LemFi Card and Account Agreement

Please read this carefully and retain it for future reference. These Terms and Conditions (the "Agreement") are revised periodically, so it may include changes from earlier versions. You will be notified of these new terms, and you can accept or not. If you do not accept this Agreement will be immediately terminated and your Account will be closed.

By providing a written or electronic signature on a signature card or opening, or continuing to hold an Account with us, you agree to the most recent version of this Agreement, which can be accessed from the LemFi mobile application or www.lemfi.com.

"We", "our", and "us" refer to the RightCard Payment Services Ltd. (“RightCard”), our successors, affiliates, or assignees.

"You", “user”, “customer” and "your" refers to the person who has opened and owns the Account.

RightCard's business days are Monday through Friday, excluding federal holidays, even if we are open. Any references to "days" found in this Agreement are calendar days unless indicated otherwise.

LemFi is the trading name of RightCard Payment Services Limited.

By activating your Card, you agree that you have read and understood the terms of this Agreement (a copy of which you may download and store at any time). This Agreement shall commence at that time and continue unless cancelled or terminated. We reserve the right to change this Agreement by giving two months’ notice to you. If we do this, you may terminate this Agreement immediately and without charge before the proposed changes take effect, otherwise you shall be deemed to have accepted such changes when the two months’ notice expires.

You will be able to use the Mobile App to view the available balance in your Account, which is the total amount of funds in your Account. Funds associated with your Account that are in transit and have not settled with RightCard may not be available for withdrawal until the funds settle with RightCard.

Please note that we reserve the right to impose limits on the maximum amount that you can maintain in, or transact with, your Account and reserve the right to change such limits at any time by providing you with a simple notice.

We will communicate with you in English (the language in which this Agreement was agreed with you on registration for your Account). Key information relating to your Transactions will be provided to you via the email address you registered with us and/or via your Account within the mobile app. You may access, download and print this information at any time by logging in to your Account and selecting “Download Statement”.

In addition, you agree that we may provide notices or other information to you from time to time by posting it in your Account within the mobile app, emailing it to your registered email address, calling you by phone or sending you mobile messages. Notices to you by email or mobile messages shall be deemed given 24 hours after the email is sent, unless the sending party is notified that the email address is invalid. Please remember to keep your information updated for you to be able to receive notices from us.

1. Definitions & Interpretation

In this document, if we use words that start with a capital letter, that means the word has been defined in this ‘Definition & Interpretation’ section.

Account Services

For Account service assistance or additional information regarding your Account, please contact Customer Service at contact@lemfi.com

Your card or account can be managed via the app. To report your card lost or stolen please contact us or use the app to mark the card lost or stolen.

The issuer for your Visa Debit card is RightCard Payment Services Ltd. RightCard is registered in England under Registration Number 9163262. Registered address B7b St. Faiths Street Maidstone, Kent England ME14 1LH UK.

RightCard is licensed as a principal member with Visa.

2. Limitations on Frequency and Amounts of Transactions

From time to time, we may increase or decrease the limits or add additional limits to your use of the Account. Including the Card, in their sole discretion without notice to you except as required by applicable law, for security, risk or other reasons. Your Account limits can be found in the table below.

Your Account is not intended for business use, and we may close the Account if we determine it is being used for business purposes. RightCard may refuse to process any transaction(s) that it believes may violate the terms of this Agreement or applicable law.

Fee Section

You agree to pay the Account fees set forth in the "Fee Schedule" below. All the fees will be deducted from your Account and will be assessed as long as there is a remaining balance on your Account. If at any time your remaining Account balance is less than the fees being assessed, the balance of your Account will be applied to the fees resulting in a zero or negative balance on your Account. The remainder of the fees due will be collected upon the next deposit into your Account.

3 Type of Service, Eligibility and Account Access

3.1 Your Card is not a credit card. Regardless of the type of Card you have, you will have only one Account where your Available Balance is located.

3.2 We shall keep records of information and documents that you submit in order to get
approved for our program, in accordance with all applicable legal and regulatory
requirements.

