LemFi Global Accounts

1. Introduction to LemFi

1.1 When the word "LemFi" is used in these terms, this means Rightcard Payment Services Limited, a private limited company incorporated in England and Wales (company number: 09163262), with its registered address at The Jellicoe - 5 Beaconsfield St, London N1C 4EW. LemFi operates the website at https://www.lemfi.com/. References to "us", "we" and "our" mean Rightcard Payment Services Limited, trading as LemFi.

1.2 How you can contact LemFi:


Email	contact@lemfi.com
In-app messaging	Via the customer support function in the LemFi app, available at any time.
Telephone	+44 204 579 5921 (available seven days a week)

1.3 LemFi is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 (FCA register reference 900424) for the issuing of electronic money. Depending on the market in which you are registered, your Global Account may be provided by LemFi's affiliated entities as set out in section 2.3 below. The entity providing your account will be the entity responsible for the obligations set out in these terms in respect of that account.

1.4 "You" and "your" in these terms means you, being the individual who wishes to use LemFi's Global Account services and agrees to comply with LemFi's onboarding requirements and these terms and conditions as amended from time to time.

1.5 How LemFi can contact you:


Post	Using the address LemFi holds for you, as set out in the profile section of the app.
Call or message	Using the telephone number LemFi holds for you, as set out in the profile section of the app.
Email	Using the email address LemFi holds for you, as set out in the profile section of the app.
In-app messaging	Via the LemFi app or another secure messaging channel designated by LemFi.
Security / fraud alerts	LemFi will contact you via one or more of the above methods unless prohibited by law.

It is your sole responsibility to keep your contact details up to date. You can update your details via in-app messaging, telephone or email.

2. The LemFi Global Account — Product Overview

2.1 What is the Global Account? LemFi's Global Account is a multi-currency electronic money account that allows you to hold, send, receive and convert money in a range of currencies. The specific currencies available to you depend on the country in which you are registered with LemFi (your "user country"), as set out in section 2.2 below.

2.2 Wallet availability by user country. The following wallets are available at launch. In addition to any wallet in your home currency, you may create the additional currency wallets listed below without requiring support intervention:

User Country	Issuing Entity	Additional Wallets Available
United States (US)	Pomelo Technology US Inc.	AED, CAD, GBP, KES, NGN
United Kingdom (GB)	Rightcard Payment Services Limited	AED, CAD, KES, NGN
Canada (CA)	Pomelo Technology Canada Ltd.	AED, GBP, KES, NGN
Nigeria (NG)	Rightcard Payment Services Limited	AED, CAD, GBP, USD

The wallet availability mapping is server-configurable. LemFi may update available currencies from time to time without requiring an app update; any material changes will be notified to you in accordance with section 17.

2.3 Issuing entities and settlement rails. Depending on the currency of the wallet, your wallet will be issued and safeguarded in different financial institutions.[^1]

2.4 What can you do with the Global Account? LemFi's Global Account services allow you to:

create and hold wallets in your available currencies (within the mapping set out in section 2.2);
fund each wallet using the methods available for that currency and user segment (bank transfer, incoming payment, or such other methods as LemFi makes available);
exchange money between your wallets across the supported FX pairs (see section 14);
send money to other LemFi users;
send money in various currencies to bank and mobile money accounts in countries supported by LemFi (see the app for the current list of supported corridors);
receive money from friends, family, employers or customers;
view wallet balances and transaction history via the LemFi app;
send and receive GBP payments in the United Kingdom using the Faster Payments Scheme;
send and receive EUR payments using SEPA (where applicable to your account).

2.5 Third-party wallets. You may also be able to access, via the app, wallets provided by third-party providers (for example, a Nigerian Naira (NGN) wallet provided by Pagatech). The use of any third-party wallet is subject to that third party's terms and conditions. By opening or using a third-party wallet, you will be deemed to have agreed to the relevant third party's terms and to acknowledge that the relevant third party is solely responsible for the operation of and payments from that wallet. LemFi accepts no responsibility for the acts or omissions of any third-party wallet provider.

3. About These Terms

3.1 Why should you read these terms? These terms govern LemFi's provision of the Global Account services to you. They explain your responsibilities and LemFi's responsibilities, how these terms can be amended or terminated, and the extent of LemFi's liability to you.

