General Terms and Conditions of Use and Sale

(This document is a free English translation of the original French report. In the event of

any discrepancy, the French version shall prevail.)

1. Purpose and Acceptance

1.1 Purpose

These General Terms and Conditions of Use and Sale (the “Terms”) govern access to, registration for, subscription to, purchase of and use of the services offered under the Winble brand (the “Service”), including, depending on the selected offer:

Freemium access to the platform;

A paid digital subscription to the Digital Pack Service;

Access to a mobile account management application;

Access to exclusive content and benefits linked to the relevant community;

Access to partner services available on the platform, and to any other partner added at a later date;

The purchase of gift vouchers, e-gift cards and similar products giving rise, as the case may be, to an immediate discount or a reward pot;

Access, through a regulated financial partner, to a virtual and/or physical Visa card, a payment account, a dedicated IBAN and associated payment services;

Access, where applicable, to a connected payment medium such as a ring, bracelet or other compatible wearable.

The Service is composed of distinct modules, which may be provided immediately, as an option, at a later date, or subject to eligibility, technical, territorial, regulatory and contracting availability with the relevant third parties.

1.2 Who Does What

The platform and the non-regulated services are operated by BLEU BLANC PAY, a simplified joint stock company (société par actions simplifiée) with share capital of EUR 50,000, whose registered office is located at 59 avenue Marceau, 75116 Paris, registered with the Paris Trade and Companies Register under number 989 865 878 (“Winble” or the “Operator”).

SMART GOOD THINGS HOLDING acts as the parent company of the group to which BLEU BLANC PAY belongs. Unless expressly stated otherwise, it is not the User’s direct operating contractual counterparty.

The regulated payment services, including in particular the Visa card, the payment account, the IBAN, payment transactions, top-ups, fund management and the associated regulatory controls, are provided exclusively by Wallester AS, a company incorporated under Estonian law, based at Ahtri tn 6, 10151 Tallinn, Estonia (the “Financial Partner”), in accordance with its own contractual documentation and fee schedule.

BLEU BLANC PAY is neither the provider maintaining the payment account, nor the holder of the funds, nor the User’s payment services provider. Where applicable, BLEU BLANC PAY acts solely as platform operator, distributor of the access journey and first-level support provider, within the limits permitted by applicable regulations.

The payment wearable is supplied, distributed or supported by BLEU BLANC PAY (also referred to as the “Wearable Provider”).

Partner services, including, where applicable, press, coaching, cybersecurity, VPN, content, assistance, insurance or any other third-party service listed on the platform, are provided by third-party partners acting in their own name and under their own responsibility, in accordance with their own contractual, technical, pricing and privacy terms. BLEU BLANC PAY acts, as the case may be, as platform operator, distributor, integrator, access facilitator or first-level support provider, without being the publisher or provider of such services, unless expressly stated otherwise.

1.3 Acceptance

Registration, account activation, subscription to an offer, purchase of a gift voucher or activation of a payment service constitutes full and complete acceptance of these Terms, as well as, where applicable:

The Financial Partner’s terms and conditions for regulated payment services;

The Wearable Provider’s terms and conditions;

The partner services terms and conditions;

The Privacy Policy;

The Cookies Policy;

The Complaints / Support Policy;

Any pricing sheet, merchant sheet, partner notice or pre-contractual information displayed before validation.

Acceptance of these Terms is evidenced by an explicit positive action by the User, time-stamped and retained by BLEU BLANC PAY. A copy of the applicable contractual documents, or durable access thereto, is made available to the User after subscription.

1.4 Order of Precedence

In the event of any inconsistency:

1. The specific terms applicable to a given service shall prevail for their own subject matter;

2. The Financial Partner’s documents shall prevail for regulated payment services;

3. The partner merchants’ terms and conditions shall prevail for the use of gift vouchers with the relevant merchant;

4. The partner notices or terms and conditions shall prevail for warranties, exclusions, limits, deductibles and claim handling arrangements.

In all circumstances, this order of precedence shall apply without prejudice to any mandatory provisions that are more protective of the consumer.

2. Description of the Service

The Winble Service is based on a modular architecture. Depending on the subscribed plan and the offer sheet applicable on the subscription date, it may include:

Non-regulated digital services provided by BLEU BLANC PAY;

Physical products or media;

Regulated payment services provided by the Financial Partner;

Services provided by third-party partners.

Unless expressly stated otherwise in the offer sheet, each component of the Service is legally distinct and may be subject to its own activation, eligibility, technical availability, territorial availability, stock, compatibility, identity verification or acceptance of specific terms and conditions.

2.1 Freemium Access

Under the offer sheet in force on the subscription date, Winble offers free access to certain platform functionalities, according to the scope displayed at the time of registration.

2.2 Paid Digital Pack Service

The Digital Pack Service consists of a digital subscription giving access, depending on the subscribed plan and the offer sheet in force on the subscription date, to all or part of the following components:

Access to the Winble mobile application;

A virtual Visa card;

A physical Visa card;

A payment wearable in the form of a bracelet, ring or any other compatible medium;

Exclusive content linked to the User’s community;

A variable volume of exclusive monthly content;

Digital partner services;

Reward pot and promotional benefit programs;

Warranties, assistance or insurance, where these are actually activated in the relevant offer;

Additional benefits announced at the time of subscription.

Certain components may be provided immediately, offered as an option, or only become accessible from a commercial or technical launch date expressly brought to the User’s attention before subscription, or within the maximum period indicated in the applicable offer sheet. If such component is not made available within that period, and where the relevant component is an essential and determining element of the subscribed offer, the User shall benefit, as the case may be, from an equivalent service, a price adjustment, or the right to terminate the relevant plan for the future without charge.

The components included in each plan are those displayed in the offer in force on the subscription date. They may vary in particular depending on:

The presence of a virtual Visa card;

The presence of a physical Visa card;

The presence or absence of a wearable;

The applicable reward pot level;

The number of monthly content items accessible;

The presence of partner services or insurance;

The operational availability date of certain services.

2.3 Regulated Payment Services

Where the offer so provides, and subject to the User’s eligibility, validation of the required checks and acceptance by the Financial Partner, the User may access regulated payment services provided exclusively by the Financial Partner, including in particular:

Opening of a payment account;

Allocation of a dedicated IBAN;

Issuance of a virtual and/or physical Visa card;

Payment transactions;

Where applicable, top-up or account funding transactions.

2.4 Payment Wearable

Where the plan so provides, and subject to actual availability, technical compatibility and activation of the underlying payment method, the User may associate a compatible connected medium such as a ring, bracelet or other wearable with the User’s Winble ecosystem.

2.5 Gift Vouchers and Reward Pot

The platform may allow the User to purchase gift vouchers, e-gift cards or similar products from partner retailers. Depending on the relevant offer, the purchase or use of such products may give rise to an immediate discount or a reward pot.

2.6 Partner Services

The platform may list, integrate, include or allow the activation of services provided by third-party partners. These services are accessible depending on the subscribed plan, their actual availability, the relevant geographical area, the relevant partner’s conditions and, where applicable, completion of a separate activation flow.

3. Eligibility, Account Creation and Checks

3.1 Eligibility Conditions

The Service is reserved for natural persons of legal age acting for personal purposes, having the required legal capacity and residing in an eligible country of the European Economic Area or in any other territory accepted by Winble and/or the Financial Partner. These countries are expressly listed in the subscription flow and on the dedicated information page accessible from the website or the application, subject to continuing eligibility maintained by the Financial Partner.

3.2 Account Creation

The User must create a personal account by providing the requested information, including:

Last name;

First name;

Email address;

Phone number;

Password;

Any other information necessary for the creation of the account or the provision of the Service.

Only one account is allowed per natural person, unless expressly agreed otherwise by Winble.

3.3 Accuracy of Information

The User undertakes to verify the accuracy, completeness and truthfulness of the information recorded under the “My Account” section, which enables BLEU BLANC PAY to contact the User by email, phone or through the application for the purpose of managing the services and carrying out audit operations. The User undertakes to keep such information up to date, without prejudice to the User’s GDPR rights and without confusion with the contact details intended for the exercise of those rights.

3.4 Checks and KYC

Access to certain services, in particular payment services, may be subject to identity and compliance checks, which may include:

Email verification;

SMS verification;

OTP authentication;

Device check;

Collection of an identity document;

A selfie or video;

Proof of address;

Proof of activity;

Information on the source of funds;

Any additional information reasonably required.

Such checks may be renewed at any time during the relationship when required by law, risk considerations or the Financial Partner.

