Seapoint Customer Agreement

Last updated: 2nd April 2025

1. About Seapoint and contact information

1.1 Company details. Seapoint Finance UK Limited (company number 16138873) (Seapoint, we, our or us) is a company registered in England and Wales and our registered office is at 1st Floor 8 Bridle Close, Kingston Upon Thames, London, United Kingdom, KT1 2JW. We operate the website seapoint.co.

1.2 We are a distributor of emoney for Modulr FS Limited (“Modulr”). We are not providing you with any payment or regulated services on behalf of Modulr. The emoney account is provided by Modulr to you, a company regulated by the UK Financial Conduct Authority for the issuance of electronic money (FRN 900573). The Modulr terms and conditions as provided in Annex 1 shall apply to your access and use of your emoney account.

1.3 We have been appointed an agent of Yapily Connect Limited (“Yapily”), an account information service & payment initiation service provider regulated by the UK Financial Conduct Authority (ref number 827001). We are providing the Account Information Service to you as an agent of Yapily. The Yapily terms and conditions as provided in Annex 1 shall apply to your use of the Account Information Service.

1.4 Contacting us. To contact us, you can email us at . How to give us formal notice of any matter under the Agreement is set out in clause 20.2.

1.5 How we will contact you. We will contact you using the contact details you provided when you registered for the Services or such other contact details that you provide to us. It is your responsibility to keep these up to date. By using our Services you agree to receive electronic communications from us. If we have reasonable concerns about the security of your Seapoint Profile, or any suspected or actual fraudulent use of your Seapoint Profile, we will contact you via telephone, email, or both (unless contacting you would be unlawful or compromise our reasonable security measures).

2. Our Agreement with you

2.1 Our Agreement. The Agreement applies to the access and/or use of the Services by you (“Customer” or “you”). The Agreement is made up of:

(a) the Application Form;

(b) each Pricing Schedule;

(c) Product Specific Terms (as applicable); and

(d) these terms and conditions.

If there is any conflict or ambiguity between the terms of the documents listed above, a term contained in a document higher in the list has priority over one contained in a document lower in the list.

The Agreement applies to the exclusion of any other terms that you seek to impose or incorporate, or which are implied by law, trade custom, practice or course of dealing.

2.2 Additional Documents. The following additional documents (“Additional Documents”) will also apply to your use of the Services and should be read together with this Agreement:

a) Third Party Terms

b) Acceptable Use Policy

c) Privacy Policy

d) Cookie Policy

e) FAQs

f) Product Documentation

For the avoidance of doubt, the above documents do not form part of the Agreement.

2.3 Corporate opt-out. You acknowledge and agree that you are not a Consumer, Micro-enterprise or a Charity. You agree that none of the following regulations of the Payment Services Regulations 2017 (‘PSRs’) will apply to this Agreement:

a) Part 6 of the PSRs (Information Requirements for Payment Services): regulations 40 to 62 inclusive; and

b) the following regulations of Part 7 of the PSRs: 66(1) (charges), 67(3) and (4) (withdrawal of consent), 75 (evidence on authentication and execution), 77 (payer or payee’s liability for unauthorised transactions), 79 (refunds for direct debits), 80 (requests for direct debit refunds), 83 (revocation of a payment order), 91 (defective execution of payer-initiated transactions), 92 (defective execution of payee-initiated transactions) and 94 (liability for charges and interest).

2.4 Your copy. You should print off a copy of this Agreement or save it to your computer for future reference. You can always see the most current version of the Agreement on our website. If we need to send you information in a form you can keep at any time, we will either send you an email or provide information on our website or via the Seapoint Platform that you can download. Please keep copies of all communications we send to you.

2.5 Capitalised terms that are not otherwise defined in this Agreement have the meanings given in clause 22.1.

3. Changes to the Agreement and/or Services

3.1 We may change the Agreement by giving you thirty (30) days’ prior written notice. We will consider that you have accepted the proposed changes if you do not terminate the Agreement by giving us written notice during the notice period.

3.2 We may also make changes to the Agreement immediately, without prior notice, if they:

a) reflect changes to law or regulation;

b) are changes that will either benefit you or will not negatively affect your rights and obligations under this Agreement;

c) reflect changes to the structure of our business or the Seapoint Group;

d) correct errors, omissions, inaccuracies or ambiguities;

e) make sure we follow standard practices in our industry that improve customer protections;

f) reflect changes to our agreements with our third-party service providers;

g) reflect legitimate internal cost increases or reductions that we pay when providing a particular Service; or

h) relate to the addition of a new service or extra functionality of the Services.

3.3 If you disagree with any changes. If you do not agree with any change to this Agreement, you can stop using the Services and end this Agreement in accordance with clause 17.4.

3.4 Service updates. We may change or update the Services from time to time. We may need to do this to facilitate the continued and proper operation of the Services, make improvements to the Services or to comply with Applicable Law. Some updates may require you to take steps to implement them. You agree to implement such updates as soon as reasonably practicable after receipt. In some cases (for example, if there are security risks), you will not be able to use the Services until you have implemented the update. If you have not implemented an update within 6 months of us releasing it, we may stop providing some of the Services to you or terminate this Agreement, by giving you 30 days’ prior written notice.

4. Customer due diligence

4.1 In accordance with Applicable Law, we will carry out customer due diligence checks on you, your directors, partners, ultimate beneficial owners, and employees (as relevant), and any person involved in your transactions. You must comply promptly with all requests for information that we make for the purpose of meeting our operational and legal requirements. You must provide us with complete, accurate, and up to date information at all times. You acknowledge that we may not provide you with any Services until we have received all the information we require. We will not be responsible for any Loss arising out of your failure to do so.

4.2 You agree that we may make, directly or using a third party, any inquiries we believe are necessary to verify information you provide to us, including checking commercial databases or credit reports.

4.3 Sharing relevant information. The Customer hereby authorises Seapoint to share or submit CDD Information, or any other relevant information received from the Customer to the relevant Authorities and/or Service Providers to obtain permission for providing the Services to the Customer, or for any ongoing monitoring related purpose.

5. The Services

5.1 Your Seapoint Profile. In order to use the Services, you must provide the necessary information as prompted through the Seapoint Platform to register and create your Seapoint Profile.

5.2 Authorised Users.You may appoint an ‘Authorised User’ (for example, any of your directors, officers, employees or professional advisors) to act on your behalf in connection with your Seapoint Profile. You must set up each Authorised User on the Seapoint Platform and promptly provide us with any contact or identification information of the Authorised User that we may require.

5.3 You agree that:

a) your Authorised Users have the authority to provide instructions to us in connection with the Services;

b) we may rely on instructions given by the Authorised User, and you will be bound by the actions of your Authorised Users, until you provide us with written notice withdrawing or otherwise varying the authority of an Authorised User;

c) we may refuse access to your Authorised User(s) if we are concerned about unauthorised or fraudulent access; and

d) you will promptly report to us of any infringements or unauthorised access to the Services.

5.4 You confirm you are acting on your own account, not on behalf of any other person or legal entity. If you are entering into this Agreement as trustee of a trust, you must disclose that to us. We will deem any activities on your Seapoint Profile to have been carried out by you.

5.5 Keeping your Seapoint Profile safe. In order to use the Seapoint Platform, you (or your Authorised User) must log in using the unique password and any multiple-factor authentication. We may require your Authorised User to authenticate that they are the Authorised User when logging in to the Seapoint Platform, or for certain transactions made via the Seapoint Platform. You must store all log-in information and passwords to access the Seapoint Platform safely and securely at all times and only allow Authorised Users to access the Services.

5.6 You must contact us at immediately and change your password if you suspect your Seapoint Profile, access to the Seapoint Platform, or other security credentials are stolen, lost, used without your authorisation or otherwise compromised. Any undue delay in notifying us may affect the security of your Seapoint Profile or access to the Seapoint Platform and result in you being responsible for financial losses.

5.7 Emoney account. You agree and acknowledge that:

a) the emoney account within your Seapoint Profile is provided by Modulr. Any services in connection with Modulr’s emoney account are provided by Modulr.

b) your Modulr emoney account is connected to the Seapoint Platform. Seapoint is providing you with access to the Modulr emoney account via the Seapoint Platform.

c) your access, use and/or any transactions carried out in respect of the Modulr emoney account is subject to Modulr’s terms and conditions, which you may access via the link provided in Annex 1.

d) Seapoint may send or issue instructions to Modulr on your behalf in connection with your emoney account, in accordance with terms of this Agreement.

e) Your Modulr emoney account allows you to receive, hold and/or send money in the Supported Currencies, together with any other functionalities which may be made available to you from time to time as communicated to you in writing.

5.8 Account Information Service.

(a) We will provide Account Information Service to you as an agent of Yapily.

(b) In order to connect your account to the Seapoint Platform:

(i)You will be required to review and agree to Yapilyʼs and.

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(ii) Once agreed, you will be directed to your bank’s or financial services provider's login page to authenticate and verify your consent to share financial data with Yapily.

(iii) Upon successful account linking, your account balance and transaction history will be retrieved through an API connection to Yapily and displayed on the Seapoint Platform.

(c) Any account linked with the Seapoint Platform will be kept linked for 90 days. After this period, we will ask you to re-confirm the access.

(d) Any account linked can be disconnected within the Seapoint Platform.

6. Customer’s obligations

6.1 You shall:

(a) ensure that all the information you provide to us is complete and accurate;

(b) cooperate with us in all matters relating to the Services;

(c) provide us with such information and materials we may reasonably require in order to supply the Services, and ensure that such information is complete and accurate in all material respects;

(d) comply with all Applicable Laws, any applicable Network Rules, this Agreement and any applicable Additional Documents; and

(e) notify us in writing before you make any change to the nature of the goods and/or services you supply which fall within your business as identified to us.

6.2 If our ability to perform the Services is prevented or delayed by any failure by you to fulfil any obligation listed in clause 6.1 (Your Default):

(a) we will be entitled to suspend performance of the Services until you remedy Your Default, and to rely on Your Default to relieve us from the performance of the Services, in each case to the extent Your Default prevents or delays performance of the Services. In certain circumstances Your Default may entitle us to terminate the Agreement under clause 17;

(b) we will not be responsible for any Losses you sustain or incur arising directly or indirectly from our failure or delay to provide the Services; and

(c) it will be your responsibility to reimburse us on written demand for any costs or losses we sustain or incur arising directly or indirectly from Your Default.

6.3 Audit. If we give you at least 5 Business Days' written notice, we (or our Representatives, any Service Provider or relevant Authority) may during Business Hours inspect, audit and take copies of relevant records, and other documents as necessary, to verify your compliance with this Agreement and/or any applicable terms relevant to the Services.

7. Fees

7.1 In consideration for the Services, you must pay our fees as set out in each Pricing Schedule (Fees) in accordance with this clause 7.

7.2 Our Fees may change from time to time in accordance with clause 3.

7.3 Our Fees are exclusive of VAT. Where VAT is payable in respect of some or all of the Services you must pay us such additional amounts in respect of VAT, at the applicable rate, at the same time as you pay the Fees. Any tax payable in respect of the Services provided or payments made under or in connection with this Agreement (other than tax payable on our net income, profits or gains) will be payable by you.

8. How to pay

8.1 You agree to pay the Fees set out in the Pricing Schedule. All Fees are payable upon receipt of the Services. You acknowledge and agree that Seapoint is authorised to instruct Modulr to deduct any Fees payable under this Agreement from your e-money account.

8.2 If there are insufficient funds in your e-money account, you hereby authorise Seapoint to collect the outstanding amount via direct debit and/or by charging your payment card details.

8.3 You must ensure that sufficient funds are available in your e-money account, bank account, and payment card to cover all Fees due under this Agreement.

8.4 If you fail to make a payment under the Agreement by the due date, then, without limiting our remedies under clause 17, you will have to pay interest on the overdue sum from the due date until payment of the overdue sum, whether before or after judgment. Interest under this clause 8.4 will accrue each day at 4% a year above the Bank of England's base rate from time to time, but at 4% a year for any period when that base rate is below 0%.

8.5 You must pay all amounts due under the Agreement in full without any set-off, counterclaim, deduction or withholding (other than any deduction or withholding of tax as required by law).

8.6 We may at any time set off any payment liability you have to us against any payment liability that we have to you, whether either liability is present or future, liquidated or unliquidated, and whether or not either liability arises under this Agreement. If the liabilities to be set off are expressed in different currencies, we may convert either liability at a market rate of exchange for the purpose of set-off.

9. Complaints

9.1 If a problem arises or you are dissatisfied with the Services, please get in touch with us by following our complaints procedure.

10. Intellectual property rights

10.1 Seapoint and its licensors shall retain ownership of all Intellectual Property Rights in the Services, Seapoint Platform, Seapoint API, Product Documentation (together “Seapoint Materials”) excluding any Customer Materials contained within them.

10.2 Seapoint grants to the Customer a non-exclusive, royalty-free, non-transferable licence during the Term to use the Seapoint Materials (excluding the Customer Materials) for the purpose of receiving and using the Services in its business. The Customer shall not sub-license the rights granted in clause 10.2 without Seapoint’s prior written consent.

10.3 The Customer does not have any right to the Seapoint Materials other than the right to use them in accordance with the licence granted in clause 10.2. Except as allowed by law or by Seapoint, the Customer cannot use, distribute, reproduce, modify, copy, adapt, translate, create derivative works from, transfer, loan, rent, sublicense, sell, frame or otherwise re-publish or redistribute, publicly perform or publicly display any part of the Seapoint Materials. The Customer will not allow any unauthorised person to access or use the Seapoint Materials. The Customer also cannot reverse engineer, decompile, disassemble or attempt to extract the source code of the Seapoint Materials.

10.4 The Customer and its licensors shall retain ownership of all Intellectual Property Rights in the Customer Materials. The Customer grants Seapoint a non-exclusive, royalty-free, transferable licence to use, copy and modify the Customer Materials during the Term (i) for the purpose of providing the Services to the Customer; and/or (ii) in accordance with the terms of this Agreement. Seapoint may grant sublicences of the Customer Materials to its subcontractors, Service Providers and other suppliers where necessary for the provision of the Services or complying with this Agreement.

