Date published: 20 May 2022
Date of effect: 20 July 2022
1.1. These terms and conditions (“Agreement”) govern the terms under which you may use the “Taptap
Send™” App to: a) open a Taptap Send account (the “Wallet”) and/or b) make non-recurring
international remittances to any eligible Recipient (together, the “Services”). By accessing,
registering with and using the Services, you agree to be bound by the Agreement. If you do not
wish to be bound by the Agreement, do not access, register with or use the Services. The language
of this Agreement is English and all Services, Payment Instructions and Transfers carried out in
connection with it shall be in English.
1.2. In this Agreement, the terms “Taptap Send”, “we”, “us”, and “our” refer to Taptap Send UK Limited
(previously known as Segovia Technology UK Limited), together with its employees, directors,
affiliates, successors, and assigns. Taptap Send is a company registered number 10416468 in
England and Wales, with its registered office at Epworth House, 25 City Road, Shoreditch, London,
EC1Y 1AA. Taptap Send is authorised by the Financial Conduct Authority (“FCA”) under the
Electronic Money Regulations 2011 with Firm Reference Number 900842 for the provision of
e-money and payment services.
1.3. The terms “you” and “your” refer to users of each of the Services, as Senders, Recipients, other
users or visitors to the website.
1.4. This Agreement is effective from the date on which you first access, register or use any of the
Services and will continue until terminated by us or you (in accordance with Clause 13). The
Agreement may change from time to time (in accordance with Clause 12), but changes will only be
effective from the date notified to you and will not change the terms on which you previously used
“App” means our mobile application you can use for accessing your Wallet and sending Payment
“Destination Country” means the country in which the Recipient receives money through a Service.
“Password” includes a Personal Identification Number “PIN” or such other log-in information that
we may choose to accept from time to time (which may include biometric information if supported
by your phone).
“Payment Instruction” means a specific instruction from you requesting us to effect a Transfer
either a) from your Wallet; or b) by way of a non-recurring remittance.
“Payment Instrument” means a valid instrument of payment used to initiate a Payment Instruction
or to load funds onto the Wallet, such as a debit card in your name (by way of example only).
“Payout Amount” means the amount paid, after any foreign exchange conversion, to the Recipient
exclusive of the Service Fee.
“Recipient” means someone who receives money into an account or by way of cash pick-up or
similar services, in each case provided by a Service Provider pursuant to a Payment Instruction sent
through the Services.
“Sender” means someone who uses the Services to send money.
“Send Amount” means the amount of money that the Sender wishes to send to the Recipient,
excluding any applicable Service Fee and prior to any foreign exchange conversion.
“Service Fee” means our fee (which may vary depending on the destination of the Sender and the
Recipient and the Send Amount), which will be presented to you before loading a Wallet or
confirming a Payment Instruction. Other taxes and charges may exist that are not paid through or
imposed by us (e.g. mobile money withdrawal fees).
“Service Provider” means a local bank, mobile network operator, or other third party service
provider in a Destination Country (with whom we work to provide the remittance Services) which
provides an account, cash pick-up or similar services to a Recipient.
“Transfer” means the transfer of money through one of the Services.
“Transfer History” means the record of your Wallet transactions and Transfers on our App, which
you may access using your email and Password registration details.
“Wallet” means an electronic money account registered in your name, which enables you to
electronically hold, send and receive funds in the form of electronic money in the currencies
supported through the App. The funds in the Wallet can be in multiple currencies but only in the
supported currencies that we offer, which may change from time to time.
3.1. The Services allow you to:
3.1.1.open a Wallet which will allow you to:
220.127.116.11. store a balance (in the each of the currencies supported by the App from time to time);
18.104.22.168. convert funds from one currency to another using your Wallet;
3.1.2.send international remittances to Recipients via selected Service Providers in Destination
Countries (either from your Wallet balance or using a Payment Instrument).
