What is Fillit?
Fillit is a prepaid card service that allows users to transfer money from their accounts or other merchants such as e-shops and others on a plastic or virtual Fillit Prepaid Mastercard® and allows them to use this card as any other worldwide payment card. Fillit.eu and Fillit trademarks belong to Streamflow EOOD, a company based in Bulgaria, founded in 2014.
The Easier Way To Manage
Your Money with Fillit Every Day
Looking for a home for your money because you don’t have a bank account? Does your employer want to pay you via bank transfer? Would you like to keep some of your spending money separate from your current account and credit card?
Fillit Mastercard has the answer for you:
Fillit prepaid card for everyday money.
From everyday shopping and paying bills and monthly subscriptions, to topping-up a
mobile phone or sending money overseas Fillit prepaid cards are the quick and easy
solution, for everyone.
All you’ll need to do to get one is provide proof of your identity and your address when you order the Fillit Prepaid card.
What’s even better there is no credit checks, and no lengthy application process.
Fillit Prepaid Mastercard cards are accepted at over 36.9 million locations worldwide displaying the Mastercard Acceptance Mark. In addition, you can withdraw money from ATM at any time and safely in more than 2.1 million locations worldwide displaying the Mastercard Acceptance Mark.
PRICES, LIMITS & TRANSFERS
Fillit Cardholder Fees
- Card Fee (including: Mastercard Chip PIN lost/stolen at same cost, Card Carrier, Envelopes and Card personalisation fee) 15.00€ (Preorder now: 10.50€)
- Virtual card creation (per card) 5.50€
Fillit Wallet Limits
- Maximum balance *No minimum balance 150,000.00 €
- Maximum Amount to be Loaded (24 hours) 15,000.00 €
- Wallet to Wallet Transfer Max 3 transactions up to total 4,000.00 € daily
Fillit Cardholder Limits
- Maximum balance *No minimum balance 20,000.00 €
- Maximum Amount to be Loaded (24 hours) 5,000.00 €
- Maximum Amount to be Loaded (1 month) 20,000.00 €
- Maximum Amount to be Loaded (1 year) 150,000.00 €
- Maximum ATM Withdrawals (24 hours) 750.00 €
- Maximum ATM Withdrawals (1 month) 30,000.00 €
- Maximum ATM Withdrawals (1 year) 100,000.00 €
- Maximum ATM Withdrawals (lifetime) 300,000.00 €
- Maximum POS/Signature Purchases (24 hours) 10,000.00 €
- Maximum POS/Signature Transactions (24 hours) 40
- Maximum POS/Signature Purchases (1 month) 20,000.00 €
- Card to Card Transfer Max 3 transactions up to total 1,500.00 € daily
- Activation Fee FREE
- Monthly Service charge 1.50€
- ATM SEPA 2.99€
- ATM International 2.40% + 1.80€
- ATM Balance inquiry (PIN change at ATM /ATM Decline Fee) 0.50€
- POS Domestic (and within SEPA Inc. MOTO/CNP) FREE
- POS International (Inc. MOTO/CNP) 1% + 0.80€ per transaction
- SMS Balance check, block/unblock, activate per SMS 0.30€
- ATM Transaction Decline 0.50€
- Mastercard MoneySend (Mastercard Payment Transactions / Gaming Credit) SEPA 1.00€
- Mastercard MoneySend (Mastercard Payment Transactions / Gaming Credit) Outside - SEPA 1.00€ + 0.50%
- POS Transaction Decline/return fee 0.50€
- Wallet load via Prepaid card 3.50%
- Wallet load via Debit/Credit card 3.50%
- Wallet to Wallet transfer 1.00€
- Wallet to Card transfer 0.20€
- Card to Wallet transfer 0.20€
- Card to Card transfer 1.00€
- Bank transfer from wallet to UK bank account 3.00€
- Bank transfer from wallet to bank within SEPA region 6.00€
- Bank transfer from wallet to bank outside SEPA region 29.00€
- SMS – PIN resend 1.50€
- Online PIN reveal 1.50€ per reveal online
- Inactivity Fee (90 days) 3.00€
- Card cash out/Administration Fee 9.00€
- KYC 2.00€
- Chargeback handling – per chargeback 30.00€
- Bank charge for all loading through IBAN 1.00€ per deposit
- 3D Secure fee per transaction FREE
Acquiring Services for Businesses
Our acquiring solution is dedicated to every business. We conquered huge knowledge of the specific markets. In combination with best fees in the market, our solution is the best solution for every business and will acquire you the power to become part of the digital economy.
Acquiring Services for Cruise Industry.
Our acquiring solution is dedicated to Cruise Industry.
We conquered huge knowledge of the specific markets.
In combination with best fees in the market, our solution is the best solution for every cruise company and will Acquire you the power to become part of the digital economy.
Acquiring Services for Hotel Industry.
Our acquiring solution is also dedicated to Hotel Industry.
We understand the varied needs of your business and the payments industry.
We can provide you with the ability to accept electronic payments safely and securely, across the globe.
Fast, Accurate & Affordable
Let Fillit be your partner in growing your business.
Pay employees easily
Just enter the hours and automatically get instant paychecks. You can print the checks yourself or use FREE direct deposit. It’s that easy!
Work with your accountant on taxes
Create reports for your accountant for tax filings. Basic includes tax calculations but doesn’t include tax forms – choose Enhanced Payroll for that.
Basic Payroll features
- Instant paychecks for W-2 employees
- Automatic guaranteed tax calculations
- No tax forms included – create reports for your accountant for tax filings
- Run payroll from your iPad, iPhone or Android (online version only)
- Versions to work with or without QuickBooks
- Free direct deposit
- Free live support from experts
- Hassle-free workers’ compensation
- Automatic labor law posters
- Employee time tracking
- Get our FREE hiring guide
Point of Sale
Accept Chip & PIN Payments at your Point of Sale
Cashless point of sale payment with a prepaid card is easy and convenient for your customers. Leverage new sales potential and facilitate fast, easy and convenient transactions by implementing a POS solution from Ecomm Merchant Solutions.
Our POS Visa and Mastercard acceptance terminals are the easiest and quickest methods for processing card payments.
For cashless payment processing at every point of sale, both countertop and mobile, we offer a specialised range of cutting edge terminals from industry leader, PAX Technology.
Accept contactless payments – for small payments it's as simple as 'tap and go'. There is no need for your customer to put their card into the terminal or enter a PIN.
The S920 is the world’s sleekest compact mobile point of sale terminal, packed
with the most complete range of payment industry certifications ever and is
manufactured to the highest of global standards using state-of-the-art technology
and high-end materials.
Featuring a large ultra-clear high-definition multimedia colour touch screen and a beautiful back-lit keypad, the pocket-sized S920 is the hospitality & restaurant industry’s preferred choice, where portability, usability and seamless customer interaction are key requirements. Merchants adore the S920’s elegant sleek chassis, the superior battery life and the faster transaction times powered by a high-tech processor, larger memory capacity, and embedded contactless and NFC technology.
- 3G, 4G, GPRS, WiFi, Bluetooth
- Contactless, Chip, Magstripe
- Large Colour Touch Screen
- Visa & Mastercard NFC
- High Capacity Battery
- High Speed Printer
- PCI PTS 4.x, SRED
- Linux OS
S920 Mobile Terminal
The beautifully designed D200 integrates with any mobile payment app running on iOS or Android smart device via Bluetooth, WiFi, GPRS
or cable connection. The D200 offers the latest PCI PTS 3.x security, SRED and Visa payWave & Mastercard PayPass contactless certification.
Apple Inc. has given the D200 a special certification called MFi meaning that Apple has tested and approved the D200 to meed the highest
performance standards for integratio with any iPad or iPhone.
- Contactless, Chip, Magstripe
- iOS & Android Compatible
- VISA & Mastercard NFC
- WiFi Apple MFi approved
- PCI PTS 3.x, SRED
PAX's S800 is the world's most innovative countertop payment terminal powered by a secure
and flexible Linux operating platform. This supports rapid development of customized and
secure software applications that give new meaning to the concept of payment and valueadded
The S800 comes in a compact and stylish form factor, equipped with large colour screen, wide choice of connectivity options and built-in NFC capability to enable mobile and contactless transactions. The S800 packs a 32-bit ARM11 processor and massive amounts of memory via Micro SD to deliver exceptional performance.
- Sleek compact design
- Built-in contactless / NFC
- Fast thermal printer (25 lps)
- Multiple peripheral ports
- Advanced DDR technology
- 400MHz 32-bit ARM11 processor
Alipay Merchant Solutions
Convenient Alipay payment offered by Fillit.
Benefits of accepting Alipay for Merchants
- 450 million Alipay users worldwide
- Free marketing promotion from the build-in platform ‘discover’, which will guide users to your store, and will promote your store and discounts to the customers directly and effectively
- Alipay will also offer extra coupons to attract the customers to shop in your store
- Settlement to your bank account or our prepaid card
- No set up fee, easy boarding process
Customer Scans Merchant mode
- We will provide a simple barcode stand to each merchant. The merchant’s unique barcode is scanned by the customer and the amount is entered
- Fillit Merchant Solutions settle directly with the Merchant
Learn everything about Fillit Prepaid Card.
- Sign your name on the reverse of the card
- Activate your card by entering the website, going to the cards page, clicking on the activate button an entering the requested information
- Load your card and start purchases, payments or transfers. Once you have completed these steps your card is ready for use online, through our mobile application or over 37 million locations worldwide displaying the Mastercard Acceptance Mark.
- Transferring wages to your card
- To pay employees their wages onto the card
- To manage payments for travel expenses, fuel expenses, subsistence, amongst others
- To carry travel money on a card for safe and secure use abroad
- To share money with friends and family through additional cards
- To make or receive Insurance Claim payouts
- To use safely and securely on Gaming sites and make and receive winnings payouts
- Online Shopping 24/7, 365 days of the year
Essentially, you can use Fillit Prepaid Mastercard for your business or for yourself to make purchases online, over the phone and in-store at over 36.9 million locations worldwide, and withdrawals at over 2.1 million ATM locations worldwide where Mastercard is accepted.
