Terms and Conditions

Created with Lunacy

1. GENERAL PROVISIONS

1.1 The Terms and Conditions set out in this agreement (the “Agreement”) form a contract between you and BlaBla Connect Limited, a company incorporated in the UK with company number 08246355 and trading as PassTo, an e-money service provider registered and domiciled in the UK and bound by the legal requirements of the Financial Conduct Authority (FCA) (“PassTo”).

1.2 BlaBla Connect Limited is authorised by the Financial Conduct Authority as an Electronic Money Institution under the Electronic Money Regulations 2011 for the issuing of electronic money. We are included in the FCA’s Register of Electronic Money Institution firms (Firm Reference Number 900662) which can be found on the FCA website www.fca.org.uk

1.3 If there is any aspect of this Agreement that you do not understand or where you require further information, you should contact our Customer Support team via the contact details provided below:

support@passto.app

1.4 All communications pursuant to and connected with this Agreement will be in English, including any notices provided to you. You have the right to receive a copy of this Agreement any time throughout its duration.

2. THE SERVICE

2.1 The Service enables users to store money and transmit money to certain third parties in accordance with this Agreement using the PassTo website and mobile applications.

2.2 Using the Service is subject to full compliance with the Agreement. By using or continuing to use the Services you are deemed to accept this Agreement and all policies of PassTo eWallet.

2.3 In this Agreement, “you” or “your” means you, the person that is, at the relevant time or times, a User of the Service and that is bound by this Agreement. Unless otherwise stated, “PassTo”, “we” or “our” will refer collectively to PassTo, its officers, directors, agents, subsidiaries, joint ventures, employees and suppliers.

2.4 PassTo may amend this Agreement by giving you two months’ notice. If you do not object to the amendments within two months’ of our notice of amendment, such amendments will be deemed to have been accepted by you.

2.5 This is an important document, which you must consider carefully when choosing whether to use the Services. We, at PassTo may close, suspend, or limit your access to your Account or the Services, and/or limit access to your funds if you breach this Agreement.

2.6 You are solely responsible for understanding and complying with all laws, rules and regulations of every jurisdiction or country that may be applicable to you in connection with your use of the Services.

3. DEFINITIONS

Account means a PassTo eWallet account.

Add Funds / Adding Funds means the transfer of money to your PassTo eWallet Account in accordance with Clause 8.1.

AML means Anti-Money Laundering.

Business Days means days that are Monday through Friday except statutory holidays that are observed in UK.

Claim means a challenge to a payment that a User files directly with PassTo.

Customer Support means PassTo customer support, which can be accessed online through https://www.passto.app or by email at support@passto.app

Due Diligence means the investigation or exercise of care that a reasonable business or person is expected to take before entering into an agreement or contract with another party, or an act with a certain standard of care.

Error means a processing error made by us or our service providers in which your Account is mistakenly debited or credited.

Information means any Account information that you provide to us, including but not limited to personal information, financial information, or other information related to you or your business.

Password means an alpha-numeric code which enables logging into an Account.

Payment Method means the payment method used to fund a transaction.

Payment Processing means a general business category including third-party electronic payment solutions.

Payment Transaction means either Adding Funds or Withdrawing Funds.

Policy or Policies means any policy of ours that is set out in the PassTo eWallet website, and/or any agreements between you and PassTo that have been entered into via the PassTo eWallet website, or otherwise in connection with your use of the Service(s).

Proxy Server means in computer networks, a server (a computer system or an application program) that services the requests of its clients by forwarding requests to other servers.

Restricted Activities means those activities described in Clause 10 of this Agreement.

Reversal means we reverse a payment you received because (a) it was sent to you in Error by us, (b) the sender of the payment did not have authorisation to send the payment, (c) you received the payment for activities that violated this Agreement, the AUP (as defined below) , or any other Policy, or (d) we decided a Claim against you.

Send Money means a function that enables a User to send funds to another User using their name and PassTo Account details. Both the receiver and the sender of the funds must be PassTo eWallet holders.

Service(s) means all products and services and any other features, technologies and/or functionalities offered by PassTo on its website or through any other means.

Substantial Change means a change to this Agreement that reduces your rights or increases your responsibilities.

User means a PassTo customer with an active eWallet account.

Account Verification means the identification of Users as part of BlaBla’ Connect Limited’s Know Your Customer (KYC) and Customer Identification Program (CIP) policy. Account Verification is important for the PassTo eWallet network as it enhances security and helps to protect our Users against fraud and money laundering. An account that has been verified by PassTo does not indicate or constitute an endorsement of a User or a guarantee of a User’s business practices or compliance with any applicable laws and regulations.