3.2. To register for the Services, download the App (e.g. from the Apple App Store or Google Play) and
follow the instructions. By signing up for the Services, you are accepting the terms of this
3.3. Once you have registered for the Services and have logged into the App, you can:
3.3.1. load money onto your Wallet using a Payment Instrument, to generate an electronic money
3.3.2.get a refund of balance from your Wallet (in accordance with Clause 7 below);
3.3.3.submit Payment Instructions by selecting whether you want to make the payment from your
Wallet balance or via another chosen Payment Instrument, entering or selecting the Send
Amount and associated information, then clicking “Send” on the confirmation page. Your
confirmation authorizes us to debit the balance of your Wallet or charge your Payment
Instrument (as applicable) for the appropriate amount and provides consent for us to do so.
We will then immediately transfer the Payout Amount to the Recipient, which means that you
will not be able to cancel a Transfer once we have received the Payment Instruction;
3.3.4. view your Transfer information, including current and previous Transfers;
3.3.5.convert funds from one currency to another using your Wallet by selecting the currency to be
purchased, entering the amount of sell currency to be exchanged and then clicking “Confirm”
(or equivalent) on the confirmation page (setting out the applicable exchange rate); and
3.3.6.otherwise manage your use of the Services.
3.4. You must use a valid Payment Instrument to pay us to issue e-money onto your Wallet.
3.5. You must use a valid Payment Instrument or balance in your Wallet to make Payment Instructions
through the Services.
3.6. For security reasons, we may require you to re-enter your Password or to otherwise confirm your
identity to finalise your Payment Instructions or access certain functions in the App (including but
not limited to loading or accessing your Wallet).
3.7. When you initiate a Payment Instruction, we will notify you of the Service Fee to be charged (if
any) and the applicable exchange rate you will receive.
3.7.1. If we charge a Service Fee, it may vary based on the type of Transfer you are attempting (e.g.
based on the destination of you and the Recipient and the amount you wish to send).
3.7.2. When we refer to an exchange rate in this Agreement, it means the rate set by us for the
relevant currency pair, which will generally change on a daily basis. For some pairs, there will
be a difference between the exchange rate at which we buy foreign currency and the
exchange rate provided to you, which is designed to cover our operating costs and the risk
that exchange rates move between the time we send the Payout Amount to the Recipient and
receive the Send Amount from you.
3.7.3.Our Service Fees and exchange rates will be presented to you in the App before you confirm
3.8. You can load money into your Wallet in a different currency from the one in which the Wallet is
denominated (e.g. you pay in GBP to receive an equivalent amount of e-money denominated in a
different currency). Please note that:
3.8.1.If you load money in a different currency from the one in which your Wallet is denominated,
22.214.171.124. we will apply our standard exchange rate (which may change at any time) and
applicable Service Fees for such exchange; and
126.96.36.199. our bank may contact us with a request for instruction, in which case we may contact
you with further information.
3.9. When you convert funds from one currency to another using your Wallet we will charge our
Service Fees and standard exchange rates.
3.10. Our Service Fees and exchange rates are available on our website and in the App.
3.11. If you have a balance in your Wallet that you haven’t spent for two years or more, we will take
reasonable steps to contact you about refunding the balance. If we don’t succeed in contacting
you, we may return the money to the last known external account number or Payment Instrument
we have on file for you (if any).
3.12. You may choose to participate in our Referral Program. If you participate in our Referral
Program, you agree to be bound by the Referral Program Terms and Conditions, which can be
found at https://www.taptapsend.com/referrals-terms.
4.1. Subject to this Agreement, we agree to provide the Services to you using reasonable care. You
acknowledge that the Services may not be available, in whole or in part, in certain regions,
countries, or jurisdictions.
4.2. We are not obliged to process any particular Transfer. When you submit a Payment Instruction, you
are requesting that we process the Transfer on your behalf and consenting to the execution of the
Transfer. We may, in our sole discretion, choose whether or not to accept the offer to process that
Transfer (in accordance with Clause 6).
4.3. We will ask you for information when you are registering for the Services, and may also ask you for
information at other times, to fulfil our legal requirements. You must provide us with accurate and
use and store this information.
