Terms
& Conditions.

Jubilee Services SA/NV (“Jubilee”, “we”, “us”, “our”) is a Public Limited Company incorporated under the laws of Belgium, with registered office at Rue Dethy 4, 1060 Saint-Gilles, Brussels, Belgium, and registered with the Crossroads Bank for Enterprises under number 0639.848.226. You can reach us by telephone at + 32 2 342 20 22.

We are authorised and regulated by the National Bank of Belgium (“NBB”) as a payment institution for the provision of money remittance services (payment service no. 6) in accordance with the Belgian Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, access to the business of payment service providers and to the activity of issuing electronic money, and access to payment systems (the “Belgian PI Law”).

The following terms and conditions (the “Terms”) govern the provision by us, to you, of the money remittance services that you access through the Nala platform and application, as provided by NALA Payments Netherlands B.V.

You can contact us via:

• Post: Rue Dethy 4, 1060 Saint-Gilles, Brussels, Belgium;
• Email: compliance@jubilee.services; or
• Through the Partner Platform (as defined in Clause 2 below).
• Telephone: + 32 2 342 20 22

Our regulator is the National Bank of Belgium (NBB), Boulevard de Berlaimont 14, 1000 Brussels, Belgium (www.nbb.be).

For the purposes of the General Data Protection Regulation, Jubilee is the data controller in respect of the personal data we collect, use, retain, and disclose in connection with the money remittance services described in these Terms. Our data protection contact details are set out in our Privacy Policy. For information on how we process your personal data, including your rights as a data subject, please refer to our Privacy Policy, available on our website.

In these Terms, the following definitions apply:

• “Partner Platform” means NALA Payments Netherlands B.V. (trade register number 90375696), a technical service provider that operates the customer-facing platform and application through which you access our services. The Partner Platform is not an EEA-licensed payment institution, electronic money institution, or money remittance provider.
• “PSD2” means Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market.
• “PI Law” means the law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, access to the business of payment service providers, access to the business of issuing electronic money and access to payment systems.
• “E-Money Provider” means Modulr Finance B.V. (company number 81852401), a Dutch electronic money institution authorised and regulated by the Dutch Central Bank (DNB) under reference number R182870, which provides your e-money wallet.
• “EEA” means the European Economic Area.
• “ePrivacy Directive” means Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector.
• “Business Day” means any day on which we are open for business (other than a Saturday, Sunday, or public holiday in Belgium) as required for the execution of a payment transaction.
• “Withdrawal Period” has the meaning as provided in clause 15.1.

The Partner Platform provides the platform interface through which you can access our money remittance services, and performs additional functions, such as collecting onboarding information, transmitting your remittance instructions to us, and providing customer support services. The Partner Platform does so under its own responsibility and those services are governed by the terms and conditions that you have accepted with them. We remain responsible to you for the money remittance services described in these Terms and for our compliance with the Belgian PI Law and applicable EU payment services legislation.

Your e-money wallet is provided and maintained by the E-Money Provider. Your relationship with the E-Money Provider in respect of your e-money wallet is governed by the E-Money Provider’s own terms and conditions. We do not provide e-money services, wallet services, or maintain any payment account in your name.

Your relationships with the parties involved in the service are as follows:

• The Partner Platform provides the technology platform through which you access services.
• The E-Money Provider provides your e-money wallet, issues electronic money, and processes transfers from your wallet to us.
• Jubilee (us) provides the money remittance service — we receive funds transferred from your e-money wallet and arrange for the transfer of a corresponding amount to your intended recipient in the destination country. These Terms govern that service.

By using our money remittance services, you confirm that you have read, understood, and agreed to these Terms, the Partner Platform’s terms of service, and the E-Money Provider’s terms and conditions.

We provide a money remittance service: we receive funds from you (via your e-money wallet with the E-Money Provider) for the sole purpose of transferring a corresponding amount to a named recipient (“payee”), typically in another country.

We do not create or maintain a payment account in your name or in the name of the payee. Our service is limited to money remittance as defined under Article 4(22) PSD2 and its implementation in Belgian law.

Remittance payments will be delivered to the payee by crediting the payee’s bank account or mobile money account, subject to availability in the relevant destination country.

We use a network of licensed local pay-out partners to deliver funds to recipients in destination countries, and the actual disbursement to the payee is executed by the licensed local pay-out partner in the relevant jurisdiction.

