Renopay Acceptable Use Policy

Version 1.0
Effective Date: 6 July 2026

Renopay Limited  |  Company No. 16521097  |  Registered in England and Wales
Registered office: 124-128 City Road, London, EC1V 2NJ

1. About this Policy

1.1 Purpose

Renopay Limited (“Renopay”, “we”, “us”, “our”) operates the Renopay marketplace, web application, mobile application, and associated services (the “Platform”), which provides a secure, milestone-based way for Homeowners and Builders to manage payments for residential construction, renovation, and landscaping Projects. This Acceptable Use Policy (the “Policy”) sets out the rules that govern how you may use the Platform, the content you may upload or share, and the standards of conduct we expect of every User. Its purpose is to keep the Platform safe, lawful, and trustworthy for everyone who uses it.

1.2 Who this Policy applies to

This Policy applies to every User of the Platform, including Homeowners and Builders, and to anyone who accesses or interacts with the Platform whether or not they have registered an account. By creating an account on, accessing, or using the Platform, you agree to comply with this Policy at all times.

1.3 Relationship with the Agreement and with OPP

This Policy forms part of the Agreement and should be read together with it, with the Privacy Policy, and with the OPP PSU Terms. Where this Policy refers to action affecting funds (including freezing, withholding, releasing, or refunding Escrow Funds), that action is taken by OPP under the OPP PSU Terms, not by Renopay. Renopay is the operator of the marketplace and is responsible for content and account decisions on the Platform; OPP, as the FCA-authorised payment provider, is solely responsible for decisions regarding payment, escrow, and safeguarding. This Policy does not amend or extend the OPP PSU Terms.

1.4 Online safety

Renopay operates the Platform (including its in-app messaging functionality) as a “user-to-user service” for the purposes of the Online Safety Act 2023. We take our duties under that Act seriously, including our duties in relation to illegal content. This Policy, together with our reporting and moderation processes, forms part of how we meet those duties.

2. General Principles

When you use the Platform, you must:

• (a) comply with all applicable laws and regulations, and with this Policy, the Agreement, and the OPP PSU Terms;
• (b) act honestly, fairly, and in good faith towards Renopay, OPP, and other Users;
• (c) provide accurate, complete, and up-to-date information, and keep your account details current;
• (d) use the Platform only for its intended purpose, namely the legitimate procurement, supply, management, and payment of residential construction, renovation, or landscaping work; and
• (e) respect the rights, safety, privacy, and dignity of other Users.

The remainder of this Policy explains what this means in practice. The lists of prohibited content and conduct in this Policy are examples and are not exhaustive.

3. Prohibited Content

You are responsible for all content you upload, post, transmit, or share on the Platform, including project photographs, videos, documents, completion evidence, reviews, profile information, and messages sent through the Platform's messaging functionality (“Content”). You must not upload, post, transmit, or share any Content that:

• (a) is unlawful, or promotes, facilitates, or encourages any unlawful act;
• (b) is false, misleading, or deceptive, or that misrepresents your identity, qualifications, insurance, accreditations, or your connection with any person;
• (c) is defamatory, harassing, threatening, abusive, hateful, discriminatory, or that incites violence or hatred against any person or group (including on the basis of race, religion, sex, gender, sexual orientation, disability, age, or any other protected characteristic);
• (d) infringes the intellectual property rights, privacy rights, or any other rights of any third party;
• (e) contains the personal data of any third party without that person's lawful consent, or that discloses another person's private or confidential information;
• (f) is obscene, pornographic, sexually explicit, or otherwise indecent;
• (g) contains viruses, malware, or any other harmful code, or that is designed to interfere with, damage, or gain unauthorised access to the Platform, any systems, or any data; or
• (h) is otherwise objectionable, or that brings or is likely to bring Renopay, OPP, or the Platform into disrepute.

3.1 Illegal content

In addition to the above, you must never use the Platform to create, upload, store, share, or transmit illegal content. This includes, and Renopay has a zero-tolerance approach to:

• (a) child sexual abuse or exploitation material, or any content that sexualises, grooms, endangers, or exploits a child;
• (b) terrorist content, or content that encourages, promotes, or provides instruction in terrorism or violent extremism;
• (c) content that encourages, assists, or threatens serious violence against any person;
• (d) content facilitating fraud, money laundering, terrorist financing, modern slavery, human trafficking, or the supply of illegal goods or services; and
• (e) any other content that is a criminal offence to create, possess, or distribute.

