Thank you for opening an account with Trumia Ltd (“Trumia” or the “Institution”). These Terms andConditions were last updated and published on the 28th August, 2024

1. General

1.1. These Business General Terms and Conditions (“Terms and Conditions”) set out the terms andconditions under which Trumia shall provide the Trumia Services to the User.

1.2. These Terms and Conditions along with the Fee Schedule, Data Privacy Notice and any other documents which are stated to apply to the provision of our services form a legal agreement between the User and Trumia.

1.3. For further information, please refer to our FAQ page which sets out other useful information about Trumia and how it provides the Trumia Services. The FAQs do not form part of Trumia’s legal agreement with the User.

1.4. The Agreement will take effect immediately upon acceptance by the User and will terminate in accordance with the provisions of these Terms and Conditions.

1.5. The Agreement is deemed to be accepted by the Applicant by clicking the “I accept the Terms and Conditions” tick box during the customer onboarding process via the Trumia Platform.1.6. A copy of this Agreement will be sent to the email address which is provided to Trumia and it is recommended that a copy is kept for future reference. The User can request a copy be sent using the contact information provided below. Trumia makes these T&Cs publicly available, at all times, on its website (www.trumia.com) for the perusal of prospective clients and account holders.

2. Information about Trumia

2.1. Trumia is a limited liability company incorporated and registered under the laws of Malta under company registration number (C96757) with its registered office at Quad Central, Q3, Level 3, Triq l-Esportaturi, Zone 1, Central Business District, Birkirkara CBD 1040, Malta and is licensed by the MFSA as a financial institution in terms of the Financial Institutions Act. Trumia is authorised to provide the Trumia Services.

2.2. Information about Trumia can be accessed by using the MFSA Financial Services Register. TheMFSA’s address and contact details are:

- Registered address: Malta Financial Services Authority, Triq l-Imdina, Zone 1, CentralBusiness District, Birkirkara, CBD 1010, Malta.

- Postal address: P.O. Box 81, Head Office, Marsa, Malta MTP 1001

- Phone: +356 2144 1155

2.3. Trumia’s contact details are as follows:

- Registered address: Quad Central, Q3, Level 3, Triq l-Esportaturi, Zone 1, CentralBusiness District, Birkirkara CBD 1040, Malta

- Business address: Quad Central, Q3, Level 3, Triq l-Esportaturi, Zone 1, Central BusinessDistrict, Birkirkara CBD 1040, Malta

- E-Mail: contactus@trumia.com

2.4. Trumia has passported the Trumia Services to the EEA under the freedom to provide services

3. Interpretation

Definitions

3.1. In these Terms and Conditions, the following definitions shall apply:

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Interpretation

3.2. Clause headings in this Agreement are for convenience only and are not relevant in theinterpretation of the Terms and Conditions.

3.3. In these Terms and Conditions, unless the context otherwise requires, any reference to the singular shall include the plural and vice versa, the use of the masculine pronoun shall include the feminine, the use of the neutral pronoun shall include the masculine or the feminine as the case may be and any reference to any statute, law or regulation having the force of law or any section thereof includes reference to any modification thereto or re-enactment of such statute, law or regulation having the force of law for the time being in force.

3.4. The English language version of the Agreement shall be the language constituting this Agreement for all purposes including dispute resolution. All communications between the User and Trumia shall be in English. Where any translation of this Agreement or parts thereof in another language are available, such translation is for informal purposes only and does not alter or take precedence over the provisions of this Agreement, and the provisions of this Agreement in the English language shall prevail.

3.5. The provision of the Trumia Services is governed by mandatory legal and regulatory provisions in force from time to time under applicable law, as well as by any specific conditions which may be agreed between Trumia and the User, both of which will prevail over this Agreement in the event of any conflict between them.

4. Charges and Fees

4.1. Trumia will charge Fees for the provision of the Services as set out in the Fee Schedule communicated to the Applicant during the onboarding process and as outlined in Appendix Ito these Terms and Conditions. The Fee Schedule and Appendix I to these Terms andConditions will provide a complete list of fees and charges which may be applicable to the Trumia Services.

4.2. By using the Trumia Services, the User agrees that any applicable fees and charges may be debited to the Account or otherwise agrees that any such applicable fees and charges shall be paid on demand.

4.3. Any charges and fees may include any applicable withholding tax, duties, value added tax or any other taxes which may arise in respect of any of the Trumia Services. Trumia will not provide prior notice of the imposition or variation in any applicable taxes arising in respect of any of the Trumia Services.

4.4. The User hereby agrees that any fees, charges or other amounts which are due and payable to Trumia under the Agreement may be directly debited or otherwise deducted from the funds available on the Account as and when they are due and payable at such intervals as may be required by Trumia.

5. Representations, Undertakings and Duties of the User

5.1. Upon accepting this Agreement and any amended version thereof, each of the Account Users and/or the User represents, and warrants on an ongoing basis, as applicable that:

(a) The Account User is duly authorised to represent the User and all corporate or other action has been taken to authorise the Account User to make use of the Trumia Services in the name of and for and on behalf of the User.

(b) The Applicant is duly authorised to provide all requested information, including KYCInformation, to Trumia at the account opening stage.(c) The User is duly registered, organised and validly existing under the applicable laws of its jurisdiction and any actions which are required for the acceptance of this Agreement and the performance of any obligations, transactions or other matters under this Agreement have all been duly authorised.

(d) The User is registered and incorporated within the European Union or a reputable jurisdiction with an equivalent regulatory framework where the establishment and use of the Account and use of the Trumia Services is allowed and by entering into this Agreement the User represents and warrants that opening of the Account and use of the Trumia Platform and the Trumia Services does not violate any applicable legislation in force.