We, Us or Our means BlaBla Connect Limited (trading as PassTo).

Withdrawal of Funds / Withdrawing Funds means the withdrawal of funds from your Account in accordance with Clause 8.2.

4. USE OF THE SOFTWARE, PRODUCTS AND BLABLA WEBSITES

4.1 PassTo provides the Service, i.e., third-party payment processing services and related actions on your behalf. At all times, your funds are held separately from those of our corporation and are not incorporated into or used for BlaBla Connect Limited’s operating expenses or corporate purposes. You acknowledge that PassTo offers an electronic payment Service and is not a bank. Our Service facilitates a display of your electronic transactions.

4.2 By initiating and sending payments through the Service or adding funds to your wallet, you appoint PassTo as your agent to obtain the funds on your behalf and transfer them to the designated receiver. When a payment is made, PassTo processes the funds on your behalf through the banks or institutions that hold your funds. You will not be able to withdraw those funds or send those funds to any other User unless the initial transaction is verified.

4.3 When you receive funds through the Service, PassTo processes the funds on your behalf through the banks or financial institutions that hold your funds. Funds received in your account are held in a pooled bank or financial institution accounts.

5. ELIGIBILITY

5.1 You confirm that all of the following are true of you from your entry into this Agreement until the termination of your Account:

(a) You are an individual at least 18 years old at the time of registering an Account and you acknowledge that PassTo reserves the right to ask for official personal identification documents for the purpose of verification and you promise that you do not require the consent or approval of any other person or entity to enter into this Agreement.

(b) You are the beneficial owner of the Account, and conduct transactions only on your behalf and not on behalf of any third party.

(c) You are not in violation of any laws or regulations of your own country or residence or of any other country by opening an Account or using the Service. Breach of this clause will lead to closure of your Account and you will hold all legal responsibility.

(d) Accounts are non-transferable and under no circumstances are to be transferred or assigned to a third party or legal entity.

(e) You must comply with security, password protection and identity protection recommendations provided by PassTo and by following its relevant Policies.

(f) You will not do anything to harm the reputation of PassTo.

6. ACCOUNT TYPES AND ACCESS

6.1 PassTo only provides services to consumers for personal non-commercial use.

6.2 Members who try to access their Account through a proxy server will be denied access. They must contact their internet service provider to disable their proxy server.

7. ACCOUNT VERIFICATION

7.1 We must verify Users in order to comply with the applicable laws and regulations including FCA rules, Anti-Money Laundering (AML) regulations and Counter- Terrorism Legislation. You agree to complete Account Verification procedures when you register for a new Account.

7.2 You authorise PassTo, directly or through third parties, to make necessary inquiries to verify your identity. PassTo cannot and does not guarantee any User’s identity. PassTo makes no promises to you regarding the identity of any User.

7.3 Personal Account Verification: We may request and you agree to provide any of the following in connection with our Account Verification procedures to authenticate your personal identity:

(a) a valid government-issued photo identification;

(b) an attestation of identity;

(c) Proof of residential address dated within the last 3 months (ie: a utility bill or bank statement)

(d) Liveness check (video) taken with a smartphone or other device; and

(e) any other applicable documentation as requested from time to time.

7.4 File Type for the Submission Documents & Digital Photographs: We may but do not guarantee that we will accept documentsthat are digitally photographed, scanned, or photocopied, in any of the following file formats: JPG, PNG and PDF. You can also provide digital documents though services other online user sites offer.

7.5 Worldwide databases:PassTo conducts verification through worldwide databases as part of its Account Verification procedures, which includes databases used by PassTo to achieve compliance with OFAC (Office of Foreign Asset Control) requirements, United Nations (UN) global sanctions reports and government watch-lists. At any time, due to a requirement to satisfy any of the Account Verification methods including the use of worldwide databases, we may ask you and you agree to provide information or documentation as requested from time to time.

7.6 Failure to complete Account Verification: If you refuse or fail to complete or respond to any requests we have made for information or documents in connection with Account Verification, we may refuse to open an Account for you or your Account may be suspended regardless of any or all pending or unsettled transactions.

7.7 Please note that PassTo reserves the right to refuse a transaction or deny operation to a client or account at any time should suspicion arise that it may be connected to money laundering, criminal activity or any other predicate offence to money laundering. PassTo will not enter into any business arrangement with anyone or group suspected of or directly involved in money laundering, or where funds have been from either the sources or ends of an illegal activity.

