Cardholder Agreement Consumers
Introduction
These terms and conditions (together with the Tariff and any other documents incorporated by reference, the Agreement”) set
out the terms and conditions that apply to your Account, Card and any other associated services provided to you by Paynetics AD
(“Paynetics”, “we” “us”, our) under this Agreement.
This Agreement constitutes a legal contract between you and Paynetics. It contains important information that may affect your
rights, use of any of our services and your ability to recover your money. Please read all of the documents forming part of this
Agreement carefully and keep a copy or download a copy of them for your records and future reference.
This Agreement shall be governed by and construed in accordance with the laws of the Republic of Bulgaria, without giving effect
to conflict of law principles, and subject to mandatory provisions under the laws of your country of residence. To the extent that
Bulgarian law is in conflict with laws of your country of residence, Bulgarian law shall prevail to the maximum extent possible. If
not prohibited by the laws of your country of residence, disputes shall be settled by Bulgarian courts.
You can request a copy of this Agreement at any time throughout its duration by contacting Customer Relations Centre. By
submitting your order for a Card to Paynetics and by clicking “I Accept” in the relevant box, you indicate that you have accepted
this Agreement.
You should read this Agreement alongside Privacy Policy which you can view here
https://paynetics.digital/privacy-and-security-policy/. Our Privacy Policy (as it may be amended from time to time in accordance
with its terms), together with this Agreement, describes the basis upon which any personal data we collect about you, either
directly or from our authorised partners or that you provide to us or them, will be processed, handled and shared by us.
1. DEFINITIONS
In this Agreement:
Account means any e-money payment account opened and maintained for you by Paynetics under this Agreement.
App means either Mobile App and / or Web App as available.
ATM" means an automated teller machine that can be used for cash withdrawals using a Card, and sometimes for other
payment and non-payment transactions.
“Card” means any Paynetics debit Mastercar card issued to you by Paynetics that is linked to your Account(s) . The Card is a
type of a payment instrument which allows you to access the Account`s balance to make debit card payments. The Card may be
physical or virtual.
“Card Organisation” means Mastercard International (‘MasterCard’), VISA Europe (‘VISA’) or any other organisation maintaining
a card payment system under which Card payments are processed.
“Faster Payments” means a payments system which allows sending and receive payments in GBP the UK between participating
payment service providers.
“Mastercard” means Mastercard International Incorporated or its successors.
“Mobile App” means the mobile application developed by the Technical Provider and published in the Apple AppStore and
Google PlayStore, which enables you to access your Account and/or Card.
“Paynetics”, “we”, “us”, our means:
(a) where payment services under this Agreement are provided in the UK - Paynetics AD, a company with its seat and registered
address at Ground Floor, 76A James Bourchier, Lozenets District, Sofia Municipality, Sofia, Bulgaria, entered in the Bulgarian
1
17759041v.2
Commercial Register kept by the Registry Agency under UIC: 131574695 (“Paynetics AD”) or such other Paynetics entity
authorised in the UK as notified to you. For the purposes of UK services, Paynetics AD is an electronic money institution deemed
authorised and regulated by the UK Financial Conduct Authority under the Temporary Permissions Regime (firm reference
number 900785) for the issuance of e-money and provision of payment services in the UK. Details of the Temporary Permissions
Regime, which allows EEA-based firms to operate in the UK for a limited period while seeking full authorisation, are available on
the Financial Conduct Authoritys website; or
(b) where payment services under this Agreement are provided in the EEA Paynetics AD. For the purposes of EEA services,
Paynetics AD is an electronic money company holding a license for operating as an electronic money company issued by the
Board of Directors of the Bulgarian National Bank by Decision 44 of 11 April 2016, and is entered in the register kept by the
Bulgarian National Bank, which is accessible on http://www.bnb.bg/RegistersAndServices/RSPIPublicRegisters/index.htm. The
Bulgarian National Bank supervises the activities of Paynetics AD .
“PIN” shall mean a unique four-digit personal identification number, which can be used to confirm Card payments.
Technical Provider means the operator that performs certain technical and operational functions in relation to our services,
including the operation of Platform which connects the customers with Paynetics.
“Prohibited Transaction means any of transactions or activities as listed below or as may be subsequently made available on
the Website from time to time:
1. Any sales of ‘pyramid’ type, Ponzi schemes or similar marketing or matrix programs or other schemes for quick enrichment
or high-yield investment programs;
2. Sale, supply or purchase of illegal items or items promoting or facilitating illegal activities;
3. Sale, supply or purchase of counterfeit products or products infringing intellectual property rights;
4. Products or services for the processing or aggregation of payments by third parties;
5. Money laundering;
6. Terrorism financing or propaganda;
7. Pornography, escort services and selling and/ or advertising sexual services;
8. Using the Card or Account in a manner and/or for purposes that violated any applicable law and/or regulations of the Card
Organisation or SEPA;
“SEPA” means Single Euro Payments Area scheme, which allows sending and receiving payments in EUR between participating
payment service providers.
Tariff means the fees and limits applicable to your Accounts, Card and any other services provided to you under this
Agreement. The Tariff, as amended from time to time, is available on the Website
Web App means the web application developed by the Technical Provider and run on a web server, which enables you to
access your Account and/or Card.
“Website” means the following website: https://resources.weavr.io/my-neo-group_conusmers-programme-terms
2. ABOUT OUR SERVICES
2.1. Your Accounts are maintained by Paynetics and the Card is issued to you by Paynetics. The value stored on your Accounts is
electronic money, otherwise referred to as ‘e-money. Paynetics is not a bank and your Account is not a bank account. The
funds available in your Account are not a deposit. No interest will accrue on your Account balance. Your Card is a debit card
linked to your Account, it is not a credit or charge card.
2
17759041v.2
2.2. The Financial Services Compensation Scheme does not apply to funds held in your Accounts. Instead, Paynetics protects
your funds through a process known as ‘safeguarding, in line with its regulatory requirements. In this process, Paynetics
keep your money separate from our own funds and places it in a safeguarding account with a bank or cover it by an
insurance policy or a comparable guarantee. Before we provide any of our services to you, you will have to successfully
complete our process for verifying your identity. The process may involve you providing us a valid passport / ID card and a
bank statement or other identification documents, as well as a selfie, together with the presented identity document in real
time, or any other procedure we may specify. We may use ID verification agencies or other automated platforms to verify
your identity. We or the Programme Manager may require you to provide additional information at any time for the
duration of this Agreement.
2.3. This Agreement will only become effective once you receive a confirmation that Paynetics has approved your application.
Paynetics will not be obliged to provide any of the services under this Agreement before such confirmation is provided.
Paynetics may refuse to approve any application and/or enter into an agreement for its services for any reason.
2.4. To be eligible for our Account and associated services, you must be: (a) 18 years of age or over; and (b) UK resident (for
services provided in the UK). We can close your Account or stop providing our services if we find out you are not eligible for
it.
2.5. The Account and Card are issued to individuals only. You may only use your Account and Card personally and do not have
the right to transfer their use to anyone else. In case you allow access to or provide any other means to use your Account or
Card to any other person, you will bear full responsibility for all payments initiated by them.
2.6. You must not use your Account or Card for or in relation to (including sending or receiving proceeds from):
2.6.1. any activities which do not comply with any applicable laws or regulations, including but not limited to laws relating
to money laundering, fraud, financial services or consumer protection;
2.6.2. Prohibited Transaction under this Agreement; or
2.6.3. trading or business purposes.
3. RECEIVING/SENDING PAYMENTS
3.1. When this Agreement becomes effective, Paynetics will set up and maintain:
3.1.1. an EUR Account with a dedicated IBAN and one or more Cards, which may be used for sending or receiving
payments via SEPA in EUR and for Card payments and cash withdrawals in EUR; and/or
3.1.2. a GBP Account with a dedicated IBAN, an account number with sort code and one or more Cards, which may
be used for sending or receiving payments via Faster Payments in GBP and for Card payments and cash
withdrawals in GBP.
3.2. Limits may apply to your Account and Card, such as limits on minimum load payments to your Account, the maximum
balance that can be held on your Account, the value of individual Account and/or Card payments or an aggregate value or
number of payments in a particular time period. The applicable limits are as set out in the Tariff and may be changed by us
from time to time. To manage our risk, particularly with respect to money laundering, fraud or security concerns, we may
also apply internal controls, including limits, to certain types of transactions from time to time but for security purposes,
will not disclose them.
4. LOADING FUNDS TO YOUR ACCOUNT
4.1. The minimum load amount to top up your Account is indicated in the Tariff.
4.2. The balance of the Account should never exceed the limits set out in the Tariff.
4.3. You can load your Account using the following methods:
3
17759041v.2
4.3.1. EUR Account can be loaded by receiving payments via SEPA;
4.3.2. GBP Account can be loaded by receiving payments via Faster Payments.
4.4. The received funds will be credited to your Account immediately after Paynetics receives the funds.
4.5. Paynetics may refuse to execute an incoming payment and your Account will not be credited if:
4.5.1. your Account or payment breaches any of the limits as set out in the Tariff;
4.5.2. your Account is inactive, blocked or terminated;
4.5.3. the sender has provided incorrect/invalid Account details for payment;
4.5.4. Paynetics reasonably believes the payment is fraudulent, illegal or unauthorised;
4.5.5. Paynetics reasonably believes the payment related to a Prohibited Transaction.
4.6. If an incoming payment is refused for any of the reasons set out above, the funds may be sent back to the sender without
prior notice to you.
4.7. Paynetics will charge you with a top up fee every time your Account is loaded as set out in the Tariff.
5. MAKING PAYMENTS FROM YOUR ACCOUNT
5.2. You must make sure that your Account has sufficient funds available to cover the amount of a given payment and all
applicable fees. Paynetics may refuse to perform any given payment if your Account does not have sufficient balance to
cover the amount of the payment and all applicable fees.
5.3. Paynetics will execute your payment instructions for payments from your Account on the same day it receives them (or the
future day agreed if it is in the future). The time of receipt of your payment instruction is when Paynetics receives it (which
will typically be on the same day you instruct the payment) or, if the payment instruction specifies the payment is to take
place on a future day, then your payment instruction will be treated as received on that day. You cannot cancel a payment
after you have authorised it and Paynetics has received your payment instruction for it, except that you can cancel a future
payment, such as a recurring Card payment if you notify Paynetics of cancellation no later than the end of the business day
before the payment is due to be made via the App. Cancelling a future dated payment such as a recurring Card payment
with us will not cancel the agreement with the organisation you are paying. You should tell the organisation collecting the
payment about the changes to your instructions.
5.4. After receiving your payment instruction for payment from your Account (including Card payments), Paynetics will credit
the recipient’s account within the timescales set out below.
Type of payment
Delivery to the recipients account
Payments in EUR or GBP to an account in the UK or the
EEA (including where there has been a currency
conversion between EUR and GBP)
No later than the end of the business day after your
payment instruction is received
Payments in any other currency or to an account outside
the UK or the EEA
Varies, depending on the currency or country the payment
is sent to
5.5. Paynetics will deduct the value of payments together with all applicable fees from the balance on the relevant currency
Account. Payments from your Account by way of credit transfers in EUR or GBP will be deducted from your EUR or GBP
Account respectively. Card payments in EUR or GBP will also be deducted from your respective currency Account. Card
payments in any other currency will always be deducted from your Account at then prevailing currency conversion rates. If
there is insufficient balance on the relevant GBP or EUR Account to complete the payment, including all applicable fees,
funds will be automatically transferred from your Account in the other currency to your relevant currency Account at then
prevailing currency conversion rates. If there is insufficient balance on both your EUR and GBP Accounts to complete the
4
17759041v.2
payment, including all applicable fees, the payment will be refused. See clause 11 for more detail on the applicable currency
conversion rates and fees.
5.6. You agree you will not make any attempts to interrupt or impair the functionality of our information system, including but
not limited to, not to spread files containing viruses, damaged files or other similar software which may be used for
accessing, modifying, deleting or damaging data files.
6. ACCESS TO YOUR ACCOUNTS BY THIRD PARTY PROVIDERS
6.2. You may choose to allow (and provided you have given them your explicit consent):
6.2.1. providers of account information service (i.e. an online service which accesses one or more payment accounts to
provide a consolidated view of such accounts) to access information on your Account; and/or
6.2.2. providers of payment initiation service (i.e. an online service which allows a third party to initiate payments on
behalf of the account holder from their account and at their request) to initiate payments (other than Card
payments) from your GBP and EUR Accounts.
6.3. Only those providers of account information or payment initiation services that are authorised with the Financial Conduct
Authority or another European regulator to provide the relevant service in the UK or an EU member state, as applicable,
can be given access to your Account. The Financial Conduct Authority’s register (available at https://register.fca.org.uk/ ) will
tell you whether a provider is authorised in the UK, and we recommend you check it before using their services.
6.4. We will treat any instruction from such providers of account information or payment initiation services as if it was from you.
Some providers may use your Account security details to provide their service. You should always consider the implications
of sharing your security information.
6.5. We can deny providers of account information or payment initiation services access to your Account if we are concerned
about unauthorised or fraudulent access. We will notify you of the denial of access and the reasons for it beforehand if
possible or otherwise immediately afterwards (unless doing so would compromise our security measures or would be
unlawful). The access to your Account may be restored once the reasons for denying the access no longer justify such
denial.
7. GIVING INSTRUCTIONS FOR PAYMENTS FROM YOUR ACCOUNTS
7.2. For a payment from your Account (including transfers to your other Accounts) to be properly executed, you must provide us
the following information when you instruct us to make the payment (in addition to any other information we may ask for):
7.2.1. for payments from your GBP Account to a UK account via Faster Payments: the recipient’s name, account number,
the payment amount and sort code and a payment reference;
7.2.2. for payments from your EUR Account to an EEA account via SEPA: the recipient’s (beneficiary) name, IBAN, the
payment amount, its currency and reason for payment (this information meant for the beneficiary), additional
clarifications;
7.2.3. for payments from your EUR Account to an account outside the EEA via SEPA (to countries that participate in SEPA):
in addition to information set out at 7.1.2, you will also need to provide the senders (originator) address and may
also be required to provide the recipient’s (beneficiary) bank’s BIC;
7.3. for any payments above EUR 15,000 or its equivalent in another currency: the sender (originator) and / or recipient
(beneficiary) could also be required to provide a declaration to prove the origin of funds; If you provide us with incorrect or
incomplete information or refuse to provide information, we may refuse to execute the payment, the funds could be lost
and irrecoverable or there could be a delay in the recipient receiving the payment.
7.4. You give us instructions and consent to a payment from your Account in one of the following ways:
7.4.1. using the App;
5
17759041v.2
7.4.2. giving us instructions via a third party (such as payment initiation service provider);
7.4.3. using Cards (see clause 10 below on how you instruct us to make payments using a Card);
You may be required to provide security details and/or use a particular authentication method depending on the method
you use. We will tell you which authentication can be used or if they are unable for any particular types of service.
Paynetics reserves the right to change or introduce new authentication methods at any time, including for reasons relating
to changes in the law, technical characteristics of the services or security.