3.3 Reference to a currency (e.g. Euros € or Pound Sterling £) shall mean that amount or
the local currency equivalent in which your Card is denominated.

3.4 Any Transaction on your Card in a currency other than the currency in which your Card is denominated, will require a currency conversion using an Applicable Exchange Rate.

3.5 The Available Balance on your Card and/or Account will not earn any interest.

3.6 The Payment Services are prepaid payment services and not a credit or RightCard product, you must therefore ensure that you have a sufficient Available Balance from time to time to pay for your Transactions and applicable Fees. If for any reason a Transaction is requested, and the Transaction amount exceeds the Available Balance,
the transaction will be declined.

3.7 This Agreement does not give you any rights against the Card Schemes, its affiliates or any third party.

3.8 Only persons over 18 years of age are entitled to use this service.

3.9 Each time you perform a transaction you may be asked to enter a PIN. as long as the
correct pin is entered, we will assume that you are the person giving instructions and
making Transactions and you will be liable for them.

3.10 We will do all that we reasonably can to prevent unauthorised access to the Account,
we will accept liability for any loss or damage to you resulting directly from any unauthorised access to the Account.

4 Service Limits, Direct Debits, Transfers & SEPA Transfer Payment (UK Only)

4.1 Cards are issued in accordance with regulatory limits and these terms. Limits relating to the use of Cards can be found in Fees & Limits sections and on the app. For anti-money laundering and anti-fraud reasons we reserve our rights to change particular payment restrictions (including from those published or included herein) without notice and to the extent required to meet our regulatory obligations.

4.2 We cannot be held liable for the payment process or fees associated with RightCard(s) and or intermediary RightCard(s) to process payments from you to us. Any fee(s) charged by third parties, not limited to receiving, processing or crediting a payment for you will be deducted by us before crediting the remaining balance to you.

4.3 You accept responsibility for cancelling any Direct Debit on your Account with the originator directly.

4.4 You may be asked to provide us with evidence of the source of funds in order for us to meet our regulatory requirements, in which case you agree to provide that evidence promptly. You represent and warrant to us that the evidence you provide to us is up to date, complete and accurate.

4.5 You may incur a charge for unpaid SEPA Transfers if there are not enough funds in your Account to pay an incoming SEPA Transfer request.

5 Use of the Payment Services

5.1 You may access your Account information by logging into your Account through the
mobile app. From here you will be able to view details on your Transactions, including dates. This information is accessible at any time and can be stored and reproduced as necessary.

5.2 You can use the Payment Services up to the amount of the Available Balance for Transactions.

5.3 If the Available Balance is insufficient to pay for a Payment, some Merchants will not permit you to combine use of a Card or Account with other payment methods.

5.4 The value of each Transaction and the amount of any Fees payable by you under this Agreement will be deducted from the Available Balance.

5.5 Once a Transaction is authorised, the relevant payment order may not be withdrawn (or revoked) by you after the time it is received by us. A Transaction will be deemed to have been received by us at the time you authorise the Transaction as follows:

• for Payments and ATM Transactions, at the time we receive the payment order for the Transaction from the merchant acquirer or ATM operator, and
• A request for a Direct Debit is deemed to be received on the agreed day (if the agreed day is not a Business Day, the request shall be deemed to have been received on the following Business Day).

5.6 In order to protect you and us from fraud, Merchants may seek electronic authorisation before processing any Payment. If a Merchant is unable to get an electronic authorisation, they may not be able to authorise your Payment.

5.7 We may refuse to authorise any use of the Payment Services which could breach these terms and conditions or if we have reasonable grounds for suspecting that you or a third party have committed or are planning to commit fraud or any other illegal or un-permitted use of the Payment Services.

5.8 Your ability to use or access the Payment Services may occasionally be interrupted, for example if we need to carry out maintenance on our systems. We will send communication out 2 weeks prior to any planned downtime either via email or text. Please contact Customer Services via telephone number to notify us of any problems you are experiencing using your Card or Account and we will endeavour to resolve any problem.