7.8 In the event that PassTo receives, during its request for documentation, deceptive documentation, contact details, or any other false information, PassTo will terminate the offending account immediately. PassTo is legally bound to report such misdemeanors to the relevant authorities, and as such the user may be subject to a criminal investigation. PassTo participates fully in the regulated anti-money laundering rules. For customers from the European Union the EU AML Regulations are applicable. Users are under agreement to keep their accounts and contact information current at all times. Providing false, doctored, or deceptive documents is considered as fraud and will be treated as such.

8. ACCOUNT BALANCES

8.1 Adding Funds: You can add funds to your Account by online payment gateways or bank transfers, according to the Services available in your country. Once you have funded your Account, you can use the Services. If you have any questions regarding Adding Funds, contact PassTo Customer Support by e-mail at support@passto.app or through https://www.passto.app

8.2 Withdrawing Funds: You can withdraw funds from your Account via one of the following methods:

(a) transferring funds by way of an electronic transfer to other Accounts held by other Users (a “Payment Transaction”); or

(b) transferring funds to your personal bank account that is not your PassTo eWallet Account.

8.3 We may block a Withdrawal of funds if:

(a) your instructions are unclear;

(b) if we are required to do so in accordance with any applicable laws or regulations or if we deem it necessary or appropriate to be compliant with any applicable laws or regulations; or

(c) if we suspect criminal activity.

8.4 If you have any questions regarding the Withdrawing Funds, contact PassTo Customer Support by e-mail at support@passto.appor through https://www.passto.app].

8.5 A Payment Transaction will be considered as authorised by you if you have given your consent to the execution of the Payment Transaction. You are deemed to have provided your consent when confirmation via PIN code, biometric or other verification options as provided through the PassTo app after each transaction request.

8.6 Closing Your Account: You may close your account at any time by contacting customer support by e-mail at support@passto.app or through https://www.passto.app

8.7 You will remain liable for all obligations related to your Account even after the Account is closed.

8.8 Interest or Earnings: You understand and accept that you will not receive interest or other earnings on the funds that PassTo processes on your behalf through pooled bank or financial institution accounts. In consideration for your use of the Service, you irrevocably transfer and assign to PassTo any ownership right that you may have in any interest that may accrue on funds held in pooled bank or financial institution accounts. This assignment applies only to interest earned on your funds, and nothing in this Agreement grants PassTo any ownership right to the principal of the funds. In addition to or instead of earning interest on pooled bank or financial institution accounts, PassTo may receive a reduction in fees or expenses charged to it by banking services by the banks or institutions that hold your funds.

8.9 Timing of Payments: Once you have submitted instructions for a transaction to us via the PassTo app, we will execute the transaction on the same business day and the payee will receive funds no later than the next business day. It is important to note that the actual time required for the funds to reach the recipients account is not entirely in our control. The actual time the transfer will take from the moment it is initiated in your PassTo wallet to the moment it reaches the recipients account may depend on many factors relating to the operational and compliance procedures of the recipient bank, the banking network the payment goes through and any intermediary parties involved. It also depends on varying working hours of different institutions. For this reason, we can only provide an estimation and not the actual time.

8.10 Right of Set-off: Without prejudice to any other rights PassTo may be entitled to, we may at any time and without notice set off any amount you (whether actual or contingent, present or future) owe PassTo against any amount owed by PassTo to you.

9. ERRORS AND UNAUTHORISED TRANSACTIONS

9.1 Protection for Unauthorised Transactions and Errors: An “Unauthorised Transaction” occurs when a payment is sent from your Account that you did not authorise, for example in the case of fraud. This could occur if someone steals your password, uses the password to access your Account, and sends a payment from your Account (therefore an Unauthorised Transaction has occurred).

If you give someone access to your Account (by giving them the username or password to your Account) and they conduct transactions without your knowledge or permission, you are responsible for any resulting use and loss and this will not classify as an Unauthorised Transaction. We will not be liable or responsible for the recovery of funds if you send a payment to the wrong party, or send a payment for the wrong amount (based on a typographical error, for example) and this will not classify as an Unauthorised Transaction, nonetheless, we will, where possible, make reasonable efforts to recover the funds in such circumstances.

9.2 You should regularly review your Account history statement to ensure that there has not been an Unauthorised Transaction or Error. We will send an email with a copy of your Account history statement to the primary email address you have provided once a month in order to notify you of each transaction from your Account. You should also review these transaction confirmations to ensure that each transaction was authorised and is accurate.

