1.GENERAL

1.1 These Terms of Use constitute a legally binding agreement made between you, whether personally or on behalf of an entity (“you”) and Sticpay(“we,” “us” or “our”),concerning your access to and use of the www.sticpay.com website as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively, the “Site”).

1.2 You agree that by accessing the Site, you have read, understood, and agree to be bound by all these Terms of Use. If you do not agree with all these Terms of Use, then you are expressly prohibited from using the Site and you must discontinue use immediately.

1.3 Supplemental Terms of Use or documents that may be posted on the Site from time to time are hereby expressly incorporated herein by reference. We reserve the right, in our sole discretion, to make changes or modifications to these Terms of Use at any time and for any reason.

1.4 We will notify you of any changes by sending an e-mail to the primary e-mail address registered with your Account or by posting a notice of the changes on our Website with a link to the amended Terms of Use. If the proposed changes will affect your rights, we will provide you with thirty (30) days’ notice before implementing them. However, any changes made to these Terms of Use that are favourable to you or that do not affect your rights will come into effect immediately.

1.5 It is your responsibility to periodically review these Terms of Use to stay informed of updates. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised Terms of Use by your continued use of the Site after the date such revised Terms of Use are posted.

1.6 If you disagree with the changes implemented in the Terms of Use, you have the right to terminate and close your Account immediately. You need to notify us that you do not agree to the changes. This will constitute notice that you wish to terminate your agreement with us, and your Account will be immediately closed upon receipt of your notice to terminate. Any funds in your Account will be returned to you using such method as notified by you (subject to the normal applicable Fees).

1.7 The information provided on the Site is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject us to any registration requirement within such jurisdiction or country.

1.8 Accordingly, those persons who choose to access the Site from other locations do soon their own initiative and are solely responsible for compliance with local laws, if and to the extent local laws are applicable.

1.9 Where our Site contains links to other Sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.

1.10 We do not guarantee that our Site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our Site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

2.REGISTERING FOR AN ACCOUNT

2.1 In order to open a Sticpay Account, you need to be at least 18 years old.

2.2 You must not be a resident of any country where we do not provide services. A list of non-serviced countries can be found here. We reserve the right to amend this list from time to time. Any changes made will come into effect immediately and without notice.

2.3 You may open a Sticpay Account provided it is legal to do so in your country of residence. By opening a Sticpay Account you represent and warrant to us that your opening of a Sticpay Account does not violate any laws or regulations applicable to you. You shall pay us the amount of any losses we incur in connection with your breach of this section.

2.4 You must create an Account by registering your details according to the instructions found on the Sign-Up page on our Site.

2.5 As part of the sign-up process you must agree to these Terms of Use and our Privacy Policy.

2.6 All information provided when registering an account and at any time thereafter must be correct and truthful. You represent and warrant that you will maintain the accuracy of such information and promptly update such registration information, as necessary. If you do not provide such information or fail to cooperate with us, we reserve the right to suspend or close your account.

2.7 You must provide us with the necessary documentation and pass all our verification checks.

3.USE OF YOUR STICPAY ACCOUNT

3.1 Your Sticpay Account is an electronic money account which enables you to send and receive electronic payments.

3.2 Electronic money accounts are not bank accounts.

3.3 The Sticpay Account registered belongs only to the natural person or legal entity that registered it. You cannot transfer your Account to any third parties, and you cannot assignor grant any legal or equitable interests over your Sticpay Account to any other party.

3.4 All of your transactional records (deposits, withdrawals, payments sent and received) can be found in the Transfer History section in your Account. Each transaction has a unique transaction ID. You should quote this transaction ID when communicating with us about a particular transaction. You should check your Sticpay Account balance and transaction history regularly. You should report any irregularities or clarify any questions you have as soon as possible by contacting Support Team.

3.5 We reserve the right to decline any transaction at our sole discretion in circumstances where that transaction is fraudulent, would be in breach of these Terms of Use or any applicable law and regulation or you have insufficient funds to make the transaction.

3.6 The amount of any payment made to your Account will be credited to your Account balance, less any applicable fees.

3.7 You are fully responsible for any goods or services sold or provided by Merchants that are paid for using the Sticpay Account. Any dispute with a Merchant regarding any product or service bought by you through Sticpay is between you and the Merchant and you agree that we shall not be a party to such dispute. We do not provide any warranties, representations, conditions or guarantees with respect to such goods and services.

3.8 If you receive funds into your Account that were not intended to be transferred to you or if your Account is credited with a wrong amount, we are entitled to remove these funds from your Account.

3.9 You must ensure that the payment details you enter when making a withdrawal or a transfer are correct and complete. We will not be liable for funds being sent to the wrong account where this is due to you providing incorrect payment details.

4.ACCOUNT SECURITY

4.1 You must always take all reasonable steps to keep your Sticpay Account password and any other security features safe and never disclose them to anyone. Our personnel will never ask you to provide your password to us or to a third party. Any message you receive or website you visit that asks for your password or other security features, other than the Sticpay Website or a Sticpay payment gateway on a merchant website, should be reported to us. We advise you to change your password regularly (at least every three (3) to six (6) months) in order to reduce the risk of a security breach. We also advise you not to choose a password that is easily guessed from information someone might know or gather about you or a password that has a meaning. You must never allow anyone to access your Sticpay Account or watch you accessing your Sticpay Account. You must comply with the security procedures we tell you about from time to time.

4.2 If you have any proof or suspicion that your Sticpay account or any of the security features related to it have been compromised, stolen, lost or misappropriated, you need to immediately change your password and contact us without undue delay. If you delay in notifying us of any such security concerns, you risk being found liable for any losses incurred as a result of your intentional or negligent failure to notify us. We advise that you also contact the Police in case you believe someone else accessed your Sticpay Account.