5.9 We will retain all your personal information and Transaction data in line with regulations for 5 years.

5.10 You agree to only use the Services for lawful purposes and to adhere at all times to all laws, rules and regulations applicable to the use of the Payment Services, including the terms of this Agreement.

5.11 You may not use the Services to receive or transfer any funds on behalf of any other natural person or legal entity.

6. Access by Third Party Providers

6.1 Any consent you give to a third-party provider is an agreement between you and it, we will have no liability for any loss whatsoever, as a result of any such agreement.

6.2 Before giving consent, you should satisfy yourself as to what degree of access you are consenting to, how it will be used and who it may be passed on to.

6.3 You should make yourself aware of any rights to withdraw the consent of access from
the third party provider and what process it has in place to remove access.

6.4 To the extent permitted by law or regulation and subject to any right to refund you may have under this Agreement, between you and us, we are not responsible for any actions that the relevant third party takes in relation to suspending or terminating your use of their service or for any resulting losses. We are also not responsible for, or a party to, any agreement that you enter into with any relevant third party. You should make sure that you read and comply with such agreement or other applicable policies and note that this Agreement will continue to apply between us including to any Payment Services and our Fees as stated continue to apply.

6.5 Where appropriate, we may deny access to your Account, to any third party where we
consider such access to be a risk of money laundering or terrorism financing, fraud or other criminal activity. Should we need to take these actions and where possible, we will give reasons for doing so unless restricted by law or for internal security reasons.

7. Condition of Use at Certain Merchants

7.1 In some circumstances we or Merchants may require you to have an Available Balance
in excess of the Payment amount.

7.2 In some circumstances Merchants may require verification that your Available Balance
will cover the Payment amount and initiate a hold on your Available Balance in that amount, examples include rental cars. In the event a Merchant places a pre- authorisation on your Account, you will not have access to these funds until the Payment is completed or released by the Merchant which may take up to 30 days.

7.3 If you use your Card at an automated fuelling station, subject to Merchant acceptance, your Card may need to be pre-authorised for a pre-determined amount in the relevant currency. If you do not use the whole pre-authorisation or do not have Available Balance to obtain a pre-authorisation, it is possible that the pre-authorised amount will be held for up to 30 days before becoming available to you again.

7.4 Some Merchants may not accept payment using our Payment Services. It is your responsibility to check the policy with each Merchant. We accept no liability if a Merchant refuses to accept payment using our Payment Services.

7.5 In relation to any dispute between you and a Merchant, provided you are able to satisfy us that you have made all efforts to resolve the dispute with the relevant Merchant, we will attempt to assist you so far as is reasonably practicable. If there is an unresolvable dispute with a Merchant in circumstances where the Card has been used for a Payment, you will be liable for the Payment and will have to resolve this directly with the relevant Merchant.

8. Managing & Protecting Your Account

8.1 You are responsible for the safekeeping of your username and password for your
Account (“Access Codes”) and the personal identification number for your Card (“PIN”).

8.2 Do not share your PIN with anyone. You must keep your PIN safe, and separate from your Card or any record of your Card number and not disclose it to anyone else. This
includes:

8.2.1 memorising your PIN as soon as you receive it,

8.2.2 never writing your PIN on your Card or on anything that you usually keep with
your Card;

8.2.3 keeping your PIN secret at all times, including by not using your PIN if anyone else is watching;

8.2.4 not disclosing your PIN to anyone else.

8.3 The user of the Card(s) must sign the signature strip on any Personalised Card immediately when received.

8.4 If you forget your PIN, you may go into the app and retrieve your pin by following the steps on the settings tab.

8.5 Do not share your Access Codes with anyone . If you disclose the Access Codes to anyone, you are responsible and liable for their access, use or misuse of the Account, their breach of the terms of this Agreement or disclosure of the Access Codes.

8.6 The Payment Services may only be used by you, if this is not complied you will be liable for the losses you suffer from unapproved usage of the Payment Services.

