SERVICE AGREEMENT

KEY DEFINITIONS AND INTERPRETATION

In this Service Agreement, the following words have the meanings set out below.

Acceptable Language means English language.

Acceptable Use Policy means acceptable use policy available at Zolvat Website.

Account or Zolvat Account means an account opened in the Portal in the name of the Client and used to perform Payment Services or use other Services.

Business Day means any day set by Zolvat on which Zolvat provides the Services to the Clients. Zolvat shall be entitled to set different Business Days for the provision of different Services.

Confidential Information means, except as otherwise provided in this Service Agreement, all information (however recorded or preserved) disclosed by or exchanged between the Parties in connection with the Services, including, but not limited to:

• Any information provided by a Party in respect of itself or its business affairs; and
• Any information or analysis derived from the Confidential Information.

Client means the Account holder, who may be a natural person or legal entity using the Services. If the reference is made to the authorized person to use Zolvat’s platform and the Client is the User, then reference to User will refer to the Client as well.

Client Funds means the funds transferred to the Account, kept in it and intended for performance of the Payment Transactions through the Portal.

Electronic money, or E-money means a digital form of payment stored on an electronic device or in an account.

Fees mean fees for the Services payable by the Client. Fees are available at Zolvat Website or can be agreed by the Client and Zolvat individually. The Company’s pricing policy, including its risk-based tiered pricing methodology and automatic tier reclassification rules, is set out in Section 15.8 of this Service Agreement.

Identification means identification and verification of the identity of the Client, User or related person in accordance with the procedure established by Zolvat.

Identity Authentication Measures mean the signature, electronic signature of the Client, personal identification number assigned (issued) to the Client or User, the e-mail address and telephone number of the Client or User or other means (passwords, codes, keys) used for validation of the identity of the Client in the manner agreed by Zolvat and the Client and authorization of the Payment Transactions.

Parties means the Client and Zolvat referred to jointly.

Party means Zolvat or the Client separately.

Password means any code of the Client or User created in the Portal or a code provided to the Client or User by Zolvat for the access to the User Account and/or the Account or initiation and management of different Services provided by Zolvat and/or initiation, authorization, execution, confirmation and receipt of the Payment Transactions.

Payee means a natural or legal person which is indicated as the recipient of funds in the Payment Transaction.

Payer means a natural or legal person which is indicated as the transferor of funds in the Payment Transaction.

Payment Order means an instruction of a sender to a receiving institution, transmitted orally, electronically, or in writing, to pay, or to cause another institution to pay, a fixed or determinable amount of money to a beneficiary.

Payment Transaction means an action, initiated by the payer or on his behalf or by the payee, of placing, transferring or withdrawing funds, irrespective of any underlying obligations between the payer and the payee.

Payment Service means the payment services provided by Zolvat to the Client as defined in the license of the electronic money institution issued to Zolvat, including all transactions related to keeping of the Account, Payment Transactions and other payment services as may be included in the license from time to time.

Personal data means any information that relates to an identified or identifiable living individual (data subject). Different pieces of information, which together can lead to the identification of a particular person, may also be considered personal data.

Service means the specific service provided by Zolvat to the Client, including Payment Service.

Service of issuing electronic money means the service provided by Zolvat that allows clients to purchase electronic money in exchange for physical or digital payment.

Service of redeeming of electronic money means the service provided by Zolvat that allows clients to exchange their electronic money for cash or transfer it to a bank account or payment card. It involves converting electronic money, which is stored and transacted electronically, back into fiat currency upon their request.

Services Agreement means an agreement on the provision of Services between Zolvat and the Client concluded by means of acceptance by the Client of this Service Agreement, Privacy Policy, Cookies Policy, Fees Schedule, Acceptable Use Policy, or any other documents governing Zolvat Services, as the case may be.

Statement of Account means a document drawn up and provided by Zolvat stating information on the Payment Transactions carried out on the Account during the respective period.

Portal or Zolvat Portal means a web software solution enabling the Client to access the Account, manage the Client Funds and perform exchange of other information with Zolvat using secure electronic computerized communication means.

Unique identifier means a combination of letters, numbers or symbols specified to the Client by Zolvat and to be provided by the Client to identify unambiguously another payment service user and/or the payment account of that other payment service user for a Payment Transaction.

Website or Zolvat Website means the website owned and operated by Zolvat with web address https://zolvat.com.

For consistency, references to the “Services Agreement,” “General Service Agreement,” and “Service Agreement” are harmonized to “Service Agreement.”

Unless stated otherwise, references to time and Business Days are in Cyprus local time (EET/EEST). Cut-off times may vary by service and will be disclosed in the Portal or applicable service terms.

1. SUBJECT OF THE AGREEMENT. GENERAL PROVISIONS

1.1 Zolvat Ltd (hereinafter “Zolvat”, or the “Company”), registration number HE 422567, is an electronic money institution acting in accordance with license No. 115.3.1.59 issued by the Central Bank of Cyprus on 14.06.2024.

1.2 Clients can contact Zolvat at:

• Telephone: +357 99 175946
• E-mail: contact@zolvat.com
• Website: https://zolvat.com
• Mail address: 213B Arch. Makariou III, Maximos Plaza, Office 3, Limassol 3105, Cyprus

1.3 This Service Agreement (the “Agreement”) constitutes a contract between the Client and Zolvat in relation to provision of Payment Services in accordance with its provisions.

1.4 Before the Client decides to use Services and agree with the terms and conditions of this Agreement, he/she is obliged to read this document carefully, because it constitutes the legally binding relationship between the Client and Zolvat. The Client may print or download, and keep, a copy of this Service Agreement Service Agreement for future reference.

1.5 Under this Agreement, Zolvat undertakes to open the Account(s) for the Client, accept the funds from the Client, issue the appropriate amount of E-money and credit them to the Account opened by the Client, execute the Client’s instructions for the transfer and redemption of E-money and other payment transactions, to enable the Client to manage the Account and execute other operations performed by Zolvat, and the Client undertakes to pay Zolvat for the provided Services and performed operations.

1.6 Zolvat shall be entitled, at its own discretion and without the Client’s consent, to authorize third parties for provision of the Services.

1.7 Zolvat’s partners may, at any time, impose separate requirements and/or instructions for specific Services or use of the Services and the Client undertakes to comply with such instructions.

1.8 In using third-party services Zolvat shall act exclusively as an intermediary between the Client and service provider and shall be not liable for the proper provision of such services.

1.9 Terms and instructions of Zolvat’s partners Terms and instructions of Zolvat’s partners (including further amendments) are mandatory for the Client and it shall be obliged to comply with them for the entire duration of the Agreement. Zolvat and Zolvat’s partners may oblige the Client to refrain from any actions that are not consistent with the terms and instructions, while the Client shall fulfil such obligations without any reservations.

1.10 Various terms in this Agreement have a defined meaning, which is set out in the part “Key Definitions and Interpretation” or in other relevant sections throughout the Agreement.

1.11 Conditions of separate Services provided by Zolvat are set in separate agreements for specific Services which prevail over other provisions of this Agreement.

1.12 The Agreement is concluded and all communications between the Parties are sent in English, unless the Parties agree on another language acceptable to them or the Website indicates that another language is acceptable to Zolvat. All notices (including information on payment transactions) to the Client are sent by Zolvat to the Client by e-mail, submitted to the Account, uploaded on the Website or provided by other electronic channels (unless otherwise provided). The Client is also able to access the information relevant to him when logged in to the Website and the Account.

1.13 The Client has the right to get the copy of this Agreement on durable medium at any time. If the Client wishes to receive it printed on paper, additional Fees might be applied.

1.14 Clients have the right to receive information on the terms and conditions of this Agreement and payment services in writing or by e-mail; they can also find the terms of this Agreement and the provision of payment services on the Website at any time.

1.15 Clients have the right to get familiar with the current version of the Agreement, amendments to the Agreement and related information on the Website.

1.16 This Agreement shall come into force from the day the Client has been registered for Client Account and shall be effective for an indefinite period, until and unless of its termination by either of the Parties.

2. IDENTIFICATION AND AUTHENTICATION. SIGNATURE. DOCUMENTS REQUIREMENTS

2.1 In order to start using the Services, the User is required to submit to Zolvat an application through the Website, as well as the other documents and information required by Zolvat for Identification purposes.

2.2 A Client can apply to become a User and open an Account provided that:

• The User is an Individual, of at least 18 years of age,
• If the application is done on behalf of a legal entity, the User should confirm that he/she has the authority to bind the legal entity on whose behalf he/she uses and/or accesses the Services and that this legal entity accepts the terms of this Agreement,
• The User represents and warrants that opening of an Account does not violate any laws or regulations applicable to the User and the Client.

2.3 Zolvat shall require Identification of the User, the Client, representatives, authorized persons, directors, shareholders, beneficial owners of the Client, cardholders, merchants, agents, intermediaries, or other persons related to provision of the Services. By agreeing to this Service Agreement, the Client and User agree to the Identification of these persons. Zolvat shall have the right to request repeated Identification at any time at its discretion.

2.4 Identification information may include, but not limited to, the following:

• In case of a natural person, valid identity document with a photograph, signature, name and surname, personal identification number, date and place of birth (if available, personal identification number or any other unique sequence of symbols assigned to the person intended for identification of the person), number of the document, citizenship, document issuance and expiry dates, and other data evidencing the identity of the Client or User; and
• In case of a legal entity, certificate of incorporation (or a similar document), an extract from the register of legal entities (or a similar document) stating its name, legal form, place of registration and registered office, legal entity identification number (legal entity registration number or another code assigned in the register of legal entities) and documents evidencing the shareholders, controlling persons and ultimate beneficial owners of the legal entity.

