Terms of Service

Last Updated: 2025-01-05 Effective Date: 2025-01-05 Version: 2.0 (Non-Custodial Remittance Orchestration Platform)

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1. Introduction and Definitions

1.1 Service Description

These Terms of Service ("Terms") govern your use of PayWolt's cross-border remittance orchestration platform (the "Service" or "Platform").

PayWolt is a technology service provider that orchestrates international money transfers between licensed payment service providers. PayWolt does not hold, custody, transmit, or otherwise control customer funds at any time.

1.2 Legal Entity

1.3 Definitions

For the purposes of these Terms:

1.4 Nature of Service

PayWolt is NOT:

• A bank or credit institution
• An electronic money institution (EMI)
• A payment institution (PI)
• A money transmitter or remittance business
• A custodian or holder of customer funds

PayWolt IS:

• A technology service provider
• An orchestration platform connecting licensed providers
• A transaction routing and monitoring service

Critical Principle: All regulated payment activities (fund collection, custody, transmission, and delivery) are performed exclusively by our licensed Provider partners, not by PayWolt.

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2. Eligibility and Account Registration

2.1 Eligibility Requirements

To use the Service, you must:

1. Be at least 18 years of age (or the age of majority in your jurisdiction, whichever is higher)
2. Have legal capacity to enter into binding contracts
3. Be a resident of a supported jurisdiction
4. Not be located in, or a resident of, any jurisdiction subject to comprehensive economic or trade sanctions by the European Union, United Nations, United States, or United Kingdom
5. Not appear on any sanctions lists, including but not limited to:
   • EU Consolidated Sanctions List
   • OFAC Specially Designated Nationals (SDN) List
   • UN Security Council Sanctions List
6. Not have been previously suspended or terminated from the Service for Terms violations
7. Provide accurate, current, and complete information during registration

2.2 Account Registration

Account creation requires:

1. Email Verification: A valid email address that you control
2. Phone Verification: A valid mobile phone number for two-factor authentication
3. Password Creation: A secure password meeting minimum security requirements
4. Acceptance of Terms: Express consent to these Terms and our Privacy Policy

You may create only one Account per person. Multiple accounts may be consolidated or terminated without notice.

2.3 Account Security

You are solely responsible for:

1. Maintaining the confidentiality of your login credentials
2. All activities conducted through your Account, whether authorized or not
3. Immediately notifying us at security@paywolt.com if you suspect unauthorized access
4. Enabling and maintaining two-factor authentication (strongly recommended)

PayWolt will NEVER ask for your password via email, phone, social media, or any other communication channel. Any such request is fraudulent and should be reported immediately.

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3. Identity Verification (KYC)

3.1 Provider-Performed Verification

To comply with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations, identity verification is required for cross-border transfers and is performed exclusively by licensed payment service Providers, not by PayWolt.

PayWolt's Role: We collect your identity information and securely transmit it to the relevant Provider for verification.

Provider's Role: The Provider performs identity verification, makes verification decisions, and stores identity documents.

3.2 Verification Levels and Limits

Transfer limits are determined by your KYC verification level as assessed by the Provider:

*Actual limits are determined by the Provider and may vary by jurisdiction, transfer corridor, and risk assessment.

3.3 Verification Process

The typical verification flow:

1. You submit identity documents via the PayWolt Platform
2. PayWolt securely forwards your documents to the relevant Provider's API
3. The Provider performs verification checks, including:
   • Document authenticity validation
   • Biometric verification (where applicable)
   • Sanctions and watchlist screening
   • Politically Exposed Person (PEP) checks
4. The Provider returns a verification decision
5. PayWolt displays the result in your Account

Processing Time: Typically 1-3 business days, but may be longer for enhanced verification levels.

3.4 Ongoing Verification Requirements

Providers may request additional verification at any time to:

• Comply with updated regulatory requirements
• Investigate potentially suspicious activity
• Refresh expired documentation
• Authorize higher-value transfers

Failure to provide requested information may result in:

• Transfer restrictions or declines
• Account limitations or suspension
• Account closure (in extreme cases)

3.5 Data Storage

PayWolt stores:

• Verification status (e.g., "APPROVED", "PENDING", "REJECTED")
• Verification level (e.g., "BASIC", "STANDARD")
• Provider reference ID
• Verification timestamp

PayWolt does NOT store:

• Identity document images (passport, driver's license, national ID)
• Selfie photographs or biometric data
• Proof of address documents
• Original source of funds documentation

All such documents are stored exclusively by the Provider in accordance with applicable data protection regulations.

