Effective date: 9 October 2026. These Terms apply from that date, subject to the notice and acceptance requirements in Section 26. They supplement the Finotive One Master Terms of Use.

1. Finotive Pay

1.1 Contracting party

These Finotive Pay Service Terms (the “Terms”) form an agreement between you and Finotive Pay (CY) Limited, a company registered in the Republic of Cyprus under company number HE475209, with its registered office at Office 113, Block A, Agios Pavlos Ct, 228 Archbishop Makarios III Avenue, 3030 Limassol, Cyprus (“Finotive Pay”, “we”, “us” or “our”). Support and formal complaints may be sent to [email protected] or to our registered office, marked for Finotive Pay.

Where you act as an approved business Client or corporate Contractor, the contracting user is that legal entity, not merely the person operating its access. Each individual representative must have authority to act and must use their own approved credentials. A personal Trader account remains personal to its registered owner.

1.2 Services and access

Finotive Pay provides payment administration and payment-management functionality within the Finotive ecosystem and may provide approved services to Clients and Contractors. Available functionality may include Contractor onboarding, compliance information collection, contract and statement-of-work administration, Account Details, payment instructions, payment processing, payout and Withdrawal administration, payment records and related Platform services.

Features depend on your approved role, jurisdiction, verification status, provider availability and the functionality enabled for your account. Some features may be released to selected users first. Registration does not entitle you to every feature. Cards, third-party merchant spending, general person-to-person transfers and other products not expressly enabled under these Terms are not made available by these Terms alone.

1.3 Acceptance and eligibility

You must maintain an eligible Finotive One identity, satisfy the relevant verification checks and accept these Terms through the acceptance process provided. Individuals must be at least 18 and legally capable of contracting. We may record the accepted version, date, time, user identity and associated technical evidence. Merely receiving an unsolicited payment does not constitute acceptance.

We will make the applicable Terms and transaction information available in a form you can retain. You must maintain accurate contact information. Mandatory consumer status and legal protections are determined by law, not solely by whether your account is described as a Trader, Affiliate, Client or Contractor account.

2. Definitions

Account Details means the virtual account identifiers, which may include a virtual IBAN, allocated for identifying incoming payments into our OpenPayd account and reconciling them to your Balance. They are not a separate bank, payment or e-money account in your name.

Affiliate means a user approved under the applicable Finotive Affiliate Programme Terms, made available through the affiliate onboarding process or dashboard. Programme entitlement and commission rules remain governed by those terms.

Available Balance means the cleared portion of your Balance that is not reserved, restricted or subject to a lawful hold and is available for permitted use.

Balance means the monetary amount recorded as owing to you by Finotive Pay, before deducting any separately identified reservation or restriction. It does not include an unapproved reward, simulated trading capital or Promotional Credit.

Balance Currency means USD, EUR or GBP, as applicable to the relevant currency ledger. Separate currencies are not automatically converted or consolidated.

Business Day means a day, other than a Saturday, Sunday or public holiday in the Republic of Cyprus, on which banks in the Republic of Cyprus are open for general business.

Central European Time means Central European local time: CET (UTC+1) in winter and CEST (UTC+2) during daylight saving, following the Europe/Berlin time zone. References to a weekly cutoff use this local clock, not a permanently fixed UTC offset or Cyprus local time.

Client means a business or other approved customer expressly authorised by Finotive Pay to fund and instruct genuine payments to onboarded Contractors through the Client payment workflow. A Trader is not a Client merely because they have a Balance.

Client Payment means an approved payment by a Client to an identified Contractor under an underlying commercial arrangement, recorded through the separate Client payment workflow. It is not a Trader Withdrawal or a general user-to-user transfer.

Consultant Services Agreement means a separate agreement expressly identifying any consultancy, contract-administration or related services, the parties providing them, their fees and their respective obligations.

Contractor means an individual or legal entity onboarded and approved to receive payments from a Client for genuine services or deliverables. Contractor status does not permit onward payments to unrelated third parties.

Finotive Service means a product or service provided by the separately identified Finotive entity, including Finotive Funding, Finotive Futures, Finotive Markets or Finotive Pay.

Payment Service Provider means a bank, electronic money institution, payment institution, payment processor, crypto-asset service provider or other third party used in providing a payment or conversion service. This collective term does not imply that all providers have the same regulatory status or protections.

Payout Method means an available external payment route described in Section 9.

Platform means the Finotive Pay dashboard, website, approved application or interface through which the relevant functionality is made available.

Processing Week means the period from Friday 00:00:00 up to, but not including, the following Friday 00:00:00, in Central European Time.

Promotional Credit means a discount, bonus, trading credit or other conditional promotional benefit which is not a withdrawable Pay Balance unless its applicable terms expressly provide otherwise.

Qualifying Activity means a genuine authenticated login by you to Finotive Pay or your linked Finotive One account; a genuine user-initiated payment, purchase, deposit or Withdrawal; receipt of a substantive cleared monetary credit; or verified contact with us concerning your Balance. Automated technical events, marketing messages, fees and promotional adjustments alone do not count.

Trader means an individual using Finotive Pay in connection with their own Finotive Funding, Futures, Markets or other approved Finotive Service. The own-name restrictions also apply to an individual Affiliate using their personal Pay account.

Trader Proceeds means approved Funding or Futures rewards, permitted Affiliate commissions, and withdrawals or other amounts lawfully released from the user’s own Markets or other Finotive Service account. Markets withdrawals may include the user’s own capital and must not be treated as simulated rewards.

Withdrawal or Payout means an external transfer instructed from your Available Balance to an eligible destination belonging to the same verified user, except where a separately approved Client Payment is expressly identified as such.

you or user means the individual or approved legal entity contracting under these Terms. References to a business user mean a user acting in its business or professional capacity, to the extent recognised by applicable law.

Unless expressly stated otherwise, “days” means calendar days. A mandatory statutory definition or calculation of a time period prevails where applicable.

3. Clients, Contractors and Traders

3.1 Separate roles and permissions

Trader functionality and Client payment functionality are separate. Roles may be linked to one Finotive One identity, but permissions, beneficial ownership, source-of-funds records and payment ledgers must identify the capacity in which each transaction is made. Approval for one role does not grant another role.

3.2 Trader and personal Affiliate accounts

A Trader may receive their own Trader Proceeds, make permitted own-name deposits, withdraw to their own verified destination and use an Available Balance for the same-user ecosystem transactions in Section 7. A Trader may not send any part of their Pay Balance to another person, another user, a friend, family member, nominee, contractor or separate company.

This restriction applies to the whole Trader Balance, including deposits and amounts credited from Funding, Futures and Markets. A company owned or controlled by the Trader is still a different legal person. A Trader may not bypass this rule by creating invoices, designating another user as a Contractor, assigning a reward, transferring into a Client funding ledger or moving funds through another Finotive Service.

3.3 Approved Client payments

Clients may use the separately approved workflow to onboard Contractors, collect compliance information, establish contractual arrangements, record deliverables and acceptance criteria, instruct payments and manage Contractor relationships. We may require a statement of work, invoice, evidence of acceptance and proof that the recipient and funding are legitimate.

Only funds accepted and recorded for that Client’s approved business payment activity may fund Client Payments. Personal Trader Proceeds cannot be reclassified as Client funding to enable third-party payments. A user holding both roles must keep their personal Trader funds separate from the business Client’s payment records. We may refuse a transaction that appears to disguise a prohibited Trader transfer.

3.4 Contractor receipts and onward withdrawals

Contractors may connect with Clients, provide compliance information, store payment preferences, record contractual arrangements and receive approved Client Payments. Once a Contractor has an Available Balance, an external Withdrawal must go to that same Contractor’s verified account or wallet. For a corporate Contractor, the destination must belong to the contracting company, not a director, employee or shareholder personally.