10.5 If there is any claim that the supply, receipt or use of the Services infringes the Intellectual Property Rights of any third party (Supplier IPR Claim), Seapoint may, at its expense:

(a) procure for the Customer theright to continue to use the Services, or relevant part of the Services, in accordance with the terms of this Agreement;

(b) modify or replace the Services with non-infringing versions, provided that the modified or replaced versions are at least equivalent in terms of functionality, quality and performance as the original versions; or

(c) if clause 10.5(a) and clause 10.5(b) are not reasonably practicable, terminate the Customer's right to use the Services affected by the Supplier IPR Claim with immediate effect by notice in writing to the Customer and provide a pro-rata refund of any prepaid fees by the Customer as at the date of termination in respect of the affected Services.

10.6 Clause 10.5 is the Customer's exclusive remedy and the Supplier's only liability with respect to infringement of a third party's Intellectual Property Rights.

10.7 Seapoint shall not be liable for any Supplier IPR Claim to the extent that the actual or alleged infringement arises from:

(a) the use of Customer Materials in the development of, or the inclusion of Customer Materials in, any Services;

(b) any changes made to the Services without Seapoint’s prior written consent;

(c) compliance with the Customer's instructions in connection with the Services;

(d) the use of the Services in combination with any other materials not supplied or approved in writing by Seapoint; or

(e) the use of the Services for a purpose or in a manner not authorised in writing by Seapoint or the failure of the Customer to adhere to Seapoint’s instructions for the use of the Services.

10.8 The Customer:

(a) warrants that the supply, receipt and use of the Customer Materials in the performance of this Agreement by Seapoint and its Affiliates shall not infringe the Intellectual Property Rights of any third party; and

(b) shall indemnify Seapoint and its Affiliates against all Losses incurred by Seapoint and its Affiliates as a result of any claim that the supply, receipt or use of the Customer Materials infringes the Intellectual Property Rights of any third party.

10.9 If a third party brings a claim against either Party or any of its Affiliates (each a Party A) or notifies Party A of its intention to do so, and that claim may reasonably be considered likely to give rise to a liability under this clause 10 (Claim), Party A shall:

(a) as soon as reasonably practicable, notify the other Party (Party B) of the Claim, specifying the nature of the Claim in reasonable detail;

(b) allow Party B, at the Party B’s cost, to conduct all negotiations and proceedings in relation to the Claim and to settle or compromise the Claim;

(c) not make any admission of liability, settlement or compromise in relation to the Claim without the prior written consent of Party B (that consent not to be unreasonably conditioned, withheld or delayed); and

(d) provide Party B, at Party B’s cost, with reasonable information, assistance and co-operation in responding to and defending Claim.

10.10 Each Party's liability under this clause 10 will be reduced to the extent that any Losses are caused by the failure of the other Party to comply with clause 10.9.

10.11 Marketing. You agree that we may include and use your company name, logos, trade name, trademarks and general business information in our promotional and marketing materials for the Services and on our website. You may at any time and upon reasonable notice request in writing that we stop using your company name, logos, trade name, trademarks and general business information for these purposes.

10.12 Seapoint Marks. All Seapoint Marks owned or used by Seapoint in the course of its business are the property of Seapoint. Seapoint reserves all Intellectual Property Rights in relation to the use of the Seapoint Marks. You may not use the Seapoint Marks or any similar marks without the prior written consent of Seapoint.

11. Data protection

11.1 For the purposes of this clause 11, the terms Commissioner, controller, data subject, personal data, personal data breach, processor and processing shall have the meaning given to them in Data Protection Legislation.

11.2 Each party shall comply with all Data Protection Legislation in its processing of personal data under or in connection with this Agreement. This clause 11 is in addition to, and does not relieve, remove or replace, a Party's obligations or rights under Data Protection Legislation.

11.3 The Parties have determined that for the purposes of Data Protection Legislation, Seapoint and the Customer shall act as independent controllers in respect of the Shared Personal Data.

11.4 Without prejudice to clause 11.2, the Customer shall ensure that it has all necessary consents and notices in place to enable the Shared Personal Data to lawfully transferred to or collected by Seapoint, and further processed by Seapoint, in connection with the performance of this Agreement.

11.5 Particular obligations relating to data sharing. Each party shall:

(a) process the Shared Personal Data only for the Agreed Purposes;

(b) not disclose or allow access to the Shared Personal Data to anyone other than the Permitted Recipients;

(c) ensure that all Permitted Recipients are subject to written contractual obligations concerning the Shared Personal Data (including obligations of confidentiality) which are no less onerous than those imposed by this Agreement;

(d) ensure that it has in place appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

(e) not transfer any personal data received from the Data Discloser outside the UK unless the transferor ensures that (i) the transfer is to a country approved under the applicable Data Protection Legislation as providing adequate protection; or (ii) there are appropriate safeguards or binding corporate rules in place pursuant to the applicable Data Protection Legislation; or (iii) the transferor otherwise complies with its obligations under the applicable Data Protection Legislation by providing an adequate level of protection to any personal data that is transferred; or (iv) one of the derogations for specific situations in the applicable Data Protection Legislation applies to the transfer.

11.6 Mutual assistance. Each party shall assist the other in complying with all applicable requirements of the Data Protection Legislation. In particular, each Party shall:

(a) promptly inform the other Party about the receipt of any data subject rights request;

(b) provide the other Party with reasonable assistance in complying with any data subject rights request;

(c) not disclose, release, amend, delete or block any Shared Personal Data in response to a data subject rights request without first consulting the other Party wherever possible;

(d) assist the other Party, at the cost of the other Party, in responding to any request from a data subject and in ensuring compliance with its obligations under the Data Protection Legislation with respect to security, personal data breach notifications, data protection impact assessments and consultations with the Information Commissioner or other regulators;

(e) notify the other Party promptly (and in any event within 24 hours) if it becomes aware of a personal data breach that is directly relevant to the other Party.

(f) at the written direction of the Data Discloser, delete or return Shared Personal Data and copies thereof to the Data Discloser on termination of this Agreement unless required by law to store the Shared Personal Data;

(g) use compatible technology for the processing of Shared Personal Data to ensure that there is no lack of accuracy resulting from personal data transfers;

(h) maintain complete and accurate records and information to demonstrate its compliance with this clause 11; and

(i) provide the other Party with contact details of at least one employee as point of contact and responsible manager for all issues arising out of the Data Protection Legislation.

12. Customer Materials

12.1 You hereby authorise we may use, share and release the Customer Materials: (a) for the purpose of fulfilling our obligations under this Agreement or in connection with the provision of the Services.

(b) to assess financial and insurance risks;

(c) in connection with the enforcement of this Agreement;

(d) to recover debt or in relation to your insolvency;

(e) to maintain and develop customer relationships, our services and systems; and

(f) to prevent and detect fraud or crime.

12.2 You agree that we may use and/or disclose your Confidential Information and/or Customer Materials for preparing and furnishing compilations, analyses, and other reports of aggregated information and anonymised information, PROVIDED THAT in each case such compilations, analyses or other reports do not identify (i) you (other than where Seapoint prepares the compilation, analysis or other report either for and to you or on your behalf) or (ii) any person whose transactions were the subject of or involved in the preparation of any such compilation, analysis or other report.

13. Limitation of liability

13.1 Nothing in the Agreement limits:

(a) any liability for death or personal injury caused by negligence;

(b) any liability for fraud or fraudulent misrepresentation;

(c) any liability for breach of the terms implied by section 2 of the Supply of Goods and Services Act 1982 (title and quiet possession);

(d) your indemnity obligations under this Agreement;

(e) your liability under clause 10 (Intellectual Property rights), clause 11 (Data protection), clause 14 (Indemnity), clause 15 (Confidentiality), 18 (Anti-bribery and anti-corruption);

(f) your obligation to pay any Fees under this Agreement; and

(g) any liability which cannot legally be limited.

13.2 Subject to clause 13.1, we will not be liable to you, whether in contract, tort (including negligence), for breach of statutory duty, or otherwise, arising under or in connection with the Agreement for:

(a) loss of profits;

(b) loss of sales or business;

(c) loss of agreements or contracts;

(d) loss of anticipated savings;

(e) loss of use or corruption of software, data or information;

(f) loss of or damage to goodwill; and

(g) any indirect or consequential loss.

13.3 Exclusions. We shall not be liable for any failure to perform (nor any defective or delayed performance of) any of our obligations under this Agreement if and to the extent such failure is due to:

(a) your breach of this Agreement;

(b) us taking steps to comply with any relevant requirement under any Applicable Laws, Network Rules or any Authority;

(c) any cessation or interruption of any part of the Services which are due to any act or omission of a third party (e.g. a Service Provider or payment network);

(d) a suspension of Services by us under clause 17; or

(e) circumstances beyond our reasonable control.

13.4 Additional disclaimers.

(a) We shall not be liable for (a) the accuracy or reliability of any data you send to us; (b) our interpretation of that data; or (c) the consequences or accuracy of our interpretation of that data or any subsequent interpretation or risk assessment you undertake in relation to that data.

(b) The data made available via your Seapoint Profile is supplied to you on an “as is” basis for your information only and is not intended to be relied upon by you for any purpose whatsoever.

(c) we do not warrant that the data made available via your Seapoint Profile is accurate, sufficient, up-to-date, reliable or error-free at the time it is accessed.

(d) The electronic transmission of data, including transmission via the internet cannot be guaranteed to be secure or error-free. There is always a possibility that data sent by electronic means could be intercepted by a third party, corrupted, lost, destroyed, delayed or otherwise adversely affected. As a result, we shall not be liable to any party in respect of any error or omission arising from or in connection with the electronic transmission of information to you or your reliance on such data. This includes but is not limited to acts or omissions of your and/or our internet service providers. This exclusion of liability shall not apply in the event of any proven criminal, dishonest or fraudulent acts on our part.

13.5 Subject to clause 13.1, 13.2, 13.3 and 13.4, our total liability to you arising under or in connection with the Agreement, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, will be limited to the total Fees paid by you to Seapoint during the 12 month period prior to the date the liability first arose.

13.6 Unless you notify us that you intend to make a claim in respect of an event within the notice period, we shall have no liability for that event. The notice period for an event shall start on the day on which you became, or ought reasonably to have become, aware of the event having occurred and shall expire 6 months from that date. The notice must be in writing and must identify the event and the grounds for the claim in reasonable detail.

13.7 This clause 13 will survive termination of the Agreement.

14. Indemnity

14.1 You agree to indemnify us against all Losses incurred or suffered by us in connection with or as a result of:

(a) your breach of this Agreement, any applicable Additional Documents, failure to comply with Applicable Law or Network Rules, or your use or misuse of the Services;

(b) your breach of any Third Party Terms, your use or misuse of any services provided by a Service Provider;

(c) Seapoint acting on any instructions which we reasonably believe to have been made by you or your Authorised User;

(d) the enforcement or attempted enforcement of this Agreement; and

(e) any reasonable steps taken in the protection of our interests in connection with any allegation of fraud made in relation to you or your business.

15. Confidentiality

15.1 Each party shall keep the other Party's Confidential Information secret and confidential and shall:

(a) not use such Confidential Information except for the purpose of exercising or performing its rights and obligations under or in connection with this Agreement (Permitted Purpose); and

(b) not disclose such Confidential Information in whole or in part to any third party, except as expressly permitted by this Agreement.

15.2 A party may disclose the other party's Confidential Information to those of its Representatives who need to know such Confidential Information for the Permitted Purpose, provided that:

(a) it informs such Representatives of the confidential nature of the Confidential Information before disclosure; and

(b) it procures that its Representatives shall, in relation to any Confidential Information disclosed to them, comply with the obligations set out in this clause as if they were a party to this agreement, and at all times, it is liable for the failure of any Representatives to comply with the obligations set out in this clause 15.

15.3 A Party may disclose Confidential Information to the extent such Confidential Information is required to be disclosed by law, by any governmental or other regulatory authority (including, without limitation, any relevant securities exchange or by a court or other authority of competent jurisdiction provided that, to the extent it is legally permitted to do so, it gives the other Party as much notice of the disclosure as possible and, where notice of disclosure is not prohibited and is given in accordance with this clause 15.3, it takes into account the reasonable requests of the other Party in relation to the content of the disclosure.

15.4 On termination or expiry of this Agreement, each Party shall:

(a) destroy or return to the other party all documents and materials (and any copies) containing, reflecting, incorporating or based on the other Party's Confidential Information;

(b) erase all the other party's Confidential Information from computer and communications systems and devices used by it, including such systems and data storage services provided by third parties (to the extent technically and legally practicable); and

(c) certify in writing to the other Party that it has complied with the requirements of this clause, provided that a recipient party may retain documents and materials containing, reflecting, incorporating or based on the other Party's Confidential Information to the extent required by law or any applicable governmental or regulatory authority. The provisions of this clause shall continue to apply to any such documents and materials retained by a recipient party.

15.5 This clause 15 shall continue to apply after termination or expiry of this Agreement.

16. Representations and warranties

16.1 Mutual representations and warranties. Each party warrants, represents and undertakes that:

(a) it has full capacity and authority to enter into and to perform this Agreement;

(b) there are no actions, suits or proceedings or regulatory investigations pending or, to that Party's knowledge, threatened against or affecting that Party before any court or administrative body or arbitration tribunal that might affect the ability of that Party to meet and carry out its obligations under this Agreement; and

(c) this Agreement constitutes its legal, valid and binding obligations.

16.2 Seapoint representations and warranties. Seapoint warrants, represents and undertakes that:

(a) the Services will be provided in accordance with Applicable Law and generally accepted industry standards; and

(b) it will use reasonable commercial efforts to provide the Services.

16.3 Disclaimers.

(a) Except as expressly stated in this Agreement, all warranties, conditions and terms, whether express or implied by statute, common law or otherwise (including any implied warranties of satisfactory quality or fitness for a particular purpose or non-infringement) are excluded to the fullest extent permitted by law.