4.3 If we think your Sticpay Account is at risk of fraud or a security threat, we will use the fastest and most secure way of contacting you using the details you have provided to tell you what you need to do to help deal with that risk. We also reserve the right to suspend your Sticpay Account or restrict some of its functionalities if we have reasonable grounds to believe that your Account’s security features have been compromised. We will notify you of such suspension and the reasons behind it unless notifying you would be unlawful or would compromise our security interests.

5.ACCOUNT RESTRICTIONS

5.1 You agree to use your Account in accordance with these Terms of Use and/or any other instructions we may give you from time to time. You agree and acknowledge that you are prohibited from using our Site and Services in relation to the following non-exhaustive list of activities:

5.1.1 systematically retrieve data or other content from the Site to create or compile, directly or indirectly, a collection, compilation, database, or directory without written permission from us.

5.1.2 make any unauthorized use of the Site, including collecting usernames and/or email addresses of users by electronic or other means for the purpose of sending unsolicited email, or creating user accounts by automated means or under false pretences

5.1.3 trick, defraud, or mislead us and other users, especially in any attempt to learn sensitive account information such as user passwords

5.1.4 make improper use of our support services or submit false reports of abuse or misconduct

5.1.5 attempt to impersonate another user or person or use the username of another user

5.1.6 use any information obtained from the Site in order to harass, abuse, or harm another person

5.1.7 harass, annoy, intimidate, or threaten any of our employees or agents engaged in providing any portion of the Site to you

5.1.8 decipher, decompile, disassemble, or reverse engineer any of the software comprising or in any way making up a part of the Site.

5.1.9 delete the copyright or other proprietary rights notice from any Content

5.1.10 sending unsolicited email or similar methods of mass messaging (spam)

5.2 You are forbidden from conducting transactions (deposits, withdrawals, payment, transfers) that are directly or indirectly connected or furthering the following activities sand subject matters. Those include, but are not limited to:

5.2.1 Material which incites or promote violence and/or racism

5.2.2 Prescription drugs, illegal drugs

5.2.3 Illegal tobacco products

5.2.4 Firearms and weapons

5.2.5 Child pornography

5.2.6 Satellite and cable TV descramblers

5.2.7 Any fake or counterfeit government ID’s, Visas, Licenses or other

5.2.8 Any goods or services that infringe on the intellectual property rights of third parties

5.2.9 Pyramid or Ponzi scheme products or third-party payment processing or payment aggregation products, multi-level marketing and other “get-rich-quick” schemes or high yield investment programs

5.2.10 Prepaid or other stored value cards that are not associated with a merchant and/or are not limited to purchases of particular products or services

5.2.11 Unlicensed gambling services of any type.

We reserve the right to add, in our sole discretion, other prohibited items to the above list without prior notice.

5.3 You cannot use our services if you reside in certain countries. A list of non-serviced countries can be found here. We reserve the right to amend this list from time to time. Any changes made will come into effect immediately and without notice.

5.4 It is strictly prohibited to use your Account for any illegal purposes including but not limited to fraud and money laundering. We will investigate and report any suspicious activity to the relevant law enforcement agency. You are prohibited from using your Account to abuse, exploit or circumvent the usage restrictions imposed by a merchant or a Third-Party Provider on the services it provides.

5.5 If you conduct or attempt to conduct any transaction in violation of the prohibitions contained in these Terms of Use, we reserve the right to: reverse the transaction and/or close or suspend your Account and/or report the transaction to the relevant law enforcement agency and/or claim damages from you.

5.6 You agree and acknowledge that it is solely your responsibility to ensure that you engage in transactions to/from other persons/merchants which are both compliant with any applicable laws and regulations and not in breach of these Terms of Use. The mere fact that a person or entity conducts payments through Sticpay Services is not an indication of the legality of the supply or provision of their goods and services. If you are in doubt as to the legality of a supply or purchase, you should not continue with your payment.

6.ACCOUNT SUSPENSION

6.1 We may, at our discretion, suspend or limit access to your Account, without prior notice, in the following circumstances:

6.1.1 If you breach these Terms of Use

6.1.2 If we have reasonable grounds to believe that your Account has been used without your authorization or in connection with a suspicious or unauthorized transaction

6.1.3 If we determine you provide us with false and misleading information

6.1.4 If we have reasonable grounds to believe your Account has been used in relation to a prohibited activity or transaction as per section 5 of these Terms of Use

6.1.5 If you abuse or attempt to abuse the charge back process offered by your bank or credit card company

6.1.6 If funds are credited to your Account as a result of fraud or suspicion of fraud

6.1.7 If you refuse to cooperate in an investigation or to provide adequate identity or security information or documentary evidence for verification when requested

6.1.8 If we believe your Account has been used or allegedly used, or may be used, in, or to facilitate, any fraud, financial-crime related activity or any other illegal activity

6.1.9 To comply with money laundering or terrorist financing investigations or prohibitions issued by any government authorities, agencies or commissions

6.2 Subject to section 6.3, if we close or suspend your Account, we will notify you by e-mail before doing so and return to you any unrestricted or undisputed funds in your Account in accordance with your instructions.

6.3 In certain circumstances, we may be legally prohibited from notifying you that your Account has been suspended or closed. In such circumstances, we will endeavour to inform you as soon as we are able. Where an Account is suspended, we may, at our discretion, lift the suspension provided we are satisfied that the circumstances giving rise to the suspension no longer exist.

6.4 If we terminate or suspend your account for any reason, you are prohibited from registering and creating a new account under your name, a fake or borrowed name, or the name of any third party.

7.ACCOUNT CLOSURE

7.1 You have the right to close your Account and thereby terminate your agreement with us (and your right to use Sticpay Services) at any time by notifying our Support Team. If your Account holds a balance at the time of its closure, we will ask you to withdraw your funds. After all the funds are withdrawn, you will no longer be able to access your Account. If you want to access your transaction history after the closure of your Account, you will need to contact our Support Team and request the information. You may do so for a period of five (5) years from the date of closure of your Account.