7.5. Paynetics may refuse to carry out any instructed payment from your Account if it does not meet the requirements of this
Agreement, including, but not limited to any of the following circumstances:
7.5.1. Paynetics reasonably suspects that the payment is unauthorised or involved in fraud or illegal activity;
7.5.2. your instruction is unclear, incorrect or incomplete;
7.5.3. Paynetics reasonably believes that there has been a violation of this Agreement;
7.5.4. you have failed to use the authentication method and/or provide security information required;
7.5.5. there are insufficient funds in the Account to cover the payment and any applicable fees;
7.5.6. the payment violates any applicable limits;
7.5.7. carrying out your instruction might cause us to break the law, order of a regulatory body, code, rule of Card
Organisation or other duty applicable to Paynetics;
7.5.8. due to a technical impossibility to carry out the payment;
7.5.9. Paynetics reasonably believes payment is related to a Prohibited Transaction.
7.6. If we refuse to execute the payment, we will notify you as soon as possible unless it would not be unlawful for us to do so. If
possible, we will provide the reasons for refusal to execute the payment and where those reasons relate to factual matters,
the procedure for rectifying any factual errors that led to such refusal.
7.7. The execution of any payment to or from your Account (including Card payments) may be delayed or refused due to the
performance of Paynetics’ security or legal compliance checks, including if Paynetics suspects that the payment is involved
in fraudulent, illegal or unacceptable activities or constitutes an unauthorised payment.
8. DESCRIPTION OF THE CARD
8.2. Your Card is issued to you by Paynetics and is linked to your Account in EUR and/or GBP, as applicable, maintained by
Paynetics. Your Card can be used in your country of residence or abroad.
8.3. The Card is issued under the Mastercard brand pursuant to license granted by Mastercard International.
8.4. Unless specified otherwise in this Agreement, your Card can be used to pay merchants for goods or services at (whether
in-store, online or over the phone) and for cash withdrawals at ATMs. If you have been issued with a virtual Card, it can only
be used to pay merchants online. Your Card can be used at all card acceptance terminal devices bearing the Mastercard
logo which maintain the necessary functions.
8.5. Card payments will be executed immediately after Paynetics receives the payment request.
8.6. The value of all Card payments, including all applicable fees, will be deducted from your relevant Account balance, see
clause 5.4.
6
17759041v.2
8.7. You will be responsible for all goods or services purchased with the Card. Any dispute with a merchant about a product or
service purchased with the Card will be considered a dispute between you and the merchant, and should be addressed
directly to that merchant. Paynetics does not accept any responsibility or liability for the quality, safety, legality or any other
aspect relating to and does not provide any warranties regarding such goods or services purchased with the Card.
8.8. Paynetics will not be liable if a merchant refuses to accept a Card or if Paynetics has refused to executed a payment in
accordance with this Agreement.
8.9. The Card is property of Paynetics as a card issuer and cannot be transferred and/or made available to anyone else.
9. CARD ISSUANCE, LOADING, ACTIVATION AND REPLACEMENT
9.2. Each Card has a validity period within which you may use the Card. If your Card is physical, it will expire on the last day of
the month/year indicated on its front. If your Card is virtual, it will expire on the last day of the month/year indicated on the
App or on the expiry date sent to you by e-mail . All Card payments initiated after the expiration or cancellation of the Card
will not be authorised or executed.
9.3. Paynetics will issue the Card within 10 business days from the date your application is accepted and, if the Card is not
virtual, will deliver it to you personally. If your Card is virtual, the Card will be made available to you via the App
immediately after your application is approved by Paynetics.
9.4. The physical Card will be personally delivered to you and you may be required to produce an ID document to collect it. You
must sign on the signature strip on the reverse side of the physical Card immediately after receiving it.
9.5. You will be provided with a PIN to use with your Card. You can change your PIN at an ATM. You should memorise your PIN
and then destroy the media on which it is recorded. You have important obligations to keep your security details such as PIN
safe (see clause 14 below).
9.6. You may request Paynetics to issue a new Card in the following cases:
9.6.1. in case of destruction or damage to the Card;
9.6.2. in case of loss, theft or other misappropriation of the Card,
9.6.3. in case of a forgotten PIN, and
9.6.4. upon expiry of your Card’s validity period. If your Card expires, it will only be automatically replaced if your Card was
used within the last two months before its expiry date.
9.7. If your Card is replaced because it was lost or damaged, or in case of a forgotten PIN or upon expiry of your Card’s validity
period, you will be charged a Replacement Fee (see Tariff) which will be deducted from your Account. If your Card has been
reported stolen or misappropriated you will be charged a fee that is directly related to the cost of replacement (see Tariff). If
your Card has been reported lost, stolen or misappropriated but later is found, then you should immediately inform
Paynetics about it and destroy the Card.
9.8. When you receive the Card it will be inactive. You have to activate the Card before using it. Otherwise, any Card payments
attempted by you will be rejected. The Card can be activated online by following the instructions for activation provided to
you.
10. GIVING INSTRUCTIONS FOR CARD PAYMENTS
10.2. You give us an instruction and consent to a payment made using your Card using any one of the following methods:
10.2.1. in case of cash withdrawal from an ATM: by entering a PIN;
10.2.2. in case of payment for goods or services in-store: by entering a PIN and/or signature on the receipt or by
tapping/waving the Card (or a device where it is held) over a card reader for contactless payments;
7
17759041v.2
10.2.3. in case of online payments for goods or services online or via the phone: by providing your Card details and a
one-time payment code or other security information or credentials, when requested.
10.3. Your consent for a Card payment may cover a single payment or a series of recurring payments on a Card (such as
where you give your Card details to a merchant to be used for Card payments in the future) for a set or variable
amount.
10.4. Merchants in certain business sectors (e.g. car rental companies, hotels and other service providers) estimate the
amount of the final Card payment to them and require to “pre-authorise” or withhold the estimated amount on the
Card. Sometimes, that withheld amount may exceed the final amount spent. In such cases, the initially withheld funds
will not be available to you for up to 15 days until the final Card payment request is received by us or released by the
merchant. Paynetics may release such amounts only with the merchant’s consent.
10.5. You are responsible to provide a correct and accurate instructions for execution of a payment. If the instructions
provided by you are incorrect, inaccurate or incomplete, Paynetics will not be liable for errors or inaccuracies in the
transaction. If a payment is carried out in accordance with the instructions provided by you, it will be deemed to have
been correctly executed.
11. FEES AND EXCHANGE RATES
11.2. Fees that apply to your Account, Card and associated services and/or transactions are as set out in the Tariff. All fees
will be determined in the currency of the relevant Card and/or Account to which they relate and will be deducted from
the relevant Account.
11.3. Paynetics reserves the right to change the applicable fees in accordance with this Agreement (see further clause 16).
Changes in the reference exchange rate will apply immediately without prior notice.
11.4. If a payment received or sent into/from your Account is in a currency other than the currency of the Account (including
transfer between your different currency Accounts), then the payment amount will be converted into the currency of
the destination account using an exchange rate made up of a reference rate (available at the App) plus the currency
conversion mark-up fee as set out in the Tariff. The exchange rate will be determined at the time (with respect to
payments into Account) the payment is received or (with respect to payments from Account) the payment instruction
is received by Paynetics.
11.5. If a payments using a Card is in a currency other than the currency of the Account from which it is taken, then the
amount deducted will be the amount of the Card payment converted to the currency of the Account using the
reference exchange rate applied by MasterCard® (available at
https://www.mastercard.co.uk/en-gb/personal/get-support/convert-currency.html) plus the currency conversion
mark-up fee set out in the Tariff for Card payments. The exchange rate shall be determined on the date of the Card
payment is processed. The exchange rate is not set by Paynetics and varies throughout the day meaning it may change
between the date the Card payment is made and the date it is processed. Paynetics provides information on the total
currency conversion charges applicable with respect to Card payments, expressed as a percentage mark-up over the
latest available euro foreign exchange reference rates issued by the European Central Bank on the Website .
12. NEGATIVE BALANCE
12.2. If any action results in a negative balance in your Account, you must reimburse Paynetics the amount of the negative
balance immediately upon request. Paynetics may charge the amount of the negative balance against the funds on any
other Accounts held by you, including any subsequently loaded funds. Paynetics may suspend Accounts and Card until
it is reimbursed for the negative balance in full and may take legal action against you to recover such amount.
13. COMMUNICATION PROCEDURE
13.2. The Agreement is executed in English and all communications between you and us will be in English, unless expressly
agreed otherwise in this Agreement.
8
17759041v.2
13.3. Your representatives or persons authorised by you may receive information about the payments made with the
Card/Account electronically.
13.4. We can communicate with you (including to provide any information or notifications in relation to this Agreement)
using any of the following methods:
13.4.1. via the App;
13.4.2. by email;
13.4.3. by phone (including by sending you an SMS);
13.4.4. by writing to your home address.
We will tell you if any of these communication methods are not available. We will also tell you if you need any technical
requirements or software to communicate with us.
13.5. We will use the contact information you have most recently given us to communicate with you. If any of your contact
details change, you must inform Paynetics about it as soon as possible by updating your details via the App All
notifications, invitations or other notices sent to your last email address last known to Paynetics will be deemed to
have been delivered.
13.6. You can contact Paynetics via Customer Relations Centre (see contact details at clause 21).
13.7. Paynetics will provide information about your Account and Card transactions and fees by means of electronic
statements which will be accessible on the App. Paynetics will also notify you at least once per month by SMS or email
that your statement is ready Statements will not be provided on paper. You should carefully review your Account and
Card transaction information regularly. Your statements will remain available on the App for you to access for 1 year.
You may wish to download or print your statements for your future reference. You will be charged a fee (see Tariff) if
you ask us to provide additional information or provide it in a different manner than as described here.
14. SECURITY MEASURES
14.2. You must use your Card and Account in accordance with the terms and conditions set out in this Agreement. You have
important obligations to do everything you reasonably can to keep your Account and Card safe and to notify Paynetics
of any loss, theft, misappropriation or unauthorised use of the Card or Account immediately after becoming aware of it
as further described below.
Your obligations to keep your Account and Card safe
14.3. You will be provided with or will be able to set up certain security details (such as your Card PIN and any password,
passcode or other login details which can be used to access or make payments with your Account or Card via the App).
You must:
14.3.1. take all reasonable measures to keep your Account, Card and security details safe;
14.3.2. not write down any of your security details (such as PIN or password) unless it is done in a way to make it
difficult for anyone else to recognise them;
14.3.3. not record security details such as PIN on the Card or keep such information together with the Card;
14.3.4. not to disclose to and/or allow anyone else (other than authorised providers of account information services or
payment initiation services) to use in any manner whatsoever your security details such as user identifiers,
passwords or PINs;
14.3.5. keep your Card and any personal devices (mobile phones, computers, tablets) that can be used to access your
Account, Cards or security details secure and not let anyone else use them to make payments;
9
17759041v.2
14.3.6. not choose security details such as PIN or password to access your Card or Account that is easy for someone to
guess such as letters or digits that:
14.3.6.1. are easily associated with you, for example your telephone number or date of birth;
14.3.6.2. are part of the data imprinted on the Card;
14.3.6.3. consist of the same digits (1111) or the sequence of running digits (1234); or
14.3.6.4. are identical to previously selected PIN/password.
14.3.7. use up-to-date virus, malware, and spyware software and a firewall on any devices used to access your Account
or cards to reduce the risk of security breaches.
Your obligation to notify us
14.4. If your Card has been withheld by an ATM, you must immediately notify Paynetics. If Paynetics is not able to return the
Card to you, Paynetics will issue a new Card to replace it.
14.5. You must immediately notify Paynetics Customer Relations Centre (using contact details at clause 21) if:
14.5.1. your Card is lost, stolen or misappropriated; or
14.5.2. you believe there has been unauthorised use of your Card or Account or anyone else may be able to use or
access your Account, Card or security details to access them.
Paynetics will make all reasonable efforts to stop the use of Account and/or Card by blocking the Account and/or Card
payments after receiving a notification from you.
14.6. Paynetics may restrict, block or deactivate the Card or Account if:
14.6.1. Paynetics is concerned about the security of the Card or Account or the security details relating to them;
14.6.2. Paynetics becomes aware or suspects that the Account, Card or security details relating to them are being used
in an unauthorised, unlawful or fraudulent manner;
14.6.3. Paynetics reasonably believes it needs to do so to comply with the law or court order in any applicable
jurisdiction, the instructions provided by a Card Organisation or any other rule or duty applicable to Paynetics;
14.6.4. this Agreement is terminated for any reason;
14.6.5. you request us to do so;
14.6.6. you have breached any term of this Agreement in a material way.
14.7. We will, if possible, notify you before restricting, blocking or deactivating your Account or Card that we will do so and
the reasons for it. If we are unable to notify you beforehand, we will notify you immediately afterwards. We will not
notify you if doing so would compromise our security measures or would be unlawful.
14.8. Your Card and/ or Account will be unblocked or re-activated (or replaced) as soon as possible after the reasons for
blocking cease to exist.
Communicating with you about fraud or security threats
14.9. We may need to contact you urgently in the event of suspected or actual fraud or security threats to your Account,
Card and/or security details. To do so, we may use an SMS, telephone, e-mail or another secure procedure. When we
10
17759041v.2
contact you, we may also give you information on how you can minimise any risk to your Account, Card or security
details depending on the nature of the security threat. But will never ask you to give your full security details (such as
PIN, password or passcode) or ask you to transfer money to a new account for security reasons.
15. LIABILITY & REFUNDS
15.2. You must notify Paynetics in writing of any unauthorised or incorrectly executed payments on your Card or Account
without undue delay after becoming aware of such unauthorised or incorrectly executed payment and in any case no
later than 13 months from the date the payment was debited to your Account. You can notify us of such unauthorised
or incorrectly executed payments by contacting the Customer Relations Centre (see clause 21 for details).
15.3. If you notify us of an unauthorised or incorrectly executed payment in accordance with clause 15.1, you may be
entitled to receive a refund of the funds as detailed below. Paynetics will verify the authenticity of the payment, its
proper recording and reporting, and whether the transaction has been affected by a technical malfunction or other
defect.
15.4. In you are entitled to a refund for an incorrectly executed or unauthorised payment, we will refund you as soon as
possible upon receipt of your claim or any additional information we may request in order to investigate your right to a
refund. However, if after we refund you, our investigation leads us to reasonably that you were not entitled to the
refund, we will have the right deduct the amount of the refund from any funds on Accounts you hold with us and
reserve the right to recover the value of the refunded payment by any other legal means.
Unauthorised payments from your Account or Card
15.5. If Paynetics establishes you have not authorised a payment from your Account or using your Card (for example,
someone else made it) and there are no reasonable grounds for suspecting that you acted fraudulently, Paynetics will
refund the value of the unauthorised payment by no later than the end of the business day after you notify Paynetics
of the unauthorised payment. The refund will include any fees to restore your Account to the position it would have
been at if the unauthorised payment was not made. Paynetics may hold you responsible for up to first £35 for services
provided in the UK and EUR 50 for services provided in the EU incurred as losses with respect to unauthorised
payments arising from the loss, theft or misappropriation of your Card or security details before you notify Paynetics.
15.6. You will not be entitled to a refund and you will bear all losses, irrespective of their amount, relating to an
unauthorised payment if:
15.6.1. the payment was authorised by you;
15.6.2. you have acted fraudulently;
15.6.3. you have intentionally or with gross negligence have failed to comply with one or more of the obligations under
this Agreement (for example, with regards to keeping your Account and Card safe or to notify us of any
unauthorised payments).
Non-executed or Incorrectly executed payments from your Account or Card
15.7. If Paynetics fails to execute or incorrectly executes a payment from your Account or made using a Card, Paynetics will
promptly reimburse the amount of the payment (including any fees to restore the Account to the position it would
have been at if the defective payment was not made), unless Paynetics can show that the recipients payment service
provider has received the payment (in which case they will be liable). In this case, on your request, Paynetics will make
reasonable efforts to trace the payment and inform you about the outcome.