(b) We do not make any commitments about the content or data within the Seapoint Platform, the specific functions of the Seapoint Platform or its accuracy, reliability, availability or ability to meet your needs.

(c) We cannot guarantee that the Seapoint Platform will operate uninterrupted or error-free, that it will always be available, that the information it contains is current or up-to-date, that it will be free from bugs or viruses, or never be faulty. Occasionally we may have to interrupt your use of the Seapoint Platform. In such a case we will restore access as quickly as practicable.

16.4 Customer representations and warranties. Customer warrants, represents and undertakes that:

(a) this Agreement was accepted or executed by your duly authorised representative;

(b) it will comply with this Agreement, the Additional Documents and all Applicable Law regarding your use of the Services;

(c) that all information supplied to us is true, complete and accurate in all material respects and you will not omit or withhold any information which would render the information so supplied false, incomplete or inaccurate in any material respect.

(d) it will use the Services only for lawful purposes.

17. Term and termination

17.1 Term. This Agreement shall come into force on the Commencement Date and, unless the Agreement and/or any Service is otherwise terminated earlier in accordance with any provision of this Agreement, this Agreement and the Services shall continue thereafter until it is terminated in accordance 17.3 or 17.4.

17.2 Immediate termination/suspension. Without limiting any of our other rights, we may suspend the performance of the Services (in whole or in part), or terminate the Agreement (in whole or in part) with immediate effect by giving written notice to you if:

(a) you commit a material breach of any term of the Agreement and (if such a breach is remediable) fail to remedy that breach within 30 days of you being notified in writing to do so;

(b) you fail to pay any amount due under the Agreement on the due date for payment;

(c) you take any step or action in connection with you entering administration, provisional liquidation or any composition or arrangement with your creditors (other than in relation to a solvent restructuring), applying to court for or obtaining a moratorium under Part A1 of the Insolvency Act 1986, being wound up (whether voluntarily or by order of the court, unless for the purpose of a solvent restructuring), having a receiver appointed to any of your assets or ceasing to carry on business or, if the step or action is taken in another jurisdiction, in connection with any analogous procedure in the relevant jurisdiction;

(d) you suspend, threaten to suspend, cease or threaten to cease to carry on all or a substantial part of your business;

(e) you undergo a change of control (control shall have the meaning given to it in s1124 of the Corporation Tax Act 2010) and we have not provided our prior written consent which shall not be unreasonably withheld.

(f) your financial position deteriorates to such an extent that in our opinion your capability to adequately fulfil your obligations under the Agreement has been placed in jeopardy.

(g) we suspect criminal activity on your Seapoint Profile or your Seapoint Profile is being used fraudulently;

(h) we reasonably believe you are in breach of Applicable Law;

(i) we are legally required to do so, including by any relevant Authority;

(j) a Service Provider has suspended or terminated their services to you;

(k) a Service Provider has suspended its services to us or our agreement with the Service Provider is terminated.

(l) you are in breach of the Acceptable Use Policy; or

(m) you have given us false or inaccurate information, or we have been unable to verify any information you have provided.

17.3 Seapoint Termination. We may terminate the Agreement at any time by giving you 30 days prior written notice that we are closing your Profile and ending the provision of the Services.

17.4 Customer Termination. You can stop using any part of the Services or close your Seapoint Profile and stop using all Services and terminate the Agreement at any time, by giving us 30 days’ prior written notice.

17.5 Consequences of termination.

(a) On termination or expiry of the Agreement:

(i) you must return all Seapoint Materials;

(ii) you will not be able to use the Services. All rights granted to you under this Agreement will end;

(iii) all of your payment obligations under this Agreement for Services provided through to the effective date of termination will immediately become due and payable;

(iv) each Party shall comply with clause 15.4.

(b) Termination of the Agreement will not affect your or our rights and remedies that have accrued as at termination.

17.6 Survival. Any provision of the Agreement that expressly or by implication is intended to come into or continue in force on or after termination will remain in full force and effect.

18. Anti-bribery and anti-corruption

18.1 Each Party (Notifying Party) shall during the Term:

(a) comply with the Relevant Requirements;

(b) establish, maintain and enforce its own policies and procedures, including but not limited to adequate procedures under the Bribery Act 2010, to ensure compliance with the Relevant Requirements;

(c) notify the other Party (in writing) if it becomes aware of any breach of clause 18.1(a), or has reason to believe that it has received a request or demand for any undue financial or other advantage in connection with the performance of this Agreement;

(d) promptly notify the other Party (in writing) if a foreign public official becomes an officer or employee of the Notifying Party or acquires a direct or indirect interest in the Notifying Party. Each Party warrants that it has no foreign public officials as direct or indirect owners, officers or employees at the Commencement Date;

18.2 Breach of this clause 18 shall be deemed a material breach.

18.3 For the purpose of this clause 18, the meaning of adequate procedures and foreign public official and whether a person is associated with another person shall be determined in accordance with section 7(2) of the Bribery Act 2010 (and any guidance issued under section 9 of that Act), sections 6(5) and 6(6) of that Act and section 8 of that Act respectively.

19. Events outside our control

19.1 We will not be liable or responsible for any failure to perform, or delay in performance of, any of our obligations under the Agreement that is caused by any act or event beyond our reasonable control (Event Outside Our Control).

19.2 If an Event Outside Our Control takes place that affects the performance of our obligations under the Agreement:

(a) we will contact you as soon as reasonably possible to notify you; and

(b) our obligations under the Agreement will be suspended and the time for performance of our obligations will be extended for the duration of the Event Outside Our Control. We will resume the provision of the Services to you after the Event Outside Our Control is over.

19.3 You may cancel the Agreement affected by an Event Outside Our Control which has continued for more than 60 days. To cancel please contact us at support@seapoint.co.

20. Communications between us

20.1 When we refer to "in writing" in this Agreement, this includes email.

20.2 Any notice or other communication given by one of us to the other under or in connection with the Agreement must be in writing and be delivered personally, sent by pre-paid first-class post or other next working day delivery service, or email.

20.3 A notice or other communication is deemed to have been received:

(a) if delivered personally, on signature of a delivery receipt or at the time the notice is left at the proper address;

(b) if sent by pre-paid first-class post or other next working day delivery service, at 9.00 am on the second working day after posting; or

(c) if sent by email, at 9.00 am the next working day after transmission.

20.4 In proving the service of any notice, it will be sufficient to prove, in the case of a letter, that such letter was properly addressed, stamped and placed in the post and, in the case of an email, that such email was sent to the specified email address of the addressee.

21. General

21.1 Assignment and transfer

(a) We may assign or transfer our rights and obligations under the Agreement to another entity.

(b) You may only assign or transfer your rights or your obligations under the Agreement to another person if we agree in writing.

21.2 Non-exclusive. The provision of the Services under this Agreement is not exclusive.

21.3 Waiver. A waiver of any right or remedy under this Agreement or by law is only effective if given in writing and shall not be deemed to be a waiver of any subsequent right or remedy. A failure or delay by a party to exercise any right or remedy provided under this Agreement or by law shall not constitute a waiver of that or any other right or remedy, nor shall it prevent or restrict any further exercise of that or any other right or remedy. No single or partial exercise of any right or remedy provided under this Agreement or by law shall prevent or restrict the further exercise of that or any other right or remedy.

21.4 Severance. Each paragraph of the Agreement operates separately. If any court or relevant authority decides that any of them is unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.

21.5 Third party rights. The Agreement is between you and us. No other person has any rights to enforce any of its terms.

21.6 Entire agreement. This Agreement constitutes the entire agreement between the Parties and supersedes and extinguishes all previous and contemporaneous agreements, promises, assurances, and understandings between them, whether written or oral, relating to its subject matter. You acknowledge that you have not relied on any statement, promise or representation or assurance or warranty that is not set out in the Agreement.

21.7 Language. The Agreement is made only in the English language.

21.8 Non-solicitation. You must not attempt to procure services that are competitive with the Services from any of our directors, employees or consultants, whether as an employee or on a freelance basis, during the period that we are providing the Services to you and for a period of six months following termination of the Agreement.

21.9 Governing law and jurisdiction. The Agreement is governed by English law and we each irrevocably agree to submit all disputes arising out of or in connection with the Agreement to the exclusive jurisdiction of the English courts.

22. Definitions and interpretation

22.1 Definitions

a) Affiliate: in relation to a Party, any entity that directly or indirectly controls, is controlled by, or is under common control with that Party from time to time.

b) Agreed Purpose: the sharing of personal information between the Customer and Seapoint to enable Seapoint to:

(i) provide the Services and manage Seapoint’s relationship with the Customer;

(ii) comply with all Applicable Law, including conducting anti-money laundering, financial crime and other screening checks; and

(iii) comply with this Agreement and the Privacy Policy.

c) Applicable Law: all laws, legislation, regulations, binding codes of practice, or rules or requirements of any relevant Authority applicable to the activities undertaken or procured by the Parties under this Agreement, as interpreted by taking into account any code of practice or guidance issued by any Authority with which reputable financial institutions in the United Kingdom are required or accustomed to comply.

d) Authority: any national, state, or local government or regulatory authority, agency, court, or other entity asserting executive, legislative, administrative, or judicial jurisdiction over a Party.

e) Account Information Service: the provision of consolidated information on one or more payment accounts held by you with another payment service provider or with more than one payment service provider including when the information is provided:

(i) in its original form or after processing; and

(ii) only to you or to you and to another person in accordance with your instructions.

f) Business Day: a day, other than a Saturday, Sunday or public holiday in England, when banks in London are open for business.

g) Business Hours: the period from 9.00 am to 5.00 pm on a Business Day.

h) CDD Information: any information relating to the Customer provided to or obtained by Seapoint in connection with clause 4.

i) Charity: a body whose annual income is less than £1 million and is: (i) in England and Wales, a charity as defined by section 1(1) of the Charities Act 2011 (meaning of “charity”); (ii) in Scotland, a charity as defined by section 106 of the Charities and Trustee Investment (Scotland) Act 2005 (general interpretation); (iii) in Northern Ireland, a charity as defined by section 1(1) of the Charities Act (Northern Ireland) 2008 (meaning of “charity”) or as defined in the PSRs from time to time.

j) Commencement Date: the date on which we notify you (in our sole and absolute discretion) that your application for provision of Services has been accepted.

k) Confidential Information: all information (however recorded or preserved) that one Party or any of its Affiliates (discloser) discloses or makes available to the other Party or any of its Affiliates (recipient) in connection with this Agreement and which would be regarded as confidential by a reasonable business person. It includes any information of a confidential nature relating to the Fees or either Party's operations, products, processes, trade secrets or know-how. It does not include information that:

i.is or becomes generally available to the public (other than as a result of the recipient's breach);

ii.was available to the recipient on a non-confidential basis before disclosure by the discloser;

iii.was, is or becomes available to the recipient on a non-confidential basis from a person who, to the recipient's knowledge, is not bound by a confidentiality agreement with the discloser or otherwise prohibited from disclosing the information to the recipient;

iv.is developed by or for the recipient independently of the information disclosed by the discloser; or

v.the Parties agree in writing is not confidential or may be disclosed.

l) Consumer: an individual who, in contracts for payment services to which the PSRs apply, is acting for purposes other than a trade, business or profession.

m)Customer Materials:

i.all documents, information, items and materials in any form (whether owned by the Customer or a third party)which are provided by the Customer to the Supplier in connection with the Services; and

ii.all information and details of your instructions and transactions transmitted via the Services.

n) Data Discloser: a Party that discloses Shared Personal Data to the other Party.

o) Data Protection Legislation:all applicable data protection and privacy legislation in force from time to time in the UK including the UK GDPR; the Data Protection Act 2018 (DPA 2018) (and regulations made thereunder); the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended and all other legislation and regulatory requirements in force from time to time which apply to a Party relating to the use of personal data (including, without limitation, the privacy of electronic communications); and the guidance and codes of practice issued by the Information Commissioner or other relevant regulatory authority and applicable to a party.

p) Group: in relation to a company, that company, any subsidiary or holding company from time to time of that company, and any subsidiary from time to time of a holding company of that company.

q) Losses: all liabilities, damages, losses (including loss of profits, loss of business, loss of reputation, loss of savings and loss of opportunity), fines, awards, expenses and costs (including all interest, penalties, legal costs (calculated on a full indemnity basis) and reasonable professional costs and expenses).

r) Micro-enterprise: an enterprise (i.e. any person engaged in an economic activity, irrespective of legal form) which employs fewer than 10 persons (full time or equivalent) and whose annual turnover and/or annual balance sheet total does not exceed EUR 2 million or the sterling equivalent or as defined in the PSRs from time to time.

s) Network Rules: all applicable rules, regulations and/or operating guidelines issued by a card scheme, payment network or alternative payment method provider from time to time relating to any of your transactions or related processing of your data.

t) Permitted Recipients: the Parties to this Agreement, the employees, contractors, officers, advisers and/or Affiliates of each Party, any third parties engaged to perform obligations in connection with this Agreement.

u) Pricing Schedule: the document which sets out the Fees payable to Seapoint in connection with the Services.

ii) Product Documentation: any documentation, tools, tutorials and/or guidelines applicable to the Seapoint products and services that are made available to you from time to time.

v) Product Specific Terms: any specific terms and conditions in relation to a product or service that we provide to you, which are notify or made available to you (as applicable).

w) Representatives means, in relation to a Party, its employees, officers, representatives, contractors, subcontractors and advisers.

x) Relevant Requirements: all applicable laws, statutes, regulations, and codes relating to anti-bribery and anti-corruption including but not limited to the UK Bribery Act 2010.

y) Seapoint API: if made available by Seapoint at its sole discretion, the technical interface setting out the protocols and specifications required to effect an integration

of the Customer’s technical systems with the Seapoint Platform for Authorised Users to use the Services.

z) Seapoint Marks: all trade marks, logos, trade names, domain names and any other

logos or materials of Seapoint or its licensors.

aa) Seapoint Profile: the electronic information profile that records your business details

and that is used to log into and use the Seapoint Platform.

bb)Seapoint Platform: the proprietary technology and associated products devised by Seapoint to provide with Services.

cc)Service Provider: any service provider contracted by Seapoint to provide certain services to you which you may access through the Seapoint Platform.

dd)Services: the services selected on the Application Form and/or made available on the Seapoint Platform to the Customer (including the Seapoint API).

ee)Shared Personal Data: the Parties may share some or all of the following types of personal data regarding data subjects:

i.full name;

ii.email address;

iii. phone number and other contact information;

iv. date of birth;

v.nationality;

vi.public information about the data subject;

vii.other relevant verification or due diligence documentation as required to comply with Applicable Law;

viii.transaction data (including any payer or payee details)

ix.any other data that is necessary or relevant to carry out the Agreed Purposes.

ff) Supported Currency: EUR.

gg)Party: We or you, collectively “Parties”.

hh)Term: has the meaning given to this term in clause 17.1.

ii)Third Party Terms: the terms and conditions applicable to the services provided by a Service Provider to you and listed in Annex 1.