3.5 Business representatives

A Client or corporate Contractor may nominate verified representatives only through the access controls we approve. Each representative must use separate personal credentials and act within the permissions granted. The business must remove authority promptly when it changes and is responsible for properly authorised instructions, subject to Section 16.

Business access does not allow sharing of passwords, two-factor authentication or a representative’s Finotive One identity. It does not permit access to another person’s Trader account. The limited business-representation permission in this Section applies only to the approved business workspace and takes precedence over a general personal-access restriction solely to that extent.

4. Contractual relationships

4.1 Underlying agreements

Finotive Pay does not become a party to the underlying agreement between a Client and Contractor merely because it administers that agreement or its payment. The parties remain responsible for scope, deliverables, acceptance, employment or contractor classification, payment obligations, taxes and their other contractual obligations. Finotive Pay does not guarantee performance or assume an employer-of-record role under these Terms.

A separate Consultant Services Agreement governs only the expressly identified Consultant Services. We do not adjudicate an ordinary dispute about service quality merely because a payment passed through the Platform, but may review evidence relevant to fraud, a lawful hold, correction or a binding order.

4.2 When a Client payment takes effect

A deposit into a Client funding record, an unapproved payment instruction or a pending entry does not itself establish payment to the Contractor. Unless a disclosed collection-agent mandate or mandatory law requires a different result, a Client Payment through a Pay Balance is completed when the authorised amount is finally credited as cleared to the identified Contractor and we assume the corresponding Balance obligation. An agreed direct external Client Payment is completed under the acceptance and settlement event disclosed for that route.

The applicable Client onboarding or commercial agreement must identify any different collection-agent arrangement and when receipt by the agent discharges the Client. The same amount is not payable twice. An incorrect, fraudulent or lawfully reversed payment remains subject to Section 16.

4.3 Finotive Service payouts

The relevant Funding, Futures, Markets or other service provider decides entitlement and releases amounts under its own terms. A simulated profit, pending reward request or internal approval is not an Available Pay Balance until the permitted credit has been completed. Once we record an amount as owing by Finotive Pay, we are responsible for that Pay Balance; later external settlement reduces it. Crediting a Pay Balance is not the same as completing an external Withdrawal.

Each Finotive entity remains responsible for its own services and obligations. A Markets client-money or statutory obligation is not transferred or reduced merely by relabelling an amount in a dashboard. Any necessary authority and legal transfer must accompany the actual movement of funds.

5. Payment services and treatment of funds

5.1 Role and legal nature of your Balance

Finotive Pay may act as a payment agent or facilitate payments through third-party Payment Service Providers. Finotive Pay does not itself provide banking, deposit-taking, stored-value, escrow, insurance or other regulated financial services except to the extent expressly permitted under applicable law. These Terms do not represent that Finotive Pay holds a provider’s licence or regulatory status.

Your Balance is our record of the amount we owe you. It is not a deposit account opened in your name with Finotive Pay or a Payment Service Provider merely because it appears on the Platform. Your contractual entitlement to payment of the Balance is against Finotive Pay (CY) Limited, subject to these Terms and applicable law.

5.2 Holdings and payout coverage

We maintain pooled holdings with or through Revolut, OpenPayd and ChangeNOW to cover the aggregate amounts recorded as owing on Finotive Pay user Balances, together with additional reserves for payouts. The allocation between providers varies with currencies, conversion and settlement requirements. Holdings associated with crypto payout activity may include conversion proceeds and crypto-assets used in that activity; your Pay Balance remains denominated in its Balance Currency.

We maintain individual records identifying amounts owed to each user and distinguish them from amounts not yet credited, reservations, restrictions and our additional payout reserves. We reconcile the relevant user ledgers and provider records on each Business Day, investigate discrepancies and take corrective action. Records and coverage arrangements do not, by themselves, create a trust, a separate provider account for each user or a legally segregated proprietary interest. No fixed excess-reserve percentage is promised.

5.3 Provider protections and risks

Amounts held as e-money with OpenPayd are subject to its applicable safeguarding arrangements, which are distinct from bank deposit insurance. Those arrangements operate at the provider level and do not themselves protect you against Finotive Pay’s insolvency. Funds at different providers, during conversion or held as crypto-assets do not necessarily receive the same protection.

A linked vIBAN does not give you an OpenPayd account or direct contractual relationship with OpenPayd. Using another provider through Finotive Pay does not, by itself, make you its direct customer. This does not exclude any rights you separately hold under a direct provider agreement or mandatory law.

Provider insolvency, account restrictions, settlement failure, conversion risk and crypto-asset volatility or loss may affect the value or accessibility of our holdings. If Finotive Pay becomes insolvent, recovery of your Balance is subject to applicable insolvency law and any rights established under that law. Repayment may be delayed and you may not recover the full amount. These risk disclosures do not remove a legal responsibility that cannot be excluded.

5.4 Deposit guarantees and compensation schemes

Your Finotive Pay Balance is not itself an insured bank deposit in your name and is not protected by the UK Financial Services Compensation Scheme against Finotive Pay’s failure. Finotive Pay does not provide its own deposit-guarantee, insurance or compensation scheme.

Eligible deposits at Revolut Bank UAB may benefit from the Lithuanian deposit-guarantee scheme at the eligible depositor level. Eligibility, exclusions, account ownership and aggregation rules apply. The fact that Finotive Pay holds money at Revolut does not establish that Finotive Pay is an eligible depositor or that each Pay user has a separate insured deposit or individual guarantee limit.

OpenPayd safeguarding is not deposit insurance against OpenPayd’s failure. A separate claim under an underlying bank’s deposit-protection scheme may arise in particular circumstances if that bank fails, subject to the relevant law and scheme rules. We do not represent that such a claim or any pass-through protection is available to each Pay user. Crypto-assets and crypto exchange exposures are not bank deposits protected by a deposit-guarantee scheme.

Nothing in these Terms excludes any protection or claim that applies to you by mandatory law. No provider-level protection described here is a guarantee of full or immediate repayment of your Pay Balance.

5.5 No interest or investment authority

Your Balance does not earn interest. Any separately offered investment product is governed by its own agreement with the identified investment provider. These Terms do not authorise Finotive Pay to invest your Balance.

5.6 Availability

Payment availability depends on jurisdiction, provider, currency, compliance status, transaction type and operational availability. A restriction on one route does not itself extinguish your entitlement to a valid Balance. Alternative routes, where lawful and practicable, are handled under Sections 16 and 21.

6. Payment Service Providers

Payments may involve banks, electronic money institutions, payment processors, wallet providers, card processors, money transmitters, crypto-asset service providers or other third parties. Our principal providers are:

Service	Provider
Account Details and bank transfers in USD, EUR and GBP	OpenPayd Financial Services Malta Limited, registered in Malta under company number C 75580 and authorised by the Malta Financial Services Authority (MFSA) as a financial institution.
Local bank transfers in Malaysia and Vietnam	Transact365 (T365), through T365 Asia Limited (Hong Kong, company number 71024332; 65-67 Bonham Strand East, Sheung Wan, Hong Kong) or T365 UK Ltd (England and Wales, company number 16114568; 86-90 Paul Street, London EC2A 4NE), depending on the payout destination. We will identify the entity used for a particular payout on request.
Revolut payouts and relevant operational holdings	Revolut Bank UAB, incorporated in Lithuania, company number 304580906; a credit institution authorised and regulated by the Bank of Lithuania and European Central Bank, authorisation code LB002119.
Crypto-asset exchange supporting crypto payouts	ChangeNOW, operated by CHN Group LLC, incorporated in Saint Vincent and the Grenadines, company number 3010 LLC 2023 (IBC No. 3010 LLC 2023), with its registered address at Euro House, Richmond Hill Road, Kingstown, Saint Vincent and the Grenadines. The actual exchange and payout arrangements are subject to the relevant provider agreement and available service.