8.7 You must not give the Card to any other person or allow any other person to use the Payment Services. You must keep the Card in a safe place.

8.8 Failure to comply with Clauses 8.2 and/or 8.5 may affect your ability to claim any losses under this Agreement in the event that we can show that you have intentionally failed to keep the information safe or you have acted fraudulently, intentionally, with undue delay or with gross negligence. In all other circumstances your maximum liability shall be as set out below.

8.9 If you believe that someone else knows your Account or Card security details, you should contact us immediately in accordance with this Agreement.

8.10 Once your Card has expired,or if it is found after you have reported it as lost or stolen, you must destroy your Card including the magnetic strip.

9. Identity Verification

9.1 If you enter into Transactions over the internet, some websites require you to enter your name and address. In such cases you should supply the most recent address which has been registered with us by you as the Account address. The Account address is also the address to which we will send any correspondence.

9.2 You must notify us within 7 days of any change in the Account address or any other contact details. You can notify us by contacting Customer Services who may require you to confirm such notification in writing or provide supporting documentation. You will be liable for any loss that directly results from any failure to notify us of such a change as a result of undue delay, your gross negligence or fraud.

9.3 We reserve the right at any time to satisfy ourselves as to your identity and home address (for example, by requesting relevant original documents) including for the purposes of preventing fraud and/or money laundering. In addition, at the time of your application or at any time in the future, in connection with your Account, you authorise us to perform electronic identity verification checks directly or using relevant third parties.

10 Expiry & Redemption

10.1 Your Card has an expiry date printed on it (the “Expiry Date”). The Card will no longer be usable following the Expiry Date, and you must not use it after that time,

10.2 If a Card expires you can contact Customer Services to request a replacement Card, We reserve the right to issue you with a replacement for an expired Card even if you
have not requested one.

10.3 We shall have the absolute right to offset, transfer, or apply sums held in the Account(s) or Cards in or towards satisfaction of all or any liabilities and Fees owed to us that have not been paid or satisfied when due.

10.4 We shall have the absolute right to close your Account and submit a charge back claims for the relevant Transactions if your Account is in negative standing for more than 60 days. If our chargeback is successful, funds paid to your Account may only be used to credit your Card or Account, and your Account will remain closed.

10.5 If your Account is inactive (including without limitation no access to the account or payment Transactions) for at least 2 consecutive years and has an Available Balance, we may (but we are not obliged to) notify you by sending an e-mail to your registered e- mail address and give you the option of keeping your Account open and maintaining or redeeming the Available Balance. If you do not respond to our notice within thirty (30) days, we will automatically close your Account and initiate a Transfer of your Available Balance to the last payment account notified by you to us (your “Nominated RightCard Account”).

11. Termination or Suspension of Your Account and/or Processing of Transactions

11.1 We may terminate this Agreement and your use of the Payment Services with prior
notice of at least 2 months.

11.2 We may terminate or suspend,for such period as may reasonably be required,your use
of the Payment Services in whole or in part at any time or the processing of any Transaction(s) if:

• there is any fault or failure in the relevant data processing system(s);
• we reasonably believe that you have used or are likely to use the Payment Services, or allow them to be used, in breach of this Agreement or to commit an offence;
• any Available Balance may be at risk of fraud or misuse;
• we suspect that you have provided false or misleading information;
• we are required to do so by law, the police, a court or any relevant governmental
  or regulatory authority;
• required to fulfil our legal obligations in relation to the fight against money
  laundering and financing of terrorism;
• there is suspicion of unauthorised or fraudulent access to or use of your Account
  or that any of its security features have been compromised, including the
  unauthorised or fraudulent initiation of a Transaction;
• we have reasonable grounds to believe you are carrying out a prohibited or illegal
  activity;
• we are unable to verify your identity or any other information pertaining to you, your
  Account or a Transaction.