7.2 We reserve the right to terminate this Agreement with you and subsequently close your Account by giving you one (1) months’ notice.

8.PRIVACY

8.1 By using the Sticpay Services, you agree to be bound by our Privacy Policy, which is incorporated into these Terms of Use.

8.2 You hereby explicitly consent to us accessing, retaining and processing any information you provide to us and that we collect from you for the purposes of providing the Sticpay Services to you. This does not impact out rights and obligations under the current Data Protection legislation. If you do not wish to have your data used in this way, you may withdraw your consent by specifically informing us of that via e-mail. If you withdraw your consent, we will no longer be able to provide you with the Sticpay Services and, as a result, your Account will be closed. We will then cease to collect and use your data. However, we may continue to use your data for other legally required purposes, such as to comply with the record-keeping requirements imposed on us.

9.COMPLAINTS PROCEDURE

9.1 Any complaints regarding our services should be addressed to us in the first instance. All complaints should be made formally, in writing, for them to be effectively recorded and investigated. Please raise any issue or complaint with our team by emailing us at account@sticpay.com. It is important that you clearly indicate you wish to make a complaint rather than to enquire about a matter. Explain the nature of the problem and provide as with many details as possible.

9.2 Once a formal complaint is received, one of our team members will acknowledge your complaint in a timely manner. They will do their best to help you or, if necessary, will refer your complaint to an appropriate Manager. During our investigation, we may contact you to request additional information necessary to help us solve your issue. Your prompt response in those circumstances will help us finalize the investigation in a timely manner.

10.WARRANTIES, LIABILITIES, DISCLAIMER

10.1 The Site is provided on an as-is and as-available basis. You agree that your use of the Site and Sticpay Services will be at your sole risk.

10.2 WE MAKE NO EXPRESS WARRANTIES, GUARANTIES OR CONDITIONS TO YOU WITH RESPECT TO THE STICPAY SERVICES EXCEPT AS SET OUT IN THESE TERM SOF USE, AND ALL IMPLIED AND STATUTORY WARRANTIES AND CONDITIONS, INCLUDING WITHOUT LIMITATION ANY WARRANTY OR CONDITION OF FITNESS FOR A PARTICULAR PURPOSE ARE HEREBY EXPRESSLY DISCLAIMED EXCEPT WHERE IMPLIED OR STATUTORY WARRANTIES CANNOT BE DISCLAIMED BY APPLICABLE LAW.

10.3 We make no warranties or representations about the accuracy or completeness of the Site’s content, or the content of any websites linked to the Site, and we will assume no liability or responsibility for any:

10.3.1 errors, mistakes, or inaccuracies of content and materials

10.3.2 personal injury or property damage, of any nature whatsoever, resulting from your access to and use of the Site

10.3.3 any unauthorized access to or use of our secure servers and/or any and all personal information and/or financial information stored therein

10.3.4 any interruption or cessation of transmission to or from the Site

10.3.5 any bugs, viruses, trojan horses, or the like which may be transmitted to or through the Site by any third party, and/or

10.3.6 any errors or omissions in any content and materials or for any loss or damage of any kind incurred as a result of the use of any content posted, transmitted, or otherwise made available via the Site.

10.4 We do not warrant, endorse, guarantee, or assume responsibility for any product or service advertised or offered by a third party through the site, any hyperlinked website, or any website or mobile application featured in any banner or other advertising.

10.5 You may open a Sticpay Account provided it is legal to do so in your country of residence. By opening a Sticpay Account you represent and warrant to us that your opening of a Sticpay Account does not violate any laws or regulations applicable to you. You agree to pay us, our affiliates, holding companies, subsidiaries, agents and subcontractors, the amount of all claims, losses, damages, expenses and liabilities whatsoever suffered or incurred by us, our affiliates, holding companies, subsidiaries, agents or subcontractors as a result of your use of the Sticpay Services in violation of any law or regulation. This provision shall survive termination of the relationship between you and us.

10.6 We shall not be liable for any indirect or consequential losses including but not limited to loss of profit, loss of business and loss of reputation. We shall not be liable for any losses arising from our compliance with legal and regulatory requirements.

10.7 Nothing in these Terms of Use shall operate to exclude liability for death or personal injury due to negligence or for fraud or fraudulent misrepresentation or for any statutory liability that cannot be excluded or amended by agreement between the parties.

10.8 Notwithstanding the foregoing, we shall not be liable for any disruption or impairment of our service or for disruptions or impairments of intermediary services on which we rely for the performance of our obligations hereunder, provided that such disruption or impairment is due to abnormal and unforeseeable circumstances beyond our reasonable control, or the control of the intermediary affected.

10.9 In no event will we or our directors, employees, or agents be liable to you or any third party for any direct, indirect, consequential, exemplary, incidental, special, or punitive damages, including lost profit, lost revenue, loss of data, or other damages arising from your use of the site.

11.INTELLECTUAL PROPERTY RIGHTS

11.1 Unless otherwise indicated, the Site is our proprietary property and all source code, databases, functionality, software, website designs, audio, video, text, photographs, and graphics on the Site (collectively, the “Content”) and the trademarks, service marks, and logos contained therein (the “Marks”) are owned or controlled by us or licensed to us, and are protected by copyright and trademark laws and various other intellectual property rights and unfair competition laws of the Malaysia, foreign jurisdictions, and international conventions.

11.2 Except as expressly provided in these Terms of Use, no part of the Site and no Content or Marks may be copied, reproduced, aggregated, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted, distributed, sold, licensed, or otherwise exploited for any commercial purpose whatsoever, without our express prior written permission.

11.3 Provided that you are eligible to use the Site, you are granted a limited license to access and use the Site and to download or print a copy of any portion of the Content to which you have properly gained access solely for your personal, non-commercial use. We reserve all rights not expressly granted to you in and to the Site, the Content and the Marks.