- Wire Transfer to Fillit prepaid Mastercard Personal IBAN
- Online – Register your prepaid card online with us to link the card to your Prepaid card. Once you have registered your debit/credit card you can then load funds directly to your prepaid card
- Debit Card online
- Via Bank Transfer or Standing Order
- Via Wage Transfer
- Via SMS Text Messages from your phone
Fillit prepaid card 'Plus' cardholders have access to load their card with a debit card. In order to upgrade your card to 'Plus' you must provide us with proof of your identity (passport or driver’s license) and a proof of address (utility bill or bank statement). You can easily upgrade to the Fillit prepaid card 'Plus' by logging into your online account, selecting the 'Upgrade' button and uploading scanned color copies of your documents.
If you would prefer to post these documents please send color scans of your documents to
*The upgrade fee is 2€.
Please note you must have at least 2€ available balance on your card if you wish to upgrade your card.
- Shopping securely online - Your card is not linked to your bank account greatly reducing the risk of fraud when you shop online.
- Sending money to family and friends - Fillit cardholders can send money to other Fillit cardholders instantly for a set rate of €1.00.
- Individuals with a poor credit rating - Any resident of the UK over 18 years of age is eligible for a Fillit card. No credit checks.
- Managing your budget - Set out your budget, load it to the card and you can be safe in the knowledge you can never spend more than you can afford.
- Online gambling - If you like an occasional flutter on the horses or playing online poker the Fillit card could be ideal for you.
- Teens - Keep track of your kids spending by loading their spending money onto a card.
- Wages Payments - Cashing wages cheques can be both costly and time consuming.
- Business Expenses cards - Business expenses cards provide a quick distribution method for company expenses or per diem allowances.
Once this is done, you will be able to use the following commands with your Fillit Prepaid Card by sending simple text messages to the phone number +447403925031.
Retrieve your PIN
This functionality allows you to get the PIN for your Fillit card
Text PIN 'Last 8 digits of your card number' to the mobile: +447403925031
Example: PIN 12345678
Allows you to load your own card using your debit card that is pre-registered on the system.
Text LOAD 'Last four digits of your card number' 'Amount' to +447403925031
Example: LOAD 1234 5000
Note that the amount is expressed in the currency of your Fillit Card. So in the example above either €50.00 was loaded depending on the currency of your card.
Transfer funds from your Fillit card to another Fillit Card.
Using recipient card number
Text TOCARD 'Last four digits of your card number' 'Recipient card number' 'Amount' to +447403925031
Example: TOCARD 1234 5299650000000000 1000
Using the recipient mobile number
Text TOCARD 'Last four digits of your card number' 'Recipient mobile phone number' 'Amount' to +447403925031
Example: TOCARD 1234 00447974171234 1000
The card number entered is the card number of the person you are transferring funds to. Note that the amount is expressed in the currency of the sending in €. So in the example above 10.00€ would have been sent depending on the currency of your card.
Find out the current balance on your Fillit card.
Text BALANCE 'Last four digits of your card number' to +447403925031
Example: BALANCE 1234
You will receive an instant SMS back with the up-to-date balance on your card.
Lock & Unlock
To temporarily prevent any withdrawals from cash machines (ATMs) and purchases via retailers (POS), you can lock your Fillit card.
Text LOCK 'Last four digits of your card number' to +447403925031
Example: LOCK 1234
Text UNLOCK 'Last four digits of your card number' to +447403925031
Example: UNLOCK 1234
Please note that this command is intended to be used for temporarily locking your card to stop others attempting to use it or if you do not wish to use it for an extended period of time. If you suspect that your card is lost or has been stolen, you should contact customer services at [email protected] or by phone to +359 (2) 8504004 immediately.
SMS System Help
You do not need to memorize or know all these commands by heart. You can always view these commands online on the website or if you don't have access to the internet, you can view the SMS commands with the instruction below
Text HELP to +447403925031
- Go to my cards.
- Check what card you want to activate.
- Enter the 16 digit card number and expiration date when you press activate.
Then you can check your PIN at card details. You must never share this with anyone.
Have questions? We are happy to help.
Contact us with any questions regarding Fillit.
- 25A "Knyaginya Maria Luiza" Blvd, Plovdiv 4000, Bulgaria
- [email protected]
Fillit Mastercard Terms & Conditions
Fillit MASTERCARD® PREPAID CARD ACCOUNTHOLDER AGREEMENT
Valid as of 21st May 2018
By activating your Card, you agree that you have read and understood the terms of this Agreement (a copy of which you may download and store at any time). This Agreement shall commence at that time and continue unless cancelled under Clause 10 or terminated under Clause 12. We reserve the right to change this Agreement by giving 2 months\' notice to you in accordance with Clause 18. If we do this, you may terminate this Agreement immediately and without charge before the proposed changes take effect, otherwise you shall be deemed to have accepted such changes when the 2 months\' notice expires. However, you agree that changes to the Applicable Exchange Rate may be applied immediately and at the rate quoted via the Payment Service at the time of the relevant Transaction. Please also read the conditions of redemption, including any fees relating to redemption, in Clause 11 before activating your Card.
We will communicate with you in English (the language in which this Agreement was agreed with you on registration for your Account). Key information relating to your Transactions will be provided to you at the email address you register with us and/or in your Account. You may access, download and print this information at any time by logging in to your Account. In addition, you agree that we may provide notices or other information to you from time to time by posting it in your Account, emailing it to your registered email address, mailing it to your registered physical address, calling you by phone or sending you mobile messages. Notices to you by email or mobile messages shall be deemed given 24 hours after the email is sent, unless the sending party is notified that the email address is invalid. Notices sent by registered mail shall be deemed to have been received three days after the date of mailing. You may contact us as specified in Clause 2.
You may request a copy of any legally required disclosures (including this Agreement) from us via the contact details in Clause 2, and we will provide this to you in a form which enables you to store the information in a way that is accessible for future reference for a period of time adequate for the purposes of the information and which allows the unchanged reproduction of the information stored via, for example, our website, your Account or by email.
1. Definitions & Interpretation
In this document, if we use words that start with a capital letter, that means the word has been defined in this ‘Definition & Interpretation’ section.
'Account' or 'E-Wallet' a data account in our systems where we record your Available Balance, Transaction Data and other information from time to time;
'Account Closure Fee' has the meaning given in the attached Fees & Limits Schedule;
'Account Information Service' means an online service to provide consolidated information on one or more payment accounts held by the payment service user with another payment service provider or with more than one payment service provider;
' Account Information Service Provider' or ‘AISP’ the supplier of an Account Information Service’;
'Additional Cardholder' where applicable, a person who holds a Secondary Card;
'Applicable Exchange Rate' the exchange rate available on our website https://prepaidfinancialservices.com/en/exchange-rates.
'ATM' An automated teller machine is an electronic telecommunications device that enables Customers to perform financial transactions, particularly cash withdrawal, without the need for a human cashier, clerk or bank teller;
'Authorised Person' means any person to whom you authorise us to access your Account;
'Available Balance' the amount of E-money issued by us to you but not yet spent or redeemed;
'Business Day' Monday to Friday, 0900hrs to 1700hrs GMT, excluding bank and public holidays in the UK;
'Card' a prepaid Mastercard debit card issued by us and linked to your Account, which can be used to spend your Available Balance wherever Mastercard cards are accepted;
'Card Replacement Fee' has the meaning given in the attached Fees & Limits Schedule;
'Card Scheme'the operator of the payment scheme under which we issue each Card;
'Customer Due Diligence' the process we are required to go through to verify the identity of our Customers;
'Customer Funds Account' the segregated bank account where we hold relevant funds corresponding to your Available Balance in accordance with the safeguarding provisions of the Electronic Money Regulations 2011;
'Direct Debit'an automated payment method set up between you and us to send payments to organisations in accordance with a direct debit mandate given by you to the organisation which manages the frequency and amount of each payment;
'E-money' monetary value issued by us to your Account on receipt of funds on your behalf in our Customer Funds Account, equal to the amount of funds received;
'European Economic Area' or 'EEA' The means the European Union (‘EU’) member states, as well as Iceland, Liechtenstein and Norway.
'Fees' the fees payable by you for the Payment Services as specified in the attached Fees & Limits Schedule;
'IBAN' means an International Bank Account Number used to identify bank accounts for the purposes of international payments;
'Late Redemption Fee' has the meaning given in the attached Fees & Limits Schedule;
'Merchant' a retailer who accepts Payment for the sale of goods or services to you.
'Payment' means a payment for goods or services using a Card.
'Payment Initiation Service'means an online service to initiate a payment order at the request of the payment service user with respect to a payment account held at another payment service provider;
'Payment Initiation Service Provider' or (‘PISP’) is a payment service provider who supplies a Payment Initiation Service;
'Payment Services' means the services supplied by us to you under this Agreement, including issuing Cards, Accounts and IBANs; and executing Transactions;
'PFS IBAN' means a virtual IBAN issued by our bank service provider that we allocate to your Card or your Account you which can be used by you or others for Direct Debits or for the purpose of making a SEPA Transfer of funds that will result in a credit of the relevant funds to your Account.
'Secondary Card' where applicable, any extra Card which is issued to a Customer or Authorised Person;
'SEPA Transfer' A facility available for UK registered Accounts only whereby you instruct us to send Euros to a bank account elsewhere in the Single Euro Payments Area ('SEPA'), quoting the IBAN of the intended recipient of the funds.
'Simplified Due Diligence' means a lighter form of Customer Due Diligence, resulting in certain lower Card and Account limits
'Transaction' a Direct Debit, Payment, a Transfer or a SEPA Transfer;
'Transfer' a transfer of E-money from one Account to another Account.
'Virtual Card' a Card number issued by us for the purpose of making a single Payment without also issuing any corresponding physical card.
2. Contact and Regulatory Information
2.1 Your Card or Account can be managed online at www.fillit.eu or via email to [email protected] or by phone to +359 (2) 8504004. To report your Cards lost or stolen please call +359 (2) 8504004 or email [email protected]
2.2 The issuer for Your Fillit Prepaid Mastercard Card and provider of the Payment Services is Prepaid Financial Services Limited (PFS). PFS is registered in England and Wales under Company Registration Number is 6337638. Registered Office: 5th Floor, Langham House, 302-308 Regent Street, London, W1B 3AT.