Where we become aware of illegal content, we will act without undue delay to remove it, and we will report it to OPP and to law enforcement or other relevant authorities where we are required or consider it appropriate to do so. We may preserve relevant Content, records, and account information in connection with any such report or investigation. We will cooperate with law enforcement and regulatory authorities as required by law.

4. Prohibited Conduct

Whether or not it involves Content, you must not:

• (a) use the Platform for any unlawful, fraudulent, dishonest, or improper purpose;
• (b) impersonate any person, or falsely state or misrepresent your affiliation with any person or organisation;
• (c) create, control, or use multiple or fictitious accounts to mislead other Users, evade enforcement action, manipulate reviews or ratings, or circumvent any limit or restriction;
• (d) harass, bully, intimidate, stalk, or threaten any other User, or any Renopay or OPP staff member;
• (e) interfere with, disrupt, or place an unreasonable load on the Platform, its servers, or its networks;
• (f) attempt to gain unauthorised access to any part of the Platform, any account, or any system or network connected to the Platform;
• (g) use the Platform to send unsolicited commercial communications (spam), or to advertise or promote goods or services unrelated to a legitimate Project; or
• (h) encourage, assist, or enable any other person to do any of the above.

5. Platform Integrity and Misuse of the Escrow Process

The Platform exists to protect both Homeowners and Builders through a milestone-based escrow process. Conduct that undermines the integrity of that process harms other Users and is strictly prohibited. In particular, you must not:

• (a) Milestone and approval abuse: submit false or misleading completion evidence; mark a Milestone as complete when the work has not been done as agreed; or pressure, coerce, induce, or collude with another User to approve a Milestone, or to release Escrow Funds, dishonestly or otherwise than in accordance with the Agreement;
• (b) Sham or bad-faith Disputes: raise a Dispute Ticket that you know to be without genuine basis, or raise or prolong a Dispute in bad faith in order to delay payment, extract an unwarranted concession, or otherwise misuse the Platform's Dispute mechanism;
• (c) Collusion: act together with another User to misuse the escrow process, to obtain funds dishonestly, to launder money, or to create artificial, fictitious, or sham Projects or Transactions;
• (d) Off-platform pressure: pressure, mislead, or induce another User to move a Project off the Platform, to release funds outside the Platform, or to bypass the protections that the Platform and OPP's escrow process provide;
• (e) Fake or manipulated reviews: post, solicit, or incentivise reviews, ratings, or feedback that are false, misleading, or not based on a genuine Project experience, or attempt to manipulate any rating or reputation feature; and
• (f) Circumvention of checks: take any step designed to evade, frustrate, or defeat OPP's KYC, AML, sanctions, fraud-prevention, or due-diligence processes, or any limit, restriction, or security measure applied on the Platform or by OPP.

This Policy addresses conduct that undermines the integrity and safety of the Platform. It is separate from, and in addition to, the commercial non-circumvention provisions in Section 5.3 of the Agreement (which deal with avoidance of Platform Fees). Both apply.

5.1 Honest dealing in Disputes

When raising or responding to a Dispute, you must act in good faith, provide truthful information, and not fabricate, alter, conceal, or destroy evidence. The Platform record may be made available to an Expert in any Expert Determination, and providing false information may amount to a breach of this Policy and of the Agreement, as well as having consequences at law.

6. Data, Scraping, and Intellectual Property

To protect the Platform, other Users, and their data, you must not:

• (a) scrape, harvest, crawl, index, or extract data from the Platform by automated or manual means, except as expressly permitted by us in writing;
• (b) copy, reproduce, republish, distribute, or create derivative works from the Platform or any Content belonging to Renopay or another User, except as permitted by the Agreement;
• (c) reverse-engineer, decompile, disassemble, or attempt to derive the source code, structure, or underlying ideas of the Platform, except to the extent this restriction is prohibited by law;
• (d) use the Platform, or any data or Content obtained from it, to build, train, or improve any machine-learning model, dataset, or competing product or service; or
• (e) collect, compile, or use information about other Users (including builders' or homeowners' contact details or project information) for any purpose unrelated to a legitimate Project, including marketing, solicitation, or resale.

7. Security and Account Responsibilities

You are responsible for keeping your account secure. You must:

• (a) keep your login credentials confidential and not share them with, or allow them to be used by, any unauthorised person;
• (b) not access or attempt to access any account that is not your own;
• (c) promptly notify Renopay of any actual or suspected security breach, account compromise, or unauthorised access to your account; and
• (d) comply with any additional security requirements that Renopay or OPP may reasonably impose.