3.5 Refusal, Suspension or Restriction

Winble and/or the Financial Partner may refuse, suspend, defer or restrict all or part of the Service in the event of non-eligibility, insufficient information, failure of checks, suspicion of fraud, regulatory constraint, asset freezing, international sanctions, security issues or risk.

4. Subscription, Pricing and Hybrid Economic Model

4.1 Principle

The Digital Pack Service is provided in the form of a tacitly renewing digital subscription, distinct from the regulated payment services provided by the Financial Partner.

4.2 Winble Pricing

Unless a specific promotional offer is displayed prior to validation, the pricing terms applicable to the Winble Service shall be those presented to the User during the subscription process, in the offer sheet, the pricing sheet, or any other pre-contractual document applicable on the date of subscription.

Prices are stated in euros, inclusive of all taxes (VAT included), at the applicable VAT rate in force on the date of subscription, determined in accordance with the tax rules applicable to the place of taxation of the service.

The total amount inclusive of taxes actually payable by the User shall be summarised before the subscription is validated. Where required or permitted by applicable regulations or billing arrangements, the amount excluding taxes and the amount of VAT applied shall also be indicated on the invoice or on any supporting document made available.

Any change in the applicable VAT rate or in the tax rules determining the place of taxation of the service may automatically be reflected in future payment periods as from the date on which such change comes into force.

Only the items expressly displayed as included in the offer sheet in force on the date of subscription shall be contractually due as of that date.

4.3 Fees Separate from the Financial Partner

The price of the Winble subscription covers the non-regulated services included in the subscribed plan.

The Visa card, payment account, dedicated IBAN and certain associated regulated services may give rise to separate fees, independent from the price of the Winble subscription, in accordance with the Financial Partner’s contractual documentation and fee schedule.

The User expressly acknowledges that:

The Winble subscription remunerates the Digital Pack Service operated by BLEU BLANC PAY;

The fees relating to the payment account, the Visa card and regulated services fall under the Financial Partner;

These two pricing components are legally and economically distinct.

In the event of failure, refusal, abandonment or impossibility to complete the identity verification or compliance process required by the Financial Partner, the User may, for a maximum period of thirty (30) days from notification of such failure, retain access solely to the non-regulated components effectively available, including access to the application, content, promotional benefits, reward pot programs and partner services that can be activated without a payment service.

The regulated payment services, including in particular the payment account, the IBAN, the Visa card and the functionalities directly depending on them, are then neither opened, nor activated, nor due by BLEU BLANC PAY.

At the end of this transitional period, and unless the process required by the Financial Partner has been validated in the meantime, the User may, as the case may be:

Maintain a plan limited to the non-regulated components, if such plan exists and is offered in the current pricing grid;

Request a switch to a suitable lower-tier plan;

Or terminate the relevant plan for the future without charge.

No debit for a plan including a non-activated regulated component may occur beyond this transitional period, unless the User has expressly agreed to maintain a plan limited to the non-regulated components.

For plans including only non-regulated digital components in addition, where applicable, to payment services, no partial refund shall be due solely because the payment services were not activated, provided that the non-regulated components of the plan remained accessible in accordance with the offer sheet.

Conversely, where the plan includes a physical component expressly identified as included and such component was not delivered due to the definitive failure of the KYC process before its issuance, personalisation, dispatch or handover to the User, the fees specifically charged for that undelivered component shall not be due or, if paid in advance, shall be refunded.

Where the offer sheet expressly provides that a regulated component or a physical medium constitutes an essential, immediate and determining element of a higher-tier plan, and that component ultimately cannot be provided before any substantial activation of the other components of that plan, the User shall benefit, for the future, either from a switch to a suitable lower-tier plan or from a partial refund corresponding to the price difference between the two plans for the unperformed period.

In any event, failure of the KYC process gives no right to the regulated services refused by the Financial Partner and does not, by itself, entitle the User to an automatic full refund of the Winble subscription where non-regulated services have been activated or remain accessible.

4.4 Services Offered as an Option or from a Deferred Date

Where a benefit, product or service is presented as:

“Optional”;

“Included from [date / month]”;

“Available from a specified date”;

“Available within the maximum period indicated in the offer sheet”;

Or “subject to activation”.

its actual access shall only occur upon operational availability and, where applicable, following payment of the corresponding supplement, validation of the KYC process, technical activation or acceptance of the applicable specific terms and conditions.

The temporary unavailability of a service presented as future or deferred shall not constitute a contractual breach where it was clearly brought to the User’s attention before subscription, with an indication of an availability date or a maximum availability period, and where that service was not presented as immediately available. Where such component constitutes an essential and determining element of the subscribed offer, the User shall benefit, as the case may be, from an equivalent service, a price adjustment or a right to terminate for the future without charge.

4.5 Price Changes

Any price change shall be notified on a durable medium with reasonable notice and shall not apply before the next due date. The User may terminate before it takes effect if the change is unfavourable to the User.

5. Payment Account and Visa Card

5.1 Regulated Provider

The regulated payment services are not provided by BLEU BLANC PAY in its own name, but by Wallester AS, within the limits set out in its contractual documentation.

Funds are at no time held by BLEU BLANC PAY.

5.2 Opening of the Payment Account

Where the product so provides, an individual payment account with a dedicated IBAN may be opened in the User’s name after validation of the checks required by the Financial Partner.

5.3 Nature of Funds

The funds held in the payment account fall under the Financial Partner and the regulatory framework applicable to it. They do not constitute a standard interest-bearing bank account opened with BLEU BLANC PAY.

Funds are at no time held by BLEU BLANC PAY.

5.4 Visa Card

The User may benefit, depending on the selected offer and subject to eligibility, from a virtual and/or physical Visa card.

The card may only be used for the purposes provided in the applicable documentation, within the limits of available funds, the set limits, risk restrictions, Visa network rules and applicable laws.

5.5 Activation

The card may only be used after activation according to the flow indicated in the application or in the interface made available.

5.6 Limits and Restrictions

Payments, withdrawals, online transactions, contactless transactions, top-ups and other transactions related to regulated payment services may be subject to limits, security thresholds, usage restrictions or operational limitations defined by the Financial Partner in accordance with its contractual documentation, applicable regulations and program risk parameters.

Such information may, where applicable, be displayed, relayed or made configurable via the Winble application, without BLEU BLANC PAY acting as a payment services provider.

5.7 Strong Customer Authentication

Certain transactions or access events may require strong customer authentication, notably through OTP, local biometrics, in-app validation or any other mechanism compliant with applicable law.

5.8 Refusal of a Transaction

A transaction may be refused in particular in the event of:

Insufficient funds;

Limit exceeded;

Authentication failure;

Geographical, technical or merchant restriction;

Suspicion of fraud;

AML/CFT control;

Blocking, suspension or closure of the card or account.

5.9 Transaction History and Statements

The User may consult the history of transactions according to the methods made available in the Winble application, the partner environment or any other intended channel.

5.10 Disputes

Without prejudice to the mandatory rights granted to the User by the regulations applicable to payment services, disputes relating to payment transactions, unauthorised transactions, cards, top-ups, blocks and chargebacks are handled in accordance with the Financial Partner’s documentation, Visa rules and the applicable mandatory legal provisions.

Without prejudice to the Financial Partner’s documentation, the User must report any unauthorised or incorrectly executed transaction without undue delay and no later than thirteen months after the debit date. In the event of an unauthorised transaction, reimbursement shall occur under the conditions and within the time limits provided by the law applicable to the Financial Partner.

Before opposition is made, the User’s liability is limited under the conditions provided by law, except in the event of fraud, intentional misconduct or gross negligence. Proof of authentication, recording of the transaction and the absence of technical malfunction lies with the payment services provider.

5.11 Fate of Funds upon Termination or Closure of the Payment Account

Termination of the Winble subscription alone does not, in itself, automatically result in closure of the payment account opened with the Financial Partner, unless otherwise indicated in the subscription flow, in the Financial Partner’s applicable documentation or requested expressly by the User.

In the event of closure of the payment account or termination of the framework agreement for payment services, the funds available in the payment account are not retained by BLEU BLANC PAY. They remain managed by the Financial Partner and are returned or transferred by it in accordance with its contractual documentation and applicable regulations.

For this purpose, the User may be required to provide an external bank account opened in the User’s name or otherwise validly accepted by the Financial Partner in order to enable the transfer of the available balance. The Financial Partner may apply the necessary security, compliance, anti-money laundering, sanctions and consistency checks before any transfer.