2.3 PFS is authorised and regulated as an e-money issuer by the Financial Conduct Authority registration number 900036. Details of the PFS authorisation licence by the Financial Conduct Authority is available on the public register at https://register.fca.org.uk/ShPo_firmdetailsPage?id=0010X00004G2NAwQAN .
2.4 Prepaid Financial Services Limited acts as the programme issuer.
2.5 STREAMFLOW LTD is the programme manager. STREAMFLOW LTD is registered in Bulgaria with registered office 25A "Knyaginya Maria Luiza" Blvd, Plovdiv 4000, Bulgaria.
2.6 Prepaid Financial Services Limited is licensed as a principal member with the Mastercard Scheme. Mastercard is a registered trademark of Mastercard International Incorporated.
3. Type of Service, Eligibility and Account Access
3.1 Your Card is not a credit card and is not issued by a bank. Regardless of the type of Card(s) you have, you will have only one Account where your Available Balance is located.
3.2 Your Payment Services may not be activated unless we have been provided with the required information so that we may identify you and can comply with all applicable Customer Due Diligence requirements. We shall keep records of such information and documents in accordance with all applicable legal and regulatory requirements.
3.3 Reference to a currency (e.g. Euros € or Sterling £) shall mean that amount or the local currency equivalent in which your Card is denominated.
3.4 Any Transaction on your Card in a currency other than the currency in which your Card is denominated, will require a currency conversion using an Applicable Exchange Rate.
3.5 The Available Balance on your Card and/or Account will not earn any interest.
3.6 The Payment Services are prepaid payment services and not a credit or bank product, you must therefore ensure that you have a sufficient Available Balance from time to time to pay for your Transactions and applicable Fees. If for any reason a Transaction is processed, and the Transaction amount exceeds the Available Balance, you must repay us the amount of such excess immediately and we shall be entitled to stop any existing or subsequent Transactions from proceeding.
3.7 This Agreement does not give you any rights against the Card Schemes, its affiliates or any third party.
3.8 Only persons over 18 years of age are entitled to register for the Payment Services.
3.9 Each time you seek access the Account we will asking for your Access Codes (as defined in Clause 8). As long as the correct Access Codes are entered, we will assume that you are the person giving instructions and making Transactions and you will be liable for them, except to the extent provided for in Clause 8. We can refuse to act on any instruction that we believe: (i) was unclear; (ii) was not given by you; or (iii) might cause us to breach a legal or other duty; or if we believe the Payment Service is being used for an illegal purpose.
3.10 We will do all that we reasonably can to prevent unauthorised access to the Account. As long as you have not breached the other terms contained in this Clause 3 or Clause 8, we will accept liability for any loss or damage to you resulting directly from any unauthorised access to the Account pursuant to Clauses 14 and 15 of this Agreement.
4. Service Limits, Direct Debits, Transfers & SEPA Transfer Payment (UK Only)
4.1 Transactions may be restricted by Card or Account type, individual usage patterns and payment risk profiles. Cards are issued in accordance with regulatory limits and conditions. Limits relating to the use of Cards can be found in the attached Fees & Limits Schedule and on our website at [insert url for limits]. For anti-money laundering and anti-fraud reasons we reserve our rights to change particular payment restrictions (including from those published or included herein) without notice and to the extent required to meet our regulatory obligations.
4.2 Simplified Due Diligence may be restricted to domestic ATM access, along with reduced annual maximum load limits and capped annual withdrawal limits. These limits will be subject to Scheme and regulatory requirements.
4.3 You can make a Transfer to another Account by signing in to your Account and following the relevant instructions.
4.4 When sending funds to your Account with us, we recommend that your or other senders make a SEPA Transfer using your PFS IBAN.
4.5 We cannot be held liable for the payment process or fees associated with bank(s) and or intermediary bank(s) to process payments from you to us. Any fee(s) charged by third parties, not limited to receiving, processing or crediting a payment for you will be deducted by us before crediting the remaining balance to you.
4.6 You are responsible for checking and confirming payment details and fees before making a payment to us or to your Account.
4.7 Where enabled, you may be eligible to instruct other organisations to create regular Direct Debits from your Account. You will be responsible for ensuring that the correct details are provided in order for the Direct Debit to be created for you. You must ensure at all times that you have a sufficient Available Balance to allow for the funds to be debited from your Account. You are responsible for checking the terms and conditions that have been provided to you by the organisation receiving the Direct Debit payments.
4.8 You may incur a charge for unpaid Direct Debits if there are not enough Available Funds to pay an incoming Direct Debit request.
4.9 You accept responsibility for cancelling any Direct Debit on your Account with the originator directly. Neither PFS nor STREAMFLOW LTD XXX will be able to do this on your behalf, and cannot accept liability for any losses due to your failure to cancel any Direct Debit.
4.10 PFS will credit payments received to your Account at least once a day and before the end of the Business Day. Amounts received after the cut off period will be processed the next Business Day and you will hold PFS free and clear from any responsibility is this regard.
4.11 You may be asked to provide us with evidence of source of funds in order for us to meet our regulatory requirements, in which case you agree to provide that evidence promptly. You represent and warrant to us that the evidence you provide to us is up to date, complete and accurate.
4.12 Where so enabled you may change your PIN at selected ATMs subject to a Fee.
4.13 Where enabled, you may be eligible to instruct companies to create regular SEPA Transfers from your UK issued and registered Account. You will be responsible for ensuring that the correct details are provided in order for the SEPA Transfer to be created for you. You must ensure at all times that you have a sufficient balance on your Account to allow for the funds to be debited from your Account. You are responsible for checking the terms and conditions that have been provided to you by the SEPA Transfer originator. PFS and/or STREAMFLOW LTD[name of programme manager], reserve(s) the right to decline or terminate any SEPA Transfer instruction(s) that you have requested.
4.14 You may incur a charge for unpaid SEPA Transfers if there are not enough funds in your Account to pay an incoming SEPA Transfer request.
5. Use of the Payment Services
5.1 You may access your Account information by logging into your Account through our website. From here you will be able to view details on your Transactions, including dates, currencies, charges or exchange rates applied. This information is accessible at any time and can be stored and reproduced as necessary.5.1 You may access your Account information by logging into your Account through our website. From here you will be able to view details on your Transactions, including dates, currencies, charges or exchange rates applied. This information is accessible at any time and can be stored and reproduced as necessary.
5.2 You can use the Payment Services up to the amount of the Available Balance for Transactions.
5.3 If the Available Balance is insufficient to pay for a Payment, some Merchants will not permit you to combine use of a Card or Account with other payment methods.5.4 The value of each Transaction and the amount of any Fees payable by you under this Agreement will be deducted from the Available Balance.5.5 Once a Transaction is authorised, the relevant payment order may not be withdrawn (or revoked) by you after the time it is received by us, except for recurring SEPA TransfersDirect Debits , for which you may revoke the payment order up until the end of the Business Day before the day agreed for debiting the funds (see Clause 5.6). A Transaction will be deemed to have been received by us at the time you authorise the Transaction as follows:
i)for Payments and ATM Transactions, at the time we receive the payment order for the Transaction from the merchant acquirer or ATM operator, and
ii)A payment order for a Transfer or SEPA Transfer is provided to and received by us at the time it is issued by you via the Account;
iii) A request for a recurring SEPA TransferDirect Debit is deemed to be received on the agreed day (if the agreed day is not a Business Day, the request shall be deemed to have been received on the following Business Day).
5.6 Any recurring SEPA TransferDirect Debit will remain in effect until revoked by you at the latest by the end of the Business Day preceding the latest execution date for the relevant SEPA TransferDirect Debit. You accept responsibility for cancelling any SEPA TransferDirect Debit on your Account with the relevant organisation it was intended to payoriginator directly. Neither we nor STREAMFLOW LTD [name of programme manager] will be able to do this on your behalf and cannot accept liability for any losses due to late or non-cancellation of Direct Debits.
5.7 Where a revocation of an authorised payment is agreed between us and you, we may charge a Fee for revocation.
5.8 We will ensure that the amount of a SEPA Transfer is credited to the payment service provider of the payee by end of the Business Day following the time of the receipt of your payment order. If the payment service provider of the Merchant is located outside the EEA, we will effect payment as soon as possible and in any event as required by applicable law.
5.9 In order to protect you and us from fraud, Merchants may seek electronic authorisation before processing any Payment. If a Merchant is unable to get an electronic authorisation, they may not be able to authorise your Payment.
5.10 We may refuse to authorise any use of the Payment Services which could breach these terms and conditions or if we have reasonable grounds for suspecting that you or a third party have committed or are planning to commit fraud or any other illegal or un-permitted use of the Payment Services.
5.11 Your ability to use or access the Payment Services may occasionally be interrupted, for example if we need to carry out maintenance on our Systems. Please contact Customer Services via our website to notify us of any problems you are experiencing using your Card or Account and we will endeavour to resolve any problem.
5.12 Where applicable, you may apply to us for up to 3 Secondary Cards, for use by Additional Cardholders on your Account. Additional Cardholders, for whom you are legally responsible, must be 13 years of age or older. All other Additional Cardholders must be 18 years of age or older. It is your responsibility to authorise the Transactions incurred by each Additional Cardholder on the relevant Secondary Card and to ensure that the Additional Cardholder keeps to the provision of this Agreement. You are responsible for their use of the Secondary Card and for paying any amounts they add to your Account even if the Additional Cardholder does not keep to the provisions of this Agreement. We accept no responsibility or liability of any kind whatsoever for use of any Secondary Card by any Additional Cardholder for Transactions not authorised by you. If you successfully register and request one, we will send you a Secondary Card in the name of the Additional Cardholder with a copy of this Agreement, for which we will charge you an Additional Card Fee. Upon receipt of the Secondary Card, you may give the Secondary Card to the Additional Cardholder for their use, subject to:
i) you providing them with the copy of this Agreement (by using the Secondary Card the Additional Cardholder consents to the terms of this Agreement, which will then bind you and the Additional Cardholder in relation to the use of the Secondary Card);
ii) the Secondary Card must only be used by that person;
iii) you continuing to hold the Account and the Card with which the Secondary Card is associated;
iv) you informing the Additional Cardholder that you have retained the Primary Card and that you are still able to use the Account;
v) us obtaining such further information and documentation in order to enable us to comply with all applicable Customer Due Diligence anti-money laundering requirements in relation to the Additional Cardholder.
