TRANSFERRA UN LIMITED Terms and Conditions for Payment Services and the Use of Electronic Money

These Terms and Conditions for Payment Services and the Use of Electronic Money (the “Terms”) and each of the documents we refer to in them are our standard client agreement (the “Framework Contract”). It creates a legally binding agreement between You (hereinafter referred to as “You” or the “Client”) and TRANSFERRA UN LIMITED (hereinafter referred to as “Us” or “TRANSFERRA”) relating to the use of Electronic Money issued by TRANSFERRA as a means of payment on the Website. 

For your own benefit and protection, You should read these Terms and each of the documents we refer to carefully before accepting them. If you do not understand any point, please ask for further information.

TRANSFERRA is a company limited by shares incorporated in England and Wales with registered number 13014681 whose registered office is at 37th Floor 1 Canada Square, Canary Wharf, Greater London, London, United Kingdom, E14 5AA.

TRANSFERRA is an Electronic Money Institution (EMI) authorised by the Financial Conduct Authority (hereinafter also referred to as the “FCA”) to issue electronic money under the Electronic Money Regulations 2011 (EMRs 2011) and provision of other payment services under Payment Services Regulations 2017 (PSRs 2017), FCA Reference number: 942346.

You can contact  TRANSFERRA at its registered offices, which are at 37th Floor 1 Canada Square, Canary Wharf, Greater London, London, United Kingdom, E14 5AA, or by email at: info@transferra.uk 

References hereinafter to the “Parties” are a reference to You and TRANSFERRA.

1. Definitions

For the purposes hereof, the words hereafter are defined as follows:

Business Day: means a day other than a Saturday, Sunday or a public holiday in England when financial institutions in London are open for business.

Client: any natural or legal person acting on their own behalf and holding Electronic Money registered in an E-Wallet Account opened in their name, in order to carry out one or more Payment Transactions.

Electronic Money: means the monetary value available at any given time that represents a debt payable by TRANSFERRA to the Client. Electronic Money is issued by TRANSFERRA in exchange for the Client’s delivery of the corresponding funds and constitutes a means of payment exclusively accepted by the Recipients. TRANSFERRA stores the Electronic Money on its server in an E-Wallet Account opened for this purpose.

E-Wallet Account: an account opened in TRANSFERRA’s system in the name of the Client and used to make Payment Transactions. It’s allowing TRANSFERRA:

(a) to identify in its records each Client’s Payment Transaction.

(b) to determine the amount of Electronic Money available to the Client at any time. The E-Wallet Account may under no circumstances be compared to a deposit account or a current account.

Fee Schedule: means the document comprising all the fees payable by a Client for the use and management of an E-Wallet Account and in respect of Payment Transactions made using an E-Wallet Account. The Fee Schedule is included in the Website’s pricing.

Login: means the data required for TRANSFERRA to identify a Client in order to get access to your E-Wallet Account.

Order: means the instruction given by the Client to TRANSFERRA via the System for the purpose of carrying out a Payment Transaction. An Order may not be withdrawn by You after the date on which it is deemed irrevocable as indicated in these Terms.

Payment Transaction: means a money transfer operation in Client E-Wallet Account, wherein funds received by the Client and sending and converting initiated by the Client.

Recipient: means private individual or legal entity specified in the Order as recipient of funds of the Payment Transaction.

Strong Customer Authentication: means authentication based on the use of two or more elements that are independent, in that the breach of one element does not compromise the reliability of any other element and designed in such a way as to protect the confidentiality of the authentication data. Rules for Strong Customer Authentication are set in the Payment Services Regulations 2017 (PSRs).

Terms: means the present document.

Website: means the website which is operated by TRANSFERRA at https://transferra.uk/.

2. Purpose

2.1. These Terms and Conditions constitute the entire terms and conditions concluded between the Parties for the provision of e-money services and the opening and management of Your E-Wallet Account.