We do not accept responsibility for any goods or services that may be paid for by a money transfer. You are cautioned against sending money to any person you do not know.

To use our money remittance services, you must:

• be at least 18 years of age;
• be a resident of the EEA;
• hold a valid e-money wallet with the E-Money Provider, accessible through the Partner Platform, funded via bank transfer or debit card; and
• have completed our customer onboarding and identity verification requirements.

As part of our legal and regulatory obligations, we are required to verify your identity before providing our services. You must provide us (directly or via the Partner Platform) with accurate and complete information, including your name, date of birth, address, telephone number, email address, and such identification documents as we may require (such as a government-issued identity document). For full details of how Jubilee and the Partner Platform collect, use, retain, and share the personal data you provide during onboarding, which includes the lawful bases for the processing, your data subject rights, and the identities of third parties with whom data maybe shared, please read our Privacy Notice carefully before you register for our services. The Privacy Notice contains the information we are required to provide to you under Article 13 GDPR and should be read alongside these Terms.

We reserve the right to refuse to provide our services, or to suspend or terminate our relationship with you, on objective grounds, including where:

• we are unable to complete or maintain required customer due diligence;
• we have anti-money laundering, sanctions, counter-terrorism financing, or fraud concerns;
• you have breached these Terms;
• we are required to do so by law, regulation, or instruction from a regulatory authority; or
• there is a material operational or security risk.

We may impose limits on your remittances, either per individual transfer or on an aggregate basis. We may also restrict the amount of currency you may exchange at any given time.

You represent and warrant that:

• you are over 18 years old;
• the information you supply to us is true, accurate, and complete;
• the funds used for remittance transactions are lawfully obtained;
• your remittance instructions will not breach any applicable law or regulation; and
• you will not use our services for any unlawful purpose.

You must promptly notify us (via the Partner Platform or our contact details above) of any changes to the information you have provided to us.

To initiate a remittance, you give your instruction through the Partner Platform. Although you interact with the Partner Platform’s application, your remittance instruction is legally given to us. The Partner Platform transmits your instruction to us on your behalf via automated systems.

Before completing a remittance, the following information will be provided to you via the Partner Platform:

• the amount you wish to send and the currency;
• the amount the recipient will receive in the destination currency;
• the exchange rate applied to the transaction (which includes our remuneration for the service); and
• the estimated time for delivery of the remittance.

By clicking “Submit” (or equivalent confirmation) on the Partner Platform, you:

• authorise the E-Money Provider to transfer the relevant funds from your e-money wallet to our corporate account; and
• authorise us to execute the remittance by arranging for the transfer of a corresponding amount to the payee in the destination country.

Your consent to the remittance transaction is given at the point you confirm the transaction on the Partner Platform. We shall treat the instruction transmitted by the Partner Platform as your authorised instruction.

You must provide accurate payee information as required, which may include the payee’s full name, country, and bank account details or mobile money number (as applicable). If this information is incorrect, it may result in the remittance being delayed or the funds being lost. We are not responsible for losses arising from incorrect payee information provided by you. We will make reasonable efforts to help you to recover the funds, if possible. We may charge you a reasonable fee to cover the cost of doing so.

Where required by Article 97 of PSD2 and the related Belgian transposition, the authentication of your payment instruction is performed through the secure authentication procedures of the E-Money Provider. We may decline to execute a remittance instruction if Strong Customer Authentication has not been satisfactorily completed.

Once we receive your funds (via the transfer from your e-money wallet to our corporate account) and your remittance instruction, we will execute the remittance.

We will arrange for the corresponding amount to reach the payee or the payee’s payment service provider:

• by the end of the next Business Day after we receive your instruction, for remittances to payees within the EEA in Euro; or
• by the end of the fourth (4th) Business Day after we receive your instruction, for remittances in other EEA currencies to payees within the EEA; or
• for remittances to payees outside the EEA, we will use reasonable endeavours to process the remittance promptly, with estimated delivery times communicated to you before you confirm the transaction. Specific execution timeframes may vary by destination country and delivery method.

We must receive your remittance instruction before 4:00 PM (Central European Time) for it to be treated as received on that Business Day. Instructions received after that time, or on a day that is not a Business Day, will be deemed received on the next Business Day.