5.13 You will remain responsible for the use of the Payment Services, and for any Fees and charges incurred by the Additional Cardholder(s), and you will continue to be regarded as the holder of any funds already or subsequently loaded on the Account. The use of a Card in relation to which an Additional Cardholder has been registered will be regarded as confirmation that you have provided the Additional Cardholder with this Agreement.
5.14 You or any Additional Cardholder may us to remove that Additional Cardholder, and in that case you must cut the relevant Secondary Card in half.
5.15 You agree that we may give information about your Account to each Additional Cardholders and restrict what Additional Cardholders can do in relation to your Account.
5.16 Except as required by law, we shall not be responsible, and you will be solely responsible, for compiling and retaining your own copy of the data in your Account and your activities in connection with this Agreement. Upon the termination of this Agreement for any reason, we shall have no obligation to store, retain, report, or otherwise provide any copies of, or access to, the Transaction data or any records, documentation or other information in connection with any Transactions or the Account.
5.17 You agree to only use the Payment Services for lawful purposes and to adhere at all times to all laws, rules and regulations applicable to the use of the Payment Services, including the terms of this Agreement.
5.18 You may not use the Payment Services to receive or transfer any funds on behalf of any other natural person or legal entity.
6. Access by Third Party Providers
6.1 You may consent to regulated third party providers (PISPs or AISPs) accessing your Account online to make payments or obtain information about balances or Transactions on your Card and/or Account.
6.2 The PISPs and/or AISPs must be appropriately registered and authorised in accordance with PSD2. You should check with the regulatory authority of the relevant country before giving consent to the relevant PISP/AISP.
6.3 Any consent you give to a third-party provider is an agreement between you and it, we will have no liability for any loss whatsoever, as a result of any such agreement.
6.4 Before giving consent, you should satisfy yourself as to what degree of access you are consenting to, how it will be used and who it may be passed on to.
6.5 You should make yourself aware of any rights to withdraw the consent of access from the third party provider and what process it has in place to remove access.
6.6 To the extent permitted by law or regulation and subject to any right to refund you may have under this Agreement, between you and us, we are not responsible for any actions that the relevant third party takes in relation to suspending or terminating your use of their service or for any resulting losses. We are also not responsible for, or a party to, any agreement that you enter into with any relevant third party. You should make sure that you read and comply with such agreement or other applicable policies and note that this Agreement will continue to apply between us including to any Payment Services and our Fees as stated continue to apply.
6.7 Where appropriate, we may deny access to your Account, to any third party where we consider such access to be a risk of money laundering or terrorism financing, fraud or other criminal activity. Should we need to take these actions and where possible, we will give reasons for doing so unless restricted by law or for internal security reasons.
7. Condition of Use at Certain Merchants
7.1 In some circumstances we or Merchants may require you to have an Available Balance in excess of the Payment amount. For example, at restaurants you may be required to have 15% more on your Card than the value of the bill to allow for any gratuity or service charge added by the restaurant or you.
7.2 In some circumstances Merchants may require verification that your Available Balance will cover the Payment amount and initiate a hold on your Available Balance in that amount, examples include rental cars. In the event a Merchant places a pre-authorisation on your Account, you will not have access to these funds until the Payment is completed or released by the Merchant which may take up to 30 days.
7.3 If you use your Card at an automated fuelling station, subject to Merchant acceptance, your Card may need to be pre-authorised for a pre-determined amount in the relevant currency. If you do not use the whole pre-authorisation or do not have Available Balance to obtain a pre-authorisation, it is possible that the pre-authorised amount will be held for up to 30 days before becoming available to you again.
7.4 Some Merchants may not accept payment using our Payment Services. It is your responsibility to check the policy with each Merchant. We accept no liability if a Merchant refuses to accept payment using our Payment Services.
7.5 In relation to any dispute between the you and a Merchant, provided you are able to satisfy us that you have already made all efforts to resolve the dispute with the relevant Merchant, we will attempt to assist you so far as is reasonably practicable. We may charge you a chargeback processing fee as referenced in the Fees & Limits Schedule provided to you with this document, for any such assistance we may give you with any dispute. If there is an un-resolvable dispute with a Merchant in circumstances where the Card has been used for a Payment, you will be liable for the Payment and will have to resolve this directly with the relevant Merchant.
8. Managing & Protecting Your Account
8.1 You are responsible for the safekeeping of your username and password for your Account ('Access Codes') and the personal identification number for your Card ('PIN')
8.2 Do not share your PIN with anyone. You must keep your PIN safe, and separate from your Card or any record of your Card number and not disclose it to anyone else. This includes:
i. memorising your PIN as soon as you receive it, and destroying the post mail or other authorised communication used to transmit it to you;
ii. never writing your PIN on your Card or on anything you usually keep with your Card;
iii. keeping your PIN secret at all times, including by not using your PIN if anyone else is watching;
iv. not disclosing your PIN to any person.
8.3 The user of the Card(s) must sign the signature strip on any Personalised Card immediately when received.
8.5 Do not share your Access Codes with anyone except an Authorised Person. If you disclose the Access Codes to any Authorised Person, you are responsible and liable for their access, use or misuse of the Account, their breach of the terms of this Agreement or disclosure of the Access Codes.
8.6 The Payment Services may only be used by you and each Additional Cardholder or Authorised Person.
8.7 You must not give the Card to any other person or allow any other person to use the Payment Services except Authorised Persons or Additional Cardholders. You must keep the Card in a safe place.
8.8 Failure to comply with Clauses 8.2 and/or 8.5 may affect your ability to claim any losses under Clause 14 in the event that we can show that you have intentionally failed to keep the information safe or you have acted fraudulently, intentionally, with undue delay or with gross negligence. In all other circumstances your maximum liability shall be as set out below at Clause 15.
8.9 If you believe that someone else knows your Account or Card security details, you should contact us immediately in accordance with Clause 13.
8.10 Once your Card has expired (see Clause 11), or if it is found after you have reported it as lost or stolen, you must destroy your Card by cutting it in two, through the magnetic strip.
9. Identity Verification
9.1 If you enter into Transactions over the internet, some websites require you to enter your name and address. In such cases you should supply the most recent address which has been registered with us by you as the Account address. The Account address is also the address to which we will send any correspondence.
9.2 You must notify us within 7 days of any change in the Account address or your other contact details. You can notify us by contacting Customer Services who may require you to confirm such notification in writing. You will be liable for any loss that directly results from any failure to notify us of such a change as a result of undue delay, your gross negligence or fraud. We will need to verify your new Account address and shall request the relevant proofs from you.
9.3 We reserve the right at any time to satisfy ourselves as to your identity and home address (for example, by requesting relevant original documents) including for the purposes of preventing fraud and/or money laundering. In addition, at the time of your application or at any time in the future, in connection with your Account, you authorise us to perform electronic identity verification checks directly or using relevant third parties.
10. Right to Cancel ('Cooling-Off')
You have a right to withdraw from this Agreement under the following conditions:
10.1 where you purchased the Payment Services then you have a 'Cooling Off' period of 14 days beginning on the date of the successful registration of your Account, to withdraw from this Agreement and cancel the Payment Services, without any penalty but subject to deduction of any reasonable costs incurred by us in the performance of any part of the provision of services before you cancel. You must contact us within this 14-day period and inform us that you wish to withdraw from this Agreement and you must not use the Payment Services. We will then cancel the Payment Services and reimburse the amount of Available Balance on the Account to you. However, we reserve the right to hold Available Balance for up to 30 business days from receipt of your instructions before returning the balance, to ensure that details of all Transactions have been received.
10.2 After the Cooling Off period you may only terminate the Payment Services as described in Clause 12.
11. Expiry & Redemption
11.1 Your Card has an expiry date printed on it (the 'Expiry Date'). The Card (and any Secondary Card) and any PFS IBAN linked to the Card will no longer be usable following the Expiry Date, and you must not use it after that time, but you will still be able to receive and send funds to and from the Account associated with the Card.
11.2 If a Card expires before your Available Balance is exhausted, you can contact Customer Services to request a replacement Card, provided you do so 14 days before the Expiry Date printed on your Card and subject to payment of a Fee (where specified). We reserve the right to issue you with a replacement for an expired Card even if you have not requested one. If you have not requested a replacement Card, you will not be charged a Card Replacement Fee.
11.3 If your PFS IBAN is linked to your Account, rather than linked to your Card, then it will not expire when the Card expires, but will be available to use as long as the Account is available for your use.
11.4 Notwithstanding any Expiry Date printed on your Card, yYour funds are available for redemption by contacting us at any time before the end of the 6 years after the date on which this Agreement you terminateends under Clause 12 your Account, after which time your Available Balance will no longer be redeemable to you and we are entitled to retain the corresponding funds. Where an Available Balance remains for more than one year after the date on which this Agreement ends under Clause 12, we are not required to safeguard the corresponding funds in our Customer Funds Account, but you can still request redemption for up to 6 years. We may deduct from the proceeds of redemption of any such Available Balance the amount of any Late Redemption Fee.
11.5 Provided that your request for redemption is made less than 12 months following the date on which this Agreement ends under Clause 12, redemption will not incur any Late Redemption Fee. If you make a request for redemption more than 12 months after the date on which this Agreement ends under Clause 12 an Account Closure Fee may be charged (where specified).
11.6 We shall have the absolute right to set-off, transfer, or apply sums held in the Account(s) or Cards in or towards satisfaction of all or any liabilities and Fees owed to us that have not been paid or satisfied when due.
11.7 We shall have the absolute right to close your Account and submit a chargeback claim for the relevant Transactions if your Account is in negative standing for more than 60 days. If our chargeback is successful, funds paid to your Account may only be used to credit your Card or Account, and your Account will remain closed.
11.8 If your Account is inactive (including without limitation no access to the account or payment Transactions) for at least 2 consecutive years and has an Available Balance, we may (but we are not obliged to) notify you by sending an e-mail to your registered e-mail address and give you the option of keeping your Account open and maintaining or redeeming the Available Balance. If you do not respond to our notice within thirty (30) days, we will automatically close your Account and initiate a Transfer of your Available Balance to the last payment account notified by you to us (your ['Nominated Bank Account')] or by cheque to your last known address.