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4. Cross-Border Transfer Service

4.1 Service Scope

PayWolt orchestrates cross-border remittances across supported Corridors by coordinating licensed Providers for:

1. Foreign Exchange (FX) Quotes: Obtaining locked exchange rates
2. Payment Collection: Receiving your payment
3. Fund Transmission: Moving funds between Providers (where applicable)
4. Payout Execution: Delivering funds to your Recipient

4.2 Supported Corridors

The Platform supports multiple transfer Corridors, including but not limited to:

• Africa ↔ Europe: (e.g., Nigeria → Germany, Ghana → United Kingdom)
• Africa ↔ Africa: (e.g., Nigeria → Kenya, Ghana → South Africa)
• Europe → Africa: (e.g., Germany → Nigeria, France → Ghana)

A complete list of supported Corridors is available in the PayWolt mobile application and website. Corridors may be added, modified, or temporarily suspended based on:

• Provider availability
• Regulatory changes
• Liquidity constraints
• Risk management decisions

4.3 Payment Service Providers

PayWolt integrates with licensed payment service providers, initially including:

Provider Extensibility: PayWolt's architecture supports integration with additional Providers. The list above represents initial Providers and is not exhaustive. Provider information for each transfer is disclosed before you confirm the transaction.

Provider Selection: PayWolt automatically selects the optimal Provider(s) for each transfer based on:

• Transfer Corridor
• Source and target currencies
• Regulatory requirements
• Cost optimization (for your benefit)
• Service availability and reliability

You authorize PayWolt to select Providers on your behalf in accordance with the above criteria.

4.4 Transfer Process and Lifecycle

Each transfer progresses through the following stages:

Stage 1: Quote Generation

1. You specify:
   • Source country and currency
   • Target country and currency
   • Transfer amount (either send amount or receive amount)
   • Recipient details
2. PayWolt obtains an FX quote from the designated FX Provider
3. PayWolt calculates total fees (see Section 5)
4. A Quote is presented with:
   • Locked exchange rate
   • Estimated delivery time
   • Total fees
   • Total amount you will pay
   • Amount recipient will receive
   • Quote expiry time (typically 15 minutes)

Important: Exchange rates fluctuate continuously. The Quote locks the rate for the specified duration. If you do not confirm within this period, the Quote expires and you must request a new Quote. PayWolt does not automatically re-price expired Quotes.

Stage 2: Transfer Confirmation and Payment

1. You review and accept the Quote
2. PayWolt validates:
   • Quote has not expired
   • Your KYC status meets minimum requirements (typically BASIC level, APPROVED status)
   • Transfer amount complies with Corridor limits
   • Sufficient liquidity exists at Payout Provider (see Section 4.7)
3. If validation succeeds, a payment link or instruction is generated
4. You are redirected to the Collection Provider's payment page
5. You complete payment using the Provider's available methods (card, bank transfer, mobile money, etc.)

Payment Custody: Your payment is received and held exclusively by the Collection Provider, not by PayWolt.

Stage 3: Payment Confirmation

1. The Collection Provider processes your payment
2. Upon successful payment:
   • The Collection Provider notifies PayWolt via secure webhook
   • PayWolt verifies the webhook authenticity using cryptographic signature validation
   • The transfer status updates to COLLECTED
3. If payment fails or is cancelled:
   • The transfer status updates to FAILED or CANCELLED
   • No payout is initiated

Underpayment: If the amount received is less than the total amount due (e.g., due to foreign exchange fluctuations in the payment method), the transfer will fail and a refund will be processed by the Collection Provider.

Stage 4: Payout Execution

1. PayWolt instructs the Payout Provider to deliver funds to the Recipient
2. The Payout Provider:
   • Validates Recipient bank account details
   • Performs compliance screening (if required)
   • Initiates the payout via local payment rails (SEPA, SWIFT, mobile money, etc.)
3. The transfer status updates to PAYOUT_PROCESSING

Liquidity Model: PayWolt maintains pre-funded liquidity pools at Payout Providers to enable instant or same-day payout initiation. These funds are PayWolt's corporate operational funds, not customer deposits.

Stage 5: Completion or Failure

Successful Completion:

• The Payout Provider confirms delivery to the Recipient's bank account
• The transfer status updates to COMPLETED (Terminal State)
• You and the Recipient receive confirmation notifications

Payout Failure:

• If the payout fails due to a temporary issue (e.g., network error), PayWolt automatically retries up to 3 times with exponential backoff (intervals: 1 minute, 5 minutes, 15 minutes, 1 hour)
• If the payout fails due to a permanent issue (e.g., invalid account, recipient bank rejection, compliance hold), the transfer status updates to FAILED (Terminal State) and a refund is initiated (see Section 4.6)

4.5 Transfer Timing

Estimated delivery times vary by Corridor:

Actual delivery time depends on:

• Collection Provider's processing time
• Payout Provider's processing time
• Recipient bank's processing time
• Banking hours and public holidays in source and target countries
• Compliance review requirements

PayWolt is not liable for delays caused by Providers or recipient banks beyond our reasonable control.