Separate rules apply to your OPP Account and OPP Security Credentials under the OPP PSU Terms. You should keep those credentials safe in accordance with the OPP PSU Terms, and notify OPP immediately if you believe they have been compromised.

8. Reporting Violations

If you encounter Content or conduct on the Platform that you believe breaches this Policy, or that is harmful or illegal, please report it to us so that we can take appropriate action. You can report a concern:

• (a) using the in-app “Report” function, where available; or
• (b) by emailing us at info@renopay.co.uk, with sufficient detail to allow us to identify and assess the Content or conduct in question (including, where relevant, the User, Project, or Milestone concerned, and a description of the issue).

When you make a report, we will acknowledge it within 2 business days and aim to assess and, where appropriate, act on clearly identified breaches within 5 business days. Where Content is or appears to be illegal, we will act without undue delay. We may need to ask you for further information, in which case our timeframes run from the date we receive it. We treat reports confidentially so far as we reasonably can, consistent with the need to investigate and to comply with our legal obligations.

Reports about Renopay's own services (as opposed to other Users' Content or conduct) are handled under the complaints procedure in the Agreement. Reports about OPP's payment services should be directed to OPP in accordance with the OPP PSU Terms.

9. Moderation and Enforcement

9.1 Our moderation approach

We may, but are not obliged to, monitor or review Content on the Platform. We operate a notice-and-takedown approach: where we become aware (whether through a report or otherwise) of Content or conduct that breaches this Policy, we will take such action as we consider appropriate and proportionate in the circumstances. We do not generally pre-screen Content before it is posted.

9.2 Action we may take

Depending on the nature and seriousness of a breach, and taking into account whether it is a first or repeated breach, we may take one or more of the following actions:

• (a) issue a warning;
• (b) remove, disable, or restrict access to the relevant Content;
• (c) restrict or remove your access to particular features of the Platform;
• (d) suspend your access to the Platform (in whole or in part), in accordance with Section 10 of the Agreement;
• (e) terminate your account and your access to the Platform, in accordance with Section 10 of the Agreement;
• (f) notify OPP, which may (acting under the OPP PSU Terms and in its sole discretion as the regulated payment provider) take its own action, including suspending payouts or freezing Escrow Funds; and
• (g) report the matter to law enforcement, regulators, or other relevant authorities, and cooperate with any resulting investigation.

For clarity, decisions to remove Content or to restrict, suspend, or terminate Platform access are made by Renopay. Decisions regarding the freezing, withholding, release, or refund of funds are made by OPP under the OPP PSU Terms. Renopay does not control OPP's decisions about funds.

9.3 Urgent action

Where Content or conduct is illegal, or poses a risk to the safety of any person or to the integrity or security of the Platform, we may take immediate action (including immediate removal of Content or suspension of access) without prior notice. We will, where lawful and appropriate, notify you of the action and the reason for it as soon as reasonably practicable.

9.4 Notice and reasons

Other than where Section 9.3 applies, or where we are prevented from doing so by law or for security reasons, we will notify you if we remove your Content or restrict, suspend, or terminate your access, and we will give you the reason. Where a breach is capable of being remedied, we will, where appropriate, give you a reasonable opportunity to put it right before taking more serious action, consistent with Section 10 of the Agreement.

10. Appeals

If you believe that we have removed your Content or restricted, suspended, or terminated your access in error, you may ask us to review that decision. To do so, contact us at info@renopay.co.uk within 14 days of the action, explaining why you think the decision was wrong and providing any relevant information. We will review your appeal fairly, by a person not solely responsible for the original decision where reasonably practicable, and we will respond within a reasonable period, normally within 10 business days. This appeal process does not affect your statutory rights, your rights under the Agreement, or your right to refer a relevant complaint about OPP's payment services to OPP and, where eligible, to the Financial Ombudsman Service.

11. Changes to this Policy

We may update this Policy from time to time, for example to reflect changes in law, regulation, the Platform, or our services. Where we make changes that are material to your rights or obligations, we will give you reasonable notice in accordance with Section 11 of the Agreement. Your continued use of the Platform after a change takes effect constitutes acceptance of the updated Policy. The version in force at any time is the version published on the Platform.

12. How to Contact Us

If you have any questions about this Policy, or wish to report a concern, you can contact us at info@renopay.co.uk, or by post to Renopay Limited, 124-128 City Road, London, EC1V 2NJ. Formal notices under the Agreement must be given in accordance with Section 15 of the Agreement.

— End of Acceptable Use Policy —