3.2 How do you accept these terms? You accept these terms by ticking or clicking the relevant acceptance box when you register with LemFi, or by otherwise agreeing via the app. By using the Global Account, you confirm that you have read, understood and agreed to be bound by these terms.

3.3 When do these terms come into force? These terms come into force when you have accepted them and LemFi has successfully onboarded you, and remain in force until terminated.

3.4 How can these terms be terminated? You can terminate these terms immediately at any time by contacting LemFi's support team using a method set out in section 1.2. LemFi can terminate these terms by providing you with two months' notice using a method set out in section 1.5. LemFi may also close or suspend your account in accordance with section 13.

3.5 What happens when these terms are terminated? You will no longer be a LemFi customer and will be unable to use the Global Account. It is your sole responsibility to ensure that there is no money in any of your wallets before requesting closure. For six years after termination, you may contact LemFi by email to request that any remaining wallet balance is sent to a payment account in your name. During this period, LemFi may deduct money from your wallet to pay any amounts you owe.

3.6 Language. These terms are in English. Where a non-English version is provided, it is for reference only; the English version governs.

3.7 Business days. References to a business day mean a day other than a Saturday, Sunday or public holiday in England.

3.8 Key Definitions


App	The "LemFi" mobile application, available on Google Play and the App Store.
APP Fraud	Authorised Push Payment Fraud: where you are tricked into sending money to a fraudster unbeknown to you at the time.
Beneficiary	The person who will receive money when you execute a payment using the app.
Beneficiary account	The mobile money wallet, payment account or bank account belonging to the beneficiary.
Electronic money	An electronic alternative to money. When you send LemFi money, LemFi credits your wallet, backed by an equivalent amount in safeguarded accounts.
FX / exchange	The conversion of money from one currency to another using LemFi's prevailing exchange rates.
Global Account	Your multi-currency electronic money account(s) with LemFi, as described in these terms.
Money	Money as you would normally understand it, and electronic money stored in your wallet.
Nominated Account	The bank or payment account in your name that you designate for withdrawals.
Payment	LemFi sending money from your wallet to another wallet or to a non-LemFi payment account.
Terms	This Customer Agreement and any applicable terms and conditions relevant to the Global Account.
User country	The country of your user profile and regulatory home with LemFi, which determines your available wallets and issuing entity.
Wallet	An electronic money account held by you with LemFi in a specific currency.

4. Your Global Account and Wallets

4.1 What is the Global Account? Your Global Account is your collection of electronic money wallets with LemFi. Each wallet holds money in a specific currency. The currencies available to you are set out in section 2.2 above and are determined by your user country. LemFi may add or remove available currencies from time to time; you will be notified of any material changes.

4.2 Creating a wallet. You can create a wallet by selecting "Add wallet" in the app. The app will display the currencies available to you based on your user country. Once you select a currency, LemFi's backend will create or assign your wallet and return account details (including any relevant IBAN, account number, or other funding reference). Your new wallet will be displayed with its available funding and withdrawal methods and any applicable limits.

4.3 What can you use your wallet for? Once you have money in a wallet, you may: (a) exchange it to another supported currency wallet; (b) send it to other LemFi users; (c) send it to bank and mobile money accounts in supported countries; and (d) withdraw it to your Nominated Account.

4.4 How does your wallet differ from a bank account? Your wallet differs from a bank account in that money in your wallet: (a) will not be invested or lent to third parties; (b) will not accrue interest; and (c) will be safeguarded as described in section 5, but will not be covered by the Financial Services Compensation Scheme (FSCS).

4.5 How do you add money to your wallet? You can add money by: (a) sending a bank transfer from your own bank account using the IBAN or account details linked to your wallet; or (b) receiving money from friends, family, employers or customers. Available funding methods may vary by wallet currency and are displayed in the app.

4.6 Limits. Transaction limits apply per wallet and per action (create, fund, withdraw, send, exchange). Limits are defined by reference to your user country, wallet currency, and action type, and may differ by KYC verification tier. Current limits are displayed in the app. LemFi may update limits from time to time in accordance with its compliance obligations.