2.3 Zolvat expressly reserves the right to request any other documents or information for Identification purposes.

2.4 The Client or User shall provide only full and accurate information for the purposes of application and identification. The Client or User shall bear any losses that may occur due to the submission of invalid, incorrect or inaccurate Information to Zolvat.

2.6 If there is any change in information previously provided to Zolvat by the Client or User, the Client or User undertakes to notify Zolvat immediately.

2.7 Zolvat reserves the right to close or set restrictions on the Account or the User Account if the Client or User does not comply with this Agreement, applicable laws and regulations, does not respond to reasonable requests of Zolvat or Zolvat is not able to verify the authenticity of information, data or documents provided for the purposes of Identification.

2.8 Zolvat shall have full discretion to accept or decline any documents provided by the Client or User for Identification purposes.

2.9 An authorized representative of the Client having appropriate powers (the User) shall be entitled to use and operate the Account on behalf of the Client and enter transactions in the name of the Client using the funds held at the Account. The User’s authority to represent the Client must be confirmed by the relevant document, including, but not limited to, articles of association, a resolution of a competent corporate body, a contract, or a power of attorney.

2.10 Zolvat may require that the Client who is a natural person does not use the authorized representatives in dealings with Zolvat in connection with the Services and deals with Zolvat directly on his/her own behalf.

2.11 If the Client or User uses the Portal, submits a Payment Order, requests information on the Account, the User Account, the Client Funds, the performed Payment Transactions, or other Services to be received by phone or email, such Client or User must be authenticated according to the Identity Authentication Measures, Passwords or by other means provided by Zolvat.

2.12 Zolvat shall be entitled to reject the application of the Client or User without specifying any reasons.

2.13 Generally, the Parties will exchange documents that require signature using recognized and reputable electronic signature solutions, such as DocuSign. At the same time, Zolvat reserves the right to request that the Client or User signs the documents in the presence of Zolvat’s representative, provides signed documents in a notarized form or delivers original signature pages of the relevant document.

2.14 The Client or User agrees that the Identity Authentication Measures specified and verified at the moment of Identification (e-mail address, telephone number) may be used for signature of the documents between the Parties.

2.15 The documents and Payment Order endorsed by the Identity Authentication Measures shall be deemed to be of the same legal force as the documents bearing a hand-written signature and the seal (if any) and shall be accepted as means of evidence in adjudication of any disputes between Zolvat and the Client.

2.16 Authenticity of the documents submitted by the Client or User electronically may be verified by Zolvat by requesting originals, apostilled or notarized copies of such documents.

2.17 If Zolvat has reasonable doubts regarding the authenticity or accuracy of the documents provided by the Client or User, Zolvat shall be entitled not to fulfill the requests/orders provided by the Client or User and request additional proof of the authenticity or accuracy of the documents provided by the Client.

2.18 If the documents provided to Zolvat are executed outside of Cyprus, Zolvat may request that such documents be certified by apostille or legalized by other means.

2.19 Documents provided to Zolvat shall be executed in English or contain the accurate English translation. If the documents are made in a different language or do not have English translation, Zolvat may request that these documents be translated to English, this translation be signed by the translator and authenticity of signature be attested by a notary.

2.20 All costs of drawing up, delivery, approval and translation of the Client’s or User’s documents provided to Zolvat shall be borne by the Client or User; however, in cases were deemed necessary and/or expedient, Zolvat may arrange for such translation at its own expense, provided the Client shall reimburse Zolvat for duly documented applicable costs.

2.21 Zolvat shall be entitled to keep and store the copies and originals (if any) of the documents provided by the Client or User in accordance with provisions of applicable legislation.

3. USER AND USER ACCOUNT

3.1 The User is a natural person, duly authorized representative of the Client for the purposes of using the platform through which Zolvat offers its Services.

3.2 User Account means an account opened for the User in the Portal under his/her personalized credentials and defining his/her rights in the Portal. User Account is used to access Accounts and use Services.

3.3 The User shall be entitled to manage the Account on behalf of the Client by logging in to the User Account that has been assigned to the Account with his login name, password, and confirmation through other Identity Authentication Measures.

3.4 Only the User for whom the User Account was created can hold and operate the User Account, and only the User shall be entitled to login to User Account. The User shall hold sole responsibility for unauthorized access to the User Account he/she is entitled to operate.

3.5 The User cannot have more than one User Account in the Portal. If for any reason multiple User Accounts for a single User have been created in the Portal, Zolvat will notify the User and will close such User Accounts leaving only one User Account operating. Failure to comply with this requirement may result in the suspension or termination of the User Account or civil and criminal liability for the User.

3.6 A User can operate multiple Zolvat Accounts.

4. FEES

4.0 The list of Fees applicable to the Services is set out in the Fees Schedule.

4.1 List of Fees applicable to the provision of Services is available on Zolvat Website or can be agreed by the Client and Zolvat individually. The Client will be required to confirm that it is fully aware of the Fees charged by Zolvat for the Services.

4.2 If Zolvat changes the Fees, the Client will be notified in advance. Changes will take effect after the applicable notice period; if the Client disagrees, the Client may terminate the Agreement before the effective date without penalty.

4.3 The Fees due to Zolvat for a specific Payment Transaction will be deducted at the execution of that Payment Transaction. The Fees will be indicated to the Client before execution of the Payment Transaction (unless the rules of the specific payment instrument specify otherwise). Fees for currency conversion will be made available to the Client before processing of its Payment Order.

4.4 The Client shall ensure that the funds held at the Account are sufficient for deduction of the Fees and execution of the relevant Payment Transaction, otherwise the Payment Transaction may not be executed.

4.5 Zolvat will deduct the Fees for a specific Payment Transaction in the same currency as the currency of the Payment Transaction and from the Account of the Client which is debited or credited for the purposes of such Payment Transaction. If there are no sufficient funds on such an Account, Zolvat may deduct the Fees from other Accounts of the Client in a different currency.

4.6 Monthly Fees, by default, shall be deducted in EUR.

4.7 Zolvat may deduct the amounts due from the Client from the funds that the Client receives into its Account, or from the funds that the Client attempts to withdraw or send from its Account.

4.8 Zolvat may make additional charges to the Client for an executed Payment Transaction equivalent to the number of charges received by Zolvat from the recipient bank and/or its correspondent bank in relation to such executed Payment Transaction. The amount of such charges differs and is determined according to each bank’s internal policies and regulations.

5. OPENING OF THE ACCOUNT. CLIENT FUNDS

5.1 After the User fills the online onboarding forms, submits all required documents and information and passes applicable identification and verification tests, Zolvat shall inform the Client of the opening of the Account within 72 (seventy-two) hours from the time of submission.

5.2 In case the Account opening is approved, the User can proceed with registration, opening, activation and use of this Account from the time of receipt of relevant notification.

5.3 In case the request for opening of the Account is rejected, Zolvat shall be under no obligation towards the prospective Client to provide any explanation of such rejection.

5.4 The Account is opened for the Client for an indefinite period, until and unless either the Client provides an express request to close his account, or Zolvat closes the Account in cases provided in this Agreement.

5.5 Zolvat will charge an application fee for any potential Client that wishes to open the Account. The application fee will be deducted from the initial transfer of funds by the Client.

5.6 The Account will enable the Client to transfer and hold money intended for transfers on its Account, carry out domestic and international money transfers, receive money to the Account, pay for goods and services and perform other operations directly related to money transfers.

5.7 The Client Funds held on the Account shall be considered as the Client’s owned funds in electronic form.

5.8 The Client Funds held on the Account does not constitute a deposit and Zolvat will not, in any circumstances, pay any interest on the Client Funds held on the Account. Client Funds held with Zolvat are not covered by deposit protection schemes, investor compensation funds, and are not subject to any similar protections or benefits.

5.9 When the Client transfers funds into its Account and/or it receives a payment into their Account, Zolvat shall place the funds into designated accounts held with authorized credit or financial institutions. Such accounts shall be clearly identified as Client accounts and funds kept on them shall be at all times segregated from the own funds of Zolvat. Client Funds are safeguarded in accordance with the Republic of Cyprus Payment Services and Access to Payment Systems Laws of 2018 (as amended) and applicable Central Bank of Cyprus Directives. Funds received in exchange for electronic money are placed in segregated safeguarding accounts with authorized credit or financial institutions and are kept separate from Zolvat’s own funds at all times. Client Funds are not deposits and are not protected by any deposit guarantee scheme; however, they are safeguarded as described herein.

5.10 At the Client’s request, the Client Funds held on the Account may at any time be withdrawn to the Client (in whole or in part). A withdrawal request may be sent in the form of a Payment Order for the transfer of the Client Funds from the Account to another account opened in the name of the Client with another credit or financial institution, or by other form agreed with Zolvat.

5.11 Withdrawals in favor of third parties are not allowed, except for cases where the Client provides sufficient justification of such withdrawal and this is approved by Zolvat on a case-by-case basis.

5.12 No additional Fee for withdrawal of Client Funds will be charged, except for the regular Fee payable on the Payment Transaction.

5.13 If the Account is closed for any reason or there is no authorized User on such Account, the Electronic Money held on such Account shall be transferred to the account indicated by the Client within 3 Business Days from the date of the relevant notice to the Client from Zolvat.

5.14 At its sole discretion Zolvat may establish the limits in respect of each specific Account, Client, User, Transaction, based on the criteria determined by Zolvat or for other reasons. The Client or User will be informed about the limits applied to the relevant Account; however, Zolvat will not be under obligation to disclose any of such criteria or reasons.