9.3 When an Unauthorised Transaction or an Error occurs in your Account, we will cover you for the full amount of every Unauthorised Transaction (as defined below) or Error so long as you follow the procedures set out below.

9.4 Notification Requirements: You must notify us immediately on becoming aware of any Unauthorised Transaction or Error, this may include the following:

(a) there has been an Unauthorised Transaction or Unauthorised access to your Account;

(b) there is an Error in your Account history statement;

(c) your password has been compromised; or

(d) you need more information about a transaction listed on the statement or transaction confirmation.

9.5 When you notify us of an Unauthorised Transaction or Error, provide us with all of th­­­­e following information:

(a) your full name and the email address registered to your Account;

(b) a description of the suspected Unauthorised Transaction or Error (including the amount and date of the suspected Unauthorised Transaction or Error) and an explanation as to why you believe the transaction qualifies as an Unauthorised Transaction or Error;

(c) whether you need more information to identify the transaction and what the information is; and

(d) the amount of any suspected Unauthorised Transaction or Error.

9.6 If you notify us orally, we may require that you send the above information in writing within ten (10) Business Days of your oral notification.

9.7 You must notify us of any Unauthorised Transaction or Error within 13 months from the date of the Payment Transaction; failure to do so will result in you waiving any right to remedy the Unauthorised or incorrectly executed Payment Transaction unless we have failed to inform you of the occurrence of the Payment Transaction within 13 months of Payment Transaction.

9.8 Actions after Receipt of Your Notification: Once you notify us of any suspected Unauthorised Transaction or Error in accordance with the Clause 9.2 above (or we otherwise learn of an Unauthorised Transaction or Error) we will do the following:

(a) We will conduct an investigation to determine whether there has been an Unauthorised Transaction or Error and if so, whether the Unauthorised Transaction or Error is eligible for protection (an “ Eligible Unauthorised Transaction”). We may request additional information from you during our investigation and you agree to provide such information (failure to do so will result in elongating the time we will take to complete our investigation set out in Clause 9.5(b) and Clause 9(c) below).

(b) We will aim to complete our investigation within ten (10) Business Days of the date we received your written or oral notification of the suspected Unauthorised Transactions or Error. If your Account is new (i.e., the first transaction from your Account was less than 30 Business Days from the date of the transaction), we may take up to 20 Business Days to complete this investigation. If we need more time, we may take up to 45 Days to complete our investigation.

(c) We will inform you of our decision within 3 Business Days after completing our investigation. If we determine that there was an Unauthorised Transaction or Error, we will promptly credit the full amount into your Account within 3 Business Day of our determination. If we decide that there was not an Unauthorised Transaction or Error, we will include an explanation of our decision in our email to you.

10. RESTRICTED ACTIVITIES

10.1 You will not during the course of this Agreement, your use of the PassTo website (https://www.passto.app), your use of your Account, your use or acceptance of the Services, or in the course of your interactions with PassTo, other Users, or third parties generally do any of the following (“ Restricted Activities”):

(a) Breach this Agreement or any other Policy we have notified you of;

(b) Breach any applicable law, statute, ordinance, or regulation (including but not limited to legislation/regulations relating to money laundering and / or financing terrorist activities);

(c) use the services in a manner that you knew or reasonably ought to have known or intended to tamper, hack, modify or otherwise corrupting the security or functionality of the Service (whether for your own Account or others)

(d) act in a manner that is defamatory, trade libelous, threatening, harassing, abusive or otherwise reasonably deemed by PassTo to be inappropriate;

(e) provide PassTo or any other User with information that was known by you to be or ought to be known by you to be false, inaccurate or misleading (including but not limited to submitting altered documents for Account Verification);

(f) engage in potentially fraudulent or suspicious activity and/or transactions;

(g) refuse to cooperate in an investigation conducted by us or any applicable regulator or government authority in connection with your Account; or refuse to provide confirmation of your identity to PassTo upon request;

(h) control an Account that is linked to another Account that has engaged in any of the Restricted Activities;

(i) cause fees, fines, penalties or any other liabilities to be incurred by PassTo, other Users or third parties;

(j) use your Account or the Service in a manner that PassTo reasonably believes to be an abuse of the system or a violation of network rules;

(k) disclose or distribute another User’s information to a third party without prior consent from the User to do so;

(l) take any action that imposes an unreasonable or disproportionately large load on our infrastructure;