4.6 Failed Transfers and Refunds

If a transfer fails after payment collection:

Automatic Retry: For temporary failures (network errors, provider downtime), PayWolt automatically retries payout execution up to 3 times.

Permanent Failure: If the payout cannot be completed after maximum retries, or if the failure is non-retryable (e.g., invalid recipient account, compliance rejection):

1. The transfer status updates to FAILED (Terminal State)
2. PayWolt initiates a refund request with the Collection Provider
3. The Collection Provider processes the refund to your original payment method
4. Refund processing time: typically 5-10 business days (depending on the payment method and Collection Provider's policies)

PayWolt's Role in Refunds: PayWolt does not hold your funds and cannot directly issue refunds. All refunds are processed by the Collection Provider in accordance with their terms and applicable payment network rules.

Fees on Failed Transfers:

• If the transfer fails before payout execution: Full refund including fees (unless the failure was caused by incorrect information you provided)
• If the transfer fails after payout execution has been attempted: PayWolt's platform fee may be non-refundable, but Provider fees will be refunded where applicable

4.7 Liquidity Availability

Liquidity Model: To enable rapid payout execution, PayWolt maintains pre-funded balances (liquidity pools) at Payout Providers. These are PayWolt's own operational funds, not customer deposits.

Liquidity Checks: Before accepting your payment, PayWolt verifies that sufficient liquidity exists at the Payout Provider to complete the transfer. If liquidity is insufficient:

• The transfer is declined before payment collection
• You are notified and may retry later or choose an alternative Corridor
• No payment is collected and no fees are charged

Operational Transparency: Liquidity availability is monitored in real-time. Corridor availability displayed in the Platform reflects current liquidity status.

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5. Fees and Pricing

5.1 Fee Structure

The total cost of a transfer consists of:

1. PayWolt Platform Fee: A technology orchestration fee for routing and monitoring your transfer
2. Provider Fees: Fees charged by the Collection Provider and/or Payout Provider for regulated payment services
3. Foreign Exchange Margin: The difference between the mid-market rate and the rate offered by the FX Provider (typically included in the exchange rate)

5.2 Fee Transparency

Pre-Transaction Disclosure: All fees are disclosed in the Quote before you confirm the transfer. The Quote displays:

• Source amount (the amount you send)
• Exchange rate
• PayWolt platform fee
• Provider fees (itemized where feasible)
• Total fees
• Total amount you will pay
• Target amount (the amount recipient will receive)

Fee Breakdown Example (Nigeria → Germany, 100,000 NGN):

Source Amount:           100,000 NGN
FX Rate:                 1,850 NGN per EUR
Raw Target Amount:       54.05 EUR

PayWolt Platform Fee:    500 NGN (0.5%)
Provider Fees:           2,000 NGN
Total Fees:              2,500 NGN

Total You Pay:           102,500 NGN
Recipient Receives:      54.05 EUR

5.3 Fee Calculation

PayWolt Platform Fee:

• Calculated as a percentage of the source amount (basis points)
• Varies by Corridor (typically 0.3% - 1.0%)
• May include a minimum fee per transaction

Provider Fees:

• Set independently by each Provider
• Vary by:
  • Payment method (card vs. bank transfer)
  • Transfer Corridor
  • Transfer amount
  • Provider's cost structure

5.4 Fee Changes

PayWolt may modify platform fees at any time, subject to the following notice requirements:

For Future Transactions: Fee changes apply immediately to new Quotes. The applicable fees are always displayed in the Quote before you confirm.

No Retroactive Changes: Fees locked in an accepted Quote will not change, even if PayWolt updates its fee schedule before the transfer completes.

5.5 Third-Party Fees

Recipient Bank Fees: The Recipient's bank may deduct fees from the incoming payment. These fees are set by the recipient bank and are outside PayWolt's control. Typical recipient bank fees:

• SEPA transfers: Usually free
• SWIFT transfers: EUR 5 - EUR 25
• Local bank transfers (Africa): Varies by country and bank

Intermediary Bank Fees: For certain Corridors (especially SWIFT-based), intermediary banks may deduct fees. PayWolt recommends using Corridors with direct payout rails (SEPA, local ACH, mobile money) to minimize intermediary fees.

5.6 Currency Conversion

Exchange Rate Source: Exchange rates are provided by the designated FX Provider for each Corridor (Wise or Flutterwave). PayWolt does not set or control exchange rates.