(e) The User is acting in its own name and not on behalf of another person, unless otherwise notified to Trumia in writing and accepted by Trumia. Upon notification, Trumia reserves the right to suspend the Account or provision of the Trumia Services until the necessary procedures and checks have been carried out by Trumia.

(f) The User and/or the Account User as applicable, warrants and confirms that it is compliantwith all laws to which they are subject including, without limitation, all tax laws andregulations, exchange control requirements and registration requirements.

(g) Trumia is bound by the Applicable AML Laws and Trumia is legally bound to request, obtain and process KYC Information on the User and/or its officials, ultimate beneficial owners or other persons connected to the User in accordance with its internal policies. Each of theAccount Users and/or the Applicant hereby agree and warrant:- to provide the KYC Information which Trumia may request, including in order to onboard the User and open the Account as well as any other KYC Information which Trumia may require from time to time; and- any KYC Information provided are true, correct and complete.

(h) The User must duly inform Trumia if its officials, ultimate beneficial owners or other persons connected to it become a PEP or a close associate of a PEP and agrees that Trumia may be required to take request further KYC Information or take further action in respect of the Account and access to the Trumia Platform.

(i) All funds held in the Account or transferred to or from the Account, originate from legitimate sources or activities.

(j) The User must duly notify Trumia in writing of any change or dispute that may affect the Trumia Services.

(k) The User and each of the Account Users shall comply with all applicable laws and regulations, including the Applicable AML Laws and any other legislation on anti-money laundering and anti-terrorist financing and any orders issued by the relevant regulatory authorities.

(l) The User and each of the Account Users warrant that the use of the Trumia Services will be done in good faith, solely for legal purposes and in accordance with the provisions of these Terms and Conditions.

(m) The User and each of the Account Users shall not create or suffer to allow anyEncumbrance over the Account and shall not otherwise use the Account and/or any funds there in as security or as a guarantee in any manner whatsoever.

5.2. By using the Trumia Services, the User and each Account User undertakes that they:

(a) must take all steps and shall be responsible for ensuring that the Account password, username, any login credentials or other security information required to access or use the Account is kept safe to prevent unauthorised use of the Account.

(b) if they suspect that the details of the Account have been compromised in any way, the credentials and any login information will be changed as soon as possible.

(c) must inform Trumia as soon as possible and without any delay of any suspicion that theAccount has been compromised in any way or someone has accessed or the Account without their permission or if the debit or credit card with which the Account is linked is lost, stolen or otherwise may be subject to unauthorised use by another person.

(d) shall pay any amounts due and payable in terms of the Agreement, including any relevant bank charges or third-party fees as may be applicable as set out in the Fee Schedule.

6. Breach of the Agreement

6.1. The occurrence of any of the following events, plus those named elsewhere as such in this Agreement, shall constitute a breach of this Agreement:

(a) The User and/or any one of the Account Users fails to comply with these Terms and Conditions or with any obligation imposed by the Agreement.

(b) Trumia has reasonable grounds to believe that the User, or any one of the Account Users ,may be: i) using or obtaining or allowing someone else to use the Trumia Services illegally,(ii) acting fraudulently, (iii) behaving improperly, threateningly or in an abusive manner, (iv)being investigated for any reason (whether known to the User or otherwise) by any governmental department, agency or authority, (v) are found guilty or have pleaded guilty toa criminal charge (excluding any motoring offence), (vi) in breach of any representation, warranty or undertaking pursuant to these Terms and Conditions.

(c) The User and/or any one of the Account Users fails to respond, reply or otherwise acknowledge any reasonable attempts by Trumia to contact the User or the User fails to comply with any reasonable request made by the User in relation to any PaymentTransaction.

(d) The User and/or any one of the Account Users creates or suffer to allow any Encumbrance over the Account or otherwise uses the Account and/or any funds therein as security or asa guarantee in any manner whatsoever.

(e) The User is declared insolvent or commences a voluntary action or other procedure seeking or proposing an administration, liquidation, reorganisation, an arrangement or composition with creditors, a freeze or moratorium, or other similar relief with respect to the User or to its debts under any bankruptcy, insolvency, regulatory, supervisory or similar law, or the User seeks the appointment of a trustee in bankruptcy, receiver, liquidator, administrator or other similar official in relation to it or any part of the User’s undertakings or assets or the User takes any corporate action to authorise any of the foregoing and, in the case of a reorganisation, arrangement or composition, the User does not consent to such a proposal.

7. User Rights

7.1. Payment Orders

7.1.1. Trumia will consider that the User gave consent and authorised the execution of aPayment Transaction when the Payment Order is submitted over the Trumia Platform. The User provides this authorisation by filling in the required details when prompted on the Trumia Platform.

7.1.2. The User is responsible for ensuring that the correct details are entered whenever submitting any instructions to Trumia.

7.1.3. The User will be required to authenticate the Payment Order using multi-factor authentication in order to provide consent to execute a Payment Order in line with all regulatory requirements under applicable law. In the absence of such consent thePayment Order shall be considered unauthorised and the Payment Transaction shall not be executed.

7.1.4. Trumia will provide the User with the following information before the Payment Order is completed:

(a) all charges payable by the User in relation to the Payment Transaction; and

(b) where applicable, the actual or reference exchange rate to be applied to the PaymentTransaction.

7.1.5. The User may, at any time, request Trumia to provide the following information on an individual Payment Order:

(a) the maximum execution time it will take for the funds to be made available to thePayee; and

(b) a breakdown of the amounts of the fees and any charges payable by the User in relation to the Payment Transaction.