2.2. The services that will be provided by Us under these Terms and Conditions shall include: (i) the opening and management of an E-Wallet Account, (ii) issuing e-money to your E-Wallet Account (upon receipt of cleared funds paid to Us by an accepted payment method), (iii) redeeming e-money (following a request by you to redeem e-money held in your E-Wallet Account and funds converting).

3. Client Registration

3.1. Registration procedure and procedure for opening an E-Wallet Account:

3.1.1. You must provide:

(a) your surname, name and  email address (for natural persons); or

(b) Company name, e-mail address (for legal persons), if TRANSFERRA is not already in possession of this information.

3.1.2. You confirm upon submission of Your request to register to TRANSFERRA that:

(a) (if You are a natural person) You are at least 18 (eighteen) years old;

(b) You are legally competent to enter into this Framework Contract;

(c) You are acting on your own behalf and not for any other person; and

(d) all information that You provided during registration is true, accurate and up-to-date.

3.1.3. Legal E-Wallet Account requires the Client to submit the application form, documents and information set by TRANSFERRA. To become a Client, the Client must apply providing all of the information requested on the registration stage of Website and 3rd party AML providers. The Client must not provide any false, inaccurate, incomplete or misleading information. The Client may only open an E-Wallet Account in TRANSFERRA if it is legal to do so in the Client’s country of residence. By opening an E-Wallet Account in TRANSFERRA the Client represents and warrants to TRANSFERRA that the Client’s opening E-Wallet Account of TRANSFERRA does not violate any laws or regulations applicable to the Client.

3.1.4. The documents required for any Client who is a natural person in accordance with the above are as follows:

(a) A copy of an official and valid identity document;

(b) A document of proof of address which is less than 3 months old.

3.1.5. The documents required for any Client who is a legal person in accordance with the above are as follows:

(a) An original or copy of an extract of the official register, less than three months old and stating the name, legal form, head office address and the identities of associates and executives;

(b) A certified copy of the statutes and any decisions appointing the legal representative;

(c) A copy of the legal representative’s identity document and a document of proof of address which is less than 3 months old;

(d) A copy of each beneficiary’s identity document and a document of proof of address which is less than 3 months old;

(e) Any other document requested in Application form.

3.1.6. It is expressly provided that TRANSFERRA retains the right to request at any time additional documents regarding the Client, including any Client’s Payment Transaction.

3.2. E-Wallet Account use limitations:

3.2.1. At  TRANSFERRA’s discretion, a Client who has not provided all the required documents as listed below may be set to limitations to use his/her E-Wallet Account. Upon receipt of all the documents listed below and provided that they are deemed satisfactory by TRANSFERRA, such limitations will be lifted.

3.3. TRANSFERRA will contact You using the contact details You provided when You opened Your E-Wallet Account, or any updated contact details You have provided to TRANSFERRA. It is Your responsibility to update TRANSFERRA with any new contact information, including a change in address. TRANSFERRA will send any correspondence to the most recent email address or postal address You have provided to TRANSFERRA for Your E-Wallet Account. You must advise TRANSFERRA promptly of any change to Your contact details in the interests of security (including name or address) and provide appropriate supporting evidence required by TRANSFERRA.

4. Operation of the E-Wallet Account

4.1. Clients can send funds and receive funds by SEPA, SEPA instant, FPS, CHAPS, BACS transfer and Internal payments by TRANSFERRA, or any other means accepted by TRANSFERRA, in one or more instalments.

4.1.1. Before submitting a payment instruction to Us, You must ensure that you have sufficient e-money available in your E-Wallet Account to cover the Payment Transaction amount and any related costs (as set out in the Fee Schedule), otherwise we will refuse the Payment Transaction.

4.1.2. To carry out such a Payment Transaction, You must Login to the Website and place a money transfer order via the dedicated Payment Transaction page. TRANSFERRA E-Wallet Account is protected by additional security measures such as Strong Customer Authentication, the Client needs to follow the instructions provided to the Client with such additional security measures.