4.7 How long will it take for money to be credited? For bank transfers, LemFi will credit your wallet when cleared funds have arrived. For Faster Payments (GBP), funds are typically received within two hours. For SEPA Instant (EUR), receipt is typically near real-time. For other currencies and rails, timings will be displayed in the app. Timings may be affected by delays outside LemFi's control.

4.8 Currency conversion on receipt. If money is received in a different currency from that of the relevant wallet, it will be converted into the wallet currency using LemFi's prevailing exchange rate at the time of receipt. Your statement will show the exchange rate applied. Exchange rates fluctuate and the rate shown when you check may differ from the rate applied at conversion.

4.9 Balance and transaction history. You can view your wallet balances and transaction history at any time via the app while your account is open. LemFi will send a push notification to your device each time money is received. LemFi recommends that you keep push notifications enabled.

4.10 Statements. You can download transaction statements from the app at any time while your account is open. LemFi recommends that you download statements before requesting account closure, as you will lose in-app access once your account is closed. After closure, you may request statements from customer support; following identity verification, LemFi will send them to your registered email address.

4.11 Adding money by third parties. A third party may add money to your wallet by: (a) sending money from their own LemFi wallet; or (b) sending money from an external account using the IBAN or account details linked to your wallet.

4.12 Fees. LemFi's fees are disclosed in the app before you confirm each transaction. Fees are subject to change; LemFi will provide notice of fee changes in accordance with section 17. LemFi may deduct fees directly from your wallet. If fees exceed your available balance, you may fall into a negative balance which you must immediately remedy.

4.13 Negative balances. LemFi will verify that you have sufficient funds before executing a transaction. However, you may fall into a negative balance if fees exceed your balance. If this occurs, you must immediately top up your wallet.

4.14 Mistaken payments. If LemFi reasonably believes that money has been paid into your wallet by mistake, LemFi may: (a) notify you; (b) share your personal information with the payer's payment service provider; (c) freeze an amount up to the amount received in error; and/or (d) deduct the relevant amount and return it to the payer's payment service provider. You must notify LemFi if you believe a payment received was not made in error.

5. How Your Money Is Safeguarded

5.1 When LemFi receives money for your wallet, it will issue electronic money to your wallet and place the equivalent amount of money in safeguarded accounts.

5.2 Money in any third-party wallet (such as an NGN wallet provided by Pagatech) will be safeguarded by the relevant third-party provider, not by LemFi.

5.3 Safeguarded accounts are separate from LemFi's own funds. In the unlikely event that LemFi becomes insolvent, safeguarded funds are protected from the claims of LemFi's creditors and should be returned to you in full.

5.4 Your wallet is not covered by the FSCS or any equivalent government deposit guarantee scheme. Your funds are protected by safeguarding only.

5.5 LemFi will stop safeguarding your funds when they have been transferred out of your wallet to the recipient or to their payment service provider, as applicable.

6. Eligibility for the Global Account

6.1 The Global Account is available to individuals who meet LemFi's eligibility criteria. By applying, you represent and warrant that:

you are at least 18 years of age;
you are an individual applying for personal use (and, where applicable, as a freelancer or self-employed person for your own transactions — see section 6.3);
you are registered or resident in one of the supported user countries: United States, United Kingdom, Canada or Nigeria;
you have the power, authority and capacity to enter into and comply with these Terms;
all information you provide during onboarding and on an ongoing basis is complete, accurate and not misleading, and you will notify LemFi of any material changes;
you will use the Global Account only for lawful purposes and in accordance with these Terms.

6.2 You must continue to meet LemFi's eligibility criteria on an ongoing basis. LemFi may amend its eligibility criteria from time to time; you will be notified of material changes.

6.3 Personal and freelance use. You may use the Global Account for personal transactions and, where applicable, as a freelancer, self-employed person or sole trader for transactions that are solely your own. You may not use the Global Account to hold or transact funds on behalf of third parties, or for activities that constitute a business for which LemFi's prior written approval has not been obtained.

6.4 LemFi reserves the right to decline any application or to close an account if eligibility requirements are not or are no longer met.

7. Identity Verification and Onboarding

7.1 Before you can use the Global Account, you must complete LemFi's identity verification and onboarding process. LemFi will conduct verification checks in accordance with applicable anti-money laundering legislation, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), and its internal due diligence procedures.