7.1.6. After the amount of a Payment Transaction is debited from the Account or following receipt of the Payment Order, Trumia will provide the User with the following information through the Payment Notification:

a) the Transaction Unique Reference Number and information relating to the Payee;

b) the amount of the Payment Transaction in the currency in which the Account was debited or in the currency used for the Payment Order;

c) all charges payable or paid by the User in connection with the Payment Transaction and where applicable a breakdown of such charges payable by the Payer;

d) where applicable, the actual or reference exchange rate to be applied to the Payment Transaction and the amount of the Payment Transaction after that currency conversion; and

e) the debit value date or the date of receipt of the Payment Order.

7.1.7. The information in the Payment Notification shall be sent without undue delay via the Trumia Platform to the User.

7.2. Receipt of Payment Orders and Execution of Payment Transactions

7.2.1. Payment Transactions are requested and authorised by the User by selecting the required Trumia Service over the Trumia Platform and providing the required information when prompted. Unless Trumia is prohibited by law from doing so or otherwise may refuse to execute the Payment Transaction in line with these Terms and Conditions or with its obligations at law, Trumia will execute the Payment Transactions authorised by the User.

7.2.2. Trumia may delay, decline or reverse, refuse, freeze, block, any Payment Order, or suspend the use or freeze the Account, whereupon Trumia will not be liable to the User in such circumstances for any losses howsoever caused. Trumia shall not be required to inform the User of such actions.

7.2.3. When submitting a payment order, the User may withdraw consent for a Payment Order at any time before it has been received by the Payee’s payment service provider. Once a Payment Order is authorised by the User and it is received by us, it cannot be revoked unless the instructions relate to a Payment Transaction for execution on a future date, in which case it may be revoked prior to the date of its execution.

7.2.4. If the User does not have sufficient funds in the Account, including funds to pay any applicable fees or charges, Trumia will not execute the Payment Order in which case, theUser will be informed of such refusal and whenever possible, the reasons for such refusal and the procedure for correcting any factual mistakes that led to the refusal, unless Trumia is prohibited to do so by law.

7.3. Incoming Payments

7.3.1. Trumia may reject and return incoming Payment Transaction if it has reasonable grounds to suspect that the Payment Transaction is fraudulent, suspicious or connected with illicit or unlawful purposes or is otherwise considered to be a Prohibited Transaction for the purposes of these Terms and Conditions, in breach of any sanctions as may be issued by relevant authorities from time to time or if Trumia has received instructions from any regulatory authority or if the inward Payment Transaction is otherwise flagged by a correspondent bank or other payment service provider. In particular, Trumia may reject and return incoming Payment Transactions in cases where:

a) the details in the Payment Order provided by the Payer to its payment service provider differ from the details of the Account; and

b) the incoming Payment Transaction originates from a payment account or Payee which are considered to be in Trumia’s sole discretion to be a non reputable, risky or otherwise unacceptable jurisdiction (a “ProhibitedJurisdiction”). A list of Prohibited Jurisdictions is set out on the Trumia website.

7.3.2. For avoidance of doubt, it is the sole responsibility of the Payer to provide the correct information in respect of the Account in order for Trumia to accept any inward payments into the Account.

7.3.3. In its sole discretion, or if so requested by a correspondent bank Trumia may request additional details and if required, documentation in respect of any inward PaymentTransactions made to the Account. In the event that this request is not complied with within two (2) Business Days or if Trumia is not satisfied with the information provided, the funds will not be credited to the Account and will be returned to the Payer.

7.3.4. Trumia will not be liable for otherwise responsible for any direct, indirect or consequential loss as a result of a rejected inward payment and the return of funds from an in ward payment may be subject to fees as set out in the Fee Schedule and/or the Appendix I to these Terms and Conditions.

7.3.5. Incoming payment are subject to the execution times as set out in these Terms andConditions, provided that these shall not apply to inward Payment Transaction which need to be verified or investigated further as contemplated in this Clause 7.3.

7.3.6. Trumia accepts no responsibility for any delay attributable to any verification or investigation procedures in accordance with this Clause 7.3, whether such procedures are carried out by Trumia or by any correspondent bank or other payment service provider.

7.4. Blocking the Account and Refusal to Execute

7.4.1. Trumia may refuse to execute a Payment Transaction if it has reasonable grounds to suspect that the Payment Transaction is fraudulent, suspicious or connected with illicit or unlawful purposes or is otherwise considered to be a Prohibited Transaction in line with Trumia’s internal policies and procedures and Clause 16 of these Terms and Conditions, for the purposes of these Terms and Conditions, or are in breach of any sanctions as maybe issued by relevant authorities from time to time or if Trumia has received instructions from any regulatory authority.

7.4.2. In certain circumstances, including but not limited to, in the event theUser undertakes a Prohibited Transaction, Trumia may choose to or be obliged to freeze or block Payment Transactions, the Account or access to the Trumia Platform or any of them, to comply with its regulatory obligations or any sanctions which may be issued by any authority, whether such sanctions are directly binding in Malta or not.

7.4.3. Freezing or blocking can arise as a result of the account monitoring that Trumia conducts or where the name of Payee matches a name on a relevant government list of prohibited, sanctioned persons or where the Payment Transaction is being sent to a country that has been subjected to a relevant government asset control or sanctions list or where thePayment Transaction is being sent to or originates from a Prohibited Country as set out on the Trumia Platform. If this occurs, Trumia and its representatives are not liable to theUser for any resulting losses whatsoever and the User agrees to indemnify Trumia and its representatives to the extent that Trumia and its representatives incur any losses in connection with the freezing or blocking of the User’s account.

7.5. Segregation of funds and safeguarding

7.5.1. Funds received from the User will be safeguarded in accordance with applicableregulation in force from time to time.

7.5.2. Please refer to the FAQ for more information about how funds are segregated.7.6. Liability for Payment Transactions

7.6.1. Trumia is not liable for funds being sent to the wrong account where this is due to theUser providing and/or confirming incorrect payment details. The User is solely responsible for ensuring that the account number, sort code, IBAN and/or BIC/SWIFTare correct. If the User transferred funds to the wrong account, the User may request that Trumia assists in reclaiming the funds. However, Trumia may charge an administration fee as detailed in the Fee Schedule and cannot guarantee that the reclaim efforts will be successful.