Before restitution or transfer, the balance may in particular be reduced by transactions still pending settlement, sums still due in respect of the account or regulated services, contractually applicable fees, and any sum the blocking, withholding or temporary retention of which is imposed by law, by a security measure, by a dispute or fraud process, or by a regulatory obligation.

The remaining net balance, after clearance of the applicable transactions, fees, withholdings or obligations, shall be transferred or returned by the Financial Partner under the conditions and within the time limits set out in its contractual documentation and applicable regulations.

6. Payment Wearable

6.1 Definition and Function

The wearable is a connected payment medium, such as a ring, bracelet or any other compatible object, which may be associated with a card or an eligible payment method accessible within the Winble ecosystem.

The wearable constitutes a medium for accessing a payment method and not a standalone account. It does not constitute a deposit, a separate payment account or a payment instrument independent from the card or service to which it is linked.

6.2 Activation and Pairing

Use of the wearable requires, depending on the case:

Holding an eligible subscription plan;

Holding an eligible card or payment method;

Actual availability of the wearable in the subscription country;

Operational availability of the service on the subscription date;

Technical compatibility of the wearable, the application and the relevant partner;

Pairing of the wearable with the compatible payment method;

Completion of the required security, authentication or compliance checks.

Where the wearable is presented as “optional”, “included from [date/month]”, or available from a specified date or within the maximum period indicated in the offer sheet, its activation is only possible from its actual commercial and technical launch date. In all cases, the User is informed of the availability date or the applicable maximum period before subscription.

6.3 Pocket / Vault Security Model

For security reasons, transactions carried out by means of the wearable may be subject to a sub-limit distinct from that of the main card, called “Pocket”, “Vault” or any other functional designation chosen by Winble.

Unless otherwise indicated in the application:

The wearable may only use the amount or limit allocated to that sub-limit;

That limit is distinct from the overall limit applicable to the main card;

Any transaction exceeding the contactless single transaction limit, the sub-limit allocated to the wearable or the applicable security thresholds may be refused, require stronger authentication or require prior action in the application.

The limits applicable to the wearable, the Pocket or the Vault are indicated in the application, the pricing grid or the product documentation in force on the date of use.

6.4 Service Dissociated from Ownership of the Medium

The fact that the User owns the wearable and, where applicable, the associated physical card does not grant any autonomous right to the maintenance, continuation or reactivation of the payment service attached to those media.

The payment service associated with the wearable remains subject to:

The validity of the user account;

The validity of the underlying card or payment method;

The continuation of the relevant program;

The User’s eligibility;

Compliance with security, compliance and regulatory requirements;

The continuation of the technical and contractual relationships with the Financial Partner and the wearable provider.

Accordingly, the wearable or the physical card may remain materially in the User’s possession while becoming unusable as soon as the associated service is suspended, blocked, closed, expired, replaced or deactivated.

6.5 Loss, Theft, Compromise or Unauthorised Use

In the event of loss, theft, suspected loss, compromise, unauthorised pairing or fraudulent use of the wearable, the associated card or the phone used to manage the service, the User must:

Immediately deactivate the wearable from the application, where this functionality is available;

Request without delay that the wearable and/or the associated card be blocked, as the case may be;

Contact Winble support and, if necessary, the Financial Partner;

Make such report immediately and, in any event, as soon as possible after becoming aware of the incident.

The User acknowledges that any delay in reporting may prevent rapid blocking of the medium or the associated payment method and increase the risk of unauthorised transactions.

6.6 Liability and User Security Obligations

The User is responsible for:

Physical safekeeping of the wearable;

Protecting the phone, application, codes, OTPs, passwords, local biometric data and other authentication means;

Proper use of the activation, deactivation, suspension or opposition functions made available;

Compliance with the security instructions communicated by Winble, the Financial Partner or the relevant provider.

Subject to the applicable mandatory legal provisions, in particular regarding unauthorised payment transactions, Winble may not be held liable for the consequences of loss, theft, delayed reporting, gross negligence or use of the wearable, the associated card or the authentication means in a manner contrary to instructions.

6.7 Ownership of Physical Media

Unless expressly stated otherwise in the documentation applicable to a specific product or service, the wearable and, where applicable, the physical card handed over to the User become the User’s property upon handover or delivery.

Such ownership is strictly limited to the physical medium itself. It does not entail any transfer of ownership over:

The user account;

The payment account;

The IBAN;

The payment token;

The application functionalities;

The payment service;

The intellectual property rights attached to the card, the wearable, the application or the program.

The User may under no circumstances modify, alter, divert, reproduce, market, recondition, resell as an active payment medium, or otherwise use without authorisation a wearable or physical card whose associated service has been suspended, blocked, closed, expired, replaced or deactivated.

6.8 End of Service, Mandatory Deactivation, Replacement and After-Sales Service

In the event of termination of the contract, termination of the program, closure of the account, blocking of the service, replacement of the card or wearable, end of compatibility or any other cause rendering the service unavailable, the User undertakes to:

Immediately cease any use of the relevant physical card for payment transactions;

Deactivate, neutralise or destroy the medium that has become unusable, according to the instructions provided, where such measure is required for reasons of security, fraud, compliance, regulation or proper program management;

Not attempt to reactivate, circumvent, divert or use an invalid, blocked, expired, replaced, closed or deactivated medium.

Replacement, reissuance, reactivation, delivery, after-sales service and the handling of material defects of the wearable fall, as the case may be, under Winble, the Financial Partner or the wearable provider, in accordance with the applicable documentation.

Replacement, reissuance, shipping, handling or reactivation fees may be charged in accordance with the applicable pricing grid.

6.9 Legal Conformity Guarantee for the Wearable and Physical Media

Where the wearable or any other physical medium is sold or provided by BLEU BLANC PAY to a consumer, it benefits from the legal conformity guarantee under the conditions provided by the French Consumer Code.

BLEU BLANC PAY is liable for any lack of conformity existing at the time of delivery of the good and appearing within the legal time limit applicable from that time.

The consumer may, under the legal conditions, request that the good be brought into conformity by repair or replacement or, failing that, obtain a price reduction or resolution of the contract where the legal conditions are met.

This legal guarantee covers the physical medium itself. It does not cover the unavailability, suspension, closure, refusal of activation or deactivation of the underlying payment service or payment account where the physical medium is itself compliant.

Where the physical card is issued, personalised or provided by the Financial Partner, requests relating to its material defects, replacement or reissuance are handled according to the latter’s applicable documentation, without prejudice to the consumer’s mandatory legal rights.

6.10 After-Sales Service, Material Defect and Exclusions

Any apparent material defect, manufacturing defect, pairing anomaly attributable to the medium, non-receipt, abnormal deterioration not attributable to the User, or malfunction of the wearable must be reported to Winble support as soon as possible, together with any useful element enabling the nature of the issue to be assessed.

Depending on the case and the role of the relevant entity, BLEU BLANC PAY, the wearable provider or the Financial Partner shall examine the request and implement conformity, replacement, reissuance or any other appropriate measure.

The following do not fall within after-sales service in respect of a conformity defect:

Normal wear and tear;

Breakage, loss, theft or damage resulting from abnormal use, impact, immersion, unauthorised modification or lack of maintenance;

Incompatibility with a technical environment that does not meet the communicated prerequisites;

Inability to use the medium due to suspension, expiry, replacement or closure of the underlying payment method or account;

Termination of the program or of a functionality for regulatory, technical or security reasons.

These provisions apply without prejudice to the mandatory legal guarantees from which the consumer benefits.

7. Gift Vouchers, Immediate Discount and Reward Pot

7.1 Purchase of Vouchers and Retail Cards

The User may purchase, through the platform, gift vouchers, e-gift cards, codes or similar products from partner retailers.

Gift vouchers and retail cards are merchant or partner products distinct from the regulated payment service.

7.2 Pre-Contractual Information

Before purchase, the platform displays, as the case may be:

The retailer’s name;

The face value;

The price paid;

The immediate discount or associated reward pot;

The validity period;

The channel of use;

Any exclusions;

Any limits;

The merchant’s specific conditions.

7.3 Immediate Discount

Where the offer so provides, the discount is deducted immediately from the price paid at the time of the order.

7.4 Reward Pot

Depending on the subscribed plan and the relevant program, the User may benefit from:

A reward pot on purchases made with partner merchants;

A reward pot on the purchase of gift vouchers or e-gift cards;

A reward pot on purchases made with the Winble card or wearable;

A promotional reward pot credited according to the rules of the applicable program.

Rates and limits may vary depending on the subscription plan and the relevant channel. The exact details of the eligibility rules, exclusions, limits and crediting periods are displayed on the platform or in the sheet for the relevant program.