4.1.3. TRANSFERRA may refuse any payment at its sole discretion and without giving rise to any right to compensation. 

4.1.4. Any sums debited from your E-Wallet Account will be as a result of (i) the execution of Payment Transactions, (ii) the collection by TRANSFERRA of any fees owed by you under the Terms and Conditions and the Fee Schedule, or (iii) the reversal of a transaction you made by an accepted payment method.

4.1.5. Payments are subject to payment limits. These limits are set depending on the Client’s E-Wallet Account level.

4.1.6. The amount of Electronic Money available on the E-Wallet Account is automatically adjusted based on the Orders transmitted to TRANSFERRA (or in the process of being transmitted), the Electronic Money issued, any charges due and payable and any cancellation of one of the aforementioned transactions hereunder.

4.1.7. Where appropriate, the Client must acquire a sufficient amount of Electronic Money  before an Order can be legitimately transmitted to TRANSFERRA for execution. The Electronic Money may be issued and stored by the Client, provided that the corresponding funds are duly received by TRANSFERRA. The Electronic Money may in no way be issued on the basis of a credit granted to the Client.

4.2. The transmission terms of a Payment Transaction by the Client are as follows. 

4.2.1. When carrying out a Payment Transaction, the Client logs on to the Website by entering his/her Login and password. The Client completes the relevant form on the Payment Transaction page and, where appropriate, provides the supporting documents. The form should include the following components: (i) the Payment Transaction amount; (ii) the currency; (iii) the details required to identify the Recipient; (iv) the Payment Transaction description; and (v) any other required information. The Client then gives his/her consent to the Payment Transaction and the Payment Transaction becomes irrevocable when the Client clicks on the validation tab on the form and confirms the Payment Transaction by Strong Customer Authentication. 

4.2.2. Client must ensure that the payment details the Client enters when withdrawing funds are correct and complete. TRANSFERRA will not be liable for withdrawn funds being sent to the wrong payment instrument where this is due to the Client providing incorrect payment details. When withdrawing to a bank account, the Client must ensure that the account number, sort code, IBAN and/or BIC/SWIFT are correct.

4.2.3. If the Client has withdrawn funds to the wrong payment instrument, the Client may request that TRANSFERRA assist the Client in reclaiming the funds, however, TRANSFERRA will charge the Client a fee according to applicable Fees for doing so, and TRANSFERRA cannot guarantee that the reclaim efforts will be successful.

4.2.4. TRANSFERRA reserves the right to carry out any necessary money laundering, terrorism financing, fraud or other illegal activity checks before authorising any withdrawal of the Client’s funds, including in relation to returning any funds to the Client after the Client has closed TRANSFERRA E-Wallet Account.

4.2.5. TRANSFERRA shall be deemed to have received submitted instructions in accordance with the following principles:

(a) if TRANSFERRA and You mutually agree that execution of the Payment Transaction is to take place:

(i) on a specific day;

(ii) on the last day of a certain period; or

(iii) on the day on which you have put funds at the disposal of TRANSFERRA,

the time of receipt is deemed to be the day so agreed, unless it is not a Business Day in which case it will be deemed to be received on the next applicable Business Day; 

in all other cases:

(b) if an instruction is submitted before 1600 GMT on a Business Day, it will be deemed to be received on that Business Day;

(c) if an instruction is submitted after 1600 GMT on a Business Day, it will be deemed to be received on the next applicable Business Day;

(d) if an instruction is submitted on day that is not a Business Day, it will be deemed to be received on the next applicable Business Day.

5. Login objection, Transaction dispute and Reporting

5.1. Login objection:

5.1.1. The Client must inform TRANSFERRA of the loss or theft of their Login, or misuse or unauthorized use of his/her Login or data as soon as he/she becomes aware of this fact in order to request that the Login be blocked. Such a declaration should be made:

(a) by telephone call to the customer service of TRANSFERRA; or

(b) directly by email through the contact form available on the Website.