15.8. Pаynetics will not be liable for any payment executed in accordance with the payment instructions given by you. If the
payment instruction you have given us was incorrect or incomplete (for example, you have made a mistake in giving us
the recipient’s account details), Paynetics will make reasonable efforts to recover the payment amount. Paynetics may
charge you a fee for any such recovery as indicated in the Tariff. If Paynetics is not able to recover the payment
amount, Paynetics will, on your written request, provide you with the relevant information about the payment.
11
17759041v.2
Late or incorrectly executed payments to your Account
15.9. If Paynetics has received a payment for your Account but has not executed or incorrectly executed the payment (for
example, where Paynetics is responsible for crediting your Account with the received payment later than it should have
been), Paynetics will immediately credit your Account with the correct amount (including any fees to restore the
Account to the position it would have been at if the payment was executed correctly and in time).
15.10. If a payment is received in your Account incorrectly (for example, by mistake), Paynetics may, where it considers
reasonable to do so, hold the payment and return it to the sender. In any case, Paynetics is obliged to provide certain
information to the senders payment service provider about you and the payment to enable them to recover the
funds.
Payments initiated by payee
15.11. If you authorise a payment initiated by or through the payee without knowing the final amount of the payment (for
example, a Card payment initiated by the merchant when renting a car or booking a hotel room), you have the right to
request Paynetics for a refund of such payment provided that all of the following conditions are met:
15.11.1. you have asked for a refund within 8 weeks from the date on which your Paynetics Account was debited;
15.11.2. at the time of authorisation to execute the payment, its exact amount was not specified; and
15.11.3. the amount of the payment exceeded the amount you could have reasonably expected taking into account
your previous spending patterns, the terms of this Agreement and the case-specific circumstances. If the
amount of the payment increased because of the currency exchange when the reference exchange rate agreed
with Paynetics has been applied, it will not be a valid reason.
At the request of Paynetics, you must provide information to show the conditions above have been met.
15.12. Within 10 business days of receiving your request for a refund, or, where applicable, of receiving the further
information Paynetics requested, Paynetics will refund the full amount of the payment or inform you of the refusal to
refund it, together with the grounds for refusal and the authorities to which you can complain if you do not accept
those grounds. The refund will include the entire amount of the payment which will be dated back to the date on
which your Account was debited.
15.13. You will not be entitled to a refund of any payment initiated by or through payee when:
15.13.1. you have given your consent to perform the payment directly to Paynetics; and
15.13.2. where applicable, Paynetics or the payee has informed you about the upcoming payment at least 4 weeks
before it was due to be made.
General liability
15.14. Paynetics will not be liable to you for any damages or losses arising from or relating to:
15.14.1. your failure to use the Card or Account in accordance with this Agreement;
15.14.2. any payments executed in accordance with the information or instructions provided by you which were
incorrect, inaccurate or incomplete;
15.14.3. any unusual or unforeseeable circumstances beyond the control of Paynetics, the consequences of which could
not be avoided despite Paynetics’ best efforts;
15.14.4. refusal of a merchant, ATM or any other person to accept the Card or any other Account payment;
12
17759041v.2
15.14.5. malfunction of a mobile device or other equipment, software or services required for the successful technical
performance of an operation which is beyond the control of Paynetics;
15.14.6. compliance with the applicable legal or regulatory requirements or any rules or guidelines provided by the
Card Organisation;
15.14.7. you acting fraudulently or with gross negligence;
15.14.8. loss of revenue, goodwill, lost benefits or expected savings;
15.14.9. any loss or damage which is not a direct result nor a direct consequence of a breach of this Agreement by
Paynetics; or
15.14.10. any loss or damage caused by a virus, Denial of Service attack dissemination or other technologically harmful
material that may infect a computer or other device or equipment, software programs, data or other
proprietary material in connection to the Card, Account and this Agreement;
15.14.11. the quality, safety, legality or any other aspect of goods and/or services purchased using the Card or Account or
any possible disputes arising between you and the provider of such goods/services;
15.14.12. Paynetics refusing to accept or execute any payment or restricting, blocking or deactivating your Account
and/or Card in accordance with this Agreement;
15.14.13. loss or damage beyond Paynetics’ responsibility by law.
15.15. None of the terms of this Agreement will limit or exclude Paynetics’ liability for fraud, gross negligence or any other
liability which cannot be legally excluded or limited by law.
15.16. You are responsible for the use of the Card and Account in accordance with this Agreement. You will be liable to
Paynetics for all losses and damages caused by their improper and/or non-compliant use that does not comply with
this Agreement.
16. CHANGES TO THIS AGREEMENT
16.2. Paynetics may make changes to this Agreement, including the fees set out in the Tariff, as set out further below for
reasons which may include (but are not limited to):
16.2.1. changes to the products or services or introducing new products or services under this Agreement;
16.2.2. withdrawal of a particular part of our products or services;
16.2.3. changes in market conditions or operating costs that affect Paynetics;
16.2.4. changes in technology, our systems and/or payment methods;
16.2.5. making this Agreement clearer or more favourable to you; or
16.2.6. changes in relevant laws or regulations, or codes or rules that apply to Paynetics.
16.3. Paynetics will notify you about any changes to this Agreement, including the Tariff, and the date on which such
changes shall take effect, by posting a notice on the Website and/or via email, at least 2 months before the changes
take effect. Paynetics can make immediate changes, without notice to you, to the exchange rates used to convert
Account or Card payments where such changes are the result of changes in the reference rate we have disclosed to
you or are more favourable to you.
13
17759041v.2
16.4. If you do not approve of the changes to this Agreement, you have the right to terminate this Agreement free of charge
by informing Paynetics before the changes take effect. Paynetics will treat you as having accepted the changes unless
you inform Paynetics that you do not approve these changes before they take effect.
17. TERM OF THE AGREEMENT. CANCELLATION. TERMINATION. VALIDITY PERIOD OF THE CARD
17.2. This Agreement will become effective when your application is approved by Paynetics. This Agreement will remain
valid until it is terminated in accordance with its terms.
17.3. You can cancel your Account and Card and terminate this Agreement within 14 days of the date you receive
confirmation your application has been approved by Paynetics by contacting the Customer Relations Centre. You will
not be charged for cancelling within this period and the funds in your Account will be returned to you in accordance
with clause 18. You will not be entitled to a refund of any payments and associated fees made from your Account or
using the Card up to the date you notify Paynetics of the cancellation.
17.4. This Agreement can be terminated by you:
17.4.1. notifying Paynetics you do not accept changes to this Agreement in accordance with clause 16.3;
17.4.2. notifying Paynetics of the cancellation of this Agreement in accordance with clause 17.2;
17.4.3. providing Paynetics a written request for termination of this Agreement at any time.
17.5. This Agreement can be terminated by Paynetics:
17.5.1. providing you 2 months’ notice of termination of this Agreement;
17.5.2. immediately if:
17.5.2.1. you breach an important term or persistently breach the provisions of this
Agreement;
17.5.2.2. Paynetics reasonably believes that your Account, Card or any of its services is being
used for any fraudulent or illegal purposes or in an unauthorised manner or for
Prohibited Transactions;
17.5.2.3. Paynetics is required to so to comply with any law or regulation or a requirement by a
regulatory authority or a Card Organisation;
17.5.2.4. Paynetics reasonably believe that continuing to permit use of your Account or Card
may cause Paynetics to breach any applicable law or regulation, code or other duty
applicable to it or expose Paynetics to any adverse action, censure, fine or penalty
from any regulatory authority, law enforcement or other governmental agency or
Card Organisation;
17.5.2.5. you become bankrupt or die;
17.5.2.6. in other cases provided by law or in the Agreement.
17.6. If this Agreement is terminated for any reason, your right to use the Account and Cardwill be terminated, your Account
will be closed and Card will be deactivated. All fees and other amounts due to Paynetics under the Agreement, if any,
will become payable on termination. You can request the return of any remaining funds on your Account in accordance
with clause 18.
17.7. You will be responsible for all payments performed prior to termination of this Agreement, their resulting liabilities and
any other obligations relating to the use and servicing of the Account or Card prior to such termination.
14
17759041v.2
18. REDEMPTION
18.2. You can redeem all or part of the e-money held on your Account any time for the duration of this Agreement by
requesting Paynetics to refund it to you. After this Agreement is terminated, you can only request to redeem the
remaining e-money on your Account in full. You can request to redeem the e-money by contacting Customer Relations
Centre. You will need to provide Paynetics the details of an account [which must be an account in your name] to which
you would like the refund to be made and any other details we may require. Paynetics may require you to provide
satisfactory confirmation of your identity and address before the refund is made.
18.3. All redemptions will be paid in the currency of your Account in which the remaining e-money being redeemed is held,
at an exchange rate (if applicable) prevailing at the time of processing the redemption.
18.4. A redemption fee (see Tariff) will be charged to cover redemption costs on each redemption request if:
18.4.1. redemption is requested before this Agreement is terminated for any reason;
18.4.1.1. you terminate this Agreement before any agreed termination date; or
18.4.1.2. redemption is requested more than one year after the date this Agreement is
terminated.
18.5. The redemption fee (see Tariff) will not be charged for redemption that is requested:
18.5.1.1. at termination of this Agreement or up to one year after that date;
18.5.1.2. when you cancel this Agreement in accordance with clause 17.2.
18.6. Paynetics will not refund the remaining value of e-money on your Account if you make the request for redemption
more than 6 years after the date of termination of this Agreement.
19. COMPLAINTS
19.2. If you wish to complain about Paynetics services under this Agreement, you can do so by contacting Paynetics
Customer Relations Centre.
19.3. You can find more information on how we handle complaints on the Website. We will provide you with a copy of our
complaints procedure on your request or if we receive a complaint from you. In most cases, Paynetics will review your
complaint and provide a full response within 15 business days from the date the complaint is received. In exceptional
circumstances, where Paynetics is unable to respond to your complaint in full within that timeframe, Paynetics will
send you a holding response with reasons for the delay and the timeframe within which you will receive a full
response, which in any case will be within 35 business days from the date your complaint was received.
20. Where the payment services under this Agreement are provided in the UK, if Paynetics fails to provide a full response to
your complaint within the time limit referred to above or has failed to resolve your complaint to your satisfaction, you may
refer your complaints to the Financial Ombudsman Service (Exchange Tower, London E14 9SR, phone 0800 023 4567, email
complaint.inf[email protected] ). Details of the service offered by the Financial Ombudsman Service are
available at www.financial-ombudsman.org.uk.
20.2. Where the payment services under this Agreement are provided in the EEA, if Paynetics fails to provide a full response
to your complaint within the time limit referred to above or has failed to resolve your complaint to your satisfaction,
you may refer your complaints to the Payment Disputes Conciliation Committee with the Commission for Consumer
Protection (1000, Sofia, 1 Vrabcha Str, fl. 4, Bulgaria). Details of the service offered by the Payment Disputes
Conciliation Committee are available at www.kzp.bg and https://abanksb.bg/pkps/pkps-contacts-En.html.
21. MISCELLANEOUS
15
17759041v.2
21.2. Where the payment services under this Agreement are provided in the UK, this Agreement shall be governed by the
English law. Any disputes relating to this Agreement will be finally settled by English court.
21.3. Where the payment services under this Agreement are provided in the EEA, this Agreement shall be governed by the
Bulgarian law. Any disputes relating to this Agreement will be finally settled by Bulgarian court.
21.4. Paynetics may transfer or assign its rights and obligations under this Agreement to another company or individual at
any time. If the transfer means that another organisation will be providing the services under this Agreement to you
instead of Paynetics, Paynetics will give you notice of the transfer and the date when the transfer will take effect.
Unless specified otherwise in the notice, the terms of this Agreement will be binding on you and the transferee as if
the transferee was the original party to this Agreement from the date the transfer takes effect. This will not affect any
of your legal rights relating to this Agreement or the services provided under it.
21.5. You cannot transfer or assign any of your rights and obligations under this Agreement to another individual or
company without Paynetics’ prior written consent.
21.6. If a court or competent authority establishes that a certain provision in the Agreement (or any part of any provision) is
invalid, illegal or unenforceable, such provision (or part of it) shall be deemed to be non-existent to the extent
necessary, but the validity and applicability of all other provisions of the Agreement shall not be affected.
22. CUSTOMER RELATIONS CENTRE
22.2. You can contact Paynetics Customer Relations Centre using the contact details set out below. For monitoring purposes,
we may record any conversation with the Customer Relations Centre.
22.2.1. Contact us about our services (open from 9 a.m. to 4 p.m., CET, from Monday to Friday):
22.2.1.1. by phone: +65 6956 9405, Monday - Friday 8:30am - 6pm, SGT
22.2.1.2. by email: [email protected]om Monday Friday 9:00am - 4pm, CET
22.2.1.3. by writing at Frasers Tower, Level 17, 182 Cecil Street, Singapore, 069547.
22.2.2. Report lost, stolen or misappropriated Cards or other unauthorised access to your Account (available 24 hours
a day):
22.2.2.1. Via the app;
22.2.2.2. Via +44 20 3769 8510
16
17759041v.2
BUSINESS DEBIT CARD Agreement Corporate clients
Introduction
These terms and conditions (together with the Tariff and any other documents incorporated by reference, the Agreement”) set
out the terms and conditions that apply to your Account, Card and any other associated services provided to you (“Customer,
you, your”), in your capacity as a legal entity, in relation to your business operations, and the individuals designated by you
(“Cardholder/s”) by Paynetics AD (“Paynetics”, “we” “us”, “our”) under this Agreement.
This Agreement constitutes a legal contract between you and Paynetics. It contains important information that may affect your
rights, use of any of our services and your ability to recover your money. Please read all of the documents forming part of this
Agreement carefully and keep a copy or download a copy of them for your records and future reference.
You can request a copy of this Agreement at any time throughout its duration by contacting Customer Relations Centre. By
submitting your order for a Card to Paynetics and by clicking “I Accept” in the relevant box, you indicate that you have accepted
this Agreement.
You should read this Agreement alongside the Privacy Policy which you can view here
https://paynetics.digital/privacy-and-security-policy/. Our Privacy Policy (as it may be amended from time to time in accordance
with its terms), together with this Agreement, describes the basis upon which any personal data we collect about you, either
directly or from our authorised partners or that you provide to us or them, will be processed, handled and shared by us.
1. DEFINITIONS
In this Agreement:
Account means any e-money payment account opened and maintained for you by Paynetics under this Agreement.
App means either Mobile App and / or Web App as available.
ATM" means an automated teller machine that can be used for cash withdrawals using a Card, and sometimes for other
payment and non-payment transactions.
“Business Debit Card” or “Card” means any Paynetics debit Mastercard© card for corporate clients (business customers) issued
by Paynetics that is linked to your Account(s). The Card is a type of a payment instrument which allows you to access the
Account`s balance to make debit card payments. The Card may be physical or virtual.
“Card Organisation” means Mastercard International (‘MasterCard’), VISA Europe (‘VISA’) or any other organisation maintaining
a card payment system under which Card payments are processed.
Cardholder means an individual designated by you as a cardholder, who represents you or is your signatory, or is your
employee, and who is expressly approved by Paynetics.
“Faster Payments” means a payments system which allows sending and receiving payments in GBP in the UK between
participating payment service providers.
“Mastercard” means Mastercard International Incorporated or its successors.
“Mobile App” means the mobile application developed by the Technical Provider and published in the Apple AppStore and
Google PlayStore, which enables you to access your Account and/or Card.