11.3 Where it is practicable and lawful for us to do so or would not compromise reasonably justified security reasons, we will notify you via email of the suspension or restriction and the reasons for it before such measures take place or immediately thereafter.

11.4 We will reinstate your Account or execute the relevant Transaction(s) as soon as practicable after the reasons stipulated herein no longer apply or exist.

11.5 Once the Payment Services have been terminated, it will be your responsibility to destroy the Card(s) that were provided to you.

11.6 If, following reimbursement of your Available Balance, any further Transactions are found to have been made or charges or Fees incurred using the Card(s) or we receive a reversal of any prior funding Transaction, we will notify you of the amount and you must immediately repay to us such amount on demand as a debt.

12. Loss or Theft of your Card or Misappropriation of Your Account

12.1 If your Card is lost or stolen or if you think someone is using your Card, PIN and/or Access Codes without your permission or if your Card is damaged or malfunctions:

12.1.1 you must contact us as soon as possible and you must provide us with your Account or Card number and either your Username some other identifying details acceptable
to us so that we can be sure we are speaking to you; and

12.1.2 Provided we have obtained your consent to cancel the card, we will then provide you with a replacement Card with a fee.

12.2 Once we have been notified of any loss or theft, we will suspend the card as soon as we are able, to limit any further losses. We can only take steps to prevent unauthorised use of the card if you can provide us with the Account or Card number and if you can produce sufficient details to identify yourself and the relevant Account.

12.3 Replacement Cards will be posted to the most recent Account address registered by you. Failure to provide the correct address will result in a Card Replacement Fee.

12.4 If you subsequently find or retrieve a Card that you have reported lost or stolen, you must immediately destroy the found Card by cutting it in half through the magnetic stripe and chip.

12.5 You agree to help us, our agents, regulatory authorities and the police if your Card is lost, stolen or if we suspect that the Payment Services are being misused.

13. Liability for Unauthorised or Incorrectly Executed Transactions

13.1 Subject to this Agreement we will reimburse you in full for all unauthorised Transactions sent from your Account immediately and in any event no later than the end of the following Business Day after noting or being notified of the Transaction (except where we have reasonable grounds for suspecting fraud), provided that you have informed us of the unauthorised Transaction without undue delay after becoming aware of the Transaction and in any event, no later than 13 months after the Transaction was executed. Where applicable, we shall restore your Account to the state in which it would have been had the unauthorised Transaction not taken place, so that the credit value date shall be no later than the date the amount had been debited. For the avoidance of doubt unauthorised Transaction is a Transaction that was not made or approved by you.

13.2 You may be liable for losses relating to any unauthorised Transactions up to a maximum of £35 resulting from the use of a lost or stolen Card or the misappropriation of your Account, unless the loss, theft or misappropriation was not detectable to you prior to payment (except where you acted fraudulently) or was caused by acts or lack of action of our employee, agent, branch or service provider.

13.3 You are liable for any losses incurred by an unauthorised Transaction if you have acted fraudulently or failed either intentionally or through gross negligence, to use your Account in accordance with the terms of this Agreement or to keep your Access Codes confidential and secure in accordance with Clause 8.

13.4 You shall not be liable for losses incurred by an unauthorised Transaction which takes place after you have notified us of a compromise of your card or Access Codes according to Clause 8, unless you have acted fraudulently, or where we have failed to provide you with the means to notify us in the agreed manner without delay on you becoming aware of the loss, theft, misappropriation or unauthorised use of your Card or Account.

13.5 We shall not liable for a refund or losses incurred by an incorrectly or non-executed payment Transaction if the details of the payee’s account provided by you were incorrect or we can prove that the full amount of the Transaction was duly received by the payment service provider of the payee.

13.6 We shall not be liable for any unauthorised or incorrectly executed Transactions incase the Transaction was affected by abnormal and unforeseeable circumstances beyond our reasonable control or where we acted in accordance with a legal obligation.