22.2 Interpretation

a) Clause, Schedule and paragraph headings shall not affect the interpretation of this Agreement.

b) A person includes a natural person, corporate or unincorporated body (whether or not having separate legal personality).

c) The Schedules form part of this Agreement and shall have effect as if set out in full in the body of this Agreement. Any reference to this Agreement includes the Schedules.

d) Unless the context otherwise requires, words in the singular include the plural and in the plural include the singular.

e) Unless expressly provided otherwise in this Agreement, a reference to legislation or a legislative provision is a reference to it as amended, extended or re-enacted from time to time.

f) Unless expressly provided otherwise in this Agreement, reference to legislation or a legislative provision includes all subordinate legislation made from time to time under that legislation or legislative provision.

g) Any words following the terms including, include, in particular, for example or any similar expression shall be interpreted as illustrative and shall not limit the sense of the words preceding those terms.

Annex 1: Third Party Terms

1. Modulr terms and conditions

MFBV INTRODUCED CLIENT SCHEDULE

INTRODUCED CLIENT TERMS OF BUSINESS

BACKGROUND

Modulr Finance B.V. (“Modulr”) is a provider of Modulr Products (as described to you by Partner Platform), which includes the provision of an electronic money account for businesses and associated payment services. These Introduced Client Terms of Business govern the Modulr Products that Modulr agrees to provide to the Introduced Client.

These Introduced Client Terms of Business (including all the attached Schedules), together with the Modulr Account Terms and Conditions set out the terms on which the Modulr Products are provided and constitute the Agreement between Modulr and the Introduced Client.

THE PARTIES AGREE AS FOLLOWS:

1. Interpretation

1.1. In these Introduced Client Terms of Business: (a) a reference to a clause is a reference to a

clause in these Introduced Client Terms of Business; (b) headings are for reference only and

shall not affect the interpretation of these Introduced Client Terms of Business; (c) the

singular shall include the plural and vice versa; (d) a reference to a person includes a natural

person, corporate or unincorporated body (whether or not having separate legal

personality) and that person's personal representatives, successors and permitted assigns;

(e) a reference to a party shall include its personal representatives, successors and

permitted assigns; (f) reference to a statute or statutory provision is a reference to it as

amended, extended or re-enacted from time to time.

2. Modulr Products

2.1. Modulr will make available to the Introduced Client such products that are provided

to the Partner Platform and as described by Partner Platform in the application process.

2.2. The Introduced Client agrees to the Partner Platform providing all such information to Modulr who will check and verify the identity of the Introduced Client, its directors, beneficial owners and Authorised Users as required by law.

2.3. The Introduced Client acknowledges that a search of the available public registers may take place for anti-money laundering purposes on the individuals listed in clause 2.2 above. 2.4. The Introduced Client acknowledges that the individuals noted in clause 2.2 above may have their their personal details accessed by third parties for the specific purpose of anti-money laundering and countering the financing of terrorism (AML/CFT), identity verification and fraud prevention.

2.5. The Account is provided by Modulr to the Introduced Client in accordance with the Modulr

Account Terms and Conditions. Modulr Products provided to the Introduced Client under

this Agreement are for the sole use by the Introduced Client.

2.6. The Introduced Client can use the Account and Cards (where applicable) to make

Transactions on the terms and conditions set out in the Modulr Account Terms and

Conditions. A record of all

Transactions relating to the Account can viewed on the Website or accessed via the

Partner Platform (as applicable).

2.7. The Introduced Client shall promptly notify Customer Services as soon as it becomes aware

login and security information enabling access to its Modulr Products have been lost, stolen

or compromised.

2.8. From time to time Modulr may carry out additional checks on the Introduced Client, i

including the identity of its directors, beneficial owners and the nature of its business in

accordance with its Due Diligence Procedure and as required by law. Modulr may contact

the Introduced Client or the Partner Platform (as applicable) for such purposes. The

Introduced Client agrees to provide such information as necessary.

2.9. The Introduced Client shall comply with all legislation and regulation as it applies to the Introduced Client. Any failure to comply with relevant legislation or regulation shall be considered a material breach of the Agreement and may result in Modulr discontinuing the provision of the Modulr Products as set out in clause 6.4.

2.10. The Introduced Client shall implement as appropriate Modulr’s reasonable security recommendations it notifies to the Introduced Client from time to time.

3. Authorised Users

3.1. Access to the Modulr Products is restricted to individuals that have been designated

by the Introduced Client as Authorised Users.

3.2. The Introduced Client must notify Modulr of all individuals it wishes to be an Authorised

User.

3.3.Each Authorised User is permitted to access and use the Modulr Products in accordance

with these Introduced Client Terms of Business.

3.4. The Introduced Client will be responsible for training its Authorised Users in the

appropriate use of Modulr Products.

3.5. The Introduced Client shall ensure its Authorised Users;

3.5.1 take all reasonable care to ensure Modulr Product access credentials, including login details to the Website, where applicable, are kept confidential to each Authorised User; and

3.5.2 do not share any information that would enable another party to access the Introduced Client’s Modulr Account.

3.6. The Introduced Client acknowledges and agrees that each Authorised User is authorised by the Introduced Client to act on its behalf. Modulr shall deem any instruction given by an Authorised User is an instruction given by the Introduced Client.

3.7. The Introduced Client will be responsible for timely notification to Modulr of any revocation of Authorised User access and will be liable for Transactions made, Fees incurred and use of Modulr Products by an Authorised User until Modulr has had two full Business Days to act on any received notice. This clause shall not apply to Introduced Clients accessing Modulr Products via the Partner Platform.

3.8. Where the Introduced Client accesses Modulr Products through a Partner Platform, such Partner Platform will be considered the Authorised User. In this instance if additional Authorised Users are required they must be requested by the Partner Platform. The use of a Partner Platform to access the Modulr Products by the Introduced Client are set out in further detail below.

4. Accessing Modulr Products through a Partner Platform

4.1. In the event the Introduced Client utilizes a Partner Platform to access Modulr Products, the Introduced Client agrees and authorises the Partner Platform to instruct Modulr to access and

use the Modulr Products on behalf of the Introduced Client, which shall include but not be limited to making Transactions, viewing and retrieving Transaction data, initiating refunds and closing the Account.

4.2. The Introduced Client acknowledges and agrees that Modulr shall have no liability whatsoever with respect to the performance, availability or quality of any Partner Platform.

4.3. The Introduced Client acknowledges and agrees to the following:

4.3.1. it must satisfy itself that its Platform Partner Agreement grants the Partner Platform all permission necessary to operate the Account on the Introduced Client’s behalf; 4.3.2. the Platform Partner will be granted full access to operate the Introduced Client’s Account as an Authorised User of the Introduced Client;

4.3.3. it is responsible for monitoring Partner Platform activities on its Account. Any queries relating to such activities will be raised with the Partner Platform directly and settled between Partner Platform and the Introduced Client;

4.3.4. the Introduced Client has no recourse against Modulr for any act or omission of the Partner Platform with respect to its Account;

4.3.5. the Introduced Client understands it can only access its Account to make Transactions, review Transactions made or otherwise use Modulr Products through the service provided by the Partner Platform; and

4.3.6. it will only use the Account for the purpose set out in the Partner Platform Agreement.

4.4. On receipt of notification by Modulr from the Partner Platform that it wishes to terminate this Agreement, this Agreement shall terminate. Any funds in the Introduced Client’s Account will be returned in accordance with the terms of the Modulr Account Terms and Conditions.

4.5. If the Introduced Client has any complaint or concern relating to the Modulr Account or other Modulr Products, such complaint or concern shall be raised directly to the Partner Platform, who shall deal with it in accordance with Modulr’s Complaints Policy, a copy of which is available on request from the Partner Platform and on the Website.

5. Customer Services

5.1. The Introduced Client can contact Customer Services if it has any queries about the Modulr Products. Information may be requested from the Introduced Client, including but not limited to, its Authorised Users, Cardholders or Transaction information so that it can verify the identity of an Authorised User , the Cardholder and/or the Modulr Products provided to such Introduced Client.

5.2. Any information shared by the Introduced Client will be kept strictly confidential. Where such information is provided in connection to a service provided by a third party, for example, the Account, then the Introduced Client’s information will only be used in accordance with instructions of such third party and only for the purpose of providing Customer Services to the Introduced Client on behalf of such third party.

5.3. As part of Modulr’s commitment to providing a quality customer service, its managers periodically monitor telephone communications between its employees and Introduced Clients to ensure that Modulr’s high quality service standards are maintained. The Introduced Client consents to such monitoring and recording of telephone communications and agrees to make its Authorised Users aware of such practice.

6. Term and Termination

6.1. This Agreement shall commence on the date the Introduced Client receives confirmation from Modulr or the Partner Platform (where applicable) of its successful application for Modulr Products and shall continue until terminated by the Introduced Client, Partner Platform (if acting on behalf of the Introduced Client) or Modulr.

6.2. The Introduced Client or the Partner Platform (where applicable) may terminate this Agreement immediately by notifying Customer Services in writing by post or email.

6.3. Modulr may terminate this Agreement and close the Introduced Client’s Account(s) by providing the Introduced Client with at least two months’ notice.

6.4. Modulr may suspend or terminate this Agreement immediately if, for any reason, the Introduced Client (i) is unable to satisfy the Due Diligence Procedures, (ii) for breach of this Agreement, (iii) has provided false, incomplete or misleading information, (iv) has engaged in fraudulent, money laundering, terrorism financing or other illegal activity or we have reasonable suspicions in respect of same or (v) we are required to do so under any applicable law or regulation or at the direction of any regulatory, law enforcement or other competent authority. Modulr shall notify you as soon as possible, unless prohibited by law, of such suspension or termination of the Agreement.

6.5. This Agreement will automatically terminate when all Accounts of the Introduced Client are closed (for any reason).

6.6. Modulr may terminate or suspend this Agreement in whole or in part immediately by giving written notice to the Introduced Client if Modulr ceases to provide Cards pursuant to the provisions of Schedule 1.

6.7. On termination of this Agreement for any reason, any balance remaining in the Introduced Client’s Account(s) shall be returned to the Introduced Client in accordance with the Modulr Account Terms and Conditions. The Introduced Client shall pay immediately all outstanding Fees due (where applicable) under this Agreement and in the event of a negative balance in an Account, shall reimburse Modulr such amount equal to the negative balance.

7. Intellectual Property

7.1. The Introduced Client acknowledges all Intellectual Property Rights in the Modulr Products are owned by or provided under licence to Modulr. Modulr grants the Introduced Client a non exclusive, royalty-free licence for the duration of this Agreement to access and use the Modulr Products only for the purpose contemplated by this Agreement.

7.2. Nothing in this Agreement shall operate to create or transfer any Intellectual Property Right to the Introduced Client.

8. Force Majeure

8.1. Modulr will not be liable for the non-performance or failure to provide any part of the Modulr Products occurring as a result of any events that are beyond the reasonable control of Modulr, for example, but not limited to, fire, telecommunications or internet failure, utility failure, power failure, equipment failure, employment strife, riot, war, terrorist attack, non-performance of third party suppliers, acts of God such as storm or lightening damage, or other causes over which Modulr has no reasonable control.

9. Assignment Transfer and Subcontracting

9.1. The Modulr Products provided to the Introduced Client are personal to the Introduced Client. The Introduced Client cannot novate, assign or otherwise transfer this Agreement, any interest or right under this Agreement (in whole or in part) without the prior written consent of Modulr. This clause shall have proprietary effect (goederenrechtelijke werking). 9.2. The Introduced Client agrees Modulr may, in its sole discretion, assign, or transfer some or all of its rights and obligations or delegate any duty of performance set out in the documents forming this Agreement. Modulr may subcontract any of its obligations under this Agreement.

9.3. In the event of any transfer of this Agreement by Modulr to another service provider, Modulr will notify the Introduced Client no later than two months before the proposed transfer; if the Introduced Client does not want to transfer to the new provider, the Introduced Client must notify Modulr of its objection in writing to Customer Services. On receipt of such notification, Modulr will terminate this Agreement. Any balance remaining in the Introduced Client’s Account(s) will be returned to the Introduced Client in accordance with the redemption procedure set out in the Modulr Account Terms and Conditions.

10. Liability

10.1. Nothing in this Agreement will operate to limit either party’s liability with respect to fraud or for death or personal injury resulting from negligence, in either case whether committed by that party or its employees, agents or subcontractors.

10.2. Modulr makes no warranty that access to and use of the Modulr Products will be uninterrupted or error free.

10.3. The Introduced Client acknowledges and agrees that Modulr is not liable to the Introduced Client for any loss, liability or damages the Introduced Client suffers which result from, are related to, or in any way are connected with any fraud control, restriction measures, or other measures implemented from time to time including as required for compliance with legal and regulatory requirements, unless such loss, liability or damage is a direct result of Modulr’s fraud, gross negligence or willful misconduct in procuring the implementation of fraud control or purchase restriction measures that Modulr has expressly agreed in writing to procure for the Introduced Client.