“Paynetics”, “we”, “us”, our means:
(a) where payment services under this Agreement are provided in the UK - Paynetics AD, a company with its seat and registered
address at Ground Floor, 76A James Bourchier, Lozenets District, Sofia Municipality, Sofia, Bulgaria, entered in the Bulgarian
Commercial Register kept by the Registry Agency under UIC: 131574695 (“Paynetics AD”) or such other Paynetics entity
1
17759041v.2
authorised in the UK as notified to you. For the purposes of UK services, Paynetics AD is an electronic money institution deemed
authorised and regulated by the UK Financial Conduct Authority under the Temporary Permissions Regime (firm reference
number 900785) for the issuance of e-money and provision of payment services in the UK. Details of the Temporary Permissions
Regime, which allows EEA-based firms to operate in the UK for a limited period while seeking full authorisation, are available on
the Financial Conduct Authoritys website; or
(b) where payment services under this Agreement are provided in the EEA Paynetics AD. For the purposes of EEA services,
Paynetics AD is an electronic money institution holding a license for operating as an electronic money institution issued by the
Board of Directors of the Bulgarian National Bank by Decision 44 of 11 April 2016, and is entered in the register kept by the
Bulgarian National Bank, which is accessible on http://www.bnb.bg/RegistersAndServices/RSPIPublicRegisters/index.htm. The
Bulgarian National Bank supervises the activities of Paynetics AD .
“PIN” shall mean a unique four-digit personal identification number, which can be used to confirm Card payments.
Technical Provider means the operator that performs certain technical and operational functions in relation to our services,
including the operation of Platform which connects the customers with Paynetics.
“Prohibited Transaction means any of the transactions or activities as listed below or as may be subsequently made available
on the Website from time to time:
1. Any sales of ‘pyramid’ type, Ponzi schemes or similar marketing or matrix programs or other schemes for quick enrichment
or high-yield investment programs;
2. Sale, supply or purchase of illegal items or items promoting or facilitating illegal activities;
3. Sale, supply or purchase of counterfeit products or products infringing intellectual property rights;
4. Products or services for the processing or aggregation of payments by third parties;
5. Money laundering;
6. Terrorism financing or propaganda;
7. Pornography, escort services and selling and/ or advertising sexual services;
8. Using the Card or Account in a manner and/or for purposes that violated any applicable law and/or regulations of the Card
Organisation or SEPA;
“SEPA” means the Single Euro Payments Area scheme, which allows sending and receiving payments in EUR between
participating payment service providers.
Tariff means the fees and limits applicable to your Accounts, Card and any other services provided to you under this
Agreement. The Tariff, as amended from time to time, is available on the Website
Web App means the web application developed by the Technical Provider and run on a web server, which enables you to
access your Account and/or Card.
“Website” means the following website: https://resources.weavr.io/my-neo-group_corporates-programme-terms
2. ABOUT OUR SERVICES
2.1. Your Accounts are maintained by Paynetics and the Card is issued to you by Paynetics. The value stored on your Accounts is
electronic money, otherwise referred to as ‘e-money. Paynetics is not a bank and your Account is not a bank account. The
funds available in your Account are not a deposit. No interest will accrue on your Account balance. Your Card is a debit card
linked to your Account, it is not a credit or charge card.
2
17759041v.2
2.2. The Financial Services Compensation Scheme does not apply to funds held in your Accounts. Instead, Paynetics protects
your funds through a process known as ‘safeguarding, in line with its regulatory requirements. In this process, Paynetics
keeps your money separate from our own funds and places it in a safeguarding account with a bank or cover it by an
insurance policy or a comparable guarantee. Before we provide any of our services to you, you will have to successfully
complete our process for verifying your identity. The process may involve you providing us a valid passport / ID card of your
statutory representative/s and ultimate beneficial owner/s and a bank statement or other identification documents,
together with the presented identity document in real time, or any other procedure we may specify. We may use ID
verification agencies or other automated platforms to verify your identity. We or the Program Manager may require you to
provide additional information at any time for the duration of this Agreement.
2.3. This Agreement will only become effective once you receive a confirmation that Paynetics has approved your application.
Paynetics will not be obliged to provide any of the services under this Agreement before such confirmation is provided.
Paynetics may refuse to approve any application and/or enter into an agreement for its services for any reason.
2.4. The Account and Card are issued to you in your capacity as a legal entity. You may designate individuals, who may use them
the Cardholders. The Cardholders may use your Account and/or Card only personally and may not provide them for use to
anyone else. If a Cardholder provides access and/or any other means for use of the Account and Card to a third party, you
shall be fully liable for all transactions initiated by such third parties You must not use your Account or Card for or in relation
to (including sending or receiving proceeds from):
2.5. You and the Cardholders must not use your Account or Card for or in relation to (including sending or receiving proceeds
from):
2.5.1. any activities which do not comply with any applicable laws or regulations, including but not limited to laws
relating to money laundering, fraud, financial services or consumer protection; or
2.5.2. Prohibited Transaction under this Agreement.
2.6. You shall ensure the Cardholders’ compliance with this Agreement. You shall be liable to Paynetics for the Cardholders’
actions.
3. RECEIVING/SENDING PAYMENTS
3.1. When this Agreement becomes effective, Paynetics will set up and maintain:
3.1.1. an EUR Account with a dedicated IBAN and one or more Cards, which may be used for sending or receiving
payments via SEPA in EUR and for Card payments and cash withdrawals in EUR; and/or
3.1.2. a GBP Account with a dedicated IBAN, an account number with sort code and one or more Cards, which may be
used for sending or receiving payments via Faster Payments in GBP and for Card payments and cash
withdrawals in GBP.
3.2. Limits may apply to your Account and Card, such as limits on minimum load payments to your Account, the maximum
balance that can be held on your Account, the value of each Account and/or Card payments or an aggregate value or
number of payments in a particular time period. The applicable limits are as set out in the Tariff and may be changed by us
from time to time. To manage our risk, particularly with respect to money laundering, fraud or security concerns, we may
also apply internal controls, including limits, to certain types of transactions from time to time but for security purposes,
will not disclose them.
4. LOADING FUNDS TO YOUR ACCOUNT
4.1. The minimum load amount to top up your Account is indicated in the Tariff.
4.2. The balance of the Account should never exceed the limits set out in the Tariff.
4.3. Your Account can be loaded using the following methods:
3
17759041v.2
4.3.1. EUR Account can be loaded by receiving payments via SEPA;
4.3.2. GBP Account can be loaded by receiving payments via Faster Payments.
4.4. The received funds will be credited to your Account immediately after Paynetics receives the funds.
4.5. Paynetics may refuse to execute an incoming payment and your Account will not be credited if:
4.5.2. your Account or payment breaches any of the limits as set out in the Tariff;
4.5.3. your Account is inactive, blocked or terminated;
4.5.4. the sender has provided incorrect/invalid Account details for payment;
4.5.5. Paynetics reasonably believes the payment is fraudulent, illegal or unauthorised;
4.5.6. Paynetics reasonably believes the payment related to a Prohibited Transaction.
4.6. If an incoming payment is refused for any of the reasons set out above, the funds may be sent back to the sender without
prior notice to you.
4.7. Paynetics will charge you with a top up fee every time your Account is loaded as set out in the Tariff.
5. MAKING PAYMENTS FROM YOUR ACCOUNT
5.1. You/the Cardholders must make sure that your Account has sufficient funds available to cover the amount of a given
payment and all applicable fees. Paynetics may refuse to perform any given payment if your Account does not have
sufficient balance to cover the amount of the payment and all applicable fees.
5.2. Paynetics will execute your/the Cardholder’s payment instructions for payments from your Account on the same day it
receives them (or the future day agreed if it is in the future). The time of receipt of your/the Cardholders payment
instruction is when Paynetics receives it (which will typically be on the same day the payment is instructed) or, if the
payment instruction specifies the payment is to take place on a future day, then the payment instruction will be treated as
received on that day. You/the Cardholder cannot cancel a payment after you/the Cardholder have authorised it and
Paynetics has received your/the Cardholders payment instruction for it, except that you/the Cardholder can cancel a future
payment, such as a recurring Card payment if you/the Cardholder notify Paynetics of cancellation no later than the end of
the business day before the payment is due to be made via the App. Cancelling a future dated payment such as a recurring
Card payment with us will not cancel the agreement with the organisation you are paying. You/the Cardholder should tell
the organisation collecting the payment about the changes to your/the Cardholders instructions.
5.3. After receiving your/the Cardholders payment instruction for payment from your Account (including Card payments),
Paynetics will credit the recipient’s account within the timescales set out below.
Type of payment
Delivery to the recipients account
Payments in EUR or GBP to an account in the UK or the
EEA (including where there has been a currency
conversion between EUR and GBP)
No later than the end of the business day after the
payment instruction is received
Payments in any other currency or to an account outside
the UK or the EEA
Varies, depending on the currency or country the payment
is sent to
5.4. Paynetics will deduct the value of payments together with all applicable fees from the balance on the relevant currency
Account. Payments from your Account by way of credit transfers in EUR or GBP will be deducted from your EUR or GBP
Account respectively. Card payments in EUR or GBP will also be deducted from your respective currency Account. Card
payments in any other currency will always be deducted from your Account at then prevailing currency conversion rates. If
there is insufficient balance on the relevant GBP or EUR Account to complete the payment, including all applicable fees,
funds will be automatically transferred from your Account in the other currency to your relevant currency Account at then
prevailing currency conversion rates. If there is insufficient balance on both your EUR and GBP Accounts to complete the
4
17759041v.2
payment, including all applicable fees, the payment will be refused. See clause 11 for more detail on the applicable currency
conversion rates and fees.
5.5. You agree you and the Cardholders will not make any attempts to interrupt or impair the functionality of our information
system, including but not limited to, not to spread files containing viruses, damaged files or other similar software which
may be used for accessing, modifying, deleting or damaging data files.
6. ACCESS TO YOUR ACCOUNTS BY THIRD PARTY PROVIDERS
6.1. You may choose to allow (and provided you have given them your explicit consent):
6.1.1. providers of account information service (i.e. an online service which accesses one or more payment accounts
to provide a consolidated view of such accounts) to access information on your Account; and/or
6.1.2. providers of payment initiation service (i.e. an online service which allows a third party to initiate payments on
behalf of the account holder from their account and at their request) to initiate payments (other than Card
payments) from your GBP and EUR Accounts.
6.2. Only those providers of account information or payment initiation services that are authorised with the Financial Conduct
Authority or another European regulator to provide the relevant service in the UK or an EU member state, as applicable,
can be given access to your Account. The Financial Conduct Authority’s register (available at https://register.fca.org.uk/ ) will
tell you whether a provider is authorised in the UK, and we recommend you check it before using their services.
6.3. We will treat any instruction from such providers of account information or payment initiation services as if it was from you.
Some providers may use your Account security details to provide their service. You should always consider the implications
of sharing your security information.
6.4. We can deny providers of account information or payment initiation services access to your Account if we are concerned
about unauthorised or fraudulent access. We will notify you of the denial of access and the reasons for it beforehand if
possible or otherwise immediately afterwards (unless doing so would compromise our security measures or would be
unlawful). The access to your Account may be restored once the reasons for denying the access no longer justify such
denial.
7. GIVING INSTRUCTIONS FOR PAYMENTS FROM YOUR ACCOUNTS
7.1. For a payment from your Account (including transfers to your other Accounts) to be properly executed, you/the Cardholder
must provide us the following information when you/the Cardholder instruct us to make the payment (in addition to any
other information we may ask for):
7.1.1. for payments from your GBP Account to a UK account via Faster Payments: the recipient’s name, account
number, the payment amount and sort code and a payment reference;
7.1.2. for payments from your EUR Account to an EEA account via SEPA: the recipient’s (beneficiary) name, IBAN, the
payment amount, its currency and reason for payment (this information meant for the beneficiary), additional
clarifications;
7.1.3. for payments from your EUR Account to an account outside the EEA via SEPA (to countries that participate in
SEPA): in addition to information set out at 7.1.2, you/the Cardholder will also need to provide the senders
(originator) address and may also be required to provide the recipient’s (beneficiary) bank’s BIC;
7.2. For any payments above EUR 15,000 or its equivalent in another currency: the sender (originator) and / or recipient
(beneficiary) could also be required to provide a declaration to prove the origin of funds; If you/the Cardholder provide us
with incorrect or incomplete information or refuse to provide information, we may refuse to execute the payment, the
funds could be lost and irrecoverable or there could be a delay in the recipient receiving the payment.
7.3. You /the Cardholder give us instructions and consent to a payment from your Account in one of the following ways:
5
17759041v.2
7.3.1. using the App;
7.3.2. giving us instructions via a third party (such as payment initiation service provider);
7.3.3. using Cards (see clause 10 below on how you instruct us to make payments using a Card);
You/the Cardholder may be required to provide security details and/or use a particular authentication method
depending on the method you use. We will tell you which authentication can be used or if they are unable for
any particular types of service. Paynetics reserves the right to change or introduce new authentication
methods at any time, including for reasons relating to changes in the law, technical characteristics of the
services or security.
7.4. Paynetics may refuse to carry out any instructed payment from your Account if it does not meet the requirements of this
Agreement, including, but not limited to any of the following circumstances:
7.4.1. Paynetics reasonably suspects that the payment is unauthorised or involved in fraud or illegal activity;
7.4.2. your/the Cardholder’s instruction is unclear, incorrect or incomplete;
7.4.3. Paynetics reasonably believes that there has been a violation of this Agreement;
7.4.4. you/the Cardholder have failed to use the authentication method and/or provide security information
required;
7.4.5. there are insufficient funds in the Account to cover the payment and any applicable fees;
7.4.6. the payment violates any applicable limits;
7.4.7. carrying out your/the Cardholders instruction might cause us to break the law, order of a regulatory body,
code, rule of Card Organisation or other duty applicable to Paynetics;
7.4.8. due to a technical impossibility to carry out the payment;
7.4.9. Paynetics reasonably believes payment is related to a Prohibited Transaction.
7.5. If we refuse to execute the payment, we will notify you as soon as possible unless it would not be unlawful for us to do so. If
possible, we will provide the reasons for refusal to execute the payment and where those reasons relate to factual matters,
the procedure for rectifying any factual errors that led to such refusal.
7.6. The execution of any payment to or from your Account (including Card payments) may be delayed or refused due to the
performance of Paynetics’ security or legal compliance checks, including if Paynetics suspects that the payment is involved
in fraudulent, illegal or unacceptable activities or constitutes an unauthorised payment.
8. DESCRIPTION OF THE CARD
8.1. Your Card is issued to you by Paynetics and is linked to your Account in EUR and/or GBP, as applicable, maintained by
Paynetics. Your Card can be used in your country of establishment or abroad.
8.2. The Card is issued under the Mastercard brand pursuant to license granted by Mastercard International.
8.3. Unless specified otherwise in this Agreement, your Card can be used to pay merchants for goods or services at (whether
in-store, online or over the phone) and for cash withdrawals at ATMs. If you have been issued with a virtual Card, it can only
be used to pay merchants online. Your Card can be used at all card acceptance terminal devices bearing the Mastercard
logo which maintain the necessary functions.
8.4. Card payments will be executed immediately after Paynetics receives the payment request.
6
17759041v.2
8.5. The value of all Card payments, including all applicable fees, will be deducted from your relevant Account balance, see
clause 5.4.
8.6. You will be responsible for all goods or services purchased with the Card. Any dispute with a merchant about a product or
service purchased with the Card will be considered a dispute between you and the merchant, and should be addressed
directly to that merchant. Paynetics does not accept any responsibility or liability for the quality, safety, legality or any other
aspect relating to and does not provide any warranties regarding such goods or services purchased with the Card.