13.7 A claim for a refund of an authorised Direct Debit or Payment initiated by or through a payee (e.g. a Merchant) where the authorisation did not specify an exact amount of payment Transaction (and the amount of the Payment exceeded the amount that you reasonably could have expected taking into account your previous spending pattern, this Agreement and the circumstances of the case), must be made within 8 weeks from the date on which the funds were deducted from your Available Balance. Within 10 Business Days of receiving your claim for a refund or within 10 Business Days of receiving further information from you, we will either refund the full amount of the Payment as at the date on which the amount of the Payment was debited or provide you with justification for refusing the refund.

13.8 The right to are fund under this Clause 10 does not apply where you have given consent directly to us for the Payment to be made and, if applicable, information on the Payment was provided or made available to you by us or the payee in an agreed manner for at least four weeks before the due date.

13.9 If you are not satisfied with the justification provided for refusing the refund or with the outcome of your claim for a refund, you may submit a complaint to us or contact the complaints.

13.10 If at any time we have incorrectly deducted money from your Available Balance, we shall refund the amount to you. If we subsequently establish that the refunded amount had been correctly deducted, we may deduct it from your Available Balance and may charge you a Fee. If you do not have sufficient Available Balance, you must repay us the amount immediately on demand.

13.11 Where any request, Transaction, disputed Transaction, arbitration or reversed Transaction involves third party costs, you remain liable for these and they will be deducted from your Account or otherwise charged to you.

14 General Liability

14.1 Without prejudice Clause 10 and this Clause 11:

• neither party shall be liable to the other for indirect or consequential loss or damage (including without limitation loss of business, profits or revenues), incurred in connection with this Agreement, whether arising in contract, tort (including negligence), breach of statutory duty or otherwise;
• we shall not be liable:
  1. if you are unable to use the Card or Payment Services for any valid reason
     stated in this Agreement;
  2. for any fault or failure beyond our reasonable control relating to the use of the
     Payment Services, including but not limited to, a lack of Available Balance or
     fault in or failure of data processing systems;
  3. for any loss, fault or failure relating to the use of a Third-Party Provider as
     stated in Clause 6.3, 6.6 and 6.7 of this Agreement,
  4. if a Merchant refuses to accept a Payment or fails to cancel an authorisation
     or pre-authorisation;
  5. for the goods or services that are purchased with your Card;
  6. for any dispute you might have with a Merchant or other user of the Payment
     Service where you acted with:
  • undue delay
  • fraudulently; or
  • With gross negligence. (including where losses arise due to your failure
    to keep us notified of your correct personal details)

14.2 You agree that you will not use the Payment Services in an illegal manner and you agree to indemnify us against any claim or proceeding brought about by such illegal use of the Payment Services by you, your Authorised Person(s) and Additional Cardholder(s).

14.3 You are solely responsible for your interactions with Merchants or other users of the Payment Service. We reserve the right, but have no obligation, to monitor or mediate such disputes.

14.4 To the fullest extent permitted by relevant law, and subject to Clause 14 and Clause 15.5, our total liability under or arising from this Agreement shall be limited as follows:

• where your Card is faulty due to our default, our liability shall be limited to replacement of the Card or, at our choice, repayment to you of the Available Balance; and
• in all other circumstances of our default, our liability will be limited to repayment of the amount of the Available Balance.

14.5 Nothing in this Agreement shall exclude or limit either Party's liability in respect of death or personal injury arising from that party's negligence or fraudulent misrepresentation.

14.6 No party shall be liable for, or be considered in breach of this Agreement on account of, any delay or failure to perform as required by this Agreement as a result of any causes or conditions which are beyond such Party's reasonable control.

15. Dispute Resolution

15.1 We are committed to providing an excellent customer experience for all our Customers.If we do not meet your expectations in any way, we want to have the opportunity to put things right.

15.2 In the first instance, your initial communication will be with our Customer Services Team who can be contacted by Email to support@lemfi.com. Our Customer Services Team will listen to your needs and will do their best to solve your issue promptly and fairly. We value the opportunity to review the way we do business and help us meet our customers’ expectations. We commit to acknowledge your complaint within 48 hours and review and provide an outcome within 14 days.