Once we have received your remittance instruction and the corresponding funds, you cannot revoke it, unless you inform us in writing that you withdraw your consent no later than the end of the Business Day before the agreed date of execution. After that point, the remittance is irrevocable.

Once a payee has received a remittance sent by us in accordance with your instructions, that payment cannot normally be reversed.

If we refuse to execute a remittance instruction, we will notify you of the refusal and, where possible, the reasons for it, unless we are prohibited from doing so by applicable law (in particular by anti-money laundering, counter-terrorism financing, or sanctions legislation).

In accordance with the Belgian PI Law and applicable regulatory requirements, we safeguard the funds received from you for the execution of a remittance transaction. We hold such funds in a dedicated account for the duration of the payment execution; any funds remaining at the close of the Business Day following receipt are transferred to and held in a segregated account with an authorised credit institution. These safeguarded funds are protected from the claims of our other creditors and, in the unlikely event of our insolvency, would be returned to you in priority.

When you use our money remittance service that involves a currency conversion, we will apply our applicable exchange rate and any applicable fees. Our applicable fees and exchange rates can be found on the app; for each transfer, they will be disclosed to you before you confirm the transaction.

Our fees are due when you confirm the transaction on the Partner Platform.

Our exchange rate is displayed in the Nala app. It may vary depending on the currencies involved and may change throughout the day. The rate applied will be the rate at the time your transaction is confirmed unless otherwise agreed. Our exchange rates may differ from publicly reported commercial exchange rates.

Third parties may impose taxes, fees or charges on you or the recipient. You are solely responsible for payment of these taxes, fees or charges, unless otherwise required by applicable law.

We may change the basis on which we charge for our services at any time, including by introducing separate fees. We will notify you at least two (2) months before any such change takes effect, in accordance with Clause 12 of these Terms.

We are required by Belgian and EU law to comply with anti-money laundering (AML), counter-terrorism financing (CTF), and sanctions requirements. In connection with these obligations:

• We will screen all remittances against applicable sanctions lists maintained by Belgian, EU, UN, and other relevant authorities;
• We may request additional information or documentation from you regarding the purpose or source of funds of any transaction;
• We may suspend, delay, or refuse a remittance if a potential sanctions match or suspicious activity is identified; and
• We may report suspicious activity to the Belgian Financial Intelligence Processing Unit (CTIF-CFI) or other competent authorities without prior notification to you, where permitted or required by law.

In accordance with the tipping-off restrictions set out in Articles 54 to 57 of the Belgian AML Law of 18 September 2017 and Article 39 of Directive (EU) 2015/849 (as amended by Directive (EU) 2018/843), we are legally prohibited from notifying you that an STR has been or will be filed, or that an AML or financial crime investigation is underway in relation to you or a transaction you have initiated. We will thus not inform you of those.

You agree to cooperate with us in the discharge of our AML, CTF, sanctions, and security obligations by providing such information and documentation as we may reasonably request from time to time.

You are prohibited from using our services for or in connection with any criminal, illegal, or sanctioned purpose. You agree that you will not use our services to transact with or transmit funds to or for the benefit of any person or entity subject to applicable sanctions.

We will communicate with you primarily through the Partner Platform and via email. We may also contact you by telephone, SMS, or post where appropriate.

After we accept a remittance instruction from you, we will provide the following information, free of charge via the Partner Platform or email, within one (1) Business Day:

• a reference enabling you to identify the transaction and information about the payee;
• the amount of the remittance in the currency of instruction;
• the exchange rate applied and the amount the recipient will receive after conversion; and
• the date of receipt of your instruction.

You must review all confirmations and communications we send you within a reasonable time and promptly advise us of any apparent mistake or discrepancy. Delay in notification may make correcting errors difficult.

These Terms are provided in English. If we provide a translation into any other language, it is for convenience only, and the English version shall prevail.

We will contact you by email or via the Partner Platform if there are suspected or actual fraud or security threats. If we believe email communication may not be secure, we will contact you by telephone.

Where Jubilee wishes to send you communications by electronic means (including email or SMS) for purposes other than the provision or administration of the money remittance service, such as marketing, promotional communications, or service updates unrelated to a specific transaction, we will only do so with your prior, freely given, specific, and informed consent, in accordance with the ePrivacy Directive as implemented under Belgian law by the Act of 13 June 2005 on electronic communications. We will not make your consent to marketing communications a condition of access to our money remittance services. You may withdraw your consent to receive marketing communications at any time without charge by contacting us or by following the unsubscribe instructions in any marketing communication. Withdrawal of consent does not affect the lawfulness of any communications sent prior to withdrawal.