7.6.2. In the event that the User discovers an unauthorised Payment Transaction the User must notify Trumia without delay and in any event no later than thirteen (13) months from the date of that Payment Transaction in order to be entitled to redress.

7.6.3. Where the User believes that Trumia may have failed to perform or incorrectly executed a Payment Transaction, the User must notify Trumia without delay, on becoming aware of any such transaction giving rise to a claim, and in any event no later than one month from the date of debit of that Payment Transaction. Where the User is able to demonstrate to Trumia’s reasonable satisfaction (including, but not limited to, providing such documentation as Trumia may reasonably require from the User) that the Payment Transaction was incorrectly executed or unauthorised, Trumia will investigate such claims and where Trumia has failed to perform or incorrectly performed such PaymentTransaction, Trumia will without undue delay make good and correct the error.

8. Trumia Platform

8.1. The Trumia Platform is an online platform accessible through the website or through our mobile app which is accessible through a smartphone or other electronic device.

8.2. The Trumia Platform allows the User and the Account Users acting on its behalf to access theTrumia Services, including:
8.2.1. send and receive money from other accounts and top up the Account;

8.2.2. change money from one currency to another in accordance with the rates of exchange made available on the Trumia Platform at a given time; and

8.2.3. view the transaction history and information about the Account and manage theAccount.

8.3. The Account Administrator may assign different access permissions and payment limits toeach of the Account Operators, in which case use of the Trumia Platform by the AccountOperator shall be limited accordingly. The Account Administrator is solely responsible for ensuring that the access permissions and payment limits notified to Trumia are correct and up to-date.

8.4. Entering an incorrect passcode consecutively for multiple times may automatically terminate the connection and block access to the Trumia Platform.8.5. In the event that Trumia becomes aware of any unauthorised use of the Trumia Platform or if Trumia suspects that the password has been compromised and/or misappropriated by a third party, Trumia shall communicate with the User using such secure procedure/s as Trumia shall consider necessary and/or appropriate in the circumstances. This may include contacting theUser on any contact number or email address indicated during the account opening process.

8.6. The Account User is responsible for ensuring that he or she has properly logged out of the Trumia Platform.

8.7. Without prejudice to anything else in these Terms and Conditions, Trumia shall not, in any event, be liable for:

8.7.1. any transaction effected on the Trumia Platform by any unauthorised third party, or for any unauthorised access or unauthorised instructions;

8.7.2. losses resulting from the use of the Trumia Platform in cases of unforeseeable circumstances beyond the reasonable control of Trumia, or force majeure;

8.7.3. any operational failures preventing the use of the Trumia Platform, interruptions preventing the Account User from accessing the Trumia Platform, and/or

8.7.4. any liability arising from the use of the internet as a means of communication, and/or any damage or loss caused by matters relating to the Account User ’s own smartphone or other electronic device, including without limitation any losses incurred by the User due to any cyber-attacks, hacking, viruses, malware or other malicious software or program which may affect the Account User’s smartphone or electronic device.

8.8. Trumia may refuse to carry out an instruction or immediately terminate the execution of an instruction or reverse any instruction made through the Trumia Platform, in whole or in part, if it reasonably believes that the instruction is invalid or has not come from a person duly authorised to act in the name of and for and on behalf of the User or if it believes that the User and/or the Account User has not acted in accordance with these Terms and Conditions or for any other justifiable reason. The User shall hold Trumia harmless from any liability for any loss as a result of Trumia’s refusal in these circumstances and shall immediately indemnify Trumia for any loss it may suffer as a result of any such circumstance/s.

8.9. Trumia ensures that all transactions effected through the Trumia Platform are carried out as soon as is reasonably practicable. However, some transactions may take time to process, particularly if the service is suspended, such as for maintenance reasons. Trumia shall not be liable for any damages incurred or suffered by the User as a result of any such delay. The User accepts that once a transaction has been processed, it cannot be stopped, modified or delayed.

8.10. Once a request or instruction has been accepted and/or a transaction has been successfully processed, full transaction details will be made available via the online statement.

8.11. Trumia is under no obligation to provide a physical receipt or other written confirmation in connection with any transaction. Receipts provided for successful transactions will be virtual and accessible via the Trumia Platform.

8.12. Should a request or instruction for a transaction be incomplete or erroneous, any loss arising as a result thereof will be borne by the User.

8.13. Balances and available funds reported on the Trumia Platform are approximate real time balances rather than settled balances. This means that the balance may not be taking into account pending debits and credits. Once Trumia receives information on any pending debits and credits, the information will be made available on the Trumia Platform.

9. Opening and Using an Account

9.1. The Applicant shall commence the application process through our website www.trumia.com orby downloading the mobile application from the relevant digital application store. The Applicant can apply for an Account by filling in their details as prompted by the Trumia platform. In line with its legal obligations, Trumia will request KYC Information from the Applicant.

9.2. By completing the application, the Applicant requests Trumia to open an Account (or more than one Account) based on the selections chosen during the application process.

9.3. Trumia may refuse to set-up an Account for any reason without having to justify its decision to the Applicant. Such a refusal shall not result in the payment of any damages.

9.4. The Account/s is/are an electronic money account/s and allows the User to hold, send or receive electronic money in the currencies that Trumia supports as selected by the User from the currencies that Trumia makes available from time to time.

9.5. The Account/s may be subject to limits related to uploads, payments and other limits, depending on the User’s country of incorporation, regulatory requirements, any pending verification queries related to the Account and other factors used by us to determine such limits from time to time as notified by Trumia over the Trumia Platform.