15.3 If we unable to resolve your complaint and you wish to escalate your complaint further, please contact the Financial Ombudsman Service at South Key Plaza, 183 Marsh Wall, London, E14 9SR. Details of the service offered by the Financial Ombudsman Service are available at https://www.financial-ombudsman.org.uk/

15.4 You must provide us with all receipts and information that are relevant to your claim.

16. Your Personal Data

16.1 In order for us to provide you with the services relating to your Account, we are required to collect and process personal data about you, ns, with your consent or on a legal basis to meet our obligations for Anti-Money Laundering legislation or other governmental organisation.

16.2 Your consent will be sought for collection of your data and you have the right to agree or decline. Where you decline consent for the collection and processing of your data we reserve our right to discontinue service due to our obligations as a financial services institution.

16.3 We may disclose or check your personal data with other organisations and obtain further information about you in order to verify your identity and comply with applicable money laundering and governmental regulations. A record of our enquiries will be left on your file.

16.4 We may pass your personal data on to third-party service providers contracted to PFS in the course of dealing with your Account. Any third parties that we may share your data with are obliged to keep your details secure, and to use them only to fulfil the service they provide you on our behalf. Where we transfer the personal data to a third country or international organisation, we ensure this is done securely and that they meet a minimum standard of data protection in their country.

16.5 You have the right to receive information concerning the personal data we hold about you and to rectify such data where it is inaccurate or incomplete. You have the right to object to or withdraw any consent you have given for certain types of processing such as direct marketing.

16.6 Your data will be retained for 6 years after the end of the provision of services to you, where your data will be destroyed in compliance with the requirements of the General Data Protection Regulation.

16.7 In the event that you wish to make a complaint about how your personal data is being processed by us (or third parties as described in 17.5 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and RightCard’s Data Protection Officer.

16.8 Our Privacy Policy provides full details on your rights as a data subject and our obligations as a data controller. Please read this document carefully and ensure you understand your rights.

17. Changes to the Terms and Conditions

We may update or amend these terms and conditions (including our Fees & Limits Schedule). Notice of any changes will be given on our website, or by e-mail notification, or by SMS at least 2 months in advance. By continuing to use the Payment Services after the expiry of the 2-month notice period you acknowledge that you indicate your acceptance to be bound by the updated or amended terms and conditions. If you do not wish to be bound by them, you should stop using the Payment Services and close your account.

18. Miscellaneous

18.1 We may assign or transfer our rights, interest or obligations under this Agreement to any third party (including by way of merger, consolidation or the acquisition of all or substantially all of our business and assets relating to the Agreement) upon 2 month’s written notice. This will not adversely affect your rights or obligations under this Agreement.

18.2 Nothing in this Agreement is intended to confer a benefit on any person who is not a party to it, and no such person has any right under the Contracts (Rights of Third Parties) Act 1999 to enforce any terms of this Agreement, but this Clause do not affect a right or remedy of a third party which exists or is available apart from that Act.

18.3 Any waiver or concession we may allow you, will not affect our strict rights and your obligations under this Agreement.

18.4 This Agreement and the documents referred to init,constitute the entire agreement and understanding of the parties and supersede any previous agreement between the parties relating to the subject matter of this Agreement.

19. Funds Protection

All relevant funds corresponding to your Available Balance are segregated from our funds and held in the Customer Funds Account in accordance with the safeguarding requirements of the Electronic Money Regulations 2011 by law. In the event that, we became insolvent those funds are protected against claims made by any of our creditors.

20. Regulation & Law

20.1 The Payment Services, Card and Account are payment services and not deposit,credit
or RightCard products and are not covered by the Financial Services Compensation
Scheme.

20.2 This Agreement shall be governed by and interpreted in accordance with the laws of
England & Wales, and any dispute or claim in relation to this Agreement shall be subject to the non-exclusive jurisdiction of the English courts. However, if you reside outside of England and Wales you may bring an action in your country of residence.