12.FORCE MAJEURE

12.1 We are not responsible for any failure to perform our obligations under this Agreement if we are prevented or delayed in performing these obligations by an event or circumstances beyond our reasonable control. Such event or circumstances include, but are not limited to earthquakes, flood, fire or other physical natural disaster, riot, war, acts of terrorism, revolution, explosions, national strikes, government restrictions and pandemics.

13.SEVERABILITY

13.1 If any provision or part of a provision of these Terms of Use is determined to be unlawful, void, or unenforceable, that provision or part of the provision is deemed severable from these Terms of Use and does not affect the validity and enforceability of any remaining provisions.

14.THIRD PARTY RIGHTS

14.1 No term of this Agreement shall be enforceable by any person who is not a party to this Agreement.

15.WHOLE AGREEMENT

15.1 This Agreement contains our entire agreement. No warranty shall be implied or have any effect unless specifically included in this Agreement and in any changes subsequently notified or the additional conditions. Our failure to exercise or enforce any right or provision of these Terms of use shall not operate as a waiver of such right or provision.

16.GOVERNING LAW

16.1 These Terms of Use and your use of the Site are governed by and construed in accordance with the laws of Malaysia. Any dispute arising under this Agreement will be under the sole jurisdiction of the Courts of Malaysia.

17.DEFINITIONS

Various terms in these Terms of Use have a defined meaning as follows:

“Business Day” means any day other than a Saturday or a Sunday or a public or bank holiday in Labuan, Malaysia.

“Support Team” means our customer service, which you can reach by sending a message through the “Support” facility on the website.

“Privacy Notice” is Sticpay's policy governing the processing of personal data, which is available on the Website, as may be amended from time to time.

“Sticpay” means STIC FINANCIAL LTD. (registration number: LL17331) whose registered office is at LEVEL 15(A1), MAIN OFFICE TOWER FINANCIAL PARK LABUAN, JALAN MERDEKA 87000 LABUAN MALAYSIA.

“Sticpay Account” means the electronic money account you open and maintain through the Sticpay Website.

“Sticpay Website”, “Website” or “Site” means the website available at www.sticpay.com

“Terms of Use” means these Sticpay Account Terms of Use, published on the Website and as may be amended from time.

“We”, “us”, “our” means Sticpay.

“You” or “your” means you, the natural person or legal entity in whose name the Sticpay Account is opened and maintained

STIC FINANCIAL LTD. (registration number: LL17331) is registered with the Labuan Financial Services Authority as a Money Broker and Payment Systems operator under license number MB/21/0073

18. COUNTRIES NOT ALLOWED

You are restricted from using STICPAY if you reside in one of the following countries below.

  • Afghanistan (AF)
  • American Samoa (AS)
  • Central African Republic (CF)
  • Cuba (CU)
  • Ethiopia (ET)
  • Iran (IR)
  • Iraq (IQ)
  • Ivory Coast (CI)
  • Lebanon (LB)
  • Libya (LY)
  • Mali (ML)
  • Myanmar (MM)
  • Nicaragua (NI)
  • North Korea (KP)
  • Northern Mariana Islands (MP)
  • Puerto Rico (PR)
  • Sint Maarten (SX)
  • Somalia (SO)
  • South Sudan (SS)
  • St Helena (SH)
  • Sudan (SD)
  • Syria (SY)
  • United States (US)
  • Virgin Islands  (US) (VI)
  • Yemen (YE)

1.GENERAL

1.1 These Terms of Use constitute a legally binding agreement made between you, whether personally or on behalf of an entity (“you”) and Sticpay(“we,” “us” or “our”),concerning your access to and use of the www.sticpay.com website as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively, the “Site”).

1.2 You agree that by accessing the Site, you have read, understood, and agree to be bound by all these Terms of Use. If you do not agree with all these Terms of Use, then you are expressly prohibited from using the Site and you must discontinue use immediately.

1.3 Supplemental Terms of Use or documents that may be posted on the Site from time to time are hereby expressly incorporated herein by reference. We reserve the right, in our sole discretion, to make changes or modifications to these Terms of Use at any time and for any reason.

1.4 We will notify you of any changes by sending an e-mail to the primary e-mail address registered with your Account or by posting a notice of the changes on our Website with a link to the amended Terms of Use. If the proposed changes will affect your rights, we will provide you with thirty (30) days’ notice before implementing them. However, any changes made to these Terms of Use that are favourable to you or that do not affect your rights will come into effect immediately.

1.5 It is your responsibility to periodically review these Terms of Use to stay informed of updates. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised Terms of Use by your continued use of theSite after the date such revised Terms of Use are posted.

1.6 If you disagree with the changes implemented in the Terms of Use, you have the right to terminate and close your Account immediately. You need to notify us that you do not agree to the changes. This will constitute notice that you wish to terminate your agreement with us, and your Account will be immediately closed upon receipt of your notice to terminate. Any funds in your Account will be returned to you using such method as notified by you (subject to the normal applicable Fees).

1.7 The information provided on the Site is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject us to any registration requirement within such jurisdiction or country.

1.8 Accordingly, those persons who choose to access the Site from other locations do soon their own initiative and are solely responsible for compliance with local laws, if and to the extent local laws are applicable.

1.9 Where our Site contains links to other Sites and resources provided by third parties,these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.

1.10 We do not guarantee that our Site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our Site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

2.REGISTERING FOR AN ACCOUNT

2.1 In order to open a Sticpay Account, you need to be at least 18 years old.

2.2 You must not be a resident of any country where we do not provide services. A list of non-serviced countries can be foundhere.
We reserve the right to amend this list from time to time. Any changes made will come into effect immediately and without notice.