(m) take any action which you know or ought to have known would facilitate, use or create viruses, Trojan horses, worms ,time bombs, cancelbots or other computer programming routines that may damage, detrimentally interfere with, surreptitiously intercept or expropriate any system, data or information belonging to or used by PassTo (i.e. BlaBla Connect Limited);

(n) take any action which you know or reasonably ought to have known was likely to cause PassTo to lose (in whole or in part) the services of its internet service provider, payment service providers or other suppliers;

(o) use an anonymising proxy, robot, spider or other automatic device, or manual process to monitor or copy our website without our prior written consent;

(p) use any device, software or routine to bypass our robot exclusion headers, or interfere or attempt to interfere with our website or the PassTo eWallet Services;

(q) spamming (including and not limited to using spam-ware, spy-ware, etc.);

(r) use your Account as a virtual terminal;

(s) use the PassTo eWallet brand to market or advertise non-PassTo Services;

(t) using or selling any form of e-cash, web cash or other matter, tangible or not, that is redeemable for a product or service from a third party;

(u) diluting our traffic by using our trademarks (including but not limited to Ad words, whether as key words, meta-data or otherwise);

(v) act on behalf of a third party (including but not limited to acting as a payment processor to collect payments on behalf of merchants);

(w) act in the capacity of a business or for the purpose of a business (whether incorporated or not) carried on by you or a third party, including but not limited to any business associated with: (i) the sale of traveller’s cheques or money orders, (ii) currency exchanges or cheque cashing; (ii) credit repair or debt settlement services; (iv) credit transactions or insurance activities; (v) the sales of products or services identified by any applicable government agency to have a high likelihood of being fraudulent;

(x) use the Services for the purpose of gambling, including, but not limited to casino games, sports betting, horse or greyhound racing, lottery tickets, other ventures that facilitate gambling, games of skill (whether or not it is legally defined as a lottery) and sweepstakes without: (i) the operator having obtained prior approval from PassTo; and (ii) the operator and customer being located exclusively in jurisdictions where such activities are permitted by law.

The above list of Restricted Activities is not exhaustive, and may be updated at any time (and notified to you).

11. CONSEQUENCE OF RESTRICTED ACTIVITIES (INCLUDING BREACH OF AGREEMENT)

11.1 If we, in our sole discretion, believe that you may have engaged in any Restricted Activities, we may take various actions to protect PassTo, its shareholders, subsidiaries and affiliates, other Users, other third parties or you from Reversals, Claims, fees, fines, penalties and any other liability. The actions we may take include but are not limited to the following:

(a) We may close, suspend, or limit your access to your Account or the Services;

(b) We may refuse to provide the Services to you permanently; and

(c) We may hold your funds for a period of time reasonably needed to protect against the risk of liability to PassTo eWallet or a third party, or if we believe that you may be engaging in potentially fraudulent or suspicious activity and/or transactions.

11.2 You may be responsible for any Reversals, Claims, fees, fines, penalties and other liability incurred by PassTo, a User, or a third party caused by or arising out of your breach of this Agreement, and/or your use of the Services. You agree to reimburse PassTo, a User, or a third party for any and all such liability.

12. CHARGES

The following charges will be incurred by you for the following:

(a) Refusal of a Payment – Any incurred costs will be passed on to you per Payment Transaction, when such Payment Transaction is refused by an intended recipient’s bank or payment services firm. There will also be an additional administrative cost of £15.00 associated with dealing with such payments;

(b) Revocation of a Payment Transaction – Any incurred costs will be passed on to you per Payment Transaction when you have asked us to reverse (and we have made such reasonable efforts to reverse the funds) of a Payment Transaction. There will also be an additional administrative costs of £15.00 associated with dealing with such payments;

(c) An Incorrect Recipient Information – if you make an error in the information you provide us for the proposed recipient of your Payment Transaction and ask us to recover the funds, any incurred costs will be passed on to you per Payment Transaction. We will make reasonable efforts to recover the funds (even if we are unable to ultimately do so). There will also be an additional administrative fee of £15.00 associated with dealing with such payments;

13. LIABILITIES

13.1 Our liabilities: Nothing in this Agreement shall serve to limit or exclude our liability for a breach of our obligations to you under this Agreement or that we otherwise are required to provide by law (including an obligation to provide a service as described). Nor shall anything in this Agreement limit our liability for death or personal injury caused by our negligence or for our fraud. You can find more about your statutory rights through your Citizens Advice Bureau or from the Competition and Markets Authority (or equivalent outside the UK).