A provider may use banking, exchange or settlement partners. We may add, replace, suspend or remove a provider for a valid operational, legal or commercial reason, subject to Section 26 and any mandatory notice. We will disclose any material change affecting the service or treatment of your Balance.

Provider terms apply to you only to the extent legally applicable or expressly presented for acceptance in relation to a service you obtain directly. Our business agreement with a provider is not automatically an agreement between that provider and you. Outsourcing does not remove our responsibilities under these Terms or law; third-party failure is addressed under Section 23.

7. Your Balance and use within the ecosystem

7.1 Credits, debits and status

Your Balance may be recorded in USD, EUR or GBP. It increases when cleared deposits, Trader Proceeds or approved Client Payments are credited. It decreases when an authorised Withdrawal or purchase is completed, a lawful fee is charged, an authorised same-user Markets transfer is completed or an amount is lawfully reversed under Section 16.

Pending incoming funds and unapproved rewards are shown separately and are not amounts available to spend. Reserved and restricted amounts remain identifiable but cannot be withdrawn or spent while the reservation or lawful restriction applies. A reservation reduces Available Balance without creating a second debit. On failure or cancellation, the unused reservation is released; a completed payment is not charged twice.

7.2 Transaction records

The Platform or a statement supplied on request will identify relevant amounts, currencies, fees, credits, debits, reservations, status and available transaction references. We may correct a manifest recording error on an evidenced basis and will notify you where legally permitted. You should review records regularly and report discrepancies promptly. Our records are evidence, not conclusive proof that prevents you from challenging an error.

7.3 Purchases of Funding and Futures accounts

Where offered at checkout, you may use Available Balance to purchase Finotive Funding accounts or Finotive Futures accounts for yourself. Any combination with another payment method is allowed only if checkout supports it. The selling entity, product, applicable terms, price, currency, discount and total debit must be shown before you confirm.

By confirming, you authorise the specified Pay debit and settlement to the identified selling entity. You are not paying another Trader. The seller remains responsible for the account and its product, cancellation and refund terms. A failed order must not leave you permanently debited for an unprovided purchase, subject to any actual service already lawfully supplied.

7.4 Transfers to your own Markets account

Where enabled, you may instruct a transfer from Available Balance to a verified Finotive Markets account belonging to the same legal person. You may not deposit to another person’s trading account. The receiving Markets entity, trading account, amount, any conversion and applicable terms will be identified before confirmation.

The transfer is completed when the identified Markets provider receives and accepts the funds or another disclosed legally effective settlement event occurs. Until then, the amount remains traceable as reserved or in transit and is not treated as simultaneously spendable in Pay and Markets. Once completed, the Markets provider administers the amount under its applicable account and client-money terms. A rejected transfer is released or recredited, subject to lawful actual costs and Section 16.

7.5 Pay-funded promotions and Markets deposit bonuses

Eligible Pay-funded Funding or Futures purchases may receive promotional discounts. Eligible transfers to Markets may receive a deposit bonus where the relevant Markets provider lawfully offers it. The level, availability, eligibility, duration, minimum amount, combination rules and any bonus conditions are those displayed for the particular offer before you confirm.

Promotions may be introduced, varied or withdrawn for future transactions, and no permanent discount or bonus rate is promised. A change does not retrospectively remove a benefit already validly earned under an accepted offer, except under the offer’s disclosed conditions or for proven abuse, error or a legal requirement.

A Markets bonus or promotional trading credit is not a cash deposit or withdrawable Pay Balance unless its specific terms expressly say otherwise. The Markets terms must explain any effect of withdrawals on the bonus, trading conditions and any restrictions. Bonus removal does not itself authorise confiscation of your deposited principal. Offers are subject to jurisdictional availability and legal restrictions.

7.6 Refunds, reversals and promotion abuse

An approved refund of a Pay-funded purchase will normally be credited to the Pay Balance and currency originally debited, subject to mandatory refund rules. A refund cannot exceed the amount actually paid and does not turn a discount into cash. A Markets withdrawal is governed by the Markets provider’s process and is not an automatic reversal of a completed deposit.

We may prevent duplicate claims, circular transfers, artificial deposits, self-referral or refund schemes designed to obtain benefits without a genuine eligible transaction. Any removal or recovery must be grounded in the applicable terms, evidence and law. Unrelated deposited funds are not forfeited merely because a trading rule or promotion was breached.

8. Account Details and deposits

8.1 Requesting Account Details

Where available, you may request one set of Account Details per Balance Currency through the dashboard. You must have approved Finotive One identity verification and provide your residential address, or the required registered and operating addresses for an approved business. We may require further provider checks.

Your name may appear in payment identifiers or instructions for matching purposes. The actual provider account remains in Finotive Pay’s name, and the identifiers do not create a bank or e-money account for you. Use only the beneficiary wording and routing details provided. Available fields depend on the currency and route and may include an IBAN, BIC, account number or GBP sort code; every field is not available for every currency.

8.2 Automatic issue

Where supported and verification is complete, Account Details may be issued automatically when you make your first bank-transfer Withdrawal via OpenPayd in a currency for which you do not already hold them. Issue remains subject to provider approval and does not itself approve a payment.

8.3 Own-name deposits and approved Client funding

A personal deposit must come from an account held in the same verified legal name as the Pay user. We may seek proof of ownership and reject, hold or return a third-party deposit. A genuine Client Payment must instead use the separately approved workflow and may not be disguised as a personal top-up.

An approved Client must fund its own business payment record using the accepted business funding route and ownership details. Payments from a Client to an onboarded Contractor are permitted only under Sections 3 and 4. Unapproved third-party collections and receipt on behalf of another person remain prohibited.

8.4 Crediting and deposit limits

An incoming transfer is credited after provider receipt, matching and applicable verification, not merely because the sender submits a payment instruction. Finotive Pay does not impose a standard published deposit minimum or maximum under this version, but provider limits, account-specific limits, legal requirements and risk controls may apply. We may disclose or apply a limit where reasonably necessary.

We may refuse, hold or return funds for legal, compliance, fraud-prevention or provider reasons. Returns normally follow the lawful original-source route; they do not create an unrestricted right to nominate a different recipient. Sending-bank and unavoidable third-party return charges may apply, subject to Section 16 and mandatory law.

8.5 Closure of Account Details

Account Details may be disabled on suspension, termination, provider instruction or dormancy under Section 21. Receipt after closure may be rejected or returned. Disabling an identifier does not itself extinguish a valid Balance. Give senders updated instructions before reusing a closed or changed payment route.

9. Payout Methods and destination ownership

Depending on jurisdiction, currency and verification, available routes may include bank transfers through OpenPayd using SEPA, SEPA Instant, Faster Payments, CHAPS, T2 and SWIFT; T365 local bank transfers in Malaysia (MYR) and Vietnam (VND); Revolut payments using a Revtag; and direct crypto payouts under Section 14. T2 is the payment infrastructure formerly referred to as TARGET2. Only enabled routes shown for your account are available.

Withdrawals may only be made to an eligible account or wallet held in your name or otherwise verified as belonging to you. We may reject or suspend a Withdrawal where ownership cannot be verified or a third-party destination is identified. Any restriction on the affected funds will continue only for as long as reasonably necessary for a lawful investigation or as required by applicable law. Once the restriction is resolved, the funds will be released, returned or otherwise dealt with in accordance with these Terms and applicable law.