12. Termination or Suspension of Your Account and/or Processing of Transactions
12.1 We may terminate this Agreement and your use of the Payment Services with prior notice of at least 2 months.
12.2 Your use of your Card and any PFS IBAN linked to the Card ends on the Expiry Date in accordance with Clause 11.2.
12.3 This Agreement and your use of the Payment Services will also end when your ability to initiate all Transactions ceases.
12.4 We may terminate or suspend, for such period as may reasonably be required, your use of the Payment Services in whole or in part at any time or the processing of any Transaction(s) if:
i. there is any fault or failure in the relevant data processing system(s);
ii. we reasonably believe that you have used or are likely to use the Payment Services, or allow them to be used, in breach of this Agreement or to commit an offence;
iii. any Available Balance may be at risk of fraud or misuse;
iv. we suspect that you have provided false or misleading information;
v. we are required to do so by law, the police, a court or any relevant governmental or regulatory authority;
vi. required to fulfil our legal obligations in relation to the fight against money laundering and financing of terrorism;
vii. there is suspicion of unauthorised or fraudulent access to or use of your Account or that any of its security features have been compromised, including the unauthorised or fraudulent initiation of a Transaction;
viii. we have reasonable grounds to believe you are carrying out a prohibited or illegal activity;
ix. we are unable to verify your identity or any other information pertaining to you, your Account or a Transaction.
12.5 If any Transactions are found to have been made using your Card or PFS IBAN after expiry or any action has been taken by us under Clause 12.43, you must immediately repay such amounts to us.
12.6 Where it is practicable and lawful for us to do so or would not compromise reasonably justified security reasons, we will notify you via email of the suspension or restriction and the reasons for it before such measures take place or immediately thereafter.
12.7 We will reinstate your Account or execute the relevant Transaction(s) as soon as practicable after the reasons pursuant to Clause 12.43 no longer apply or exist.
12.8 If you wish to terminate the Payment Services at any time, you must request termination and the return of your Available Balance by email to our address in Clause 2 from the email address registered in your Account. Our Customer Services department will then suspend all further use of your Payment Services.
12.9 Once we have received all the necessary information from you (including any Customer Due Diligence) and all Transactions and applicable Fees and charges have been processed, we will refund to the you any Available Balance less any Fees and charges payable to us, provided that:
i. you have not acted fraudulently or with gross negligence or in such a way as to give rise to reasonable suspicion of fraud or gross negligence; and
ii. we are not required to withhold your Available Balance by law or regulation, or at the request of the police, a court or any regulatory authority.
12.10 Once the Payment Services have been terminated, it will be your responsibility to destroy the Card(s) that were provided to you.
12.11 If, following reimbursement of your Available Balance, any further Transactions are found to have been made or charges or Fees incurred using the Card(s) or we receive a reversal of any prior funding Transaction, we will notify you of the amount and you must immediately repay to us such amount on demand as a debt.
13. Loss or Theft of your Card or Misappropriatione of Your Account
13.1 If your Card is lost or stolen or if you think someone is using your Card, PIN and/or Access Codes without your permission or if your Card is damaged or malfunctions:
i. you must contact us as soon as possible and you must provide us with your Account or Card number and either your Username and Password or some other identifying details acceptable to us so that we can be sure we are speaking to you; and
ii. Provided we have obtained your consent to close the Account, we will then provide you with a replacement Card with a corresponding new Account loaded with an amount equivalent to your last Available Balance.
13.2 Once we have been notified of any loss or theft, we will suspend the Payment Services as soon as we are able, to limit any further losses (see Clause 14). We can only take steps to prevent unauthorised use of the Payment Services if you can provide us with the Account or Card number and Username and Password and if you can produce sufficient details to identify yourself and the relevant Account.
13.3 Replacement Cards will be posted to the most recent Account address registered by you. Failure to provide the correct address will result in a Card Replacement Fee.
13.4 If you subsequently find or retrieve a Card that you have reported l ost or stolen, you must immediately destroy the found Card by cutting it in half through the magnetic stripe and chip.
13.5 You agree to help us, our agents, regulatory authorities and the police if your Card is lost, stolen or if we suspect that the Payment Services are being misused.
14. Liability for Unauthorised or Incorrectly Executed Transactions
14.1 Subject to Clauses 14.2, 14.3 and 14.6 we will reimburse you in full for all unauthorised payment tTransactions sent from your Account immediately and in any event no later than the end of the following Business Day after noting or being notified of the Transaction (except where we have reasonable grounds for suspecting fraud), provided that you have informed us of the unauthorised Transaction without undue delay after becoming aware of the tTransaction and in any event, no later than 13 months after the tTransaction was executed. Where applicable, we shall restore your Account to the state in which it would have been had the unauthorised Transaction not taken place, so that that the credit value date shall be no later than the date the amount had been debited.
14.2 You may be liable for losses relating to any unauthorized Transactions up to a maximum of £35 resulting from the resulting from the use of a lost or stolen Card or the misappropriate of your Account, unless the loss, theft or misappropriation was not detectable to you prior to payment (except where you acted fraudulently) or was caused by acts or lack of action of our employee, agent, branch or service provider.
14.3 You are liable for any losses incurred by an unauthorised Transaction if you have acted fraudulently or failed either intentionally or through gross negligence, to use your Account in accordance with the terms of this Agreement or to keep your Access Codes confidential and secure in accordance with Clause 8.
14.4 You shall not be liable for losses incurred by an unauthorised Transaction which takes place after you have notified us of a compromise of your Access Codes according to Clause 8, unless you have acted fraudulently, or where we have failed to provide you with the means to notify us in the agreed manner without delay on you becoming aware of the loss, theft, misappropriation or unauthorised use of your Card or Account.
14.5 We shall not liable for a refund or losses incurred by an incorrectly or non-executed payment Transaction if the details of the payee\'s account provided by you were incorrect or we can prove that the full amount of the Transaction was duly received by the payment service provider of the payee.
14.6 We shall not be liable for any unauthorised or incorrectly executed Transactions in case the tTransaction was affected by abnormal and unforeseeable circumstances beyond our reasonable control or where we acted in accordance with a legal obligation.
14.7 Where we are liable for the incorrect execution of a Transfer or SEPA Transfer that you receive under this Agreement, we shall immediately place the amount of the Transaction at your disposal in accordance and credit the corresponding amount to your Account no later than the date on which the amount would have been value dated, had the Transaction been correctly executed.
14.8 Where we are liable for the incorrect execution of a Payment, Transfer or SEPA Transfer by you as payer, we shall, without undue delay, refund to you the amount of the non-executed or defective Transaction, and, where applicable, restore the debited Account to the state in which it would have been had the defective Transaction not taken place.
14.9 In the case of a non-executed or defectively executed Payment, Transfer or SEPA Transfer by you as payer, we shall, regardless of whether we are liable, on request, make immediate efforts to trace the Transaction and notify you of the outcome, free of charge.
14.10 A Payment initiated by or through a payee (e.g. a Merchant) shall be considered to be unauthorised if you have not given your consent for the Payment to be made. If you believe that a Payment has been made without your consent you should contact us in accordance with Clause 2.
14.11 A claim for a refund of an authorised Direct Debit or Payment initiated by or through a payee (e.g. a Merchant) where the authorisation did not specify an exact amount of payment Transaction (and the amount of the Payment exceeded the amount that you reasonably could have expected taking into account your previous spending pattern, this Agreement and the circumstances of the case), must be made within 8 weeks from the date on which the funds were deducted from your Available Balance. Within 10 Business Days of receiving your claim for a refund or within 10 Business Days of receiving further information from you, we will either refund the full amount of the Payment as at the date on which the amount of the Payment was debited or provide you with justification for refusing the refund.
14.12 The right to a refund under this Clause 146 does not apply where you have given consent directly to us for the Payment to be made and, if applicable, information on the Payment was provided or made available to you by us or the payee in an agreed manner for at least four weeks before the due date.
14.13 If you are not satisfied with the justification provided for refusing the refund or with the outcome of your claim for a refund, you may submit a complaint to us or contact the complaints authority as described in Clause 16.
14.14 If at any time we have incorrectly deducted money from your Available Balance, we shall refund the amount to you. If we subsequently establish that the refunded amount had been correctly deducted, we may deduct it from your Available Balance and may charge you a Fee. If you do not have sufficient Available Balance, you must repay us the amount immediately on demand.
14.15 Where any request, Transaction, disputed Transaction, arbitration or reversed Transaction involves third party costs, you remain liable for these and they will be deducted from your Account or otherwise charged to you.
15. General Liability
15.1 Without prejudice to Clause 14 and subject to Clause 15.4;
i. neither party shall be liable to the other for indirect or consequential loss or damage (including without limitation loss of business, profits or revenues), incurred in connection with this Agreement, whether arising in contract, tort (including negligence), breach of statutory duty or otherwise;
ii. we shall not be liable:
1. if you are unable to use the Card or Payment Services for any valid reason stated in this Agreement;
2. for any fault or failure beyond our reasonable control relating to the use of the Payment Services, including but not limited to, a lack of Available Balance or fault in or failure of data processing systems;
3. for any loss, fault or failure relating to the use of a Third-Party Provider as stated in Clause 6.3, 6.6 and 6.7 of this Agreement,
4. if a Merchant refuses to accept a Payment or fails to cancel an authorisation or pre-authorisation;
5. for the goods or services that are purchased with your Card;
6. for any dispute you might have with a Merchant or other user of the Payment Service; where you acted with:
15.1.ii.6.1. undue delay
15.1.ii.6.3. With gross negligence. (including where losses arise due to your failure to keep us notified of your correct personal details)
15.2 You agree that you will not use the Payment Services in an illegal manner and you agree to indemnify us against any claim or proceeding brought about by such illegal use of the Payment Services by you, your Authorised Person(s) and Additional Cardholder(s).
15.3 You are solely responsible for your interactions with Merchants or other users of the Payment Service. We reserve the right, but have no obligation, to monitor or mediate such disputes.
15.4 To the fullest extent permitted by relevant law, and subject to Clause 14 and Clause 15.5, our total liability under or arising from this Agreement shall be limited as follows:
i. where your Card is faulty due to our default, our liability shall be limited to replacement of the Card or, at our choice, repayment to you of the Available Balance;
ii. in all other circumstances of our default, our liability will be limited to repayment of the amount of the Available Balance.