5.15 The Client shall have the right to request Zolvat to decrease or increase the transaction limits applied to its Account. Increase or decrease of the transaction limits applied to Account may be permanent or temporary.

6. EXECUTIONS OF PAYMENT ORDERS

6.1 In order to execute a Payment Transaction, the User will be required to submit a Payment Order in the Portal and confirm its consent by a one-time Password received by SMS or other Identity Authentication Measures. If the Payment Order was duly confirmed by the User after submission, the Client shall not have the right to dispute or challenge the Payment Transaction executed in accordance with such Order.

6.2 Clients can make a transfer by entering details of the recipient requested in the transaction form: recipient’s account details, the Unique Identifier, amount and currency of transfer, payment purpose or payment code, information if the receiver is a natural or legal person and other information requested by the Portal.

6.3 Zolvat has the right to determine the mandatory information to be submitted to Zolvat for the payment order to be properly executed. The payment order shall comply with the requirements established by Zolvat, the agreements concluded between the Client and Zolvat and the legal requirements for the submission of the payment order and/or its content. The payment order shall be worded clearly, unambiguously, executable, and it shall clearly express Client’s will. Zolvat is not liable for any errors, inconsistencies, repetitions and/or contradictions contained in the payment order, including, but not limited to, the accuracy of its details.

6.4 It is the User’s responsibility to make sure that the details in transaction form are entered correctly. Any error may result in the unsuccessful or delayed transfer. Zolvat shall not be liable for any losses the Client might incur from entering an incorrect Unique Identifier. If the User specifies not only the Unique Identifier but also provides additional information, Zolvat shall only be responsible for the execution of the transaction in accordance with the specified Unique Identifier.

6.5 If the Client makes an invalid transfer, invalid account crediting or indicates invalid payment transfer data and requests to revise the payment, additional fees may be charged.

6.6 If the Payment Order contains incorrect information, the payment will not be executed unless, in exceptional cases, Zolvat corrects the details of the Payment Order and effects it under the normal procedure at its own initiative provided that it has enough information to make such corrections.

6.7 The Payment Order shall be deemed to be received by Zolvat (and the time limit for execution of the Payment Order shall start to run) on the day of its submission and confirmation by the User, and, if such day is not a Business Day, the Payment Order shall be deemed to be received on the following Business Day.

6.8 The Payment Order which is received by Zolvat on a Business Day after the business hours shall be deemed to be received on the next Business Day.

6.9 Zolvat will execute payment orders submitted by Users on the following obligatory conditions:

• Payment Orders meet the requirements of applicable legislation, conditions of the Agreement and other requirements established by Zolvat.
• Client Account has sufficient funds for the execution of the submitted Payment Order and the Fee for its execution.
• the funds in Client Account are not frozen, seized and there is no other restriction on the management of funds in the Account.
• Payment orders are not subject to any restrictions stipulated by other legal acts or agreements concluded between the Client and Zolvat.
• Payment Order does not exceed the transaction limit imposed by Zolvat.

6.10 Before executing the Payment Order submitted by the Client, Zolvat shall have the right to request the Client to provide the documents confirming the legitimate source of funds that are the subject of the Payment Order, legal background of the Payment Transaction, Identification, supporting documents for a transaction, information on the counterparty or other documents related to the Client’s business activities or a particular transaction. If the Client fails to provide the requested documents, Zolvat may refuse to execute the Payment Order.

6.11 Zolvat shall have the right to refuse to execute a submitted Payment Order if there are reasonable doubts that the Payment Order has been submitted by an authorized User, or the documents provided to Zolvat are not sufficient, contradictory, ambiguous, false or the submitted Payment Order is illegitimate. In such cases Zolvat shall have the right to request additional documents and information from the Client or refrain from execution of the Order.

6.12 Zolvat may execute the Payment Order in full or in part, suspend or cancel its execution if it is in the best interests of the Client, required under applicable laws or due to other reasons beyond the control of Zolvat. In such cases the Client will be informed immediately and served with the reasons thereof, unless such notice is impossible for technical reasons, or restricted by an effective legal act or court decision.

6.13 Delays in execution or refusal to execute Payment Orders for the reasons and following the procedures stated in p. 6.10, p. 6.11 and p. 6.12 above do not constitute any infringement on the part of Zolvat and do not entitle the Client to claim from Zolvat any losses incurred due to such delays or refusals.

6.14 If the Client indicates incorrect Unique Identifier of the Payee and the Payment Order with such incorrect data is executed, Zolvat shall not bear any liability in connection with such Payment Order. In such a case, Zolvat will make reasonable efforts to cancel the Payment Transaction and return the funds to the Account. Additional Fees may be charged by Zolvat for such assistance.

6.15 If the amount of Client Funds on the Account is insufficient for execution of a Payment Order, it will not be executed. The Portal will attempt to execute the Payment Order for 5 (five) consecutive business days following the receipt of the Payment Order. If after the expiry of this period the Payment Order has not been executed, it will be canceled.

6.16 If the amount of Client Funds on the Account is insufficient for a transfer in one currency, but there is a sufficient amount of Client Funds in another currency, the Client may convert its Client Funds into the currency of transfer in question to procure its execution.

6.17 Cancellation of the confirmed Payment Order by the Client is possible only in exceptional cases and, in any case, is subject to the consent of Zolvat.

6.18 The Client may set a future date for execution of a Payment Order and/or provide that a Payment Order shall be executed subject to an incoming transfer. If on the indicated date the amount of Client Funds is sufficient, such Payment Order will be executed. A transfer to another Zolvat Account shall be executed on the same day and, in case a future date for execution is set, until 17:00 (EET/EEST) on the specified date.

6.19 Cancellation of the Payment Orders with the future execution date is allowed not later than till the end of the Business Day immediately preceding the future execution date. Zolvat shall not be liable if the requested cancellation of the Payment Order was not processed. Zolvat will charge a Fee for cancellation of such Payment Order.

6.20 If the Client Funds that has been subject to the executed Payment Order has been returned due to reasons beyond the control of Zolvat (incorrect information in the Payment Order, the account of the Payee is closed), the returned amount shall be credited to the Client’s Account and the Fees paid by the Payer for execution of the Payment Order shall not be repaid and any other fees and costs related to repayment of money can be debited from the Client’s Account (for example Correspondent Bank fees).

6.21 The Client will be able to check the outstanding balance and all the transaction history on its Account (debits, credits and charged Fees) for any period as well as get the Statement of Account by logging in to the User Account.

6.22 Zolvat shall be entitled to record and store any Payment Orders placed in the Portal and to record and store information on all Payment Transactions performed by the Client. These records may be presented by Zolvat to the Client and/or third persons (if they have a legitimate basis to request those) as evidence confirming the submitted Payment Orders and/or executed Payment Operations.

6.23 When a transfer other than SEPA credit transfer is performed and the Client makes credit transfer from the Account to other payment accounts, Zolvat may be indicated as the Payer. However, the Payee may also be supplied with the following information, subject to the Payee’s Portal:

• Detailed information about the Payer-Client is given in the field of the primary Payer (if the Payee’s Portal is supported by the relevant e-banking or payment Portal); or
• Detailed information about the Payer-Client is given in the field of payment purpose.

6.24 In addition to other provisions of this Agreement, Zolvat shall have the following rights in respect of Client Funds and the Account:

• If the funds have been incorrectly credited to the Account or incorrectly deducted from the Account, or other mistakes in transactions with the Account have been noticed, to correct these errors without additional consent of the Client.
• In the enforcement of a court decision or in other cases provided by applicable law, withdraw funds from the Account without Client’s consent.
• To suspend the deduction and payment of funds from the Account until the Client covers all of its debts to Zolvat or in accordance with other cases provided by applicable law.
• Do not accept or execute instructions to execute transactions in the Account, if the funds in the Account are frozen or the Client’s right to manage the funds in the Account is otherwise restricted.
• In case a client performs/receives SWIFT payment when SWIFT service is not enabled to this Client, apply the most expensive SWIFT rates according to the Zolvat price list provided on the Website.

7. UNAUTHORIZED PAYMENTS

7.1 The Client shall immediately notify Zolvat if it becomes aware that for any reason the Client is not entitled to the funds held on its Account. Such funds will be frozen by Zolvat and will be further transferred to a person that has a legal right to such funds without any Client’s instruction. If Zolvat is unable to do so due to the insufficiency of funds held on the Account, the Client shall compensate the difference within 3 (three) Business Days from receipt of Zolvat’s request

7.2 If the Client believes that any transaction has been incorrectly performed or was not authorized by it, the Client must inform Zolvat Client support as soon as possible via email, Website or other means of communication as applicable.

7.3 The User must check at least once a month the information on transactions executed in Client Accounts and to inform Zolvat in writing (by email) about any unauthorized or inappropriately executed payment transactions, the funds that do not belong to the Client credited to its Accounts and any other mistakes, inconsistencies or inaccuracies in the Accounts and in related transactions. The notification must be submitted promptly, and in any case no later than 60 (sixty) calendar days from the day Zolvat has executed the payment transaction which is indicated by the Client as unauthorized or improperly executed. If no such notifications are submitted by the specified time, the Client shall be deemed to have unconditionally agreed with the transactions executed in its Account. Clients should review account statements at least monthly and report any unauthorized or incorrectly executed transactions promptly to improve recovery chances. This reminder does not limit statutory timeframes.