7.5 Use and Validity

Gift vouchers and retail cards are subject to the partner merchant’s conditions. The User is solely responsible for using them before expiry.

7.6 Personal Use and Prohibitions

Gift vouchers, retail cards, discounts and reward pots are intended for personal use. They may not be resold, assigned for consideration, converted into cash, exchanged for credit, or used in an abusive, fraudulent or circumvention-based manner.

For the purposes hereof, abusive use means any behaviour by the User having the purpose or effect of diverting the normal purpose of the program, improperly obtaining a discount, reward pot or benefit, or circumventing the applicable conditions, including, in particular, through artificial multiplication of transactions, irregular creation or use of accounts, purchases followed by repeated cancellations, use contrary to the program conditions, prohibited resale, or more generally any abnormal, fraudulent or offer-purpose-diverting practice.

7.7 Recovery or Cancellation of a Benefit

Winble may cancel or recover all or part of a discount, reward pot or promotional benefit in particular in the event of:

Refund;

Cancellation;

Dispute or chargeback;

Fraud;

Abusive use as defined herein;

Credit error;

Non-compliance with the conditions of the relevant program.

8. Partner Services and Exclusive Content

8.1 Principle

Depending on the subscribed plan, Winble may include or enable the activation of third-party partner services, notably in the areas of press and editorial content, well-being, sports and coaching, relaxation and personal development, music and audio, content intended for children, entertainment and digital reading content, cybersecurity and browsing protection, as well as any other digital service compatible with the offer available on the platform.

Such third-party services may, depending on the offer in force and subject to their availability, their effective integration into the platform and the execution of the necessary agreements with the relevant partners:

Be included only in certain plans;

Be offered as an option or additional service;

Be activated at the User’s request;

Be made available from a specified date or within the maximum period indicated in the offer sheet;

Be replaced by equivalent or comparable services.

The nature, scope, functionalities, duration of access and activation conditions of these services may vary depending on the selected plan, the User’s profile, the relevant geographical area, the applicable technical constraints and the conditions defined by the third-party partners.

In addition, depending on the selected plan, the User may benefit from access to exclusive content linked to the community or environment associated with the offer, which may include different levels of access, a variable monthly volume of content, and specific benefits or functionalities determined by the subscribed plan.

Winble does not guarantee the permanent availability, unchanged identity or continued availability in identical form of the partner services or exclusive content presented, which may evolve, be suspended, withdrawn or modified at any time, in particular in the absence of contracting, upon termination of a partnership, or due to regulatory, technical or commercial constraints.

8.2 Partners’ Own Conditions

Each partner service remains subject to its own terms of use, technical restrictions, eligibility criteria, territorial rules and privacy policies.

8.3 Activation Terms

Access to a partner service may require:

An activation code;

An onboarding link;

Federated authentication;

Creation of a dedicated account;

Acceptance of the partner’s terms and conditions.

8.4 Evolution of Partner Services

Winble may suspend, withdraw, modify or replace a partner service in the event of the end of a partnership, unavailability, regulatory constraint, change in the economic model or replacement by an equivalent or comparable service, provided that such evolution is based on a valid reason and is brought to the User’s attention in accordance with these Terms.

Unless a technical, regulatory, legal or security impossibility requires faster interruption, any partner service presented as included in a paid plan shall be maintained at least until the end of the current subscription period upon its activation or renewal.

Where the evolution affects an accessory or non-determining partner service of the plan, Winble may substitute an equivalent or comparable service without additional cost to the User, subject to clear and understandable prior information.

Where the removal or modification of a partner service substantially affects the balance of a paid plan or concerns an essential and determining element thereof, the User shall be informed, reasonably in advance, of the effective date of such evolution and shall benefit, as the case may be, from an equivalent or comparable service, a price adjustment, or the right to terminate the relevant plan for the future without charge.

8.5 Liability

Winble is responsible for the contractual provision of the access promised in its offer, within the limits of its own scope. The third-party partner remains solely responsible for the provision of its own service.

8.6 Legal Conformity Guarantee for Digital Services

BLEU BLANC PAY provides, within its own scope, the digital content and digital services included in the offer in compliance with the applicable legal conformity requirements.

Where digital content or a digital service is provided on a one-off basis or through a series of separate operations, BLEU BLANC PAY is liable for any lack of conformity existing at the time of supply and appearing within the legal period applicable from that time.

Where digital content or a digital service is provided continuously for a specified period, BLEU BLANC PAY is liable for any lack of conformity appearing during the period in which it is supplied under the contract.

In the event of lack of conformity, the consumer may obtain conformity of the digital content or digital service or, failing that, a price reduction or termination of the contract, under the conditions provided by law.

This legal guarantee applies to non-regulated digital services falling within BLEU BLANC PAY’s scope. It does not extend to regulated payment services provided by the Financial Partner within its own scope, nor to the actual performance of services provided by third-party partners, without prejudice to BLEU BLANC PAY’s obligation to ensure the contractual provision of the access promised in its offer.

9. Security, Opposition and Liability

9.1 Security of the Account and Means of Access

The User is responsible for the confidentiality of the User’s identifiers, passwords, OTPs, devices, local biometrics, card data, authentication secrets and, more generally, any means enabling access to the Service.

9.2 Vigilance Obligations

The User undertakes in particular to:

Protect the User’s equipment;

Not disclose codes to third parties;

Report any compromise without delay;

Use the Service in accordance with the law and these Terms;

Not attempt to circumvent limits, restrictions or anti-fraud mechanisms.

9.3 Prohibited Uses

The following are notably prohibited:

Any unlawful use;

Any fraud or attempted fraud;

Creation of multiple accounts;

Mass automation;

Abuse of the reward pot;

Unlawful resale of vouchers;

Use of the Service on behalf of a third party without authorisation.

9.4 Opposition and Reporting

Any loss, theft, compromise or unauthorised use of the account, card, wearable or phone must be reported immediately.

9.5 Unauthorised Payment Transactions

In the event of an unauthorised payment transaction resulting from the loss or theft of a payment instrument, the User’s liability before opposition is limited under the conditions provided by applicable law, except in the event of fraud by the User or intentional or grossly negligent breach of the User’s security obligations.

9.6 Winble Liability

Subject to the applicable mandatory provisions, Winble is only liable for direct, foreseeable and certain damage resulting from a breach personally attributable to it.

In particular, Winble is not liable for:

Network or service interruptions attributable to third parties;

Partner merchants;

Third-party partner services;

The Wearable Provider;

The Financial Partner in respect of regulated services falling within its own scope;

Refusal by a merchant to accept a payment method;

Improper use by the User of the account, the card or the wearable.

No provision herein is intended to exclude or limit liabilities that cannot legally be excluded, in particular in cases of fraud, wilful misconduct, gross negligence, bodily harm, or breach of mandatory legal obligations.

Winble is responsible for its own service of providing the access promised in the offer, within the limits of its own scope.

9.7 Force Majeure

No party may be held liable in the event of force majeure within the meaning of applicable law.

10. Anti-Money Laundering, Sanctions and Asset Freezing

10.1 AML/CFT Controls

Winble and its partners may implement any useful measure in relation to anti-money laundering, counter-terrorist financing, fraud prevention, sanctions circumvention, promotional abuse and risky behaviour.

10.2 Supporting Documents and Risk-Related Restrictions

The User acknowledges that access to the card, payment account, top-ups, transactions and certain services may be limited or refused if the User’s profile, country, activity, use or transactions do not fall within the Financial Partner’s acceptance criteria.

The Financial Partner applies a risk and compliance policy including, in particular, country restrictions, KYC/AML requirements, controls on the source of funds, transaction limits, and anti-fraud monitoring rules in real time and on a deferred basis.

10.3 Protective Measures

In the event of reasonable doubt, alert, report, risk, legal obligation or asset freezing, Winble or the competent partner may, within their respective scopes:

Suspend a transaction;

Defer a credit;

Refuse a top-up;

Block a card;

Block an account;

Deactivate a wearable;

Cancel a reward pot;

Freeze funds where required by law;

Suspend or terminate the business relationship.

10.4 No Detailed Statement of Reasons

Where the law permits or requires, Winble and/or the Financial Partner may refrain from communicating in detail the reasons for a refusal, suspension, block or report.

11. Personal Data, History and Portability

11.1 Allocation of Roles

BLEU BLANC PAY processes the data necessary for operation of the platform, subscriptions, gift vouchers, promotional benefits, customer support and non-regulated services.

The Financial Partner processes, within its own scope, data relating to regulated payment services, KYC, payment transactions, fraud, disputes and regulatory obligations.