10.4. Modulr shall not be liable to the Introduced Client for any loss or damage the Introduced Client may suffer as a result of any act or omission of an Authorised User or Cardholder or an Authorised User’s use or Cardholder’s use or inability to use of the Modulr Products. 10.5. The Introduced Client agrees to indemnify Modulr against any and all actions, claims, costs, damages, demands, expenses, liabilities, losses and proceedings Modulr directly or indirectly incurs or which are brought against Modulr if the Introduced Client, or an Authorised User, or a Cardholder has acted fraudulently, been negligent or has misused a Modulr Product or any of the services provided under this Agreement.

10.6. Modulr shall not be responsible in any way for any interest or claims of any third parties in respect of the Modulr Products, except as required by law or regulation.

11. Reports

11.1. Modulr may make available certain management or other reporting or business administration functionality via the Website.

11.2. Modulr may from time to time amend, modify, replace or withdraw in whole or in part such reporting it provides without further notice.

12. Data Privacy

12.1. Modulr will collect and retain personal information about the Introduced Client and each Authorised User and Cardholder to enable Modulr to deliver the Modulr Products, the services linked to it and deal with any enquiries that the Introduced Client may have about it. Modulr is the data controller of the personal information gathered by Modulr for such purpose. If Modulr uses a third party to provide a part of the Modulr Product then that provider will be the owner and controller of the personal information they require to collect in order to operate the relevant service. The use of personal information by third-party service providers will be set out in their service terms and conditions of use.

Modulr will, at such third-party provider’s direction, process personal data on its behalf, for example, to enable Modulr to provide Customer Services to the Introduced Client.

12.2. Modulr processes personal information in accordance with relevant laws on the protection of personal data.

12.3. If Modulr transfers the Introduced Client’s information to a third party in a country outside of the European Economic Area Modulr will ensure that the third party agrees to apply the same levels of protection that Modulr is legally obliged to have in place when Modulr processes personal data.

12.4. Further information about how Modulr uses personal information can be found in Modulr’s Privacy Policy; please contact Customer Services for a copy of this.

13. Changes to the Agreement

13.1. Modulr may amend or modify this Agreement by giving two months’ notice to the Introduced Client unless Modulr is required to make such a change sooner by law. All proposed changes will be posted on the Website and communicated to the Introduced Client by such other means that Modulr agreed with the Introduced Client, for example by email. If the Introduced Client is accessing Modulr Products via a Partner Platform, all notifications will be communicated via such Partner Platform.

13.2. The Introduced Client has no obligation to accept such amendments proposed by Modulr. 13.3. The Introduced Client will be taken to have accepted any change to this Agreement that Modulr notifies to the Introduced Client unless the Introduced Client tells Modulr otherwise before the relevant change takes effect. In such circumstances, Modulr will treat notice of objection by the Introduced Client as notification that the Introduced Client wishes to terminate this Agreement and the use of all Modulr Products immediately. All Accounts of the Introduced Client will be closed and any balance remaining in the Introduced Client’s Account will be returned to the Introduced Client in accordance with the redemption procedure set out in the Modulr Account Terms and Conditions. In such circumstances, the Introduced Client will not be charged a fee for the Account closure and return of any balance.

14. General

14.1. In these Introduced Client Terms of Business, headings are for convenience only and shall not affect the interpretation of these Introduced Client Terms of Business.

14.2. Any delay or failure by Modulr to exercise any right or remedy under this Agreement shall not be interpreted as a waiver of that right or remedy or stop Modulr from exercising its rights at any subsequent time.

14.3. In the event that any part of this Agreement is held not to be enforceable, this shall not affect the remainder of the Agreement which shall remain in full force and effect.

14.4. The Introduced Client shall remain responsible for complying with this Agreement until its Account(s) are closed (for whatever reason) and all sums due under this Agreement have been paid in full.

14.5. This Agreement is written and available only in English and all correspondence with the Introduced Client shall be in English.

14.6. Exclusion of relevant statutory provisions: the following provisions of the Netherlands Civil Code do not apply in the relationship between Modulr and the Introduced Client: articles 7:516, 7:517, 7:518 and 7:519, article 7:520(1), article 7:522(3), article 7:527, articles 7:529 to 7:531, article 7:534 and articles 7:543, 7:544 and 7:545 Netherlands Civil Code and all legislation pursuant to and/or based on such articles. Furthermore, if not already covered by the articles referred to in the preceding sentence, the rules regarding provision of information in the Market Conduct Supervision (Financial Institutions) Decree (Besluit gedragstoezicht financiële ondernemingen Wft) that follow from Title III PSD2 do not apply.

The above contains the exclusion of the relevant provisions of PSD2 as implemented in Dutch law. Consequently, all rules with regard to the content and provision of the information required by Title III of PSD2 and the following provisions of Title IV of PSD2 do not apply to this Agreement: article 62(1), article 64(3), article 72, article 74, article 76, article 77, article 80 and article 89 of PSD2 and all legislation pursuant to and/or based on such articles. This clause shall not apply if the Introduced Client is a Consumer

14.7. This Agreement – and any contractual and non-contractual obligation pursuant hereto - is governed by the laws of the Netherlands and the Introduced Client agrees that any disputes hereunder (including non-contractual disputes) shall be under the exclusive jurisdiction of the competent Courts of Amsterdam.

Schedule 1: Card Obligations

1. Introduction

1.1.The terms of Schedule 1 shall apply where Virtual Cards and/or Physical Cards are included within the Modulr Products.

2. Transactions Disputes and Chargebacks

2.1.For the purposes of these Introduced Client Terms of Business, a “Chargeback” means a refund of a Card Transaction after the Introduced Client (or Modulr on its behalf) successfully disputes the Card Transaction as permitted by the Card Scheme rules.

2.2.The Introduced Client shall provide Modulr all relevant information in relation to Virtual Card Transaction as may be required by Modulr to resolve the dispute in accordance with applicable law and, where applicable, to raise a Chargeback in accordance with Card Scheme rules.

2.3.The Introduced Client agrees that Card Scheme’s decision on the validity of the Chargeback is final and binding and that in the event a Chargeback is not successful or is subsequently reversed the Introduced Client will be liable for the amount of the disputed Card Transaction.

2.4.Modulr shall at its discretion not refund a Chargeback to the Introduced Client until the relevant challenge periods have passed under the relevant Card Scheme rules unless it is required to do under relevant law or regulation.

3. Cardholders

3.1.Where corporate Cards are made available to the Introduced Client as part of Modulr Products, Introduced Client will be able to designate individuals as Cardholders permitted to use certain Cards. 3.2.The Introduced Client must notify Modulr of all individuals it wishes to be Cardholders and shall not permit any other person to use the Cards.

3.3.The Introduced Client shall be responsible for ensuring that each Cardholder is informed of the Modulr Account Terms and Conditions as they apply to the Cards and the Introduced Client shall ensure that the Cardholder complies with them.

3.4.In addition to clause 3.3 above, Introduced Client shall be responsible for ensuring that each Cardholder reads and accepts the Modulr Corporate Cardholder Terms and Conditions, which shall be made available to the Cardholder by the Introduced Client. Introduced Client shall keep a record of each Cardholder’s confirmation given in accordance with this clause and shall promptly make such records available to Modulr on request.

3.5.The Introduced Client shall ensure its Cardholders take all reasonable care to keep any security credentials relating to the use of Cards, such as PIN or any access or similar codes, where applicable, confidential and in accordance with the Modulr Account Terms and Conditions and Corporate Cardholder Terms and Conditions. Where Cards are enabled to be registered/stored within third party apps/devices, the security credentials relating to those third party apps/devices will also be deemed to be security credentials relating to the use of Cards.

3.6.The Introduced Client acknowledges and agrees that each Cardholder is authorised by the Introduced Client to act on its behalf. Modulr shall deem any instruction given by a Cardholder with respect to Card Transactions as an instruction given by the Introduced Client and the Introduced Client shall be responsible for all actions and the use of Physical Cards by any Cardholder.

3.7.In the event of any changes to this Agreement, Modulr Account Terms and Conditions and/or the Modulr Corporate Cardholder Terms and Conditions, or if the Introduced Client’s Account and/or Card is suspended, cancelled or terminated, it is the Introduced Client’s responsibility to communicate any such changes and/or any information regarding the suspension, cancellation or termination to each Cardholder.

4. Withdrawal of Cards; Change of Card Scheme; and Conditions for Tokenisation Services

4.1.Modulr reserves the right to:

4.1.1. cease providing Cards as part of Modulr Products for any reason; 4.1.2. provide Cards issued under a different Card Scheme; and

4.1.3. cease or amend the ability for Cards to be registered/stored within one or more third

party apps/devices.

4.2. Modulr shall provide to Introduced Client tokenisation services subject to, where applicable, prior approval of the Introduced Clients by the relevant tokenisation provider (Apple Pay and/or Google Pay). Modulr shall not be liable to the Introduced Client in the event approval is not granted or is later withdrawn by the relevant tokenisation provider.

The Modulr Account Terms and Conditions; Important information you need to know Please read these Terms and Conditions carefully before you agree to use an Account or any related services provided by or through us.

These Terms and Conditions, together with the Introduced Client Terms of Business constitute the entire agreement between Modulr and you.

By accepting the Modulr Account Terms and Conditions you accept the terms of the Agreement, or by agreeing to open an Account and/or using our services, you accept these Terms and Conditions. If there is anything you do not understand, please contact Customer Services.

1. DEFINITIONS

3DS - means the EMV 3DS service offered by us for you or a Cardholder to use when you or a Cardholder make a purchase or place an order on the internet with your Card.

Account - The electronic money account, also known as Modulr Account provided by us in accordance with these Terms and Conditions.

Account Information Service Provider – means a third party payment service provider who is authorised by or registered with De Nederlandsche Bank N.V. or another European regulator to provide online account information services, who, with your permission will be able to access certain online account information on one or more payment accounts held by you to give you a consolidated view of your payment accounts.

Account Limits – any limit that applies in relation to your Account and/or Card, such as account maximum balance, and limits on receiving and sending payments from your Account as referred in paragraph 2.

Account Manager - The individuals elected by the Account Owner to be responsible for the management of the Account, also known as an “Authorised User”.

Account Owner – The entity legally responsible for an Account.

Agreement - The agreement for your Account made up of these Terms and Conditions, together with the Introduced Client Terms of Business, which constitute the entire agreement between you and Modulr.

Application Programming Interface (API) – means the interfaces provided by Modulr to the Introduced Client (and the Partner Platform on the Introduced Client’s behalf) to directly instruct Modulr Accounts via the Introduced Client’s or the Partner Platform’s own application.

AML Policy - Modulr’s written policy on anti-money laundering and counter terrorist financing as may be amended from time to time by Modulr.

Applicant – A customer of the Partner Platform who applies for Modulr Products but is yet to be accepted by Modulr as an Introduced Client.

Available Balance - The value of funds available on your Account.

Bacs Credit – Means Bacs Direct Credit. A service enabling organisations to make payments to an account which takes 3 Business Days for the funds to be cleared.

Business Days - Monday to Friday between the hours of 9am-5pm but does not include bank holidays, or public holidays in the Netherlands.

Card – means a Virtual Card or a Physical Card.

Cardholder - means the individual authorised to use the Physical or Virtual Card issued to you.

Card Scheme -Mastercard and/or Visa or such other payment network through which Card Transactions are processed as may be made available to you from time to time.

Card Transaction –means a Virtual Card Transaction or a Physical Card Transaction.

CHAPS – the Clearing House Automated Payment System, a service enabling organisations to make same-day payments to an account within the UK, within the CHAPS operating days and times.

Chargeback has the meaning given to it in Schedule 1 of the Introduced Client Terms of Business. Consumer - means a natural person not acting in the course of its business or profession.

Confidential Information - any information (whether or not recorded in documentary form, or stored on any magnetic or optical disk or memory) relating to: the business, products, affairs, strategy, contracts, customer relationships, commercial pipelines, business contacts, prospective customers, existing customers, business models, customer pricing, management

systems, business methods, corporate plans, maturing new business opportunities, research and development projects, marketing and sales information, sales targets and statistics, discount structures, suppliers and potential suppliers, source codes, computer programs inventions, know-how, technical specifications and other technical information relating to products and services.

Customer Services - The contact centre for dealing with queries about your Account.

Data Protection Laws – means all laws relating to the processing of Personal Data, privacy and security, including, without limitation, the EU Data Protection Directive 95/46/EC, the Dutch GDPR Implementation Act (Uitvoeringswet Algemene Verordening gegevensbescherming) (as may be amended from time to time) and the General Data Protection Regulations (EU) 2016/679 ("GDPR") together with equivalent legislation of any other applicable jurisdiction, delegated legislation of other national data protection legislation, and all other applicable law, regulations and approved codes of conduct, certifications, seals or marks in any relevant jurisdiction relating to the processing of personal data including the opinions, guidance, advice, directions, orders and codes of practice issued or approved by a supervisory authority or the Article 29 Working Party or the European Data Protection Board.

Due Diligence Procedure - Modulr’s procedures for carrying out due diligence on Introduced Clients in order to comply with its policies and regulatory obligations.

Faster Payment - A service allowing you to make and receive electronic GBP payments in the which is received by the recipient bank within 2 hours provided that the receiving organisation or bank is part of Faster Payments Scheme.

Information – Means any information related to the organisation, and any personal information related to Account Manager or the Cardholder.

Intellectual Property Rights – means without limitation all patents (including models and inventions), trademarks, service marks, trade names, internet designations including domain names, business names, copyrights, design rights, database rights, rights to or in computer software, know-how, trade secrets, rights to or in confidential information and all other intellectual property rights and rights or forms of protection of a similar nature or effect which may subsist anywhere in the world whether or not registered or capable of registration, together with all applications for registration of, and any licence to use, any of the foregoing and "Intellectual Property" shall be construed accordingly;

Introduced Client – Any client of Modulr which has been introduced by the Partner Platform and whose account is operated by the Partner Platform based on instructions the Partner Platform receives from the Introduced Client (where relevant). Introduced Client Terms of Business - The terms on which Modulr provides Modulr Products to the Introduced Client. Merchant- means a merchant authorised to accept Card Scheme-branded Cards.