5.1.2. On receipt of the notification, TRANSFERRA, through TRANSFERRA, will immediately block Your E-Wallet Account. The event will be recorded and time stamped. A time stamped objection number will be communicated to the Client. A written confirmation that Your E-Wallet Account has been blocked will be sent to You by TRANSFERRA by email. TRANSFERRA is responsible for the file at an administrative level and retains all the data for 18 (eighteen) months. Upon written request by the Client and before expiration of such a deadline, TRANSFERRA will communicate a copy of this objection.

5.1.3. TRANSFERRA shall not be held liable for the consequences of any request to block Your E-Wallet Account that is made by a person who is not the Client.

5.1.4. An objection request is deemed to be made at the date and hour of its actual receipt by TRANSFERRA. In case of theft or fraudulent use of the Login, TRANSFERRA is entitled to request a receipt or a copy of the complaint, information about the circumstances leading to the alleged theft or fraudulent use from the Client who undertakes to respond as soon as possible.

5.2. Transaction Dispute:

5.2.1. For any claim concerning Payment Transactions or reimbursements executed hereunder by TRANSFERRA, the Client is advised to contact TRANSFERRA.

5.2.2. If You notify TRANSFERRA that TRANSFERRA has incorrectly executed an Order, TRANSFERRA will refund the amount of the incorrectly executed Payment Transaction and the E-Wallet Account will be restored to its former state before the receipt of the Order without undue delay. The Order is then resubmitted correctly. A Client who wishes to dispute a Payment Transaction not authorized by him/her shall contact the customer service department of  TRANSFERRA by telephone (contact details shown on the Website) as soon as possible after becoming aware of it.

5.2.3. In the event of loss or theft of Your security information (Login and password), or where You have failed to keep your security information safe, You may be responsible for unauthorized transactions carried out before notification of the dispute. However, You may be responsible for a greater amount if You have acted fraudulently, have not used your E-Wallet Account in accordance with these Terms or otherwise through Your fault. Except where You have acted fraudulently, You will not be responsible for any losses incurred in respect of unauthorized Payment Transactions arising after you have notified TRANSFERRA of the lost, theft, misappropriation, or authorized use of your E-Wallet Account details.

5.2.4. The Client may dispute an authorized transaction whose exact amount is undefined or those whose final amount is not that which he/she could have reasonably expected taking into E-Wallet Account his/her profile, previous expenditures and the agreed upon conditions. This request must be submitted to TRANSFERRA within 8 weeks of the execution of the Order on the E-Wallet Account. TRANSFERRA must reimburse the Client within a period of 10 Business Days after receipt of the request, if the latter proves justified, taking into account applicable laws, and whether the request consists of all the components necessary for examination by TRANSFERRA. TRANSFERRA reserves the right to refuse such a reimbursement, which will be explained and notified to the Client. The latter will provide the necessary information in order to determine the circumstances of the Payment Transaction. TRANSFERRA reserves the right not to reimburse the fees resulting from the Payment Transactions concerned. 

5.3. Reporting:

5.3.1. The Client may access, at any time, on its personal page on the Website, the indicative amount of Electronic Money available on their E-Wallet Account.

5.3.2. The Client has, on their personal page on the Website, a statement of Payment Transactions carried out on the E-Wallet Account. The Client is advised to pay careful attention to the list of these Payment Transactions.

5.3.3. TRANSFERRA shall make available to the Client upon written request a monthly statement of the E-Wallet Account, covering the 13 previous months.

6. Anti-money laundering and terrorism financing

6.1.  TRANSFERRA is subject to applicable legislation regarding the combating of money laundering and the financing of terrorism. As a result, TRANSFERRA must obtain information from any Client, for any transaction or business relationship, of the origin, purpose and destination of a transaction or opening of an E-Wallet Account. 

6.2. The Client recognizes that TRANSFERRA can, at any time, stop or delay the use of a Login, access to an E-Wallet Account or the execution of a Payment Transaction or a reimbursement in the absence of sufficient information pertaining to its purpose or nature. They are informed that a transaction carried out within the framework of these conditions may be subject to the national financial intelligence unit’s right to disclosure.