7.4 The Client or User shall notify Zolvat immediately if the Payment Transaction has been incorrectly executed due to the reasons beyond control of the Client or User or was not authorized by the Client. Failure to notify Zolvat immediately on becoming aware of such fact, and in any case within 13 (thirteen) calendar months from the date of the unauthorized or incorrectly executed Payment Transaction will be considered as acceptance by the Client of such Payment Transaction and the Client will lose its entitlement to have the unauthorized or incorrectly executed Payment Transaction refunded by Zolvat.

7.5 Where it is established that the transaction was not authorized by the Client or was incorrectly initiated or performed by Zolvat and the Client has notified the Company as soon as it noticed it but not later than within 13 (thirteen) months of the date of the unauthorized transaction was performed, and unless the Client or User acted fraudulently or have intentionally or with gross negligence failed to protect the Identity Authentication Measures, Zolvat shall refund to the Client the full amount debited without authorization.

7.6 The Client agrees to report unauthorized payments to relevant legal authorities and share with Zolvat the reporting confirmation received from the relevant legal authorities.

7.7 The Client is liable for:

• all losses incurred in respect of a payment or currency exchange transaction, ATM withdrawal, other transactions made by Zolvat which was not authorized by the Client, if it has acted fraudulently, unfairly or has intentionally or with gross negligence failed to comply with the obligations set out in part “Security” of this Agreement or the Client did not notify Zolvat on time in accordance with this Section; and
• where the above provision does not apply, up to 50 (fifty) EUR of any losses incurred in respect of payment or currency exchange transaction, ATM withdrawal, other transactions which were not authorized by the Client related with usage of lost/stolen payment instrument or unlawful take over the instrument, where the Client has otherwise failed to comply with its obligations under part “Security”;
• Except where the Client has acted fraudulently or with intentional or gross negligence, it will not be liable for any losses incurred in respect of a transaction which occurs after the Client has notified Zolvat, without undue delay, on becoming aware of the loss, theft, misappropriation or unauthorized use of Client Account or other payment instrument.

7.8 Zolvat is liable for incorrectly executed transactions in the Account; however, the Company shall not be liable for non-performance or defective performance of the transaction Zolvat performed in accordance with the incorrect Unique Identifier given to it by the Client. However, Zolvat shall take reasonable efforts to recover funds and may apply additional Fees for doing so, including but not limited to passing on to the Client charges made by payment service providers for their assistance in the tracing process.

7.9 Zolvat shall not be liable for the correct performance of the transaction, if it can prove that the receiver’s payment services provider received the payment within the appropriate time period. Zolvat will however, upon the Client’s request, make efforts to trace any non-performed or defectively performed payment transactions and notify the Client of any outcome involving the investigation.

8. RESTRICTIONS ON THE USE OF ZOLVAT SERVICES

8.1 Prohibited Activities and Conduct

When using the Services of Zolvat, the Client or User must not:

• Breach this Agreement, other applicable supplements, agreements, applicable laws and regulations, including, but not limited to, legal acts related to prevention of money laundering and terrorist financing.
• Use, or attempt to use Zolvat Services to conduct business activities indicated as restricted or unacceptable by Zolvat, or for any illegal purposes, including, but not limited to, fraud and money laundering; financing of terrorist organizations; unlawful sexually oriented materials or services; counterfeit products; unlawful gambling activities; unlawful purchase or sale of tobacco, firearms, weapons, war ammunition, prescription drugs, other controlled substances; unlawful trade of currency (Forex), binary options or other products and services prohibited by law; unlawful provision of financial or investment services.
• Use, or attempt to use the Services with or for the benefit of a country, organization, entity, or person embargoed or sanctioned by any relevant government or international organization, including European Union, United Nations Security Council, US Office of Foreign Assets Control (OFAC), UK Office of Financial Sanctions Implementation (OFSI).
• Transfer and/or receive money earned because of activities or transactions contradicting applicable laws.
• Request to perform a transaction or to receive a payment from restricted countries or persons or in connection with restricted industries.
• Conduct the business or use the Zolvat Services in any manner that is likely to result in or may result in complaints, disputes, reversals, chargebacks, fees, fines, penalties, losses or other risks or liability to Zolvat, other Clients, third parties, Client and User.
• Infringe the rights of Zolvat or any third party to the trademarks, copyrights, patents, trade secrets and other intellectual property rights or rights of publicity or privacy; violate any rights of third parties.
• Provide false, inaccurate, misleading, or incorrect information and otherwise circumvent the procedures of Zolvat.
• Refrain from providing the information, including the confirmation of the identity, or undertake other actions that are reasonably requested by Zolvat in connection with the Services.
• Refuse to cooperate with Zolvat in investigation of violations.
• Spread, facilitate the spreading of computer viruses and conduct any other activities which could cause Portal malfunctions, damage or destroy information or result in any other damage to portals, equipment or information of Zolvat or any third parties.
• Undertake any other deliberate actions disturbing provision of the Services to the Client, User or third parties or disturb proper functioning of the Portal.
• Log in to the Portal as an anonymous user (via public proxy servers).
• Disclose Passwords, Identity Authentication Measures and other personalized safety features to third persons and allow unauthorized persons to use the Services in the name of the Client or User or use of anyone else’s passwords and other Personalized Safety Features.
• Provide false, misleading or incorrect information about Zolvat and cooperation with Zolvat to third parties.

8.2 Actions Zolvat May Take

If Zolvat believes that the Client or the User might have breached these provisions, the Company may take actions to protect itself, other Clients and third parties. The actions Zolvat may take include but are not limited to:

• Closing, suspending, or limiting access to the Portal, User Account, Account (-s) and/or payment instruments.
• Contacting other Zolvat Clients, third parties who have transacted with the Client; contacting Client’s bank or card issuer; and/or warning third parties, law enforcement, or impacted third parties of the Client’s actions.
• Taking legal action against the Client.
• Terminating this Agreement within time defined in the notice of termination.
• Fully or partially reversing a transaction.
• Suspending performance of the transaction.
• Freezing Client’s funds or part of it.
• Refusing to provide Services, limiting them.
• Changing any conditions of the provision of Zolvat Services.

8.3 Notification of Actions

Where it is possible, Zolvat will provide the Client and the User with the relevant information regarding the actions taken, but the Company may be unable to do so in accordance with the relevant law including interfering during an investigation.

8.4 Reimbursement for Damages

The Client shall reimburse all direct and indirect damages, fines and other monetary sanctions applied to Zolvat due to non-compliance with this Agreement.

9. COMMUNICATION AND NOTIFICATIONS ABOUT CHANGES OF THE AGREEMENT

9.1 Client Contact Information

The Client shall provide Zolvat with its valid e-mail address and telephone number and confirm it. The Client agrees that the provided email address and telephone number will be used for communication with Zolvat and that the User will check it regularly. The Client shall inform Zolvat on any changes of its contact details.

9.2 Contacting Zolvat

Clients can contact Zolvat Client support by email, phone, Website and other means of communication specified in the Website.

9.3 Submitting Notices to Zolvat

Clients can submit their notices to Zolvat by e-mail or via the Website, or they may also contact Zolvat by telephone or other means specified on the Website. Zolvat has the right to request a Client to send a message, information or documents at a particular time in any other manner and form requested by Zolvat (including by registered mail), and the Client shall undertake to do so at its own expense.

9.4 Receipt of Client Notices

Notices, information or documents submitted by the Client are deemed received by Zolvat when Zolvat confirms to the Client that the relevant notice, information or document has been received.

9.5 Zolvat Notices as Offers

Notices sent to the Client by Zolvat cannot be considered as an offer by Zolvat to the Client to conclude an agreement or to use the Services, unless Zolvat’s statement expressly states that such a tender is offered.

9.6 Unilateral Changes to Agreement

Zolvat has the right to unilaterally change the terms of the Agreement (including the Fees of the Services) by giving the Client a written notice (by email and/or via the Portal, and, where required, on a durable medium) 60 (sixty) calendar days in advance. For Clients who are natural persons (“Personal Clients“), changes to Fees published on the Website (including changes to the Fees Schedule) will apply after the above 60 (sixty) calendar days”‘ notice period. For Clients who are legal entities (“Business Clients“), changes to Fees published on the Website (including changes to the Fees Schedule) will apply immediately upon publication on the Website (or from any later effective date stated in the notice or on the Website), to the extent permitted by applicable law. The amendments to the Agreement shall be deemed approved and agreed with by the Client if the Client does not submit a written notice of disagreement before the date of entry into force of the amendment specified in the notice of amendment. The Client’s use of the Services after the effective date of the amendment of the Agreement terms constitutes the Client’s consent to the amendment of the Agreement terms. If the Client disagrees with the amendments and notifies Zolvat about it in writing, all agreements concluded between Zolvat, and the Client shall cease to be effective from the day of entry into force of the amendment to this Agreement. The Client is not entitled to unilaterally change the terms of this Agreement. Unless a longer period is required by law or scheme rules, Zolvat will provide at least 60 (sixty) calendar days”‘ prior notice for changes that are adverse to the Client. The Client may terminate the Agreement without penalty and without an account closure fee before the change takes effect. Continued use of the Services after the effective date constitutes acceptance.

9.7 Methods of Communication

Zolvat will give messages and notices to the Clients or Users by publishing them on the Zolvat Website (in case such messages are addressed to multiple recipients), the Portal, sending them via email, regular mail, SMS, or mobile push notifications, in each case using verified Identity Authentication Measures.

