through the TEL.mobi Group system, with the Courier/Delivery company’s (low) costs automatically factored in to the sale price.
Webtel.mobi / the TEL.mobi Group do not add any mark-up to this Courier/Delivery cost, but rather provide this for free to Members, as well as negotiating down for Members the Courier/Delivery cost charged by the Courier/Delivery company.
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Sellers do not require a Payment Gateway to sell their items. They only need to display their TEL.mobi Group ITAN number and Registered Mobile Number, and specific Item Numbers for the products being sold, and payment will be made instantaneously via a transfer of Stored Credit from one TEL.mobi Group Member to another, in the Closed-Loop Members-only system, instantly and fully recorded in both Members’ “History” Facilities.
Payment can additionally be made in whatever currency the products are offered for sale without incurring the notorious “double-billing” from hidden and forced Currency Conversions at very unfavorable rates, because TEL.mobi Group Members can do their own Currency Conversions at extremely favorable rates between their own Currency Wallets in their TEL.mobi Accounts before purchasing.
Although transfers of Stored Credit via Top-Up Transfers are implemented immediately and placed into the seller’s TEL.mobi Stored Credit account, this Stored Credit for such purchases is (automatically) frozen in the Member’s Account until the Courier/Postal Company doing the delivery confirms the successful receipt and delivery of the purchased item to the buyer, whereupon the freeze is (automatically) lifted. This is another process to ensure security of selling and purchasing parties, provided for free to TEL.mobi Members.
In Developing Market countries or areas where there is no recognizable physical address for pickups or deliveries, the VSMPs to which Members in such areas belong act as collection and/or delivery hubs (they are able to charge fees for this service – negotiated directly between the Member and the VSMP).
6. This entire Service and Facility is a free service to TEL.mobi Group VSMPs and Members.
7. The infrastructure for this service is already built into the TEL.mobi Group’s System, and it will be rolled out to TEL.mobi Group Members and VSMPs in the near future.
This is a world-first and unique Service and Facility in the Global Telephony Sector.
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F. TEL.mobi Group Targeted Pay Per Click Marketing (PPC) Facility:
1. In respect of the Targeted Marketing sector, the primary current methodology applied – often by Social Media Companies – is akin to acting as de-facto Intelligence Organizations; but Intelligence Organizations without any oversight at all. This is because they seize and retain all of their clients’ private and other data, match it with multiple other sites internet-wide, and then sell this private data to advertisers.
2. In respect of the Targeted PPC sector, the primary current methodology applied is to charge clients enormous fees for a service that has dubious results at best.
3. The above approaches are totally counter to the TEL.mobi Group’s views towards business in general and its Members and VSMPs in particular – which views are that it should provide them with the best possible service at the lowest possible cost, if not for free, and safeguard their privacy.
4. On review, it was established the Webtel.mobi and the TEL.mobi Group could, in fact, provide a extremely Targeted PPC Service internationally, in a manner that complied with its views on business and Member Privacy, yet delivered one of the most effective – if not the most effective – Targeted PPC Marketing systems worldwide.
5. This would be through providing a Targeted PPC Marketing service on its Desktop platforms, with mini paragraph-size marketing messages with clickable links within them, running down the side of the page that shows the TEL.mobi Product and Service Platform.
6. A company that provides a similar service internationally – and which derives almost all of its revenues from this service – is Google. However, there are significant differences between the service provided by Google and the TEL.mobi Group’s Targeted PPC Marketing Facility, as follow:
The TEL.mobi Group will provide absolutely precisely-targeted PPC marketing spots at the lowest costs – not the highest costs – possible.
The TEL.mobi Group’s Targeted PPC System will not have to use imponderables and/or hopes or suppositions in respect of precise targeting, it will utilize cold fact.
The TEL.mobi Group Targeted PPC Facility will be able to do so without using or abusing any private data / preferences / choices / profiling /information grabs from its Members at all.
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7. The reasons for the abovementioned advantages enjoyed by the TEL.mobi Group in this respect are as follow:
Every Eligible Entity that established a VSMP in the TEL.mobi Group provides information necessary for formation of the VSMP.
This information includes:
The sector in which the Eligible Entity functions.
The precise nature (sub-sector) of the VSMP’s activities within that sector.
The address at which it is located – including Country, Province/State, City/Town and/or Suburb.
As such, all of the above information is already in the TEL.mobi Group system, but none of it is private business data – just already openly disclosed business or organization locations and sectors of business / activities – and none of it at all is private Member data either.
Moreover, multiple Eligible Entities in exactly the same sectors and sub-sectors have VSMPs worldwide. As an example – Universities.
Universities from all countries in the world, many cities/towns in these countries, and many suburbs in these cities/towns have applied too be VSMPs. Therefore, if another TEL.mobi Group wishes to place PPC marketing on TEL.mobi Group platforms targeted at University Students, the facility already exists to allow the advertiser to do so without (mis)using any private Member or VSMP data.
This is because the system already has all of the details of the Eligible Entities in the TEL.mobi Group system that are Universities, and even what type of Universities, and their Countries, Provinces/States, Cities/Towns and even Suburbs of location.
As such, Targeted PPC marketing can be directed automatically by the TEL.mobi Group System directly onto the online platforms of Universities – but not just to Universities in general, rather to a far more targeted selection.
This is because of the fact that due to the pre-existing Eligible Entity Sector, Sub-Sector and Location details in the TEL.mobi Group system, PPC Advertisers can – without gaining access to any private Eligible Entity, VSMP or Member data – select to place their PPC advertisements on the VSMPs of:
All Universities in the world, or Universities offering specific fields of study, or
All Universities / Universities in a specific field of study in one specific country, or
All Universities / Universities in a specific field of study in a specific Province/State of one country, or
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All Universities / Universities in a specific field of study in a specific City/Town in a Province/State, or
All Universities / Universities in a specific field of study in a specific Suburb of a City/Town.
And moreover, the PPC Advertiser can also then be sure that all persons who click on his or her PPC Advertisement on the chosen VSMP will all be Students (mostly) at the selected University/ies, or Faculty Members at the selected University/ies, or Parents/Family of Students at the chosen University/ies.
This is because every VSMP is specific only to one specific Eligible Entity (i.e. each university has its own VSMP, each Travel Agent has its own VSMP, Each Hotel has its own
VSMP, each Sports Club has its own VSMP, etc).
There is no more Targeted a Marketing system available anywhere worldwide – and moreover, it is precise and pinpoint targeting without having to use any private Member or
VSMP data, at all.
8. In all current “Targeted” PPC systems internationally, clients pay enormous amounts of money to buy “Key Word” positioning. This is, however, a risky strategy, for the following reasons:
An Advertiser wanting to target University Students may pay enormous amounts of money for the word “University”, so that whenever people type in the word “University” in their Search Engine searches, their PPC advertisements will appear in or alongside the results.
However, this does not take into account the fact that anyone could be typing in the word “University” – and for any reason.
It could be journalists looking for information, researchers from any number of organizations for any number of reasons, cleaning staff or groundsmen seeking employment, Accounting firms looking for potential clients, a whole multitude of Services’ Companies looking to provide their services to the University – not just students.
This already unfavorable situation is made worse by not factoring in the harm caused by “click farms” or bots who click automatically on large search engine platforms.
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9. In summary, that which appears to be “Targeted” is by no means really Targeted at all, and can result in Advertisers spending enormous amounts of money to buy “Key Words” or “Key Phrases” that, in the final analyses, are fairly useless in real terms. The situation is, in fact, much like this comparative example:
It is like an Advertiser wanted to market a product to Business Class airline passengers, and paid salespeople to stand at the entrance to an airport terminal, to give out very expensive advertising leaflets targeting specifically Business Class airline passengers to everyone who entered the airport. Some Business Class airline passengers would receive the leaflets, but most of the leaflets would in fact go to the ground staff, restaurant staff, cleaners, security personnel, Economy/Coach Class airline passengers and others who walked into the entrance of the airport terminal.
As such, many or most of the very expensive leaflets would be given to people who would not be interested in them and just throw them (and thereby, the advertiser’s money) away, because they would not be the targeted Business Class passengers.
This also does not take into account that – like click farms and bots with online advertisements – some or many of the salespeople may just throw their quotas of the very expensive leaflets away, and not give them out.
10. In comparison, a comparative airport example of the TEL.mobi Group Targeted PPC Marketing would be like and Advertiser being able to take very low-cost but good-looking advertising leaflets targeting Business Class airline passengers, and then:
Go and stand directly at the Business Class check-in counters inside and airport terminal.
And furthermore being able to select the specific airline on which Business Class passengers were flying.
And moreover being able to select only the Business Class airline passengers flying on a specific airline, and flying to a specific destination.
And therefore giving all of the advertising leaflets to exactly the required targeted market, at an extremely low cost per leaflet.
11. This is the most targeted and cost-effective targeted PPC Marketing system available today – and available without the requirement for compromising any VSMP or Member private data. It is also a world-first and unique system.
12. The infrastructure for this Facility has already been built into the TEL.mobi System, and this facility will be made available to TEL.mobi Group Members in the near future.
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G. TEL.mobi Group Global Emergency System Facility:
As stated by the Global ICT Practice of Frost & Sullivan, the TEL.mobi Group’s Global Telephony System has the largest geographic footprint of any telephone company in the world.
Specifically, it is able to make Calls and send Texts to and from all and any Mobile Phones worldwide – or make calls to and from any Landline Telephones worldwide.
It is the only Telephone Company in the world that can do this (and at costs that are on average up to 80% lower than the standard cost of other providers).
For this reason, other than equipping the TEL.mobi Group to be able to carry out comprehensive business worldwide, this situation also provides the TEL.mobi Group with the opportunity to implement positive and helpful projects for people on a global basis.
One way of utilizing its global footprint to implement a globally positive and helpful Facility worldwide is the TEL.mobi Group’s Global Emergency System Facility, which functions as follows:
1. On a regular basis, many thousands of people either lose their lives or are seriously injured in Natural Disasters worldwide – specifically due to Tsunamis, Tornadoes and similar natural Disasters.
2. The characteristic of multiple types of Natural Disasters that take many thousands of people’s lives is that they are predictable, and predicted, with quite some accuracy.
3. What causes these predictable and predicted Natural Disasters to take so many lives is not, therefore, a lack of information as to their approach.
4. It is rather that there does not exist a comprehensive worldwide system (or indeed, often, not even a comprehensive National or Local system) to inform people of the approaching Natural Disaster in a manner that ensures – to the greatest extent possible – that they will receive the information before the Natural Disaster strikes.