2.3 You may open a Sticpay Account provided it is legal to do so in your country of residence. By opening a Sticpay Account you represent and warrant to us that your opening of a Sticpay Account does not violate any laws or regulations applicable to you.You shall pay us the amount of any losses we incur in connection with your breach of this section.

2.4 You must create an Account by registering your details according to the instructions found on the Sign-Up page on our Site.

2.5 As part of the sign-up process you must agree to these Terms of Use and our PrivacyPolicy.

2.6 All information provided when registering an account and at any time thereafter must be correct and truthful. You represent and warrant that you will maintain the accuracy of such information and promptly update such registration information, as necessary. If you do not provide such information or fail to cooperate with us, we reserve the right to suspend or close your account.

2.7 You must provide us with the necessary documentation and pass all our verification checks.

3.USE OF YOUR STICPAY ACCOUNT

3.1 Your Sticpay Account is an electronic money account which enables you to send and receive electronic payments.

3.2 Electronic money accounts are not bank accounts. By accepting these Terms of Use you acknowledge that the UK’s Financial Services Compensation Scheme (FSCS) does not apply to your Sticpay Account. In the unlikely event that we become insolvent, you may lose the electronic money held in your Sticpay Account. However, the European Electronic Money Directive 2009/110/EC and UK national legislation apply to us and these are designed to ensure the safety and liquidity of funds deposited in electronic money accounts within the EEA.

3.3 The Sticpay Account registered belongs only to the natural person or legal entity that registered it. You cannot transfer your Account to any third parties, and you cannot assignor grant any legal or equitable interests over your Sticpay Account to any other party.

3.4 All of your transactional records (deposits, withdrawals, payments sent and received)can be found in the Transfer History section in your Account. Each transaction has a unique transaction ID. You should quote this transaction ID when communicating with us about a particular transaction. You should check your Sticpay Account balance and transaction history regularly. You should report any irregularities or clarify any questions you have as soon as possible by contacting Support Team.

3.5 We reserve the right to decline any transaction at our sole discretion in circumstances where that transaction is fraudulent, would be in breach of these Terms of Use or any applicable law and regulation or you have insufficient funds to make the transaction.

3.6 The amount of any payment made to your Account will be credited to your Account balance, less any applicable fees.

3.7 You are fully responsible for any goods or services sold or provided by Merchants that are paid for using the Sticpay Account. Any dispute with a Merchant regarding any product or service bought by you through Sticpay is between you and the Merchant and you agree that we shall not be a party to such dispute. We do not provide any warranties,representations, conditions or guarantees with respect to such goods and services.

3.8 If you receive funds into your Account that were not intended to be transferred to you or if your Account is credited with a wrong amount, we are entitled to remove these funds from your Account.

3.9 You must ensure that the payment details you enter when making a withdrawal or a transfer are correct and complete. We will not be liable for funds being sent to the wrong account where this is due to you providing incorrect payment details.

4.ACCOUNT SECURITY

4.1 You must always take all reasonable steps to keep your Sticpay Account password and any other security features safe and never disclose them to anyone. Our personnel will never ask you to provide your password to us or to a third party. Any message you receive or website you visit that asks for your password or other security features, other than the Sticpay Website or a Sticpay payment gateway on a merchant website, should be reported to us. We advise you to change your password regularly (at least every three (3) to six (6)months) in order to reduce the risk of a security breach. We also advise you not to choose a password that is easily guessed from information someone might know or gather about you or a password that has a meaning. You must never allow anyone to access your Sticpay Account or watch you accessing your Sticpay Account. You must comply with the security procedures we tell you about from time to time.

4.2 If you have any proof or suspicion that your Sticpay account or any of the security features related to it have been compromised, stolen, lost or misappropriated, you need to immediately change your password and contact us without undue delay. If you delay in notifying us of any such security concerns, you risk being found liable for any losses incurred as a result of your intentional or negligent failure to notify us. We advise that you also contact the Police in case you believe someone else accessed your Sticpay Account.

4.3 If we think your Sticpay Account is at risk of fraud or a security threat, we will use the fastest and most secure way of contacting you using the details you have provided to tell you what you need to do to help deal with that risk. We also reserve the right to suspend your Sticpay Account or restrict some of its functionalities if we have reasonable grounds to believe that your Account’s security features have been compromised. We will notify you of such suspension and the reasons behind it unless notifying you would be unlawful or would compromise our security interests.

5.ACCOUNT RESTRICTIONS

5.1 You agree to use your Account in accordance with these Terms of Use and/or any other instructions we may give you from time to time. You agree and acknowledge that you are prohibited from using our Site and Services in relation to the following non-exhaustive list of activities: - systematically retrieve data or other content from the Site to create or compile, directly or indirectly, a collection, compilation, database, or directory without written permission from us. - make any unauthorized use of the Site, including collecting usernames and/or email addresses of users by electronic or other means for the purpose of sending unsolicited email, or creating user accounts by automated means or under false pretences - trick, defraud, or mislead us and other users, especially in any attempt to learn sensitive account information such as user passwords - make improper use of our support services or submit false reports of abuse or misconduct - attempt to impersonate another user or person or use the username of another user - use any information obtained from the Site in order to harass, abuse, or harm another person - harass, annoy, intimidate, or threaten any of our employees or agents engaged in providing any portion of the Site to you - decipher, decompile, disassemble, or reverse engineer any of the software comprising or in any way making up a part of the Site. - delete the copyright or other proprietary rights notice from any Content - sending unsolicited email or similar methods of mass messaging (spam)

5.2 You are forbidden from conducting transactions (deposits, withdrawals, payment, transfers) that are directly or indirectly connected or furthering the following activitiesand subject matters. Those include, but are not limited to: - Material which incites or promote violence and/or racism - Prescription drugs, illegal drugs - Illegal tobacco products - Firearms and weapons - Child pornography - Satellite and cable TV descramblers - Any fake or counterfeit government ID’s, Visas, Licenses or other - Any goods or services that infringe on the intellectual property rights of third parties - Pyramid or Ponzi scheme products or third-party payment processing or payment aggregation products, multi-level marketing and other “get-rich-quick” schemes or high yield investment programs - Prepaid or other stored value cards that are not associated with a merchant and/or are not limited to purchases of particular products or services - Unlicensed gambling services of any typeWe reserve the right to add, in our sole discretion, other prohibited items to the above list without prior notice.