6.3. The Client can, in accordance with the legislation, access all of the information disclosed, provided this right to access does not undermine the purpose of the fight against money laundering and terrorism financing of terrorism, where this data concerns the applicant.

6.4. No prosecutions or civil liability actions can be brought, or any professional sanction taken against TRANSFERRA, its managers or employees who have reported their suspicions in good faith to the national authority.

7. Keeping E-Wallet Account Safe

7.1. You must protect the secrecy of your Login and password at all times and never disclose it to another person. You must take reasonable steps to keep Your Login and password safe and prevent fraudulent use of Your E-Wallet Account. For example, You should keep information relating to Your E-Wallet Account in a safe place, You should not write down your Login and password and You should take care to ensure that other people do not oversee or hear you using your Login and password.

7.2. You agree to immediately inform us in the event that You suspect any unauthorized use of Your E-Wallet Account.

7.3. TRANSFERRA reserves the right to immediately suspend or withdraw Your right to make Payment Transactions where (i) TRANSFERRA has reasonable grounds to believe that there may be a breach in the security of your E-Wallet Account, (ii) TRANSFERRA suspects unauthorized or fraudulent use of Your E-Wallet Account or (iii) TRANSFERRA is so required by law. If TRANSFERRA decides to take such action, TRANSFERRA will notify You in advance, except where this is not possible, in which case TRANSFERRA will inform You at the earliest opportunity. TRANSFERRA will not inform You if it would compromise its reasonable security measures or is otherwise unlawful. If the reasons for TRANSFERRA actions cease to exist, TRANSFERRA will reinstate Your E-Wallet Account.  

8. Security

8.1. TRANSFERRA undertakes to provide its services in accordance with the applicable and professional laws and regulations. In particular, TRANSFERRA will make every effort to ensure the security and confidentiality of the Client’s data, in compliance with current regulations in force. TRANSFERRA reserves the right to temporarily suspend access to the E-Wallet Account online for technical, security or maintenance reasons, without these operations being eligible for any compensation.  TRANSFERRA will limit this type of interruption to a necessary minimum.

8.2. TRANSFERRA cannot, however, be held liable to the Client for possible errors, omissions, interruptions or delays produced by the Website resulting in an unauthorized access to the latter. Nor can TRANSFERRA be held liable for thefts, destruction or unauthorized communications of data arising from unauthorized access to the Website. In addition,  TRANSFERRA will not be involved in the existing legal relationship between the Client and the Recipient of the Payment Transaction. TRANSFERRA cannot be held liable for faults, wilful default or negligence of the Client or Recipient towards each other.

8.3. TRANSFERRA is solely responsible for the security and confidentiality of the data exchanged within the framework of the use of the Website.

8.4. TRANSFERRA is responsible for the security and confidentiality of the data that it exchanges with the Client within the context of these Terms in respect of the creation and management of the E-Wallet Account, as well as the Payment Transactions associated with the E-Wallet Account.

9. Limitation of TRANSFERRA liability

9.1.  TRANSFERRA will not intervene in any way in the legal and commercial relationships and any litigation arising between the Recipient and the Client. TRANSFERRA has no control over the compliance, security, legality, characteristics and appropriateness of the products subject to a Payment Transaction. In this respect, it is up to the Client to obtain all useful information before proceeding to the purchase of a product or service, the collection of funds or any other transaction, in full knowledge of all the considerations involved. Any transaction carried out by the Client gives rise to a contract directly formed between him/her and the Recipient(s) with whom  TRANSFERRA has no contact.  TRANSFERRA cannot, under any circumstances, be held liable for the non-performance or poor execution of obligations that may result, or possible damages caused to the Client in this respect.