4.4. While our Service is generally able to send Transfers instantly:
4.4.1. if the Recipient’s account is held in the United Kingdom (“UK”) or European Economic Area
(“EEA”) and is in pounds (£) or euro (€), the Recipient’s account provider (e.g. bank) will, at
the latest, receive the money by the end of the business day following the time of us receiving
the Payment Instruction (or, in the case of a paper payment order, by the end of the second
business day following receipt of a Payment Instruction); and
4.4.2. otherwise (but to the extent that the Transfer is to be executed wholly within the UK in
accordance with section 86(3) of the Payment Services Regulations 2017), the Recipient’s
account provider will receive the money, at the latest, within four working days after we
receive the Payment Instruction.
4.5. While Recipients generally receive the Payout Amount instantly:
4.5.1. if the Recipient’s account provider is in the UK or the EEA, and the Recipient’s account is in
pounds (£) or an EEA currency, the account provider is required by law to put the money into
the Recipient’s account as soon as it receives it; and
4.5.2. banking practices may vary if you send money to a non-UK or non-EEA currency account or to
an account outside the UK or EEA – for more information on when a payment will be credited
to such an account, you need to contact the Recipient’s account provider.
4.6. Delivery times quoted on our website (or elsewhere) are representative for the “normal”/average
service and are not a guarantee of an individual Service or Transfer time.
4.7. We may delay or suspend a Transfer or a currency conversion via the Wallet including:
4.7.1. to verify your identity;
4.7.2. to respond to any security alerts which we receive in relation to your use of the Services or
any particular Transfer;
4.7.3. to validate your Payment Instruction;
4.7.4. due to system outages within our Service Providers; and/or
4.7.5. otherwise to comply with applicable law.
4.8. We may send and receive notifications in relation to a Transfer by email, SMS, and notifications via
the App. Without undue delay, we will provide you with information after acceptance of a Payment
Instruction enabling you to identify the Transfer, along with details of the amount of the Transfer in
the currency used in the Transfer, any Service Fees we may charge, the amount received in foreign
currency, and the date on which the Payment Instruction was received.
4.9. We will attempt to maintain up to date information regarding the availability of Service Providers
by means of information on our website or our App.
5.1. You agree that:
5.1.1. you will not access, use or attempt to use the Services to provide any Payment Instructions
unless you are at least 18 years old, and that you have the legal capacity to form a binding
legal contract in any relevant jurisdiction;
5.1.2. for each Payment Instruction that you submit, we may charge a Service Fee in addition to the
Send Amount. Payment becomes due at the time that you submit your Payment Instruction.
To the maximum extent permitted by law, the Service Fee is non-refundable unless expressly
stated in this Agreement. If you submit a Payment Instruction that results in us becoming
liable for charges including but not limited to chargeback or other fees, you agree to
reimburse us for all such fees; and
5.1.3.in connection with your registration and use of the Services, you will:
188.8.131.52. provide us with true, accurate, current and complete evidence of your identity, and
promptly update your personal information if and when it changes;
184.108.40.206. provide us with any identity documentations as may be requested by us;
220.127.116.11. provide us with details of one or more Payment Instruments;
18.104.22.168. provide us with true, accurate, current and complete information as we indicate on the
website is required to receive the Services and any other information which may be
required in relation to the Recipient; and
22.214.171.124. provide us with any other information that must be provided for a Payment Instruction
to be properly executed, either when you are preparing the Payment Instruction on our
App, or if we contact you for additional information relating to the Payment Instruction.
5.2. You must make every effort to keep your log in details safe and prevent unauthorised access to the
5.2.1. changing your Password regularly and ensure that it is not reused for other services;
5.2.2. contacting us (at the details in the Contact section below) if anyone asks you for your
5.2.3. setting up 2-step authentication where prompted; and
5.2.4. keeping your e-mail account secure. Let us know immediately if your email address becomes
5.3. Contact us if you suspect your log in details have been compromised. If you suspect your log in or
other security credentials are stolen, lost, used without your authorisation or otherwise
compromised, you must contact us (at the details in the Contact section below) immediately; you
are also advised to change your Password. Any undue delays in notifying us may affect the security
of your data (including your Payment Instrument) and also result in you being responsible for
5.4. You must not share your username and Password with anyone else.
5.5. We do not accept any liability for loss or damages to you or any third party resulting from
non-payment or delay in payment of a Payout Amount to a Recipient or failure to perform a
Transfer under the Services if you are in serious breach of your obligations listed in this Clause 5, or
if the foregoing non-payment, delay or failure is caused by a Service Provider.