5.3 You cannot use our services if you reside in certain countries. A list of non-serviced countries can be foundhereWe reserve the right to amend this list from time to time. Any changes made will come into effect immediately and without notice.

5.4 It is strictly prohibited to use your Account for any illegal purposes including but not limited to fraud and money laundering. We will investigate and report any suspicious activity to the relevant law enforcement agency. You are prohibited from using yourAccount to abuse, exploit or circumvent the usage restrictions imposed by a merchant or a Third-Party Provider on the services it provides.

5.5 If you conduct or attempt to conduct any transaction in violation of the prohibitions contained in these Terms of Use, we reserve the right to: reverse the transaction and/or close or suspend your Account and/or report the transaction to the relevant law enforcement agency and/or claim damages from you.

5.6 You agree and acknowledge that it is solely your responsibility to ensure that you engage in transactions to/from other persons/merchants which are both compliant with any applicable laws and regulations and not in breach of these Terms of Use. The mere fact that a person or entity conducts payments through Sticpay Services is not an indication of the legality of the supply or provision of their goods and services. If you are in doubt as to the legality of a supply or purchase, you should not continue with your payment.

6.ACCOUNT SUSPENSION

6.1 We may, at our discretion, suspend or limit access to your Account, without prior notice,in the following circumstances: - If you breach these Terms of Use - If we have reasonable grounds to believe that your Account has been used without your authorization or in connection with a suspicious or unauthorized transaction - If we determine you provide us with false and misleading information - If we have reasonable grounds to believe your Account has been used in relation toa prohibited activity or transaction as per section 5 of these Terms of Use - If you abuse or attempt to abuse the charge back process offered by your bank or credit card company - If funds are credited to your Account as a result of fraud or suspicion of fraud - If you refuse to cooperate in an investigation or to provide adequate identity or security information or documentary evidence for verification when requested - If we believe your Account has been used or allegedly used, or may be used, in, or to facilitate, any fraud, financial-crime related activity or any other illegal activity - To comply with money laundering or terrorist financing investigations or prohibitions issued by any government authorities, agencies or commissions

6.2 Subject to section 6.3, if we close or suspend your Account, we will notify you by e-mail before doing so and return to you any unrestricted or undisputed funds in your Account in accordance with your instructions.

6.3 In certain circumstances, we may be legally prohibited from notifying you that your Account has been suspended or closed. In such circumstances, we will endeavour to inform you as soon as we are able. Where an Account is suspended, we may, at our discretion, lift the suspension provided we are satisfied that the circumstances giving rise to the suspension no longer exist.

6.4 If we terminate or suspend your account for any reason, you are prohibited from registering and creating a new account under your name, a fake or borrowed name, or the name of any third party.

7.ACCOUNT CLOSURE

7.1 You have the right to close your Account and thereby terminate your agreement with us(and your right to use Sticpay Services) at any time by notifying our Support Team. If yourAccount holds a balance at the time of its closure, we will ask you to withdraw your funds.After all the funds are withdrawn, you will no longer be able to access your Account. If you want to access your transaction history after the closure of your Account, you will need to contact our Support Team and request the information. You may do so for a period of five(5) years from the date of closure of your Account.

7.2 We reserve the right to terminate this Agreement with you and subsequently close youAccount by giving you one (1) months’ notice.

8.PRIVACY

8.1 By using the Sticpay Services, you agree to be bound by our Privacy Policy, which is incorporated into these Terms of Use. More details on how we process your data can be found in our Privacy Policy which can be accessed here.

8.2 You hereby explicitly consent to us accessing, retaining and processing any information you provide to us and that we collect from you for the purposes of providing the Sticpay Services to you. This does not impact out rights and obligations under the current DataProtection legislation. If you do not wish to have your data used in this way, you may withdraw your consent by specifically informing us of that via e-mail. If you withdraw your consent, we will no longer be able to provide you with the Sticpay Services and, as a result,your Account will be closed. We will then cease to collect and use your data. However, we may continue to use your data for other legally required purposes, such as to comply with the record-keeping requirements imposed on us.

9.COMPLAINTS PROCEDURE

9.1 Any complaints regarding our services should be addressed to us in the first instance. All complaints should be made formally, in writing, for them to be effectively recorded and investigated. Please raise any issue or complaint with our team by emailing us at account@sticpay.com. It is important that you clearly indicate you wish to make a complaint rather than to enquire about a matter. Explain the nature of the problem and provide as with many details as possible.

9.2 Once a formal complaint is received, one of our team members will acknowledge your complaint in a timely manner. They will do their best to help you or, if necessary, will refer your complaint to an appropriate Manager. During our investigation, we may contact you to request additional information necessary to help us solve your issue. Your prompt response in those circumstances will help us finalize the investigation in a timely manner.

9.3 We endeavour to provide you with an answer or resolution to your complaint within the timeframes as outlined by the Financial Ombudsman Service. Should this not be possible due to unforeseen circumstances or lack of information, we will contact you.

9.4 If your complaint is not resolved to your satisfaction, you may contact the FinancialOmbudsman Service at Exchange Tower, London, E14 9SR, United Kingdom. For more information, please access our Complaints Policy and Procedure which can be foundhere.

9.5 Please note that the FCA EMI licence held by Coopertoby under CFS Zipp Limited only covers the funds and activities of EEA registered clients and merchants. NON-EEA clients and merchants are not subject to the licence and are not eligible to submit complaints to the Financial Ombudsman Service..