15.5 Nothing in this Agreement shall exclude or limit either Party's liability in respect of death or personal injury arising from that party's negligence or fraudulent misrepresentation.
15.6 No party shall be liable for, or be considered in breach of this Agreement on account of, any delay or failure to perform as required by this Agreement as a result of any causes or conditions which are beyond such Party's reasonable control.
16. Dispute Resolution
16.1 We are committed to providing an excellent customer experience for all our Customers. If we do not meet your expectations in any way, we want to have the opportunity to put things right.
16.2 In the first instance, your initial communication will be with our Customer Services Team who can be contacted by Email to [email protected] or by phone to +359 (2) 8504004. Our Customer Services Team will listen to your needs and will do their best to solve your issue promptly and fairly. We value the opportunity to review the way we do business and help us meet our customers\' expectations.
16.3 If having received a response from our Customer Services Team you are unhappy with the outcome, please contact the Complaints Team of Prepaid Financial Services Ltd, 5th Floor, Langham House, 302-308 Regent Street, London, W1B 3AT in writing via email on [email protected]
16.4 Once received, the Complaints Team will conduct an investigation and you will receive a response of its findings within 15 days of receipt of the complaint. In exceptional circumstances where we are unable to reply within the first 15 days, we will reply providing a reason for the delay and deadline for response, not more than 35 days after first receipt of complaint.
16.5 If the Complaints Team is unable to resolve your complaint and you wish to escalate your complaint further, please contact the Financial Ombudsman Service at South Key Plaza, 183 Marsh Wall, London, E14 9SR. Details of the service offered by the Financial Ombudsman Service are available at http://www.financialombudsman.org.uk/consumer/complaints.htm or alternatively you can lodge your complaint in your country of domicile with the Online Dispute Resolution process at https://ec.europa.eu/consumers/odr/main/index.cfm?event=main.home.show&lng=EN
16.6 You must provide us with all receipts and information that are relevant to your claim.
17. Your Personal Data
17.1 PFS is a registered Data Controller with the Information Commissioners Office in the UK under registration number Z1821175 https://ico.org.uk/ESDWebPages/Entry/Z1821175
17.2 In order for us to provide you with the services relating to your Account, we are required to collect and process personal data about you, Additional Cardholders and Authorised Persons, with your consent or on a legal basis to meet our obligations for Anti-Money Laundering legislation or other governmental organisation. Where applicable, if an Account holder is under 16, then parental consent is explicitly required.
17.3 Your consent will be sought for collection of your data and you have the right to agree or decline. Where you decline consent for the collection and processing of your data we reserve our right to discontinue service due to our obligations as a financial services institution.
17.4 We may disclose or check your personal data with other organisations and obtain further information about you in order to verify your identity and comply with applicable money laundering and governmental regulations. A record of our enquiries will be left on your file.
17.5 We may pass your personal data on to third-party service providers contracted to PFS in the course of dealing with your Account. Any third parties that we may share your data with are obliged to keep your details secure, and to use them only to fulfil the service they provide you on our behalf. Where we transfer the personal data to a third country or international organisation, we ensure this is done securely and that they meet a minimum standard of data protection in their country.
17.6 You have the right to receive information concerning the personal data we hold about you and to rectify such data where it is inaccurate or incomplete. You have the right to object to or withdraw any consent you have given for certain types of processing such as direct marketing.
17.7 Your data will be retained for 6 years after the end of the provision of services to you, where your data will be destroyed in compliance with the requirements of the General Data Protection Regulation.
17.8 In the event that you wish to make a complaint about how your personal data is being processed by us (or third parties as described in 18.5 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and PFS\'s Data Protection Officer.
18. Changes to the Terms and Conditions
We may update or amend these terms and conditions (including our Fees & Limits Schedule). Notice of any changes will be given on our website, or by e-mail notification, or by SMS at least 2 months in advance. By continuing to use the Payment Services after the expiry of the 2-month notice period you acknowledge that you indicate your acceptance to be bound by the updated or amended terms and conditions. If you do not wish to be bound by them, you should stop using the Payment Services and terminate this Agreement in accordance with Clause 10 before the changes take effect.
19.1 We may assign or transfer our rights, interest or obligations under this Agreement to any third party (including by way of merger, consolidation or the acquisition of all or substantially all of our business and assets relating to the Agreement) upon 2 month\'s written notice. This will not adversely affect your rights or obligations under this Agreement.
19.2 Nothing in this Agreement is intended to confer a benefit on any person who is not a party to it, and no such person has any right under the Contracts (Rights of Third Parties) Act 1999 to enforce any terms of this Agreement, but this Clause do not affect a right or remedy of a third party which exists or is available apart from that Act.
19.3 Any waiver or concession we may allow you, will not affect our strict rights and your obligations under this Agreement.
19.4 This Agreement and the documents referred to in it, constitute the entire agreement and understanding of the parties and supersede any previous agreement between the parties relating to the subject matter of this Agreement.
20. Funds Protection
All relevant funds corresponding to your Available Balance are segregated from our funds and held in the Customer Funds Account in accordance with the safeguarding requirements of the Electronic Money Regulations 2011 by law. In the event that we became insolvent those funds are protected against claims made by any of our creditors.
21. Regulation & Law
21.1 The Payment Services, Card and Account are payment services and not deposit, credit or banking products and are not covered by the Financial Services Compensation Scheme.
21.2 This Agreement shall be governed by and interpreted in accordance with the laws of England & Wales, and any dispute or claim in relation to this Agreement shall be subject to the non-exclusive jurisdiction of the English courts. However, if you reside outside of England and Wales you may bring an action in your country of residence.
22. Fees and Limits
Card Fee (including: Mastercard Chip PIN lost/stolen at same cost, Card Carrier, Envelopes and Card personalisation fee) 6.50€
Virtual card creation (per card) 3.50€
Maximum balance *No minimum balance 20,000.00 €
Maximum Amount to be Loaded (24 hours) 5,000.00 €
Maximum ATM Withdrawals (24 hours) 750.00 €
Maximum POS/Signature Purchases (24 hours) 10,000.00 €
Card to Card Transfer Max 3 transactions up to total 1,500.00 € daily
Activation Fee FREE
Monthly Service charge 1.50€
ATM SEPA 2.99€
ATM International 2.40% + 1.80€
ATM Balance inquiry (PIN change at ATM /ATM Decline Fee) 0.50€
POS Domestic (and within SEPA Inc. MOTO/CNP) FREE
POS International (Inc. MOTO/CNP) 1% + 0.80€ per transaction
SMS Balance check, block/unblock, activate per SMS 0.30€
ATM Transaction Decline 0.50€
Mastercard MoneySend (Mastercard Payment Transactions / Gaming Credit) SEPA 1.00€
Mastercard MoneySend (Mastercard Payment Transactions / Gaming Credit) Outside - SEPA 1.00€ + 0.50%
POS Transaction Decline/return fee 0.50€
SMS/Internet Prepaid card load 3.50%
SMS/Internet Credit card load 3.50%
SMS/Internet Card to Card transfer 1.00€
Bank transfer from card to UK bank account 3.00€
Bank transfer from card to bank within SEPA region 6.00€
Bank transfer from card to bank outside SEPA region 29.00€
SMS – PIN resend 1.50€
Online PIN reveal 1.50€ per reveal online
Inactivity Fee (90 days) 3.00€
Card cash out/Administration Fee 9.00€
Chargeback handling – per chargeback 30.00€
Bank charge for all loading through IBAN 1.00€ per deposit
3D Secure fee per transaction FREE
Money Laundering – what is it?
Money laundering comprises, in summary, being in possession of, or dealing in any way, or assisting another party in connection with, property arising from any criminal offence, including terrorist related activities. Accordingly, if suspicion is formed about such an activity, it needs to be reported to the Money Laundering Reporting Officer (MLRO) for consideration, which in this case is the External Consultant. Criminal property means any pecuniary or proprietary benefit arising from criminal conduct. Money laundering also includes any matters connected with funds being used or provided for any terrorism related purpose where no other crime may have taken place. We are not required to become experts in criminal law. But we should apply our general knowledge and experience in seeking to fulfil our legal obligations. Apart from the more obvious offences relating to drugs trafficking, terrorism, fraud, theft and false accounting, and such offences as you may be aware of from service line specific knowledge, consideration also needs to be given to other potential offences which may well be encountered in business. These include bribery, corruption and criminal breach of competition. If in doubt, we should contact our advisor, which plays the relevant role in such cases.
Fraud – what is it?
Fraud, for the purposes of these procedures, relates to actions taken by potential or existed customers to make fraudulent moves and transactions to the detriment of our company by using false identities and personal details &/or false credit card details to deposit and withdraw money which will possibly be reclaimed at a later stage through a chargeback by the rightful owners. Fraud could also relate to a legitimate customer who falsely claims that his credentials- ways of payment (e.g. Credit Card) was used without his knowledge so that he can recover monies lost on bets. Internal fraud is covered by other internal controls and procedures implemented by STREAMFLOW EOOD.
- 2.1 STREAMFLOW EOOD shall only carry on business with persons whom they have adequately identified and in whom there is no suspicion of criminal or terrorist activity.
- 2.2 STREAMFLOW EOOD shall not accept to open anonymous accounts or accounts in fictitious names such that the true beneficial owner is not known.
- 2.3 STREAMFLOW EOOD shall not accept customer residing from a non reputable jurisdictions.
- 2.4 STREAMFLOW EOOD shall keep at all times a secure online list of all registered customers and also keep contact with them.
- 2.5 STREAMFLOW EOOD must not launder money or assist others to do so intentionally or otherwise.
- 2.6 STREAMFLOW EOOD shall take all measures necessary to detect and prevent fraudulent customers and activity through regular monitoring.
- 2.7 STREAMFLOW EOOD must not impede, by action or inaction, any official investigation of money laundering.
- 2.8 STREAMFLOW EOOD personnel must report any suspicion of money laundering to the MLRO – The External Auditor- Counsellor.
- 2.9 The personnel shall affect all Anti-Money Laundering Actions through its MLRO who will in turn escalate the reports as necessary.
- 2.10 STREAMFLOW EOOD shall, as much as possible, follow the relevant 40 + 9 recommendations of the Financial Actions Task Force (www.fatf-gafi.org).