You have the right to request and receive these Terms on a durable medium via the Partner Platform or at the contact details in Clause 1.4.

You must keep any security credentials, passwords, or personalised security features associated with your access to services (including those used on the Partner Platform) safe and confidential at all times. You must not share them with any other person.

You must notify us immediately (via the Partner Platform or at the contact details in Clause 1.4) if you become aware that your security credentials have been lost, stolen, compromised, or that someone else has gained unauthorised access. We will take immediate steps to prevent further unauthorised use.

You must ensure that all information you provide to us (directly or via the Partner Platform) is accurate, complete, and up to date, and you must promptly notify us of any changes.

You must ensure that the funds used for remittances are sufficient and available in your e-money wallet with the E-Money Provider before initiating a remittance instruction. We will not execute a remittance unless we have received the corresponding funds from your e-money wallet.

We may change any provision of these Terms. We will notify you at least two (2) months before any change takes effect.

Notification of changes will be provided via the Partner Platform and/or by email or other means reasonably likely to come to your attention.

You will be deemed to have accepted any change if you do not notify us to the contrary before the date on which the change takes effect. If you do not accept a proposed change, you may terminate our agreement with immediate effect at any time before the change takes effect, free of charge, by notifying us.

If we have made a major change or a number of minor changes in any one year, we will make a copy of the updated Terms available to you.

These Terms will continue until terminated in accordance with this Clause 13.

You may terminate our agreement under these Terms at any time by notifying us (via the Partner Platform or at our contact details in Clause 1.4). Termination of your agreement with us does not affect your separate relationships with the Partner Platform or the E-Money Provider, which are governed by their respective terms.

We may terminate our agreement under these Terms by giving you at least two (2) months’ written notice.

We may terminate or suspend our services to you immediately if:

• you are in material breach of these Terms;
• you have provided false, incomplete, or misleading information;
• we are unable to satisfy our customer due diligence requirements;
• we have reasonable grounds to suspect fraud, money laundering, terrorism financing, or other illegal activity;
• we are required to do so by law, regulation, or instruction from a competent authority; or
• you have used our services for unlawful purposes.

Where we suspend or terminate our services, we will, to the extent legally permitted, notify you as soon as possible and provide reasons unless doing so would compromise security measures or breach legal obligations.

Termination does not affect rights or obligations that have accrued prior to termination, including any remittances in progress. Any remittance instruction accepted by us before termination will be completed in accordance with these Terms.

If you are a consumer, you may withdraw from the agreement under these Terms without giving any reasons within fourteen (14) calendar days starting on the day after this Agreement is concluded between you and us (the “Withdrawal Period”).

To exercise your right of withdrawal you must inform Jubilee of your decision by a clear, unambiguous statement before the Withdrawal Period expires. You may do so:

• In-App via the Mama Nala help feature. If you use this online feature, we will send you an acknowledgement of receipt of the withdrawal on a durable medium (e.g. by email), including its content and the date and time of its submission, without undue delay after you have confirmed your intention to withdraw from the agreement;
• sending an email to compliance@jubilee.services; or
• writing to us at Rue Dethy 4, 1060 Saint-Gilles, Brussels, Belgium.

Example of clear and unambiguous statement: “I/We hereby give notice that I/we withdraw from my/our contract for the provision of the services available through the Partner Platform.”. Upon receipt of that statement, The Partner Platform will notify us of your decision to withdraw.

To meet the deadline, it is sufficient that you send your communication before the Withdrawal Period expires.

Your right of withdrawal does not apply to:

• Any payment transaction whose price depends on fluctuations in the financial market which we cannot control, including fluctuations in currency exchange rates. Accordingly, once you instruct the Partner Platform to execute a payment transaction that involves currency conversion, that payment transaction cannot be withdrawn, cancelled or reversed under this clause; and
• Any payment transaction that has been fully performed by both parties at your express request before you exercise your right of withdrawal. Accordingly, once you have authorised a payment transaction and it has been executed at your request, that payment transaction cannot be withdrawn, cancelled or reversed under this clause.