13.2 If you have a dispute with one or more Users or third parties, you agree to compensate us for all claims, suits, amounts, fees, damages and costs that we incur in relation to the dispute between you and the other User or third party.

13.3 Your liabilities: Your Account is protected by a login credentials. You are responsible for maintaining adequate security and control of any and all of your usernames and passwords or any other codes that you use to access the Service.

13.4 If you share your username or password with others or allow others to discover and use your username and password with the Account, you are giving access to the funds and information in the Account. You assume all responsibility for Payment Transactions that result from your failure to protect your username and password. It is important to contact us immediately if you believe your Account may have been compromised or someone has transferred money through your Account without your permission.

13.5 We recommend you adopt the following practices to protect your login credentials:

(a) keep your login credentialssecurely stored (do not record your login credentialsin places that are easy to find by others or hack) and do not share your login credentialswith anyone else. If you feel that your password might have been compromised, report it immediately to PassTo at e-mail at support@passto.app

(b) report any unusual transaction records in your Account(s) to PassTo e-mail at support@passto.app

(c) regularly change your PIN code; and,

(d) beware of email phishing scams and do not open unrequested file attachments. We will not display your personal information in emails or ask you to confirm any personal data by replying emails.

13.6 You may be required to compensate us for any losses we incur as a result of your failure to protect your login credentials.

13.7 Risk-Based Holds: We may, in our sole discretion, place a hold on any or all of the payments you receive when we believe there may be a high level of risk associated with you, your Account, or any or all of your transactions. Our determination may be based on different factors and we may rely on information it receives from third parties. If we place a hold on a payment, the funds will appear in your “pending balance” and the payment status will indicate the hold.

If we place a hold on any or all of the payments you receive, we will provide you with notice of our actions, where permissible by applicable laws and regulations. We will release the hold on any payment after 30 Days from the date the payment was received into your Account unless we have a reason to continue to hold the payment such as (a) the receipt of a Dispute, Claim, or Reversal, (b) we believe that you have violated this Agreement or any other Policy and that such a violation results in the need to continue holding the funds, or (c) we believe that you may be engaging in potentially fraudulent or suspicious activity and/or transactions. In such an event, we may continue holding the payment in your Account until the matter is resolved pursuant to this Agreement.

13.8 Disputed Transaction Holds: If a User files a Dispute, Claim, or Reversal on a payment you received, we may place a temporary hold on the funds in your Account to cover the amount of the liability. If you win the dispute or the transaction is eligible, we will lift the temporary hold. If you lose the dispute, we will remove the funds from your Account.

13.9 Reserves:We may, in our sole discretion, place a reserve on funds held in your Account if we believe there may be a high level of risk associated with your Account. If we place a reserve in your Account, transactions will be shown as “pending” in your PassTo eWallet balance, and you will not have access to funds in a “pending” status until they are cleared.

If your Account is subject to a reserve, we will provide you with notice specifying the terms of the reserve, where permissible by law and regulations. The terms may require that a certain percentage of the amounts received into your Account are held for a certain period of time, or that a certain amount of money is held in reserve, or anything else that we determine is necessary to protect against the risk associated with your Account. We may change the terms of the reserve at any time by providing you with notice of the new terms.

13.10 Please note that an Account that has been terminated at the request of a User cannot be re-opened. If you wish to re-use the Services, you will be required to open a new Account. We reserve the right to terminate your Account in accordance with Clause 10 if you withdraw your consent to receive electronic communications. Any electronic communications will be considered to be received by you within 24 hours of the time we post it to our website or email it to you. Any notice sent to you by postal mail will be considered to be received by you in three (3) Business Days after we send it.

14. CONFIDENTIALITY

14.1 CONFIDENTIALITY OF YOUR INFORMATION: PassTo agrees to treat all information provided by you to us as confidential unless the information is in the public domain other than as a result of being disclosed in breach of this Agreement. However, you agree that PassTo may disclose information provided by you to us without your consent to:

(a) those who provide advice or other services to PassTo, including legal advisers, worldwoide databases as referenced in Clause 7.5 , or other organisations that help PassTo or its Affiliates make credit decisions and reduce the risk of fraud;

(b) in the course of carrying out Account Verification, fraud prevention or credit control checks;

(c) any other party where PassTo is required to do so by Applicable Regulations;

(d) to any regulator or government agency upon request;

(e) to any third party as necessary to meet PassTo’s obligations under this Agreement including a trading venue or trade repository.