7.2 You agree to provide all information and documentation reasonably requested by LemFi for identity verification, fraud prevention and compliance purposes. LemFi may conduct periodic reviews and request updated information at any time.

7.3 LemFi may use third-party identity verification and credit reference agencies for these purposes. You consent to LemFi sharing your personal data with such agencies as necessary.

7.4 Your applicable transaction limits may differ by KYC verification tier. Your current tier and the limits that apply to each of your wallets are displayed in the app.

7.5 If you fail to provide required information within the timeframes requested, LemFi reserves the right to restrict, suspend or close your account.

8. Accessing Your Global Account

8.1 You will access your Global Account via the LemFi app. You are responsible for keeping all login credentials — including your username, password, PIN and biometric authentication data — safe and secure.

8.2 LemFi will take all reasonable steps to keep the app available. There may be periods of scheduled maintenance or unplanned downtime. LemFi will endeavour to give advance notice of scheduled downtime where practicable.

8.3 You must notify LemFi immediately if you become aware of or suspect any unauthorised access to your account or compromise of your login credentials. You will not be able to access your account until LemFi has verified your identity following such a notification.

8.4 You must maintain an up-to-date email address with LemFi to receive important communications. Please ensure your email settings are configured to receive emails from LemFi.

8.5 You must tell us immediately if you do not recognise any transaction on your Global Account.

9. Your Instructions to LemFi

9.1 You can give LemFi instructions relating to your Global Account via the app or, where accepted by LemFi, by email.

9.2 LemFi will act on your instructions unless:

LemFi reasonably believes you did not authorise the instruction;
LemFi reasonably suspects the instruction is fraudulent;
it is necessary to reject the instruction to protect you or LemFi from a crime;
the instructions are unclear or incomplete;
acting on the instruction would cause LemFi to breach any applicable law or regulation; or
acting on the instruction would result in your account falling below nil balance.

10. Payments Into Your Global Account

10.1 LemFi will only accept payments that are legitimate, free from fraud or criminal activity, and subject to LemFi's acceptance processes including compliance with its legal and regulatory obligations.

10.2 LemFi cannot accept cash or cheque payments into your Global Account.

10.3 When LemFi receives an electronic payment, the money will be credited to your wallet on the same day, subject to any delays beyond LemFi's control and subject to LemFi's acceptance of the transaction in compliance with its obligations, including any requirement for you to provide additional information about the transaction.

11. Payments Out of Your Global Account

11.1 All withdrawals must be authorised by you.

11.2 Withdrawal values must not be less than the minimum amount specified in the app for the relevant wallet currency (which for GBP wallets is £1), unless you are closing your Global Account.

11.3 LemFi may ask you to confirm your identity before processing a withdrawal. A withdrawal is not authorised until any such confirmation has been provided.

11.4 Withdrawals are processed using the payment method applicable to each wallet currency:

GBP wallets: Faster Payments to your Nominated Account.
EUR wallets: SEPA (Credit Transfer or Instant, as available) to your Nominated Account.
USD wallets: via GIBank rails to your Nominated Account.
CAD wallets: via Pateno / DCBank rails to your Nominated Account.
AED wallets: via Lorum rails to your Nominated Account.

11.5 Once a payment has been processed and sent, LemFi cannot stop or reverse it.

11.6 You will not be able to submit a withdrawal if you have insufficient funds in the relevant wallet to cover the payment amount.

12. LemFi's Right to Restrict or Refuse Transactions

12.1 LemFi reserves the right to restrict amounts sent or received at its sole discretion. LemFi may refuse to carry out a transaction in the following circumstances:

LemFi reasonably believes that you or someone else is using the Global Account illegally or fraudulently;
LemFi is required by law or regulation to refuse, or reasonably believes that processing would breach applicable law;
you are subject to a bankruptcy, insolvency or winding-up event, or LemFi reasonably believes such an event is imminent;
the relationship between you and LemFi has irretrievably broken down (for example, due to abusive or threatening conduct towards LemFi's staff);
there is a genuine dispute about the ownership of or entitlement to funds in the account;
you are in breach of these Terms;
LemFi needs to verify your identity or the validity of instructions;
there are insufficient cleared funds to cover the transaction;
the terms of the Nominated Account prevent completion of the payment;
there are technical issues preventing execution;
circumstances beyond LemFi's reasonable control prevent normal service; or
LemFi reasonably believes you are using the account for unauthorised business purposes.