Third-party partners process, within their own scope, data relating to the services they provide.

11.2 Purposes

Personal data is processed for:

Account creation and management;

Performance of the contract;

Provision of the Service;

Payment management;

Fraud prevention;

Regulatory compliance;

Customer relationship management;

Improvement of the Service;

Sending communications where the legal basis allows it.

11.3 Portability

The User may exercise, where the legal conditions are met, the User’s right to portability with respect to the data provided by the User and, where applicable, certain observed data arising from use of the Service, excluding derived, inferred or internally analysed data, unless otherwise provided by law.

In this respect, the User may request that the data provided by the User be communicated in a structured, commonly used and machine-readable format, such as CSV, JSON or any other technically equivalent format allowing reuse, as well as, where the right to portability applies, available data relating to the User’s usage or transaction history falling within the relevant scope.

BLEU BLANC PAY shall respond to the request as promptly as possible and, in any event, within a maximum period of one (1) month from receipt. This period may be extended by an additional two (2) months due to the complexity of the request or the number of requests received, provided that the User is informed within the initial one (1)-month period.

11.4 Rights

The User has, under the applicable legal conditions, a right of access, rectification, erasure, objection, restriction, portability and the right to define instructions relating to the fate of the User’s data after death.

These rights may be exercised in accordance with the procedures set out in the Privacy Policy and, where applicable, with the controller responsible for the relevant service scope.

11.5 Privacy Policy

Detailed arrangements relating to processing, retention, transfer and the exercise of rights are set out in the Privacy Policy.

Personal data is retained for the period necessary to achieve the purposes for which it was collected, and may then, where applicable, be archived for the applicable limitation, evidentiary, accounting, tax, regulatory or litigation periods.

Depending on the organisation of the services, the identity of the service providers used and the location of the relevant partners, certain data may be processed within the European Economic Area or transferred to a third country.

Any transfer outside the European Economic Area shall take place in compliance with the applicable regulations and on the basis of a recognised transfer mechanism, such as an adequacy decision, standard contractual clauses approved by the European Commission, binding corporate rules or any other legally permitted mechanism.

The User may obtain additional information on transfers concerning the User and, where applicable, a copy or reference of the appropriate safeguards implemented, according to the procedures described in the Privacy Policy.

12. Right of Withdrawal

12.1 Principle

Where the contract is concluded at a distance, the consumer in principle benefits from a fourteen-day withdrawal period, unless a legal exception applies.

12.2 Immediate Commencement of the Digital Pack Service

Where the User expressly requests immediate activation of the Digital Pack Service before the expiry of the withdrawal period, the Service shall begin without delay.

In such case, the User expressly acknowledges:

Requesting immediate performance of the contract;

That certain digital components may be activated and consumed as soon as the subscription is made;

That, for digital content and digital services provided immediately, the right of withdrawal may be lost or limited in the cases provided by law;

That, for the other components of the Service, an amount corresponding to the service already performed up to the withdrawal date may remain due where permitted by law.

12.3 Gift Vouchers, E-Gift Cards and Codes Provided Immediately

Gift vouchers, e-gift cards, codes or digital content provided immediately after payment are deemed to begin being performed as soon as they are made available.

Where the flow so provides, the User expressly acknowledges requesting such immediate supply and waiving the right of withdrawal in the cases provided by law.

12.4 Additional Exclusions or Limitations

Any exclusions, limitations or specific arrangements relating to the right of withdrawal that are specific to a partner service, insurance, a regulated service or a digital product are set out in the documentation applicable to that service.

12.5 Standard Withdrawal Form

In accordance with the French Consumer Code, a standard withdrawal form is attached to these Terms. The User may use that form or any other unambiguous statement expressing the User’s wish to withdraw under the conditions provided in this article.

13. Duration, Suspension and Termination

13.1 Duration

The Winble account is entered into for an indefinite term. The Digital Pack Service subscription is entered into for the period displayed at the time of subscription. Unless otherwise indicated in that offer sheet, the initial term is one (1) month from the subscription date. At the end of the initial term, the subscription is tacitly renewed for successive periods of the same duration, unless terminated under the conditions provided herein.

Where the provisions of the French Consumer Code relating to tacit renewal apply, BLEU BLANC PAY shall inform the User, in writing and on a durable medium, of the option not to renew the subscription, at the earliest three (3) months and at the latest one (1) month before the deadline for opposing renewal. Such information shall state clearly and understandably the deadline by which the User may oppose the renewal.

Failing such information being provided under the conditions laid down by law, the User may terminate the subscription free of charge at any time from the renewal date.

13.2 Termination by the User

The User may terminate the subscription at any time from the User’s account area, where such functionality is available, or by sending the request to:

contact@winble.com

Unless a more favourable legal or commercial provision applies, termination shall take effect at the end of the current period, as indicated in the offer sheet applicable on the subscription date.

Where the subscription is annual or entered into for any other fixed term, termination shall take effect at the end of the current annual period or the current fixed period, unless a more favourable legal or contractual provision applies to the User.

Termination of the Winble subscription alone does not automatically result in closure of the payment account or the card, unless otherwise indicated in the flow, in the applicable documentation or expressly requested by the User.

Where required by law, and in particular where the contract was concluded electronically or can be concluded by that means, termination shall be made possible through the same means.

13.3 Termination by Winble

Winble may suspend or terminate all or part of the Service in particular in the event of:

Proven fraud or attempted fraud;

Security breach affecting the account, the Service or the program;

Legal or regulatory obligation imposing an immediate measure;

Temporary suspension necessary for checks;

Or, with reasonable notice, an evolution of the Service, end of partnership or faultless commercial discontinuation.

13.4 Termination or Closure by the Financial Partner

The Financial Partner may suspend, block or close the payment account, the card or the regulated services in the cases provided by its documentation, applicable regulations or its risk requirements.

13.5 Consequences of the End of the Contract

On the effective end date of the relevant contract or service:

Access to the relevant functionalities ends;

Physical assets (physical card, bracelets and wearables) must cease to be used;

Benefits not definitively acquired may be cancelled;

Amounts due remain payable;

Data is retained in accordance with the applicable legal or regulatory periods.

13.6 Modification of the Terms and the Service

BLEU BLANC PAY may amend these Terms and all or part of the Service in order, in particular, to take into account a legal, regulatory, case-law, technical, security, economic, commercial, operational or anti-fraud development, the evolution of its partners, or the addition, removal or adaptation of a functionality.

Any change adversely affecting the User’s rights or obligations, or any substantial modification of the Service, shall be subject to clear and understandable prior information on a durable medium, within a reasonable period before its entry into force.

The User may, where applicable, terminate for the future under the conditions specified in that notification.

As regards digital content and digital services provided by BLEU BLANC PAY, updates or modifications not necessary to maintain conformity may only be implemented for a valid reason provided for herein, after clear and understandable prior information to the User on a durable medium, stating in particular their effective date. Where such modification negatively affects the consumer’s access to or use of the digital content or digital service in a non-minor manner, the User may terminate the relevant contract free of charge within the period indicated in the notification, unless BLEU BLANC PAY allows the User to retain the digital content or digital service without said modification and without additional cost.

Updates necessary to maintain conformity, security or continuity of the Service may be deployed without giving rise to any specific right other than those provided by law.

14. Complaints, Consumer Mediation and Applicable Law

14.1 Complaints

Any complaint must first be sent to Winble customer support through the following channel:

Support email address: contact@winble.com

Complaints relating to services provided by BLEU BLANC PAY within its own scope are handled by Winble according to its internal procedures.

Complaints relating to regulated payment services, including in particular the payment account, the IBAN, the Visa card, payment transactions, top-ups, transaction disputes, blocks, oppositions and chargebacks, fall under the Financial Partner and are investigated and handled by it in accordance with its complaint procedure, its contractual documentation and the applicable regulations.

BLEU BLANC PAY may, where applicable, intervene solely as a point of contact or first-level support for receipt, transmission or routing of the complaint, without being competent to decide on the merits of complaints falling within the Financial Partner’s regulated scope.

A response shall be provided within the time limits applicable to the relevant provider. In matters relating to payment services, these time limits derive in particular from the sector-specific rules applicable to the competent payment services provider.

14.2 Consumer Mediation

In the event of a dispute between a consumer and BLEU BLANC PAY relating to a service falling within its own scope, in particular non-regulated digital services, the subscription, content, promotional benefits, gift vouchers distributed through the platform, customer support or physical media falling under BLEU BLANC PAY, the consumer must first send a written complaint to customer support according to the terms set out in Article 14.1.