Rate Composition:

• Mid-Market Rate: The interbank exchange rate (e.g., from Reuters, Bloomberg)
• Provider Margin: The FX Provider's markup (typically 0.3% - 1.5% depending on currency pair)
• Quoted Rate: The rate offered to you in the Quote

Rate Transparency: The Quote displays the exchange rate you will receive. For comparison, mid-market rates are available from independent sources such as xe.com or Google Finance.

Rate Lock Duration: The exchange rate is locked for the duration specified in the Quote (typically 15 minutes). After expiry, you must request a new Quote at the then-current rate.

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6. Transfer Limits

6.1 Limit Types

Transfers are subject to multiple limit types:

6.2 Corridor-Specific Limits

Each Corridor has defined minimum and maximum transfer amounts. Example:

Limits are displayed in the Platform and in the Quote before you confirm.

6.3 Limit Increases

To request higher limits:

1. Complete a higher KYC verification level with the Provider
2. Provide additional documentation as requested (e.g., source of funds, proof of income)
3. Establish a transaction history demonstrating legitimate use

Limit increases are subject to Provider approval and may take 3-10 business days to process.

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7. Prohibited Uses and Restricted Activities

7.1 Prohibited Purposes

You may NOT use the Service for:

Illegal Activities:

• Money laundering or terrorist financing
• Fraud, scams, or deceptive schemes
• Tax evasion or avoidance schemes
• Financing illegal goods or services
• Violating economic or trade sanctions
• Financing human trafficking, modern slavery, or exploitation

Restricted Business Activities (without prior written approval):

• Operating unlicensed money transmission or remittance services
• Operating unlicensed gambling or gaming services
• Adult entertainment or sexually explicit services
• Sale of weapons, ammunition, or explosives
• Sale of controlled substances or pharmaceuticals without license
• Cryptocurrency mixing, tumbling, or anonymization services

Abuse and Circumvention:

• Creating multiple Accounts to circumvent limits
• Providing false, misleading, or fraudulent information
• Using another person's identity or Account
• Circumventing security measures or access controls
• Exploiting system vulnerabilities or bugs for personal gain
• Interfering with the Platform's operation or other users' access

7.2 Compliance Monitoring

PayWolt and its Providers actively monitor for prohibited activities using:

• Automated transaction screening
• Behavioral analytics
• Sanctions and watchlist checks
• Manual compliance review (for high-risk transactions)

7.3 Consequences of Prohibited Use

Violation of this Section may result in:

1. Immediate transfer cancellation or reversal
2. Account suspension or permanent termination
3. Forfeiture of fees (no refund)
4. Reporting to law enforcement or regulatory authorities
5. Legal action to recover damages or comply with legal obligations
6. Permanent ban from the Service

PayWolt reserves the right to report suspicious activity to:

• Financial Intelligence Units (FIUs)
• Hellenic Authority for Combating Money Laundering (Greece)
• Relevant authorities in other jurisdictions
• Providers' compliance teams

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8. Account Suspension, Restriction, and Termination

8.1 PayWolt's Right to Restrict or Suspend

PayWolt may, at its sole discretion, restrict, suspend, or terminate your Account or access to specific features if:

1. You violate these Terms or any applicable law
2. We suspect fraudulent, abusive, or suspicious activity
3. Your Account has been inactive for 12 consecutive months
4. A Provider suspends or terminates your account with them
5. We receive a legal order, subpoena, or regulatory directive
6. You fail to complete required KYC verification
7. You are added to a sanctions list or watchlist
8. We determine that continued service poses legal, regulatory, or reputational risk to PayWolt

Notice: We will attempt to provide advance notice of suspension or termination except where:

• Immediate action is required to prevent harm or comply with law
• Providing notice would violate legal obligations
• The Account is being used for prohibited activities

8.2 Your Right to Terminate

You may terminate your Account at any time by:

1. Submitting a closure request via support@paywolt.com
2. Following the account closure process in the Platform (if available)

Effect of Voluntary Termination:

• Access to the Service will be revoked immediately or within 2 business days
• Pending transfers will be processed to completion where feasible
• No new transfers can be initiated
• You remain liable for any fees or obligations incurred before termination

8.3 Effect of Termination

Upon Account termination (voluntary or involuntary):

1. Access Revoked: You will no longer be able to log in or use the Service
2. Pending Transfers:
   • Transfers in non-Terminal States may be cancelled or completed at PayWolt's discretion
   • Transfers in Terminal States (COMPLETED, FAILED, etc.) are unaffected
3. Data Retention: PayWolt will retain your data as required by law for regulatory compliance (typically 5-10 years for financial transaction records)
4. No Refund of Fees: Fees for completed or failed transfers are non-refundable upon termination
5. Outstanding Obligations: You remain liable for any amounts owed to PayWolt or Providers

8.4 Survival

The following provisions survive termination of these Terms:

• Sections 5 (Fees), 7 (Prohibited Uses), 10 (Intellectual Property), 12 (Disclaimers), 13 (Limitation of Liability), 14 (Indemnification), and 15 (Dispute Resolution)

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9. Unauthorized Transactions and Disputes

9.1 Reporting Unauthorized Transactions

Unauthorized Transaction: A transfer initiated without your permission, consent, or knowledge.