8.7. Paynetics will not be liable if a merchant refuses to accept a Card or if Paynetics has refused to executed a payment in
accordance with this Agreement.
8.8. The Card is property of Paynetics as a card issuer and cannot be transferred and/or made available to anyone else.
9. CARD ISSUANCE, LOADING, ACTIVATION AND REPLACEMENT
9.1. Each Card has a validity period within which you/the Cardholder may use the Card. If your Card is physical, it will expire on
the last day of the month/year indicated on its front. If your Card is virtual, it will expire on the last day of the month/year
indicated on the App or on the expiry date sent to you by e-mail . All Card payments initiated after the expiration or
cancellation of the Card will not be authorised or executed.
9.2. Paynetics will issue the Card within 10 business days from the date your/the Cardholders application is accepted and, if the
Card is not virtual, will deliver it to your/the Cardholder personally. If your Card is virtual, the Card will be made available to
you/the Cardholder via the App immediately after your/the Cardholders application is approved by Paynetics.
9.3. The physical Card will be personally delivered to you/the Cardholder and the Cardholder may be required to produce an ID
document to collect it. The Cardholder must sign on the signature strip on the reverse side of the physical Card immediately
after receiving it.
9.4. You/the Cardholder will be provided with a PIN to use with your Card. You/the Cardholder can change your PIN at an ATM.
You/the Cardholder should memorise your PIN and then destroy the media on which it is recorded. You and the
Cardholders have important obligations to keep all security details such as PIN safe (see clause 14 below).
9.5. You may request Paynetics to issue a new Card in the following cases:
9.5.1. in case of destruction or damage to the Card;
9.5.2. in case of loss, theft or other misappropriation of the Card,
9.5.3. in case of a forgotten PIN, and
9.5.4. upon expiry of your Card’s validity period. If your Card expires, it will only be automatically replaced if your Card was
used within the last two months before its expiry date.
9.6. If your Card is replaced because it was lost or damaged, or in case of a forgotten PIN or upon expiry of your Card’s validity
period, you will be charged a Replacement Fee (see Tariff) which will be deducted from your Account. If your Card has been
reported stolen or misappropriated you will be charged a fee that is directly related to the cost of replacement (see Tariff). If
your Card has been reported lost, stolen or misappropriated but later is found, then you should immediately inform
Paynetics about it and destroy the Card.
9.7. When you/the Cardholder receive the Card it will be inactive. You/the Cardholder have to activate the Card before using it.
Otherwise, any Card payments attempted by you/the Cardholder will be rejected. The Card can be activated online by
following the instructions for activation provided by us.
10. GIVING INSTRUCTIONS FOR CARD PAYMENTS
10.1. You /the Cardholder give us an instruction and consent to a payment made using your Card using any one of the
following methods:
7
17759041v.2
10.1.1. in case of cash withdrawal from an ATM: by entering a PIN;
10.1.2. in case of payment for goods or services in-store: by entering a PIN and/or signature on the receipt or by
tapping/waving the Card (or a device where it is held) over a card reader for contactless payments;
10.1.3. in case of online payments for goods or services online or via the phone: by providing your Card details and a
one-time payment code or other security information or credentials, when requested.
10.2. Your /the Cardholders consent for a Card payment may cover a single payment or a series of recurring payments on a
Card (such as where you/the Cardholder give your Card details to a merchant to be used for Card payments in the
future) for a set or variable amount.
10.3. Merchants in certain business sectors (e.g. car rental companies, hotels and other service providers) estimate the
amount of the final Card payment to them and require to “pre-authorise” or withhold the estimated amount on the
Card. Sometimes, that withheld amount may exceed the final amount spent. In such cases, the initially withheld funds
will not be available to you/the Cardholder for up to 15 days until the final Card payment request is received by us or
released by the merchant. Paynetics may release such amounts only with the merchant’s consent.
10.4. You and the Cardholders are responsible to provide a correct and accurate instructions for execution of a payment. If
the instructions provided by you/the Cardholders are incorrect, inaccurate or incomplete, Paynetics will not be liable
for errors or inaccuracies in the transaction. If a payment is carried out in accordance with the instructions provided by
you/the Cardholders, it will be deemed to have been correctly executed.
11. FEES AND EXCHANGE RATES
11.1. Fees that apply to your Account, Card and associated services and/or transactions are as set out in the Tariff. All fees
will be determined in the currency of the relevant Card and/or Account to which they relate and will be deducted from
the relevant Account.
11.2. Paynetics reserves the right to change the applicable fees in accordance with this Agreement (see further clause 16).
Changes in the reference exchange rate will apply immediately without prior notice.
11.3. If a payment received or sent into/from your Account is in a currency other than the currency of the Account (including
transfer between your different currency Accounts), then the payment amount will be converted into the currency of
the destination account using an exchange rate made up of a reference rate (available at the App) plus the currency
conversion mark-up fee as set out in the Tariff. The exchange rate will be determined at the time (with respect to
payments into Account) the payment is received or (with respect to payments from Account) the payment instruction
is received by Paynetics.
11.4. If a payments using a Card is in a currency other than the currency of the Account from which it is taken, then the
amount deducted will be the amount of the Card payment converted to the currency of the Account using the
reference exchange rate applied by MasterCard® (available at
https://www.mastercard.co.uk/en-gb/personal/get-support/convert-currency.html) plus the currency conversion
mark-up fee set out in the Tariff for Card payments. The exchange rate shall be determined on the date of the Card
payment is processed. The exchange rate is not set by Paynetics and varies throughout the day meaning it may change
between the date the Card payment is made and the date it is processed. Paynetics provides information on the total
currency conversion charges applicable with respect to Card payments, expressed as a percentage mark-up over the
latest available euro foreign exchange reference rates issued by the European Central Bank on the Website .
12. NEGATIVE BALANCE
12.1. If any action results in a negative balance in your Account, you must reimburse Paynetics the amount of the negative
balance immediately upon request. Paynetics may charge the amount of the negative balance against the funds on any
other Accounts held by you, including any subsequently loaded funds. Paynetics may suspend Accounts and Card until
it is reimbursed for the negative balance in full and may take legal action against you to recover such amount.
13. COMMUNICATION PROCEDURE
8
17759041v.2
13.1. The Agreement is executed in English and all communications between you and us will be in English, unless expressly
agreed otherwise in this Agreement.
13.2. Your representatives, persons authorised by you and the Cardholders may receive information about the payments
made with the Card/Account electronically.
13.3. We can communicate with you (including to provide any information or notifications in relation to this Agreement)
using any of the following methods:
13.3.1. via the App;
13.3.2. by email;
13.3.3. by phone (including by sending you an SMS);
13.3.4. by writing to your home address.
We will tell you if any of these communication methods are not available. We will also tell you if you need any technical
requirements or software to communicate with us.
13.4. We will use the contact information you have most recently given us to communicate with you. If any of your contact
details change, you must inform Paynetics about it as soon as possible by updating your details via the App. All
notifications, invitations or other notices sent to your last email address last known to Paynetics will be deemed to
have been delivered.
13.5. You can contact Paynetics via Customer Relations Centre (see contact details at clause 21).
13.6. Paynetics will provide information about your Account and Card transactions and fees by means of electronic
statements which will be accessible on the App. Statements shall not be provided on paper. Information about your
Account and Card shall be updated, if there was any activity with the Account and/or the Card, including information
on all collected fees. From the moment of accessing the statement on the App you will be considered to be informed
about the relevant transaction. You will be charged for obtaining additional information or for obtaining it in a manner
different from the one described herein.
14. SECURITY MEASURES
14.1. You and the Cardholders must use your Card and Account in accordance with the terms and conditions set out in this
Agreement. You and the Cardholders have important obligations to do everything you and the Cardholders reasonably
can to keep your Account and Card safe and to notify Paynetics of any loss, theft, misappropriation or unauthorised
use of the Card or Account immediately after becoming aware of it as further described below.
Your and the Cardholders’ obligations to keep your Account and Card safe
14.2. You/the Cardholders will be provided with or will be able to set up certain security details (such as your Card PIN and
any password, passcode or other login details which can be used to access or make payments with your Account or
Card via the App). You/the Cardholders must:
14.2.1. take all reasonable measures to keep your Account, Card and security details safe;
14.2.2. not write down any of your security details (such as PIN or password) unless it is done in a way to make it
difficult for anyone else to recognise them;
14.2.3. not record security details such as PIN on the Card or keep such information together with the Card;
14.2.4. not to disclose to and/or allow anyone else (other than authorised providers of account information services or
payment initiation services) to use in any manner whatsoever your security details such as user identifiers,
passwords or PINs;
9
17759041v.2
14.2.5. keep your Card and any personal devices (mobile phones, computers, tablets) that can be used to access your
Account, Cards or security details secure and not let anyone else use them to make payments;
14.2.6. not choose security details such as PIN or password to access your Card or Account that is easy for someone to
guess such as letters or digits that:
14.2.6.1. are easily associated with you, for example your telephone number or date of birth;
14.2.6.2. are part of the data imprinted on the Card;
14.2.6.3. consist of the same digits (1111) or the sequence of running digits (1234); or
14.2.6.4. are identical to previously selected PIN/password.
14.2.7. use up-to-date virus, malware, and spyware software and a firewall on any devices used to access your Account
or cards to reduce the risk of security breaches.
Your obligation to notify us
14.3. If your Card has been withheld by an ATM, you must immediately notify Paynetics. If Paynetics is not able to return the
Card to you, Paynetics will issue a new Card to replace it.
14.4. You must immediately notify Paynetics Customer Relations Centre (using contact details at clause 21) if:
14.4.1. your Card is lost, stolen or misappropriated; or
14.4.2. you believe there has been unauthorised use of your Card or Account or anyone else may be able to use or
access your Account, Card or security details to access them.
Paynetics will make all reasonable efforts to stop the use of Account and/or Card by blocking the Account and/or Card
payments after receiving a notification from you.
14.5. Paynetics may restrict, block or deactivate the Card or Account if:
14.5.1. Paynetics is concerned about the security of the Card or Account or the security details relating to them;
14.5.2. Paynetics becomes aware or suspects that the Account, Card or security details relating to them are being used
in an unauthorised, unlawful or fraudulent manner;
14.5.3. Paynetics reasonably believes it needs to do so to comply with the law or court order in any applicable
jurisdiction, the instructions provided by a Card Organisation or any other rule or duty applicable to Paynetics;
14.5.4. this Agreement is terminated for any reason;
14.5.5. you request us to do so;
14.5.6. you have breached any term of this Agreement in a material way.
14.6. We will, if possible, notify you before restricting, blocking or deactivating your Account or Card that we will do so and
the reasons for it. If we are unable to notify you beforehand, we will notify you immediately afterwards. We will not
notify you if doing so would compromise our security measures or would be unlawful.
14.7. Your Card and/ or Account will be unblocked or re-activated (or replaced) as soon as possible after the reasons for
blocking cease to exist.
Communicating with you about fraud or security threats
10
17759041v.2
14.8. We may need to contact you urgently in the event of suspected or actual fraud or security threats to your Account,
Card and/or security details. To do so, we may use an SMS, telephone, e-mail or another secure procedure. When we
contact you, we may also give you information on how you can minimise any risk to your Account, Card or security
details depending on the nature of the security threat. But will never ask you to give your full security details (such as
PIN, password or passcode) or ask you to transfer money to a new account for security reasons.
15. LIABILITY & REFUNDS
15.1. You must notify Paynetics in writing of any unauthorised or incorrectly executed payments on your Card or Account
without undue delay after becoming aware of such unauthorised or incorrectly executed payment and in any case no
later than two months from the date the payment was debited to your Account/Card. You can notify us of such
unauthorised or incorrectly executed payments by contacting the Customer Relations Centre (see clause 21 for
details). You shall be considered to be informed of an unauthorised or incorrectly executed payment as from the
moment of accessing the relevant statement on the App. Paynetics shall not be held liable for any unauthorised or
incorrectly executed payment transactions under this Article 15 where Paynetics has not received a notice within two
months from the date when your Account/Card was debited.
15.2. If you notify us of an unauthorised or incorrectly executed payment in accordance with clause 15.1, you may be
entitled to receive a refund of the funds as detailed below. Paynetics will verify the authenticity of the payment, its
proper recording and reporting, and whether the transaction has been affected by a technical malfunction or other
defect. Since you are not a user, you agree that Articles 78 and 80 of the Bulgarian Payment Services and Payment
Systems Act (or the equivalent provisions of the UK law, if applicable) shall not apply to the relations with Paynetics
under the Agreement.
15.3. In the event that Paynetics establishes an unauthorised transaction and where there are no reasonable grounds for
suspecting that you/the Cardholder acted fraudulently, Paynetics shall refund to you the value of the unauthorised
transaction within the statutory timelines. If necessary, Paynetics shall restore your Account/Card to the status it would
be if the unauthorised transaction was not effected.
15.4. In you are entitled to a refund for an incorrectly executed or unauthorised payment, we will refund you as soon as
possible upon receipt of your claim or any additional information we may request in order to investigate your right to a
refund. However, if after we refund you, our investigation leads us to reasonably that you were not entitled to the
refund, we will have the right deduct the amount of the refund from any funds on Accounts you hold with us and
reserve the right to recover the value of the refunded payment by any other legal means.
15.5. In the event that Paynetics establishes an unauthorised transaction and where there are no reasonable grounds for
suspecting that you/the Cardholder acted fraudulently, Paynetics shall refund to you the value of the unauthorised
transaction within the statutory timelines. If necessary, Paynetics shall restore your Account/Card to the status it would
be if the unauthorised transaction was not effected.
15.6. The provision of Article 15.3 hereof shall not apply and you shall bear all losses, irrespective of their amount, relating
to unauthorised transactions if you/the Cardholder have caused them by fraud or failure to perform one or more of
the obligations under the Agreement.
15.7. You shall pay a fee in accordance with the Tariff in the cases where it appears that their notification under Article 15.1
hereof is unjustified.
Unauthorised payments from your Account or Card
15.8. You will not be entitled to a refund and you will bear all losses, irrespective of their amount, relating to an
unauthorised payment if:
15.8.1. the payment was authorised by you/the Cardholder;
15.8.2. you have acted fraudulently;
11
17759041v.2
15.8.3. you have failed to comply with one or more of the obligations under this Agreement (for example, with regards
to keeping your Account and Card safe or to notify us of any unauthorised payments).
Non-executed or Incorrectly executed payments from your Account or Card
15.9. If Paynetics fails to execute or incorrectly executes a payment from your Account or made using a Card, Paynetics will
promptly reimburse the amount of the payment (including any fees to restore the Account to the position it would
have been at if the defective payment was not made), unless Paynetics can show that the recipients payment service
provider has received the payment (in which case they will be liable). In this case, on your request, Paynetics will make
reasonable efforts to trace the payment and inform you about the outcome.
15.10. Paynetics will not be liable for any payment executed in accordance with the payment instructions given by you. If the
payment instruction you have given us was incorrect or incomplete (for example, you have made a mistake in giving us
the recipient’s account details), Paynetics will make reasonable efforts to recover the payment amount. Paynetics may
charge you a fee for any such recovery as indicated in the Tariff. If Paynetics is not able to recover the payment
amount, Paynetics will, on your written request, provide you with the relevant information about the payment.
Late or incorrectly executed payments to your Account
15.11. If a payment is received in your Account incorrectly (for example, by mistake), Paynetics may, where it considers
reasonable to do so, hold the payment and return it to the sender. In any case, Paynetics is obliged to provide certain
information to the senders payment service provider about you and the payment to enable them to recover the
funds.