Failing amicable resolution of the dispute, the consumer may refer the matter free of charge to the consumer mediator designated by BLEU BLANC PAY, subject to the admissibility conditions provided by the French Consumer Code.

The details of the competent mediator, effectively designated by BLEU BLANC PAY and listed by the Consumer Mediation Evaluation and Control Commission, are as follows:

La Société Médiation Professionnelle

http://www.mediateur-consommation-smp.fr

Alterités, 5 rue Salvaing, 12000 Rodez

Disputes relating to regulated payment services, including in particular the payment account, the IBAN, the Visa card, payment transactions, top-ups, transaction disputes and chargebacks, fall under the complaint process and, where applicable, the out-of-court dispute resolution mechanism designated by the Financial Partner in its own documentation, and not solely under the mediator designated by BLEU BLANC PAY for its own scope.

14.3 Applicable Law

These Terms are governed by French law.

However, where the User has consumer status and resides in another State, this choice of law may not have the effect of depriving the User of the protection afforded by the mandatory provisions of the law of the State in which the User has the User’s habitual residence, where such provisions apply.

For regulated payment services, the Financial Partner’s documentation may provide for a specific applicable law or jurisdiction, subject to the mandatory protective provisions applicable to the consumer.

14.4 Jurisdiction

In the event of a dispute relating to these Terms, and subject to the mandatory rules applicable to jurisdiction, the consumer may bring proceedings either before the competent courts of the State in which the defendant is domiciled, or before the courts of the State in which the consumer is domiciled.

Where proceedings are brought against a consumer, they shall be brought before the competent courts of the State in which that consumer is domiciled, unless an overriding mandatory provision provides otherwise.

These provisions apply without prejudice to any specific rules that may apply to regulated payment services and to the remedies provided by the Financial Partner’s documentation.

ANNEX – STANDARD WITHDRAWAL FORM

(Please complete and return this form only if you wish to withdraw from the contract.)

For the attention of:

BLEU BLANC PAY

59 avenue Marceau, 75116 Paris

Email address: contact@winble.com

I/We (*) hereby give notice that I/We (*) withdraw from the contract for the sale of the goods (*) / for the provision of the services (*) below:

Ordered on (*) / received on (*):

Name of consumer(s):

Address of consumer(s):

Signature of consumer(s) (only if this form is notified on paper):

Date:

(*) Delete as appropriate.

ANNEX - WALLESTER PAYMENT ACCOUNT AND CARD TERMS AND CONDITIONS

The Wallester Payment Account and Card Terms and Conditions below are incorporated into these Terms for the card, payment account and related payment services provided by Wallester AS. Cardholders must read and accept them together with the Winble Terms before using the card service.

The Wallester document is reproduced in English as supplied by Wallester AS.

1. DEFINITIONS

1.1. The Terms and Conditions use the definitions below:

1.1.1. Agreement means an agreement (separate agreement or part of other services agreement) concluded between the Partner and the Client regarding provision of services to the Client and all its’ appendices;

1.1.2. Authentication is the performance of such operations as enable the Cardholder to be identified and/or the validity of the Card issued to the Cardholder to be established;

1.1.3. Account means a virtual account held in the Wallester System in the name of the Client for the purpose of providing services pursuant to this Agreement;

1.1.4. Means of Authentication means information, objects, attributes, or other means that enables the Cardholder to Authenticate himself, prove the validity of the Card, or authorize Operations (for example, a one-time authentication code, PIN or CVV code);

1.1.5. Authorisation means the process of giving the Cardholder permission to do or have something;

1.1.6. Available Funds means the amount of funds available in the balance for Operations;

1.1.7. Card means a payment instrument that uses the Visa network, issued by Wallester and which the Cardholder may use to perform Operations. The Card can be a Chip&Pin Card or a Virtual Card;

1.1.8. Card Data includes the Cardholder's name, the Card number, validity period and security feature (e.g. CVV code) of the Card;

1.1.9. Cardholder means a person corresponding to Wallester’ requirements and who has been authorized by the Client to use the Card on behalf of the Client. The Client is responsible for any Operations performed by the Cardholder with the Card;

1.1.10. Chip&Pin Card means a physical Card with an electronic chip, requiring a PIN-code as an authorization mean and has a Near Field Communication function. A Chip&Pin Card can be made of plastic, veneer, metal or any other suitable material;

1.1.11. Client means a customer of the Partner with whom the Partner has concluded the Agreement;

1.1.12. Digital Wallet is a service provided by another company (e.g. Apple Pay, Android Pay, Samsung Pay, etc.) that allows to use the Card to complete transactions where the Digital Wallet is accepted;

1.1.13. Imperative Norms are legal provisions contained in legislation that cannot be derogated from by agreement in favour of Wallester;

1.1.14. Near Field Communication (NFC) means technology which can be used for contactless exchange of data over short distances;

1.1.15. Operation means using the Card in a Terminal to pay for goods and/or services, or to obtain information, and/or to withdraw cash if cash withdrawal via Visa card is enabled by service providers other than Wallester, or using the Card for online payment to a merchant providing goods and/or services;

1.1.16. Partner means the contractual partner of Wallester;

1.1.17. Partner's Website means a website operated and managed by the Partner to provide its services to the Client and/or Cardholder;

1.1.18. Partner's Application means an application for a smart device, which is operated and managed by the Partner to provide services to the Client and/or the Cardholder;

1.1.19. Payment Card Terms and Conditions means this document, which stipulates the rights and obligations of Wallester, the Client and/or Cardholder in the provision of services by Wallester to the Client;

1.1.20. Strong Authentication means authentication of the Cardholder based on at least two elements that fall into the following categories: knowledge (something known only to the Cardholder), possession (something possessed only by the Cardholder), or attribute (something peculiar to the Cardholder), which are independent of each other, so that a breach of one of these elements does not compromise the credibility of the other, and the structure of which allows to protect the confidentiality of the authentication data;

1.1.21. Terminal means an ATM, point-of-sales terminal, or any other system (incl. online environment) through which the Cardholder can perform Operations with the Card;

1.1.22. Virtual Card means a Card that consists of digital Card Data, is accessible online and has no physical body;

1.1.23. Visa means the International Card Organization Visa Europe Ltd;

1.1.24. Wallester means Wallester AS (registration number 11812882), the payment services provider, registered office at Ahtri tn 6, 10151 Tallinn, Estonia, which holds activity license No. 4.1-1/224 issued by the Estonian Financial Supervision and Resolution Authority.

2. THE ACCOUNT

2.1. Wallester opens Account in the Wallester System in the name of the Client only for the purpose of carrying out the Operations. All funds added to the Account may be used only for the settlement of the Operations.

2.2. The funds held in the Account are not covered by the Financial Services Guarantee Scheme. The Account is not a checking or savings account and is in no way linked to any other account the Client may have. Client funds are safeguarded in segregated bank accounts and kept separate from Wallester's own funds. The Client will not receive any interest on the funds held in the Account.

2.3. Wallester reflects the Available Funds and history of Operations on the Account. This information is available in the Wallester System or in the Wallester App. Wallester does not charge any fees for this information.

2.4. The Client can add (top-up) funds to the Account by transferring funds from bank accounts bearing the Client's name with a financial institution registered in the EU/EEA or the UK. When adding (topping up) funds to the Account, the Client has to follow the instructions provided in the Wallester System or in the Wallester App. All top-ups are subject to anti-fraud verification procedures, which may delay access to the funds. Wallester reserve the right to reject any request to add funds to the Account at our sole discretion.

2.5. The Client may transfer Available Funds within the Wallester System or the Wallester App to other Wallester Clients, if such option is provided by Wallester. Wallester starts the execution of the Operation immediately after the Client has authorized the Operation.

2.6. Wallester has the right to deduct the fees payable by the Client from the Available Funds in accordance with the Price List established by Wallester. If the Account does not have sufficient Available Funds to cover a fee, the amount of such fee will be deducted from any funds subsequently added to the Account.

2.7. The Client is responsible for all activities and Operations in the Wallester System, in the Wallester App and on the Account.

2.8. In case of any questions, disputes or complaints regarding the Account, the Wallester System or the Wallester App, the Client should contact the Wallester support service support@wallester.com

3. USE OF THE CARD

3.1. Only the Cardholder has the right to perform Operations with the Card.

3.2. Upon issuance of the Card, the Cardholder shall be provided with personal Means of Authentication (e.g. PIN or CVV code), which shall serve as the Cardholder’s signature when performing the Operations. At the Cardholder’s request, Wallester shall have the right to send the Card and the Means of Authentication by post to the address provided by the Cardholder to Wallester.