Your Reporting Obligation: If you discover an unauthorized transaction, you must notify PayWolt immediately via:

• Email: security@paywolt.com
• In-App: Help > Report Unauthorized Activity
• Urgent Hotline: (if available in your region)

Timeframe for Reporting: Under EU Directive 2015/2366 (PSD2), you have 13 months from the date of the transaction to report unauthorized transactions and claim a refund. However, immediate reporting (within 24-48 hours of discovery) significantly improves the likelihood of successful fund recovery.

9.2 Distinction: Unauthorized vs. Erroneous Transfers

Unauthorized Transaction:

• Someone else accessed your Account without permission and initiated a transfer
• Examples: Account hacked, credentials stolen, device compromised
• Remedy: Eligible for refund (subject to liability limits in Section 9.4)

Erroneous Transfer (Authorized but Incorrect):

• You authorized the transfer, but sent it to the wrong recipient, amount, or Corridor
• Examples: Mistyped recipient account number, selected wrong currency
• Remedy: Recovery depends on Recipient's voluntary cooperation (see Section 9.6)

This distinction is critical for determining your refund eligibility.

9.3 Investigation Process

Upon receiving your unauthorized transaction report:

Extended Investigations: Complex cases (e.g., requiring cooperation from foreign banks) may require up to 35 business days. We will inform you if an extension is necessary and provide an estimated completion date.

9.4 Liability for Unauthorized Transactions (PSD2 Compliance)

Your liability for unauthorized transactions depends on whether you exercised reasonable care in safeguarding your Account credentials:

Burden of Proof: Under PSD2 Article 72, PayWolt must prove that you acted with gross negligence. Absent such proof, you are entitled to a full refund.

Refund Timing: If your claim is approved, PayWolt will coordinate with the Collection Provider to refund the amount by the end of the next business day.

9.5 Gross Negligence Defined

Gross negligence includes, but is not limited to:

1. Credential Sharing:

   • Intentionally sharing your password, PIN, or two-factor authentication codes with others
   • Allowing another person to access your Account with your knowledge

2. Insecure Storage:

   • Writing down passwords and storing them with your device (e.g., sticky note on laptop)
   • Saving passwords in unencrypted files accessible to others

3. Ignoring Security Warnings:

   • Continuing to use the Account after receiving notifications of suspicious activity
   • Failing to change credentials after being notified of a potential compromise
   • Ignoring alerts about unrecognized login locations or devices

4. Deliberate Security Bypass:

   • Disabling two-factor authentication without legitimate reason
   • Using the Account on known-compromised devices or networks
   • Ignoring software updates that patch critical security vulnerabilities

Not Gross Negligence: Falling victim to sophisticated phishing, credential stuffing attacks using breached passwords from other services, or SIM-swapping attacks generally does not constitute gross negligence (absent other aggravating factors).

9.6 Erroneous Transfers (Recovery Assistance)

If you authorized a transfer but sent it to the wrong recipient or made an error in the details:

PayWolt's Assistance:

1. We will attempt to contact the Recipient on your behalf via the contact information provided
2. We will request voluntary return of the funds
3. We will coordinate with Providers to facilitate the return (if the Recipient agrees)

Limitations:

• We cannot compel Recipients to return funds that you voluntarily sent
• Recovery depends entirely on the Recipient's cooperation
• Legal action to recover funds is your responsibility (PayWolt can provide transaction documentation to support your claim)

Prevention: PayWolt displays recipient confirmation screens before you authorize a transfer. Review all details carefully before confirming.

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10. Intellectual Property

10.1 PayWolt's Intellectual Property

All content, features, and functionality of the Service, including but not limited to:

• Software, source code, and algorithms
• User interface designs and graphics
• Trademarks, service marks, logos ("PayWolt" name and logo)
• Text, images, and audiovisual content
• Documentation and user guides

are owned by DONATION POS L.P. or its licensors and are protected by:

• Hellenic Republic copyright law
• European Union intellectual property directives
• International copyright treaties (Berne Convention, WIPO Copyright Treaty)
• Trademark law

10.2 Limited License to Use

Subject to your compliance with these Terms, PayWolt grants you a limited, non-exclusive, non-transferable, revocable license to:

1. Access and use the Service for personal, non-commercial cross-border remittances
2. Download and use the PayWolt mobile application on devices you own or control

Restrictions: You may NOT:

• Copy, modify, distribute, sell, or lease any part of the Service
• Reverse engineer, decompile, or disassemble the software
• Remove or alter copyright, trademark, or proprietary notices
• Use the Service to build a competitive product or service
• Frame, mirror, or scrape content from the Service
• Use automated tools (bots, scrapers) to access the Service without written permission

10.3 User-Generated Content

If you submit feedback, suggestions, or ideas regarding the Service ("Feedback"), you grant PayWolt a perpetual, irrevocable, worldwide, royalty-free license to use, modify, and incorporate such Feedback without compensation or attribution.