5. This is especially the case in Developing Countries, where the infrastructure for radio and other means of mass warnings do not exist, or people are too poor to afford them.
6. However, in all of these countries and situations, almost all people – rich or poor – have Mobile Phones, and the TEL.mobi Group – via Webtel.mobi – can communicate with every single one of them, immediately, worldwide and simultaneously. It is the only entity in the world that can do this.
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7. As such, Webtel.mobi has structured, for the entire TEL.mobi Group, a Global Emergency System Facility, which functions in the following manner:
All TEL.mobi Group Members can sign up on this Facility for free.
Members will provide their address details so that their geolocation is registered in the TEL.mobi system.
Members who are travelling to X or Y country or Region or City will also be able to enter their destination and period of time that they will be in or at that destination.
The TEL.mobi Group system will integrate via API connection to all relevant and existing early warning systems, such as the Pacific Tsunami Warning Centre, the NORA Storm Prediction Center, and various others that exist internationally.
When a warning is provided of an impending or approaching Natural Disaster, this will be received by the TEL.mobi System, which will automatically send out an Emergency Alert Text message to all people in the vicinity where the impending and/or approaching Natural Disaster is due to strike.
These messages will be sent out to each Member living in the predicted impact area – or who has travelled to the predicted impact area – in that Member’s selected language as used on the TEL.mobi Group.
This will ensure that, on a global basis, a comprehensive and real-time warning can be provided to all potentially endangered people, in good time, directly to their own Mobile Phones – for a comprehensive and Global system poof alerts that have the highest chance of success.
8. This will not be a free facility to implement, but it will be a Free system for all TEL.mobi Group Members, as follows:
There are three levels of Alert that the TEL.mobi Group will send out via its Global Emergency Alert facility. They are:
Possible
Possible to Probable
Probable to Definite
Different people have different preferences, and some like more information than others.
For this reason, the first two levels – they being the lowest and lower levels of “Possible” and “Possible to Probable” – will be charged for.
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The third and highest level of alert – being “Probable to Definite” will be sent out with Webtel.mobi subsidizing the cost of these texts and this system in all respects, so that the Global Emergency Alert System is provided completely free to all TEL.mobi Members worldwide.
This is because it is the view of Webtel.mobi that the ability to assist people in potential distress should never be predicated on the expectation of payment or reward. Furthermore, this will also be done to assist people in poor circumstances who sign up for free as Members of the TEL.mobi Group specifically and only for the use of this Facility - because they cannot afford to use any other of its Facilities.
9. The foundational structure for this Facility is already built, and part of it is already fully operational. The completed Facility will be rolled out to TEL.mobi Group Member in the near future.
This is a world-first and unique product in the Global Telephony Sector.
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SECTION 8
TEL.MOBI GROUP
RESTRICTED SERVICES
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VOLUNTARILY RESTRICTED
TEL.MOBI GROUP
SERVICES
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VOLUNTARILY RESTRICTED TEL.MOBI GROUP SERVICES
The TEL.mobi Group system is extremely versatile and powerful. Moreover, because it was fully designed and built by Webtel.mobi in all respects, Webtel.mobi is fully aware of all of its capacities – current and future.
On occasion, TEL.mobi Group Independent Agents and VSMPs send through enquiries and requests for Services and/or Facilities that are not currently in or on the System, and these enquiries and requests are always appreciated.
There are, however, some Services and Facilities that the TEL.mobi Group has elected not to implement even though it is fully able to.
This section is therefore an advisory to Independent Agents and VSMPs about two of these Services and Facilities, which Webtel.mobi has taken a decision not to implement. It is provided in order to save Independent Agents and VSMPs the trouble of sending through motivations for Webtel.mobi to establish these Services and Facilities.
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A. Global Lottery:
1. Lotteries are generally successful if they comply with four specific prerequisites, which are as follow:
The amounts provided in prizes are fairly high.
The costs to enter are relatively low.
The process to enter is fairly easy.
The geographic area in which the entrants are / number of entrants in an area is large.
2. If any three of the above prerequisites is met, it is a virtual certainty that the lottery will be very successful.
3. If all four prerequisites are met, it will be extremely successful.
4. If all four prerequisites are met, then the lottery that has the largest representation in terms of prerequisite 4 – a large geographic area that it covers, or a large number of people within an area covered – will be spectacularly successful.
5. All of the largest lotteries in the world (in terms of the amounts of money that they take in and give out as prizes) are the ones with the largest number of persons in the entering area.
6. The Largest Lottery in the world, for example, is the Spanish Christmas Lottery – which has entrants from many Spanish-speaking countries. Its Prize Money is on average Euro 2.2 Billion / US$ 2.5 Billion. It is this successful because it adhered to all four requisites, and has a large number of people who can enter it.
7. Similarly, the Second Largest Lottery in the world – the Chinese Sports Lottery – has a similar level of prize money, and is successful to this level because it complies with all four prerequisites and has a large number of people who are potential entrants.
8. Webtel.mobi / the TEL.mobi Group outclasses both of these lotteries in terms of the first three prerequisites by factors, and in the fourth prerequisite – area and number of people covered – it shatters the combined area / number of people it can reach who are entrants by 150 times.
9. Other than this, Webtel.mobi has a fully functioning system that it can convert into a Global Lottery within less than four weeks, and it can also carry out Global Marketing. Global Entry Fee Collection and Global Payouts at no cost; conduct a live draw with fully certified draw machines live streamed worldwide at a cost of under US$ 5 000 per draw; and can obtain a valid license to conduct this activity with ease, and at low cost. 361
10. As a brief overview, the following:
The Webtel.mobi Texting Facility can be immediately made into an additional Lottery Facility simply by replacing the empty field for text copy with a series of squares in which numbers are inserted.
All Lottery details can simply be placed on that Facility’s page.
All Payment can simply be deducted from Members’ online Stored Credit Accounts – and Payouts remitted to the same online Stored Credit Accounts.
With the potential market being the entire world, and all people in the world that have any Smart Phones, pre-Smart Phones or any Internet-enabled PED able to enter immediately.
Due to the size of the potential entrant market (in the Billions), the ticket cost can be the lowest in the world, but the revenue generated will – without question or doubt – be the highest in the world.
This will, in turn, result in the highest prize money in the world.
11. This entire business model has been reviewed, due diligenced, planned and tested, and confirmations regarding the Lottery Draw machines, the certifying Accounting Firm, the appropriate license and the appropriate structuring to render the lottery legal and acceptable in all jurisdictions have been carried out.
12. The structuring is so complete that it can be fully implemented in under one month from the decision to do so.
13. However, Webtel.mobi and the TEL.mobi Group will not implement a Global Lottery.
14. This is because even though:
It will cost Webtel.mobi little more than zero to run the largest – and what would without doubt be the most profitable – Lottery in the world; and
Despite the fact that if doing so it would do so as a 100% charity and give out all funds received as prizes or to charitable causes,
15. Webtel.mobi can nevertheless not guarantee that it will not cause misery and distress to a large number of persons who are addicted to such gambling activities – to the detriment of families worldwide.
16. Due to the Global reach and nature of such a Lottery, and the enormous prizes money that would result, It will be a very tempting Lottery for many people to potentially enter.
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17. A noticeable number of people internationally who participate in lotteries are people who are in the most vulnerable circumstances, and often they utilize funds better spent on their families’ welfare or even basic survival requirements on such lotteries – either through irresponsibility or desperation – to try to win money that they think will assist them to escape their circumstances.
18. In reality, even though many people (in terms of numbers) win prizes in a lottery, in real terms, the percentage of people who win prizes is miniscule, and a large percentage of people who lose money are in the most vulnerable person category.
19. This is the cause of extreme distress not only to such people, but to all of their dependants too; and enormous prize money totals drive much greater numbers of vulnerable people to take enormous risks – to the severe detriment of their children and dependents who bear the consequences of what little money they have almost invariably being lost.
20. Webtel.mobi has not only already established the above facts in respect of implementation of a Global Lottery by itself, it has also been previously approached by lottery operators worldwide – for national lotteries, 4-in-1 lotteries in the Asian market, sports results lotteries and many others – for implementation according to contracting, subcontracting, joint-venture and other corporate structures. It has, however, gratefully declined all offers. This is not a reflection of anything negative in respect of the entities that have made the approaches to Webtel.mobi – some of them very large and internationally prestigious entities. They are all responsible entities, which run their businesses openly, correctly and according to all relevant requirements and responsibilities. It is simply that Webtel.mobi’s own choice is not to participate in this sector at this time.
21. For these reasons, Webtel.mobi will not consider implementing its Global Lottery or any other form of lottery on its platform or via VSMPs, and Independent Agents and VSMPs are thanked in advance for any consideration thereof, but are informed that any such request or approach in this regard will bear no fruit.
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B. Global Bulk SMS/Text Sending:
1. As its Global Telephony Product is one of the most sophisticated in the world, Webtel.mobi is able to provide a Bulk Text/SMS sending facility as a standard Facility within its VSMP structure if it wishes to. It has, however, disabled the Bulk Text/SMS sending facility for VSMPs.
2. The reason for this is that many companies worldwide utilize the Bulk Text/SMS Facility for sending Marketing Messages to Mobile Phones – much of which is unsolicited, or Spam.
3. Although Webtel.mobi’s systems monitor all activities on the entire TEL.mobi Group system constantly, and any such bulk Text/SMS sending will be picked up immediately, it will only be picked up when it is in the process of being sent out. Moreover, due to the Global nature of Webtel.mobi’s service offering through the VSMP system, it is not possible to prevent this from happening.
4. Webtel.mobi has been approached by multiple very large mobile marketing companies from worldwide to provide them with a Bulk Text/SMS Facility, and has been offered enormous amounts of money to do so. However, Webtel.mobi will not become involved with – or assist other to engage in – unsolicited and/or Spam Bulk Text/SMS message sending.
5. For this reason, Webtel.mobi will not consider providing a Bulk Text/SMS Facility to VSMPs as a standard offering, and Independent Agents and VSMPs are thanked in advance for any consideration thereof, but are informed that any such request or approach in this regard will bear no fruit; unless there is a very compelling motivation for it.
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SECTION 9
IMPORTANT
ADMINISTRATIVE
CONSIDERATIONS
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COMPREHENSIVE FACILITIES
FOR ELIGIBLE ENTITIES
TO ESTABLISH AND MONITOR THEIR OWN VSMPs
IN A NON-COMPLEX
AND RAPID MANNER
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COMPREHENSIVE FACILITIES FOR ELIGIBLE ENTITIES TO ESTABLISH AND MONITOR THEIR OWN VSMPs IN A NON-COMPLEX AND RAPID MANNER
A. Overview:
The TEL.mobi Platform is an extremely sophisticated and complex system. However, the sophisticated and complex “back-end” (the working parts that are not seen) have been specifically structured so as to be accessible and controllable from a “front-end” (the part that is seen and interacted with) that is easy to follow and easy to use.