5.6. When you are using the Services under this Agreement, it is your responsibility to make sure all the
details are accurate before submission. You will be given the opportunity to confirm Payment
Instructions before submission and you must check the details carefully.
5.7. The total amount that you will be required to pay, including the Service Fee and the relevant
exchange rate, will be displayed clearly on the App before you are asked to confirm your Payment
Instruction. Proceeding with a Payment Instruction at this point is entirely optional.
5.8. Others might impose taxes, fees or charges on you, e.g. for use of a particular Payment Instrument
to fund a Transfer or load the Wallet. These may include, but are not limited to, unauthorised
overdraft fees imposed by banks if there are insufficient funds in your bank account and/or the
issuer of your chosen Payment Instrument charging you a fee when you pay us.
5.9. Others might impose taxes, fees or charges on the Recipient, e.g. to withdraw the Payout Amount,
a Service Provider may charge a withdrawal fee. We may offer you the option of sending additional
funds to cover the cost of that fee. Whether you choose to pay that fee is entirely optional.
5.10. Both you and the Recipient will only act on your own behalf. You may not submit a Payment
Instruction or load a Wallet on behalf of someone else.
5.11. In using the Services, you will comply with this Agreement as well as any applicable laws, rules
or regulations. It is a breach of this Agreement to use the Services to send Transfers in connection
with illegal activity including but not limited to money-laundering, fraud and the funding of
5.12. When using the Services or when interacting with us, with another user or with a third party (in
relation to the Services), you will not:
5.12.1. breach this Agreement, or any other agreement between you and us;
5.12.2. create more than one registration without our prior written permission;
5.12.3. provide false, inaccurate, or misleading information; or
5.12.4. refuse to provide confirmation of any information you provide to us, including proof of
identity, or refuse to co-operate in any investigation.
5.13. If you think someone may be using your log in details or other security credentials without your
permission, you must notify us immediately by contacting us at the details in the Contact section
5.14. You agree that you will not use our Services for speculative trading.
6.1. You agree that we may apply limits to the amount you are able to a) load onto your Wallet; and/or
b) send to Recipients.
6.2. We may apply limits to your Transfers either on a per Transfer basis or on an aggregate basis, and
either in respect of one set of registration details or one Payment Instrument or on related sets of
registration details or Payment Instruments.
6.3. We may refuse any request to load funds to your Wallet or any Payment Instruction if we believe
6.3.1. it would put you over any load or Transfer limits we have in place or introduce;
6.3.2. it would violate this Agreement;
6.3.3. someone else is trying to make the load or Payment Instruction without your permission; or
6.3.4. you may be acting illegally or it would be against the law for us to allow the Transfer or the
loading of the Wallet.
6.4. We may suspend your use of the Services if we believe that:
6.4.1. it would violate this Agreement;
6.4.2.someone else may be trying to use it without your permission; or
6.4.3. we are required to do so by law.
6.5. In order to comply with our obligations under relevant laws, we reserve the right to ask for further
information or evidence relating to a Payment Instruction or you loading your Wallet.
6.6. We will generally inform you before or immediately after the rejection, suspension or cancellation
of your Payment Instruction or use of the Services, and will provide our reasons for doing so.
However, we will not provide reasons or any information if doing so would violate the law or
compromise our security measures.
7.1. To the extent permitted by law, once we have received your Payment Instruction, we will execute
the Transfer immediately and you do not have the automatic right to revoke it (or change the
details of the Payment Instruction). We will treat a Payment Instruction as received from you at the
time that instruction is actually received by us, which will normally be at the time you confirm a
Payment Instruction, whether or not that is during business hours.
7.2. You can request a refund of a Transfer within thirteen (13) months of the Transfer occurring if:
7.2.1.someone made a Payment Instruction without your permission; or
7.2.2.we fail to send a Transfer on time to the right Recipient and for the right amount, as indicated
on your confirmed Payment Instruction.
