Fraud Prevention Policy

This Policy sets out the measures taken by SIA “Orbis Mentor” (Orbis Mentor) to mitigate fraud, identity misuse, payment manipulation, money laundering, terrorist financing, proliferation financing and sanctions-related risks. It applies to Platform visitors and registered Users, Mentors, Mentees, Bookings, Sessions, payments, refunds and Payouts to the extent supported by the Platform.

This Policy supplements, and does not replace, the Terms of Use, Mentor Agreement, Privacy Policy or Cancellation and Refund Policy. Mandatory provisions of applicable law prevail.

Platform means the Orbis Mentor digital service at orbismentor.com. Mentor means an independent provider of mentoring services; Mentee means a User who books a Session; Session means a mentoring appointment booked through the Platform; Payout means the transfer of an amount due to a Mentor subject to applicable adjustments.

AML means anti-money laundering; CTF/CFT means countering the financing of terrorism; CPF means countering proliferation financing. KYC means know your customer; CDD means customer due diligence; EDD means enhanced due diligence; PEP means politically exposed person; UBO means ultimate beneficial owner. These terms describe industry risk controls and payment providers’ regulated procedures: their use does not, by itself, impose the full financial-sector CDD/EDD regime on Orbis Mentor.

Suspicious transaction means a transaction or attempted transaction giving rise to reasonable suspicion of money laundering, terrorist financing or proliferation financing under applicable law. Sanctions means applicable EU, UN and Latvian restrictive measures and other directly applicable restrictions.

Orbis Mentor provides digital infrastructure for discovering Mentors, booking and conducting Sessions and organising payments. Orbis Mentor is not a bank and does not claim to be a licensed payment institution. Under its current contractual model, payments, subscriptions and Mentor Payouts are processed with Stripe, including Stripe Billing and Stripe Connect Express. Orbis Mentor does not store full payment card details.

The legal classification of the payment model depends on the actual flow of funds, contractual arrangements and the degree of control over money. This Policy does not itself establish that any exemption from payment-services licensing applies; the active Stripe configuration and contractual arrangements require separate legal assessment.

Prohibited activity includes impersonation, fraudulent or abusive duplicate accounts, misrepresentation of qualifications or services, stolen or unauthorised payment instruments, fictitious Sessions, manipulated reviews, refund or chargeback abuse, collusion, attempts to obtain payment for services not delivered, unauthorised access and evasion of security controls.

The Platform must not be used to circulate illicit funds or evade sanctions. Moving Platform-originated engagements or payments outside the Platform in breach of the Terms of Use or Mentor Agreement is prohibited.

Users must submit accurate and current information; email verification is required at registration. Before a Mentor profile becomes publicly bookable, Orbis Mentor moderates the application, including relevant experience descriptions, offerings, compliance with Platform rules and necessary professional activity information.

Mentors provide identity, banking and other KYC information directly in the Stripe Connect environment. Stripe performs the checks applicable to it under its own regulatory status and terms. Orbis Mentor generally receives operationally necessary identifiers, verification statuses and transaction data.

Mentee registration does not, by itself, trigger mandatory full financial-sector KYC or EDD. Additional information may be requested when justified by risk, applicable law, a payment provider request or investigation of a specific incident.

Orbis Mentor may review account and Session activity, payment statuses, refunds, chargebacks, technical security logs, indicators of unauthorised access and User complaints. Reviews may be manual or use appropriate technical tools, applying data minimisation.

Risk indicators include discrepancies in identity and payment information, repeated unexplained refunds, fictitious transactions, sudden abnormal activity, linked accounts, unusual Payout requests and sanctions matches. An indicator does not by itself establish wrongdoing.

Orbis Mentor does not represent that it provides continuous financial-sector transaction monitoring where such duties do not apply to its actual regulatory status. Details of protective detection rules may remain confidential to preserve security.

Payments are made using supported payment service providers. The standard Session booking process does not accept anonymous or cash payments. Payouts are governed by the Terms of Use, Mentor Agreement, Stripe requirements and applicable law.

Where a complaint, refund request, chargeback, reasonably suspected fraud, sanctions risk or contractual breach arises, Orbis Mentor may proportionately and temporarily hold a Payout or activity under its control while reviewing the circumstances. Stripe may independently apply restrictions under its own terms.

Final retention of funds requires a clear legal or contractual basis. Orbis Mentor does not claim unlimited powers to freeze or confiscate Users’ money.

Orbis Mentor complies with the Latvian Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing insofar as applicable. If Orbis Mentor is not an obliged entity under Section 3, this does not automatically subject it to the full obliged-entity internal control, CDD/EDD or PEP-screening regime. However, Section 3¹ imposes on other persons a duty to provide Latvia’s Financial Intelligence Unit (Finanšu izlūkošanas dienests, FIU Latvia) with information concerning suspicious transactions and necessary information and documents.

Orbis Mentor observes directly applicable EU and Latvian sanctions, assesses identified sanctions risks and cooperates with Stripe and competent authorities as legally appropriate. Information may be requested, activities declined or suspended, profiles restricted or reports submitted where justified.

Regulation (EU) 2024/1624 (AMLR) has been adopted, but its main provisions apply from 10 July 2027. They are not represented in this Policy as already applicable obligations in October 2026.

Where there are reasonable grounds for suspicion, Orbis Mentor considers available facts, documents material circumstances and provides a report to FIU Latvia where required by Section 3¹ or other applicable law. Relevant information may also be disclosed to payment providers or competent public authorities within legal limits.

Users will not be informed of reports or investigative details where disclosure is prohibited by law or would prejudice an investigation. Data disclosures are limited to the relevant lawful purpose.

Personal data is processed under Regulation (EU) 2016/679 (GDPR), the Latvian Personal Data Processing Law and Orbis Mentor’s Privacy Policy. Depending on the activity, the legal basis may be performance of a contract, legal obligation or legitimate interests in fraud prevention and protection of rights. The legal basis is assessed for each processing purpose.

Data minimisation, role-based access and purpose-specific retention periods apply. A single financial-sector AML-file retention period is not automatically imposed on a business that is not an AML obliged entity. Data-subject rights apply subject to lawful exceptions.

Depending on the risk and contract, Orbis Mentor may request explanations, restrict features, suspend profile publication or Payouts, issue warnings, suspend or close accounts, initiate refunds or report to competent authorities. Measures must be proportionate. Users may challenge Platform decisions except where notification is legally restricted.

Users must protect credentials, promptly report suspicious conduct and must not evade security, payment or Platform Commission rules. Concerns may be reported through Platform support or to info@orbismentor.com.

This Policy may be updated following changes to law, payment arrangements, risks or Platform features. The current version and effective date are published on the Platform; material changes are notified as legally and contractually required.

Latvian law and directly applicable EU law govern this Policy. The Latvian-language text prevails in case of interpretative differences, without prejudice to mandatory consumer or data-subject rights.