This was done so as to enable all and any persons – regardless of their experience with internet- based facilities – to interact with it and use it with confidence and competence.
Moreover, on all pages, a “How it Works” section has been included to provide further helpful information on the use each facility, and Handbooks have been drawn up to assist Eligible Entities in respect of VSMP formation and monitoring.
The Primary Role of the Eligible Entity in respect of the TEL.mobi Group’s Value Constellation system is to form its own VSMP, and to receive and distribute the TEL.mobi Group’s Weekly Marketing Messages to its existing client / user / member / other base, to direct them to use the Products, services and facilities on their own VSMP.
Naturally, other than the above, Eligible Entities are also welcome to utilize the Products, Services and Facilities for starting / furthering / expanding / improving / cost-cutting their own existing Business Services/Activities.
The points on the next pages illustrate a general process that can be followed in order to facilitate rapid and non-complex Establishment and Monitoring of their own VSMP by an Eligible Entity.
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B. Preparation, Application and Establishment:
The following process is the one usually followed for the Establishment of a TEL.mobi Group VSMP:
1. Join the TEL.mobi Group as a Member after either being introduced to it by an Independent Agent, or by reviewing it yourself.
2. Familiarize yourself with the TEL.mobi Group Facilities
3. Read the Static Information Pages on the TEL.mobi Group – which run along the top and bottom of all TEL.mobi Group Sites.
4. Read the TEL.mobi Group “Terms of Use” in the Static Information Page at the bottom left hand side link on all TEL.mobi Group sites.
5. Go to the “Apply for an Affiliate (VSMP)” Facility on your TEL.mobi Account, and download & read the VSMP Handbook once (preferably). Please note that even if you do not read the VSMP Handbook before applying to be an Independent Agent, you will still be subject to the Terms, Conditions and Rules contained within it.
6. Upload your Verified and Certified KYC Documents at the “Upload KYC” Facility on your TEL.mobi account.
7. Go to the “Apply for an Affiliate (VSMP)” Facility on your TEL.mobi Account and read the information on that Page.
8. On the “Apply for an Affiliate (VSMP)” Facility on your TEL.mobi Account, click on the “Apply for a VSMP” button.
9. Go through the self-explanatory steps on that facility and Create your own VSMP.
10. If you have uploaded your KYC Document, once you have completed the process to Create your own VSMP, the VSMP will be made temporarily live. It will then be reviewed by a TEL.mobi Group Independent Agent with eight to twenty-four hours after it has been created.
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11. If there are no issues with the VSMP Name or any other aspect, it will be left permanently live. If there are issues with it, these will be attended to by the Independent Agent in consultation with the Contact persons at the Eligible Entity, after which it will – once the issues have been rectified – be left permanently live.
12. Your TEL.mobi VSMP “Welcome Letter” of Consent and VSMP Establishment – together with your unique TEL.mobi Group VSMP Number and other relevant information – will then be automatically and immediately emailed to your registered Email address.
13. This will also include the details for you to log in to your own personal VSMP Administration Console, which will enable you to view and Monitor all aspects relating to your VSMP.
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C. Familiarization – VSMP Administration Console:
1. Once an Eligible Entity has Applied for and Established a TEL.mobi Group VSMP, a “Welcome Email” is sent to the Contact Persons’ Registered Email Addresses.
2. The Welcome Email provides the Eligible Entity’s Contact Persons with:
Their Unique TEL.mobi Group VSMP Number.
Instructions on how to Access and Manage their Unique VSMP Administration Console Facility.
Additional information and advice relevant to the activities of a TEL.mobi Group VSMP.
3. Once the Eligible Entity’s Contact Persons have received this information, they should login to their Unique VSMP Administration Console (“T-OPS”) Facility, look through it, and familiarize themselves with it. The VSMP Administration Console facility will enable them to fully Monitor and Manage all aspects related to their VSMP (see the next Section of this document for details of what you will be able to see, do and manage from the Unique VSMP Administration Console Facility).
4. In their Unique VSMP Administration Console Facility, the Eligible Entity’s Contact Persons will also find the details of the Responsible Independent Agent assigned to their VSMP, and they can initiate contact with their Responsible Agent for any queries or Requests for Assistance that they may.
5. Finally, if the Eligible Entity’s Contact Persons have not already done so, as part of the familiarization process they should read the VSMP Handbook at least once.
6. After this, the Eligible Entity and its Contact Persons will be able to promote their VSMP with confidence.
7. This is because the Platform, Services and Facilities of both the TEL.mobi Group’s System & Platform – as well as the Administration Console – are both easy-to-use and self-explanatory. They are specifically designed so that – although they are complex in back-end operation – they are intuitive and easy to navigate, understand and use on the front-end.
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8. Similarly, the motivations for Members to join and use the TEL.mobi Products, Services and facilities via the Eligible Entity’s VSMP are extremely self-explanatory to them and for them. This – combined with the fact that VSMP provides the Eligible Entities with a significant new source of revenue at zero cost and effort for it, while similarly cutting its members costs and providing them with more efficient services – results in a virtual 100% positive response rate from all parties.
The TEL.mobi Group System has been designed to provide all Eligible Entities with the maximum required Structures, Processes, Assistance, Tools, Facilities, Information and Opportunities to successfully establish their own VSMPs and generate significant new revenues at zero cost – while simultaneously significantly reducing its Members costs for these services compared to other providers.
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FREE “T -OPS” ADMINISTRATION CONSOLE,
FOR EASY AND EFFECTIVE, LEADING-EDGE & COMPREHENSIVE
MANAGEMENT
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FREE “T-OPS” ADMINISTRATION CONSOLE, FOR EASY AND EFFECTIVE, LEADING-EDGE & COMPREHENSIVE MANAGEMENT
A. Overview:
The TEL.mobi Group VSMP Administration Console (“T-OPS”) System is an extremely powerful and sophisticated Management System, access to which is provided to all TEL.mobi Group Contact Persons at Eligible Entities for their VSMPs Management. It is accessible by all VSMPs worldwide, and functions on a 24/7/365 and automated basis.
Through this Management System, VSMPs can view, in real-time, all relevant information relating to their Commission Donations, their VSMPs, Facilities use, and all other aspects and Facilities required for them to carry out their functions as TEL.mobi Group VSMPs.
VSMPs are also able to fully view and review new own VSMP.
It is a self-explanatory and intuitive system, and once an Eligible Entity has been granted Consent to establish a TEL.mobi Group VSMP, they automatically and immediately receive their login credentials for the login to the Agent and VSMP Administration Console, with which they can immediately begin.
The login to the Administration Console is done in a secure manner, including TAN Text verification per session. A description of the top-level Administration Facilities that can be viewed and actioned in and from the Agent Administration Console (T-OPS System) is as follows:
1. Current Commission Donations 2. Previous Commission Donations
Select to View – Select to View –
By Currency Per month, for the preceding six
By Facility months
By VSMP A to Z By Currency
By Country A to Z By Facility
Search by Name By VSMP A to Z By Agent A to Z
By Country A to Z
Search by Name
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3. Current Statistics Global VSMPs that have signed up through my VSMP Select to View by – Select to View – Calls List by Join Date
Texts List by Country
Top-up Transfers List Alphabetically
Currency Conversions List Sector
Top-up Vouchers Search by VSMP Name
By Total or VSMP Global VSMPs signed up through my VSMP that have been Banned
4. Historical Statistics Select to View –
Select to View – List by Join Date
Per month, for the preceding six List by Country
months List Alphabetically
Calls List Sector
Texts List by Agent Name
Top-up Transfers Search by VSMP Name
Currency Conversions
Top-up Vouchers 6. View Agents By Total or VSMP My Agent
5. My VSMPs 7. New Marketing Messages
My Global VSMP View / Copy & Paste the Current Weekly Marketing Message Select to View –
List by Join Date
List by Country 8. Old Marketing Messages
List Alphabetically View all Previous Weekly Marketing List Sector Messages
List by Agent Name By Week
Search by VSMP Name
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9. Order New Top-up Vouchers By Issued / Used Date
Select – Payment Method
Voucher Currency Issue
Number of Vouchers Print Selected Voucher/s
Each Voucher's Value Email Selected Vouchers
Higher Voucher Value Text Selected Vouchers
Payment Method View Selected Vouchers in Large Font 10. Top-up Vouchers in Process
Select to View by – 12. My Details
Voucher Currency My VSMP/Agent Details
Number of Vouchers My Personal Details
Each Voucher's Value Registered Personal Address and
KYC Higher Voucher Value
Payment Method Registered Corporate Address and KYC
11. Top-up Vouchers in Stock 13. Contact Select to View or Action – Send Feedback Voucher Status Send Question In Stock
Request/Motivate Promotion Issued – Used
Appeal Demotion Issued – Unused
Appeal Banning Block Voucher/s
By Currency Report Problems
By Amount By Amount
By Issued / Used Date
Payment Method
Issue
Print Selected Voucher/s
Email Selected Vouchers
Text Selected Vouchers
View Selected Vouchers in Large Font
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B. Snapshot of the VSMP Administration Console (the T-OPS System): Snapshot of the “My VSMPs” Sub-Facility
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FAIR, OPEN AND TRANSPARENT
TEL.MOBI GROUP
VSMP TERMS, TERM AND TERMINATION
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FAIR, OPEN AND TRANSPARENT TEL.MOBI GROUP VSMP TERMS, TERM AND TERMINATION
A. Terms – Establishment and Commission Donations:
1. When a an Eligible Entity person is provided by Webtel.mobi with Consent to Establish a VSMP (which Consent is granted automatically within 24 hours of its initial establishment if the Eligible Entity has not been informed otherwise), this is referred to as “VSMP Establishment”.
2. After Establishment, the Primary responsibility of the Eligible Entity – via its nominated Contact Persons – is to receive and redistribute to existing clients / members / users / other of its Eligible Entity the Weekly Marketing Messages that are sent to it by Webtel.mobi (sent by email and placement in the Eligible Entity’s VSMP Administration Console). These Marketing Messages direct these existing clients / members / users / other of the Eligible Entity to its VSMP, for utilization of the Products, services and Facilities on its VSMP. A subsidiary activity is to notify the VSMP’s Responsible Agent or Webtel.mobi in the event of any suspicious activity/ies on the Eligible Entity’s VSMP by any of its members (transactions – minus Members’ personal data – are able to be seen at all times via the VSMP Administration Console).