Payments initiated by payee
15.12. If you/the Cardholder authorise a payment initiated by or through the payee without knowing the final amount of the
payment (for example, a Card payment initiated by the merchant when renting a car or booking a hotel room), you
have the right to request Paynetics for a refund of such payment provided that all of the following conditions are met:
15.12.1. you have asked for a refund within 8 weeks from the date on which your Paynetics Account was debited;
15.12.2. at the time of authorisation to execute the payment, its exact amount was not specified; and
15.12.3. the amount of the payment exceeded the amount you could have reasonably expected taking into account
your previous spending patterns, the terms of this Agreement and the case-specific circumstances. If the
amount of the payment increased because of the currency exchange when the reference exchange rate agreed
with Paynetics has been applied, it will not be a valid reason.
At the request of Paynetics, you must provide information to show the conditions above have been met.
15.13. Within 10 business days of receiving your request for a refund, or, where applicable, of receiving the further
information Paynetics requested, Paynetics will refund the full amount of the payment or inform you of the refusal to
refund it, together with the grounds for refusal and the authorities to which you can complain if you do not accept
those grounds. The refund will include the entire amount of the payment which will be dated back to the date on
which your Account was debited.
15.14. You will not be entitled to a refund of any payment initiated by or through payee when:
15.14.1. you have given your consent to perform the payment directly to Paynetics; and
15.14.2. where applicable, Paynetics or the payee has informed you about the upcoming payment at least 4 weeks
before it was due to be made.
General liability
12
17759041v.2
15.15. Paynetics will not be liable to you for any damages or losses arising from or relating to:
15.15.1. your/the Cardholders’ failure to use the Card or Account in accordance with this Agreement;
15.15.2. any payments executed in accordance with the information or instructions provided by you which were
incorrect, inaccurate or incomplete;
15.15.3. any unusual or unforeseeable circumstances beyond the control of Paynetics, the consequences of which could
not be avoided despite Paynetics’ best efforts;
15.15.4. refusal of a merchant, ATM or any other person to accept the Card or any other Account payment;
15.15.5. malfunction of a mobile device or other equipment, software or services required for the successful technical
performance of an operation which is beyond the control of Paynetics;
15.15.6. compliance with the applicable legal or regulatory requirements or any rules or guidelines provided by the
Card Organisation;
15.15.7. you/the Cardholders acting fraudulently or with gross negligence;
15.15.8. loss of revenue, goodwill, lost benefits or expected savings;
15.15.9. any loss or damage which is not a direct result nor a direct consequence of a breach of this Agreement by
Paynetics; or
15.15.10. any loss or damage caused by a virus, Denial of Service attack dissemination or other technologically harmful
material that may infect a computer or other device or equipment, software programs, data or other
proprietary material in connection to the Card, Account and this Agreement;
15.15.11. the quality, safety, legality or any other aspect of goods and/or services purchased using the Card or Account or
any possible disputes arising between you and the provider of such goods/services;
15.15.12. Paynetics refusing to accept or execute any payment or restricting, blocking or deactivating your Account
and/or Card in accordance with this Agreement;
15.15.13. loss or damage beyond Paynetics’ responsibility by law.
15.16. None of the terms of this Agreement will limit or exclude Paynetics’ liability for fraud, gross negligence or any other
liability which cannot be legally excluded or limited by law.
15.17. You and the Cardholders are responsible for the use of the Card and Account in accordance with this Agreement. You
will be liable to Paynetics for all losses and damages caused by their improper and/or non-compliant use that does not
comply with this Agreement.
16. CHANGES TO THIS AGREEMENT
16.1. Paynetics may make changes to this Agreement, including the fees set out in the Tariff, as set out further below for
reasons which may include (but are not limited to):
16.1.1. changes to the products or services or introducing new products or services under this Agreement;
16.1.2. withdrawal of a particular part of our products or services;
16.1.3. changes in market conditions or operating costs that affect Paynetics;
16.1.4. changes in technology, our systems and/or payment methods;
13
17759041v.2
16.1.5. making this Agreement clearer or more favourable to you; or
16.1.6. changes in relevant laws or regulations, or codes or rules that apply to Paynetics.
16.2. Paynetics may notify you about any changes to this Agreement, including the Tariff, and the date on which such
changes shall take effect, by posting on the Website, App and/or via email. Changes shall have an immediate effect.
16.3. If you do not approve of the changes to this Agreement, you have the right to terminate this Agreement. Paynetics will
treat you as having accepted the changes unless you inform Paynetics that you do not approve these changes within
14 days after their posting on the Website/App/receipt via email. In case you have informed Paynetics that you do not
accept the changes, this Agreement shall be terminated.
16.4. Paynetics shall not notify you about any modifications associated to extending the scope of the provided services,
modifications that are more favourable to you, or reproductive modifications in the regulatory acts.
17. TERM OF THE AGREEMENT. CANCELLATION. TERMINATION. VALIDITY PERIOD OF THE CARD
17.1. This Agreement will become effective when your application is approved by Paynetics. This Agreement will remain
valid until it is terminated in accordance with its terms.
17.2. This Agreement can be terminated by you:
17.2.1. notifying Paynetics you do not accept changes to this Agreement in accordance with clause 16.3;
17.2.2. providing Paynetics a written request for termination of this Agreement at any time.
17.3. This Agreement can be terminated by Paynetics:
17.3.1. providing you 1 month notice of termination of this Agreement;
17.3.2. immediately if:
17.3.2.1. you/the Cardholders breach an important term or persistently breach the provisions of this
Agreement;
17.3.2.2. Paynetics reasonably believes that your Account, Card or any of its services is being used for any
fraudulent or illegal purposes or in an unauthorised manner or for Prohibited Transactions;
17.3.2.3. Paynetics is required to do so to comply with any law or regulation or a requirement by a
regulatory authority or a Card Organisation;
17.3.2.4. Paynetics reasonably believes that continuing to permit use of your Account or Card may cause
Paynetics to breach any applicable law or regulation, code or other duty applicable to it or expose
Paynetics to any adverse action, censure, fine or penalty from any regulatory authority, law
enforcement or other governmental agency or Card Organisation;
17.3.2.5. you become bankrupt, insolvent or are subject to an event or circumstance which is analogous or
with a similar legal effect;
17.3.2.6. in other cases provided by law or in the Agreement.
17.4. If this Agreement is terminated for any reason, your and the Cardholders’ right to use the Account and Card will be
terminated, your Account will be closed and Card will be deactivated. All fees and other amounts due to Paynetics
under the Agreement, if any, will become payable on termination. You can request the return of any remaining funds
on your Account in accordance with clause 18.
14
17759041v.2
17.5. You will be responsible for all payments performed prior to termination of this Agreement, their resulting liabilities and
any other obligations relating to the use and servicing of the Account or Card prior to such termination.
18. REDEMPTION
18.1. You can redeem all or part of the e-money held on your Account any time for the duration of this Agreement by
requesting Paynetics to refund it to you. After this Agreement is terminated, you can only request to redeem the
remaining e-money on your Account in full. You can request to redeem the e-money by contacting Customer Relations
Centre. You will need to provide Paynetics the details of an account [which must be an account in your name] to which
you would like the refund to be made and any other details we may require. Paynetics may require you to provide
satisfactory confirmation of your identity and address before the refund is made.
18.2. All redemptions will be paid in the currency of your Account in which the remaining e-money being redeemed is held,
at an exchange rate prevailing at the time of processing the redemption.
18.3. A redemption fee (see Tariff) will be charged to cover redemption costs on each redemption request as per the Tariff.
18.4. Paynetics will not refund the remaining value of e-money on your Account if you make the request for redemption
more than 6 years after the date of termination of this Agreement.
19. COMPLAINTS
19.1. If you wish to complain about Paynetics services under this Agreement, you can do so by contacting Paynetics
Customer Relations Centre.
19.2. You can find more information on how we handle complaints on the Website. We will provide you with a copy of our
complaints procedure on your request or if we receive a complaint from you. In most cases, Paynetics will review your
complaint and provide a full response within 15 business days from the date the complaint is received. In exceptional
circumstances, where Paynetics is unable to respond to your complaint in full within that timeframe, Paynetics will
send you a holding response with reasons for the delay and the timeframe within which you will receive a full
response, which in any case will be within 35 business days from the date your complaint was received.
19.3 Where the payment services under this Agreement are provided in the UK, if Paynetics fails to provide a full response
to your complaint within the time limit referred to above or has failed to resolve your complaint to your satisfaction,
you may refer your complaints to the Financial Ombudsman Service (Exchange Tower, London E14 9SR, phone 0800
023 4567, email complaint.inf[email protected] ). Details of the service offered by the Financial
Ombudsman Service are available at www.financial-ombudsman.org.uk.
19.4. Where the payment services under this Agreement are provided in the EEA, if Paynetics fails to provide a full response
to your complaint within the time limit referred to above or has failed to resolve your complaint to your satisfaction,
you may refer your complaints to the Payment Disputes Conciliation Committee with the Commission for Consumer
Protection (1000, Sofia, 1 Vrabcha Str, fl. 4, Bulgaria). Details of the service offered by the Payment Disputes
Conciliation Committee are available at www.kzp.bg and https://abanksb.bg/pkps/pkps-contacts-En.html.
20. MISCELLANEOUS
20.1. Where the payment services under this Agreement are provided in the UK, this Agreement shall be governed by the
English law. Any disputes relating to this Agreement will be finally settled by English court.
20.2. Where the payment services under this Agreement are provided in the EEA, this Agreement shall be governed by the
Bulgarian law. Any disputes relating to this Agreement will be finally settled by Bulgarian court.
20.3. Pursuant to Article 46, Paragraph 5 of the Bulgarian Law on Payment Services and Payment Systems (LPSPS), the
Parties agree that Articles 47-66 of the LPSPS (or any equivalent provisions under UK law, if applicable) shall not apply
to their relations. All modifications to the Agreement and the Agreement and the Tariff shall be made as provided in
Article 16 hereof. Pursuant to Article 67, Paragraph 4 of the LPSPS, the Parties agree that Article 68, Paragraph
1, Article70, Paragraph 4 and 5, the term under Article 77, Paragraph 1, Article 78, Article 80, Article 82, Paragraph 2
15
17759041v.2
and 3, Article85, Article 91, Article 92 and Article 93, Paragraph 1 of the LPSPS (or any equivalent provisions under UK
law, if applicable) shall not apply to their relations but only the relevant provisions of the Agreement and the
Agreement in which they are incorporated by reference.
20.4. Paynetics may transfer or assign its rights and obligations under this Agreement to another company or individual at
any time. If the transfer means that another organisation will be providing the services under this Agreement to you
instead of Paynetics, Paynetics will give you notice of the transfer and the date when the transfer will take effect.
Unless specified otherwise in the notice, the terms of this Agreement will be binding on you and the transferee as if
the transferee was the original party to this Agreement from the date the transfer takes effect. This will not affect any
of your legal rights relating to this Agreement or the services provided under it.
20.5. You cannot transfer or assign any of your rights and obligations under this Agreement to another individual or
company without Paynetics’ prior written consent.
20.6. If a court or competent authority establishes that a certain provision in the Agreement (or any part of any provision) is
invalid, illegal or unenforceable, such provision (or part of it) shall be deemed to be non-existent to the extent
necessary, but the validity and applicability of all other provisions of the Agreement shall not be affected.
21. CUSTOMER RELATIONS CENTRE
21.1. You can contact Paynetics Customer Relations Centre using the contact details set out below. For monitoring purposes,
we may record any conversation with the Customer Relations Centre.
21.1.1. Contact us about our services (open from 9 a.m. to 6 p.m., EET, from Monday to Friday):
21.1.1.1. by phone: +65 6956 9405, Monday - Friday 8:30am - 6pm, SGT
21.1.1.2. by email: by email: [email protected] Monday Friday 9:00am - 4pm, CET
21.1.1.3. by writing at by writing at Frasers Tower, Level 17, 182 Cecil Street, Singapore, 069547.
21.1.2. Report lost, stolen or misappropriated Cards or other unauthorised access to your Account (available 24
hours a day):
21.1.2.1. Via the app;
21.1.2.2. Via +44 20 3769 8510
16
17759041v.2
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 1 di 43
TERMS AND CONDITIONS
Terms of Service
These Terms of Service and any terms expressly incorporated herein (the “Terms”) govern
access to and use of all parts of the website and mobile application branded as MY NEO
GROUP / NEO Dash / NEO X / NEO ONE and referring to the domains https://myneogroup.com
https:// myneodash.com (the “Website”, “App”) and all documents, data, materials or other
information made available on the Websites.
Your access to and use of the Website and/or App is conditioned on your acceptance of and
compliance with these Terms. These Terms apply to all visitors, users, Clients and others who
access or use the Website and/ or App. These Terms contain the entirety of the applicable; any
conflicting or departing terms shall not be applicable, unless We expressly confirm the
applicability.
By clicking the “Sign up” button or by accessing or using the Website and/ or App, you
acknowledge and agree to be legally bound by these Terms and Privacy Policy as published on
the Website and/ or App at the time of each use. If you do not agree to the Terms and Privacy
Policy, please refrain from using the Website and/ or App. These Terms may be made available
in several languages; all versions are legally binding, but in the event of inconsistency between
the English version and a translated version, the English version prevails.
We cannot guarantee that Our Services will always meet your demands. As We grow, We will
likely add new services, change certain features and drop old features. However, We truly hope
You will always be satisfied with Us and Services We provide to You.
Last updated: 26
th
March, 2024.
CONTENT
Please click the links below if You wish to go directly to a particular section of these Terms. The
headings are for reference only and do not affect construction and interpretation.
1. DEFINITIONS
2. GENERAL PROVISIONS
3. REGISTRATION FOR A NEO DASH / NEO ONE ACCOUNT
4. SERVICES PROVIDED AND ACCESS
5. CLIENT OBLIGATIONS
6. LINKS TO OTHER WEB SITES
7. DISCLAIMER
8. RISK DISCLOSURE
9. LIABILITY
10. INDEMNIFICATION
11. CANCELLING YOUR ACCOUNT
12. ACCOUNT SUSPENSION AND CLOSURE
13. GENERAL PROVISIONS & APPLICABLE LAW
14. CONTACT US
15. MODIFICATIONS
16. PRIVACY POLICY
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 2 di 43
1. DEFINITIONS
1.1. Capitalized terms not otherwise defined in these Terms will have the following meaning:
Account an account on the Platform opened and held in the name of a Client and maintained
by NEO Dash and/or NEO X and/or NEO ONE.
Client, “You” all the natural or legal persons who have registered on NEO Dash Platform or
NEO X / NEO ONE Apps.
NEO Dash’s Terms of Services, “Terms” NEO Dash’s Terms of Services for the Clients
available on the Website and/ or App and as may be amended from time to time.
My NEO GROUP, NEO Dash, NEO X, NEO ONE, “We”, “Us”or “Our” is a FinTech
organisation, developed by the MM BITINVEST OU company, which is based in Estonia with
the company registration number: 16019579 and with a registered address at: Narva mnt 5,
Harju maakond, Tallinn, Estonia 10117. “Collaboration Partner” provides different types of
Services to NEO Dash / NEO ONE end Clients. Through the confirmation of the present
Terms, the Client agrees to the Terms of Use and Privacy Policies of each Collaboration
Partner, without prejudice that any of these may require additional consent or validation
necessary for the part of the Service they are in charge. Collaboration Partners may restrict
their services to Client who does not comply with Collaboration Partner’s risk appetite. All
services regulated as e - money and/or payments services are exclusively provided by the
Collaboration Provider (and never by MM BITINVEST OU). Please find Our Collaboration
Partner list below in this document.