Modulr Account Terms and Conditions - This agreement, between Modulr and the Introduced Client which governs the terms on which the Introduced Client may use its Account.

Modulr Products – those products, including but not limited to the Account described by the Partner Platform in the application process.

One-Time Passcode – means the six-digit passcode sent to your mobile phone number by us, via SMS. Online Portal – means the interface provided by Modulr for the Introduced Client to access via the public internet, subject to applicability based on the Introduced Client’s relationship with the Partner Platform and can be used for the management of accounts.

Partner Platform – A third party that is permitted by Modulr to introduce and act on behalf of Introduced Clients, and permitted by you to act as an Authorised User.

Partner Platform Agreement - an agreement between the Introduced Client and the Partner Platform for the provision of various services, under the terms of which the Introduced Client wishes to open an Account with Modulr to be used for the purpose and in accordance with the terms set out in the Partner Platform Agreement.

Payment Initiation Service Provider – means a third party payment service provider authorised by or registered with De Nederlandsche Bank N.V. or another European regulator to provide an online service to initiate a Transaction at your request on your Account.

Physical Card - means a physical card-based payment instrument issued by us to you which uses the Card Scheme payments network, as well as any version or record of such an issued payment instrument stored on an app or other platform, and which may be used to make Physical Card Transactions.

Physical Card Transaction - means the use of a Physical Card to make a payment to a Merchant.

Regulator – De Nederlandsche Bank N.V., located at Spaklerweg 4, 1096 BA Amsterdam, Netherlands or any authority, body or person having, or who has had, responsibility for the supervision or regulation of any regulated activities or other financial services in the Netherlands.

SEPA – the Single Euro Payments Area is the area where citizens, companies and other economic actors can make and receive payments in euro, within Europe, whether within or across national boundaries under the same basic conditions, rights and obligations, regardless of their location. SEPA is driven by the European Commission and the European Central Bank, amongst others, as a key component of the EU Internal Market. SEPA shall be deemed to encompass the countries and territories which are part of the geographical scope of the SEPA Schemes, as listed in the EPC List of SEPA Scheme Countries, as amended from time to time.

SEPA Credit Transfer - a service allowing you to make and receive non urgent EUR electronic payments within SEPA provided that the receiving organisation or bank is part of the scheme.

SEPA Instant Credit Transfer - a service allowing you to make and receive near real time EUR electronic payments within SEPA provided that the receiving organisation or bank is part of the scheme.

SEPA Transfers – means, together, SEPA Credit Transfer and SEPA Instant Credit Transfer.

SWIFT – the global member-owned financial telecommunications system used to facilitate the secure transfer of messages, including payment instructions, between financial institutions.

SWIFT Inbound Payment – an inbound payment (in such currencies as may be supported by Modulr from time to time) made via SWIFT.

SWIFT Outbound Payment – an outbound payment (in such currencies as may be supported by Modulr from time to time) made via SWIFT.

SWIFT Payments – means, together, SWIFT Inbound Payments and SWIFT Outbound Payments (and SWIFT Payment shall be construed accordingly).

Transaction – any debit, credit or other adjustment to an Account that affects the balance of monies held in it, including a Card Transaction.

TPP (Third Party Provider) – means an Account Information Service Provider or a Payment Initiation Service Provider.

we, us, our or Modulr - Modulr Finance B.V., a company registered in the Netherlands with number 81852401, whose registered office is at Weteringschans 165 C, 1017 XD Amsterdam and who is regulated by De Nederlandsche Bank N.V. for issuance of electronic money under reference number R182870.

Virtual Card – means a virtual card-based payment instrument consisting of (amongst other things) a unique 16 digit account number issued to you which uses the Card Scheme payments network, as well as any version or record of such an issued payment instrument stored on an app or other platform, and which may be used to make Virtual Card Transactions. Virtual Card Transaction – means the use of a Virtual Card to make a payment to a Merchant.

Website – means the customer portal that Introduced Clients can login to in order to use the Modulr Products. you, your - The Account Owner, also referred to as an Introduced Client.

2. ACCOUNT & CARD LIMITS

2.1 Limits may apply to the balance on your Account at any time, the maximum value of an individual payment Transaction, maximum Virtual Transaction value per Card, the maximum aggregate value of all payment Transactions made from your Account or Cards in a particular time period e.g. during any one Business Day and the maximum number of payment Transactions made from your Account over a particular timeframe. Your Cards may also have certain Card Transaction types disabled, such as cash withdrawals at an ATM.

2.2 The limits and restrictions that apply to your Account and Card will be communicated to you during the Account set-up process and/or before the Card is issued to you (as applicable). These limits may also change over time based on your Account and/or Card usage; any such change will be communicated to you. You can check the limits at any time by contacting Customer Services. You should not make a payment Transaction request which exceeds such.

2.3 From time to time a Card Transaction may be authorised which exceeds the limit or restriction applicable to your Account or Card, for example when it is used in an offline environment for example but not limited to payments for or on transport (purchases on a train, aeroplane, underground or toll payments). In such circumstance, a negative balance on your Account may occur. In this case the process in paragraphs 5.15 to 5.17 inclusive will apply.

2.4 Certain Merchants may require verification that the funds held on your Account will cover the Card Transaction amount and will place a “pre-authorisation” on your Card. This amount will be unavailable to you until the Card Transaction is completed or released by the Merchant. The pre-authorisation allows the Merchant up to 30 days to claim and settle any funds owed to them from the Card. Examples include but are not limited to hotels and rental cars. If there are insufficient funds available on your Account, Modulr must still make this settlement, which may result in a negative balance on your Account. In this case the process in paragraphs 5.15 to 5.17 inclusive will apply.

2.5 To manage our risk, particularly with respect to money laundering, fraud or security concerns, we also apply internal controls, including limits, to certain types of payment. We change these as necessary but for security purposes, we do not disclose them.

3. SCOPE OF THESE TERMS AND CONDITIONS

3.1 Your Account is an electronic money account (and therefore is not a traditional bank account) and the electronic money and any Card associated with it is issued to you by us. We are regulated by De Nederlandsche Bank N.V. for the issuance of electronic money. Your rights and obligations relating to the use of this Account are subject to these Terms and Conditions between you and us.

3.2 The types of Transactions enabled for your Account will be explained to you by the Partner Platform, or as

subsequently enabled by us. The terms of these Modulr Account Terms and Conditions applicable to specific Transactions or payment types (for example, Cards) apply only to the extent that such Transactions or payment types are enabled for your Account. 3.3 This Agreement is written and available only in English and we undertake to communicate with you in English regarding any aspect of your Account.

3.4 You agree that we or the Partner Platform may communicate with you by e-mail or telephone for issuing any notices or information about your Account and therefore it is important that you ensure you keep your e-mail address and mobile phone number updated.

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3.5 You can request a copy of these Terms and Conditions at any time by contacting Customer Services. 3.6. By accepting these Terms and Conditions, you acknowledge that the Dutch Deposit Guarantee Scheme or other government sponsored insurance does not apply to funds held in the Account.

4. OPENING YOUR ACCOUNT

4.1 Your Account will be opened on your behalf by the Partner Platform. You may only hold an Account so long as you remain an approved client of the Partner Platform that provided you with your account details.

5. USING THE ACCOUNT

5.1 Your Account can receive bank transfers and other payment types as added and notified to you by Modulr from time to time. Subject to paragraph 5.3, we will credit your Account when we receive the funds which could be up to three Business Days after the payment being instructed, depending on how the payment was sent.

5.2 Your Account can also receive internal transfers from other Modulr Accounts owned or controlled by the Partner Platform, which apply instantly.

5.3 An incoming payment will not be credited to your Account if:

5.3.1 the Account has reached the Account Maximum Balance or Account Limits; or 5.3.2 the Account is blocked or terminated; or

5.3.3 the sender has provided incorrect/invalid Account Details for your Account; or 5.3.4 we suspect the payment to be fraudulent.

5.4 If we are unable to credit your Account for any of the reasons in paragraph 5.3 then the funds may be sent back to the sender without a prior notification to you.

5.5 Your Account will be configured and operated by the Partner Platform. You agree that Modulr and we may take instructions from the Partner Platform regarding the operation of your Account, including the creation of beneficiaries and instruction of payments, on your behalf. We and Modulr have no liability for actions taken by the Partner Platform. If you disagree with any actions taken by the Partner Platform these should be discussed with the Partner Platform. We are also authorised to take instructions from any other Account Manager (where different from Partner Platform) and, with respect to Physical Card Transactions, from the Cardholder. You are responsible for all actions of the Account Manager and any Cardholder in relation to the Account and/or Card(s).

5.6 Your Account can make payments out to external bank accounts via SEPA Transfer, Faster Payments, SWIFT Payments (if selected as a Modulr Product) and other methods as added and notified to you by the Partner Platform from time to time.

With regard to SEPA Transfers, Modulr will automatically process inbound and outbound SEPA payments via SEPA Instant Credit Transfers where possible. In the event Modulr is unable to process such payments via SEPA Instant Credit Transfers, the payments will default to being made via SEPA Credit Transfers.

5.7 Where Cards are made available to you, , your Account can be used to fund Card Transactions. You or your Account Manager or Partner Platform can request a Virtual Card or a Physical Card to be issued to you via the Online Portal or Modulr API.

5.8 Where a Virtual Card or Physical Card is issued to you, you may be able to register and/or store the details of the Card within third party apps and/or devices and to use those third party apps/devices to initiate payments with your Card. When you first register your Card within a third party app/device we support, you may be required to verify that it is you requesting the registration of the Card. If you do not do this, you may not be able to register and use your Card through the third party app/device.

5.9 The value of any Card Transaction, together with any applicable fees and charges, will be deducted from your Account once we receive the authorisation request from the Merchant.

5.10 If the Card Transaction is made in a currency other than the currency the Card is denominated in, the Card Transaction will be converted to the currency of the Card by the relevant Card Scheme at a rate set by it on the day we receive details of the Card Transaction. The exchange rate varies throughout the day and is not set by us. You can check the relevant Card Scheme rate as follows.

Mastercard Card Scheme rate at: https://www.mastercard.co.uk/en-gb/consumers/get-support/convert-currency.html; VISA Card Scheme rate at: https://www.visa.co.uk/support/consumer/travel-support/exchange-rate-calculator.html. 5.11 If you use the Card to make a purchase online you may be asked by the Merchant to use 3DS. Physical Cards are automatically enrolled for use with 3DS. When you use 3DS, you agree that the following shall apply in relation to your use of the Card:

5.11.1 You must provide us with your mobile phone number before you can use 3DS. You must ensure that your mobile phone can receive SMS at the time of your purchase.

5.11.2 When you use 3DS to purchase from a participating Merchant, you will be presented with an electronic receipt and the One-Time Passcode will be sent to your mobile phone.

5.11.3 Without your One-Time Passcode, you will not be able to make purchases from participating Merchants. 5.11.4 If you update your mobile phone number then you must notify us immediately of your new details, to ensure our records are correct.

5.11.5 The One-Time Passcode is valid for the purchase you received it for. You are responsible for the security and confidentiality of your One-Time Passcode and must not share it with anyone else.

5.11.6 You will be responsible for any fees or charges imposed by your mobile phone service provider in connection with your use of 3DS.

5.12 A Transaction is deemed to be authorised by you, when you or your Account Manager or Partner Platform: 5.12.1 enters the security information on the Modulr Online Portal to confirm a Transaction is authorised, or when it is instructed via the Modulr API with the relevant security credentials;

5.12.2 when you or your Account Manager or Partner Platform submits a request for a creation of a Virtual Card via the Online Portal or Modulr API, you shall be deemed to have authorised any subsequent Virtual Card Transaction made using such Virtual Card up to the authorisation value specified when creating the request for creation of the Virtual Card; 5.12.3 when you or the Cardholder (i) enter a PIN or provide any other security credentials; (ii) sign a sales voucher; (iii) provide the Physical Card details and/or provide any other details as requested; (iv) wave/swipe the Physical Card over a card reader; or (v) insert the Physical Card into a card device or an ATM;

5.12.4 when you give instructions through a third party (such as the recipient of a Payment Initiation Service Provider).

Once the Transaction is confirmed, we cannot revoke the Transaction save for in those circumstances set out in paragraph 5.13 below.

5.13 You can cancel any Transaction which is agreed to take place on a date later than the date you authorised it, provided that you give us notice to cancel no later than close of business on the Business Day before the Transaction was due to take place. 5.14 Cancelling a recurring Card Transaction with us will not cancel the agreement with the organisation you are paying. It is your responsibility to tell the organisation collecting the payment about the changes to your instructions. 5.15 If for any reason whatsoever, a negative balance arises because a Transaction is completed when there are not enough funds on your Account for that Transaction, you shall reimburse the negative balance amount immediately, unless circumstances described in sections 5.16 and 5.17 apply. You agree that once we make this negative balance known to you, we will charge you the amount of negative balance and you must repay it immediately. We may set-off the amount of the negative balance against any funds on your Account, including any subsequently loaded funds. Until we are reimbursed this negative balance amount, we may arrange for your Account, including Card(s) to be suspended. We may also report the negative balance to credit reference agencies.

5.16 Where a negative balance arises because of an error on the part of a Merchant where the Card Transaction occurred, we will seek to recover the negative balance amount from the Merchant.

5.17 Where a negative balance arises because of an error on the part of the recipient of the payment or us, we will seek to recover the negative balance amount from the person who made the error.

5.18 The Available Balance on your Account will not earn any interest.

5.19 You can check the balance and Transaction history of your Account at any time via the interface provided to you by the Partner Platform or by contacting Customer Services, or the Online Portal if you have relevant access details.

5.20 You will be provided with a monthly statement free of charge setting out information relating to individual payment Transactions by the Partner Platform or us (using the details we have associated with your Account).