3. In return for implementing the activities as specified in point 2 above, the Eligible Entity will receive Commission Donations from Webtel.mobi equivalent to 10% of the Net Revenue from all activities carried out over the Eligible Entity’s own VSMP, and 1% of the Net Revenues from all activities carried out over other VSMPs that have been established over/via the Eligible Entity’s own VSMP.
4. Eligible Entities/their VSMPs agree to observe and be bound by all Terms as described in the Webtel.mobi / TEL.mobi Group Terms of Use, the Terms and Rules as described in the VSMP Handbook, in the Welcome Email sent to all TEL.mobi Group VSMPs and any additional Terms and Conditions as may be provided by Webtel.mobi from time to time.
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B. Term:
Once Established, TEL.mobi Group Independent VSMPs will remain active indefinitely, until the Eligible Entity voluntarily decides to retire its VSMP, or until one of the events as described in Paragraphs C and D of this Section occurs.
C. Termination:
1. Termination of the Established VSMP can be implemented by Webtel.mobi, at its sole election and discretion, at any time, without notice. It is envisaged that this would only occur in the event of a serious contravention of the Terms, and if no other form of remedy could be applied. However, and this notwithstanding, the decision/s on such matters will be applied at Webtel.mobi’s sole election and discretion.
2. In the event of Termination, all Stored Credit due to an Eligible Entity will be remitted to the Registered Bank Account of Contact Person 1 of the Eligible Entity. This includes the Eligible Entity’s own Stored Credit in his/her TEL.mobi Account, as well as any Commission Donations in Contact Person 1 and 2’s Accounts and/or any Commission Donations outstanding or en- route to Contact Person 1’s Account. The only exception to this is if the VSMP’s Account has been handed over to the GBA for investigation, in which case, the GBA will be the decision- making authority on the return or retention of any outstanding Stored Credit.
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D. Voluntary Retirement of a VSMP:
1. If an Eligible Entity wishes to voluntarily retire a VSMP and not continue with another VSMP, the same process as described in Paragraph C above will be implemented, with the natural difference that the potential consideration for freezing of the Accounts and/or handover to the GBA do not apply.
2. If an Eligible Entity wishes to voluntarily retire a VSMP in order to rather continue its activities with a different VSMP, and in the event that this has been agreed with Webtel.mobi’s consent (for which very clear and understandable motivations need to be provided), then all Members, Accounts, Contact Persons and other aspects will be transferred across to and replicated in the new VSMP when the old one is retired.
E. Other:
1. The strategy and view of the current Management and Owners of the TEL.mobi Group is that once Established, and unless an event as described in Paragraph C of this Section occurs, TEL.mobi Group VSMPs will remain active and live indefinitely, until the Eligible Entity that has established the VSMP voluntarily decides to retire it.
2. The only exceptions to this will be:
In the event of a material Change of Ownership of Webtel.mobi (i.e. when ownership of 25.1% or more of the shares of Webtel.mobi (Holdings) Limited change ownership).
In the event of a Trade Sale of Webtel.mobi (Holdings) Limited to new owners.
3. In the event of either of these two scenarios, the current Management and Owners of Webtel.mobi will recommend to the New Owners that the VSMPs and the VSMP program and structure remains unaltered.
4. However, in the event of such an event occurring, it will be at the sole discretion of the New Owners as to whether to retain or alter the existing VSMPs and/or the existing VSMP program and structure as it is.
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ADDITIONAL
HELPFUL INFORMATION
FOR
ELIGIBLE ENTITIES
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ADDITIONAL HELPFUL INFORMATION FOR ELIGIBLE ENTITIES
Additional useful information on the TEL.mobi Product Suite and Facilities, on the TEL.mobi Group and on Webtel.mobi can be found on the Static Information Pages on all TEL.mobi Group Sites. These are the Static Links running from left to right across the top and bottom of the Sites.
This information can be useful to Eligible Entities from an interest perspective, as well as from the perspective of identifying how to utilize the Products, Services and Facilities to their and/or their Members’ benefit.
This includes information that can be found on the following Static Pages:
About The About section contains a brief summarized overview of Webtel.mobi, TEL.mobi Group and its Primary Services, method of Service Operation and Global Coverage.
Rates The Rates section illustrates the competitive advantage that the TEL.mobi Group’s Product Suite has over other entities in terms of its ultra low costs for its high service levels.
Terms of Use The Terms of Use sections describe all the terms for usage of the TEL.mobi Services.
Testimonials The Testimonials section contains a video Testimonial from the Global Information and Communications Technologies (“ICT”) Practice of Frost & Sullivan on the worldwide due diligence which it conducted on Webtel.mobi, a Regulatory Declaration on Webtel.mobi and its VSMPs by the Global ICT Practice of Frost & Sullivan, and a letter confirming the Multinational due diligence done on Webtel.mobi by seven firms of attorneys.
Security The Security section describes the multilayered security systems and processes in the Webtel.mobi and TEL.mobi Group systems and processes, for protection of Members, protection of the Webtel.mobi and TEL.mobi Group systems, and the built-in Anti-Money Laundering processes.
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TEL.mobi Group The TEL.mobi Group section describes the composition and activities of the TEL.mobi Group.
Management The Management section contains the abbreviated biographies of Webtel.mobi’s / the TEL.mobi Group’s Management Team and Strategic Advisers.
Media The Media section contains a selection of the International Media Events staged and sponsored – and the international Media Coverage of – Webtel.mobi, including details of the multiple Marketing World Records, which it set, and holds.
Videos The Videos section contains a short Corporate Video on Webtel.mobi, a TV Documentary on one of Webtel.mobi’s Global Media Events (The Webtel.mobi Intercontinental Challenge) and a selection of Community Created videos on Webtel.mobi.
Coming Soon The Coming Soon section contains details of TEL.mobi Group Services and Facilities that are being introduced into the TEL.mobi Product Suite in the near future.
Global Social Responsibility The Global Social Responsibility section contains details of the Webtel.mobi and TEL.mobi Group Corporate Philosophy / Group Philosophy and Corporate Culture / Group Culture.
Other than the information at these Static Information Pages, there is, on every Facilities Page (the Pages running from top to bottom on the left hand side of all sites), an “Info and How to Use” button on the top right of the page.
These “Info and How to Use” Pages provide detailed information as to how every separate Facility functions and works. Additionally, on some of the “Info and How it Works” Pages, additional useful information and/or Document Downloads can be found.
Moreover, if Eligible Entities would like to find out more in respect of the Independent Agent Opportunity, this can be accessed by reviewing or downloading the “Independent Agents Handbook”, which is available on the “Apply to be an Agent (IA)” Facility on TEL.mobi Group Sites.
Finally, for specific information on the ICLM Service, the ICLM Handbook can also be reviewed or downloaded from either the “Apply for an Affiliate (VSMP)” or the “Apply to be an Agent (IA)” Facilities on all TEL.mobi Group sites. 383
THE TEL.MOBI GROUP
VSMP ASSOCIATION –
TO ASSIST AND SUPPORT TEL.MOBI GROUP VSMPs
AND
ELIGIBLE ENTITIES
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THE TEL.MOBI GROUP VSMP ASSOCIATION – TO ASSIST AND SUPPORT TEL.MOBI GROUP VSMPs AND ELIGIBLE ENTITIES
Webtel.mobi will be forming the “TEL.mobi Group VSMP Association”. This will be an Association to which all TEL.mobi Group VSMPs will belong. Membership of this organization will be mandatory for all VSMPs (Note: Mandatory for VSMPs - not for Eligible Entities).
When this Association is formed, VSMPs will be automatically enrolled as Members of the Association.
There will be no fees payable to be a Member of the Association, and no mandatory duties or requirements for Members of the Association.
The purposes of the Association will be to:
1. Provide updates and information of relevance and assistance to VSMPs.
2. Provide news of VSMP activities / successes / innovations.
3. Create of forum where VSMPs can contact and/or interact with one another.
4. Coordinate voluntary-attendance meetings and/or voluntary-attendance symposiums for VSMPs’ Responsible Persons / Contact Persons in/at various locations and times.
5. Advise VSMPs of bonus and/or incentive structures that will be established, as well as the winners thereof in various categories and locations.
6. Provide a central location for help / assistance / advice sources for VSMPs in respect of TEL.mobi Group-related matters.
VSMPs will be directly advised of the establishment and login details of the VSMP Association and its website as and when it is established.
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APPLICATION TO ESTABLISH
A TEL.MOBI GROUP VSMP
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APPLICATION TO ESTABLISH A TEL.MOBI GROUP VSMP
This document has been drawn up to assist all persons at Eligible Entities who wish to Establish a VSMP.
The objective of this document is to describe all aspects of the TEL.mobi Group’ Products, Services and Facilities, and all aspects of the TEL.mobi Group’s VSMP Program clearly. This is to inform persons at Eligible Entities, and is to assist, on an ongoing basis, Contact Persons at Eligible Entities that have Established VSMPs (because it can always be referred back to by Eligible Entities’ Contact Persons).
The TEL.mobi VSMP Program is one of the most popular and fastest-growing Programs internationally. This is because it:
5. Does not require any cost or investment to Establish a VSMP.
6. Generates substantial additional revenues (via Commission Donations) for Eligible Entities at zero cost to them.
7. Enables Eligible Entities to significantly broaden their existing Product / Services offering, and/or to cut their own costs within their own business activities.
8. Provides the Eligible Entities’ existing clients / members / users with a set of high-quality Products, Services and Facilities that substantially reduces their costs for equivalent services elsewhere.
The TEL.mobi Group’s VSMP Program has previously been called the world’s largest high-revenue multi-product Franchise Group – that gives all of the Franchises and Franchise equipment, stock and administration & management tools to the Franchisees for free.
This is not, however, how Webtel.mobi – the Driver of the TEL.mobi Group – sees it. We see it merely as an example of how all persons and entities within the TEL.mobi Group – being the Driving Company Webtel.mobi, the Independent Agents and the Eligible Entities that receive VSMPs – work together to pool their resources as a Team, in order to bring the highest-quality service to TEL.mobi Group Members at the lowest possible cost. In other words, a real example of what responsible and ethical business can produce.
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The TEL.mobi Group has structured its VSMP Program to be as inclusive and helpful as possible. There are no costs, equipment or other arduous requirements for Eligible Entities to establish and start utilizing their VSMPs.
Other than this, a comprehensive range of easy-to-use online tools and resources are provided to and for Eligible Entities’ Contact Persons at no cost, specifically to make all the processes, administration, management and monitoring of their VSMPs intuitive and easy.