9.6. Trumia shall apply specific and industry-based daily limits to all accounts. Payment limits can be modified by the Account Administrator on the Trumia Platform. Any increase in daily limits carry an inherent exposure to the risk of suffering material financial losses in the case of a fraud orphishing attacks on an Account. Therefore, the Account Administrator, for and on behalf of theUser assumes full responsibility when increasing the standard limits on an Account.

9.7. Funds can be added to an Account by bank transfer. To successfully add money by bank transfer(that is, through Payment Initiation services), the bank account details stated on the Trumia Platform must be filled in and the information provided must be correct and all information requested must be provided.

9.8. Fees apply when utilising the Account. These fees are made available on our Fee Schedule and in Appendix I to these Terms and Conditions. If the User makes use of bank account that is in one currency to add money to an Account in another currency, fees may also be applicable.

9.9. Subject to the other terms of this Agreement, Trumia will use due and reasonable skill, care and diligence to execute the Payment Transactions and credit funds to the Payee’s payment service provider with the following execution times after Trumia has received valid Payment Order on a Business Day, which may be:

a) as soon as Trumia’s partners and the payment networks available to Trumia permit; or

b) as Trumia may otherwise notify the User (which may be within hours of Trumia receiving a valid instruction from the User).

9.10. Provided that the Payment Order is submitted in line with Clause 7.2 above, execution times of Payment Transactions shall be as provided on www.trumia.com.

9.11. Payments made in Euro to Payees in the European Economic Area (EEA) are made available to the Payee’s payment service provider no later than the end of the following Business Day after Trumia receives a valid Payment Order in accordance with the terms of these Terms andConditions.

9.12. All other payments made in other EEA currencies to beneficiaries in the EEA are made available to the Payee’s payment service provider no later than the end of the fourth Business Day after Trumia receives a valid Payment Order in accordance with the terms of this Agreement.

9.13. The above execution times do not apply to Payment Transactions executed in other currencies.

9.14. Trumia accepts no responsibility for any delay in onward payment attributable to the late arrival of funds from the User. Trumia accepts no responsibility for any delay in onward payment attributable to a delay in instructions or consent from the User. Trumia will not be under any obligation to issue e-money in Account or to remit funds, until the User has paid for the PaymentTransaction in full or the Account has enough funds for the purposes of the Payment Transaction.

9.15. The User is liable for losses suffered and costs incurred by Trumia or the User as a result of theUser making payment into any account that is not listed on the Payment Order.

9.16. Trumia shall not be liable for any fees or commissions charged by any intermediary bank (including the User’s bank) when any funds are transferred to any of Trumia’s bank accounts. All such applicable fees or commissions shall be borne by the User.

10. P2P Payments

10.1. Users can carry out P2P Payments by following the on-screen instructions on the Trumia Platform.

10.2. The Account User is required to ensure that the correct details are included. Any errors may result in delays or an unsuccessful transfer and Trumia will not be held liable for any losses incurred as a result of such error. In circumstances where there is the non-execution or defective execution of a P2P Payment, Trumia will make reasonable efforts to recover the funds involved. Trumia reserves the right to charge the User for recovering the funds and to pass on any charges incurred by Trumia to the User.

10.3. The request to enter into a P2P Payment will be deemed to have been received by Trumia once the Account User has confirmed the required details.

10. P2P Payments

10.1. Users can carry out P2P Payments by following the on-screen instructions on the Trumia Platform.

10.2. The User is required to ensure that the correct details are included. Any errors may result in delays or an unsuccessful transfer and Trumia will not be held liable for any losses incurred as a result of such error. In circumstances where there is the non-execution or defective execution of a P2P Payment, Trumia will make reasonable efforts to recover the funds involved. Trumia reserves the right to charge the User for recovering the funds and to pass on any charges incurred by Trumia to the User.

10.3. The request to enter into a P2P Payment will be deemed to have been received by Trumia once the User has confirmed the required details.

11. Exchange Rates

11.1. If the User uses the Account to make or receive Payment Transactions in different currencies, the current reference exchange rate together with any applicable charges will apply. A list of supported currencies is made available on the Trumia Platform.

11.2. The reference exchange rate is linked to exchange rates published by our banking partners and Trumia applies a margin over such rates.

11.3. The exchange rates vary and may change at any time and any such change will take effect immediately and without notice to the User, provided that the change in the rates are based on the reference exchange rate. Changes in exchange rates which are more favourable to theUser may be applied without notice. Changes in the exchange rate used in payment transactions shall be implemented and calculated in a neutral manner that does not discriminate against the User.

11.4. Where currency conversion has to be effected for a Payment Transaction, the applicable exchange rate (taking into account the above) Trumia will convert the amount of the PaymentTransaction into the relevant currency and the User will be requested to confirm the exchange rate and any applicable charges, if the User does not provide such confirmation the PaymentTransaction will not be carried out by Trumia.

11.5. The Trumia Platform allows for Accounts to be set up using a dual approval system. In such cases, an Account Operator may submit a request to Trumia for a Payment Transaction to be effected in a different currency and such request shall only be processed by Trumia if thePayment Transaction (including the exchange rate and applicable charges) are confirmed by the Account Administrator or by another Account Operator who has been authorised by theAccount Administrator to provide such confirmations. It is expressly agreed that exchange rates fluctuate and Trumia will not be responsible in any way for any losses as a result of delays in providing the required confirmation of Payment Transactions.

11.6. If you receive money in a different currency than the currency of your Account, then depending on how the funds arrive in the Account, either:

11.6.1. Trumia will convert the funds into the relevant currency and credit the Account. The reference exchange rate and any applicable charges as set out in the Fee Schedule will be applied to such conversion; or

11.6.2. funds will be converted by our banking partner, in which case Trumia has no control over the charges that will be applied by the bank.