For Traders, no general third-party transfer permission exists. A Revtag must identify your own Revolut account. For an exchange-hosted crypto destination, the credited exchange account must belong to you; for a self-hosted wallet, you must demonstrate ownership or control where requested. We may request verification of changes and apply proportionate security checks. A separately approved Client Payment is not an exception allowing a Trader to withdraw to another person.

A legally required return to the original sender, payment to a verified estate representative or action under a binding court or authority direction is handled through a separate controlled process, not as an ordinary user-nominated third-party Withdrawal.

10. Withdrawal limits

Limit	Amount / calculation	Applies to
Standard minimum	25 in the debited Balance Currency: USD, EUR or GBP.	All ordinary Withdrawals, subject to the higher route minimum below and the closure procedure in Section 21.
SEPA Instant minimum	Must exceed the applicable EUR 25 fee or its quoted equivalent. The standard minimum also applies.	SEPA Instant through OpenPayd.
SWIFT minimum	At least 100 in the debited Balance Currency and greater than the applicable SWIFT fee.	SWIFT through OpenPayd.
Malaysia local transfer	110 to 20,000 MYR, inclusive.	Net payout amount instructed to the local receiving bank after known fees and conversion.
Vietnam local transfer	104,000 to 300,000,000 VND, inclusive.	Net payout amount instructed to the local receiving bank after known fees and conversion.
Affiliate weekly cap	USD 12,500 equivalent across the Affiliate’s Pay currency ledgers combined, per Processing Week.	All external Withdrawals from a personal account registered as an Affiliate account, unless an expressly agreed Affiliate arrangement states otherwise.

10.1 Gross and net amounts

Unless a limit expressly refers to the amount received, a Withdrawal amount means the gross amount debited from your Balance, including the Finotive Pay Withdrawal fee. Fees are deducted from that gross amount, not added a second time. The remaining amount must satisfy applicable local payout limits after known conversion and charges. Unknown receiving-bank charges may reduce the ultimate amount credited.

10.2 Affiliate cap operation

An approved Withdrawal is allocated to the Processing Week in which it is scheduled to be sent. Its gross amount reserves that week’s capacity. Non-USD amounts are translated into USD for the cap using the Finotive Pay fiat reference rate recorded when the request is accepted and allocated; this cap calculation is not a crypto exchange quote.

Executed Withdrawals and outstanding reservations for the same Processing Week count towards the cap. Cancellation before execution releases the reservation; rescheduling moves it to the new Processing Week and is subject to available capacity there. A payment already sent continues to count for its sending week even if later returned.

Unused capacity does not carry forward. Mixed commission and other funding in an Affiliate account does not by itself remove the cap. Product purchases and same-user Markets transfers are not external Withdrawals for this cap, but may not be used to circumvent its purpose.

10.3 Other limits

We may apply a lower limit or delay a transaction where reasonably required by law, a provider or compliance or fraud controls. Any agreed higher limit remains subject to legal and provider limits; our written agreement cannot override them. Artificial splitting, duplicate profiles and disguised routing to evade limits are prohibited.

11. Payment instructions, processing times and payout schedule

11.1 Authorising an instruction

Before confirmation, you must check the gross debit, Balance Currency, recipient identifiers, route, disclosed fees and applicable conversion information. Fiat quotes are governed by Section 13; crypto instructions and any estimates are governed by Section 14. Confirming through the approved interface and completing required authentication authorises that instruction, subject to applicable law and Section 16.

We may reserve the relevant amount while an instruction is pending. Insufficient Available Balance, incomplete checks, unsupported details or a duplicate instruction may prevent acceptance. An acknowledgement of receipt is not confirmation of execution or external settlement. You must not resubmit merely because a status update is delayed; contact support to avoid duplicates.

11.2 Cancellation and amendment

You may request cancellation through an available dashboard control or support. We will cancel an unexecuted instruction where it remains revocable and has not resulted in an irreversible provider, exchange or settlement commitment. An instruction cannot normally be amended once committed; a replacement requires fresh confirmation. Any mandatory cancellation right remains unaffected.

We do not guarantee recall after funds have been sent or conversion has become binding. Any actual non-recoverable conversion or provider cost must have been disclosed or otherwise lawfully payable; there is no undisclosed discretionary cancellation penalty. A transaction must not be treated as irrevocable solely to defeat a cancellation right required by law.

11.3 Weekly schedule and cutoff

Ordinary Withdrawals are scheduled for processing each Friday throughout the day. Requests submitted and approved before Friday 00:00 Central European Time, meaning up to Thursday 23:59:59 CET or CEST as applicable, are eligible for that Friday run. Requests submitted after that cutoff normally enter the following Friday run.

A request awaiting verification or approval at the cutoff is not guaranteed inclusion. We will identify its pending status and, where legally permitted, any action required. Once the issue is resolved, it enters the next available lawful processing run. A timely complete request will not be deferred for an undisclosed discretionary reason unrelated to the checks or processing requirements in these Terms.

If the scheduled day is not a Business Day, processing moves to the next Business Day unless the route can and must lawfully be processed sooner. Receiving-country and currency-system holidays can also affect settlement. The schedule is an agreed processing arrangement only where legally permitted; it does not override a mandatory receipt, availability or execution deadline. Where the law requires an earlier payment, that requirement prevails.

11.4 Arrival after sending

The following are operational estimates after release to the relevant payment route, not estimates from the original Withdrawal request. Internal verification and weekly scheduling are separate from the payment scheme’s own execution requirements.

Payout Method	Typical arrival / explanation
SEPA Instant	Once actually accepted as an instant euro transfer, the scheme’s applicable instant-execution standard applies. Any pre-release approval or conversion stage is separate and is not described as four-hour instant-transfer execution.
Faster Payments	Usually within minutes; operational exceptions may take up to 4 hours, subject to applicable mandatory rules.
SEPA, CHAPS and T2	Usually the same or next relevant Business Day after release, depending on scheme cutoff and availability.
SWIFT	Usually 1 to 5 relevant Business Days; intermediary checks or banks may extend the estimate where law permits.
T365 Malaysia and Vietnam	Usually within minutes; operational exceptions may take up to 4 hours.
Revolut Revtag	Usually within minutes; operational exceptions may take up to 4 hours.
Direct crypto	Usually within 30 minutes after broadcast, subject to the selected network and receiving service’s confirmations. Exchange processing before broadcast is a separate stage.

11.5 Delays and tracing

A bank, intermediary, provider or network may delay receipt or perform its own checks. We will provide reasonable assistance and available references; Section 23 determines responsibility. Contact support promptly for a failed or suspected unauthorised payment and, in any event, for an ordinary bank transfer not received within 5 Business Days of sending. You need not wait 5 days to report a problem, and that period does not postpone a statutory remedy.

11.6 Delayed payouts and service disruption

A Withdrawal may be delayed where a banking, payment-processing, exchange, technical, compliance or settlement issue prevents its processing or completion. This may include restrictions or interruptions affecting a bank or Payment Service Provider, delayed access to funds held with a provider, additional verification requirements, payment-network outages, or a temporary inability to purchase, convert or transfer the cryptocurrency required for a crypto payout because of provider restrictions, service unavailability or insufficient liquidity at the relevant exchange.

Where we become aware that an affected Withdrawal is unlikely to be processed within its scheduled processing run or a previously communicated timeframe, we will notify you without undue delay through your registered email address or the Platform. Where legally permitted, the notice will explain the nature of the delay, whether the Withdrawal has been sent, any action required from you, and the anticipated processing or completion date where we can reasonably estimate one.