Furthermore, there is no pressure on VSMPs to achieve any minimums or maximums of anything. The Program is structured so as to cater for all Eligible Entities – whether they wish to promote and drive it robustly or in a more relaxed manner, at their own choice.
Having read this VSMP Handbook, all that you need to do now to become part of one of the fastest- growing and most inclusive Programs in the world, and provide and additional broad range of high- quality and revenue-generating Products, Services and facilities to your existing clients / members / users / other is just go to the “Apply to for an Affiliate (VSMP)” facility on your TEL.mobi Account, and click the Green Button.
The Management Team of the TEL.mobi Group thanks you for your interest in Establishing a TEL.mobi Group VSMP, and we look forward to welcoming your Eligible Entity’s VSMP as part of the TEL.mobi group whenever it suits you to do so.
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SECTION 10
APPENDIXES
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APPENDIX 1:
TEL.MOBI GROUP
TERMINOLOGY,
ACRONYMS AND
ABBREVIATIONS
390
APPENDIX 1 TEL.MOBI GROUP TERMINOLOGY, ACRONYMS AND ABBREVIATIONS
To assist Eligible Entities’ personnel in the understanding of acronyms and abbreviations for TEL.mobi Group Products, Services and Facilities as described in this document and used in general, the following list of commonly-used TEL.mobi Group acronyms and abbreviations – as well as a description of what they describe or relate to – is shown in this section. Many of these acronyms and abbreviations have not been used within this document in order to make the document as clear as possible for new readers.
These acronyms and abbreviations are, however, widely-used by existing TEL.mobi Group Independent Agents and other TEL.mobi Group personnel. It is not necessary to memorize these acronyms and abbreviations, because Eligible Entity personnel may choose to use them or not according to their own preferences.
This Document can also be used as an ongoing aid, for Eligible Entities’ personnel to continuously refer back to if they need to identify any particular TEL.mobi Group acronyms and/or abbreviations:
A. Services Acronyms and Abbreviations:
These include Terminology, Acronyms and Abbreviation for Proprietary Webtel.mobi / TEL.mobi Group Products / Services / Organizations, as well as Terminology, Acronyms and Abbreviations for Non-Proprietary Webtel.mobi / TEL.mobi Group Products / Services / Organizations.
1. Administration Console The Administration Console (“T-OPS” System) is the proprietary Webtel.mobi / TEL.mobi Group Management and Administration Console that enables full monitoring, oversight, management of all accounts, processes, Members, Independent Agents and VSMPs over the entire Webtel.mobi / TEL.mobi Group system. There are three partitions to the Administration / T-OPS System, being (A) Independent Agents Administration Console – with limited capacity in terms of Member Data and other Private Data, but Full capacity for non-Private Transactions / Processes review. (B) VSMP Administration Console – with limited capacity in terms of Member Data and other Private Data, but Full capacity for non-Private Transactions / Processes review (C) Strategic Administration Console – for use by Webtel.mobi Senior personnel, which has full capacity for review of every single aspects / transaction / activity / Members / Independent Agents / VSMPs / etc.
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2. Agent VSMP An Agent VSMP is a VSMP that has been established by and for the use of a TEL.mobi Group Active Independent Agent. Its purpose is for the Active Independent Agent to send to Prospective Independent Agents and to Eligible Entities, for them to sign up as either Active Independent Agents or for VSMPs directly through it. This will result in the automatic assignment of the Independent Agents who sign up through it to the Agent Stream of the Active Independent Agent whose Agents VSMP it is. It will also result in the automatic assignment of the VSMPs that sign up through to the Active Independent Agent whose Agents VSMP it is.
3. Agent-Established VSMP An Agent-Established VSMP is a Global VSMP that has been established by a TEL.mobi Group Independent Agent.
4. CD = Commission Donations Commission Donations are percentages of the Net Revenues from VSMPs’ TEL.mobi Group Facilities and Services usage that are donated to Independent Agents by the TEL.mobi Group. Every TEL.mobi Group Independent Agent receives Commission Donations from every VSMP that he/she has been responsible for establishing. Senior Tier TEL.mobi Group Independent Agents also receive a percentage of the Net Revenues from VSMPs that their Intermediate Tier and Entry Tier Agents in their Agent Stream have established.
5. Currency Wallets The Currency Wallets are the facility that enables TEL.mobi Group Members to hold their Stored Credit in the currency / currencies of their choice, and to enable favorable currency conversions for their Stored Credit.
6. Desktop Site The Desktop site is the Desktop version of the Webtel.mobi / TEL.mobi Group suite of Products and Services, which enables full use of the Products and Services from PCs / Laptops / Tablets / other non-Mobile-Phone PEDs, on all mainstream Desktop Browsers. It is also the version that contains expanded details of the Company and Services in the Static Pages running from left to right across the top and bottom of the Site’s Pages.
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7. EE = Eligible Entities An Eligible Entity is an entity in which a single nodal point or person/s is/are able to communicate with multiple other members / clients / personal / students / other from that entity. Examples of Eligible Entities are companies, organizations, charities, schools, membership organizations, small businesses, hotel groups, shopping centers, websites – virtually any organization that has members / users / clients / personnel staff / pupils / students / customers / etc. There is no upper or lower requirement for number for TEL.mobi Group VSMPs. Currently, the largest Eligible Entity with a VSMP has over 200 Million members, and the smallest Eligible Entity with a VSMP has ten members.
8. Establishing Agent An Establishing Agent is the specific TEL.mobi Independent Agent who is recorded as having been responsible for the establishment of a Specific Global VSMP.
9. Existing Active Independent Agent An Existing Active Independent Agent is a person who has received Consent from the TEL.mobi Group to act as an Independent Agent, and who has commenced these activities, and has mastered the requirements for this position.
10. GBA = Guernsey Border Agency The Guernsey Border Authority – specifically the Financial Investigations Unit of the Guernsey Border Agency, http://www.guernseyfiu.gov.gg/ – is the Law Enforcement entity to which Webtel.mobi / the TEL.mobi Group will refer all suspicious Members / activities that potentially constitute attempts at illegal activities.
11. Global VSMP A Global VSMP is a Globally Valid Virtual Specialized Mobile Provider (VSMP) of the TEL.mobi Group, which has been established by and/or for a specific Eligible Entity.
12. IA = Independent Agent An Independent Agent (“IA”) is a an Independent Person who has consent from theTEL.mobi Group to present the VSMP opportunity to Eligible Entities, in return for a Commission Donation to the IA from the TEL.mobi Group for successful VSMP appointments.
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13. IA Stream = Independent Agent Stream An IA Stream is a Grouping of Tier 1, Tier 2 and Tier 3 Independent Agents that work together in a Hierarchical Structure, headed up by a Tier 1 Independent Agent.
14. IA Sub-Stream = Independent Agent Sub-Stream An Agent Sub-Stream is the part of an Agent Stream that is managed and administered by the Tier 2 Agents in the Agent Stream. That is, the management and administration of Tier 3 Agents by Tier 2 Agents.
15. IA Tiers = Independent Agent Tiers An IA Tier is a position in the Hierarchical Structure in which IAs who present the VSMP Opportunity to Eligible Entities function. There are three Tiers of IAs in the TEL.mobi Structure. They are Tier 1, Tier 2 and Tier 3.
16. ICLM = Intra-Closed-Loop Members ICLM stands for “Intra-Closed-Loop Members”, and refers to any Transaction and/or interaction between TEL.mobi Group Members within the TEL.mobi Group’s “Members Only” and “Closed Loop” System.
17. ICLM Transaction An ICLM Transaction is a transaction through which a TEL.mobi Group Member sends a percentage of his/her Stored Credit to another TEL.mobi Group Member/s, over the TEL.mobi Group Platform, using a Mobile Operator Stored Credit Swap (MOSCS) mechanism.
18. Intermediate Tier Agent An Intermediate Tier Agent (which can be a Tier 1/2 Agent or a Tier 2/3 Agent) is an Independent Agent who has been Promoted, and has selected to remain in-between Tiers for a six-month period.
19. Mobile Site The Mobile Site is the Mobile Phone version of the Webtel.mobi / TEL.mobi Group suite of Product and Services, which enables full use of the Products and Services prom all Smart Phone Operating Systems and all pre-Smart Phones (Basic Mobile Phones and Feature Phones) on all Mainstream Mobile Browsers. This version is specifically tailored for Mobile Phone reduced-size faces, and does not have the expanded details of the Company and Services in Static Pages. It has the Desktop Site’s url on its pages to enable Members to navigate to the Desktop Version on and from their Mobile Phones to access the expanded details of the Company and Services. 394
20. MOSCS = Mobile Operator Stored Credit Swap An MOSCS is an instantaneous swap or Stored Credit between one TEL.mobi Group Member and another TEL.mobi Group Member. In an MOSCS, the “Sending Member’s” Stored Credit total on his/her TEL.mobi Group online Prepaid Telephone Account is debited, and the same amount – less the Transaction Fee – is instantly credited to the Stored Credit total of the “Receiving Member’s” TEL.mobi Group online Prepaid Telephony Account. The MOSCS is the mechanism through which TEL.mobi Group Members are able to implement “Top-Up Transfers” and ICLM Transactions”.
21. New Active Independent Agent A New Active Independent Agent is a person who has just received or recently received Consent from the TEL.mobi Group to act as an Independent Agent, and who has yet to commence or yet to master the requirements for this position.
22. Nominated Agent A Nominated Agent is an Independent Agent in an Agent Stream who has been Nominated by a Senior or Intermediate Tier Agent for Promotion.
23. Nominating Agent A Nominating Agent is a Senior or Intermediate Tier Agent who Nominates an Independent Agent within their Agent Stream for a Promotion.
24. Promoted Agent A Promoted Agent is an Independent Agent in an Agent Stream who has been previously Nominated by a Senior or Intermediate Tier Agent for Promotion, which Promotion has then been approved, accepted and applied.
25. Promoting Agent A Promoting Agent is a Senior or Intermediate Tier Agent who has previously Nominated an Independent Agent within their Agent Stream for a Promotion, which Promotion has then been approved, accepted and applied.
26. Prospective Independent Agent A Prospective Independent Agent is a person who is potentially interested to act as a TEL.mobi Group Independent Agent, but who has not yet completed an Agent Application form to apply for Consent to act as a TEL.mobi Group Independent Agent.
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27. Prospective VSMP A Prospective VSMP is an Eligible Entity that has indicated interest in acquiring a Global VSMP, and is in the process of evaluating the opportunity.
28. Receiving Member A Receiving Member is a TEL.mobi Group Member who receives a Top-Up Transfer, ICLM Transaction or other information, sent by another TEL.mobi Group Member to him/her, over the Webtel.mobi / TEL.mobi Group Platform.