12.2 LemFi also reserves the right to decline receipt of any incoming payment at its sole discretion.

12.3 LemFi will notify you if it refuses to execute a transaction and the reason why, unless it is prevented from doing so for legal, regulatory or security reasons.

13. Account Closure

13.1 You may close your Global Account at any time by contacting customer support.

13.2 LemFi may close your Global Account immediately, without notice, if:

you have not provided documents required for LemFi to meet its regulatory or legal obligations;
you have failed to provide satisfactory evidence for anti-money laundering verification;
LemFi reasonably believes that information or declarations you have provided are untrue, misleading or materially incomplete;
you have behaved abusively, offensively or violently towards LemFi's staff;
you have misused the Global Account, including for money laundering, fraud, bribery, corruption, terrorist financing, sanctions evasion or other criminal activity;
under the terms of a court order; or
you have done or failed to do something that prevents LemFi from complying with its legal or regulatory obligations.

13.3 If LemFi closes your account for any reason not listed in section 13.2, it will give you one calendar month's notice.

13.4 Unless prevented for legal reasons, upon closure LemFi will send any remaining wallet balance to your Nominated Account.

13.5 LemFi may retain funds if you do not address concerns about the origin of the money, or if a third party claims entitlement to the funds, until the matter is resolved.

13.6 LemFi will not be liable for any costs, charges, expenses or taxes that arise as a result of the closure of your Global Account.

14. Foreign Exchange (FX) and Currency Conversion

14.1 Supported FX pairs. LemFi supports conversions between the following currency pairs (in either direction):

From	To	Available to
USD	AED, CAD, GBP, KES, NGN	US, NG customers
GBP	AED, CAD, KES, NGN	US, GB, CA, NG customers
CAD	AED, GBP, KES, NGN	US, GB, CA, NG customers
AED	CAD, GBP, KES, NGN	US, GB, CA, NG customers
NGN	AED, CAD, GBP, USD	US, GB, CA customers
KES	AED, CAD, GBP, USD	US, GB, CA customers

NGN conversions are not extended to exotic currency pairs under this product version. No changes are made to existing NGN conversion support.

14.2 FX availability is rule-based and determined by reference to your user country, source wallet currency and destination wallet currency. LemFi may enable or disable specific FX pairs from time to time based on liquidity availability and other operational considerations. The app will display which conversions are currently available to you.

14.3 Exchange rates. When you convert money between currencies, LemFi will apply its prevailing exchange rate at the time of the transaction. LemFi's rates include a spread and may differ from interbank or mid-market rates. The applicable rate will be displayed in the app before you confirm the conversion. Exchange rates fluctuate; the rate shown when you check may not be the rate applied at the time of execution.

14.4 LemFi accepts no liability for losses arising from exchange rate fluctuations.

16. Your Obligations

16.1 You must use the Global Account only for lawful purposes and in accordance with these Terms.

16.2 You must not use the Global Account for any activity that is illegal, fraudulent or prohibited by LemFi, including money laundering, terrorist financing, bribery, corruption or sanctions evasion.

16.3 You are wholly responsible for the accuracy of information you provide to LemFi. LemFi shall not be liable for acting on incorrect information received from you. You must notify LemFi immediately if you discover that any information LemFi holds for you is incorrect, misleading or fraudulent.

16.4 If LemFi's performance of its obligations is prevented or delayed by any act or omission of yours ("Customer Default"), LemFi shall have the right to suspend performance of the affected services until you remedy the default. LemFi shall not be liable for any costs or losses arising from such a suspension.

16.5 You will indemnify LemFi against any liability, cost, expense, loss or damage (including professional advisors' fees) arising from your breach of these Terms, negligence, wilful default, or fraud or fraudulent misrepresentation.