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11. Privacy and Data Protection

11.1 Data Processing

PayWolt processes your personal data in accordance with our Privacy Policy (available at www.paywolt.com/privacy) and applicable data protection laws, including:

• Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR")
• Hellenic Law 4624/2019 (GDPR implementation in Greece)
• ePrivacy Directive 2002/58/EC

11.2 Data Sharing with Providers

By using the Service, you consent to PayWolt sharing your personal data with Providers to the extent necessary to:

1. Perform KYC verification
2. Process your transfers
3. Comply with AML/CTF regulations
4. Prevent fraud and financial crime

Provider Data Processing: Providers process your data as independent data controllers under their own privacy policies. You should review each Provider's privacy policy.

11.3 Cross-Border Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including:

• United States: For transfers involving Stripe
• United Kingdom: For transfers involving Wise
• African countries: For transfers involving Flutterwave

Such transfers are protected by:

• Standard Contractual Clauses approved by the European Commission
• Adequacy Decisions (where applicable, e.g., UK under the EU-UK Trade and Cooperation Agreement)
• Provider Certifications (e.g., EU-US Data Privacy Framework, if applicable)

11.4 Your Data Rights

Under GDPR, you have the right to:

• Access: Obtain a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal retention obligations)
• Restriction: Limit how your data is processed
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to certain types of processing (e.g., direct marketing)

To exercise these rights, contact privacy@paywolt.com.

Data Retention: Transaction records are retained for 5-10 years to comply with AML/CTF and tax regulations, even if you request erasure.

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12. Disclaimers and Warranties

12.1 Service "As Is"

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, PAYWOLT DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO:

1. Merchantability: Fitness for a particular purpose
2. Non-Infringement: That the Service does not violate third-party rights
3. Accuracy: That information displayed is always accurate or up-to-date
4. Uninterrupted Service: That the Service will be available 24/7 without downtime
5. Error-Free Operation: That the Service is free from bugs, viruses, or harmful components
6. Security: That the Service is immune to cyberattacks or unauthorized access

12.2 No Financial Advice

PayWolt does not provide:

• Financial, investment, or tax advice
• Legal or regulatory compliance advice
• Recommendations on whether to make specific transfers

You should consult qualified professionals (financial advisors, tax consultants, legal counsel) for advice tailored to your circumstances.

12.3 Third-Party Services

PayWolt is not responsible for:

• Actions, errors, or omissions of Providers (Wise, Flutterwave, Stripe, or others)
• Third-party websites, services, or content linked from the Platform
• Recipient banks' policies, fees, or processing times
• Currency exchange rate fluctuations beyond the Quote validity period

12.4 Regulatory Disclaimer

PayWolt does not guarantee:

• That the Service is available or compliant in all jurisdictions
• That specific Corridors will always be available
• That regulatory changes will not affect service availability or pricing

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13. Limitation of Liability

13.1 No Liability for Provider Actions

TO THE MAXIMUM EXTENT PERMITTED BY LAW, PAYWOLT SHALL NOT BE LIABLE FOR:

1. Provider Failures: Delays, errors, or failures by Collection Providers, Payout Providers, or FX Providers
2. Payment Processing Issues: Problems with payment collection, fund transmission, or payout delivery caused by Providers
3. KYC Decisions: Rejection, delays, or errors in identity verification performed by Providers
4. Provider Insolvency: Financial difficulties or insolvency of any Provider
5. Regulatory Actions: Sanctions, freezes, or holds imposed by regulators on Providers or transactions

Recourse: For issues arising from Provider actions, you may have direct claims against the Provider under their terms of service.

13.2 No Liability for External Factors

PayWolt is not liable for delays or failures caused by events beyond our reasonable control ("Force Majeure"), including:

• Natural disasters (earthquakes, floods, hurricanes, pandemics)
• War, terrorism, civil unrest, or armed conflict
• Government actions, regulatory changes, or sanctions
• Infrastructure failures (power grid, internet backbone, payment networks)
• Cyberattacks affecting third-party systems (Provider APIs, banking networks)
• Strikes, labor disputes, or supplier failures

Service Restoration: PayWolt will use commercially reasonable efforts to resume normal service as quickly as possible following a Force Majeure event.