7.3. We will also refund a Transfer if required by law, or if the issuer of your Payment Instrument
7.4. However, we may refuse your request for a refund if we can show that:
7.4.1. you have acted fraudulently;
7.4.2. you intentionally or with gross negligence did not take all reasonable steps to keep your log in
details or other security credentials secret;
7.4.3. you are asking for a refund of a Transfer that took place before you told us that your log in
was being misused;
7.4.4. the Recipient received the money into their account at the Service Provider; or
7.4.5. there was a mistake in the Recipient’s account details which you gave us.
7.5. If you wish to request a refund for a Transfer, you should do so immediately and in any event no
later than thirteen (13) months after the Transfer occurred. A request for a refund for a Transfer
must be submitted in writing (by email) to the contact details listed in the Contact section below,
giving the Sender’s full name, address, and phone number, together with the Transfer tracking
number, Send Amount, and the reason for your refund request.
7.6. If we have executed the Transfer in accordance with the instructions you have provided to us, and
that information proves to have been incorrect, we are not liable for the incorrect execution of the
Transfer. We will however make reasonable efforts to recover the funds. We may charge you a
reasonable fee, reflective of our efforts, to do so.
7.7. For Transfers made using a Payment Instrument, any refunds will be credited back by default to the
latest known Payment Instrument used to fund the Transfer (if any), in the same currency used to
fund the Transfer. If required to process the refund, we may request additional details from you at
the relevant time.
7.8. For Transfers made using Wallet balance, any refund will be credited back by default to the Wallet,
in the same currency.
7.9. To the extent permitted by law, you can get a refund of balance from your Wallet by writing us (by
email) to the contact details listed in the Contact section below.
7.10. If you request a refund of balance from your Wallet, you agree that the balance for which you
requested a refund will be refunded to you in GBP at the exchange rate offered in the App on the
day you request your refund in writing.
7.11. However, we may refuse your request for a refund:
7.11.1. if you request a refund more than six years after termination of this Agreement;
7.11.2. if we can show that you have acted fraudulently; or
7.11.3. if we can show that you intentionally or with gross negligence did not take all reasonable
steps to keep your log in details or other security credentials secret.
7.12. Any refunds will be credited back by default to the latest known Payment Instrument used to
load the Wallet (if any). If required to process the refund, we may request additional details from
you at the relevant time.
8.1. Customer Identification Program. We may require you to supply us with personal identifying
information relating to you and the Recipient and we may also legally consult other sources to
obtain information about you and the Recipient.
8.2. Verification and Checks. We may verify your residential address and personal details in order to
confirm your identity. We may also pass your personal information to a credit reference agency,
which may keep a record of that information. We may also need to verify the identity of a
Recipient in the same way. All information provided by you will be treated securely and strictly in
inquiries we consider necessary to validate the information that you provide to us.
8.3. Data Processing and Transmission. You consent to us processing, transmitting and using your
personal data for the purposes of providing the Services, including but not limited to for
verification purposes as set out in this Clause, as well as any other purpose set out in our Privacy
Policy. You also consent to us transmitting your name, address, phone number and date of birth or
any other personal data along with your Payment Instruction to our Service Providers outside the
8.4. Government Disclosures. We may be required by law to provide information about you, your use of
the Services and your Payment Instructions to government or other competent authorities as
8.5. We may, as necessary in providing the Services, store all information required of a Recipient to
prove his or her identity or associated with their specific Payment Instruction.
9.1. The App and the Services, the content, and all intellectual property relating to them and containedin them (including but not limited to copyrights, patents, database rights, trademarks and servicemarks) are owned by us, our affiliates, or third parties. All right, title and interest in and to theTaptap Send website and the Services shall remain our property and/or the property of such otherthird parties.