Funds in account for both crypto and fiat currencies which hold inter-exchangeable value and
are operated within Our system. These funds can be digitally deposited, withdrawn,
transferred, and stored.
GDPR Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April
2016 on the protection of natural persons with regard to the processing of personal data and
on the free movement of such data and repealing Directive 95/46/EC (General Data
Protection Regulation) (Text with EEA relevance), OJ L 119, 4.5.2016. If your country of
residence is based within the European Economic Area (“EEA”) and the GDPR applies to Our
processing of your personal data (within the meaning of GDPR), your representative within the
EEA for the purposes of the GDPR is Neo Dash App, Ltd. If your Country of Residence is
outside of the EEA, provisions related to the GDPR shall not apply to your use of the Services.
Payment Card: a payment card issued to you by an authorized Third-Party Service Provider,
enabling payment transactions in fiat money than can be funded with Virtual Assets stored in
your Wallet.
Platform a publicly accessible internet-based information system which is branded as’NEO
Dash’, available via the Website and/ or App and operated or managed by MM BITINVEST
OU.
Services connecting the Clients to technological tools through the use of the Platform NEO
Dash and/or NEO ONE app providing the different Collaboration Partners services,
including but not limited to (i) virtual and physical cards, (ii) crypto wallets, (iii) crypto
exchange, (iv) rewards center, (v) token staking and (vi) Marketplace in a single Platform.
Third-Party Service Providers: authorized or regulated financial institutions, providers of
processing, identity verification, anti-money laundering services, and such other third parties
as we may partner with from time to time.
Third-Party Services: services made available by Third-Party Service Providers.
Third-Party Terms: terms, conditions, and policies of Third-Party Service Providers.
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 3 di 43
VIBAN Account: a virtual account opened for you by Striga that is linked to Striga’s payment
account opened by an authorized Third-Party Service Provider, enabling certain transactions
with fiat currency as further detailed in the Terms.
Virtual Asset: a value represented in the digital form, which is digitally transferable,
preservable, or tradable and which natural persons or legal persons accept as a payment
instrument but that is not the legal tender of any country or funds for the purposes of Article
4(25) of Directive (EU) 2015/2366 of the European Parliament and of the Council on payment
services in the internal market, amending Directives 2002/65/EC, 2009/110/EC, and 2013/36/
EU and Regulation (EU) No 1093/2010, and repealing Directive 2007/64/EC (OJ L 337,
23.12.2015, pp 35127) or a payment transaction for the purposes of points (k) and (l) of
Article 3 of the same Directive.
Virtual Asset Services: any or all of the following:
Virtual Asset Wallet Service: a Service in the framework of which we host a Virtual Asset
Wallet or account that is managed with encrypted keys and enables the holding, storage,
and transfer of Virtual Assets.
Virtual Asset Transfer Service: a Service that allows a transaction to be conducted
electronically at least in part through us in your name with the aim of moving the Virtual
Asset to the recipient’s Virtual Asset Wallet or account.
Virtual Asset Exchange Service: a Service with the help of which you exchange a Virtual
Asset against a fiat currency or a fiat currency against a Virtual Asset, or a Virtual Asset
against another Virtual Asset.
Wallet a storage which is used to store, send, and receive cryptocurrencies digital and
securely. NEO Dash has a multi-currency wallet allowing Our Clients to receive different types
of cryptocurrencies supported by the NEO Dash. The Wallet holds one or more public
addresses that act as cryptocurrency account numbers and can be used to receive that
particular asset. Blockchain is a linear chain of multiple linked blocks that are cryptographically
secured. Each block contains, among other things, a list of recent transactions and a
reference to the block which came immediately before it.
Website the website branded as My NEO GROUP, Neo Dash and NEO ONE and
referring to the domains https://myneogroup.com and https://myneodash.com
https://myneoone.com
2. GENERAL PROVISIONS
2.1. The use of the Website App and its content is voluntary and falls under the responsibility of
the Client.
2.2. The Services are intended solely for users who are at least 18 years old or of legal age in their
respective country, if higher, and who satisfy the criteria described in these Terms. The Client must
represent and warrant that he/she: (i) as an individual, legal person, or other organization, have
full legal capacity and sufficient authorizations to enter into these Terms; (ii) have not been
previously suspended or removed from using Our Services; (iii) are not located in, or a citizen or
resident of the United States; (iv) is not a legal or natural person with US citizenship, domicile or tax
liability in the USA or according to the sanction lists of OFAC, the United Nations, the European
Union, the United Kingdom, Austria, Switzerland, Liechtenstein or other sanction lists and (v) is
not a Politically Exposed Person (PEP).
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 4 di 43
2.3. Some Services may not be available in certain jurisdictions or regions or to certain users. We
reserve the right to change, modify or impose additional restrictions at Our discretion at any time.
2.4. As long as You agree to and comply with these Terms, We guarantee You the personal,
non-exclusive, non-transferable, non-sublicensable and limited right to enter and use the
Platform and the Services.
2.5. You are the only person authorized to use your Account and the Services and You may not
share your Account credentials with any other person.
2.6. Withdrawal of FIAT funds from the NEO Dash Platform and/or NEO ONE app is permissible
only to Your personal bank account, while transactions of virtual assets are allowed to third parties.
3. REGISTRATION FOR A NEO Dash / NEO ONE ACCOUNT
3.1. All users must apply for a NEO Dash and/or NEO ONE Account before using NEO Dash
and/or NEO X and/or NEO ONE Services.
3.2. When You register a NEO Dash and/or NEO ONE Account, You must provide your real
name, birthdate, country, mobile number, email address and password, and accept these
Terms, the Privacy Policy, and other Platform rules. Please use the letters of the Latin
alphabet in the sections where We ask you to fill in requested information.
3.3. From time to time We may be required to request further information regarding your
transactions in order to comply with applicable law and regulation. Failure to provide such
information in a timely fashion may result in the suspension of your ability to use the Services
(until you provide such information) or the closure of your Account.
3.4. You represent and warrant that any and all information provided to Us pursuant to the
registration process or otherwise is true, accurate and not misleading in any respect. If any such
information changes, it is your obligation to timely update such information as soon as possible
to maintain the integrity and accuracy of the information.
3.5. If there are any grounds for believing that any of the information You provided is incorrect,
false, outdated or incomplete, NEO Dash and/or NEO ONE reserves the right to send You a notice
to demand correction, directly delete the relevant information, and, as the case may be, terminate
all or part of NEO Dash and/or NEO ONE Services provided to You. If We are unable to reach You
with the contact information You provided, You shall be fully liable for any loss or expense caused
to NEO Dash and/or NEO ONE during your use of NEO Dash and/or NEO ONE Services.
3.6. For Our compliance purposes and in order to provide the Services to You, You hereby
authorize Us to, directly or through a Collaboration Partner, obtain, verify, and record information
and documentation that helps Us to verify your identity and personal Account information.
3.7. You must also keep your login data secret and take all responsible precautions to protect
the login data from unauthorized access. We reserve the right to change your login data or close
your account, if We discover that your account has been used by an unauthorized party.
4. SERVICES PROVIDED AND ACCESS
4.1. Access to the Services is granted through Our Website or Our App. Your use of the App
remains at all times subject to the terms of conditions and privacy policies of the relevant app
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 5 di 43
store from which You downloaded it, for example the Google Play or the Apple App Store. To the
extent that there is a conflict between those terms and conditions and these Terms and
Conditions, these Terms prevail.
4.2. Certain Services or parts of the Platform may be accessible only by agreeing to the terms of
use and privacy policies of Our Collaboration Partner’s. We strongly advise You to read the terms
and conditions and privacy policies before applying for the Services. Please find Our Collaboration
Partner list below in this document.
4.3. We reserve the right to change, suspend, or discontinue any aspect of the Services at any
time and in any jurisdiction, including hours of operation or availability of any feature, without
liability. This will make changes to these Terms necessary.
4.4. We may decline to process any order and may limit or suspend your use of one or more
Services at any time, in our sole discretion. Suspension of your use of any of the Services will not
affect your rights and obligations pursuant to these Terms. We may, in Our sole discretion, decline
to process orders if (i) We believe the transaction is suspicious; (ii) the transaction may involve
fraud or misconduct; (iii) it violates applicable laws; or (vi) it violates the terms of these Terms.
Where permitted by law, We will notify you by the end of the business day if We have suspended
processing your orders and, if possible, provide Our reasons for doing so and anything You can
do to correct any errors leading to the stoppage.
4.5. You must not access without authority, penetrate, interfere with, damage or disrupt (or
attempt to do any of the same) any part of the Services or its security measures, any servers,
other equipment or networks connected to the Services or on which it is stored or any software
used in the provision of the Services, including in each case by transmitting any worms, computer
viruses, malware, logic bombs, Trojan horses, spyware, harmful components or any other
software, code or data of a corrupt, destructive, malicious or disruptive nature (the “Viruses”). You
also agree to take steps to ensure that the hardware and software that you employ to access the
Services does not introduce any form of computer Viruses or similar item into the Service and
agree to indemnify Us for any loss that it may suffer as a result of such introduction.
4.6. You agree to pay NEO Dash and/or NEO ONE the fees specified in NEO Dash and/or NEO
ONE service fees schedule. NEO Dash and/or NEO ONE may, in its discretion, update the fees at
any time. Any updated fees will apply to any sales or other transactions that occur following the
effective date of the updated fees. You authorize NEO Dash and/or NEO ONE to deduct from your
account any applicable fees that you owe under these Terms.
CRYPTO CARD and vIBAN FEES
ONBOARDING
Onboarding fee only in NEO DASH
5
Payable via credit card or via NRT
Customer onboarding (KYC)
Included
Monthly fee per Active User
Included
Monthly fee per Active Card
Included
SEPA
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 6 di 43
vIBAN issuing
Included
SEPA incoming and outgoing per transaction
1
CARDS
Plastic Cards issuing
10
Virtual Cards issuing
1,50
Payment Fee per Authorization
(No additional scheme fees/settlement fees/ clearing fees)
Physical at POS
0,30
Online
0,30
Foreign Exchange Fees per transaction amount
0.0%
Fee per ATM cash withdraw
3 + 4%
CARD SHIPPING
Post (not tracked) 9-10 days
5,00
Tracked 3-6 days
10,00
Express 1-2 days
30,00
CRYPTO
Digital Asset Withdrawal per amount withdrawn
This fee is in addition to the network-fee-based fee collected by our third-party provider
0.30%
Digital Asset Deposit per amount deposited
0.30%
Cryptocurrency exchange
0.70%
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 7 di 43
4.7. Fees collection can happen directly by the Platform or through our Third-Party Providers,
guaranteeing the we instruct our Third-Party Providers to debit such fees from the customer’s
account in accordance with the pricing applicable to the customer, and we assume liability for
compensating charged fees to which the customer has not consented.
4.7.1 The onboarding fee can be paid via credit card (Stripe) or via the native crypto token of
the platform (NRT).
When the user reaches the onboarding fee payment page, they are presented with the option
to pay via credit card or the native crypto token.
a) If the user chooses to pay via credit card, they will be prompted redirected to Stripe, a third-
party payment processor, asked to enter their credit card details, including card number,
expiration date, CVC, and billing address. Stripe verifies the payment details and, upon
successful authorization, processes the payment for the onboarding fee. Once the payment is
successfully processed, the user receives a confirmation of the payment and their onboarding
process continues.
b) If the user chooses to pay via the native crypto token (NRT), they will be provided with the
necessary instructions for making the payment using the platform's supported cryptocurrency
wallet. Upon user acceptance of paying the onboarding fee via NRTs, the platform proceeds
with the debit of 8 NRT on user’s NRT wallet embedded in the NEO DASH platform. The
platform's system monitors the blockchain for the incoming transaction and waits for the
required number of confirmations to validate the payment. Upon successful verification, the
user receives confirmation of the NRT payment, and their onboarding process proceeds.
4.8. Subject to availability, as per our arrangements, we may provide you with access to our
Platform (through the application developed, maintained, and/or made available to you by the
respective Third-Party Service Provider) to use some or all the following Services:
4.8.1. Virtual Asset Wallet Service;
4.8.2. Virtual Asset Transfer Service;
4.8.3. Virtual Asset Exchange Service;
4.8.4. vIBAN Account;
4.8.5. vIBAN Account;
4.8.6. Card issuance;
4.8.7. Payment Services.
4.8.8 Crypto Payment Card issuance
4.9. We provide Virtual Asset Services only for a limited list of supported Virtual Assets as per our
arrangements with the relevant Third-party Providers. Subject to any legal, regulatory, technical,
or reputational considerations, we may change the list of supported Virtual Assets. The Third-Party
Provider, through whom you access the Services on the Platform, may provide or enable support
for additional Virtual Assets if the Third-Party Provider is authorized to do so under applicable law;
however, we are not bound by our Third-Party Provider’ product offering and do not assume any
liability to that effect.
4.10. By using the Third-Party Services, you acknowledge that Third-Party Services are
provided or made available by Third-Party Service Providers, and the Third-Party Terms may
apply to such services. You are required to read, acknowledge, accept, and comply with the
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 8 di 43
Third-Party Terms, failure to do so may result in suspension or termination of providing the
Services and Third-Party Services to you.
4.11. In the normal course of providing our Virtual Asset Services, it may become necessary or
advantageous for MM Bitinvest OU to engage third parties to carry out certain administrative or
ancillary tasks. Our decision to involve third parties is driven by our commitment to enhance the
service experience and efficiency for our users.
While MM Bitinvest OU is dedicated to selecting third-party service providers with a
demonstrated track record of reliability and expertise, it is important for our users to understand
that MM Bitinvest OU's role is primarily that of facilitation and oversight. As such, we do not
assume direct liability for the defaults, acts, or omissions of these third parties.
We ensure a responsible approach to third-party collaborations through:
(i) A selective engagement process focusing on the expertise and reliability of third parties.
(ii) Establishing clear expectations and guidelines for performance and compliance to ensure
alignment with our service standards.
It is our policy to monitor the performance and compliance of third-party service providers to
ensure that their contributions positively impact the services we provide. However, the direct
legal and operational responsibilities between these third parties and our users are governed
by their own terms and agreements.
Our users' trust and satisfaction are paramount. Should any issues arise from the involvement
of third parties, MM Bitinvest OU commits to acting as a mediator to facilitate a resolution,
leveraging our relationships and agreements with these providers.
This approach allows us to extend the range and quality of our services while maintaining a
clear and responsible stance on our role and the extent of our liabilities.
4.12 PROHIBITED JURISDICTIONS Currently, we are unable to provide or make Services
available to citizens or residents of the following jurisdictions: Afghanistan, Albania, Algeria,
Armenia, Azerbaijan, Barbados, Belarus, Botswana, Burkina Faso, Burundi, Cambodia,
Cameroon, Cayman Islands, Central African Republic, Chad, Cuba, Democratic Republic of
Congo, Democratic People’s Republic of Korea (North Korea), Egypt, Equatorial Guinea,
Ghana, Guinea, Guinea Bissau, Haiti, Iran, Iraq, Jamaica, Japan, Jordan, Kazakhstan, Kenya,
Kyrgyzstan, Lebanon, Libya, Mali, Mauritius, Moldova, Morocco, Mozambique, Myanmar,
Nicaragua, Niger, Nigeria, Pakistan, Palestinian Authority, Panama, Philippines, Russia, Saudi
Arabia, Senegal, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania,
Trinidad and Tobago, Tunisia, Turkmenistan, Türkiye, Uganda, Ukraine, United Arab Emirates,
United States of America, Uzbekistan, Vanuatu, Venezuela, Yemen, Zimbabwe.