13.3 Exclusion of Consequential Damages

TO THE MAXIMUM EXTENT PERMITTED BY LAW, PAYWOLT SHALL NOT BE LIABLE FOR:

• Indirect Damages: Loss of profits, revenue, business opportunities, or goodwill
• Consequential Damages: Arising from errors, delays, or service interruptions
• Incidental Damages: Such as costs of procuring substitute services
• Punitive or Exemplary Damages

This exclusion applies even if PayWolt has been advised of the possibility of such damages.

13.4 Maximum Liability Cap

For Regulated Payment Services (PSD2-Governed Transactions):

PayWolt's liability for payment service failures governed by EU Directive 2015/2366 (PSD2) is limited as follows:

For Non-Payment Services (Platform Technology Failures):

For matters not covered by PSD2 (e.g., Platform bugs, data breaches unrelated to payments), PayWolt's total liability is limited to the lesser of:

1. The amount of the specific transfer in dispute, OR
2. The total fees paid by you to PayWolt in the 12 months preceding the claim

Minimum Liability Cap: In no event shall PayWolt's liability exceed EUR 10,000 per user per calendar year.

13.5 Exceptions to Limitations

The above limitations DO NOT apply to:

1. Fraud or Willful Misconduct: Intentional wrongdoing by PayWolt's employees or directors
2. Death or Personal Injury: Caused by PayWolt's negligence
3. Gross Negligence: Reckless disregard for your rights or safety
4. Statutory Rights: Liability that cannot be excluded or limited under applicable law (e.g., consumer protection laws)
5. Safeguarding Obligations: Breaches of fund safeguarding duties (if applicable to PayWolt's model)

13.6 Allocation of Risk

These limitations reflect a reasonable allocation of risk between you and PayWolt, given that:

• PayWolt does not custody or control your funds (Providers do)
• PayWolt charges modest platform fees relative to the transaction value
• Providers are independently licensed and regulated entities with their own insurance and safeguarding obligations

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14. Indemnification

You agree to indemnify, defend, and hold harmless PayWolt, its affiliates, officers, directors, employees, agents, and licensors (collectively, "PayWolt Parties") from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising out of or related to:

1. Your Breach of These Terms: Any violation of these Terms or applicable law
2. Your Prohibited Use: Use of the Service for prohibited activities (Section 7)
3. Your Negligence or Misconduct: Fraud, misrepresentation, or intentional wrongdoing
4. Third-Party Claims: Claims by Recipients, Providers, or others arising from your transfers
5. Inaccurate Information: Losses caused by incorrect recipient details or other information you provided
6. Unauthorized Access: Resulting from your failure to secure your Account credentials

Indemnification Process:

1. PayWolt will notify you of any claim subject to indemnification
2. You will have the right to assume defense of the claim (at your expense)
3. PayWolt may participate in defense with its own counsel (at PayWolt's expense)
4. You may not settle any claim without PayWolt's prior written consent

This indemnification survives termination of these Terms.

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15. Dispute Resolution and Governing Law

15.1 Governing Law

These Terms are governed by and construed in accordance with the laws of the Hellenic Republic (Greece), without regard to its conflict of law principles.

Consumer Protection: If you are a consumer resident in the European Union, you also benefit from mandatory consumer protection provisions of the law of your country of residence that cannot be waived by contract.

15.2 Dispute Resolution Procedure

Step 1: Informal Resolution (Mandatory First Step)

Before initiating formal dispute resolution, you must attempt to resolve the dispute informally by:

1. Contacting PayWolt Support: complaints@paywolt.com
2. Providing:
   • Your full name and Account email
   • Description of the dispute and relevant transaction details
   • Desired resolution or remedy
   • Supporting documentation (screenshots, receipts, etc.)
3. Allowing PayWolt 15 business days to investigate and respond

Step 2: Alternative Dispute Resolution (ADR)

If informal resolution fails, you may use free, independent ADR services:

ADR Characteristics:

• Free of charge for consumers
• Voluntary: Either party may decline to participate or accept the outcome
• Non-binding: The decision is a recommendation, not enforceable unless both parties agree
• Timeframe: Typically 90 days from submission to decision

Step 3: Judicial Proceedings

If ADR does not resolve the dispute, you may bring legal action in the competent courts.

15.3 Jurisdiction and Venue

For Claims by You (Consumer):

If you are a consumer in the EU, you may bring legal action in either:

1. The courts of Athens, Greece (PayWolt's registered office), OR
2. The courts of your country of residence

For Claims by PayWolt:

PayWolt may bring legal action only in the courts of your country of residence.

For Claims by Business Users:

If you are using the Service for business purposes, both parties agree to the exclusive jurisdiction of the courts of Athens, Greece.