Any anticipated date is a good-faith estimate based on the information available at the time, not a guarantee of receipt. Where we cannot reasonably estimate a completion date, we will explain this and tell you when to expect our next update. We will provide updates at the times communicated and notify you without undue delay of any material change to the anticipated timeframe.

We will take reasonable steps to resolve or mitigate the disruption and progress the affected Withdrawal as soon as reasonably practicable. Where an alternative eligible Payout Method is available, we may offer you that option. A change to the Payout Method, payout currency, crypto-asset, network or destination requires your authorisation, with the applicable fees and conversion terms disclosed before confirmation. Any alternative destination must satisfy the ownership requirements in Section 9.

While an instruction remains active, the affected amount may remain reserved or recorded as in transit and cannot be spent or withdrawn a second time. You may request cancellation in accordance with Section 11.2. Where an instruction is cancelled or fails, the release or re-credit of funds is governed by Section 16.

A delay does not extinguish your entitlement to a valid Balance or permit us to retain the affected funds as our own. This Section does not override a mandatory execution, cancellation, refund or other legal obligation. An accepted fixed fiat quote remains governed by Section 13, while crypto conversion and any indicative output remain governed by Section 14.

12. Fees

12.1 Withdrawal fees

Payout Method	Finotive Pay fee
SEPA, Faster Payments, CHAPS and T2 through OpenPayd	Free.
SEPA Instant through OpenPayd	EUR 25, or the quoted equivalent in the debited Balance Currency.
SWIFT through OpenPayd	1.5% of the gross Withdrawal amount, subject to a minimum of EUR 25 or its quoted equivalent.
T365 local transfer to Malaysia or Vietnam	1.5% of the gross Withdrawal amount.
Revolut Revtag	Free.
Direct crypto	No separate Finotive Pay Withdrawal fee. Provider conversion costs, spreads and network charges may affect output as described in Section 14.

The fee is deducted from the gross debit. Where a EUR-denominated fee must be translated into another Balance Currency, its equivalent is calculated at the Finotive Pay fiat rate shown at confirmation and included in the total debit. Currency rounding follows the minor unit supported for the relevant currency. Applicable taxes on our fees, where required, are disclosed as part of the charge.

For fiat transfers, the confirmation shows the fee and net amount we instruct, excluding any separately disclosed unknown intermediary or receiving charges. For crypto, the confirmation shows the gross fiat debit and any available indicative output and cost information under Section 14, not a guaranteed crypto receipt. A receiving bank, intermediary or wallet service may levy its own charges.

Any mandatory legal cap, parity rule or prohibition applicable to a charge prevails over this fee schedule. We will not apply a listed charge to the extent it is prohibited by applicable law.

12.2 Other fees and changes

Subscription, Client payment, Contractor payment, transaction or other commercial fees apply only if their amount or calculation and charging event have been disclosed and agreed before they are incurred. These Terms do not create an unspecified administration, dormancy or closure fee. Fee changes follow Section 26. Non-refundable charges on failed transactions are limited by Section 16.

13. Fiat currency conversion

13.1 Scope and accepted quote

This Section applies to fiat-to-fiat conversion shown for acceptance, such as a Withdrawal in a fiat currency different from the debited Balance Currency or an expressly quoted conversion for a same-user purchase or Markets transfer. It does not establish a fixed crypto exchange rate or crypto quantity under Section 14.

Before you confirm a quoted fiat conversion, the Platform shows the currencies, gross debit, applicable rate, disclosed fees, net amount to be instructed and any quote expiry. The rate is set by Finotive Pay by reference to market conditions and may include a commercial spread. It may differ from rates published elsewhere; no mid-market or best-rate guarantee is given.

When you validly accept a displayed fixed fiat quote within its validity period, that rate applies to the accepted instruction and is not subsequently changed merely because execution occurs later. We may reject an expired quote, a demonstrable manifest error or an instruction that cannot lawfully be processed, but will not substitute a materially different rate without renewed consent where consent is required. Refusal or correction follows Sections 15 and 16.

13.2 Returned or cancelled fiat payments

Where a completed conversion must be unwound because a payment is returned or a revocable request is cancelled after a binding conversion, the returned funds may require conversion at the rate applicable when recovered. We will disclose that rate and any actual lawful third-party cost. A gain or loss may result from ordinary exchange-rate movement.

Where the return or error is attributable to us or another person for whom we are legally responsible, any correction and allocation of costs must comply with Section 16 and applicable law. This clause does not shift such liability to you. A rate used solely to value a limit or provider holding is not a customer conversion quote.

14. Crypto payouts

14.1 Separate execution-price model

Crypto payouts use ChangeNOW or another disclosed provider for the relevant exchange and payout steps. Supported assets and networks are shown on the Platform. You authorise conversion of the specified fiat debit into the selected asset and transfer to your verified destination.

We do not display or fix a crypto exchange rate when you confirm the request. Any crypto quantity or value preview is indicative only, is not a firm offer and may change before execution. If no reliable quantity estimate is available, the confirmation will state that the output will be determined at execution. A fixed fiat quote under Section 13 does not fix the crypto output.

14.2 Pricing method and costs

The final output is calculated using the provider’s executable conversion terms when the exchange is actually carried out, after any necessary intermediate conversion, provider charges and network costs. The executable price reflects available liquidity, market conditions, the chosen asset and network and the provider’s conversion spread. The relevant time is the exchange execution time, not the request date or an earlier preview.

Finotive Pay charges no separate crypto Withdrawal fee under this version. Actual provider charges and network fees may be deducted from the amount submitted for conversion or the resulting asset amount, as applicable, and provider spreads may be embedded in the conversion. We do not deduct a separate undisclosed Finotive Pay crypto fee. Known charges or estimates are identified before confirmation; final output and available provider or blockchain references are recorded after execution.

You bear ordinary price movement between your instruction and lawful execution, including during the disclosed weekly processing cycle. We do not promise a particular quantity, fiat equivalent or minimum output unless one is expressly accepted for that transaction. This does not exclude responsibility for loss attributable to our own breach where law requires us to bear it.

14.3 Consent, failed exchanges and returns

Before confirmation, check the fiat debit, asset, network, address, any memo or destination tag, ownership and the execution-price warning. A displayed estimate is not used as a guaranteed settlement quantity. Cancellation follows Section 11.2 and may cease to be possible once an exchange or network transfer is committed.

If the provider rejects the exchange before any conversion or transfer commitment, the unused reservation is released. If funds are returned after a committed exchange, the amount actually recovered and any necessary return conversion are reconciled to your Balance. Only actual lawful non-recoverable costs may be deducted, subject to responsibility for errors under Section 16. A request is not marked externally paid merely because the exchange was requested.

14.4 Destination and network risk

You must provide the correct wallet address, network and any required tag or memo, and ensure the destination supports the asset and any minimum deposit. Transfers that have been broadcast or completed normally cannot be reversed. Incorrect details may result in permanent loss; recovery may not be possible and is not guaranteed. We may assist where practicable but do not promise to recover a user-directed mistaken transfer.

We do not guarantee blockchain uptime, asset stability, smart-contract operation or a receiving exchange’s crediting policy. Forks, depegging, congestion or provider restrictions may affect execution and asset value. Responsibility for our own errors remains subject to Section 16.

14.5 Verification

We and the provider may screen wallets and request destination ownership, beneficiary, source-of-funds, exchange or self-hosted-wallet information and any travel-rule information required by law. We may reject unsupported or prohibited routes. These checks do not permit a Trader to nominate someone else’s wallet.

15. Payment conditions and compliance checks

We may require identity and business verification, source-of-funds or source-of-wealth evidence, tax information, sanctions screening, payment-ownership evidence, the commercial purpose of a Client Payment and other proportionate information needed for the service. A central Finotive One KYC approval does not prevent an additional provider or transaction-specific check.