14.2 CONFIDENTIALITY OF PASSTO’S INFORMATION: You agree to treat all non-public information you hold about PassTo or any of its Affiliates as confidential, unless the information is in the public domain other than as a result of being disclosed in breach of this Agreement. PassToagrees, however, that you may disclose that information in the following circumstances:

(a) to any regulator or government agency upon request from such entity, provided you notify us (to the extent legally permissible) as soon as possible upon becoming aware of any such request; and,

(b) where reasonably necessary, to your agents and others who provide legal or professional advice to you provided that you procure that your agents (or others who provide legal or professional advice) comply with the obligations set out in this Clause 14 as if they were a party to this agreement.

15. PERSONAL INFORMATION

15.1 PassTo collects personal information of Account holders based on the current laws of UK and as follows:

(a) Account holders are required to provide valid and accurate personal information during registration for the online payment gateways or bank transfer funding and withdrawal option provided by PassTo to be utilized. PassTo reserves the right to verify all Information provided and copies of personal identification documents and proof of address before an account registration is approved. Failing to comply with this clause could result in immediate suspension of your account to prevent fraudulent activity.

(b) The following documents are valid for personal information verification: valid government issued photo identification document or photographic driver’s license. Documents such as birth certificate, student card, or working badge are all examples of documentation that are NOT acceptable.

(c) The following documents are valid for address verification with a date of issue to you of within 3 calendar months: recent bank or credit card statement or a utility bill such as gas, electricity or telephone at a fixed residential address.

(d) Account holders must ensure that their Account details are reviewed regularly for current updates to ensure they are receiving PassTo’s communications. PassTo is not responsible for losses caused by Account holders failing to comply with this clause.

(e) Account holder’s personal information is kept for a period of up to five (5) years following the closure of an Account. Retention is necessary for compliance with legal obligations.

16. DATA PROTECTION AND YOUR PRIVACY

16.1 Your privacy matters to us. BlaBla provides privacy notices to it customers explaining its information practices and the choices they can make about the way their information is collected and used (the “ BlaBla Connect Privacy Policy”). You can access our BlaBla Connect Privacy Policy by following this link: https://www.passto.app/privacy-policy .

17. TRANSACTIONS

17.1 Account holders have access to all transactions carried out with their Account as well as any fees involved. Any possible irregularities are to be reported by contacting PassTo Customer Service department at e-mail at support@passto.app

(a) Peer to Peer Transactions – When arranging a funds transfer transaction a user must ensure they select the intended recipient for transfer of funds from the PassTo friends contact list within the app.

(b) Remittance- When arranging a funds transfer transaction a user must ensure they include the recipients, full name, bank account number swift/iban number and mobile number (if applicable) and any other recipient information which may be required.

(c) PassTo does not hold the responsibility for spelling errors of personal information made by a User arranging a remittance or PassTo eWallet transaction to another PassTo User. Personal information for a recipient of a remittance transaction includes the correct numbers of the recipient’s account details and/or correct spelling of the recipient’s name.

(d) PassTo does not have responsibility for any type of damage or loss caused by payments made to the wrong recipients, payments made for incorrect amounts, payments made by third parties through an account holders account, delays or data loss caused by telecommunications systems, government acts, fraud or an act that is unequivocally illegal or completely wrongful of the account holder.

(e) All transactions are final and cannot be reversed.

(f) In case of suspicious/fraudulent funds, PassTo reserves the right to put such transactions on hold for further investigation.

(g) A recipient’s Account will be credited with the proper amount, once the sender confirms the transaction.

(h) PassTo Account holders can withdraw funds from PassTo Accounts by using the Service. Times to complete a withdrawal may vary due to security reasons, amount being transferred and/or account validation.

17.2 All transactions are final, irreversible and possible misunderstandings between a User and another User and transaction disputes shall be acknowledged and resolved between them, except in the case of fraudulent use of the Service, declared and or a higher legal entity of an account holder’s jurisdiction. In a transaction dispute case deemed fraudulent, PassTo will investigate and (may) reverse transactions found to violate fair practice and/or are abusive towards other Users or the Service.

18. TERMINATION OF THIS AGREEMENT

18.1 PassTo reserves the right to terminate this Agreement either:

(a) by giving you two months’ written notice or

(b) without prior notice and with immediate effect if you breach this Agreement or any of PassTo’s Policies.

18.2 Insolvency Proceedings: If any proceeding by or against you is commenced under any provision of any bankruptcy or insolvency law, we will be entitled to recover the full balance of your Account immediately after the latest transaction (including reasonable legal costs and expenses) incurred in connection with the enforcement of this Agreement.

19. GUARANTEE

19.1 PassTo does not guarantee continuous, uninterrupted or secure access to any part of the Service, and operation of our site may be temporarily suspended for maintenance or upgrade or interference by numerous factors outside of our control. We will make reasonable efforts to ensure that requests for electronic debits and credits involving bank accounts are processed in a timely manner but we make no promises regarding the amount of time needed to complete processing because the Service is dependent upon many factors outside of our control, such as delays in the banking system.

20. COMPENSATION

20.1 You agree to compensate PassTo, its shareholders, subsidiaries, and affiliates, and our officers, directors, agents, joint ventures, employees and suppliers in respect of any claim, demand (including Solicitors fees), fine, or other liability incurred by PassTo or any third party due to or arising out of your breach of this Agreement.

21. INTELLECTUAL PROPERTY

21.1 https://www.passto.appand all other URLs, logos and trademarks related to the PassTo eWallet Service are either trademarks or registered trademarks of PassTo or its licensors. You may not copy, imitate or use them without our prior written consent. In addition, all page headers, custom graphics, button icons, and scripts are service marks, trademarks, and/or trade dress of PassTo. As well, you may not copy, imitate, or use them without our prior written consent. All rights, title and interest in and to the PassTo eWallet website, the technology related to the PassTo eWallet Service, is the exclusive property of PassTo and its licensors.

21.2 For the avoidance of doubt Users shall not use PassTo eWallet’s trademarks without the prior written permission from the PassTo administration or modify trademarks of PassTo (i.e. BlaBla Connect Limited).

21.3 Failing to comply with this Clause will result in a breach of this Agreement and may result in the immediate termination of your Account.

22. TAXES

22.1 It is your responsibility to determine what, if any, taxes apply to the electronic fund payments that you make or receive, and it is your responsibility to collect, report and remit the correct tax to the appropriate tax authority. For the avoidance of doubt, PassTo is not responsible and accepts no responsibility for determining whether taxes apply to your Payment Transaction, or for collecting, reporting or remitting any taxes arising from any Payment Transaction or your use of the Services. Any such deduction or withholding, if required by the laws of any country you are subject to, is your sole responsibility.

23. ASSIGNMENT

23.1 You may not transfer or assign any rights or obligations you have under this Agreement without our prior written consent.

24. COMPLAINTS HANDLING PROCEDURE

24.1 If you are dissatisfied with our Service, please contact our complaints department by email at support@passto.app.We will acknowledge receipt of your complaint and send you a copy of our complaints handling procedure.

24.2 We will investigate your complaint, which may involve asking you for further information. We aim to resolve complaints at the earliest possible opportunity, but will (unless you have accepted our earlier response) provide you with our final response within 15 business days from receipt of your complaint (unless something out of our control causes a delay, in which case we will provide you with our final response within 35 business days).

24.3 If you are not happy with our final response, you may be able to refer your complaint to the Financial Ombudsman Service for free. The Financial Ombudsman Service can be contracted at:

Financial Ombudsman Service

Exchange Tower

London

E14 9SR

Free phone: 0800 023 4567

Low-cost phone: 0300 123 9123

Email: complaint.info@financial-ombudsman.org.uk

Website: www.financial-ombudsman.org.uk

25. GOVERNING LAW & JURISDICTION

25.1 Unless otherwise provided by applicable law, this Agreement shall be governed by the laws of England and Wales. You can bring proceedings in respect of this Agreement and the Services in the English courts. However, as a consumer: (i) if you live in Scotland you can bring legal proceedings in respect of this Agreement or the Services in either the Scottish or the English courts; (ii) if you live in Northern Ireland you can bring legal proceedings in respect of this Agreement and the Services in either the Northern Irish or the English courts; and (iii) if you are resident in another member state of the European Union, you may be able to bring proceedings in the member state in which you are resident.

25.2 If you are a consumer resident in the European Union, you will benefit from any mandatory provisions of the law of the country in which you are resident. Nothing in this Agreement affects your rights as a consumer to rely on such mandatory provisions of local law.

26. NOTICES

26.1 Notices to You : You agree that we may provide you communications about your Account and the Service electronically via an agreed e-mail address.

26.2 Notices to PassTo: Except as otherwise stated above in section titled Errors and Unauthorised Transactions, notices to us must be sent by e-mail to support@passto.app

27. VIOLATIONS OF THIS AGREEMENT

27.1 We encourage you to report violations of this Agreement to PassTo immediately to the e-mail address: support@passto.app