11.7. Payment Transactions which are made in currencies not supported by Trumia will not be effected without any liability attributable to Trumia. Trumia is not responsible in any way if theUser loses any money as a result of currency conversions or exchange rates or currency conversion fees which may be applied by third parties.

12. Funds held in the Account

12.1. All funds held in the Account do not constitute a deposit and no interest shall accrue on such funds. Trumia does not grant interest or any other benefit related to the length of time during which the User holds funds in the Account. Funds should not be retained in the Account with no activity for a period of more than ninety (90) days.

12.2. The Depositor Compensation Scheme does not apply to funds held in the Account.

12.3. The User may print statements and reports from the Trumia Platform and Trumia will provide the User with statements, in English by email upon request. In exceptional circumstances, Trumia will provide the User with statements via an alternative medium, but Trumia reserves the right to charge the User per statement provided in another medium, as outlined in the FeeSchedule. Trumia may choose to waive this charge at its own discretion.

13. Suspension of Trumia Services and Interruptions

13.1. Trumia does not guarantee continuous, uninterrupted access to the Trumia Platform and/or the Trumia Services.

13.2. Trumia may occasionally interrupt access to all or part of the Trumia Services if necessary fora legitimate purpose, including for the following reasons:

13.2.1. in order to carry out repairs, maintenance or improvement;

13.2.2. in the event of a suspected hacking attempt, embezzlement or any other security risk; and

13.2.3. upon request or instructions from competent, qualified individuals or authorities.

13.3. It may be necessary from time to time to suspend the Trumia Services and access to the Account for routine, non-routine or emergency maintenance where Trumia consider it necessary to do so. When interruption of the Trumia Services is planned, for instance in order to carry out routine maintenance and update of the Trumia Platform, Trumia shall in so far as is possible, inform the User of such planned maintenance at least twenty-four (24) hours in advance via e-mail or via a notification on the Trumia Platform.

13.4. Trumia may also suspend or interrupt any Trumia Service without notice if necessary or advisable to do so, for example if there is a suspected breach of security or for urgent maintenance and update reasons. In the event of such a suspension being necessary, Trumia will in so far as is possible, provide the User with a reasonable period of notice prior to the suspension or interruption by means of a notification on the Trumia Platform and/or by providing the appropriate notices on www.trumia.com and/or other means Trumia deems as suitable.

13.5. Trumia may also suspend any Trumia Service or limit access to all or any of the Trumia Services in the event that there is no activity in the Account for a period of more than ninety (90) days. In such a case, Trumia may need to carry out verification procedures or other checks to ensure that there are no security risks.

13.6. Trumia shall not be liable for any damages incurred or suffered by the User as a result of any delay due to such suspensions of or interruptions to the Trumia Services.

14. Non-use of the Account

14.1. In the event that the User does not make use of the Account for six months, the Account shall be considered to be dormant and will be subject to a dormant account fee as set out in the FeeSchedule.

14.2. Once the Account is marked as dormant, no Payment Transactions can be carried out and theUser will be required to reactivate the Account by contacting Trumia and carrying out the account opening process again and/or by following any other processes which Trumia may require, from time to time.

14.3. For dormant Accounts which still hold a balance, Trumia will attempt to contact the User, as a minimum quarterly, using the contact details provided by the User when opening the Account. If no reply is received, Trumia may, if applicable, send any remaining balance in the Account to the bank or payment account nominated by the User at account opening stage. In the case where Trumia does not hold details of other bank or payment accounts, Trumia will continue attempting to contact a User in accordance with this clause. The User may also contact Trumia at any time to provide instructions as to where such funds may be transferred and if such instructions are reasonable, Trumia will transfer the funds as instructed.

15. Closure of the Account

15.1. The User may close the Account in writing through the Trumia Platform.

15.2. Upon receipt of the request, Trumia will endeavour to complete the account closure within a reasonable timeframe.

15.3. The User must have a nil balance and not have any disputes which are still pending at the time of the closure by withdrawing any balance on the Account prior to instructing the closure. Should there be any negative balances on the Account due to outstanding disputes or charges, these will need to be removed or resolved before the Account can be closed. Trumia reserves the right to carry out any necessary money laundering, terrorism financing, fraud or other illegal activity checks before authorising any redemption, transfer or withdrawal of funds from the Account.

15.4. After the closure of the Account, the User will not be able to access the Account. The User will need to complete the account opening formalities once again to be able to use the Trumia Services via the Trumia Platform. In the event that the User does not have any other Account with Trumia, the relationship with Trumia will be terminated and in the event that the User wishes to open an account again, they will be required to submit an application on the Trumia website and if necessary, re-submit all required KYC Information.

15.5. If the User wants to access the transaction history after the closure of the Account, the User will need to contact Trumia and request the information. Trumia may charge for the provision of this information, at its discretion.

15.6. To the extent allowed at law, Trumia shall have the absolute right to set-off, transfer, or apply sums held in the Account in or towards satisfaction of all or any liabilities and fees owed to Trumia that have not been paid or satisfied when due.

15.7. Upon the closure of the Account, or termination of this Agreement as provided for in these Terms and Conditions, Trumia shall provide the User free of charge, the Payment Notification, covering a period of at least thirteen (13) months.

15.8. If Trumia terminates the Agreement as set out in these Terms and Conditions, and Account still holds a balance at time of account closure, Trumia will ask the User to redeem the funds or transfer the funds within a reasonable period, during which the Account will be accessible for the purpose of redeeming or transferring the remaining balance only. If the User does not redeem or transfer the funds within the set time period, the User may contact Trumia and request that any remaining funds are sent in a manner which Trumia considers to be acceptable.