10.WARRANTIES, LIABILITIES, DISCLAIMER

10.1 The Site is provided on an as-is and as-available basis. You agree that your use of theSite and Sticpay Services will be at your sole risk.

10.2 WE MAKE NO EXPRESS WARRANTIES, GUARANTIES OR CONDITIONS TO YOU WITH RESPECT TO THE STICPAY SERVICES EXCEPT AS SET OUT IN THESE TERM SOF USE, AND ALL IMPLIED AND STATUTORY WARRANTIES AND CONDITIONS,INCLUDING WITHOUT LIMITATION ANY WARRANTY OR CONDITION OF FITNESS FOR A PARTICULAR PURPOSE ARE HEREBY EXPRESSLY DISCLAIMED EXCEPT WHERE IMPLIED OR STATUTORY WARRANTIES CANNOT BE DISCLAIMED BY APPLICABLE LAW.

10.3 We make no warranties or representations about the accuracy or completeness of the Site’s content or the content of any websites linked to the Site and we will assume no liability or responsibility for any: (1) errors, mistakes, or inaccuracies of content and materials, (2) personal injury or property damage, of any nature whatsoever, resulting from your access to and use of the Site, (3) any unauthorized access to or use of our secure servers and/or any and all personal information and/or financial information stored therein, (4) any interruption or cessation of transmission to or from the Site (5) any bugs, viruses, trojan horses, or the like which may be transmitted to or through the Site by any third party, and/or (6) any errors or omissions in any content and materials or for any loss or damage of any kind incurred as a result of the use of any content posted,transmitted, or otherwise made available via the Site.

10.4 We do not warrant, endorse, guarantee, or assume responsibility for any product or service advertised or offered by a third party through the site, any hyperlinked website, or any website or mobile application featured in any banner or other advertising.

10.5 You may open a Sticpay Account provided it is legal to do so in your country of residence. By opening a Sticpay Account you represent and warrant to us that your opening of a Sticpay Account does not violate any laws or regulations applicable to you.You agree to pay us, our affiliates, holding companies, subsidiaries, agents and subcontractors, the amount of all claims, losses, damages, expenses and liabilities whatsoever suffered or incurred by us, our affiliates, holding companies, subsidiaries, agents or subcontractors as a result of your use of the Sticpay Services in violation of anylaw or regulation. This provision shall survive termination of the relationship between you and us.

10.6 We shall not be liable for any indirect or consequential losses including but not limited to loss of profit, loss of business and loss of reputation. We shall not be liable for any losses arising from our compliance with legal and regulatory requirements.

10.7 Nothing in these Terms of Use shall operate to exclude liability for death or personal injury due to negligence or for fraud or fraudulent misrepresentation or for any statutory liability that cannot be excluded or amended by agreement between the parties.

10.8 Notwithstanding the foregoing, we shall not be liable for any disruption or impairment of our service or for disruptions or impairments of intermediary services on which we rely for the performance of our obligations hereunder, provided that such disruption or impairment is due to abnormal and unforeseeable circumstances beyond our reasonable control or the control of the intermediary affected.

10.9 In no event will we or our directors, employees, or agents be liable to you or any third party for any direct, indirect, consequential, exemplary, incidental, special, or punitive damages, including lost profit, lost revenue, loss of data, or other damages arising from your use of the site.

11.INTELLECTUAL PROPERTY RIGHTS

11.1 Unless otherwise indicated, the Site is our proprietary property and all source code,databases, functionality, software, website designs, audio, video, text, photographs, and graphics on the Site (collectively, the “Content”) and the trademarks, service marks, and logos contained therein (the “Marks”) are owned or controlled by us or licensed to us, and are protected by copyright and trademark laws and various other intellectual property rights and unfair competition laws of the United Kingdom, foreign jurisdictions, and international conventions.

11.2 Except as expressly provided in these Terms of Use, no part of the Site and noContent or Marks may be copied, reproduced, aggregated, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted, distributed, sold, licensed, or otherwise exploited for any commercial purpose whatsoever, without our express prior written permission.

11.3 Provided that you are eligible to use the Site, you are granted a limited license to access and use the Site and to download or print a copy of any portion of the Content to which you have properly gained access solely for your personal, non-commercial use. We reserve all rights not expressly granted to you in and to the Site, the Content and theMarks.

12.FORCE MAJEURE

12.1 We are not responsible for any failure to perform our obligations under this Agreement if we are prevented or delayed in performing these obligations by an event or circumstances beyond our reasonable control. Such event or circumstances include, but are not limited to earthquakes, flood, fire or other physical natural disaster, riot, war, acts of terrorism, revolution, explosions, national strikes, government restrictions and pandemics.

13.SEVERABILITY

13.1 If any provision or part of a provision of these Terms of Use is determined to be unlawful, void, or unenforceable, that provision or part of the provision is deemed severable from these Terms of Use and does not affect the validity and enforceability of any remaining provisions.

14.THIRD PARTY RIGHTS

14.1 No term of this Agreement shall be enforceable by virtue of the Contracts (Rights ofThird Parties) Act 1999 by any person who is not a party to this Agreement.

15.WHOLE AGREEMENT

15.1 This Agreement contains our entire agreement. No warranty shall be implied or have any effect unless specifically included in this Agreement and in any changes subsequently notified or the additional conditions. Our failure to exercise or enforce any right or provision of these Terms of use shall not operate as a waiver of such right or provision.

16.GOVERNING LAW

16.1 These Terms of Use and your use of the Site are governed by and construed in accordance with the laws of England and Wales. Any dispute arising under this Agreement will be under the sole jurisdiction of the Courts of England and Wales.

17.DEFINITIONS

Various terms in these Terms of Use have a defined meaning as follows:

“Business Day” means any day other than a Saturday or a Sunday or a public or bank holiday in England.