- 2.11 STREAMFLOW EOOD shall follow all the laws and regulations relating to anti-money laundering and prevention of terrorism.
- 2.12 STREAMFLOW EOOD shall provide the necessary training for its personnel in anti-money laundering and fraud procedures.
- 2.13 STREAMFLOW EOOD shall keep records of all procedures carried out and reporting effected.
STREAMFLOW EOOD’ approach
- We should endeavour to establish the identity of our customers as soon as is reasonably and practically possible where deposit turnover exceeds €2.000 per day or over €15,000 per month whichever happens first. This only goes, with our registered customers in our data-base.
- We are inter-mediators of cash handling- via electronic vouchers or similar means of handling and transferring money, only, with well-respected Credit, E-Money institutions as well as Publicly Known Institutions or Regulated Banking Institutes. Our Major Clients- are considered to be these Institutions.
- We do not Co-operate or have any business relationship with shell banks- and we do not intent to.
- We wish to do business only with well-respected rated Institutions, and therefore we ask them to provide us with their
~ Publicly known Ranking
~ KYC and AMC Policies and Procedures
~ Permissions or chart of authorities, for conducting relevant business in their based country.
- We should obtain reasonable information, adequately documented and corroborated, about the identity of all our customers when required to do so, if there is doubt about the authenticity of the customer or when money transferring figures raise concern.
- From the information gathered, we should be able to obtain a reasonable assurance about the identity of our customer and that he or she is not involved in any criminal or terrorist activity or activities.
- If we should develop suspicions of money laundering activities regarding a client or a proposed client, or any third party observed in the course of our business, (wherever that client or third party may be located) we should report promptly to the company’s Money Laundering Reporting Officer (MLRO). The MLRO will investigate, analyze, consult and, if appropriate, report the activity to authorities and also BoG. The company reserves the right to take any other action considered legal and necessary.
Anti - Money Laundering and Fraud Guidance- Terminology
This Guidance is based on regulatory requirements and FATF40+9 recommendations – breach of which may well result in legal liability for the company and/or the individuals concerned. Adherence to this Guidance is, therefore, important for your protection as well as that of the company. Legalization of Revenue that may come from criminal activities (ML- MONEY LAUNDERING), according to Greek legislation (L.3691/2008, article 2) may consist from the following actions:
- The conversion or transfer of property, in the knowledge that comes from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of, or assistance to anyone involved in these activities, In order to avoid the legal consequences of these (illegal) actions.
- Concealment or disguise of the truth by any means or manner, regarding the nature, origin, distribution, handling, or use of property or the place where it has been acquired or is situated. Likewise by the ownership of the property or related property rights, aware of the fact that such property is derived from criminal activity or from an act of participation in such criminal activities etc.
- The acquisition, possession, management or use of property, knowing at the time of the acquisition or management, the fact that the property was derived or come from criminal activity or from an act of participation in such criminal activities.
- The use of the financial sector with the placing in this or using this sector through transactions, with income derived from criminal activities, with a view to give some semblance to such revenue (that come from illegal activities).
- The organization in a team or group from at least two people to commit one or more of the acts referred to in the above elements and the participation in such an organization, team or group.
- Laundering of income (revenue) from criminal activities, the activities of which comes the to legitimise property, when these activities took place at the territory of another Country, where they considered to be basic offense if committed in Greece and be punishable in accordance with the legislation of that Country.
- We are looking thorough the Country of Main Professional Activity of our customer. Therefore as Country of Main professional activity is defined, the country from which:
- Comes the main part (bulk) of the funds of the Customer,
- Where mainly operates as professional (the customer),
- Where the business transactions of the customer are carried out mainly, either directly or through partner(s),
- Where the Customer has an important political or entrepreneurial activity and presence (i.e. country in which it is considered as politically exposed person).
- Caution: in case of offshore companies the above points (1) – (4) should be assessed in relation to the real beneficiary (Beneficial Owner).
- Indicative parameters for the assessment of the countries in which the customer operates, is also the country of residence and nationality of the Customer.
Under the principle «Know Your Customer» requires the continuous monitoring of the following:
- The determination of the country’s main business activity for each Customer, and
- The selection and classification of the most dangerous country (high risk, e.g. Not FATF countries), in which case the customer operates his main professional activities, when is more than one country.
- EXAMPLE- Customer located in Greece, has been active in exports to Russia (which is directed toward the 1/3 of exports) and in China (where directed the 2/3 of exports). The countries of Russia and China are not included in non-high risk for ML. Between the two is selected as the country Main professional activity for the particular customer, China, as well as the customer develop toward this greater business activity
Client authentication procedures and “know your client” (KYC) information
The identification of the customer (beneficial owner) must be carried out before entering into business relations and in any case before the conclusion of transactions and with the use of reliable third party sources (third party diligence) which their data are hard to be falsified/ forge/faked.
By way of derogation- from the previous paragraph- shall be permitted to complete the verification of the identity of the customer (beneficial owner) when entering into business relations, where this is required, so as not, to, interrupt the smooth provision of services. However, even in this case, the risk money laundering from criminal activities or terrorist financing must be small. In these cases, the proceedings are terminated as soon as possible after the initial contact, and in any case no later than 30 days. The data for the identification of the customers (true) identity as well as the process of opening a new customer’s file is included, in the process of operations.
For the preparation of the profile of the customer, we request as minimum the following:
- The description of the professional or business activity,
- The elements of the Group/ associated companies/ the ownership structure and composition of shareholders , the country Headquarters of the Group / the associated companies,
- The real beneficiaries, historical data of growth, professional and operational activity,
- Assets size sources and assets and in general the economic background
Economic /Transactional profile:
- Real country of operations
- The purpose of the relationship and the business – financial services accounts ,
- The nature of the requested banking/ non-banking services ,
- The planned movement of accounts, and money transferring
- The variety and the amount of trade ,
- Country/countries of destination for outgoing transfers or payments,
- Reference to the risks that could result from the relation, example due to Country Risk, legal form, kind of transactions, services, and products .etc.
It should be noted that the data collection should be carried out taking into account comply with the principle of protection of personal data of the Customer.
A. For Recurrent – Business Customers- Partners
The company accepts the customer only where they do not belong to any of the categories of non-eligible customers. The verification of the customer is been carried out in accordance with the Operations procedures (registration process /Identification / Acceptance of prospective customer).
- During the assessment of the customers, the policy of the company for the Money Laundering (from now ML) and (Financing Terrorism) (from now on FT) is taken seriously into account. Moreover the risks involved and occur, from the operation of the company since the beginning of the relationship.
III. If, during the course of the cooperation, issues occur that are grounds for breaking off this cooperation and from the beginning rejection of the relationship for reasons ML and FT, the decision shall be communicated to the customer without mentioning the real reasons and inform immediately the MLRO.
- The company may revoke its decision on co-operation in case problems occur:
– During the stage of identification of the Customer
– During the presentation and control of legitimising documents
– During the relationship
B. For non-Recurrent Customers (Physical Persons)
- Non recurrent is considered to be a customer, that is not strategically selected, as a business partner, all of the times it is a physical person, so there, limited KYC and AML Procedures do apply.
- Non Recurrent customers, are considered to be those customers (physical persons) that use STREAMFLOW EOOD’ electronic of E-Voucher services, but the issuing of these vouchers are done by a third party (business partner/ customer) that goes through KYC procedures, within his own network and takes logical measures (Due Diligence Procedures).
- For those customers, the strategic partner/ customer must demonstrate the KYC and AML Procedures that he performs in order for STREAMFLOW EOOD to obtain a third party reliance upon the no-recurrent customer.
- Also Business Partner/ Customer shall demonstrate the collection and verification of information and also identification of information, which is carried out, under specific thresholds. In any case, STREAMFLOW EOOD and the relevant MLRO officer or External Auditor has the authority to conduct audits to this matter.
- When there are reasonable grounds for suspecting money laundering from criminal activities or financing of terrorism regardless of any derogation, exclusion or threshold amount (minimum threshold) of the transaction to be carried out, then we apply measures of due diligence independent from the amount of transaction, despite the measures that our business customer partner applied.
- The minimum data that our Business Customer/ Partner has to collect – regarding physical persons (non recurrent customers) and people that are using STREAMFLOW EOOD’ money transaction services (E-Vouchers) are the following,
In simplified Due Diligence
Required information Documents Required Certification
- Name- Surname
- Date –Place of birth
- I.D. / Passport number
- Issuing authority
An identity card or passport (or equivalent document) –valid- or identity card of Armed/ Security forces, which bring photo of the Customer. Valid (current) Home Address and contact phone Utility +phone bill Profession and current address of workplace Copy of his employer, copy of last salary statement or beginning ca –tax office, professional identity or document of Social Security Institution. Tax Identification Number Photocopy of salary slip/ tax awareness document or utility account
In Normal and Increased Due Diligence (most of the cases)
Business relationship & trade without physical presence of the Customer
Because of the nature of the object of our company, all transactions are carried out without the physical presence of the customer. So the same or additional measures may apply. Additional measures, such as: Client identification with additional supporting documents, data or information from valid reliable 3rd party sources. Ensuring that the first payment, within the framework of the business relationship, or any individual transactions, carried out through an account opened in the customer’s name with a credit institution established in one of the Member States of the European Union or in a state with an equivalent supervisory regime and Controlling State Authorities. Countries characterised by the FATF as “uncooperative” or the countries which do not apply or apply poorly the recommendations of the FATF, considered high-risk countries. There are no business relationships with natural or legal persons, including credit institutions and financial institutions, which are derived or have establishment of headquarters in these countries. Transactions which may come/ result from these countries, regarding market products services that our customers’ needs, shall be examined with particular attention and are subject to continuous monitoring.
Customer Data- Maintaining files
The completeness of the supporting documents that have been collected for the certification and verification of the identity of strategic customers and partners by STREAMFLOW EOOD, and on some and physical entities/ persons, is checked on the basis of the “Condition Required supporting Authentication Legal (and physical) Persons”, by specific employees or the MLRO. This situation is part of the file each Customer.
Also, we check the quality of the supporting documents, which must in any case be:
- Legible and readable
- Formal and official documents
- Valid at the beginning of the relationship
With respect to the certification of the identity of the legal persons or entities, the validity of legitimising the required documents shall be certified by the cooperating law consultant office/ employees of our company.