15.4 Class Action Waiver

Applicability: This clause applies only to the extent permitted by law (some jurisdictions prohibit class action waivers for consumers).

To the extent permitted by law, you and PayWolt agree that disputes will be resolved on an individual basis. You waive the right to participate in class actions, collective actions, or representative proceedings.

EU Consumer Exception: This waiver does not apply to EU consumers to the extent it would violate Directive (EU) 2020/1828 on representative actions for the protection of collective consumer interests.

15.5 Time Limit for Claims

Payment Service Claims (PSD2): Claims related to unauthorized, non-executed, or defectively executed payment transactions must be brought within:

• 13 months from the transaction date (for unauthorized transactions)
• 13 months from the date you should have become aware (for other payment service issues)

Other Claims: Claims not related to payment services are subject to statutory limitation periods under Greek law (typically 5 years for contractual claims).

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16. General Provisions

16.1 Entire Agreement

These Terms, together with the following documents, constitute the entire agreement between you and PayWolt:

• Privacy Policy (www.paywolt.com/privacy)
• Cookie Policy (www.paywolt.com/cookies)
• Acceptable Use Policy (incorporated in Section 7)

These Terms supersede all prior or contemporaneous agreements, communications, or understandings (written or oral) regarding the Service.

16.2 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction:

1. That provision will be modified to the minimum extent necessary to make it valid and enforceable
2. If modification is not possible, the provision will be severed
3. The remaining provisions will continue in full force and effect

16.3 No Waiver

PayWolt's failure to enforce any right or provision of these Terms does not constitute a waiver of that right or provision. Any waiver must be in writing and signed by PayWolt.

16.4 Assignment

By You: You may not assign, transfer, or delegate your rights or obligations under these Terms without PayWolt's prior written consent. Any attempted assignment in violation of this provision is void.

By PayWolt: PayWolt may assign these Terms, in whole or in part, to:

• An affiliate or subsidiary
• A successor entity in a merger, acquisition, or sale of assets
• Any third party with 30 days' advance notice to you

16.5 Notices

To You: PayWolt will send notices via:

• Email to the address associated with your Account
• In-app notifications within the Platform
• Posting on the Platform or website (for general notices)

You are responsible for maintaining a current email address.

To PayWolt: You must send legal notices to:

DONATION POS L.P. (trading as PayWolt)
Attn: Legal Department
El. Venizelou 218
Kallithea, 17675
Athens, Greece
Email: legal@paywolt.com

Notices are effective:

• For email: Upon sending (if sent to the correct address)
• For postal mail: 5 business days after mailing

16.6 Language

These Terms are provided in English. Translations may be available for convenience, but the English version governs in case of discrepancies.

16.7 Survival

Provisions that by their nature should survive termination will survive, including but not limited to Sections 5 (Fees), 7 (Prohibited Uses), 9 (Disputes), 10 (Intellectual Property), 12 (Disclaimers), 13 (Limitation of Liability), 14 (Indemnification), and 15 (Governing Law).

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17. Amendments to Terms

17.1 Right to Amend

PayWolt reserves the right to modify these Terms at any time to:

• Reflect changes in applicable law or regulatory requirements
• Address new features, services, or Providers
• Improve clarity or correct errors
• Respond to security or operational needs

17.2 Notice of Material Changes

For Material Changes (e.g., fee increases, liability limitations, dispute resolution changes):

1. PayWolt will provide at least 30 days' advance notice via:
   • Email to your registered address
   • Prominent notice in the Platform
   • Posting on www.paywolt.com/terms
2. The notice will include:
   • Effective date of the changes
   • Summary of key changes
   • Link to the updated Terms

For Non-Material Changes (e.g., clarifications, formatting, correcting typos):

• Changes may be effective immediately upon posting
• No individual notice required (though we may provide notice as a courtesy)

17.3 Acceptance of Changes

Acceptance: Continued use of the Service after the effective date constitutes acceptance of the amended Terms.

Rejection: If you do not agree to the amended Terms:

1. You must stop using the Service
2. You may close your Account before the effective date
3. Pending transfers will be processed under the previous Terms (if closed before effective date)

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18. Contact Information

For questions, concerns, or complaints regarding these Terms or the Service:

Response Times:

• Email inquiries: 2 business days (acknowledgment), 5 business days (substantive response)
• Complaints: 2 business days (acknowledgment), 15 business days (resolution)
• Security issues: 24 hours (acknowledgment), immediate action if critical

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Document Control

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BY CREATING AN ACCOUNT OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS OF SERVICE.

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These Terms of Service have been drafted to reflect PayWolt's non-custodial, orchestration-only business model for cross-border remittances. For legal advice regarding your specific situation, please consult qualified legal counsel.