29. Responsible Agent A Responsible Agent is the specific TEL.mobi Independent Agent who is recorded as being responsible for a Specific Global VSMP.
30. Sending Member A Sending Member is a TEL.mobi Group Member who sends a Top-Up Transfer, ICLM Transaction or other information to another TEL.mobi Group Member over the Webtel.mobi / TEL.mobi Group Platform.
31. SMP = Specialized Mobile Provider A Specialized Mobile Provider is a Telephony Provider that applies a “best of both” methodology – incorporating a hybrid of classic Telephony Structures and Services with 21st Century online technologies to provide Telephony Services that are easy to access, low in cost and reliable. A Specialized Mobile Provider is NOT a VoIP Service. It is a classic Telephony Service that is only Internet-Initiated, but thereafter executed via the Global Telephony Infrastructure. WM is a Specialized Mobile Provider.
32. T1 = Tier 1 Independent Agent The Senior IA Tier
33. T2 = Tier 2 Independent Agent The Intermediate IA Tier
34. T3 = Tier 3 Independent Agent The Entry IA Tier
396
35. TEL.mobi Group The TEL.mobi Group is the amalgamation of WM, all of the Independent Agents that have Consent to source VSMPs for WM, the Eligible Entities that have been allowed to acquire VSMPs and their VSMPs, and all of the Members who utilize the Facilities within the TEL.mobi Group Product Suite. This structure has been successfully and harmoniously functioning worldwide since 2009.
36. TEL.mobi Product Suite The TEL.mobi Product Suite is the combination of all of the TEL.mobi Group’s Primary Services, Secondary Services, Administrative Services, and Support Services, and all of the Facilities within these services.
37. TGVA = TEL.mobi Group Global VSMP Association The TEL.mobi Group Global VSMP Association (TGVA) is an Association that is being formed by the TEL.mobi Group. Its purpose is to promote closer communication and interaction between TEL.mobi Group Global VSMPs worldwide, and between TEL.mobi Group Global VSMPs and the TEL.mobi Group. It will also structure periodic international meetings and conventions for TEL.mobi Group Global VSMP Contact Persons, as well as a merit-based system for acknowledgement of outstanding achievements by TEL.mobi Group Global VSMPs. All Eligible Entities that are given Consent to establish TEL.mobi Group VSMPs will be required to become members of the TGVA when it is formed.
38. TIAA = TEL.mobi Group Independent Agents Association The TEL.mobi Group Independent Agents Association (TIAA) is an Association that is being formed by the TEL.mobi Group. Its purpose is to promote closer communication and interaction between TEL.mobi Group Independent Agents worldwide, and between TEL.mobi Group Independent Agents and the TEL.mobi Group. It will also structure periodic international meetings and conventions for TEL.mobi Group Independent Agents, as well as a merit-based system for acknowledgement of outstanding achievements by TEL.mobi Group Independent Agents and/or Agent Streams. All TEL.mobi Group Independent Agents will be required to become Members of the TIAA when it is formed.
39. TMG = TEL.mobi Group The TEL.mobi Group is the collective grouping comprising Webtel.mobi (“Webtel.mobi (Holdings) Limited” – which is the creator, owner and driver of the Platform and Services), the Independent Agents, Eligible Entities and their VSMPs, and all the Members who utilize the Platform and the Services within this “Closed-Loop” “Members-Only” community.
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40. Top-Up Transfer A Top-Up Transfer is a transaction through which a TEL.mobi Group Member Tops Up the Stored Credit in another TEL.mobi Group Member/s Prepaid Telephony Account/s by means of a Mobile Operator Stored Credit Swap (MOSCS) mechanism.
41. Top-Up Voucher A TEL.mobi Group Top-Up Vouchers is an Electronic Voucher that contains a digitally-recorded specific amount of Stored Credit in a specific currency, which can be acquired by TEL.mobi Group Members from TEL.mobi Group Independent Agents and/or VSMPs, and loaded onto their TEL.mobi Group Prepaid Telephony Accounts.
42. Unassigned VSMP An Unassigned VSMP is a Global VSMP that has joined the TEL.mobi Group through an Eligible Entity’s Contact Persons directly establishing their Eligible Entity’s own VSMP without the assistance of an Independent Agent, and which falls directly under the Management of the TEL.mobi Group’s own Management, and not the Management of an Agent Stream.
43. VSMP = Virtual Specialized Mobile Provider A Virtual Specialized Mobile Provider (VSMP) is a virtual version of WM, which VSMP is provided to an Eligible Entity by WM at no cost. This is a similar process to that which sees Mobile Network Operators (MNOs) provide virtual versions of their services to Mobile Virtual network Operators (MVNOs). A VSMP comes into existence when an Eligible Entity is awarded its own Virtual Version of the TEL.mobi Group’s System and Product.
44. WM = Webtel.mobi / Webtel.mobi (Holdings) Limited Webtel.mobi is a Company registered in and operating from Guernsey. It is a Global Telephony Services Provider, which has been providing Mobile Calling, Mobile Texting and Landline Calling services – as well as the secondary Services related to its telephony Services – worldwide since 2009. It is formally classified as an Internet Telephony Service Provider (ITSP). WM is a blue-chip company that has relationships with some of the world’s most reputable online security and other services. It has also previously had its company, structure and services thoroughly due diligenced by seven firms of attorneys and the Global ICT Practice of Frost & Sullivan in order to ensure that its Services and Facilities are as robust and fit-for- purpose as possible, to ensure that services to its Members are reliable and safe.
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B. Facilities Acronyms and Abbreviations:
These include Acronyms and Abbreviation for Proprietary Webtel.mobi / TEL.mobi Group Products only. These are specialized terms that are only used in internal specialized correspondence and communication by specialized personnel in Webtel.mobi. Independent Agents are welcome to utilize these acronyms and abbreviations if they wish to, but it is not necessary for them to do so.
This list excludes the Acronyms and Abbreviations for the Proprietary Webtel.mobi / TEL.mobi Group Facilities within the “T-OPS” Administration Console.
1. Active Facilities = Facilities which enable the Services to be Accessed/Provided
T=MC2 TEL.mobi Operating System
TAB TEL.mobi Account Blocking Facility
TCC TEL.mobi Currency Conversion Facility
TCL TEL.mobi Calling Facility
T-ICLM TEL.mobi ICLM Facility
TITAN TEL.mobi ITAN Facility and System
T-OPS TEL.mobi Administration Console System
TPG TEL.mobi Payment Gateway Facility
TRT TEL.mobi Refund Transfer Facility
TTT TEL.mobi Top-Up Transfer Facility 399
TUV TEL.mobi Top-up Voucher Facility
TXT TEL.mobi Texting Facility
2. Administrative Facilities = Facilities that enable Account/Services Administration
TAAL TEL.mobi Independent Agent Administration Console Login Facility
TAAP TEL.mobi Independent Agent Application Facility
TACC TEL.mobi Add a Call/Text Contact Facility
TAMN TEL.mobi Add a Number to My Numbers Facility
TARC TEL.mobi Add a Regular Top-Up Transfer/ICLM Contact Facility
TATC TEL.mobi Add a Top-Up Transfer/ICLM Contact Facility
TCCR TEL.mobi Currency Conversion Rates Calculator Facility
TCKY TEL.mobi Change Top-Up Voucher Key Facility
TCLC TEL.mobi Call/Text Contacts Facility
TCNV TEL.mobi Currency Conversion Calculator Facility
TCPW TEL.mobi Change Primary Wallet Facility 400
TCTE TEL.mobi Confirm Top-Up Transfer/ICLM By Email Facility
TCTR TEL.mobi Call/Text Rates Calculator Facility
TCTT TEL.mobi Confirm Top-Up Transfer/ICLM By Text Facility
TCUR TEL.mobi Currency Wallet Facility
TCVR TEL.mobi Check Top-Up Voucher Validity Facility
TDCH TEL.mobi Detailed Call History Facility
TDFH TEL.mobi Detailed Currency Conversion History Facility
TDIH TEL.mobi Detailed Incoming Top-Up Transfer/ICLM History Facility
TDLH TEL.mobi Detailed Credit Load History Facility
TDOH TEL.mobi Detailed Refund Transfer History Facility
TDTH TEL.mobi Detailed Text History Facility
TDVH TEL.mobi Detailed Top-Up Voucher Load History Facility
TEIN TEL.mobi Email ITAN Number Facility
THIS TEL.mobi History Facility 401
TKYC TEL.mobi Know Your Client Facility
TMDT TEL.mobi My Details Facility
TNUM TEL.mobi My Numbers Facility
TPCW TEL.mobi Change Primary Wallet Facility
TRCU TEL.mobi Remove Currency Wallet Facility
TRFH TEL.mobi Detailed Outgoing Top-Up Transfer/ICLM History Facility
TRTN TEL.mobi Request TAN Text Facility
TTIN TEL.mobi Text ITAN Number Facility
TTIR TEL.mobi Top-Up Transfer/ICLM Rates Enquiry Facility
TTTC TEL.mobi Top-Up Contacts Facility
TUBA TEL.mobi Unblock Account Facility
TVAL TEL.mobi VSMP Administration Console Login Facility
TVAP TEL.mobi VSMP Application Facility
TVNM TEL.mobi Verify Mobile Number Facility 402
3. Impending Active Facilities = Active Facilities to be available in the future
TBF Tel.mobi Global Business Pages Facility
TGF Tel.mobi Global Emergency Alert Facility
TLF TEL.mobi Loyalty Card Facility
TMF TEL.mobi Global Marketplace Facility
TPF TEL.mobi Targeted PPC Marketing Facility
T-SCRM TEL.mobi SCRM System and Facility
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APPENDIX 2:
COPIES OF REQUIRED
KYC CERTIFICATION DOCUMENTS
404
APPENDIX 2 COPIES OF REQUIRED KYC CERTIFICATION DOCUMENTS
TEL.mobi Group Members who wish to –
1. Carry out a Refund Transfer, or
2. Act as an Independent Agent, or
3. Apply for an ICLM Redemption, or
4. Carry out an SCRM Transaction, or
5. Access the VSMP Administration Console as a Contact Person 1 or Contact Person 2, or
6. Load their Accounts using a Credit Card or Debit Card for more than Euro 51 (or equivalent in another currency), or
– need to have uploaded their *Know Your Client” (“KYC”) Documentation to do so.
KYC Documentation can be uploaded from the “Upload KYC” Facility or “My Details” Facility on any TEL.mobi Group Site.