9.2. If TRANSFERRA fails to comply with the Framework Contact, TRANSFERRA is responsible for any loss or damage You suffer that is a foreseeable result of TRANSFERRA breaching the Framework Contract or failing to use reasonable care and skill when providing its services under the Framework Contract, but TRANSFERRA is not responsible for any loss or damage that is not foreseeable or which is not caused by its failures.

9.3. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time the Framework Contract was made, both TRANSFERRA and You knew it might happen.

9.4. You acknowledge and agree that TRANSFERRA will not be responsible to You for any loss or damage You suffer in connection with the use of the TRANSFERRA service where such loss or damage is caused by Your acts or omissions or by those of a third party including, but not limited to:

(a) Your failure to provide TRANSFERRA with accurate, complete and up to date information; or

(b) Losing or allowing third parties to gain access to your Login and password.

9.5. TRANSFERRA will take reasonable care to ensure that any data it holds in relation to You and Your E-Wallet Accounts is secure. However, You acknowledge and agree that a service provided via the internet cannot be completely secure and TRANSFERRA will only be responsible to You for loss or damage to Your data to the extent that it is caused by  TRANSFERRA failure to take such reasonable care.

9.6. Whilst  TRANSFERRA will use its reasonable efforts to make sure that its service is available to You when You want to use it, TRANSFERRA makes no promise or guarantee that its service will be uninterrupted or error free and TRANSFERRA will not be responsible to You for such errors or interruptions.

9.7.  TRANSFERRA will not be responsible to You for any loss of profit, loss of business, business interruption or loss of business opportunity.

9.8. To the extent permitted by applicable law, we will not be liable for any indirect, incidental, punitive, or consequential damages arising out of or in connection with the Framework Contract.

9.9. Our liability is limited to the greatest extent permitted by law.

10. Client Commitments

10.1. The Client guarantees that no part of its profile on the Website will harm the rights of third parties or is contrary to the law, to public order or to accepted principles of morality.

The Client undertakes not to:

(a) Execute the Framework Contract in an illegal manner or in conditions that are likely to damage, deactivate, overload or impair the Website;

(b) Assume the identity of another person or entity, falsify or conceal his/her identity or age, or create any false identity; or

(c) Disseminate personal data or information concerning a third party, such as postal addresses, telephone numbers, email addresses etc.

10.2. In the event of Client default, TRANSFERRA reserves the right to take any appropriate measures in order to stop the relevant actions. TRANSFERRA will also be entitled to suspend and/or block access to the E-Wallet Account.

11. Duration and Termination

11.1. The Framework Contract is concluded for an unlimited period. It is applicable from the date of receipt by the Client of the email from TRANSFERRA confirming his/her registration with TRANSFERRA.

11.2. The Client can terminate the Framework Contract at any time on 30 (thirty) calendar days' advance notice to TRANSFERRA. TRANSFERRA can terminate the Framework Contract at any time on two months' advance notice to the Client.

11.3. Such termination shall also constitute the termination of the entire Framework Contract and consequently the closure of the E-Wallet Account.

11.4. To terminate the Framework Contract, the terminating Party, if it is the Client - shall transmit a notice of termination to the other Party from email registered with Our site, if it is  TRANSFERRA - shall transmit a notice of termination to the other Party by contacts data of Client registration.

11.5. The Client shall indicate his/her bank or payment account details in the termination letter enabling TRANSFERRA to reimburse them with the available Electronic Money. In the absence of such information TRANSFERRA has no further obligations after having confirmed with the Client the transfer to the indicated bank account of the outstanding amount of the Electronic Money.

11.6. In the event of gross default, fraud or lack of payment on the part of the Client, TRANSFERRA reserves the right, without cause or prior notice, to suspend or terminate these conditions by sending an email accompanied by a registered letter with proof of delivery.

11.7. In the event that a successor to TRANSFERRA is nominated to issue the Electronic Money distributed on the Website, it is the responsibility of TRANSFERRA to obtain the Client’s express written consent to this change, about the amount of Electronic Money available and to indicate the arrangements for the transfer of funds corresponding to the available Electronic Money to TRANSFERRA.