17. Changes to These Terms

17.1 LemFi may amend these Terms at any time. Where a proposed change is to your disadvantage, LemFi will give you at least two months' prior written notice, except where required by law to make the change sooner. Notice will be given via the methods set out in section 1.5.

17.2 You will be deemed to have accepted proposed changes unless you notify LemFi of your objection before the changes take effect. If you object, you may terminate these Terms and close your Global Account in accordance with section 13, without incurring any closure charge.

17.3 Where a change is required by law, regulation or regulatory guidance, LemFi may implement it with shorter notice or with immediate effect, as required.

18. Confirmation of Payee

18.1 In accordance with regulatory requirements and fraud-prevention obligations, you may be required to confirm the identity of the person or party to whom you are authorising a payment before it is processed. LemFi will prompt you in the app where this requirement applies.

19. Transaction Statements

19.1 Transaction information is available within the app and is updated each time a transaction occurs.

19.2 Statements are provided electronically only. You can download your statements from the app at any time while your account is open.

20. Tax Requirements and Reporting

20.1 LemFi may be required by law to share information about you and your Global Account with HMRC or another competent tax authority, including tax authorities in other countries. You agree that LemFi may provide such information as required.

20.2 If LemFi requests personal information or documents in connection with tax reporting obligations, you agree to provide this within 30 days of the request.

20.3 You must notify LemFi of any changes to information relevant to your tax status. LemFi will not be responsible for any losses you suffer as a result of LemFi disclosing information about you in accordance with its legal obligations.

21. Transfer of Rights and Obligations

21.1 These Terms are personal to you. You may not transfer or assign any rights or obligations under these Terms to any third party.

21.2 LemFi may assign or transfer its rights and obligations under these Terms to any affiliate or successor business. You will be notified by email.

21.3 LemFi will only transfer your money to another person who it believes will hold those funds under the FCA Rules, or in respect of whom LemFi has exercised all required due skill, care and diligence in assessing the adequacy of their safeguarding measures.

21.4 LemFi will give you at least ten business days' written notice before taking any action under this section.

21.5 If you object to any assignment or transfer, you may terminate these Terms and close your Global Account in accordance with section 13.

22. Liability

22.1 Nothing in these Terms limits or excludes any duty LemFi owes you under the Financial Services and Markets Act 2000 or the FCA Rules, or any statutory rights that cannot lawfully be excluded.

22.2 LemFi will not be liable to you for any loss, damages or costs except to the extent that they arise directly from LemFi's gross negligence, wilful default, or fraud. LemFi will not be liable for: (a) losses not reasonably foreseeable at the time you gave LemFi an instruction; (b) loss of business, goodwill, opportunity or profit; or (c) indirect or consequential losses.

22.3 You may be entitled to recover some or all of your losses if you have been a victim of APP Fraud and have notified LemFi immediately, or where an unauthorised transaction has been made on your account, subject to section 29 and applicable law.

22.4 Nothing in these Terms requires you to compensate LemFi to any extent prohibited by applicable law.

22.5 LemFi will not be liable for loss or damage attributable to: (a) any action taken, or refusal to act, in order to comply with applicable law or FCA Rules; (b) delays arising from identity verification or compliance processes; (c) a reasonable refusal or failure to execute a payment instruction; or (d) LemFi's reasonable reliance on instructions or communications it believed to be from you.

22.6 LemFi will take reasonable care in selecting bankers, counterparties and third parties. Subject to that duty, LemFi will not be liable for losses attributable to the performance or failure of any third party involved in the provision of the Global Account.

22.7 LemFi will not be responsible for liabilities arising from circumstances outside its reasonable control, including changes in applicable law, governmental or regulatory action, currency restrictions, acts of God, civil unrest, war, terrorism, strikes, market system failure, or disruption to electronic communications or infrastructure.

23. Force Majeure

23.1 LemFi shall not be in breach of these Terms, and shall not be liable for any failure or delay in performance, to the extent that such failure or delay is caused by circumstances beyond LemFi's reasonable control, including acts of God, fire, flood, earthquake, governmental or regulatory action, war, civil commotion, terrorism, failure of computer or payment systems, power disruption, labour disputes, or failure of third-party infrastructure or payment providers.

24. Third Party Rights

24.1 A person who is not a party to these Terms has no rights under the Contracts (Rights of Third Parties) Act 1999 and no right to enforce any provision of these Terms.