A deposit, credit, Client Payment, purchase or Withdrawal may be delayed, held, rejected, reversed or restricted where required by law or reasonably necessary for a documented compliance, provider, fraud or security concern. Where legally permitted, we will explain the status, the action needed and the review outcome. We may withhold details that would breach a legal restriction or compromise a legitimate investigation.

Restrictions must be proportionate to the issue and reviewed as necessary. Unaffected amounts may remain available where doing so is lawful and safe. A provider instruction does not itself give us ownership of your Balance or authorise an indefinite hold unrelated to a continuing legal or contractual basis. We will release, return or otherwise lawfully deal with affected funds when the reason for the restriction ends.

A complaint, appeal or investigation does not automatically require release of legally restricted funds. Equally, it does not suspend a mandatory refund or response deadline unless the law permits that result. We may report matters to competent authorities and will not disclose restricted reporting information.

16. Failed, returned, incorrect and unauthorised payments

16.1 Details supplied by you

You are responsible for checking beneficiary identifiers, amounts, currency, Revtag, asset, network and wallet details before authorising a payment. Where a payment is correctly carried out using the identifier you supplied, a mistake in that identifier does not by itself make us responsible for the loss. We will comply with any applicable verification-of-payee, warning, tracing or recovery duties. Mandatory rights are not waived by this allocation.

16.2 Rejected, failed and returned Withdrawals

A Withdrawal may be rejected, fail or be returned because of incorrect or incomplete payment details, an account-name mismatch, a closed or restricted receiving account, an unsupported currency or payment route, receiving-bank or provider checks, or another processing or compliance issue. We will notify you without undue delay once we receive reliable confirmation of the failure or return and, where legally permitted, explain the reason and any action required.

Failure before execution. Where a Withdrawal fails or is cancelled before funds are sent or a binding conversion or settlement commitment is made, we will release the unused reservation or restore the corresponding debit without undue delay. Any unearned Finotive Pay Withdrawal fee will also be refunded.

Return after sending. Where a Withdrawal has been sent and the receiving bank, intermediary or Payment Service Provider subsequently returns the funds, we will re-credit the amount recovered to the Finotive Pay Balance from which the Withdrawal was made, without undue delay after the funds have been received and identified as relating to your Withdrawal. The necessary reconciliation will be completed promptly. A notification that a payment has been rejected or is being returned does not, by itself, mean that the funds have already been received by us.

Amount re-credited. Where the failure or return is not attributable to us or another person for whom we are legally responsible, the amount re-credited may be reduced only by actual, lawful third-party charges and any previously disclosed Finotive Pay fee genuinely earned for the completed service. We will not impose an undisclosed return penalty or charge the same fee twice for the same service. Any necessary return conversion is governed by Section 13 or Section 14, as applicable. We will make available a record of the amount recovered, any permitted deductions, any conversion and the amount re-credited.

Partial returns and restrictions. Where funds are returned in instalments, we will re-credit each identifiable amount without undue delay after receipt rather than waiting for the entire amount to be recovered. Re-credited funds become part of your Available Balance unless a continuing lawful restriction applies under Section 15. Funds returned after account closure will be handled under Section 21.

Replacement Withdrawals. Following re-credit, you may submit a new Withdrawal using corrected details or another eligible Payout Method belonging to you. The replacement instruction is subject to the applicable checks, limits, processing schedule and fees disclosed before confirmation. We will not automatically resend a rejected payment to changed details without your authorisation.

Our responsibility and mandatory rights. Where an error is attributable to us or another person for whom we are legally responsible, Section 16.6 applies, including any required correction of fees or conversion effects. Nothing in this Section allows us to postpone a refund or re-credit required by applicable law until we recover funds from a third party.

16.3 Credits in error, recalls and lawful recovery

Where an evidenced error, duplicate credit, valid recall, chargeback or other lawful reversal means you are not entitled to an amount, we may correct the affected entry or recover the amount lawfully due. A provider recall request is not conclusive proof by itself; we may investigate and apply a proportionate restriction while entitlement is determined.

We will give an explanation and relevant transaction detail where lawful, and you may dispute the correction. If the properly recoverable amount exceeds your Balance, we may seek repayment on reasonable notice. We do not provide an overdraft or impose an undisclosed interest charge. You must not knowingly spend an erroneous credit.

16.4 Finotive Service recovery and set-off

A reward or benefit credited from another Finotive Service may be reversed only on a valid basis under the terms governing that entitlement and applicable law. We may not seize unrelated principal or combine liabilities of different legal persons merely because accounts share a group login.

Any set-off must relate to an amount lawfully due, identify the debtor, creditor and legal basis, and respect any client-money, safeguarding or consumer protection that restricts it. An ordinary trading loss, programme failure or prospective purchase restriction is not itself authority to confiscate a valid Pay Balance. You may challenge a proposed recovery through Section 29.

16.5 Reporting and investigation

Report a suspected unauthorised, duplicate, incorrectly executed or missing transaction without undue delay to [email protected]. Provide your user identifier, transaction reference, relevant dates and a description. Do not disclose passwords, seed phrases or authentication codes. Any mandatory statutory notification period applies; these Terms do not shorten it.

We will review relevant instructions, authentication, device and transaction records, provider evidence and the information you supply. Evidence that credentials were used is relevant but is not, by itself, conclusive proof of authorisation, fraud or gross negligence. We may take reasonable steps to secure the account and preserve evidence without prejudging the claim.

16.6 Corrections and responsibility

Where we are responsible for an incorrect, duplicate or unauthorised payment, we will make the correction, recredit or refund required by applicable law, including directly related fees and conversion effects to the extent required. Where the law requires a prompt or provisional refund, we will not wait for completion of an internal investigation unless a legally permitted exception applies.

A dispute does not automatically establish a reimbursement entitlement. To the extent permitted by law, we are not responsible for a validly authorised payment correctly executed, or for loss caused by your fraud, deliberate misuse or grossly negligent breach of a relevant security duty. Any such finding must be based on evidence and the applicable legal test, not simply on a decision to dispute payment.

Any provisional credit may be reversed only if a proper investigation establishes a lawful basis and any required notice is given. You cannot recover the same loss twice from Finotive Pay, a provider, a bank or an insurer. This does not excuse Finotive Pay from performing a payment or refund obligation it owes.

16.7 Tracing and recovery assistance

We will provide reasonable tracing assistance and available payment references or blockchain hashes. User-directed mistaken transfers may be irrecoverable; no recovery guarantee is given. Any separate optional recovery service and its fee must be agreed before it is incurred. Complaints about our investigation or decision follow Section 29.

17. User responsibility

You must provide accurate information, keep ownership and authority details current, use only approved functionality and comply with applicable law. You must not use Finotive Pay for fraud, money laundering, sanctions evasion, bribery, corruption, unlawful or deceptive transactions, unauthorised payment collection, identity or account sharing, or prohibited goods and services.

Receiving or transmitting funds on behalf of another person is prohibited except for the expressly approved Client Payment workflow and a legally required controlled process. A Trader may not sell, assign or redirect their Balance to another user or use an ecosystem purchase, refund or Markets transfer to disguise such a payment. You must not evade fees, limits or restrictions through false invoices, circular payments or duplicate accounts.

You remain responsible for your own tax reporting. A payment record, reward label or Contractor classification is not legal or tax advice. Clients must have the necessary rights and lawful basis to supply Contractor information and instruct the underlying payment.

18. Prohibited activities

We may restrict a transaction for a specific legal, sanctions, provider, fraud or security reason, or because it falls outside the approved role and service. An additional prohibited-activities policy is incorporated only when it is identified, made available and expressly stated to apply at onboarding or through a lawful update. An unpublished policy does not create an unrestricted retrospective forfeiture right.