11.8. It is envisaged that the Framework Contract will be automatically terminated in the event of new circumstances affecting the ability of one Party to commit to these Terms.

12. Amendment of the Contract

12.1. TRANSFERRA reserves the right, at any time, to amend the Terms. Such amendments will be sent by email to all Clients at least one (1) month before they take effect.

12.2. If You are not happy with any amendments that TRANSFERRA plans to make to the Terms, You can terminate the Framework Contract immediately and without paying a charge. If You do not end the Terms before the proposed amendments take effect, TRANSFERRA will consider that You have agreed to the amendments. The relationship between the Parties after the date the amendments come into force shall be governed by the new version of the Terms.

12.3. It is therefore important that the Client reads his/her emails and regularly reads the Terms available on the Website at any time.

13. Right of Cancellation

13.1. The Client has a period of 14 (fourteen) calendar days to cancel the Framework Contract, without having to either justify any reason or sustain any penalty. This deadline for cancellation shall start from the day of the Client's registration.

13.2. The Client must notify its decision to cancel within the prescribed deadline to  TRANSFERRA customer service department by email which was registered on TRANSFERRA’s website. In respect of the exercise of a right of withdrawal by the Client, the Framework Contract will be cancelled without any fees charged to the Client.

13.3. In the event that a Client has already benefited from the service and is in possession of Electronic Money at the date of the withdrawal, they must transmit his/her bank account details to TRANSFERRA in order to allow TRANSFERRA to reimburse the Client with Electronic Money.

14. Personal data and professional secrecy

14.1. The Client’s personal data provided in connection with the opening of the E-Wallet Account, is used by TRANSFERRA for the purposes of managing his/her E-Wallet Account, Payment Transactions and reimbursements.

14.2. The Client agrees that his/her contact details and personal information obtained by  TRANSFERRA in connection with the Framework Contract may be transmitted to operational providers, with whom TRANSFERRA has a contractual relationship, with the sole purpose of executing Payment Transactions and providing the services under the Framework Contract, provided that these third-party recipients of personal data are subject to regulations guaranteeing a sufficient level of protection. The list of the third-party recipients of the Client’s data is available upon request from TRANSFERRA compliance manager at the following address: info@transferra.uk. This information is stored by TRANSFERRA or by any company authorized to do so in accordance with legal and regulatory rules.

14.3. The Client will be informed prior to any transfer of his/her personal data outside the UK. In such a case, TRANSFERRA undertakes to respect the regulations in force and to put in place any measure necessary in order to guarantee the security and confidentiality of data transferred in such a way. Certain information collected and held by TRANSFERRA thereunder may give rise to the rights of access and correction. Any Client may, at any time, obtain a copy of the information pertaining to him/her upon request addressed to TRANSFERRA customer correspondent at the following address: info@transferra.uk. They may request the deletion or correction of this information by letter to TRANSFERRA at the address found at the beginning of this document. The Client may, at any time, object to receiving commercial solicitations, amend his/her contact details or object to their disclosure by sending a notification by registered mail or e-mail to the customer service address of TRANSFERRA.

14.4. TRANSFERRA will store the personal information and data for a maximum legal or regulatory period applicable depending on the purpose of each type of data processing.

14.5. The conditions for the collection, possession and access to personal data obtained by  TRANSFERRA and under his/her responsibility in terms of accessing the Website, are governed by the privacy policy, which is available on the Website.

15. Inactive E-Wallet Account

15.1. Any E-Wallet Account that is inactive for a period of 3 (three) months will receive a notification of inactivity by email from TRANSFERRA. If there is no response or use of available Electronic Money within 1 (one) month, TRANSFERRA may close the E-Wallet Account and keep it active for the sole purpose of the reimbursement of Electronic Money. The right of reimbursement may be subject to time limits pursuant to the law of the residence of the Client, with such time limits starting from the last transaction on the E-Wallet Account. If the Client responds within 1 (one) month confirming that the Client wishes to keep the E-Wallet Account opened, then E-Wallet Account will be kept opened subject to a monthly fee applicable to inactive E-Wallet Accounts (as long as the E-Wallet Account is or becomes inactive) in accordance with the Fee Schedule or as otherwise notified to the Client.