25. Notices and Communications

25.1 LemFi will send all notices, information and correspondence to you via the app or to your registered email address. You agree to maintain an up-to-date email address and to inform LemFi promptly of any change. LemFi is entitled to rely on the last email address provided.

25.2 LemFi cannot guarantee that emails will be successfully delivered or will be secure. LemFi will not be liable for loss or inconvenience caused by emails that are lost, delayed, intercepted or not delivered for reasons beyond its control.

26. Security

26.1 Your access to the LemFi app is protected by the username, password and other authentication credentials you set up during registration.

26.2 Your credentials are personal to you and must not be shared with anyone. LemFi shall not be liable for any losses arising from you sharing your credentials with a third party.

26.3 You must notify LemFi immediately if you learn or suspect that your credentials have been compromised. You will be unable to access your account until LemFi has verified your identity.

27. Complaints

27.1 If you wish to make a complaint, please contact our customer support team at: support@lemfi.com or complaints@lemfi.com.

27.2 If your complaint relates to the Global Account or a payment transaction and, after receiving our final response, you remain dissatisfied, you may refer the matter to the Financial Ombudsman Service (FOS) where it falls within the FOS's jurisdiction: http://www.financial-ombudsman.org.uk/, by telephone on 0800 023 4567 or by post to Exchange Tower, Harbour Exchange, London, E14 9SR.

28. Personal Information and Data Protection

28.1 LemFi will collect, process, store and use your personal data in accordance with applicable data protection legislation. Our Privacy Notice (available at https://www.lemfi.com/legal/mobile-privacy) explains how we collect, use, disclose, transfer and store your information.

28.2 LemFi will retain identity verification records for as long as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.

28.3 You consent to LemFi disclosing information about you and your Global Account (when required by law or otherwise) to: (a) HMRC or any other government or tax authority; (b) any regulatory authority, including the FCA, or the police; (c) regulated third-party service providers; or (d) any other government body as required.

29. Authorised Push Payment (APP) Fraud Claims

29.1 If you are a victim of an APP scam, the following applies to any claim for reimbursement, provided the transactions were carried out using Faster Payments or CHAPS:

you must notify LemFi immediately and provide all relevant information, including: why you believe you are a victim of fraud; the nature of the fraud; what payments you authorised and why; and what steps you took following the fraud (for example, reporting to the police); and
you must cooperate promptly and transparently with LemFi's investigation.

29.2 LemFi will investigate your claim and respond subject to its legal and regulatory obligations. LemFi may not be able to provide a written response if doing so would contravene its other obligations.

29.3 If LemFi is satisfied that you did not contribute to the fraud by acting dishonestly, fraudulently or illegally, and your claim is genuine, LemFi may offer a full or partial refund subject to any third-party payment partner's assessment.

29.4 Your entitlement to a refund is subject to: (a) timely notification; (b) LemFi's ability to investigate; (c) LemFi's and any third-party provider's ability to obtain relevant information; (d) the fraud having occurred within 13 months prior to the date of your claim; (e) notification to the police or Action Fraud (or your consent for LemFi to do so); and (f) LemFi or its partner not declining your claim on the grounds of your non-compliance with required timeframes, fraudulent or dishonest conduct, or carelessness in recognising the fraud.

29.5 Where you are eligible for a refund, LemFi will process and pay valid claims in accordance with applicable rules.

30. Governing Law and Jurisdiction

30.1 These Terms and any dispute or claim arising out of or in connection with them (including non-contractual disputes) shall be governed by and construed in accordance with the laws of England and Wales.

30.2 Subject to your right to refer a complaint to the Financial Ombudsman Service or any other statutory dispute resolution scheme, both parties submit to the exclusive jurisdiction of the courts of England and Wales.

[^1]:

Wallet Currency	Issued / Settled via	Safeguarded by
USD	GIBank (GIB) — held 1:1 on GIB	GIBank (no separate GBP safeguarding required)
GBP	ClearBank — Rightcard	Rightcard Payment Services Limited
CAD	Pateno (via DCBank)	Rightcard Payment Services Limited
AED		Rightcard Payment Services Limited