The KYC Documentation must be Confirmed and Certified by a Notary or Attorney, which Certifying Notary or Attorney must also attach a KYC Certification Document to the Certified KYC Documents.
The relevant KYC Certification Documents are available on the “Info and How to Use” Page on the “Upload KYC” Facility on all TEL.mobi Group Sites. A copy of the relevant KYC Certification Documents is also attached on the following pages, for the three different possible categories of KYC Documents, they being:
1. Personal KYC – For TEL.mobi Group Members whose accounts are held in their personal capacity.
2. Substitute KYC – For TEL.mobi Group Members whose accounts are held in their personal capacity, who do not have formal Photographic Identification and/or Utility Bills
3. Corporate KYC – For TEL.mobi Group Members whose accounts are held as Corporate Accounts.
405
PERSONAL KYC CONFIRMATION DOCUMENT
This document is provided by the company Webtel.mobi (Holdings) Limited (https://www.webtel.mobi/pc) for the express purpose of enabling Members who wish to utilize the services of the TEL.mobi Group, and who are providing their formal Photo Identification Documents and formal Utility Bills to obtain Confirmation and Certification of the validity of these KYC Documents in an acceptable format. For the purposes of this document, this person is referred to as the “Applicant”.
This form must be completed by a Registered Notary or a Registered Attorney (an “Attorney” being a Lawyer, Solicitor. Barrister or equivalent Professional who has a license to Practice Law or provide Legal Services to the public, and who is a current Member of his/her local, regional or national Bar Association or equivalent). For the purposes of this document, the Registered Notary or Attorney completing and certifying this Document is referred to as the “Certifying Notary or Attorney”.
The Certifying Notary or Attorney must complete the attached document for the Applicant while the Applicant is in his/her presence.
Other than completion and certification of this document, the Certifying Notary or Attorney will be required to – after the Applicant has uploaded this Completed and Certified Document to the relevant TEL.mobi Group website – receive an email with a link in it, which link, when clicked on, will open a copy of this Certified Document online. This is to ensure that the Certifying Notary or Attorney can review the Completed and Certified Document that was uploaded, to confirm that:
1. It is indeed the Completed and Certified Document that was completed and certified by the Certifying Notary or Attorney, with all details and documents contained within it being unaltered from the version that the Certifying Notary or Attorney completed and certified.
2. That the Names and Details of the Certifying Notary or Attorney are correct, and unaltered from the version that the Certifying Notary or Attorney completed and certified.
For this purpose, part of this service provision to the Applicant includes the Certifying Notary or Attorney inserting a direct email address in the field below. It is to this email that the KYC confirmation email as described above will be sent. In the event of non-confirmation, the telephone number of the Certifying Notary or Attorney as provided in the document will be called to enquire as to the reason for non-confirmation:
Insert Email Address for receipt of Confirmation Email:
406
PERSONAL KYC CONFIRMATION DOCUMENT
Attach Photo Here
A Passport-size Photo, taken from the front, in This Document must be completed in Black After attaching the Photo, Color, without any object on the face/head, is Ink. Writing must be in Capital / Upper-Case Color-Photocopy or Color- to be attached. Then Color-Photocopy or Letters, whether in handwriting or typed. Full Scan this document, and Color-Scan the Document, and complete the Details and Contact Details of the Certifying then complete the Photocopied / Scanned Photocopied / Scanned version that contains Person must be inserted. Version of this Document, so the Embedded Photograph. that the Photo is Embedded into the Document To whom it may concern Webtel.mobi (Holdings) Limited Date:
I Day I Month I Year I
Part 1: Details of person conducting the Verification and Certification:
I,
(Title and First Name / Given Name)
(Surname / Family Name)
In my Capacity as,
(Insert your Professional capacity or either Attorney, Notary or Commissioner of Oaths)
Of / at the following Practice / Chambers / Firm / Office / Organization,
(Insert the Formal name of your Practice / Chambers / Firm / Office / Organization)
At the following address,
(Insert the Physical Address: Office and Street Name & number, City/Town, Province/State, Postal Code/Zip Code, Country)
407
Hereby Confirm, Verify and Certify that:
Part 2: Details of person whose details are being Verified and Certified:
1. The person personally appearing before me is the person whose photograph appears on the preceding page, and the photograph is a true likeness of the person appearing before me.
2. The person personally appearing before me has stated under oath to me that his/her names are as follow:
First Name/s:
Surname/s:
3. The person personally appearing before me has stated under oath to me that his/her residential address is as follows:
Physical Address:
(Apartment/Flat/House Name & Number, Street Name & number, City/Town, Province/State, Postal Code/Zip Code, Country)
4. The person personally appearing before me has stated under oath to me that these personal details are true and correct:
Date and Place of Birth:
(Insert the Date in the format Month / Day / Year. Insert the Place of Birth as City/Town/Village and Country) Citizenship / Nationality:
(Insert the Current Primary Citizenship / Nationality first. If Dual or Multiple Citizenship, insert all others as well)
Gender (tick applicable box):
Male
Female 408
Part 3: Documents Provided for Confirmation and Certification:
1. The Applicant has provided to me:
a. His/her valid Photographic Identification Document (only a Passport, a Government Issued Identification Document/Card with Photo or a Government Issued Drivers License with Photo are acceptable).
b. An original Utility Bill under three months old, addressed to the Applicant at the same address that appears in the Photographic Identification Document (only Electricity Bills, Gas Bills, Water Bills, Rates & Taxes Bill, Personal Tax Documents, Bank Statements or Landline telephone Bills are acceptable).
c. I have had Color Photocopies or Scans of the Photo Identification Document and Utility Bill made in my office, and have attached my own signature and applied my own stamp to these Copies of these original documents to Certify them as true copies of the originals, and these Certified Copies are attached to this document overleaf.
2. The person personally appearing has logged into his/her TEL.mobi Account in front of me, and has shown me his/her TEL.mobi Group ITAN Number, which is as follows:
ITAN Number:
W M
Part 4: Confirmation and Certification:
I confirm that the person whose photo, personal details and certified copies of Photographic Identification and Utility Bill under three months old has stated and confirmed under oath that the documents that he/she has provided, and the details as recorded in this document, are true and correct.
Thus signed on this ______day of ______(month) of 20______(year)
CERTIFYING NOTARY OR ATTORNEY APPLICANT
Signature ______Signature ______
Formal Title ______
First Name ______First Name ______
Surname ______Surname ______
Direct Contact Telephone Number; Registered Mobile Number on the TEL.mobi Account: (International Format – Country Code, Area Code, Number) (International Format – Country Code, Area Code, Number)
+ +
409
PERSONAL KYC SUBSTITUTE DOCUMENT
This document is provided by the company Webtel.mobi (Holdings) Limited (https://www.webtel.mobi/pc) for the express purpose of enabling Members who wish to utilize the services of the TEL.mobi Group, but who do not have formal Photo Identification Documents and/or formal Utility Bills to acquire a form of acceptable “Know Your Client” (“KYC”) Documentation. For the purposes of this document, this person is referred to as the “Applicant”.
This form must be completed by a Registered Notary or a Registered Attorney (an “Attorney” being a Lawyer, Solicitor. Barrister or equivalent Professional who has a license to Practice Law or provide Legal Services to the public, and who is a current Member of his/her local, regional or national Bar Association or equivalent). For the purposes of this document, the Registered Notary or Attorney completing and certifying this Document is referred to as the “Certifying Notary or Attorney”.
The Certifying Notary or Attorney must complete the attached document for the Applicant while the Applicant is in his/her presence.
Other than completion and certification of this document, the Certifying Notary or Attorney will be required to – after the Applicant has uploaded this Completed and Certified Document to the relevant TEL.mobi Group website – receive an email with a link in it, which link, when clicked on, will open a copy of this Certified Document online. This is to ensure that the Certifying Notary or Attorney can review the Completed and Certified Document that was uploaded, to confirm that:
1. It is indeed the Completed and Certified Document that was completed and certified by the Certifying Notary or Attorney, with all details contained within it being unaltered from the version that the Certifying Notary or Attorney completed and certified.
2. That the Names and Details of the Certifying Notary or Attorney are correct, and unaltered from the version that the Certifying Notary or Attorney completed and certified.
For this purpose, part of this service provision to the Applicant includes the Certifying Notary or Attorney inserting a direct email address in the field below. It is to this email that the KYC confirmation email as described above will be sent. In the event of non-confirmation, the telephone number of the Certifying Notary or Attorney as provided in the document will be called to enquire as to the reason for non-confirmation:
Insert Email Address for receipt of Confirmation Email:
410
PERSONAL KYC SUBSTITUTE DOCUMENT
Attach Photo Here
This Document must be completed in Black A Passport-size Photo, taken from the front, in After attaching the Photo, Ink. Writing must be in Capital / Upper-Case Color-Photocopy or Color- Color, without any object on the face/head, is Letters, whether in handwriting or typed. Full Scan this document, and to be attached. Then Color-Photocopy or Details and Contact Details of the Certifying then complete the Color-Scan the Document, and complete the Person must be inserted. Fingerprinting must Photocopied / Scanned Photocopied / Scanned version that contains be done in the Certifying Person’s presence. Version of this Document, so the Embedded Photograph. that the Photo is Embedded into the Document To whom it may concern Webtel.mobi (Holdings) Limited Date:
I Day I Month I Year I
Part 1: Details of person conducting the Verification and Certification:
I,
(Title and First Name / Given Name)
(Surname / Family Name)
In my Capacity as,
(Insert your Professional capacity or either Attorney, Notary or Commissioner of Oaths)
Of / at the following Practice / Chambers / Firm / Office / Organization,
(Insert the Formal name of your Practice / Chambers / Firm / Office / Organization)
At the following address,
(Insert the Physical Address: Office and Street Name & number, City/Town, Province/State, Postal Code/Zip Code, Country) 411
Hereby Confirm, Verify and Certify that:
Part 2: Details of person whose details are being Verified and Certified:
1. The person personally appearing before me is the person whose photograph appears on the preceding page, and the photograph is a true likeness of the person appearing before me.
2. The person personally appearing before me has stated under oath to me that his/her names are as follow:
First Name/s:
Surname/s:
3. The person personally appearing before me has stated under oath that his/her residential address is as follows:
Physical Address:
(Apartment/Flat/House Name & Number, Street Name & number, City/Town, Province/State, Postal Code/Zip Code, Country)
4. The person personally appearing before me has stated under oath that these personal details are true and correct:
Date and Place of Birth:
(Insert the Date in the format Month / Day / Year. Insert the Place of Birth as City/Town/Village and Country)
Citizenship / Nationality:
(Insert the Current Primary Citizenship / Nationality first. If Dual or Multiple Citizenship, insert all others as well)
Gender (tick applicable box):
Male
Female
412
5. The person personally appearing has provided his fingerprints herebelow either (tick relevant box):
By me taking his/her fingerprints myself.