9.8 Deemed Receipt of Communications

Any communications or notices sent by:

• email will be deemed received on the same day if it is received in the email inbox before 17:00 EET. If it is received in the email inbox after 17:00 EET, it will be deemed received on the next day.
• mail will be deemed received 3 (three) business days from the date of posting for Cyprus post or within 10 (ten) business days of posting for international post, and
• SMS or Push notifications will be deemed received the same day.

9.9 Proper Notice from Client/User

A notice given by the Client or User to Zolvat shall be considered given properly if a notice is sent using account messaging function or Client support e- mail indicated on the Zolvat Website, or, if at the time it is not objectively possible, by calling Client support number during business hours indicated on the Zolvat Website and sending notice to the email indicated on the Zolvat Website.

9.10 Urgent Matters

For urgent matters, such as notification about suspected or executed unauthorized or fraudulent operations, unlawful use of Services or security threats, Client or User shall always give notice using Client support numbers indicated on the Zolvat Website.

9.11 Obligation to Update Contact Details

The Client or User must immediately inform Zolvat of any changes in its verified contact details (telephone number, email and address) which could be used by Zolvat to contact the Client or User. If the Client or User fails to inform Zolvat of such changes, all consequences arising from the failure of Zolvat to give a notice to the Client or User shall be borne by the relevant Client or User.

9.12 Notification of Lost Identity Document

The Client or User shall also immediately notify Zolvat of a theft or other loss of their personal identity document.

9.13 Notification of Technical Failures

Zolvat shall promptly notify the Client or User of any known or potential technical failures of the Portal and the portals or equipment of third parties contracted by Zolvat for provision of Services which may affect the Services.

9.14 Changes to Technical Solution/Software

Zolvat shall be free to change the technical solution or update the software used to provide the Service at any time. Such changes and updates may result in temporary interruptions to Services. Zolvat will give a prior notice of any such changes and updates to the Clients and Users.

9.15 Notification of Relevant Circumstances

The Parties shall immediately notify each other of any circumstances relevant to the compliance with this Service Agreement and exercise of the Service Agreement and provide the documents substantiating such circumstances, if required (e.g. bankruptcy, initiation and opening of restructuring proceedings, liquidation, reorganization or restructuring, etc.).

10. SUSPENSION AND TERMINATION OF SERVICES. CLOSING OF THE ACCOUNT. VALIDITY AND TERMINATION OF THE AGREEMENT

10.1 Zolvat’s Right to Unilaterally Act

Zolvat, at its sole discretion, shall have the right to unilaterally and without any justification:

• Decline the application for any of the Services.
• Suspend execution of Payment Transactions.
• Fully or partially suspend provision of the Services to the Client.
• Restrict the User’s access to the User Account.
• Reverse any Payment Transaction.
• Withhold funds from them or restrict access to their funds or Account.
• Discontinue any aspect of Services; or
• Terminate the Services.

Any suspension, restriction, or termination under Section 10 will be proportionate to the risk and applied only to the extent reasonably necessary to protect Clients, comply with law or scheme rules, or protect Zolvat’s legitimate interests. Where permitted by law, Zolvat will provide the reasons and a method to contact support for further information.

10.2 Grounds for Action

Actions referred to in paragraph 10.1 of this Service Agreement may be applied in respect of the Client and User in the following cases:

• If the Client or User is in breach or there is a reasonable possibility of breach of this Service Agreement (including if Zolvat has reasonable grounds to believe that the Client or User is engaged in money laundering, financing of terrorism, fraud or other criminal activity and such activity may be carried through the Account or User Account, or any part of the Client Funds in the Account are or may be related to such activity).
• If there are reasonable grounds to suspect unauthorized or fraudulent use of the Client Funds on the Account.
• If Zolvat receives reliable information on death/liquidation/dissolution/winding up of the Client or User.
• If the Company reasonably believes that the activities of the Client or User can cause damage to Zolvat’s goodwill or reputation.
• If Zolvat is given a direction to do so by any court, regulator or other competent regulatory, tax or other government authority.
• If the Company is no longer able to provide the Services due to a change in or termination of a service from its third-party suppliers, or due to a change in the policies of those suppliers.
• In other cases, provided in this Service Agreement or applicable laws.

10.3 Notification of Actions (Exceptions Apply)

Zolvat shall promptly notify the Client or User of the acts set out in paragraph 10.1, except for cases when such notification would prejudice the safety of the Client Funds or is forbidden by the applicable laws.

10.4 Client-Requested Restrictions

The Account or the User Account may be restricted at the written request of the Client or User. Such restrictions will be lifted upon a separate written request from the Client or User.

10.5 No Liability for Zolvat’s Actions

Zolvat shall not be liable for the Client’s or User’s losses incurred due to actions set out in paragraph 10.1.

10.6 User Liability for Unauthorized Transactions

The User has the liability related to the use of electronic money in case of unauthorized transactions, lost or stolen electronic money, and any damages incurred to Zolvat, including reputational damages.

10.7 Client’s Right to Terminate and Close Account

The Client or User shall be entitled to unilaterally terminate the Service Agreement and close the Account by giving a 30 (thirty) calendar days”‘ written notice to Zolvat. In this case, the Client must settle all outstanding obligations towards Zolvat. The Client is not entitled to a refund of the paid Fees.

10.8 Termination Due to Agreement Changes

The Client can also terminate this Agreement if it does not accept changes to the Agreement, its supplements, Schedule of Fees or other applicable documents and procedures, informing Zolvat before these changes are started to apply. Where termination is due to changes to the Fees or the Schedule of Fees, the Client may close the Account without an account closure fee.

10.9 Statement of Account upon Termination

If the Client decides to terminate the Service Agreement, Zolvat will provide the Client with the Statement of Account for the last 36 (thirty-six) months, unless Client chooses not to receive such information or requests another period to be covered by the Statement of Account.

10.10 Zolvat’s Right to Terminate without Cause

Zolvat shall be entitled to unilaterally terminate the Service Agreement, refuse to provide the Services, and close the Account without specifying a reason by giving a 60 (sixty) calendar days”‘ written notice to the Client.

10.11 Termination for Inactivity

The Service Agreement may be terminated by Zolvat with immediate effect if no transactions have been performed on the Account for a period exceeding one calendar year, provided that automatic deductions of payable fees and charges are not considered as transactions. Upon termination of the Agreement, Zolvat, upon the instruction of the Client, transfers the balance of the Account (after deduction of Fees payable to Zolvat and other amounts) to another account of the credit, financial, e-money or payment institution held in the name of the Client. If the Client has not given an order to transfer funds to another account, Zolvat, at its own discretion, transfers funds to internal accounts of Zolvat and informs the Client about it or transfers the funds to the last Client’s account known to Zolvat in another financial institution.

10.12 Termination for Material Breach or Other Events

Without prejudice to any rights that are set under this Agreement, or any Party’s other rights or remedies, either Party may at any time terminate this Agreement with immediate effect by giving written notice to the other Party if:

• The other Party commits a material breach of any term of this Agreement and (if such breach is remediable) fails to remedy that breach within a period of 30 (thirty) calendar days after being notified in writing to do so.
• The other Party repeatedly breaches any of the terms of this Agreement in such a manner as to reasonably justify the opinion that this party has no intention or ability to comply with this Agreement.
• There is a change in laws, payment scheme rules, regulatory authority rules or guidance or any change in means that it has become unlawful or contrary to any such law, rules, order or regulations for either of the Parties to perform or give effect to any of its obligations hereunder and such obligation cannot be readily severed from this Agreement; and/or
• The other Party is subject to bankruptcy, insolvency, winding up, and other similar events for a legal entity or there is a confirmed case of death of a relevant natural person.

10.13 Zolvat’s Right to Terminate for Specific Reasons

Without prejudice to any rights that are set under this Agreement or any of the party’s rights or remedies, Zolvat may at any time terminate this Agreement within date specified in written termination notification if:

• Zolvat is unable to verify Client identity and provided information.
• Zolvat has reason to believe that Client use of the Zolvat Services might negatively affect the Zolvat Services, Zolvat Portal.
• The Client has acted or omitted to act in any way which Zolvat reasonably determine to diminish Zolvat reputation and/or goodwill and/or which the Company reasonably determines or suspects to give rise to any offense or any increased risk or liability to Zolvat.
• The Client does not fulfil or improperly performs the obligations provided for in the Agreement, refrains from providing required information to Zolvat or it becomes evident that the Client, at the time of concluding the Agreement or later submitted to Zolvat incorrect or misleading information, or it becomes clear that the Client engages in activities unacceptable to Zolvat, illegal activities related to money laundering and/or terrorist financing.
• The Client is engaged in such acts or activities that are considered by Zolvat, Zolvat’s partners or operators of payment portals to be inconsistent with the terms and conditions of Zolvat’s partners or operators of payment Portals, or other instructions given to the Client, or is deemed to be fraudulent or otherwise wrongful.

10.14 Deductions and Remaining Obligations upon Termination

In case of termination of the Service Agreement and closing of the Account, Zolvat may deduct from the Client Funds the amounts payable by the Client or User to Zolvat for the Services, the fines, penalties payable to the governments, competent authorities or other relevant third parties, losses and any other documented costs incurred by Zolvat or paid by Zolvat through the fault of the Client or User. If the Client Funds is insufficient for covering the amounts due, the Client or User must transfer the remaining difference to the account indicated by Zolvat not later than within 3 Business Days.

10.15 Survival of Obligations

Termination of the Service Agreement and closing of the Account shall not release the Client or User from proper performance of all obligations to Zolvat which have arisen before the date of such termination/closing.

10.16 Redemption of Funds

If Zolvat terminates this Service Agreement and any other agreements between Zolvat and the Client or User, the Client shall be obliged to promptly choose the way of redemption of its Client Funds held on the Account and notify Zolvat accordingly.