3.3. Before the Cardholder can use the Card, they must activate it by following the activation instructions provided by Partner. The Card is activated either in the self-service environment on the Partner’s Website or through the Partner's Application. The Cardholder may start performing Operations with the Card once the Card has been activated.

3.4. The Cardholder has the right to perform Operations within the amount and limits established by the Partner.

3.5. When using the Card, the Cardholder is required to use Strong Authentication, except for the limits prescribed for Operations performed with a Near Field Communication device.

3.6. If there is not enough Available Funds available to perform an Operation with the Card, some merchants will not allow the combined use of the Card with other payment methods.

3.7. Wallester starts the execution of the Operation immediately after the Cardholder has authorized the Operation with the Card. Authorization (the Cardholder's consent to perform an Operation) may be performed using the Card or through the acquirer using the Card Data. If the Cardholder has authorized the Operation with the Card, the Cardholder is not entitled to a refund of the Operation, unless the person who provided the corresponding service (for example, the merchant) agrees to refund the amount paid for the Operation.

3.8. At the request of the person servicing the Card, the Cardholder is obliged to present an identity document and consent to the recording of the document's data.

3.9. Wallester has the right to refuse to execute any Operations with the Card if:

3.9.1. the Card is invalid or closed or the use of the Card is blocked;

3.9.2. Wallester's believes that the Operation may violate the law or the terms of this Payment Card Terms and Conditions;

3.9.3. the Card is being used on illegal websites or with payment processors supporting illegal websites, or to purchase illegal goods or services;

3.9.4. the Operation amount and/or limit (including the Operation fees and expenses) exceeds the Available Funds and/or the limit established by Wallester and/or the Partner;

3.9.5. on any other basis arising from the Agreement or this Payment Card Terms and Conditions or legislation.

3.10. Wallester has the right to block the use of the Card until the circumstances have been verified if:

3.10.1. Wallester has become aware of a circumstance on the basis of which it can be reasonably concluded that the Card is available and/or its Means of Authentication are known to a person who is not authorised to use the Card;

3.10.2. the use of the Card may be associated with fraudulent or unlawful activities;

3.10.3. the Client or the Cardholder fails to fulfil its obligations under the Agreement or this Payment Card Terms and Conditions;

3.10.4. there are other grounds for blocking based on the Agreement, this Payment Card Terms and Conditions or legislation.

3.11. If the basis for blocking the Card pursuant to Clause 2.10 does not cease to exist or there is another basis for closing the Card under the Agreement or this Payment Card Terms and Conditions, Wallester has the right to close the Card.

3.12. Unless otherwise provided in the Imperative Norms, Wallester shall not be liable for any damage caused to the Client and/or the Cardholder or any other third party as a result of Wallester blocking the use of the Card or closing the Card in accordance with the Agreement or this Payment Card Terms and Conditions. This shall also apply if Wallester blocks the use of the Card in good faith on the basis of false information.

3.13. Wallester has the right to assume that all the Operations with the Card have been carried out by the Cardholder in accordance with the Cardholder's will, until proven otherwise or until the Cardholder has informed Wallester in accordance with Clause 3.3.

3.14. When using the Card, the fees related to the Operations are also taken into account, including the fee for requesting a limit query and/or viewing the Operation statement via ATM, as well as the additional fees and conversion fees calculated by Visa, etc.

4. SECURITY REQUIREMENTS FOR USING THE CARD

4.1. The Cardholder shall use the Card in accordance with this Payment Card Terms and Conditions including the following requirements:

4.1.1. to make every effort to protect the Chip&Pin Card from mechanical damage, high temperatures, electromagnetic exposure, copying, alteration, etc.;

4.1.2. not to disclose the Chip&Pin Card or the Card Data or the Means of Authentication to any third party, except to the person accepting the payment for the duration of an Operation;

4.1.3. to use the Card only in Terminals marked with the Visa logo or in Internet environments supported by Visa and to follow the instructions of the Terminal or the Internet environment when performing Operations. The instructions written on the Terminal shall be deemed to be correct and given by the Terminal. Wallester shall not be liable for any damage caused by a breach of this Clause of this Payment Card Terms and Conditions;

4.1.4. not to use the Card for illegal purposes and in a manner prohibited by applicable law, including the purchase of prohibited goods and services;

4.1.5. not to store the Card Data or the Means of Authentication on a data carrier;

4.1.6. to immediately report any errors or disruptions hindering the performance of Operations;

4.1.7. to beware of fraud. Wallester will never ask the Client or the Cardholder to provide Wallester with the Card Data or the Means of Authentication by email or phone. Therefore, do not provide anyone with any information about the Card Data or the Means of Authentication if such request is purportedly made on behalf of Wallester;

4.1.8. fulfil other obligations arising from the Agreement or this Payment Card Terms and Conditions or legislation.

4.2. If the Card is unauthorized or misused, or if the Card and/or its Means of Authentication have been lost or stolen or have or may have become known to a third party who is not entitled to use them, the Cardholder is obliged to promptly report the incident to the Partner.

4.3. Upon receipt of the information referred to in Clause 3.2, Wallester shall make every effort to prevent further use of the Card (incl. blocking the Card).

4.4. Wallester and/or any other person servicing the Card has the right to refuse to execute the Operation and/or withhold the Card if the Card and/or its Means of Authentication have been used incorrectly or if Wallester and/or the person servicing the Card has doubts about the user’s identity.

4.5. Wallester shall follow PCI DSS 3.2 requirements and follow the procedures for securing and monitoring access of Cardholder data.

5. VALIDITY OF THE CARD AND ISSUE OF A NEW CARD

5.1. The Card is valid until the last day (inclusive) of the calendar month indicated on the Card.

5.2. After the expiry of the validity period of the Card:

5.2.1. Wallester shall have the right to issue a new Chip&Pin Card (replacement card). The Partner shall inform the Client about the time and/or manner of receiving the new Chip&Pin Card;

5.2.2. the new Virtual Card is not issued automatically. The Client has to submit a new application for the Virtual Card.

5.3. Wallester has the right not to issue a new Card upon expiry of the Card's validity or upon the Client's application for a new Card (replacement card), if the Client and/or the Cardholder has breached any obligation or condition for the use of the Card arising from this Payment Card Terms and Conditions or any other agreement concluded with Wallester, or if the Client or the Cardholder no longer meets the requirements set by Wallester.

5.4. If the Client does not want a new Chip&Pin Card, the Client shall notify the Partner in writing or in another manner accepted by the Partner at least 45 days before the last day of the month indicated on the Card.

5.5. If the Client does not accept the Card and/or the Card is not activated within 3 months from the date of creation of the Card, Wallester has the right to close and destroy the Card without refunding any service charges.

5.6. The Client undertakes not to use the Card and not to allow the Cardholder to use an invalid, closed or otherwise unusable Card, and to physically destroy the Card within 3 days after it became closed or invalid or unusable.

6. DIGITAL WALLET

6.1. An alternative way to use the Card may be the Digital Wallet service. Use of the Digital Wallet is subject to additional terms and conditions and is provided at the sole discretion of Wallester. The Digital Wallet may not be accepted at all locations where the Card is otherwise accepted. The Cardholder may add or remove a Card from the Digital Wallet in accordance with the Digital Wallet provider's instructions.

6.2. Wallester will not charge the Client any additional fees for adding the Card to the Digital Wallet or using the Card in the Digital Wallet. The Digital Wallet provider may charge additional fees for the use of the Digital Wallet.

6.3. Wallester is not a Digital Wallet provider and is not responsible for the provision of the Digital Wallet service or for any failure of the Digital Wallet or inability to use the Digital Wallet for any transaction. Wallester is only responsible for providing secure information to the Digital Wallet provider to enable the use of the Card in the Digital Wallet as requested by the Client.

6.4. The Cardholder is responsible for protecting their mobile device, passwords and other information required to make Operations using the Digital Wallet and is responsible for all transactions made through their mobile device, whether the credentials used are those of the Cardholders or another person.

6.5. In the event of any questions, disputes or complaints in connection with the Digital Wallet, the Client should contact the Digital Wallet provider.

7. ENTRY INTO FORCE, AMENDMENT AND TERMINATION

7.1. The Payment Card Terms and Conditions shall enter into force upon signing the Agreement between the Partner and the Client and shall be concluded for an unspecified term.