6. THIRD PARTY ACCESS

6.1 You can instruct a TPP to access information on your Account or initiate certain Transactions from your Account provided such TPP has identified itself to us and it has acted in accordance with the relevant regulatory requirements. We will treat any instruction from an TPP as if it was from you or an Account Manager.

6.2 We may deny a TPP access to your Account if we are concerned about unauthorised or fraudulent access by that TPP. Setting out the reason for such denial. Before doing so, we will tell you that we intend to deny access and give our reasons for doing so, unless it is not reasonably practicable, in which case we will immediately inform you afterwards. In either case, we will tell you in the manner in which we consider most appropriate in the circumstances. We will not tell you if doing so would compromise our security measures or would otherwise be unlawful.

6.3 If you have provided consent to a TPP to access the data in your Account to enable them to provide account information services to you or initiate Transactions on your behalf, you consent to us sharing your information with the TPP as is reasonably required for them to provide their services to you. You must let us know if you withdraw this permission and we recommend you let the TPP know. On notification from you, we will not provide such TPP access to your Account or the data in it.

7. CLOSING YOUR ACCOUNT

7.1 You may close your Account by contacting Customer Services. Please refer to your contract with the Partner Platform for any terms relating to your need to maintain your Account.

7.2 The Account will be closed if the Partner Platform instructs us to close your Account (in which case the Partner Platform will inform you of this instruction).

7.3 On termination of the Agreement for any reason, these Terms and Conditions will automatically terminate, and your Account will be closed and any Cards issued to you will be cancelled.

7.4 Any Available Balance remaining on the Account after Account closure will be transferred to your nominated bank account via SEPA Transfer based on instructions to us from the Partner Platform. If for any reason this is not possible, such Available Balance will remain yours and you may at any time request a refund by contacting Customer Services. You will not have any access to your Account from the date of Account closure and this Agreement will terminate.

8. YOUR LIABILITY AND AUTHORISATIONS

8.1 You are responsible for understanding and complying with the Agreement including these Terms and Conditions. 8.2 We may at any time suspend, restrict or refuse to authorise any use of your Account, Cards (including cancelling Card(s)) or refuse to process your instructions or authorise any particular Transaction where:

8.2.1 we are concerned about the security of or access to your Account and/or your Card;

8.2.2 we know or suspect that that your Account and/or Card is being used in an unauthorised or fraudulent

manner; 8.2.3 we need to do so in order to comply with the law or otherwise for regulatory or crime prevention purposes; 8.2.4 the Transaction would breach the limits applicable to your Account and/or Card;

8.2.5 you, the Account Manager or the Cardholder breach an important part of these Terms and Conditions, or repeatedly breach any term in this Agreement and fail to resolve the matter in a timely manner.

8.3 If we cancel, suspend or restrict your Account and/or Card(s), or otherwise refuse to execute a payment order to or to initiate a Transaction, we will, without undue delay and provided we are legally permitted to do so, notify you or the Partner Platform of the refusal, suspension or cancellation (as applicable). If possible, we will provide the reasons for the refusal to execute the Transaction and/or suspending the use of your Account and/or Card and where those reasons relate to factual matters, the procedure of rectifying any factual errors that led to the refusal.

8.4 You, the Account Manager or Cardholder must not:

8.4.1 allow another person to use security information related to the Account, Cards, and/or app/device you use to make Transactions, write down password(s) or any security information unless this is done in a way that would make it impossible for anyone else to recognise any of that information, or

8.4.2 disclose passwords or any security information, or otherwise make them available to any other person, whether verbally or by entering them in a way that allows them to be observed by others.

8.5 You must take all reasonable steps to keep your Account and password(s) and any other security-related details safe, including the security-related details relating to any app and/or devices you have registered or stored your Card on, at all times. If you visit a website or receive a message that asks for your password, other than the Modulr website, this should be reported to us. If you are in doubt whether a website is genuine, you should contact Customer Services. If you have any indication that your Account, password or other security information has been compromised, you must immediately change your password and notify us as soon as possible.

8.6 In the event that a Transaction was not authorised by you, your Account Manager, a Cardholder or by a TPP on your behalf, we will refund the amount of the Transaction to the you immediately and in any event not later than the end of the Business Day immediately following notification of the unauthorised Transaction and your maximum liability in respect of the Transaction will be €50.

8.6.1 8.6 will not apply and you will bear all losses and liability for:

8.6.2 all Transactions that take place as a result of you or the Account Manager or Cardholder acting fraudulently or failing to comply with these Terms and Conditions with intent or gross negligence. Any such Transactions and any fees and charges relating to such Transactions will be deducted from the Available Balance on your Account.

8.6.3 all Transactions that the Partner Platform or any other Account Manager or Cardholder makes on your behalf as per this Agreement, along with those made by a TPP authorised by you to initiate a Transaction.

8.6.4 all unauthorised Transactions that arise from the use of lost or stolen Physical Cards, the Account or Card security information such as but not limited to the Online Portal log in details, API security details, Card number and CVV, if you, the Account Manager or Cardholder fail to keep the security features of the Account, Cards and/or app/device where your Card is registered/stored safe.

8.7 It is your responsibility to keep us updated of changes to your Information, including e-mail address and mobile numbers. Failure to do so may result in us being unable to contact you regarding your Account or to let you know about changes to these Terms and Conditions.

8.8 If you request to recall a Transaction due to an error or mistake caused other than by Modulr, we reserve the right to charge you (i) a handling fee of €25 per recall and (ii) any fee payable by Modulr to a third-party bank or institution for handling the recall.

8.9 You agree to indemnify and hold harmless, us, Modulr and our distributors, partners, agents, sponsors, and service providers and their group companies from and against the costs of any legal action taken to enforce this Agreement, including these Terms and Conditions and/or any breach of these Terms and Conditions by you.

9. DISPUTES AND INCORRECT TRANSACTIONS

9.1 If you (or an Account Manager or Cardholder) have a reason to believe that (i) a Transaction on your Account was unauthorised or was made incorrectly, (ii) a Physical Card is lost or stolen; or (iii) someone else (other than TPP) knows the security credentials or otherwise has unauthorised access to your Account and/or Card, you must inform us immediately by contacting Customer Services. After you notify us, we will replace a lost, stolen or misappropriated Physical Card and/or security credentials, as appropriate.

9.2 We will investigate your claim for a refund of unauthorised or incorrectly executed Transactions, provided at all times that you have notified us without undue delay of becoming aware of such incorrectly executed or unauthorised Transaction and in any case within the timeframes required by the Card Scheme rules if the incorrect Transaction relates to a Card Transaction and for all other Transactions within 13 months of the date of the relevant Transaction. We will not be liable for any unauthorised or incorrectly executed Transactions notified to us after this period.

9.3 If you dispute a Transaction:

9.3.1 subject to 9.3.2 and 9.3.3 we will immediately refund the amount to your Account to the position it would have been in if the unauthorised Transaction had not taken place. We will have no further liability to you. If we subsequently discover that you were not entitled to a refund, we shall treat the refund as a mistake and be entitled to reapply the Transaction; 9.3.2 if there are reasonable grounds for thinking that you may not be entitled to a refund (based on the evidence available to us at the time you report the unauthorised Transaction), we may investigate before giving you a refund and we will provide you with our supporting evidence if we believe you are not entitled to the refund; and

9.3.3 if the Transaction was initiated through a TPP, it is for the TPP to prove that, the Transaction was authenticated, accurately recorded and not affected by a technical breakdown or other deficiency linked to the TPP’s payment initiation service.

9.4. If an incorrect Transaction is paid into your Account that should not have, we will, where possible, immediately send the funds back to the bank acting for the person from whose account the Transaction was made. In such circumstance you agree to return the funds to us and provide such assistance that we require in recovering the amount from you. If we cannot recover the funds, we are required to provide sufficient details about you and the incorrect payment to the bank or institution that sent the payment to enable them to recover the funds.

9.5 You will be liable for all Transactions made from your Account if you (or the Account Manager or the Cardholder) have acted fraudulently or have failed with gross negligence:

9.5.1 to keep the security credentials used to access or use your Account and/or Card safe and secure or otherwise failed to comply with these Terms and Conditions in relation to the safety of your Account and/or Card; or 9.5.2 failed to notify us in accordance with 9.1 above.

9.6 You may be entitled to a refund where a Transaction from your account which was initiated by payee provided that: 9.6.1 the authorisation did not specify the exact amount;

9.6.2 the amount of Transaction exceeded the amount you could reasonably have expected (taking into your previous spending pattern and other relevant circumstances). We may ask you to provide such information as is reasonably necessary for us to determine if this is correct; and

9.6.3 you asked for a refund within 8 weeks of the date the Transaction was debited to your Account. In such circumstances we will refund you within 10 Business Days of receiving your claim for a refund or, where applicable, within 10 Business Days of receiving any further information we requested – or we will provide you with reasons for refusing the refund.

10. VARIATION

10.1 We may change these Terms and Conditions by providing you with at least two months’ prior notice by e-mail (provided you have supplied us with an up-to-date e-mail address).

10.2 If you do not agree with the changes to the Terms and Conditions, you may at any time within the two months’ notice period notify us and these Terms and Conditions will be terminated and your Account closed free of charge. If you do not notify us to the contrary during this period then you will be deemed to have accepted the change and it will apply to you when it comes into force.

10.3 If any part of these Terms and Conditions are inconsistent with any legal requirements then we will not rely on that part but treat it as if it did actually reflect the relevant legal requirement. If we need to make operational changes before we can fully comply with the new regulatory requirement, we will make those changes as soon as reasonably practical.

11. TERMINATION OR SUSPENSION

11.1 We can terminate your Account at any time if we give you two months’ notice and transfer any Available Balance at the time to your nominated bank account without a charge, or

11.2 We can suspend or terminate your Account at any time with immediate effect (and until your default has been remedied or the Agreement terminated) without any prior notice to you if:

11.2.1 we discover any of the Information that we hold for you is false, misleading or materially incorrect; or 11.2.2 if you, the Account Manager, the Cardholder or a third party has engaged in fraudulent activity, money laundering, terrorism, terrorism financing or other illegal activity in connection with your Account or we have reasonable suspicions in respect of same; or

11.2.3 if you have reached your Account Limit; or

11.2.4 you or the Account Manager have breached these Terms and Conditions; or

11.2.5 we are required to do so under any applicable law or regulation or at the direction of any regulatory,

law enforcement or other competent authority.

11.3 In the event that we do suspend or terminate your Account then if we are able to do so, we will tell you in advance otherwise we will let you know immediately afterwards (to the extent we are permitted by law).

12. OUR LIABILITY

12.1 Our liability in connection with this these Terms and Conditions (whether arising in contract, tort (including negligence), breach of statutory duty or otherwise) shall be subject to the following exclusions and limitations: 12.1.1 We shall not be liable for any default resulting directly or indirectly from any cause beyond our control, including but not limited to, a lack of funds;

12.1.2 We shall not be liable for any loss of profits, loss of business, or any indirect, consequential, special or punitive losses; 12.1.3 where sums are incorrectly deducted from your Available Balance due to our default, our liability shall be limited to payment to you of an equivalent amount to that which was incorrectly deducted from your Available Balance; 12.1.4 in all other circumstances of our default, our liability will be limited to transferring any Available Balance to your nominated bank account.

12.2 In circumstances where sums are incorrectly deducted from your Available Balance due to our fault, if we require your support to enable us to recover the incorrect deduction, you agree to provide us with all assistance that we reasonably require. 12.3 Nothing in these Terms and Conditions shall exclude or limit our liability for death or personal injury resulting from our negligence or fraud.

12.4 To the extent permitted by law, all conditions or warranties implied by law, statute or otherwise are expressly excluded. 12.5 The above exclusions and limitations set out in this paragraph shall apply to any liability of our affiliates and other suppliers, contractors, agents or distributors and any of their respective affiliates (if any), to you, which may arise in connection with these Terms and Conditions.

13. YOUR INFORMATION

13.1 Some personal data will be necessary for us to provide you with the Account and services under this Agreement. Modulr is a Data Controller and shall only use your personal data for this purpose. Please see the Privacy Policy (please contact Customer Services for details of where to access this) for full details on the personal data that we hold, how we will use it and how we will keep it safe. Modulr will at all times comply with Data Protection Laws.

13.2 We will retain details of individual transactions for six years from the date on which the particular transaction was completed. We will maintain all other records for six years from which we have ceased to provide you with any product or service.

13.3 You must update any changes to your Information by contacting Customer Services.

13.4 If we discover that the Information we hold about you is incorrect, we may have to suspend or cancel your Account until we can establish the correct Information, in order to protect us both.

13.5 If you or the Account Manager allow or give consent to an Authorised Third Party Provider to access your Account to provide their services, you should know that we have no control over how an Authorised Third Party Provider will use your information nor will we be liable for any loss of information after an Authorised Third Party Provider have access to your information.

14. COMPLAINTS PROCEDURE

14.1 Complaints regarding any element of the service provided by us can be sent to Customer Services. 14.2 All complaints will be subject to our complaints procedure. We will provide you with a copy of our complaints procedure upon request and, if we receive a complaint from you, a copy of our complaints procedure will automatically be posted or emailed to you.

14.3 In most cases we will provide a full response by email to your complaint within fifteen Business Days after the date we receive your complaint. In exceptional circumstances where we are unable to respond in full to your complaint, we will inform you of this giving our reasons for the delay and the timeframe within which you will receive a full reply, which in any event shall be within thirty-five days of the date we received your complaint.

14.4 If we fail to resolve your complaint to your satisfaction any disputes must be submitted to the exclusive jurisdiction of the competent courts in Amsterdam, the Netherlands except for as subject to your local statutory rights. If you qualify as a Consumer (i.e. non-business or professional user) you may also refer your complaint to the Financial Services Complaints Tribunal (Kifid – www.kifid.nl).

15. GENERAL

15.1 Any delay or failure to exercise any right or remedy under these Terms and Conditions by us shall not be construed as a waiver of that right or remedy or preclude its exercise at any subsequent time.