15.2. In the event of the death of the Client TRANSFERRA may close the E-Wallet Account and keep it active for the sole purpose of the reimbursement of Electronic Money. The right of reimbursement may be subject to time limits pursuant to the law of the residence of the Client, with such time limits starting from the last transaction on the E-Wallet Account. In the event of death, the Electronic Money can only be reimbursed to the Client’s assignee.

15.3. An E-Wallet Account that has been closed will not permit the further use of Electronic Money.

16. Events Outside The Control of a Party

16.1. Neither Party will be liable or responsible for any failure to perform, or delay in performance of, any of their obligations under the Framework Contract that is caused by an event outside the control of a Party.

16.2. An event outside the control means any act or event beyond a Party’s reasonable control, including without limitation strikes, lock-outs or other industrial action by third parties, civil commotion, riot, invasion, terrorist attack or threat of terrorist attack, war (whether declared or not) or threat or preparation for war, fire, explosion, storm, flood, earthquake, subsidence, epidemic or other natural disaster, or failure of public or private telecommunications networks.

17. Independence of contractual provisions

17.1. If any of the provisions of the Framework Contract is held invalid or unenforceable, it shall be deemed deleted and will not invalidate the other provisions.

17.2. If one or more of the provisions of the Framework Contract lapses or is declared as such under any law or regulation or following a final decision of a court of competent jurisdiction, the other provisions will retain their binding force and scope. The provisions considered null and invalid would then be replaced by provisions closest in scope and meaning to those initially agreed.

18. Protection of funds

The collected funds are protected against any claims from other creditors of TRANSFERRA, including in the event of enforcement proceedings or insolvency proceedings against the institution.

19. Non-transferability

The Framework Contract cannot be subject to a complete or partial transfer by the Client, whether against payment or free of charge. It is therefore forbidden to transfer to a third party any rights or obligations that the Client owns hereunder. In the event of breach of this prohibition, in addition to the immediate termination hereof, the Client may be held liable by  TRANSFERRA.

20. Complaints Handling

20.1. If the Client wishes to make a complaint about the Service, the Client can email  TRANSFERRA at info@transferra.uk, with brief details of the complaint and the email address associated with the E-Wallet Account.

20.2. If the complaint is not resolved by the end of 3rd business days after the complaint is received, TRANSFERRA will initiate a formal complaint handling procedure. TRANSFERRA will acknowledge the Client’s complaint by email within 5 business days. The email will contain details of the Complaints Procedure and the Client’s right to refer the complaint to the Financial Services Ombudsman if the Client is dissatisfied with TRANSFERRA’s assessment and ruling.

20.3. Within 15 days (complaints about rights and obligations arising under Parts 6 and 7 of the PSRs 2017) or 8 weeks (complaints not related to rights and obligations arising under Parts 6 and 7 of the PSRs 2017) after a complaint, TRANSFERRA will send the Client a final response.

20.4. A complaint about any regulated aspect of the Service that TRANSFERRA cannot settle within 15 days (complaints about rights and obligations arising under Parts 6 and 7 of the PSRs 2017) or 8 weeks (complaints not related to rights and obligations arising under Parts 6 and 7 of the PSRs 2017) after the date of complaint may be referred to the Financial Ombudsman Service at The Financial Ombudsman Service, South Quay Plaza, 183 Marsh Wall, London E14 9SR, United Kingdom (further details can be found at www.financial-ombudsman.org.uk).

21. Applicable law and competent jurisdiction

The Framework Contract is governed by the laws of England and Wales. You and  TRANSFERRA agree to submit to the non-exclusive jurisdiction of the English courts.