We may change activity restrictions for valid reasons in accordance with Section 26. Immediate action is limited to circumstances where urgent legal or security protection is justified and legally permitted. A restriction on future use does not automatically eliminate existing Balance obligations.

19. Account security

You must keep your Finotive One and Pay credentials, authentication methods, email account, devices and recovery information secure. Do not share credentials or allow someone else to operate your personal account. Approved business representatives use individual credentials under Section 3.5, never a shared login.

Tell us promptly at [email protected] if an account, device or credential may have been compromised, a destination has been changed without authority or a payment is unauthorised. You may also use an available official in-Platform security channel. These reports may be submitted at any time; submission does not mean that a channel is staffed continuously or promise a response time shorter than we actually provide, but mandatory security-response duties remain applicable.

We may require reauthentication, additional verification, destination reconfirmation or a proportionate cooling-off period after a material security change, where legally permitted. We may temporarily block access or payment functionality to protect funds. Account activity and loss allocation are governed by Section 16; you are not automatically responsible for a security failure for which we are legally responsible.

We will use official channels for security communications. Our staff will not ask for a wallet seed phrase or for you to send money to an alleged “safe account”. Keep contact details current and independently verify suspicious messages.

20. Intellectual property

Finotive Pay and its licensors retain ownership of the Platform, software, content, interfaces, documentation, branding and technology. You receive a limited, revocable, non-exclusive and non-transferable right to use them for the approved service. No ownership is transferred. You may not copy, scrape, reverse engineer, circumvent security or misuse the technology except to the extent a restriction is prohibited by law. Your rights in your own data and materials remain governed by the applicable terms and privacy notices.

21. Suspension, termination, residual balances and inactivity

21.1 Suspension and termination by us

We may suspend or terminate access for a material breach, fraud, abusive conduct, unlawful activity, payment default, compliance or sanctions concerns, prolonged inactivity or another legitimate legal, operational or risk reason. Measures must be proportionate and any notice required by law must be given. Immediate restriction or termination may be used where justified by a serious breach, legal requirement or material security risk.

For termination on ordinary operational or commercial grounds, we will provide at least 30 days’ notice, or a longer period required by law. Where an applicable payment framework requires two months’ notice, that period applies. We will explain the reason where legally permitted. A provider request alone does not confer a right to keep your money.

21.2 Closure requested by you

You may request closure through an enabled dashboard control or [email protected]. We will identify outstanding instructions, lawful fees, restrictions and the remaining Balance, close or cancel revocable functionality and arrange final settlement under this Section. An unresolved issue may prevent immediate settlement of the affected amount but does not justify an unrelated new obligation or penalty.

21.3 Final settlement and residual amounts

On closure, a valid Available Balance is payable to an eligible verified destination in your own name, less lawful charges, subject to a legally required hold or return. If a normal minimum prevents a final payment, contact us for a practicable alternative or an exception. We will not require a new purchase or deposit merely to recover money where law requires us to return it.

We may offer an eligible lower-cost route or voluntary use of the remaining Balance under Section 7. Neither a rejected destination nor a temporarily unavailable provider makes a recoverable Balance automatically ours. Amounts released after a review or returned after closure remain identifiable and are handled through the same final-settlement process.

21.4 Dormancy trigger and warnings

A personal Trader or Affiliate account may be classified as dormant after 365 consecutive days without Qualifying Activity. We will not count inactivity caused by a Finotive-imposed access block, an unresolved payment complaint, a legal freeze or circumstances in which you cannot reasonably access or claim the funds because of our action. A substantive new monetary credit resets the inactivity period for this purpose.

Before closing a dormant account, we will send a notice to your registered email and dashboard, where accessible, identifying the Balance, proposed action and a claim or reactivation deadline at least 90 days later. We will issue a reminder at least 30 days before that deadline. If delivery fails, we will take reasonable further contact steps using verified details and will not rely solely on an inaccessible dashboard.

An authenticated login, verified claim or other Qualifying Activity before the deadline stops the proposed closure, subject to lawful verification. You remain responsible for keeping your contact details current. Account Details may be disabled separately, but that does not accelerate the period for dealing with the Balance.

If the deadline passes without Qualifying Activity, we may close the dormant account. Closure does not extinguish your Balance or transfer it to us. We will continue to record the amount owed and will pay it, on a verified claim, to an eligible destination in your own name under Section 21.3, subject to any legally required hold or return. Client and Contractor funds, restricted amounts and amounts subject to an unresolved claim are dealt with under their own provisions.

21.5 Implementation, records and other events

For an existing user, any new dormancy condition applies only after valid notice and acceptance under Section 26. The 365-day dormancy period starts no earlier than the date that condition validly takes effect for that user. Historical inactivity is not used to impose immediate closure.

We retain the closure statement, notices, transaction evidence and any surviving claim records for the applicable lawful period. You may request relevant records through support after closure. Verified estate, insolvency or other legally authorised representatives may contact us through the controlled process, without sharing the deceased or affected user’s credentials. Accrued rights and lawful recovery obligations survive closure.

22. Disclaimers and service interruption

The Platform and services are provided on an “as is” and “as available” basis to the extent permitted by law. We do not guarantee uninterrupted availability, continued availability of every feature or route, or the performance of a Client or Contractor. A stated processing estimate is not a guarantee, but an estimate does not replace a mandatory performance deadline.

We may temporarily interrupt services for maintenance, security, provider failure or events beyond reasonable control and will take reasonable steps to mitigate avoidable disruption. This does not extinguish Balance obligations or excuse a failure for which we remain legally responsible. No general disclaimer limits an expressly accepted fixed fiat quote, a statutory remedy or a valid obligation to account for funds.

23. Liability and indemnity

23.1 Allocation of responsibility

We are not responsible for a Contractor’s failure to perform, a Client’s failure to pay before we assume a payment obligation, the quality of deliverables or an underlying commercial dispute to which we are not a party. We are not responsible for a user-directed error or an external bank, provider or network failure except to the extent that responsibility is imposed on us by these Terms or applicable law.

For a business user, and to the extent permitted by law, we exclude indirect or consequential loss, lost profit, lost opportunity, business interruption and reputational loss. For a consumer, exclusions apply only where lawful and do not exclude reasonably foreseeable loss caused by our breach where consumer law requires us to bear it. The fact that a payment relates to trading does not by itself remove a valid remedy.

23.2 Business-only damages cap

Subject to Section 23.3, our aggregate liability to a business user for damages arising out of the same or related events is limited to the higher of EUR 1,000 and the Finotive Pay service fees actually paid by that user in the 12 months before the first event giving rise to the claim. This cap does not apply to a user acting as a consumer. We may agree a different business cap expressly in a separate commercial agreement.

23.3 Matters not limited

Nothing in these Terms excludes or limits fraud, fraudulent misrepresentation, wilful misconduct, death or personal injury caused by negligence where liability cannot be excluded, or any other non-excludable duty. The business damages cap does not limit our obligation to account for or repay a valid Balance, make a mandatory payment refund, correct an unauthorised or incorrectly executed payment where required, or meet a client-money or safeguarding obligation that cannot lawfully be limited.

A user claiming loss must take reasonable steps to avoid or reduce further loss where appropriate. We will not compensate the same loss twice. Neither mitigation nor a provider claim excuses us from a legal payment or refund obligation. Disputes are addressed through Section 29 without limiting court rights.