With regard to the legal persons established outside Greece without installation in the country, the documents to be presented should be bearing the stamp Apostille and translated into officially Greek language, if the company deems it necessary.
The identification of the customers, as well as the legal documents of companies should be checked annually and updated accordingly. The photocopies of the above documents authentication shall be kept for a period of at least five years after the end of the business relationship, in such a way as to ensure the confidentiality of collected data. The financial transactions should be kept for ten years or as long as the EU and Local Legislation requires.
Responsible, for further communication with the Greek AML State Authority or other competent State authority is the Legal Representor (or CEO) of STREAMFLOW EOOD- in case that these been requested:
- Data authentication of the beneficiaries of the account,
- Data authentication of persons who have the right of controlling the account ,
- Legal documents of all kinds legal entities/ persons ,
- Data authentication of administrators and their legal representatives who are authorized to initiate and move the account of a legal person, legal documents and supporting documents of trade,
- Data relating to the volume and the transactions carried out by the means of account which indicates the
- origin of the money,
- Type and amount of currency of the transaction ,
- The way in which the money deposited or taken, i.e. cash, electronic transfers etc
- Identity of the person who carried out the transaction ,
- Destination of the money ,
- Written approvals and authorisations of Customers
- Type and number of account involved in the transaction
Where identification procedures do not satisfy us as to the true identity of the customer the MLRO must be consulted to determine if the issues can be resolved. This is vital as consent from the authorities may be required before we proceed if we are to avoid being charged with non-compliance with applicable regulations.
Rating Strategic Customers/ partners
The company, for the identification and evaluation of the overall risk facing, take into account at least:
- The risk from the business/ professional activity of the customer (e.g. complex ownership structure legal persons, PEP, etc),
- The risk from the market behavior of the customer (e.g. difficulties in identifying the source and origin of the assets of the client, reluctance to disclose their real owners legal person etc.),
- The risk from the products and services provided to the customer (e.g. web check out, mobile check out etc.),
- Country Risk (Origin, destination funds or carrying out work).
The parameter taken into account for the assessment and the classification of customers by degree of risk is:
As a result of this evaluation, the customers of the company are classified internally in three categories:
- Low Risk
- Medium Risk
- High Risk
STREAMFLOW EOOD, carries out, periodic assessment clients from the Commercial Department for all customers. In addition, may hold an emergency assessment and customer accounts. The special assessment shall be carried out according to the criteria in the system. In particular, the emergency procedure evaluation is activated on the following cases:
- When the customer makes an important for him and for his profile transaction (if the average trade increased both in volume and value over 20 %.)
- When the customer may have high volume disputed transactions
- When there is a significant change in customer information (e.g. on the operations of the customer)
- When the company realized that lacks sufficient information for an existing customer or there are doubts as to the accuracy and adequacy of the data collected in the past.
Generally, customers are classified into three (3) risk categories with the following characteristics:
Α = High Risk Grade:
- Legal persons established outside Single Economic Space and FATF offshore companies (Not Applicable)
- Legal persons or associations of persons non-profit-making body, trusting funds, institutions and accounts for third.
- PEP of third country. (Not Applicable)
- Customers operating in some of the classes which the company considers as high-risk
- Customers based or activity in one of the countries which the company considers as increased risk each other case which is classified in this category by the responsible Compliance
Β = Medium Risk Grade:
All the other cases which are not covered by the specific categories
C = Low Risk Grade
- Credit institution or financial institution of a Member State of the European Union, or a credit institution or financial institution which is situated in a third country which imposes requirements which are equivalent to those laid down in European Community legislation and is subject to supervision with respect to the compliance with these requirements,
- Company whose securities are admitted to trading on a regulated market in a Member State of the European Union or in a third country are subject to transparency requirements that are equivalent to those laid down by European Community legislation,
- National Public Authorities.
For the purpose of calculating the limit of 15,000 euro will be taken into account all the transactions which it seems to have been a relationship between them- due to FATF regulations and conditions.
The above classification is carried out by means of a written risk analysis for each customer for the categories high and medium.
For the customer of high-risk measures apply enhanced due diligence.
- Country Risk (Origin, destination funds or carrying out work).
- Low Risk
- Medium Risk
- High Risk
- When the customer may have high volume disputed transactions
- When there is a significant change in customer information (e.g. on the operations of the customer)
Α = High Risk Grade:
- Legal persons established outside Single Economic Space and FATF offshore companies (Not Applicable)
- PEP of third country. (Not Applicable)
- Customers operating in some of the classes which the company considers as high-risk
Β = Medium Risk Grade:
All the other cases which are not covered by the specific categories
C = Low Risk Grade
- National Public Authorities.
For the customer of high-risk measures apply enhanced due diligence.
Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address, and phone number. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
1. For content that is covered by intellectual property rights, like photos and videos (IP content), you specifically give us the following permission, subject to your privacy and application settings: you grant us a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use any IP content that you post on or in connection with Facebook (IP License). This IP License ends when you delete your IP content or your account unless your content has been shared with others, and they have not deleted it.
2. When you delete IP content, it is deleted in a manner similar to emptying the recycle bin on a computer. However, you understand that removed content may persist in backup copies for a reasonable period of time (but will not be available to others).
3. When you use an application, the application may ask for your permission to access your content and information as well as content and information that others have shared with you. We require applications to respect your privacy, and your agreement with that application will control how the application can use, store, and transfer that content and information. (To learn more about Platform, including how you can control what information other people may share with applications, read our Data Policy and Platform Page.)
4. When you publish content or information using the Public setting, it means that you are allowing everyone, including people off of Facebook, to access and use that information, and to associate it with you (i.e., your name and profile picture).
5. We always appreciate your feedback or other suggestions about Facebook, but you understand that we may use your feedback or suggestions without any obligation to compensate you for them (just as you have no obligation to offer them).
How we use collected information
Streamflow EOOD may collect and use Users personal information for the following purposes:
- To provide customer services
- To carry out Know-Your-Customer (KYC) checks
- To collect information on your account and to prevent use of our platform for money laundering and sponsor of terrorist activities.
- To analyze your account activity in order to provide you with an adequate and reliable service• To offer you the best possible options suitable for your needs.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. However, the transmission of such data over the Internet using personal computers or mobile devices is not completely safe and therefore we cannot guarantee the security of documents submitted to our platform. Any transmission of such documents is at your own risk. As soon as we receive your private information, we have strict security measures and procedures in place to avoid unauthorized access from any third party.
Who are we ?
Prepaid Financial Services (PFS) is a fast-growing technology company and e-money payments institution with offices in the UK, Malta and Ireland. PFS is authorised and regulated by the Financial Conduct Authority in the UK, as an electronic money institution, under reference number 900036. We provide own label and white label e-money financial solutions, including e-wallets, prepaid cards, and current accounts. PFS provides complete end to end solutions for clients by designing, developing, implementing, and managing these programmes..
It is important that you know exactly what we do with the personal information you and others make available to us, why we collect it and what it means for you. This document outlines the PFS approach to Data Privacy to fulfil our obligations under the EU General Data Protection Regulation (GDPR) 2018 of 25th May 2018. We also welcome it as an opportunity to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use.
The personal data we would like to collect from you is:
→ First Name and Surname with title
→ Date of birth
→ Proof of address documents
→ ID Documents
→ Other personal information such as telephone recordings; security questions, user ID
→ CCTV footage where you visit our offices or branches
→ Bank Account details
→ Telephone number
→ Transactional information
The personal data we collect will be used for the following purposes:
- Providing prepaid card services to you as per our contractual obligations
- Providing e-wallet services to you
- Providing IBAN Account services to you
- Processing your account information
- To comply with our legal obligations for the prevention of fraud, money laundering, counter terrorist financing or misuse of services
- Verifying your identity
- Contacting you regarding our service to you
- Where requested by law enforcement for investigation of crime.
Our legal basis for processing the personal data:
- receipt of your consent
- performance of a contract where you are a party;
- legal obligations that PFS is required to meet;
- national law
Any legitimate interests pursued by us, or third parties we use, are as follows:
the prevention of fraud, money laundering, counter terrorist financing or misuse of services
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified above. Consent is required for PFS to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
Consent for Children Under 16
If you are giving consent on behalf of a child under 16 then please be aware that Children need specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned, and also of their rights in relation to the processing of personal data for the purposes of using these services. By consenting to this privacy notice on behalf of a minor you are giving permission for their data to be used for the purposes described above.
Withdrawal of Consent Conditions
You may withdraw consent from direct marketing at any time by contacting our Data Protection Officer. Please note, where you have consented to your data being used for carrying out financial transactions, then the right to withdraw consent does not exist. As a payment service provider, PFS is obliged to retain data concerning financial transactions for 6 years in accordance with national law for the purpose of preventing, detecting and investigating, by the FIU or by other competent authorities, possible money laundering or terrorist financing.
PFS will only pass on your personal data to third parties, including internationally, once we have obtained your consent. Some of our service providers, like payment processors, risk management solutions and suppliers are based outside of the EEA. Where we authorize the processing or transfer of your personal information outside of the EEA, we require your personal information to be protected to data protection standards and we ensure that there are adequate safeguards in place for data protection. The GDPR prohibits transfers of personal data outside the European Economic Area to a third country that does not have adequate data protection. Where transfer occurs outside the EEA the following mechanisms are in place with the third parties: - Data Protection clauses in our contracts and agreements with third-parties - EU-US Privacy Shield - Personal Information Protection and Electronic Documents Act (PIPEDA)
PFS will process personal data for the duration of the contract for services and will store the personal data for 6 years after that date of termination of the contract. state the retention period of their personal data and provide further information on how the retention period has been established.
Your rights as a data subjectRetention period
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Your data relating to financial transactions, accounts or cards cannot be deleted due to national law associated with the prevention of fraud, money laundering, counter terrorist financing or misuse of services for crime.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review, in the event that PFS refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. You will find a copy of our Subject Access Request Form on our website.
In the event that you wish to make a complaint about how your personal data is being processed by PFS (or third parties as above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and PFS’s Data Protection Officer by email to [email protected]
Data Protection Officer
Prepaid Financial Services
302-308 Regent Street, London,
If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO).
Information Commissioner’s Office
Telephone: 0303 123 1113
Further information can be found in our Cookies Policy on our website.