16. Prohibited Transactions

16.1. The User is strictly prohibited from using the Trumia Services for the sale, supply or any other action in connection with any unlawful, illicit or dangerous goods or services (“Prohibited Transactions”) including without limitation:

(a) drugs and drug paraphernalia;

(b) weapons (including without limitation, knives, guns, firearms or ammunition)

(c) material which incites violence, hatred, racism or which is considered obscene,

(d) counterfeit products or any products, goods, items or services which infringe on third party intellectual property rights;

(e) unlicensed or illegal lotteries or gambling services (including without limitation the use of or participation in illegal gambling houses),

(f) unregistered charity services, items which encourage or facilitate illegal activities;

(g) prepaid debit cards or other stored value cards that are not associated with a particular merchant and are not limited to purchases of particular products or services,

(h) multi-level marketing, pyramid selling or ponzi schemes, matrix programmes or other“get rich quick” schemes or high yield investment programmes; or

(i) any other prohibited sector or transaction which may be set out in the our Websiteand/or Trumia Platform from time to time.

17. Right of Set-Off

17.1. To the maximum extent at law, Trumia shall have the absolute right to set-off, transfer, or apply sums held in the Account(s) in or towards satisfaction of all or any fees, liabilities, compensation or other amounts which are due and payable to Trumia.

18. Limitation of liability

18.1. Except as otherwise provided in the Agreement, Trumia shall not be liable to the User for any loss, expense, damage, delay, costs and/or compensation (whether direct, indirect or consequential) which may be suffered or incurred by the User arising from or in any way connected with any delay, failure or error in making any payment pursuant to a Payment Order where such delay failure or error is caused directly or indirectly by:

a) failure or error or essential maintenance or critical change or, repairs or alteration of any computer system or communications system or transmission link of any kind under the control of a third party or Trumia; and/or

b) the acts or omissions of any third party.

18.2. To the maximum extent possible at law, Trumia gives no warranties or representations whatsoever with specific regard to the exchange rates it provides for any Payment Transaction and is under no obligation to provide the best or most competitive exchange rates available.

18.3. To the maximum extent possible at law, Trumia’s maximum liability hereunder, including but not limited to, with respect to the Trumia Services will be limited to the amount of the direct loss resulting from any breach of Trumia’s obligations under the Agreement and shall not extend to any other losses the User may suffer such as loss of reputation loss of goodwill, consequential loss etc.

18.4. Trumia is not liable for any loss or for any failure to fulfil our duties under the Agreement if such loss or damage if caused, directly or indirectly, by force majeure such as the act of God, any act by any Government or other competent authority, civil commotion, an act of terrorism, rebellion, flood, storm, tempest, fire, the failure, malfunction or unavailability of utilities, telecommunications, data communications and computer systems and services, war, civil unrest, strikes, lock-outs or other industrial action or trade disputes or other cause whether similar or not, outside our reasonable control and which makes it practically impossible for us to comply with our obligations under the Agreement. In such event, Trumia will however use all reasonable efforts to minimize the effects or to resume operations as soon as reasonably possible, and Trumia will inform the User that such event has occurred as soon as reasonably possible.

18.5. Trumia will not be liable for any losses incurred arising from compliance with legal and regulatory requirements.

18.6. Trumia will not be liable to the User or any other person for any loss or damage suffered in connection with the Trumia Services, except as otherwise stated in the Agreement or required bylaw, or if and to the extent that such loss or damage results from fraud, gross negligence or the failure to perform Trumia’s obligations under the Agreement.

19. Indemnity

19.1. The User agrees to keep Trumia indemnified against:

a) all actions, proceedings, costs, loss and damage of any kind which Trumia may suffer as a result of it acting on any of the User’s instructions in accordance with the Agreement, or as a result of any failure on the User’s part to comply with the duties stipulated there in;

b) losses, damages, judgments, tax assessments, penalties, and/or interest arising out of any claim, action, audit, investigation, inquiry, or other proceeding instituted by a person or entity that arises out of or relates to: (a) any actual or alleged breach by the User of its representations, warranties, or obligations under the Agreement; (b) any third-party right, including without limitation any right of privacy, publicity rights or intellectual property rights; (c) the User’s improper use of the Trumia Services; (d) the User’s violation of any law, rule or regulation of any country; and/or (e) any other party’s use of the Trumia Services

c) all losses and damages which arise as a result of use of a computer or any other equipment which has any virus or any other destructive or disruptive components; and

d) any losses in connection with suspending, blocking or terminating the User’s account in accordance with these Terms and Conditions.

19.2. This Clause 19 shall survive the termination of the Agreement for any reason.

20. Data protection

20.1. Trumia collects and processes personal data in accordance with its Data Privacy Notice (refer towww.trumia.com). The Data Privacy Notice may also be obtained by contacting Trumia’s DataProtection Officer on dpo@trumia.com.

20.2. The provision of information to the User about the processing of personal data and the processing of such personal data and any other processing of personal data for the purposes of the Terms shall be carried out in accordance with the above mentioned Data Privacy Notice, the DataProtection Act (Cap. 586 of the Laws of Malta), Regulation (EC) No 45/2001 of the EuropeanParliament and of the Council of 18 December 2000 on the protection of individuals with regard to the processing of personal data by the Community institutions and bodies and on the free movement of such data, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR)and any applicable legislation.

20.3. As a financial institution, Trumia and its officers are bound by confidentiality and professional secrecy as per the applicable legal framework. Trumia may be required to share confidential information on the User from time to time. In all cases, Trumia shall operate in a manner that is conducive to the User’s privacy and shall only share confidential information in line with applicable legislation and the Data Privacy Notice.

21. Intellectual Property

21.1. The Trumia Services, including the content of the Trumia Platform, the website, text, graphics, logos, and images, as well as all other copyrights, trademarks, logos, and product and service names are owned exclusively by Trumia one of the companies in our corporate group or an authorised licensor (the “Intellectual Property”). The User is authorised solely to view and retain a copy of the pages of the website or any other material for its own personal, non-commercial use.