11. CONFIDENTIALITY AND DATA PROTECTION

11.1 Confidentiality Obligation

Each Party (the Receiving Party) to whom Confidential Information is furnished by another Party (the Disclosing Party) shall keep the Confidential Information strictly confidential and, except with the prior written consent of the Disclosing Party or unless otherwise provided, shall not, and shall ensure that its authorized representatives shall not:

• Use or exploit the Confidential Information in any way except for the Services; or
• Disclose or make available such Confidential Information in whole or in part to any third party, except as expressly permitted by the provisions of this Agreement; or
• Copy, reduce to writing or otherwise record the Confidential Information, except in cases where it is necessary for the Services.

11.2 Exceptions to Confidential Information

Confidential Information shall not include any information that:

• Is, or becomes, generally available to the public (other than because of disclosure by the Receiving Party or any of its authorized representatives in breach of this Service Agreement); or
• Was available to the Receiving Party on a non-confidential basis before disclosure by the Disclosing Party; or
• Was, is or becomes available to the Receiving Party on a non-confidential basis from a person who, to the Receiving Party’s knowledge, is not bound by a confidentiality agreement with the Disclosing Party, or otherwise prohibited from disclosing the information to the Receiving Party; or
• Was lawfully in the possession of the Receiving Party before the information was disclosed to it by the Disclosing Party; or
• The Parties agree in writing is not confidential or may be disclosed; or
• Is developed by or for the Receiving Party, independently of the information disclosed by the Disclosing Party.

11.3 Permitted Disclosure to Authorized Representatives

The Receiving Party may disclose the Disclosing Party’s Confidential Information to its authorized representatives for the purpose of provision of the Services, provided that such representatives are required to keep that information strictly confidential.

11.4 Disclosure Required by Law

The Receiving Party may disclose Confidential Information to the extent such Confidential Information is required to be disclosed by the laws or regulations of any country with jurisdiction over the Receiving Party or by any governmental or other regulatory authority or by a court or other authority of competent jurisdiction. However, to the extent it is legally allowed to do so, it must give the Disclosing Party as much notice of that disclosure as possible and consult with it as to possible steps to avoid or limit disclosure and take those steps where they would not result in significant adverse consequences for the Disclosing Party. The Company may disclose Customer and account information to competent supervisory or public authorities, including the Central Bank of Cyprus, where such disclosure is required by applicable law; further details are set out in the Privacy Policy.

11.5 Notification of Disclosure (Short Notice)

If the Receiving Party is required to provide documents or information to any governmental or other regulatory authority, but due to short notice or absence of such notice from an authority, is unable to provide the notice referred to in p. 11.4 to the other Party before Confidential Information is disclosed, it shall (to the extent permitted by law) inform the other Party immediately after the disclosure of the full circumstances of the disclosure and the information that has been disclosed.

11.6 Retention of Confidential Information

Zolvat may retain Confidential Information of the Client or User after closing of the Account or User Account for regulatory and compliance purposes.

11.7 Data Protection Consent

In order to provide the Services Zolvat needs to collect and retain Personal Data about the Client or User, and any User or certain individuals connected to them. By accepting this Service Agreement, they are giving Zolvat explicit consent to access, process and/or retain any Personal Data in accordance with provisions of Regulation (EU) 2016/679 (General Data Protection Regulation), Law 125(I) of the Republic of Cyprus providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018, and other legislative acts as applicable.

11.8 Privacy Policy

Zolvat is committed to maintaining the Client’s Personal Data in accordance with legal requirements relating to the collection, storage and use of Personal Data. Zolvat’s Privacy Policy details more information on how the Company uses and protects the Personal Data of Clients and Users and their privacy rights.

11.9 Monitoring and Recording Communications

Zolvat may monitor and/or record telephone calls and electronic exchange of information the Company has with the Client or User without specific notice or warning to them.

12. SECURITY

12.1 Client’s Responsibility for Security

Zolvat Services are financial services; accordingly, the Client shall take all reasonable steps to protect the Client Account, Personalized Safety Features and hardware/software used for Account login. Any failure to do so may cause financial losses for the Client.

12.2 Reporting Security Breaches

If the Client/the User have any indication or suspicion of the Account, Portal login details, password or other security feature being lost, stolen, misappropriated, used without authorization or otherwise compromised; the Client is strongly advised to change password. The User must contact Zolvat without undue delay on becoming aware of any loss, theft, misappropriation or unauthorized use of the Account, Portal login details, password or other security features. Any undue delay in notifying the Company may not only affect the security of the Account/Portal but may result in the Client/the User being liable for any losses as a result. If the User suspects that their Account/Portal was accessed by someone else, the User should also contact the competent authorities and report the incident.

12.3 Password/PIN Security

• The Client must take all reasonable steps to always keep its Portal password safe and never disclose it to anyone. The Client/the User are solely responsible for the safety of password and PIN.
• It is advisable that any password shall be unique and consist of at least 8 symbols, including capital and lowercase letters, numbers, and special symbols in random combinations.
• The password shall not include information about the Client, the User, family members, pets which can be known or easily guessed by third persons from information someone might know or gather about the person or an entity or a password that has a meaning, such as: names, surnames, birth dates, addresses or their fragments. Also, it shall not consist of easily memorable and/or guessable combinations of numbers and letters.
• Password, PIN shall be changed at least once in 3 or 6 months.
• The password, PIN shall not be used for logins to other portals and accounts.
• The User shall remember password, PIN and not write it down anywhere, shall not enter in mobile phone, email or other electronic means of communication, and shall not reveal it to third persons. The User must never allow anyone to access the Account or watch a person accessing the Portal.
• Zolvat’s personnel will never ask the User/the Client to provide its password to the Company or to a third party. Any message received or website visited that asks for the password, other than the Company Website, should be reported to Zolvat.
• Zolvat does not initiate notifications (via SMS messages, emails, calls) with the offer/request to change the password or links to the password reset page. If a User receives such notification, it shall be immediately communicated to Zolvat’s Client support.
• If the User receives any SMS or email, questionnaires, surveys, or other links that require to provide PIN, password or other Personalized Safety Feature, a person shall not provide his/her information and shall contact Zolvat’s Client support without delay.
• If the User believes that the password, PIN may be known to any third person, he/she shall immediately change it and contact Zolvat’s Client support.

12.4 Email/Phone Security

• Email and phone used for communication with Zolvat shall be secured with password/PIN as it is described above.
• Email and phone shall be used only by the User.
• If the User notices any suspicious activity on the email account, it shall be immediately communicated to Zolvat’s Client support and change email and Portal passwords.
• If the phone used for Portal access is lost, it shall be immediately communicated to Zolvat’s Client support and Portal passwords must be changed.

12.5 Device/Software Security

• The User shall have a continuously updated antivirus program installed on his/her devices.
• All the devices used to login to Portal, to communicate with Zolvat shall be secured with a PIN or password.
• The Users are responsible for safety of devices used to log in to the Portal, shall not leave them unattended, in public places or otherwise easily accessible to third persons.
• The User shall update software, applications, antivirus programs, browsers, and other programs in time.
• The User shall use only original software and its standard instruments provided with the device and shall not perform any amendments to the Portal files.
• The Users are forbidden to use features which allow saving login data on the device or browser.
• The User shall close any application used for login, transactions, other services every time he/she is not using it.
• Irrespective of whether the person is using a public, a shared or own computer to access the Portal, he/she must always ensure that the login details are not stored by the browser or cached or otherwise recorded. The User should never use any functionality that allows login details or passwords to be stored by the computer they are using.

12.6 Portal Usage Security

• After finishing work within the Profile, the User shall log out from the Zolvat Portal and shall not leave the Profile accessible to third persons.
• Users are highly not recommended to login to the Profile via public computers or devices of other persons.
• Users shall update contact information on the Profile in time (including but not limited to phone number and email address).
• The Users shall perform all reasonable instructions provided in the Zolvat Portal, related to safety of payment instruments, and personalized safety features.
• If the User notices any suspicious activity on the Portal and believes that third persons may have logged in it, he/she shall immediately inform Zolvat’s Client support and request to freeze the Account.

12.7 Zolvat’s Rights Regarding Security

• The Company can freeze (block) Client Portal, Account, payments instrument if Zolvat has suspicions related with safety of the Portal, Account, payment instrument, unauthorized or unfair usage of Account, payment instrument, if there is high risk that the Client may not fulfill its payment obligations.
• Where it is possible, Zolvat will provide the Client with the relevant information regarding the actions imposed, but the Company may be unable to do so in accordance with the appropriate legislation or safety requirements.

12.8 Information About Security Breaches

If Zolvat has reasons to believe that any security breach or fraud might have happened, the Company will inform the Clients about the concerns via Zolvat Portal. In case the provision of information via Zolvat Portal would not be possible, the Company will send the User encrypted message via email. General security concerns might be provided via public means of communication (such as social networks or media).

13. OBLIGATIONS AND LIABILITY OF THE PARTIES

13.1 Indemnification for Breach:

Each Party is liable and indemnifies and holds harmless the other Party for all documented fines, penalties, direct losses, costs, and reasonable legal fees incurred by the other Party due to a breach of this Service Agreement caused by willful default or gross negligence of the indemnifying Party.

13.2 Disclaimer of Warranties:

The Services are provided on an “as is” basis and without any representation or warranty, whether express, implied, or statutory. Zolvat makes no representation of any kind whatsoever for the Services or the content, materials, information, and functions made accessible by the Services or used on or accessed through the Services.