The Services are not accessible from the countries, territories, regions, and jurisdictions
provided above. We also do not open accounts for residents of the United Kingdom of Great
Britan and Northern Ireland.
4.13 EXCLUDED PAYMENT CARD USE AREA Using the Payment Card is not possible within
the following countries, territories, regions, or jurisdictions: Afghanistan, Albania, Algeria,
Bahamas, Barbados, Belarus, Botswana, Burkina Faso, Burundi, Cambodia, Cayman Islands,
Congo, Cuba, Democratic Republic of Congo, Democratic People’s Republic of Korea (North
Korea), Egypt, Equatorial Guinea, Ghana, Guinea Bissau, Haiti, Iran, Iraq, Jamaica, Jordan,
Lebanon, Libya, Mali, Mauritius, Morocco, Mozambique, Myanmar, Nicaragua, Niger, Nigeria,
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 9 di 43
Pakistan, Palestinian Authority, Panama, Russia, Saudi Arabia, Senegal, Somalia, South
Sudan, Sudan, Syria, Trinidad and Tobago, Tunisia, Turkmenistan, Türkiye, Uganda, Ukraine,
United Arab Emirates, Uzbekistan, Vanuatu, Venezuela, Yemen, Zimbabwe.
5. CLIENT OBLIGATIONS
5.1. When using the NEO Dash and/or NEO ONE Services, You must comply with the applicable
laws. You must not:
5.1.1. attack Our network security, in particular by uploading or attaching files that are infected with
viruses or other harmful components capable of impairing the operation of another user's
device;
5.1.2. impair or in any way attempt to impair other users' access to or use of the Website or the
Services (e.g., by generating, whether manually or by automated means, an unusually high
number of accesses);
5.1.3. harvest or otherwise collect information about users, including email addresses, without their
consent;
5.1.4. post false, inaccurate, misleading, defamatory, unlawful, harassing, libellous, privacy-
invading, abusive, threatening, harmful, vulgar, obscene, or otherwise objectionable content
on Our Website or through/on Our Services or commercialize any Our services, application,
or any information or software associated with them;
5.1.5. use, copy, reproduce, modify, translate, publish, broadcast, transmit, distribute, perform,
upload, display, license, sell or otherwise exploit for any purpose any content of the Website
not owned by you in a way that violates someone else’s (including Ours) rights;
5.1.6. commercialize any Our Services, application, or any information or software associated with
them.
5.2. We reserve the right to settle any damages caused due to the breach of these Terms from
the funds stored in Your account.
6. LINKS TO OTHER WEBSITES
6.1. The Platform may contain links to third-party (including, but not limited to, Collaboration
Partner) websites or services that are not owned or controlled by Us. These links are provided
solely as a convenience to you.
6.2. We have no control over, and We assume no responsibility for, the information, content,
privacy policies, or practices of any third-party websites or services. You further acknowledge and
agree that We shall not be responsible or liable, directly or indirectly, for any damage or loss caused
or alleged to be caused by or in connection with use of or reliance on any such information, content,
goods or services available on or through any such websites or services.
6.3. We do not assume any liability for the content of any referenced or linked off-site page and are
not liable for that content. The risk of injury rests entirely with You. Links from the Platform to other
websites do not constitute an endorsement, a recommendation or an approval from Us. It is your
responsibility to evaluate the content and usefulness of information obtained from other websites.
7. DISCLAIMER
7.1. There is a risk that We may be temporarily or permanently not able to provide access to the
Platform and thus also to the Services. The Platform is provided “as is” and “as available”. We and
our Collaboration Partner’s, expressly disclaim all representations or warranties of any kind,
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 10 di 43
whether express, implied, statutory or otherwise about the Platform and Services, including, without
limitation, any implied warranties of merchantability, fitness for a particular purpose, non-
infringement or course of performance.
7.2. NEO Dash and/or NEO ONE strive to ensure the Platform operates with a high standard of
reliability and security. We acknowledge that (i) the Platform may experience interruptions and may
not be available at all times or locations; (ii) we are committed to promptly addressing errors or
defects, though immediate resolution cannot be guaranteed for every instance; (iii) the Platform is
designed to be free from viruses and other harmful components, with robust security measures in
place to protect our users; however, we recognize the evolving nature of digital threats and remain
vigilant in our efforts to safeguard against them; (iv) while we take extensive measures to secure
all content and data, including your data, absolute security cannot be assured; (v) we cannot
guarantee the accuracy or reliability of results obtained from using the Services, nor that such
results will meet your specific requirements or expectations. MM Bitinvest OU is dedicated to
actively managing and mitigating the risks associated with the use of digital services, committing
to enhance security and user protection without assuming undue liability beyond what is reasonably
within our control and legal scope.
8. RISK DISCLOSURE
8.1. By accessing or utilizing the NEO Dash and/or NEO ONE Services, you acknowledge that you
are engaging voluntarily in transactions that involve sophisticated digital assets, which are inherently
risky. You recognize the various risks associated with using these Services and engaging in
cryptocurrency transactions. These risks include, but are not limited to, the potential for financial loss,
technological issues (not limited to blockchain technology flaws), and the possibility of security
breaches.
While NEO Dash and/or NEO ONE commits to implementing advanced security measures and
maintaining our systems to the highest standards possible, it is important for you to understand that
some risks in the digital asset environment are unavoidable. Technical difficulties, such as problems
with depositing or trading cryptocurrencies, may occur and could require an extended period to
resolve. We emphasize that some issues might not be resolvable.
By accepting these Terms, you acknowledge that you are aware of these risks. It is crucial to note
that NEO Dash and/or NEO ONE's role is to facilitate transactions on the Platform, and while we strive
to ensure the security and functionality of our services, we do not assume liability for the intrinsic risks
of cryptocurrency transactions. You, as the user, assume full responsibility for understanding and
accepting the risks associated with digital asset transactions, including any technological or security
risks.
This acknowledgment does not diminish the responsibility of NEO Dash and/or NEO ONE to exercise
reasonable care in providing its services. However, it is clarified that NEO Dash and/or NEO ONE,
while facilitating transactions involving digital assets through its platform, does not bear liability for
losses arising directly from the inherent risks of digital asset transactions that are beyond our control.
9. LIABILITY
9.1. In no event shall NEO Dash and/or NEO ONE, its Board Members, Employees,
Collaboration Partner’s or entities of the NEO Dash’s group, be liable for any indirect, incidental,
special, consequential or
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 11 di 43
punitive damages, including without limitation, loss of profits, data, use, goodwill, or other
intangible losses, resulting from (i) your access to or use of or inability to access or use the
Platform; (ii) any conduct, content of any third party on the Platform; (iii) any content obtained
from the Platform; and (iv) unauthorized access, use or alteration of your transmissions,
content, whether based on warranty, contract, tort (including negligence) or (v) any other legal
theory, whether or not We have been informed of the possibility of such damage, and even if a
remedy set forth herein is found to have failed of its essential purpose.
9.2. We endeavor to ensure but cannot guarantee essentially uninterrupted availability of the
Platform and the Services and error-free transmissions. Access to the Platform or the Services
may also be suspended or restricted from time to time to allow for repairs and maintenance or the
introduction of new services or tools. 9.3. We are not liable for any damages or impairments which
are the result of an improper or incorrect use of our Services by You.
10. INDEMNIFICATION
10.1. You agree to fully compensate Us for any and all claims, civil responsibilities, damages,
expenses and costs (including the costs of our necessary legal defense, e.g. court and lawyer
fees), as well as You allow Us to make any deduction from your Account, caused by or arising
from your use of the Services, your violation of these Terms or your infringement, or infringement
by any other person of your account (including, but not limited to, exploitation of the Platform’s
software error/glitch).
11. CANCELING YOUR ACCOUNT
11.1. You may cancel your Account at any time. If you do not use your Account for an extended
period and reman inactive, We reserve the right to cancel your Account and Account information
stored in the Services may be made unavailable. To cancel your account email
support@myneodash.com with your primary email address or click on the account closure button
from your profile and make sure all your funds have been withdrawn to the account that only
belongs to You.
11.2. In case there is crypto currency balance that is too small to be withdrawn (crypto dust) You
hereby waive the ownership or any current or future claims to Your remaining account balance and
agree that this amount becomes the crypto dust
12. ACCOUNT SUSPENSION AND CLOSURE
12.1. We may, in Our sole and absolute discretion, without liability to You or any third party, refuse
to let You open an Account, suspend your Account, consolidate Accounts if You have more than
one or terminate your Account or your use of one or more of the Services. Such actions may be
taken as a result of one or more of a number of factors, including without limitation account
inactivity, failure to respond to customer support requests, failure to provide positive identification,
a court order, illegal/fraudulent activities or your violation of the Terms. We may also temporarily
suspend access to your Account in the event that a technical problem causes a system outage or
Account errors until the problem is resolved. We are entitled to take all and any of the
aforementioned actions in regards to your Account for compliance reasons without the need for
providing You with more detailed explanation thereof than just “for compliance reasons” in order
to prevent the tipping-off risk.
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 12 di 43
12.2. We will determine, in Our sole discretion, whether there has been a breach of these Terms
through your use of the Services. When such a breach has occurred, We may take such action as
We deem appropriate, including all or any of the following actions:
12.2.1. immediate, temporary or permanent withdrawal of your right to use the Platform and
Services;
12.2.2. issue of a warning to You;
12.2.3. legal proceedings against You for reimbursement of all costs resulting from the breach;
12.2.4. further legal action against You; and/or
12.2.5. disclosure of such information to law enforcement authorities as We reasonably feel is
necessary.
12.3. The responses described above are not limited and We may take any other action We
reasonably deem appropriate.
12.4. We reserve the right to restrict or refuse to permit withdrawals from your Account if (i) your
Account has otherwise been suspended or closed by Us in accordance with these Terms; (ii) to do
so would be prohibited by law or a court order or We have determined that the assets were obtained
fraudulently; or (iii) You have not undergone the required identity verification procedure such that
your identity has been verified, as indicated by your Account.
12.5. Fees paid for upgrade of tier levels or any other fees paid when using our Services are not
refundable nor will be returned to you if your Account is closed or suspended whether on your
initiative or for any other reason by us.
12.6. You acknowledge and agree that closure of your Account may incur additional charges.
12.7. In the event that You or We terminate your access to the Services, or deactivate or cancel
your Account, You remain liable for all activity conducted with or in connection with your Account
while it was open and for all amounts due.
12.8. We reserve the right to maintain your account registration and trading information, after You
close your Account, for business and regulatory compliance purposes, for a period no less than
5 years, subject to applicable laws and regulations.
13. GENERAL PROVISIONS & APPLICABLE LAW
13.1. You acknowledge that we reserve the right to assign, sub-license, or otherwise transfer any of
our rights and/or obligations under these Terms to any third party at any time. It is our commitment to
ensure that any such transfer will be conducted in a manner that respects the continuity and quality
of the service provided to you and upholds your rights under these Terms.
In the event of an assignment, sub-license, or transfer, we will provide you with adequate notice to
inform you of any changes that may affect your access to and use of the Services. Your rights as
outlined in these Terms, including but not limited to privacy, data protection, and access to services,
will be maintained and respected throughout the process. We understand the importance of
transparency and the value of your trust in our services. As such, we pledge to uphold the highest
standards of service and respect for your rights, ensuring that any changes in the assignment, sub-
licensing, or transfer of obligations are communicated clearly and effectively to you.
13.2. We understand the importance of transparency and the value of your trust in our services.
As such, we pledge to uphold the highest standards of service and respect for your rights, ensuring
that any changes in the assignment, sub-licensing, or transfer of obligations are communicated
clearly and effectively to you. We will have no liability to You for any failure or delay in performing
any of Our obligations under these Terms to the extent that such failure or delay is caused or
contributed to by You or by an event or circumstance beyond Our reasonable control.
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 13 di 43
13.3. These Terms (together with the Client registration form on the Website and/or App and Our
Privacy Policy) contain the entire agreement and understanding of the Parties relating to the subject
matter of the agreement between us and supersedes all prior agreements, understandings or
arrangements (both oral and written) relating to the same.
13.4. If any provision of these Terms is found to be invalid for any reason, the invalidity of that
provision will not affect the remaining provisions of these Terms, which will remain in full force
and effect. You agree to mutually replace the respective provision by a new legal, valid and
enforceable provision which comes closely to the intent and economic effect of the invalid
provision. This also applies in case of contractual gaps .
13.5. Failure by either You or Us to exercise any right or remedy under these Terms does not
constitute a waiver of that right or remedy.
13.6. Any dispute, controversy, or claim arising out of or in connection with Our Services,
or the breach, termination, or invalidity thereof, shall be settled in accordance with the laws
of Estonia. To provide clarity and ensure a more streamlined dispute resolution process for
our users, Estonia has been selected as the sole jurisdiction for the resolution of disputes
related to these Terms & Conditions and the use of Our Services. This decision reflects
our aim to align with the legal framework most relevant to our users within the European
Economic Area (EEA). In the event of a dispute, users are encouraged to contact us
directly to seek a resolution before proceeding to legal action. Should a dispute require
legal intervention, proceedings shall be brought exclusively in the competent courts of
Estonia, which shall have exclusive jurisdiction over such disputes.
14. CONTACT US
14.1. Any Client who is dissatisfied with Our Services, has found a deficiency, or identified
dishonesty, should contact Our customer services team via Our email supp[email protected],
support@myneoone.com, or ticketing service available from your Account under the section NEO
HELP (support@bancaneo.org, support@myneogroup.com). All requests will be processed
according to the cue and processed within 24-48 hours during business days.
14.2. The Customer Support service is available from Monday to Saturday 9am - 5pm (GMT+1)
for any questions You may have.
14.3. We will do Our best to resolve your request as soon as possible, but this may not always
be possible.
14.4. We will keep You updated on the progress of handling your complaint and reply to your
reasonable information requests made in this regard by You without any undue delay.
14.5. We will keep You updated on the progress of handling your complaint and reply to your
reasonable information requests made in this regard by You without any undue delay.
15. MODIFICATIONS
15.1. We reserve the right, at Our sole discretion to modify, restrict, refuse, move, remove,
disable or discontinue, entirely or in part, at any time and without prior notice, these Terms, the
Services and content, including Client content, on the Platform. In all such cases, We will take
account of the Clients' interests.
15.2. We will inform Our Clients on all material amendments to these Terms by publishing the
updated version of these Terms on the Platform..
15.3. You consent to these Terms anew each time You use the Platform and are bound by them
as currently published on the Website at the time of each use.
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 14 di 43
16. PRIVACY POLICY
16.1. We care about your data protection, its security and confidentiality. Please see Our Privacy
Policy to find information on how We will process your personal data when You visit or use Our
Website or contact Us.
16.2 For Third Party services, we process the customer’s data upon the instructions of Third
Party services providers and the card issuer. We act as a data processor, but upon processing
any additional customer’s data, we act as a data controller.
Third party provider
MM Bitinvest
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia
Pagina 15 di 43
Virtual asset services provided by Striga Technology OÜ (registry code: 16298772), address:
Sepapaja 6, Tallinn, Estonia, in accordance with its terms and conditions pag. 13 of these T&C.
Crypto Card is issued and related payment services are provided by Wallester AS (registry
code: 11812881), address F.R. Kreutzwaldi 4, 10120 Tallinn, Estonia, in accordance with its
terms and conditions pag. 37 of these T&C.