23.4 Targeted indemnity

To the extent permitted by law, you must reimburse the relevant Finotive Pay loss or reasonably incurred third-party liability directly caused by your fraud, deliberate unlawful use, intentional provision of false authority or deliberate circumvention of the payment-ownership rules. The indemnity does not cover loss caused by our own breach, negligence or unlawful conduct, an amount we could reasonably have avoided, or a cost or penalty that cannot lawfully be passed to you. We must provide a reasonable basis for the claim and may not recover twice.

24. Cancellation and subscriptions

Where a subscription is offered, the provider, price, tax, billing period, renewal date, cancellation method and any minimum commitment will be shown before purchase. Automatic renewal and any recurring deduction from Pay Balance require the authority disclosed and accepted at that time. A general Pay registration does not authorise an undisclosed subscription.

You may cancel through the subscription control made available on the Platform or by emailing [email protected]. We will acknowledge the request. Unless the accepted offer or mandatory law provides otherwise, cancellation stops the next renewal and service continues to the end of the paid period. We do not prevent cancellation by requiring a method that is unavailable. A request received before the disclosed renewal cutoff must be applied to that renewal.

We will not create an unauthorised negative Balance to fund a renewal. Insufficient available funds may lead to non-renewal or suspension under the agreed offer. Refunds, early termination charges and any entitlement to a pro-rated repayment depend on the agreed offer and mandatory law. Any statutory cooling-off or distance-contract rights, and any valid requirements for early performance consent, remain unaffected.

25. Data protection

Personal information is handled under the Finotive Privacy Policy, the Finotive One Account, KYC and Data Sharing Notice, any applicable Pay privacy notice and applicable law. Finotive Pay determines the purposes and means of processing where it acts as a controller. A provider or business Client may be an independent controller or processor depending on the actual activity; these Terms do not deem every participant to have the same role.

We may share information necessary for identity and business verification, fraud prevention, payment instructions, account ownership, compliance, support and dispute handling with relevant Finotive entities and providers, including OpenPayd, Transact365, Revolut and ChangeNOW. Required information may include payer and payee details, account identifiers and applicable crypto transfer information. The privacy notices describe legal bases, recipients, retention, rights and any lawful international-transfer safeguards.

A Client supplying Contractor data must have an appropriate legal basis and provide required information to the Contractor. Data is not retained indefinitely simply because it once appeared in a payment record. Account closure or an erasure request does not require deletion of records that must lawfully be retained; conversely, these Terms do not create an unlimited data-sharing permission. Privacy requests may be submitted through the channels in the applicable notice.

26. Changes to these Terms

26.1 Reasons and notice

We may change these Terms, fees, limits, routes or schedules for a valid reason, including a legal or regulatory requirement, a security or fraud risk, a provider or technology change, a change in service cost or a new or modified feature. Changes must be proportionate to their stated reason.

For a change to your disadvantage, we will give at least 7 calendar days’ advance notice where that period is legally sufficient. Any longer mandatory period prevails. In particular, where applicable payment-services framework rules require two months’ notice, we will give at least two months rather than seven days. This clause does not elect out of statutory consumer, microenterprise or payment-user protections.

26.2 Delivery and acceptance

We will send material notices to your registered email and make a retainable copy available through the Platform where accessible. The notice will identify the changes, reason, effective date and any right to reject or terminate. An inaccessible website update alone is not a substitute for legally required individual notice.

You may reject an adverse change before it takes effect and close the affected service without a change-rejection penalty. Existing lawful charges and pending instructions are settled under the applicable prior terms, subject to mandatory law. You retain any lawful right to withdraw or recover your Balance and are not required to make a new purchase to reject a change.

Express reacceptance will be obtained where required. Continued use or silence will count as acceptance only where legally permitted and clearly explained in the notice. Merely holding an inactive Balance is not unrestricted consent to new forfeiture or charging powers.

26.3 Immediate and prospective changes

A legally required or urgent security change may take effect earlier only to the extent law permits. We will explain it as soon as reasonably possible, unless prohibited. A provider’s commercial request does not by itself override a mandatory notice period. A change solely beneficial to you may take effect sooner where lawful.

A change ordinarily applies to future activity. We will not retrospectively change an accepted fixed fiat quote, impose a new fee on a completed transaction or convert previously permitted conduct into a breach merely because a rule changes. New promotional offers and market-dependent crypto execution prices operate under their disclosed terms and are not promises of a permanent offer or rate. Section 21.5 governs introduction of new dormancy conditions.

27. Governing law and jurisdiction

These Terms and any non-contractual obligations arising out of or in connection with them are governed by the laws of the Republic of Cyprus. Subject to any mandatory rights concerning applicable law or jurisdiction, the courts of the Republic of Cyprus will have jurisdiction over disputes arising out of or in connection with these Terms.

A choice of Cyprus law does not deprive a consumer of mandatory protection that applies under the law of their habitual residence where that protection cannot lawfully be excluded. No provision prevents use of a court, regulator or competent dispute-resolution body where you have a legal right to do so. A complaint under Section 29 is not a compulsory prerequisite that removes such a right.

28. Incorporation of Finotive One Terms

The Finotive One Master Terms of Use made available and validly accepted with these Terms are incorporated. They govern common identity, onboarding, security, technology and ecosystem matters. These Pay Terms govern Pay-specific Balances, payment ownership, transaction processing, fees, conversion, closure, complaints and liability.

Mandatory law applies first. These Pay-specific provisions prevail over a conflicting general provision only for the relevant Pay matter, including the limited business-representative permission in Section 3.5. That permission does not relax personal Trader access or ownership rules. No separate Finotive company becomes liable merely because it shares branding, systems or a login.

The relevant product terms govern purchases, Markets accounts and promotional offers made by another Finotive entity. Their numerical or product-specific conditions do not silently amend a Pay Balance or create unrestricted cross-entity set-off. Any Consultant Services Agreement applies only to its expressly identified services. The master agreement’s severability, non-waiver, lawful assignment, survival and general interpretation provisions apply subject to these limits and mandatory law.

29. Complaints and escalation

29.1 Making a complaint

You may complain free of charge by emailing [email protected] with the subject “Formal complaint”, using an available official support channel or writing to our registered office marked “Finotive Pay Complaints”. A communication that clearly expresses a complaint will be handled as such even if you do not use that label.

Provide your registered identity or user reference, relevant transaction or account reference, dates, a description, supporting information and the outcome sought. We may request further relevant evidence without preventing you from making the complaint. Security incidents should also be reported promptly under Sections 16 and 19.

29.2 Handling and timeframes

We will acknowledge the complaint within 3 Business Days and aim to provide a reasoned final response addressing the issues within 15 Business Days of receipt. In exceptional circumstances beyond our control, we will explain the delay before the 15-Business-Day period expires and give the expected final-response date, which will not exceed 35 Business Days where those payment-complaint rules apply. We adopt the same outer response period for other Pay complaints unless a stricter applicable rule requires sooner.

Any shorter or otherwise more protective mandatory deadline prevails. Asking you for more information does not automatically restart a statutory response clock. A complaint does not automatically prove entitlement to compensation or require lifting a lawful freeze, but does not postpone a mandatory payment remedy.

29.3 Escalation and external rights

You may ask for escalation to the person responsible for Finotive Pay complaints by replying to the complaint acknowledgement or final response. We will provide an appropriately independent internal review where practicable. Product entitlement disputes may be routed to the relevant Finotive Service provider, while we remain responsible for complaints about our own Pay processing.

Our final response will identify any competent external dispute-resolution route, its contact details and applicable time limits where such a route is available or must be disclosed. Nothing in these Terms promises jurisdiction of a particular ombudsman unless it actually applies, or restricts a legal right to approach a court, regulator or other competent body. Any required standing external-dispute disclosure will be made available before you enter the relevant service.