For the avoidance of doubt, these exceptions apply only to the specific payment transactions you have instructed Jubilee to carry out. Your right to withdraw from this Agreement during the Withdrawal Period is not affected.

Consequences of withdrawal: If you validly exercise your right of withdrawal within the Withdrawal Period:

• This Agreement will terminate with immediate effect;
• The Partner Platform will notify us of your request to withdraw from your agreement with them;
• You remain responsible for any action you performed through the Partner Platform or app, including instructions you gave us (for instance, payment transactions you authorised) before we received your withdrawal notice;
• You must, without undue delay, pay all amounts due for the services we have provided to you and we will return to you any sums we have received from you, except for the outstanding amounts due, within 30 calendar days of the date on which we received notification of your withdrawal.

Relationship with your other termination rights. Your right of withdrawal under this Clause 15 is separate from, and in addition to, your right to terminate this Agreement at any time in accordance with Clause 14 (TERM AND TERMINATION), which continues to apply after the Withdrawal Period has ended.

We aim to provide the highest level of service. If you experience a problem or are dissatisfied with our services, please contact us using the contact details in Clause 1.4 or via the Partner Platform.

We will acknowledge your complaint promptly and investigate it in accordance with our internal complaints procedure. We will aim to provide a final response within fifteen (15) Business Days after receiving your complaint. In exceptional circumstances, we will inform you of the delay, the reasons for it, and provide a final response within thirty-five (35) Business Days.

If you are not satisfied with our final response, you may refer your complaint to:

• The Belgian Ombudsman for Financial Services (Service de Médiation pour le consommateur / Consumentenombudsdienst): North Gate II, Boulevard du Roi Albert II 8, Bte 1, 1000 Brussels, Belgium (https://mediationconsommateur.be); or
• FPS Economy - DG Economic Inspection (SPF Economie / FOD Economie): City Atrium C, Rue du Progrès/Vooruitgangstraat, 50, 1210 Brussels, Belgium.

You may also contact the National Bank of Belgium (NBB) if you believe we have failed to comply with our regulatory obligations.

• Termination of our agreement under these Terms does not affect your or our accrued rights and obligations at the date of termination.
• A failure to exercise or delay in exercising any right or remedy under these Terms does not constitute a waiver of that right or remedy.
• If any provision of these Terms is found to be invalid, illegal, or unenforceable, the remaining provisions shall not be affected.
• You may not assign, transfer, or create any trust in respect of any right or obligation under these Terms without our prior written consent.
• We may assign, transfer, or novate our rights and obligations under these Terms to any of our affiliates or to a successor entity in connection with a merger, acquisition, reorganisation, sale of assets, or change of control, provided that (i) your rights under these Terms are not adversely affected, (ii) we give you at least two (2) months’ prior notice in accordance with the CHANGES TO THESE TERMS section, and (iii) you may terminate this Agreement free of charge at any time before the assignment, transfer, or novation takes effect.
• These Terms do not confer any rights on any third party.
• Nothing in these Terms creates a partnership, agency, or employment relationship between you and us, or between you and NALA.
• In the event of any conflict between these Terms and NALA’s Terms of Service, these Terms shall prevail to the extent the conflict relates to the money remittance service provided by us.
• Headings used in these Terms shall not affect its interpretation.
• Any reference to a statute or statutory provision shall be construed as a reference to that statute or statutory provision as amended, extended or re-enacted from time to time.
• All communications relating to these Terms shall be made in English. Where you choose to use the Partner Platform in a language other than English, you agree that communications may be made in that language or English. The English version of communications shall prevail in the event of any discrepancy.
• All intellectual property rights relating to the remittance services and any other software including but not limited to our website, APIs, code, data, content, specifications, as well as copyrights, patents, database rights, trademarks, and service marks, are owned by us, our affiliates, or relevant third parties. You are granted only a limited right to use them in accordance with these Terms. No ownership or intellectual property rights are transferred or assigned.

These Terms and our agreement under these Terms are governed by Belgian law.

Any dispute arising from or in connection with these Terms shall be submitted to the exclusive jurisdiction of the courts of Brussels (French-speaking division), without prejudice to your right to submit a complaint to the Belgian Ombudsman for Financial Services or to exercise any other statutory right of redress available to you.