13.3 Limitation of Zolvat’s Liability (Direct Losses Only):

Zolvat shall be liable only for direct losses incurred by the Client or User because of the breach of this Service Agreement. Zolvat will not be liable for consequential or indirect loss, such as loss of profits, opportunity, or reputation.

13.4 Aggregate Liability Cap:

The aggregate Zolvat’s liability under this Service Agreement shall not exceed the amount of Fees for the last 3 (three) months paid by the Client to Zolvat or EUR 2,000 (two thousand), whichever is greater.

13.5 Exclusions from Liability Limitations:

Zolvat does not exclude or limit its liability for:

• death or personal injury caused by negligence of Zolvat.
• fraud or fraudulent misrepresentation by the Company; or
• any other matter for which it would be illegal for Zolvat to exclude or limit its liability.

13.6 Portal Operation and Failures:

Zolvat does not guarantee uninterrupted operation of the Portal because operation of the Portal may be affected by many factors beyond Zolvat’s control. Zolvat shall make all reasonable effort to secure the smooth operation of the Portal. Zolvat shall not be liable for any consequences arising out of the Portal’s failures if such failures occur not because of Zolvat’s actions or omissions.

13.7 Minimum Portal Uptime:

In any case, Zolvat shall not be liable if the Portal has been accessible and operative for more than 95% (ninety-five percent) of all time, calculated for the last 6 (six) months.

13.8 Scheduled Downtime

The case when Zolvat limits access to the Portal temporarily due to Portal repair, update, development works, and other similar cases, and notifies the Client or User of such a case at least 2 (two) calendar days in advance, shall not be considered as a failure of the Portal.

13.9 Specific Exclusions from Zolvat’s Liability:

Zolvat shall not be liable for:

• Withdrawal and transfer of Client Funds from the Account and for other Payment Transactions with Client Funds held on the Account if the Client or User has disclosed or not protected their Passwords and other Identity Authentication Measures and, thus, they have become known or might have been disclosed to third parties.
• Delay or failure to perform its obligations under this Service Agreement by reason of any cause beyond reasonable control of Zolvat, including but not limited to any action or omission of the Client, User or any third party, any force majeure event, including epidemic and pandemic, bank delay, postal delay, failure or delay of any electronic or other transmission, any accident, emergency, act of God or any abnormal or unforeseeable circumstances.
• Any consequences which occur after Zolvat terminates this Service Agreement, closes, restricts or suspends the Account or User Account, or suspends or terminates the provision of the Services in whole or in part in cases stipulated by this Service Agreement or the applicable laws and regulations.
• Any goods and services purchased using the Client Funds.
• Any other third party which is a recipient or transferor under a Payment Transaction.
• Any defaults and losses if those have occurred because of mandatory provisions and requirements of applicable laws and regulations as well as any acts, decisions or orders of the competent regulatory authorities or an effective ruling or decision of the court of competent jurisdiction.

13.10 Client/User Liability for Information Accuracy:

The Client or User shall be fully liable for correctness of the information, orders, and other instructions provided to Zolvat, including details of payment orders.

13.11 Client Liability for Unauthorized Payment Transactions (Compromised Account):

The Client shall bear all losses incurred because of an unauthorized Payment Transaction if such Payment Transaction was processed from the compromised or otherwise unlawfully accessed Account or User Account.

13.12 Client Liability for Unauthorized Payment Transactions (Client Violation):

The Client shall bear all losses incurred because of an unauthorized Payment Transaction which was executed by the Client in violation of this Service Agreement or any requirements of applicable laws, including, but not limited to, failure to promptly notify Zolvat of unauthorized use, any compromise or failure to protect Identity Authentication Measures or Passwords.

13.13 Force Majeure Notification:

Each Party shall notify the other Party in writing of any force majeure circumstances which prevent compliance with this Service Agreement within 10 (ten) calendar days from the date of occurrence of such circumstances or when it becomes aware of the occurrence of such circumstances. Failure to notify in time would deprive the relevant Party from its right to refer to the force majeure circumstances as a liability limitation event.

13.14 No Responsibility for Payer-Payee Relations:

Zolvat is not responsible for relations and claims between payers and payees and does not investigate them.

13.15 No Responsibility for Third-Party Services:

Zolvat is not responsible for third-party services and products and their quality, malfunctions of third-party electronic portals while the Client or the User are accessing third-party Portals or paying for the goods or services provided by third parties while using the Services of Zolvat. Zolvat assumes no responsibility and does not guarantee that third parties will execute a transaction with the Client or the User. Claims regarding electronic Portals of third parties, their goods and services are not examined by Zolvat; they must be provided directly to third parties.

13.16 Further Limitations on Zolvat’s Liability:

Zolvat shall not be liable to its Clients for any:

• Delay or failure to perform Zolvat’s obligations under this Agreement (including any delay in payment) by reason of any cause beyond reasonable control of Zolvat, including but not limited to any Force Majeure event, any action or inaction by the Client or any third party, bank, failure or delay of any electronic transmission, any accident, emergency, or any other abnormal or unforeseeable circumstances; or
• Losses because of a requirement imposed on Zolvat by the laws of any EEA state or other jurisdiction.

13.17 Exclusion of Indirect and Consequential Damages:

In no event shall Zolvat be liable for loss of income or profits or any special, incidental, indirect or consequential damages arising out of this Agreement or otherwise in connection with the Zolvat Services.

13.18 Comprehensive Exclusions from Zolvat’s Liability:

To the extent permitted by applicable law, Zolvat, including, but not limited to, Zolvat’s directors, members, employees or agents, is not liable, and the Client agrees not to hold Zolvat responsible, for any damages or losses (including, but not limited to, loss of money, goodwill, or reputation, income, profits or any special, indirect, or consequential damages) resulting directly or indirectly from:

• Delays or disruptions in Zolvat Services.
• The Client’s inability to use the Services for any reason.
• Incorrect or inaccurate information provided by the Client.
• Viruses or other malicious software obtained by accessing the Website or any associated site or service;
• Failures of the telecommunication networks.
• Failure of Client’s equipment.
• The content, actions, or inaction of third parties.
• Actions and mistakes of financial institutions and other entities involved in the process of payment transactions, as well as for illegitimate actions of other third parties and losses incurred by the Client due to Account blocking and/or suspension of the Services.
• illegal actions and operations of third persons performed using counterfeited and/or illegal documents or illegally received data.
• Glitches, bugs, errors, or inaccuracies of any kind in Zolvat Services.
• Any actions taken with respect to the Client, the User, Client Account/Profile.
• Client’s need to modify practices, content, or behavior, or Client’s loss of or inability to do business, because of changes to this Agreement or Zolvat policies.
• Any actions or inactions of Zolvat employees occurred during the process of payment transaction or dealing with the Client or its Client Account/Profile.

13.19 Right of Set-Off

In the event which entitles Zolvat to be compensated by the Client (including, but not limited to, any technical errors on behalf of Zolvat or its partners), the Company shall be entitled to set-off the amount the Client owes Zolvat in that currency or in a different currency by deducting amounts from Client Account. If the amount the Client owes to the Company is in a currency which is different to the E-money held in the Client Account, Zolvat shall exchange the currency applying relevant currency exchange rates. The Company does not need to notify a client of this conversion occurring.

13.20 Force Majeure Release from Liability:

A Party is released from liability for non-performance of the Agreement if it proves that the Agreement has not been executed due to a Force Majeure event. The Parties must notify in writing (including e-mail) about the occurrence of Force Majeure circumstances that prevent the fulfillment of the Agreement within 14 (fourteen) calendar days from the date of the occurrence of these circumstances.

13.21 Client Obligations:

Except expressly indicated elsewhere in this document, within the scope of this Agreement the Client has the following obligations:

• Compliance with Laws and Regulations: To comply with the obligations and requirements of the Agreement, the laws and regulations applicable to the provision of payment services, activities of electronic money institutions, prevention of money laundering and combating of financing of terrorism, and data protection. The Client also undertakes to comply with other legal acts regulating the activities of the Client. These legal acts form an integral and inseparable part of the Agreement.
• Compliance with Jurisdiction-Specific Laws: To understand and comply with all laws, rules and regulations of the specific jurisdiction that may be applicable to the Client in connection with its use of Zolvat Services, including but not limited to, those related to taxes or foreign currency transactions. The Client is liable to the state and other subjects for fulfillment of all tax obligations independently.
• Authorized Account Use: To ensure that the Account (-s) will only be used and accessed by the Client or his lawful representatives.
• Account Security and Confidentiality: To use the Account in accordance with the terms and conditions of its use, ensure the security and confidentiality of the Account and login data, and take active steps to prevent Account and its login data from being used by unauthorized third parties.
• Immediate Notification of Unauthorized Use: Upon becoming aware of the unauthorized use of the Account and/or access to the Account or its login data, as well as the evidence or suspicions that such information has become known to third parties, to notify Zolvat or the entity designated by it immediately, but not later than within 1 (one) business day.
• Authorization of Electronic Communications: To ensure that the payment orders, notices, or other actions submitted to Zolvat using the electronic communication means are properly authorized.
• Security of Personalized Safety Features: To ensure the security of the Personalized Safety Features and payment instruments provided by Zolvat, to take actions to protect the individual security features of the Personalized Safety Features and payment instruments. If the Client suspects that the Personalized Safety Features or the payment instrument is or can be used without authorization, the Client has lost it, it has been seized by another person, or the Client cannot manage it for other reasons, the Client shall immediately, and not later than within one working day, inform Zolvat about it.
• Submission of Documents and Information: At its own expense, upon request of Zolvat, to submit all documents and information required by Zolvat within the deadline specified by Zolvat. The Client undertakes to submit the documents in the form and language as requested by Zolvat. If the Client violates the obligations stipulated in this clause, Zolvat has the right to demand that the Client compensates for losses caused by the violation (including, but not limited to, the costs for the translation, delivery, and approval of the documents). When opening, processing, and closing the Account, to submit the required documents to Zolvat, confirming the right of the Client or the Client’s representative to manage the Client’s Account and the funds therein.
• Guarantee of Information Accuracy: To guarantee and to ensure that any documents and information submitted by the Client to Zolvat are correct, accurate, and complete.
• Notification of Changes to Contact Details: Immediately, but not later than within three working days, to inform Zolvat if the Client’s address, account numbers, mobile telephone number or other information and contact details change. If the Client fails to comply with this requirement, the Client cannot make any claims and objections that the actions of Zolvat carried out using the latest known details of the Client, do not conform to the Agreement or that he has not received any communications sent using those contact details.
• Right to Record Communications: To provide Zolvat with the right to record communication between Zolvat and the Client using telephone or other communication means.
• Cooperation in Investigations: To actively participate in any investigation related to the Client’s Account, activity or payment transactions, to cooperate in providing Zolvat with all information and documents requested by Zolvat.
• Payment of Fees: To pay Zolvat Fees, charges and other payables for and in connection with the Services rendered and transactions executed by Zolvat at any time, irrespective of termination, suspension or closure.
• Sufficient Funds: To ensure that the Account has sufficient funds to execute payment orders and to pay Fees for the Services rendered and payments executed. If the Account does not have sufficient funds for the payment for the Services rendered and transactions executed, the Client agrees, and Zolvat is entitled to deduct this Fee from other Accounts of the Client at Zolvat.
• Notification of Incorrect Transactions: To immediately notify Zolvat of incorrectly credited or debited funds, as well as other mistaken transactions of the Account. In the event of insufficient funds to debit the amounts incorrectly credited to the Account, the Client unconditionally undertakes within 3 (three) business days from the day of reception the request from Zolvat to return the incorrectly credited funds to Zolvat.
• Liability for Breach of Agreement: To hold responsibility for all liabilities, financial or otherwise, incurred by Zolvat, Zolvat partners, Zolvat Clients or other third parties caused by or arising out of breach of this Agreement by the Client, its use of Zolvat Services or terms and conditions of Zolvat partners and third parties. The Client agrees to reimburse Zolvat, Zolvat partners, Zolvat Clients or other third parties for any and all such liability, to the extent not prohibited by applicable law.
• Liability for Account Operations: To assume full liability for all operations executed in the Account and concluded agreements.
• Liability for Incorrect Information: To be liable for all losses incurred by Zolvat due to incorrect information provided to Zolvat, invalid documents, false payment orders and/or non-performance of other obligations stipulated in the Agreement.
• Indemnification for Breach and Use of Services: To remain liable under this Agreement in respect of all. To indemnify Zolvat and hold Zolvat, its partners, its employees or agents who are authorized to act on the Company’s behalf harmless from any claim or demand (including legal fees) made or incurred by any third party due to or arising out of the breach of this Agreement by the Client, breach of any law and/or use of Zolvat Services.

14. GOVERNING LAW. DISPUTE RESOLUTION. COMPLAINTS

14.1 Governing Law:

This Service Agreement shall be governed by the applicable laws of the Republic of Cyprus.

14.2 Dispute Resolution:

The Parties shall seek to settle all disputes amicably through negotiations. Any dispute, not settled by negotiations or other pre-trial procedures, shall be settled in the competent court of the Republic of Cyprus.

14.3 Complaint Submission:

The Client or User may bring any claim or complaint regarding the Services in writing (by e-mail or post).

14.4 Complaint Response Timeframe:

The response to the Client’s or User’s complaint shall be provided within 15 (fifteen) Business Days from the date when it was received by Zolvat, but Zolvat will, in any case, attempt to respond faster. If there are valid reasons why Zolvat cannot provide an official response to the Client’s or User’s complaint in 15 (fifteen) Business Days, Zolvat will inform the Client or User of such a situation in writing and provide reasons for the delay. In such exceptional circumstances, Zolvat will provide a response not later than 35 (thirty-five) Business Days from the date of receipt of the complaint.

14.5 Free Complaint Examination:

Claims of the Clients or Users will be examined by Zolvat free of charge.

14.6 Referral to Financial Ombudsman:

If the Client or User does not receive the response on time or they are not satisfied with the response, they may be entitled to refer the complaint to the Financial Ombudsman of Cyprus, details of which are available at http://www.financialombudsman.gov.cy.

14.7 Complaint Procedure Availability:

Complaint procedure is available on Zolvat Website. Client or User may request detailed information on the complaint handling procedure at any time by contacting Zolvat.

15. PRICING POLICY

15.1 Pricing Policy (Risk-Based Tiers and Change Rules):

Zolvat applies a tiered pricing model that is objective, proportionate, and documented, and is designed to reflect cost-to-serve and risk drivers (including, without limitation, recognised legislative and regulatory risk factors associated with certain industries and countries, and higher compliance and operational costs, such as daily sanctions screening across multiple databases, PEP screening, adverse media screening, and correspondent and third-party processing costs).

The Fees (including tier-based Fees) are published on the Website (the Fees Schedule) and/or may be agreed with the Client individually. No Services are provided unless and until the Client meets Zolvat’s onboarding and eligibility requirements.

Fee types may include (where supported):

• Account setup and maintenance fees.
• Outgoing and incoming transfer fees (including SEPA and SWIFT, and other rails where supported).
• FX conversion mark-ups and any applicable minimums or caps.
• Corridor add-ons for higher-risk payer or beneficiary geographies.
• Pass-through fees from third parties (for example, correspondent bank lifting fees, scheme fees, or network fees), where applicable.
• Onboarding and compliance add-ons (for example, enhanced due diligence reviews, and additional person screening), where applicable.
• Operational service fees (for example, payment repair, recall, amendment, statements, and confirmations), where applicable.
• Optional product fees (for example, card issuing, card replacement, acquiring, refunds, chargebacks, and disputes), where supported.

Tier determination and reclassification may take into account objective inputs and documented criteria, including (without limitation) customer type (corporate or personal), expected volumes and products used, country exposure of the Client and payment corridors (payer and beneficiary countries), industry/sector exposure, ownership and control complexity, operational cost drivers (including payment rail and third-party fees, manual review effort, and vendor costs), and risk and loss drivers (including fraud, disputes, repair/recall rates, and other relevant indicators).

The tier is applied automatically using onboarding criteria and rules and may change automatically if certain conditions are met. For example, if the Client starts transacting with higher-risk countries or corridors, changes its industry/activity profile, or its ownership and control structure becomes more complex, Zolvat may move the Client to a different tier under the Fees Schedule.

A change in tier under this Pricing Policy is an application of the existing Fees Schedule to the Client’s updated risk profile and is not, of itself, a change to the Fees Schedule. If the Client’s tier changes under this Pricing Policy, the Fees applicable to the new tier will apply from the time the relevant criteria are met, and Zolvat will notify the Client of the applicable tier and Fees.

Zolvat works continuously to further align its pricing to real risk and cost-to-serve so that lower-risk Clients may receive the lowest Fees, where possible.

Availability of Services and certain products depends on eligibility checks, supported services, and legal or regulatory restrictions (including sanctions). Changes to the Fees Schedule are made in accordance with Section 9.6.

16. MISCELLANEOUS

16.1 Necessary Consents and Licenses:

Each Party represents and warrants that it has all necessary consents, approvals, permits, and licenses required under the applicable laws that are necessary for the execution and performance of this Service Agreement.

16.2 Declaration of Understanding:

The Parties declare that, at the time of signing the Agreement, they are not aware of any circumstances prohibiting the conclusion of this Agreement or restricting the right of the Parties to conclude this Agreement. The Client declares that all the conditions of the Agreement are in accordance with his will, the terms and conditions of the Agreement, its content and the consequences of its conclusion are understandable and clear to him.

16.3 Assignment of Rights and Obligations:

The Client or User shall not have the right to assign its rights and obligations arising out of this Service Agreement nor legal ownership of the Account to third parties or otherwise grant any third party a legal or equitable interest over Client Account without a prior written consent of Zolvat. Zolvat reserves the right to assign its rights and obligations arising out of this Service Agreement to third parties at any time by serving a written notice to the Client or User if such assignment of rights and obligations is not in conflict with applicable laws and regulations.

16.4 Severability:

If any provision of the Service Agreement is recognized as invalid, this shall not affect the validity of the remaining provisions of this Service Agreement. An invalid provision should be replaced by a valid provision, the economic and legal purpose of which should be as close as possible to the invalid provision.

16.5 No Waiver:

Any delay or failure by Zolvat to exercise any right or remedy under this Service Agreement is not to be considered a waiver of that right or remedy and it will not stop the Company from exercising it at any subsequent time.

16.6 Client/User Responsibility for Understanding:

It is the responsibility of the Client and User to ensure that they have read and understood this Service agreement in its entirety and in its last updated version and by continuing to use Zolvat’s platform the Client and the User accept its terms of provision of its services of electronic money, transfer and usage of its platform.

16.7 Confidentiality:

The Parties undertake to protect each other’s technical and commercial and other confidential information, except for publicly available information obtained during performance of the Agreement, and not to transfer it to third parties without the written consent of the other Party or its authorized representatives.