“Support Team” means our customer service, which you can reach by sending a message through the “Support” facility on the website.

“Financial Ombudsman Service” means the services provided by the United KingdomFinancial Ombudsman Service, details of which can be found at www.financial-ombudsman.org.uk and who can be contacted at The Financial Ombudsman Service,Exchange Tower, London, E14 9SR, United Kingdom.

“Privacy Notice” is Sticpay's policy governing the processing of personal data, which is available on the Website, as may be amended from time to time.

“Sticpay” means COOPERTOBY LTD. (registration number:12255239) whose registered office is at Kemp House, 160 City Road, London, EC1V 2NX, United Kingdom.

“Sticpay Account” means the electronic money account you open and maintain through the Sticpay Website.

“Sticpay Website”, “Website” or “Site” means the website available at www.sticpay.com

“Terms of Use” means these Sticpay Account Terms of Use, published on the Website and as may be amended from time.

“We”, “us”, “our” means Sticpay.

“You” or “your” means you, the natural person or legal entity in whose name the Sticpay Account is opened and maintained

Coopertoby Ltd ( Companies House No. 12255239) is registered with the Financial Conduct Authority as an EMD Agent (FRN: 902825) of CFS-Zipp Ltd an Electronic Money Institution authorised by the Financial Conduct Authority (FRN: 900027).

1.1 The present Agreement determines rights and responsibilities of Internet user who expressed willingness to become the customer of STICPAY system (hereinafter referred to as"System").

1.2 User has a right to accept and not to accept the offered conditions that later on will predetermine his participation or non-participation in System.

1.3 The agreement is deemed bilateral and determines rendering of informational service to the user without binding the latter to make any investments.

1.4 Customer is obligated to provide his/her real identity in order to use STICPAY payment system. This information is used only for verification purposes and will not be disclosed to 3rd parties.

1.5 Having approved the present Agreement and proceeded with registration process in the System, user confirms the transmittal of his data into the System and their use at identification, notification and performance of transactions.

1.6 System customer has a right to change his personal data.

1.7 System customer understands and accepts that some transactions within the system are performed by 3rd parties, such as STICPAY certified Partners, and that the System is not in full control of such activities.

1.8 Customer of STICPAY has a right to minimize the use of his personal data. Customer should be aware that minimizing the use of personal data will result in decreased safety level of his/her account.

1.9 Account is a personal customer area of user which functions on the basis of user's personal data.

1.10 Customer is fully responsible for the state of his account, access to it and its control.

1.11 System is not responsible for premeditated and unpremeditated use of account by the customer in illegal transactions.

1.12 Registering in STICPAY system customer undertakes not to use it in unlawful purposes and not to act in operations that can result in system damage.

1.13 System reserves a right to carry out accounting operations and systematization of all transactions performed by the customer within system. In case of complaints of SR & I. (hereinafter referred to as "Company") or 3rd parties against the Customer Company has a right to address judicial agencies of any jurisdiction for protection of system interests, its participants, and the 3rd parties.

1.14 User's account is not subject to transfer to any other person without notification of system administration.

1.15 When you log in in your account for the first time, you will be asked to setup a two factor authentication (2FA) method to secure your account access. By volontarily declining to setup such additional security layer, you accept that Sticpay cannot be hold responsible for any unauthorized access to your account, which could result in a loss of funds.

1.16 Entering the account system customer fully responsible for all transactions performed in system on behalf of his account.

1.17 Having agreed to become System user you acknowledge the right of the System to establish any internal cross-rates for currencies and metals in which your funds are stored as money tokens.

1.18 Only customer and nobody else is responsible for any migration or loss of his/her funds including resulting from authorized access.

1.19 Customer has no right to demand to reverse the transaction done by him/her in the System.

1.20 Any transaction can be reversed only at court decision.

1.21 Transaction performed in the system on behalf of account registered in name of user is strictly secured for the owner of this account and is not subject to be challenged for non-participation of the Customer in this transaction.

1.22 System customer shall pay a special attention to accuracy of his actions as a number of operations in STICPAY are performed by one click.

1.23 System and Company will not be liable for loss of funds by Customer due to System malfunction, unauthorized access, theft, force majeure ,any special, indirect, incidental or consequential damages that may incur in connection with actions or lack of thereof of 3rd parties such as STICPAY certified Partners.

1.24 System Customer has a right to notify the administration of STICPAY of his desire to close the account at any time. In this case liquidation of account in System and removal of all personal data specified by the user at registration takes place after finishing of identification of applicant's personality and its check for compliance with the personality of the user that had registered this account.

1.25 System reserves a right to block the account for term or termless period at occurrence of some suspicions until ascertainment of circumstances.

1.26 Use of STICPAY system by US citizens and permanent residents is strictly prohibited. System reserves the right to block the registrations originating from the USA or from US citizens located abroad due to local laws and regulations. Any individual or company suspected of submitting false/misleading information with purpose of hiding US location or affiliation may be subject to account block with no prior warning.

You’re restricted to use STICPAY either you reside or nationality is from one of the following countries below.

  • Afghanistan (AF)
  • American Samoa (AS)
  • Central African Republic (CF)
  • Cuba (CU)
  • Ethiopia (ET)
  • Iran (IR)
  • Iraq (IQ)
  • Ivory Coast (CI)
  • Lebanon (LB)
  • Libya (LY)
  • Mali (ML)
  • Myanmar (MM)
  • Nicaragua (NI)
  • North Korea (KP)
  • Northern Mariana Islands (MP)
  • Puerto Rico (PR)
  • Sint Maarten (SX)
  • Somalia (SO)
  • South Sudan (SS)
  • St Helena (SH)
  • Sudan (SD)
  • Syria (SY)
  • United States (US)
  • Virgin Islands  (US) (VI)
  • Yemen (YE)
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