By a member of my staff taking his/her fingerprints in my presence with me watching.
By a third party designated by me taking his/her fingerprints in my presence with me watching.
By the Police taking his/her fingerprints, on this document, and confirming this to me in writing.
Fingerprints: Left Forefinger Left Thumb Right Forefinger Right Thumb
(Fingerprints may be taken using an Inkpad. Click here to see the method for taking fingerprints)
6. The person personally appearing has logged into his/her TEL.mobi Account in front of me, and has shown me his/her TEL.mobi Group ITAN Number, which is as follows:
ITAN Number:
W M
Part 3: Confirmation and Certification:
I confirm that the person whose photo, personal details and fingerprints are being certified in this document has stated under oath that these details are true and correct.
Thus signed on this ______day of ______(month) of 20______(year)
CERTIFYING NOTARY OR ATTORNEY APPLICANT
Signature ______Signature ______
Formal Title ______
First Name ______First Name ______
Surname ______Surname ______
Direct Contact Telephone Number; Registered Mobile Number on the TEL.mobi Account: (International Format – Country Code, Area Code, Number) (International Format – Country Code, Area Code, Number)
+ +
413
CORPORATE KYC CONFIRMATION DOCUMENT
This document is provided by the company Webtel.mobi (Holdings) Limited (https://www.webtel.mobi/pc) for the express purpose of enabling Members who wish to utilize the services of the TEL.mobi Group as Corporate or other Entities (i.e. Trusts, Unions, etc), obtain Confirmation and Certification of the validity of these Corporate Documents in an acceptable format. For the purposes of this document, this Entity is referred to as the “Applicant”.
This form must be completed by a Registered Notary or a Registered Attorney (an “Attorney” being a Lawyer, Solicitor. Barrister or equivalent Professional who has a license to Practice Law or provide Legal Services to the public, and who is a current Member of his/her local, regional or national Bar Association or equivalent). For the purposes of this document, the Registered Notary or Attorney completing and certifying this Document is referred to as the “Certifying Notary or Attorney”.
The Certifying Notary or Attorney must complete the attached document for the Applicant while the Applicant’s Representative is in his/her presence.
Other than completion and certification of this document, the Certifying Notary or Attorney will be required to – after the Applicant has uploaded this Completed and Certified Document to the relevant TEL.mobi Group website – receive an email with a link in it, which link, when clicked on, will open a copy of this Certified Document online. This is to ensure that the Certifying Notary or Attorney can review the Completed and Certified Document that was uploaded, to confirm that:
1. It is indeed the Completed and Certified Document that was completed and certified by the Certifying Notary or Attorney, with all details and documents contained within it being unaltered from the version that the Certifying Notary or Attorney completed and certified.
2. That the Names and Details of the Certifying Notary or Attorney are correct, and unaltered from the version that the Certifying Notary or Attorney completed and certified.
For this purpose, part of this service provision to the Applicant includes the Certifying Notary or Attorney inserting a direct email address in the field below. It is to this email that the KYC confirmation email as described above will be sent. In the event of non-confirmation, the telephone number of the Certifying Notary or Attorney as provided in the document will be called to enquire as to the reason for non-confirmation:
Insert Email Address for receipt of Confirmation Email:
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CORPORATE KYC CONFIRMATION DOCUMENT
Attach Photo Here
A Passport-size Photo of the Applicant is This Document must be completed in Black After attaching the Photo, Representative, taken from the front, in Color, Ink. Writing must be in Capital / Upper-Case Color-Photocopy or Color- without any object on the face/head, is to be Scan this document, and Letters, whether in handwriting or typed. Full attached. Then Color-Photocopy or Color-Scan then complete the the Document, and complete the Photocopied Details and Contact Details of the Certifying Photocopied / Scanned Person must be inserted. Version of this Document, so / Scanned version that contains the Embedded that the Photo is Embedded Photograph. into the Document To whom it may concern Webtel.mobi (Holdings) Limited Date:
I Day I Month I Year I
Part 1: Details of person conducting the Verification and Certification:
I,
(Title and First Name / Given Name)
(Surname / Family Name)
In my Capacity as,
(Insert your Professional capacity or either Attorney, Notary or Commissioner of Oaths)
Of / at the following Practice / Chambers / Firm / Office / Organization,
(Insert the Formal name of your Practice / Chambers / Firm / Office / Organization)
At the following address,
(Insert the Physical Address: Office and Street Name & number, City/Town, Province/State, Postal Code/Zip Code, Country)
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Hereby Confirm, Verify and Certify that:
Part 2: Details of the Applicant’s Representative:
1. The person personally appearing before me is the person whose photograph appears on the preceding page, and the photograph is a true likeness of the person personally appearing before me.
2. The person personally appearing before me has shown me proof in his/her valid Photographic Identification Document that his/her names are as follow:
First Name/s:
Surname/s:
3. The person personally appearing before me has shown me proof in his/her valid Photographic Identification Document or in a Utility Bill under three months old with the same address as in the Photographic Identification Document that his/her physical address is as follows:
Physical Address:
(Apartment/Flat/House Name & Number, Street Name & number, City/Town, Province/State, Postal Code/Zip Code, Country)
4. The person personally appearing before me has shown me proof in his/her Photographic Identification Document these personal details are true and correct:
Date and Place of Birth:
(Insert the Date in the format Month / Day / Year. Insert the Place of Birth as City/Town/Village and Country)
Citizenship / Nationality:
(Insert the Current Primary Citizenship / Nationality first. If Dual or Multiple Citizenship, insert all others as well)
Gender (tick applicable box):
Male
Female 416
Part 3: Documents Provided for Confirmation and Certification:
1. The Applicant has provided to me:
a. Letter of Authorization:
A letter of Authorization, signed by the Head of the Entity for which the Applicant is submitting documents for Certification, authorizing the Applicant to do so.
b. In the case of a Company / Corporation:
i. The Original Certificate / Document of Incorporation – with evidence that the Company / Corporation is still Registered with the Registrar / Registry of Companies, and is in good standing.
ii. The Original Memorandum and Articles of Association of the Company / Corporation.
iii. The Original Register of Directors of the Company / Corporation, with Original Personal KYC Documents for at least two of the Directors (or one if there is only one Director).
iv. The Original Shareholders List of the Company / Corporation, with Original Personal or Corporate KYC Documents for all Shareholders holding more than 10% of the shares of the Company / Corporation.
c. In the case of a Trust:
i. The Original Trust Deed – with evidence that the Trust is still Registered and in good standing.
ii. The list of the Trustees of the Trust, with Original Personal KYC Documents for at least two of the Trustees (or one if there is only one Trustee).
iii. The details of the Protector or Settlor of the Trust, with Original Personal KYC Documents for the Protector or the Settlor of the Trust.
iv. The details of the Beneficiaries of the Trust, with Original Personal or Corporate KYC Documents for all Beneficiaries of the Trust.
d. In the case of a Partnership:
i. The Original Partnership Agreement – with evidence that the Partnership is still in force.
ii. The list of the Partners in the Partnership, with Original Personal KYC Documents for at least two of the Partners.
e. In the case of a Union, Charity, NGO or other formal Organization:
i. The Original Founding Document of the Organization, with evidence that the Organization is still registered and in good standing.
ii. The list of the Legally Responsible Persons for the Direction / Management of the Organization, with Original Personal KYC Documents for at least two of these Legally Responsible Persons (or one if there is only one such person).
2. I have had Color Photocopies or Scans of the applicable Documents detailed in the preceding points a to e made in my office, and have attached my own signature and applied my own stamp to these Copies of these original documents to Certify them as true copies of the originals, and these Certified Copies are attached to this document overleaf.
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3. The person personally appearing has logged into his/her TEL.mobi Account in front of me, and has shown me his/her TEL.mobi Group ITAN Number, which is as follows:
ITAN Number:
W M
Part 4: Confirmation and Certification:
I confirm that the Applicant has stated and confirmed under oath that the documents that he/she has provided for Certification, and the details as recorded in this document, are true and correct.
Thus signed on this ______day of ______(month) of 20______(year)
CERTIFYING NOTARY OR ATTORNEY APPLICANT
Signature ______Signature ______
Formal Title ______
First Name ______First Name ______
Surname ______Surname ______
Direct Contact Telephone Number; Registered Mobile Number on the TEL.mobi Account: (International Format – Country Code, Area Code, Number) (International Format – Country Code, Area Code, Number)
+ +
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APPENDIX 3:
COPIES OF
ICLM REDEMPTION DOCUMENTS
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APPENDIX 3 COPIES OF ICLM REDEMPTION DOCUMENTS
VSMPs can provide Discounted Redemptions of ICLM Transactions. This is not a Webtel.mobi and/or TEL.mobi Group Service, but rather an independent activity by VSMPs, as follows:
Discounted Redemptions are where a VSMP allows Members to make an ICLM Transaction to the VSMP’s TEL.mobi Account (or a TEL.mobi Account Nominated by them), and in return provides the Member with money to the value of the ICLM Transaction, at a discount. That is, the VSMP gives the Member less money than the total of Stored Credit transferred – the difference being the VSMP’s mark-up for providing this service.
VSMPs set their own Discounting terms for such Discounted Redemptions, which are either a flat fee or a percentage of the Stored Credit transferred. They also set their own terms for the Currency in which the Member should implement the ICLM Transaction.
Although this is an independent activity that VSMPs elect to do of their own volition because it is a very profitable business model – and simultaneously also a service to the local community – the fact that they are TEL.mobi Group VSMPs brings this activity firmly within the realm of Webtel.mobi’s oversight.
As such – regardless of the fact that VSMPs do this as an independent activity – the Rules regarding ICLM Transaction Discounted Redemptions are as described previously in this Handbook. The required Proforma Documents that need to be used by VSMPs for ICLM Redemptions according to these rules are available on the “Info and How it Works” Pages on the “New Top-Up Transfer / ICLM” and “Regular Top-Up Transfers / ICLMs” Facilities on all TEL.mobi Group Sites.
Copies of these Proforma Documents appear overleaf, as follow:
ICLM Redemption A – For Members with a Photo ID and a Utility Bill
ICLM Redemption B – For Members with a Photo ID and no Utility Bill
ICLM Redemption C – For Members with a TEL.mobi Group Substitute KYC Document
ICLM Redemption D – For Members without KYC Documents
ICLM Photo and Fingerprint Confirmation Document – For Members without KYC Documents
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