7.2. Wallester has the right to unilaterally amend the Payment Card Terms and Conditions. The content of the changes will be communicated to the Client by the Partner by giving the Client at least 2 months' notice thereof. Within these 2 months, the Client has the right to terminate the Payment Card Terms and Conditions with immediate effect and free of charge provided that all the obligations arising from the Agreement and the Payment Card Terms and Conditions have been fulfilled. If the Client has not terminated the Payment Card Terms and Conditions within the period specified above, he shall be deemed to have accepted the amendments.

7.3. Wallester has the right to terminate the provision of services to the Client by giving Client at least 2 months' ordinary notice thereof.

7.4. Wallester has the right to terminate the Payment Card Terms and Conditions as an extraordinary remedy without prior notice if:

7.4.1. the risks associated with the Client are beyond Wallester's risk appetite;

7.4.2. the circumstances stipulated in Clause 2.10 have been verified;

7.4.3. the Card issued hereunder has been closed and/or blocked for at least 4 consecutive months;

7.4.4. the Card expires and the Cardholder fails to accept the new Card from Wallester within the period stipulated in Clause 4.5 (incl. failure to activate the new Card);

7.4.5. the Card has not been used for Operations for 6 consecutive months.

7.5. In addition to the cases stipulated in the Payment Card Terms and Conditions, Wallester has the right to terminate the Payment Card Terms and Conditions as an extraordinary remedy without giving advance notice on other statutory grounds.

7.6. The termination of the Payment Card Terms and Conditions shall not affect the validity of the Agreement concluded between the Partner and Client and the collectability or satisfaction of financial claims arising prior to the termination of the Payment Card Terms and Conditions.

7.7. Termination of the Agreement concluded between the Partner and the Client shall result in immediate termination of the Payment Card Terms and Conditions and blocking of the Card.

8. LIABILITY

8.1. Wallester and the Client and/or the Cardholder shall be liable for breach of their obligations in accordance with the provisions of this Payment Card Terms and Conditions and legal enactments. Wallester shall not be liable for failure to perform Operations if:

8.1.1. if there are insufficient Available Funds to carry out the Operation;

8.1.2. if there is not enough cash in the ATM where the Operation is performed;

8.1.3. if the Terminal where the Operation was performed did not work properly;

8.1.4. if circumstances beyond Wallester's control (e.g. fire, flood, national emergency, computer or communication failure) prevent the Operation from being performed;

8.1.5. if a merchant refuses to accept the Card;

8.1.6. if the Card has been blocked after the Client or the Cardholder has reported the loss or theft of the Card or the Card Data;

8.1.7. if Available Funds are subject of legal proceedings or any other encumbrance restricts their use;

8.1.8. if Wallester has reason to believe that the Operation is unauthorized;

8.1.9. there are other reasons arising from this Payment Card Terms and Conditions or legislation.

8.2. Wallester shall not be liable for third parties involved in performing Operations, for goods or services paid by the Card, and in cases where acceptance of the Card for the performance of an Operation is refused.

8.3. If an unauthorized payment has been made using the lost or stolen Card and/or the Means of Authentication, or if the Card and/or the Means of Authentication have been used in any other unlawful manner, and if the Cardholder has not properly stored the Card and/or the Means of Authentication, and if there are no legal circumstances excluding liability, the Client and the Cardholder shall be liable for any damage caused until the acceptable notification to Wallester, but not exceeding the amount of 50 euros. This amount limit shall not apply if the unauthorized payment is due to fraud on the part of the Client or the Cardholder, or if the Client or the Cardholder has intentionally or grossly negligently breached the following:

8.3.1. the obligation to use the Card and/or the Means of Authentication in accordance with this Payment Card Terms and Conditions on its issuance and use, including the obligation to make every effort to protect the Card and/or the Means of Authentication enabling its use from the moment of receipt of the Card and/or the Means of Authentication;

8.3.2. the obligation to report the loss, theft and unauthorized or improper use of the Card and/or the Means of Authentication immediately after becoming aware of the relevant incident;

8.3.3. one or more conditions for issuing or using the Card and/or the Means of Authentication.

8.3.4. The Partner shall be solely liable to the Client and the Cardholder for the performance of the Partner's obligations. Wallester shall in no case be liable for the Partner if the Partner fails to fulfil its contractual obligations.

9. WALLESTER’S RIGHTS IN PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING

9.1. In preventing money laundering and terrorist financing, Wallester shall have the following rights:

9.1.1. to request additional information about the Client and/or the Cardholder, their representatives, owners and ultimate beneficial owners and the Client’s business activities, incl. data on the origin of the wealth of the Client and their beneficial owners, on their contractual partners, turnover, the share of cash and non-cash transactions, frequency of transactions, etc.;

9.1.2. periodically verify the information forming the basis for the identification of the Client and/or the Cardholder and request the Client and/or the Cardholder to submit additional documents;

9.1.3. to identify the Client, the Cardholder and/or the beneficial owner at any time chosen by Wallester, especially, if Wallester has doubts about the accuracy of the information obtained during the initial identification;

9.1.4. to impose temporary or permanent restrictions on Operations;

9.1.5. to request documents and information about the activities of the Client and/or the Cardholder, including information about the purpose and nature of the transaction and the origin of the Client’s assets;

9.1.6. to request the Client documents that form the basis of a transaction, including information or documents about the counterparty to the transaction, the beneficial owner, or other persons involved in the transaction;

9.1.7. to request the Client and/or the Cardholder to provide any other information and to take any other action Wallester deems necessary to implement its anti-money laundering and counter-terrorist financing measures.

9.2. Wallester has the right to refuse to provide services to the Client or to issue a Card and/or to execute Operations if the Client and/or the Cardholder fails to comply with the requirements set out in Clause 8.1.

10. INFORMATION AND SUBMISSION OF COMPLAINTS

10.1. Where necessary, Wallester shall provide the Client, through the Partner, with a statement of the Cardholder's operations and related expenses in the self-service environment on the Partner's Website.

10.2. The Client or the Cardholder is obliged to check the correctness of the performed Operations. Complaints regarding unauthorized and/or improperly executed Operations shall be raised without undue delay, but no later than within the time limit provided for by the applicable legislation, in a format that allows for written reproduction.

10.3. If the Client or the Cardholder has authorized the Operation without knowing the exact amount, the Client has the right to file a complaint to or claim refund of the Operation amount directly from the recipient of the payment resulting from the Operation, instead of Wallester.

10.4. All other complaints and disputes between the Client and Wallester shall be settled by negotiation. If Wallester and the Client fail to reach an agreement with negotiations, the dispute shall be settled by the court of the place where Wallester has its registered office.

10.5. The Client agrees that the contractual relations arising from these Payment Card Terms and Conditions shall be governed by the laws of the Republic of Estonia and that disputes shall be settled by the Estonian court, unless it conflicts with Imperative Norms.

11. CONDITIONS FOR IDENTIFICATION OF PERSONS AND VERIFICATION OF DATA BY MEANS OF INFORMATION TECHNOLOGY

11.1. these terms and conditions shall be applied by Wallester to the establishment of a business relationship by means of information technology. The identification of the person and the verification of the data do not oblige Wallester to establish a business relationship or to guarantee the availability of the services;

11.2. identification of the person and verification of the data by means of information technology shall be carried out in accordance with the procedure provided for in Section 31 of the Money Laundering and Terrorist Financing Prevention Act of Estonia;

11.3. By using information technology means for identification of person and verification of data, the Client and/or his/her representative hereby acknowledges that he/she has read and understood the following:

11.3.1. he/she performs these activities in person;

11.3.2. he/she does not provide false, misleading, or incomplete information;

11.3.3. he/she has read the information on the use of information technology means on the Wallester Website and agrees with the identification of the person and the verification of the data using means of information technology;

11.3.4. he/she agrees with the application of Estonian law to the identification of person and verification of data

12. FINAL PROVISIONS

12.1. Wallester and the Client agree not to disclose any information relating to the conclusion or performance of this Payment Card Terms and Conditions to any third party, unless this is necessary for the processing of the Card or the Operations or has been agreed herein. Wallester shall have the right to process relevant data in order to provide the service to the Client and/or the Cardholder in accordance with this Payment Card Terms and Conditions.

12.2. Wallester has the right to disclose information about Operations, the Card, the Client and/or the Cardholder to third parties whose right to receive information arises from legal enactments and/or Wallester’s principles of processing client data.

12.3. The specific terms and conditions for processing of personal data are stipulated in the Privacy Policy available on Wallester's website.

12.4. Supervision over Wallester’s activities shall be carried out by the Estonian Financial Supervision and Resolution Authority (address: Sakala 4, 15030 Tallinn, telephone: +372 66 80 500, e-mail: info@fi.ee, website: www.fi.ee).