21.2. The User shall not (i) remove or alter any author, trademark, logo or other proprietary notice or legend displayed on the website or Trumia Platform or (ii) infringe our or any other third party’s copyright, patent, trademark, trade secret or other intellectual property rights, or rights of publicity or privacy.

21.3. Any use of software as part of using the Trumia Services grants the User a licence that is personal only to the User, and which is limited, non-exclusive, revocable, non-transferable and without the right to sub-licence, for the duration of the Agreement.

21.4. The User is permitted to use any software provided by Trumia for use solely for the purposes of availing of the Trumia Services pursuant to these Terms and Conditions and for no other purpose whatsoever. Nothing in these Terms and Conditions shall be interpreted as granting the User a licence to use the Intellectual Property for any other purposes.

21.5. If a User sends to Trumia any suggestions, feedback or input related to the Trumia Services, Trumia (or its group entities) will own all right, title and interest in and to this, even if designated as confidential. The User assigns to Trumia all right, title and interest in and to this input.

22. Changes in the Agreement

22.1. Any changes to this Agreement shall be sent to the User via the Trumia Platform together with acopy of the updated version of the Agreement. A description of the changes and an updatedversion of this Agreement will be sent to User at least two (2) months before the date on whichthe updated Agreement will be come into force. The date on which the updated Agreement shallapply shall be included in this notification.

22.2. Unless the User notifies Trumia of their objection to the updated Agreement before the date ofthe proposed entry into force of the updated Agreement, the User shall be deemed to haveaccepted the updated Agreement which will thereafter apply.

22.3. In the event that the User does not agree with the proposed changes to the Terms and Conditions, they may terminate the Agreement free of charge and with effect at any time until the date when the changes would have applied.

22.4. Termination

Termination by the User

22.5. The User may terminate this Agreement and close the Account at any time by providing written notice of one (1) month prior to such termination by sending a message through the Trumia platform.

22.6. There are no charges or fees to close the Account except where the Account has been open for less than six (6) months, however the User will be required to pay any fees or charges which are standing to the Account in line with the Fee Schedule. Any subscription charges which have been paid in advance shall be reimbursed proportionately.

22.7. If the User’s account has been suspended or temporarily restricted, the Account shall not be closed until Trumia concludes any outstanding issues with the Account.

Termination by Trumia

22.8. Trumia may terminate this Agreement and close the Account at any time by providing written notice of two (2) months prior to such termination. Trumia will provide such notice to the User in a durable medium via the Trumia Platform or via email except as otherwise provided in this agreement.

22.9. On termination of this Agreement for whatever reason, Trumia shall provide the User free of charge the latest available yearly statement and an interim statement covering the period of the latest date on this yearly statement until the date of termination in a durable medium via the Trumia Platform.

23. Governing law and Jurisdiction

23.1. This Agreement, including any non-contractual obligations thereunder, shall be governed by and construed in accordance with Maltese law.

23.2. The Maltese Courts have exclusive jurisdiction to settle any disputes in connection with this Agreement, and the User accordingly submits to the exclusive jurisdiction of such Courts.

24. Severability

24.1. Each of the clauses and paragraphs of these terms operates separately. If any court or relevant authority decides that any of them are unlawful and/or unenforceable, the remaining clauses and paragraphs will remain in full force and effect. Moreover, if any unlawful and/or unenforceable clause or paragraph would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the Clause or paragraph will continue in effect.

25. Complaints

25.1. The Parties will use their reasonable efforts to resolve any disputes arising hereunder without formal litigation.

25.2. Any claim or dispute arising under these Terms and Conditions or as a result of the provision of the Trumia Services should, in the first instance, be referred by the User to Trumia in writing via the Trumia Platform or via e-mail to complaints@trumia.com. Further details on how to submit a complaint can be found in our Complaints Handling Procedure found on our Website.

25.3. Trumia will do its best to resolve the complaint as soon as possible and send the User a final response by email within 15 days of receiving the complaint. If, in exceptional circumstances, for reasons beyond Trumia’s control, Trumia needs more time to respond, Trumia will send the User, a holding reply within 15 days of receiving the clear and correctly submitted complaint to let the User know when the User will receive Trumia’s final response (which will be no later than 35 days from the date on which Trumia first received the complaint).

25.4. Trumia will use its best endeavour to take the necessary steps to prevent a recurrence.

25.5. If the User does not receive Trumia’s final response on time or the User is unhappy with Trumia’s final response, the User may submit its complaint to the Central Bank of Malta atManager, Regulation and Oversight Office, Central Bank of Malta, Castille Place, Valletta, VLT1060 Malta or via email on: regulation@centralbankmalta.org.

26. Communication and Documentation

26.1. The preferred means of communication between Trumia and the Users is via the Trumia Platform.Where applicable and as outlined in this agreement, communication may also take place via email. The User acknowledges that the risk that any such communication by email may be intercepted, monitored, amended or interfered by third parties. Trumia Ltd will not be held liable by the User or by any third party in the event of such occurrence.

26.2. Trumia considers communications made by the User via the Platform as valid forms of proof that the message is originating from the User without the need to further verify the identity of the User.

26.3. Soft copies of all Payment Orders and Payment Transactions saved on the Trumia Platform have the same probative value as a hand signed paper copy, both in terms of their content and the date and time they were produced and/or received.

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Trumia Limited (C96757) is an authorised Payment Services Provider and Electronic Money Institution, licensed by the MaltaFinancial Services Authority in terms of Article 5 of the Financial Institutions Act, 1994 (Chapter 367 of the Laws of Malta).

*Note: These Fees are exclusive of any third-party fees