9.2. The App and the Services may be used only for the purposes permitted by this Agreement ordescribed on the website. You are authorised solely to view and to retain a copy of the pages of theTaptap Send App for your own personal use. You may not duplicate, publish, modify, createderivative works from, participate in the transfer or sale of, post on the internet, or in any waydistribute or exploit the Taptap Send website, App, Services or any portion thereof for any public orcommercial use without our express written permission. You may not: (i) use any robot, spider,scraper or other automated device to access the App or the Services; and/or (ii) remove or alterany copyright, trademark or other proprietary notice or legend displayed on the Taptap Sendwebsite (or printed pages of the website). The name “Taptap Send” and other names and indicia ofownership of Taptap Send’s products and/or services referred to on the Taptap Send website areour exclusive marks or the exclusive marks of other third parties. Other products, services andcompany names appearing on the website may be trademarks of their respective owners, andtherefore you should not use, copy or reproduce them in any way.
10.1. You acknowledge that this Agreement shall be entered into electronically, and that the
following categories of information (“Communications”) may be provided by electronic means:
10.1.1. this Agreement and any amendments, modifications or supplements to it;
10.1.2. your Transfer History through the Services;
10.1.3. any initial, periodic or other disclosures or notices provided in connection with the Services,
including without limitation those required by law;
10.1.4. any customer service communications, including without limitation communications with
respect to claims of error or unauthorised use of the Services; and
10.1.5. any other communication related to the Services or us.
10.2. The Services does not allow for Communications to be provided in paper format or through
other non-electronic means. You may withdraw your consent to receive Communications
electronically, but if you do, your use of the Services shall be terminated. In order to withdraw your
consent, you must contact us at the details in the Contact section below.
10.3. Copy of Agreement: This Agreement is available for you to review at any time via the App or on
our website. We will email a copy of these terms to you when you first register for the Services.
You can also ask us to email you a copy of these terms (including any modifications) at any time.
10.4. Transfer History: Each month, we will email you at the email address you have provided,
notifying you that your monthly Transfer History is ready for viewing via the App. You may also
download the Transfer History from the App for your own records.
10.5. Security: If we have to contact you because of a suspected or actual fraud or security threat, we
will do it by calling or texting your mobile number.
11.1. Where we have materially breached this Agreement causing a loss to you, we will refund you
the Send Amount and any Service Fee charged. Any claim for compensation made by you must be
supported by any available relevant documentation.
11.2. If any loss that you suffer is not covered by a right to payment under Clause 7, we expressly
limit our liability for that loss to the greater of: (i) the amount of any Service Fee that was paid to
us; and (ii) GBP 500. This liability cap applies to any single Transfer, act, omission or event and to
any number of related Transfer, acts, and omissions or events.
11.3. We do not, in any event, accept responsibility for damages as a result of:
11.3.1. any failure to perform the Services as a result of circumstances which could reasonably be
considered to be due to abnormal and unforeseen circumstances outside our reasonable
control, which may for example include delays or failures caused by problems with another
system or network (including those of our Service Providers), mechanical breakdown or
11.3.2. us meeting our obligations under any applicable laws, rules or regulations; or
11.3.3. errors on the website or with the Services caused by incomplete or incorrect information
provided to us by you or a third party.
11.4. We do not, in any event, accept responsibility for any funds after they are made available to a
Recipient (whether in the Recipient’s account or for collection via a Service Provider).
11.5. Notwithstanding anything in this Agreement to the contrary, we shall not be liable under any
theory of tort, contract, unjust enrichment, strict liability or other legal or equitable theory for lost
profits, lost revenues, lost business opportunities, exemplary, punitive, special, incidental, indirect
or consequential damages, each of which is excluded by us, regardless of whether or not we had
foreseen, or could have foreseen, or has been advised of, the possibility of such damages.
12.1. We can make a change to this agreement for any of the following reasons:
12.1.1. because of a change in legal or regulatory requirements;
12.1.2. if the change benefits you;
12.1.3. to reflect a change in our costs of providing you with the Services;
12.1.4. in response to possible risks to the security of your use of the Services; or
12.1.5. to respond to any other change that affects us, if it is fair to pass on the effects of the
change to you.
12.2. We may make reasonable and proportionate changes for any other reason we cannot foresee,
for example to respond to changes in our industry that affect how we wish to deliver our Services
12.3. We will tell you about a change to this Agreement at least two (2) months before it takes effect.
You may object to the change before it takes effect, which will end the Agreement. If you do not
object to the change, we will take that as your acceptance of the change.