15.2 If any provision of these Terms and Conditions is deemed unenforceable or illegal, the remaining provisions will continue in full force and effect.

15.3 You may not assign or transfer any of your rights and/or benefits under these Terms and Conditions and you shall be the sole party to the contract between us. You will remain liable until the Account issued to you is terminated. We may assign our rights and benefits at any time without prior written notice to you. We may subcontract any of our obligations under these Terms and Conditions.

15.4 No third party who is not a party to these Terms and Conditions has a right to enforce any of the provisions in these Terms and Conditions.

15.5 You can obtain a copy of this Agreement at any time by contacting Customer Services.

15.6 These Terms and Conditions – including any contractual and non-contractual obligations hereto - are governed by the laws of the Netherlands and you agree to the exclusive jurisdiction of the Courts of Amsterdam.

15.7 This Account is not covered by a compensation scheme. As a responsible e-money issuer, we will ensure that once we have received your funds they are deposited in a secure account, specifically for the purpose of redeeming Transactions made from your Account and will be safeguarded in accordance with our obligations under the Dutch Financial Supervision Act (Wet op het financieel toezicht). In the event that we become insolvent funds that you have loaded which have arrived with and been deposited by us are protected against the claims made by our creditors in line with Dutch law.

15.8. Exclusion of relevant statutory provisions: the following provisions of the Netherlands Civil Code do not apply in the relationship between Modulr and the Introduced Client: articles 7:516, 7:517, 7:518 and 7:519, article 7:520(1), article 7:522(3), article 7:527, articles 7:529 to 7:531, article 7:534 and articles 7:543, 7:544 and 7:545 Netherlands Civil Code and all legislation pursuant to and/or based on such articles. Furthermore, if not already covered by the articles referred to in the preceding sentence, the rules regarding provision of information in the Market Conduct Supervision (Financial Institutions) Decree (Besluit gedragstoezicht financiële ondernemingen Wft) that follow from Title III PSD2 do not apply. The above contains the exclusion of the relevant provisions of PSD2 as implemented in Dutch law. Consequently, all rules with regard to the content and provision of the information required by Title III of PSD2 and the following provisions of Title IV of PSD2 do not apply to this Agreement: article 62(1), article 64(3), article 72, article 74, article 76, article 77, article 80 and article 89 of PSD2 and all legislation pursuant to and/or based on such articles. This paragraph shall not apply if the Introduced Client is a Consumer.

16. CONTACTING CUSTOMER SERVICES

16.1 Customer Services are provided by the Partner Platform. The details shall be provided by Partner Platform.

About your contract with Modulr

The purpose of this explanatory note is to highlight the key points which are included within your contract with Modulr (the Modulr Contract). We know that agreements relating to financial services can be complicated so have put together this reference document to help.

The Modulr Contract may refer to some payment methods, for example CHAPs and the use of cards (Payment Methods), which may not apply to you. If that is the case, then the terms and conditions relating to those Payment Methods do not apply to you.

1. Who is Modulr?

Modulr is not a bank, we are an Electronic Money Institution (EMI) which helps businesses receive and make payments more easily. This is achieved by Modulr providing Seapoint with access to our technology and our connectivity to various payment systems so that Modulr can then provide its electronic accounts and payment services to you.

Modulr carries out several activities which are known as payment services and that means we are required to be authorised by the De Nederlandsche Bank N.V.. Modulr’s authorisation relating to its electronic money accounts can be found here under reference number R182870.

Why do I need these services from Modulr?

You are a customer of Seapoint and as a part of their services you require access to a Modulr electronic money account (Modulr Payment Account) and various Payment Methods, which Seapoint is not authorised to provide to you directly. Seapoint works with Modulr to enable you to have access to these regulated services.

A Modulr Payment Account will allow you to:

  • Receive payments into this account from an external bank account.
  • Make payments from this account to another account (whether held or not held by Modulr). •Check the

balance and transaction history on the account (when this functionality is enabled on your account) Payments will be made using the Payment Methods provided by Modulr (or the external third-party bank).

2. Opening your Modulr Payment Account

What do I need to do to open a Modulr Payment Account?

1. Agree to the Modulr Contract. This confirms that you accept the terms and conditions relating to Modulr providing its regulated services to you. By agreeing to these terms, you also agree to Modulr requesting identification documents from you to check your identity. This is something which Modulr is required to do to provide its regulated services to you.

2. Once you have signed the Modulr Contract, and Modulr has confirmed to Seapoint that you have passed Modulr’s identity checks, Seapoint will open a Modulr Payment Account on your behalf. This is also the time when your Modulr Contract will start. The Modulr Contract will continue until you, Modulr, or Seapoint asks for the contract to end.

3. Once your Modulr Payment Account is open, you will need to follow the requirements of your Modulr Contract. For example, we ask you to keep your security details safe and not engage in fraudulent activity.

Will Modulr share my information with other people?

To provide our regulated services to you, Modulr will be required to collect and store your personal information. Sometimes we may need to share this information with others so that we can meet our own legal requirements. Further information on the type of information Modulr collects, why this information is collected and what this information is used for can be found on our privacy policy.

If you have consented to another provider (such as an Account Information Service Provider, called a Third Party Payment Service Provider (TPP)) to have access to data relating to your Modulr Payment Account to enable the TPP to provide services to you, then you consent to Modulr providing the TPP with the data that it needs to provide its services to you. If you no longer consent to Modulr providing data to a TPP, you must let us know as soon as possible.

Do I need to pay Modulr for my Modulr Payment Account?

You don’t need to pay any fees to Modulr. Fees may need to be paid to Seapoint, as a part of the services which they provide to you.

How long will I have my Modulr Payment Account for?

You will have a Modulr Payment Account for as long as you remain a customer of Seapoint, and you continue to follow the requirements of the Modulr Contract. Of course, if you no longer want to use your Modulr Payment Account, you can close it any time by contacting Seapoint.

What if Modulr transfers its rights under the Modulr Contract to another provider?

We may transfer some or all of our rights and duties under your Modulr Contract to another service provider in the future, and if we do this, your Modulr Contract will continue with that service provider.

3. Making/receiving payments to my Modulr Payment Account

How long will it take for me to make/receive a payment to my Modulr Payment Account?

Once Modulr receives an instruction from you or Seapoint to make a payment from one account to another, we will ensure that the payment transaction is carried out according to the timeframe required by the Payment Method and relevant payment systems. When the payment will be received will depend on the time frame set out by the Payment Method and relevant payment systems.

Can I cancel payments from or to my Modulr Payment Account?

You can cancel any transaction which is agreed to take place on a future date, but you must notify Seapoint as soon as possible. However, we may not be able to cancel the transaction depending on the type of Payment Method used.

Are there any limits on my Modulr Payment Account?

Depending on the types of Payment Methods used, there may be limits on your Modulr Payment Account. This will be communicated to you by Seapoint when your Modulr Payment Account is being set up.

Requests for payments into your Modulr Payment Account will not be performed if:

  • Your Modulr Payment Account has reached any limits which may be in place.
  • Your Modulr Payment Account is blocked or has been closed.
  • The person making the payment has provided the incorrect account details for your Modulr Payment

Account.

  • We suspect that the payment may be fraudulent.

In such circumstances the funds may back sent back to the sender without prior notification to you.

4. Keeping your Modulr Payment Account and your e-money safe

How is Modulr different from a bank?

As Modulr is not a bank, it cannot provide bank accounts. Modulr can’t lend money or use money which it holds for the purposes of lending that money to others. Instead, Modulr provides payment accounts. Seapoint will provide you with access to our technology, including our connectivity to various Payment Methods so that Modulr can then provide its electronic accounts and payment services to you.

As the Modulr Payment Account is not a bank account:

  • Funds in the account will not earn any interest.
  • Funds in the account will not be protected the Deposit Guarantee Scheme, which protects money in

Dutch bank accounts up to a maximum of €100,000 per person, per bank

So, how does Modulr protect my money?

Modulr, as an EMI, is required by law to ensure that your money is protected. This protection is called safeguarding. This means that all the money which you send to your Modulr Payment Account must be protected by Modulr. Modulr does this by opening a separate bank account for its customers with a safeguarding partner in accordance with the relevant law. This bank account will be separate from Modulr’s own funds and will have the same amount of money in it which you have put into the Modulr Payment Account.

For example, if €1 is sent to your Modulr Payment Account, Modulr will put €1 into a separate bank account with its safeguarding partner.

If Modulr is unable to pay its debts, and is required to close its business:

  • an independent insolvency professional will be appointed to return your funds to you; and - the funds in your Modulr Payment Account will be separate from Modulr’s own funds. Therefore, if Modulr owes money to other companies, your funds will not be used to pay this off. However, if Modulr does not have sufficient money to pay for the costs of the insolvency practitioner then their costs may be taken from your funds before your funds are returned to you.

Further information on Modulr’s safeguarding practices can be found here.

How do we protect your Modulr Payment Account

Modulr takes the protection of your Modulr Payment Account very seriously. We have secure systems in place to help us do this and we work with Seapoint to ensure that your personal information and any security details (such as passwords) are kept safe. If you have access to your Modulr Payment Account, you must also keep safe any security details provided to you. You can contact Seapoint if you have any questions on this.

What if I notice a payment to or from my Modulr Payment Account which I don’t recognise?

If you notice that a payment is incorrect, please contact Seapoint. Seapoint will then contact Modulr on your behalf. Once Modulr has completed its investigation, we may refund or reverse a payment transaction depending on our findings.

You will be responsible for any loss caused to Modulr, including financial losses, when that loss was caused by:

  • Fraudulent use of your Modulr Payment Account.
  • Irresponsible use of your Modulr Payment Account.
  • Misuse of your Modulr Payment Account.

We are not responsible for any losses which are caused by:

  • Events which are unusual or outside of our control, like telephone or internet failures.
  • Modulr’s failure to implement any controls which we agreed with you in writing to implement.
  • Actions or failures by you, or anybody authorised by you to use your Modulr Payment Account.

We are also not responsible for:

  • Claims against us made by any other service providers in relation to the Modulr Payment Account or any of its payment services unless this is required by law.
  • Any business losses that you may suffer from.

5. Who has access to my Modulr Payment Account?

As your Modulr Payment Account is opened by Seapoint, Seapoint will usually have access and will be able to authorise transactions from your Modulr Payment Account.

You may also have access to, and can authorise transactions for, your Modulr Payment Account depending on the services that Seapoint is providing to you. If you have any questions relating to this, you should contact the Seapoint’s customer services.

Can Modulr access and make payments from/to my Modulr Payment Account?

We may suspend, restrict, or refuse to authorise use of your Modulr Payment Account, or a particular transaction where:

  • We are concerned about the security of or access to your Modulr Payment Account. •We know or suspect that your Modulr Payment Account is being used in an authorised or fraudulent manner.
  • We need to do so to comply with the law and/or regulation, including for crime prevention purposes. •

The transaction would breach the limits which apply to your Modulr Payment Account. •You have

breached or repeatedly breach any term within the Modulr Contract, and you fail to resolve the matter in a timely manner.

If we do this then we will, where the law allows us to, we will let the Seapoint know. Seapoint will then let you know.

6. Your Modulr Contract

Can Modulr make changes to my Modulr Contract?

Modulr may make changes to your contract, however we must make you aware of these changes 2 months before the change happens.

Any changes to be made to your contract will be posted on Modulr’s website and will also be communicated to you by either Modulr or Seapoint. Modulr will only make changes to your contract within a shorter timeframe when Modulr is required to by law.

You do not have to accept any changes to your Modulr Contract, however if you do not accept the changes then we will assume that you wish to end your Modulr Contract. This means that your Modulr Payment Account will be closed, and you will no longer have access to the Payment Methods provided through Modulr.

You will not be charged a fee by Modulr for the closure of your Modulr Payment Account. The closure of your Modulr Payment Account will also include the returning of funds from this account to your nominated bank account.

How can I end my Modulr contract and close my Modulr Payment Account?

You or Seapoint may decide to end your Modulr Contract.

If you wish to end your Modulr contract, please Seapoint who will work with Modulr to arrange for this. Once your Modulr Contract ends, you will no longer have a Modulr Payment Account. Any funds in those accounts will be returned to your nominated bank account. If you have not provided a nominated bank account, we may contact you to ask for these details.

As Modulr is providing a regulated service, we may be required to end your Modulr Contract immediately. This may be because:

  • You do not meet our compliance requirements (which are required as a part of our regulated services) •

You have not complied with the requirements of the Modulr Contract.

  • You, or another service provider, have acted fraudulently or have been involved in money laundering, or any other illegal activity.
  • We suspect you have acted fraudulently or have been involved in money laundering, or any other illegal activity.
  • We are required to end the Modulr Contract by law or at the request of a regulator.

If Modulr wishes to end your Modulr Contract for any other reason, we must give you at least 2 months’ notice of this.

You can close your Modulr Payment Account at any time by contacting Seapoint’s customer services. If you wish to close your Modulr Payment Account, your Modulr Contract will also automatically end. Any funds in those accounts will be returned to your nominated bank account. If you have not provided a nominated bank account, we may contact you to ask for these details.

Where can I find a copy of my Modulr Contract?

You can contact Seapoint’s customer services at any time to request a copy of your Modulr Contract.

Which laws apply to my Modulr Contract?

The laws of the Netherlands will decide legal questions about the Modulr Contract. The competent courts of Amsterdam will deal with any legal disputes under the Modulr Contract.

7. Contacting each other

When will Modulr contact me?

If you wish to close your Modulr Payment Account, and we need to send the funds in those accounts to an alternative account then we may contact you for your nominated account details. We will contact you using the details that you have provided to Seapoint. If we do contact you, we will communicate with you in English. Who can I contact if I have problems with my Modulr Payment Account?

If you have a complaint about Modulr’s services, you should contact Seapoint. Modulr will work with Seapoint to investigate your complaint. Complaints will be handled in line with Modulr’s Complaints policy which can be found here.

2. Yapily terms and conditions: Link here