12.4. You will be notified of any upcoming changes to this Agreement via announcements sent to the
email address you have provided.
13.1. This Agreement will continue until you or we terminate it.
13.2. You can terminate this Agreement free of charge, at any time our customer-support team is
open, by contacting us at the details in the Contact section below.
13.3. We can terminate this Agreement and your access to the Services at any time, with two (2)
13.4. We can terminate this Agreement your access to the Services without prior notice if:
13.4.1. we reasonably believe you are using the Services fraudulently or illegally; or
13.4.2. we have to do so by law.
13.5. We will inform you of a termination as soon as it can, if the law allows us to do so.
13.6. In the event of termination, we will cease processing any further Payment Instructions upon
receipt of the notice of termination, but will continue processing Payment Instructions that were
submitted and are still pending prior to such receipt. Your payment obligations to us will survive
the termination of this Agreement.
14.1. If you have a complaint related to your use of the Services, please email us at the details in the
Contact section below. We will acknowledge receiving your complaint within 5 business days.
14.2. We will do our best to resolve your complaint as soon as possible, and send you a final response
by email within 15 days of receiving the complaint. If, in exceptional circumstances, for reasons
beyond our control, we need more time to respond, we will send you a holding reply within 15
days of receiving your complaint to let you know when you will receive our final response. The final
response will be no later than 35 days from the date on which we first received your complaint.
14.3. If you do not receive our final response on time, or you are unhappy with our final response,
you may be entitled to refer your complaint to the Financial Ombudsman Service, details of which
are available at http://www.financialombudsman.org.uk/consumer/complaints.htm. You can also
call them on 0800 023 4567 or tell them about a complaint online (via
https://help.financial-ombudsman.org.uk/help). Please note that the ombudsman may not
consider a complaint if you have not provided us with the opportunity to resolve it previously.
14.4. Your use of the Services does not qualify for protection under the UK Financial Services
Compensation Scheme (“FSCS”). You acknowledge and agree that the Wallet is an electronic
money account, not a bank account, and is therefore not covered by the FSCS.
14.5. As a regulated firm, when we receive a payment or the money you add to the Wallet, we
quickly place it into one of the dedicated client money bank accounts that we hold with large
commercial or central banks (client money accounts keep your money separated from our own
money, and the types of banks we can use are set by regulations). This is called “safeguarding”. We
keep safeguarding the balance in your Wallet until you pay it out or get it refunded. In the event of
our insolvency, you will be paid from these dedicated client money bank accounts in priority to
other creditors in accordance with applicable law.
15.1. Governing Law: This Agreement is governed by English law. Any dispute between you and us in
connection with the Services and/or this Agreement may be brought in the courts of England and
15.2. No Third Party Rights: This Agreement does not give rise to any rights under the Contracts
(Rights of Third Parties) Act 1999 (or any other equivalent legislation) to enforce any term of this
15.3. Waiver: No waiver of any provision hereof will be effective unless made in writing and signed by
the waiving Party. The failure of any Party to require the performance of any term or obligation of
this Agreement, or the waiver by any Party of any breach of this Agreement, will not prevent any
subsequent enforcement of such term or obligation or be deemed a waiver of any subsequent
breach of this Agreement.
15.4. Transfer of rights: You may not transfer any of your rights or obligations under this Agreement.
We may transfer, assign, and/or novate this Agreement and/or any of our rights under this
Agreement at any time without your consent. This does not affect your right to terminate this
agreement under Clause 13.
15.5. Entire Agreement: This Agreement constitutes the entire agreement between the Parties and
supersedes all prior understandings, agreements, or representations by or between the Parties, or
any of them, written or oral, with respect to the subject matter of this Agreement.
15.6. Severability: If any provision of this Agreement is held invalid, illegal or unenforceable, the
validity, legality and enforceability of the remaining provisions will not be affected or impaired in
any way, and you agree to accept a replacement of such invalid, illegal and unenforceable provision
with a valid, legal and enforceable provision that achieves, to the greatest lawful extent under this
Agreement, the economic, business and other purposes of such invalid, illegal or unenforceable
The best way to contact us for any issue is to email email@example.com. You may also call us at: