1. Introduction and Purpose
These Card Terms and Conditions (“Terms”) constitute a legally binding agreement between you, the user, and Spoynt Limited (“Spoynt”, “we”, “us”, “our”), governing how you apply for, manage and use, through the Spush mobile wallet application (“Spush”), the payment card (“Card”) issued to you by Wirex. Spoynt Limited is a company duly incorporated under the laws of England and Wales, with its registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom, bearing company registration number 14156599. Spoynt Limited is an authorised Electronic Money Distributor Agent (EMD Agent) regulated by the Financial Conduct Authority (FCA) under the Electronic Money Regulations 2011 (903071). Spoynt operates in partnership with Noveba Limited, an authorised Electronic Money Institution (EMI) regulated by the FCA under the Electronic Money Regulations 2011 (900924).
The Card is issued by Wirex Limited, a company registered in England and Wales (company number 09334596), authorised and regulated by the Financial Conduct Authority as an electronic money institution (FRN 902025) (“Wirex”). Wirex is the Card issuer for all Cardholders, whether you are resident in the United Kingdom or in the European Economic Area. Spoynt is not the issuer of the Card and acts only as a referral source and technical facilitator: Wirex alone provides the Card to you and, once Wirex accepts you, you become a customer of Wirex.
To apply for a Card you must accept Wirex’s terms, which form a separate agreement between you and Wirex.
These Terms supplement the Wirex Terms: they describe how the Card works in Spush and Spoynt’s own role. If there is a conflict between these Terms and the Wirex Terms about the Card itself (including its issuance, the funds held on it, your liability for Transactions, and complaints), the Wirex Terms prevail.
Spush is a mobile wallet application developed by Spoynt Limited, downloadable from the Apple App Store for iOS devices and Google Play Store for Android devices. It is designed to streamline your payment experience by allowing you to store, manage, and utilize Cards for a variety of Transactions, including in-store purchases and online payments. This application integrates seamlessly with your Spoynt Account, offering real-time Transaction monitoring, security controls, and account management features directly from your mobile device. The purpose of these Terms is to establish a clear framework for your rights and obligations as a Cardholder, outline Spoynt’s responsibilities in coordinating with Noveba Limited and Wirex, and ensure transparency in how the Card and Spush operate within the regulatory landscape of the United Kingdom and, where applicable, the European Economic Area.
By downloading Spush, submitting an application for a Card, or engaging in any Transaction using the Card, you explicitly acknowledge and agree to be bound by these Terms in their entirety. This includes acceptance of associated policies, such as Spoynt’s Privacy Policy, which is accessible at https://spush.co.uk/privacy-policy and details how your personal data is collected, processed, and protected in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. If you find any provision unacceptable or do not wish to comply with these Terms, you must refrain from downloading Spush, applying for a Card, or using any related services. These Terms are designed to protect all parties involved — yourself as the Cardholder, Spoynt Limited as the service provider, Noveba Limited as the EMI partner, and Wirex as the Card issuer — while adhering to the legal standards set forth by the FCA under the Electronic Money Regulations 2011 and the Payment Services Regulations 2017.
Furthermore, this document serves as a supplement to any existing agreements you may have with Spoynt Limited regarding your Spoynt Account, such as the general terms of service for electronic money services. It specifically addresses the Card-related aspects of your engagement with Spush, ensuring that you have all necessary information to use the Card responsibly and securely. Spoynt Limited reserves the right to update these Terms as outlined in Section 18, and you are encouraged to review them periodically to stay informed of your rights and responsibilities.
2. Definitions and Key Terms
To ensure clarity, consistency, and ease of understanding throughout these Terms, the following key terms are explicitly defined. These definitions apply whenever the terms appear in capitalised form within this document, unless the context clearly indicates otherwise:
Card: Refers to the Visa debit payment card issued to you by Wirex and managed through Spush. The Card has its own balances, separate from your Spoynt Account (see Section 16). The Card is available as a virtual card, which exists digitally within Spush and is accessible via your mobile device without a physical counterpart, and, where made available, as a physical plastic card, which includes features such as contactless payment capabilities and an embossed Cardholder name (where applicable). Both formats support Transactions as outlined in these Terms.
VISA: means multinational payment card services corporation. The Card operates on the Visa scheme.
Wirex: means Wirex Limited (company number 09334596), the issuer of the Card, as described in Section 1.
Card Agreement and Wirex Terms: have the meanings given in Section 1.
Digital Wallet: a mobile wallet service such as Apple Pay or Google Pay, provided by Apple Inc. or Google LLC.
Privy: means Privy, the third-party infrastructure provider used by Spoynt to generate and manage the cryptographic keys associated with your Card account. Privy uses your email address as an identifier to link you to your keys, and holds a device-registered wallet address (an Externally Owned Account, or “EOA”) associated with your Card. Neither Spoynt nor Wirex has access to funds through Privy; Privy’s function is limited to key generation and transaction signing infrastructure.
Cardholder: The individual authorised to use the Card, typically the person in whose name the Spoynt Account is registered, unless multiple Cardholders are designated under a single account with Spoynt’s approval. For physical Cards, the Cardholder’s name may be printed on the Card; for virtual Cards, it is associated with the Spush profile.
Spoynt Account: An electronic money account provided by Spoynt Limited in collaboration with Noveba Limited, serving as the financial hub for your payment activities in Spush. This account holds Electronic Money, which you can manage through the Spush Personal Panel, and is subject to the terms of service governing electronic money issued by Noveba Limited. Funds held for your Card are separate from your Spoynt Account (see Section 16).
Spush: Spoynt Limited’s proprietary mobile wallet application, available for download on iOS and Android devices. Spush enables you to add, manage, and use your Card, monitor Transaction history, set spending limits, and perform other account-related functions, leveraging secure authentication methods like biometric identification and one-time passwords.
Electronic Money: Monetary value issued by Noveba Limited on behalf of Spoynt Limited, electronically stored in your Spoynt Account. This value represents funds you have transferred to Spoynt, can be redeemed at nominal value upon request, and is safeguarded under EMI regulations to protect against insolvency risks. Electronic Money is separate from the funds held for your Card; you can move funds from your Spoynt Account to your Card by SEPA transfer as described in Section 16.
Transaction: Any financial operation executed using the Card, encompassing payments for goods or services at physical merchants or online platforms, and fund transfers initiated via Spush or the Personal Panel. Transactions may be subject to currency conversion and Fees as detailed in Section 7.
Personal Panel: The secure, app-based portal accessible within Spush app, where you can view and manage your Spoynt Account and Card details.
PIN: A four-digit Personal Identification Number issued for each physical Card (where physical Cards are offered), delivered via SMS to your registered mobile number upon Card issuance.
CSC Code: A three-digit Card Security Code (also known as CVV or CVC), printed on the back of physical Cards or displayed within Spush for virtual Cards.
Fees: Charges payable for Card-related services, including issuance, maintenance, Transactions, currency conversion, and additional features, as outlined in Section 7. Depending on the Fee, it is charged by Spoynt or by Wirex under the Wirex Terms, and it may vary based on usage or Card type (physical vs. virtual).
Authentication Tool: Security mechanisms employed to verify your identity for Card and Spoynt Account access, including biometric authentication, one-time passwords (OTPs), and static passwords, complying with Strong Customer Authentication (SCA) requirements under the Payment Services Regulations 2017.
Transaction Limit: The maximum monetary amount or frequency of Transactions permitted per day, week, or month, set by Wirex (in coordination with Spoynt) based on risk assessment and regulatory requirements and, where Spush allows, adjustable by you subject to Wirex’s approval.
3. Scope of Services Provided
Spoynt Limited, through its Spush product, delivers a digital payment ecosystem designed to empower you with convenient, secure, and flexible payment options. This ecosystem presents Cards issued by Wirex within Spush alongside electronic money services facilitated by Noveba Limited. Spush serves as the primary interface for managing your Card, enabling you to perform a range of financial activities directly from your iOS or Android device. These activities include making contactless payments at merchants equipped with Near Field Communication (NFC) terminals, executing online purchases across various e-commerce platforms, adding your Card to a Digital Wallet, and topping up your Card as described in Section 16. Cash withdrawals from ATMs are not currently available with the Card.
The scope of services extends beyond mere Transaction facilitation. Spush provides real-time Transaction monitoring, allowing you to view detailed statements that include date, time, amount, merchant name, and currency for each Transaction. You can also, where available, set custom Transaction Limits, freeze or unfreeze your Card instantly in case of security concerns, and receive push notifications for every Transaction to stay informed of account activity. The integration with Noveba Limited ensures that your Electronic Money is securely held and managed, adhering to the safeguarding requirements mandated by the Electronic Money Regulations 2011, which stipulate that customer funds be kept separate from Spoynt’s operational funds to protect against financial instability.
Wirex, as the Card issuer, provides the Card infrastructure necessary for Transactions. Physical Cards (where offered) feature advanced security elements such as EMV chip technology and contactless payment capabilities, while virtual Cards offer a digital-first solution for online and mobile payments, accessible exclusively through Spush. This partnership ensures that your Card operates within the global payment network of Visa, providing broad acceptance and reliability across millions of merchants worldwide.
These Terms delineate the responsibilities of all parties involved: Spoynt Limited operates the Spush app and acts as a referral source and technical facilitator for the Card, Noveba Limited manages the Electronic Money underlying your Spoynt Account, and Wirex issues the Card and is responsible for Card onboarding checks, Transaction processing and Card complaints. Together, they form a payment solution tailored to meet the needs of modern consumers, balancing convenience with stringent security standards. The services are provided in compliance with UK financial regulations, including the Payment Services Regulations 2017, which govern payment execution timelines, liability limits, and customer protections, ensuring that you benefit from a regulated and trustworthy financial product.
4. Eligibility and Registration
To access the Spush mobile wallet and obtain a Card issued by Wirex, you must meet specific eligibility criteria and complete a detailed registration process designed to comply with applicable regulatory requirements and ensure the integrity of Spoynt’s services. Eligibility is restricted to individuals who are at least 18 years of age at the time of application, as Spoynt does not provide services to minors under any circumstances due to legal and contractual limitations.
You must additionally be a resident of the United Kingdom or of a Member State of the European Economic Area, and of a country in which Wirex makes the Card available. Wirex is the Card issuer for all Cardholders, and the Wirex Terms apply to you whether you are resident in the UK or the EEA.
This eligibility criteria is separate from, and should not be confused with, the general prohibited-jurisdictions list maintained for Spoynt’s broader e-money services (published at https://spush.co.uk/terms-of-business), which reflects AML/sanctions screening for the Noveba-issued Electronic Money relationship rather than Card issuance eligibility specifically.
The registration process begins with downloading Spush from the Apple App Store or Google Play Store onto a compatible mobile device running a supported operating system. Upon installation, you will be prompted to create a Spoynt Account by providing accurate and up-to-date personal information, including your full legal name, residential address, email address, mobile phone number, and date of birth. This information is essential for establishing your identity and ensuring compliance with Know Your Customer (KYC) obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
Following initial data submission, Spoynt, in collaboration with Noveba Limited, conducts a KYC verification process to confirm your identity and assess your eligibility. This process requires you to upload clear, legible copies of government-issued identification documents, such as a valid passport, driving licence, or national identity card, along with proof of address dated within the last three months. These documents must be in English or accompanied by a certified translation, and Spoynt reserves the right to request additional documentation or conduct video verification if deemed necessary to satisfy AML and counter-terrorism financing (CTF) requirements.
Once your KYC verification is complete — typically within 1-3 business days, though complex cases may take longer — you will receive confirmation via Spush or email, activating your Spoynt Account. At this stage, you can apply for a Card. To issue the Card, Wirex carries out its own onboarding checks, and Spoynt shares with Wirex the KYC information it holds about you for that purpose; Wirex may ask you for further information. Wirex decides, independently of Spoynt and at its sole discretion, whether to accept you as a customer and issue a Card, and Spoynt cannot override that decision. If Wirex declines your application, or later ends your Card, Spoynt cannot provide you with the Card, although your Spoynt Account may remain available. Spoynt may itself refuse registration or a Card application without providing a detailed explanation, which may occur due to incomplete documentation, failure to meet eligibility criteria, suspicion of fraudulent activity, or alignment with internal risk management policies. If refused, any prepaid Fees are non-refundable, and you will be notified of the decision via your registered email or Spush notifications.
5. Card Issuance Process
The issuance of a Card for use with Spush involves a structured process designed to ensure efficiency, security, and compliance with regulatory standards. To initiate this process, you must log into Spush or the Personal Panel and submit a Card application by selecting your preferred Card type — a virtual Card or, where available, a physical plastic Card. The application requires you to confirm your delivery address (for physical Cards), review any applicable Fees, and accept the Wirex Terms and these Terms, ensuring you are fully informed of your obligations. Spoynt keeps a record of your acceptance, including the version you accepted, and shares it with Wirex on request.
Upon submission, Spoynt passes your application to Wirex, the Card issuer, which reviews it and decides whether to issue the Card (see Section 4). You will be notified of Wirex’s decision through Spush or by email. For physical Cards, delivery is handled by a secure, tracked postal service, and you will receive a tracking number via Spush or email where available; delivery times for your country will be shown in Spush.
Virtual Cards are issued once Wirex approves your application, with Card details (16-digit number, expiry date, CSC Code) generated and displayed securely within Spush. Any Fee for issuing a Card will be shown in Spush before you confirm your application.
You may request multiple Cards where Spush and Wirex allow it, provided each additional Cardholder (if applicable) completes the required KYC checks. Wirex assigns a unique Card number to each Card. Spoynt or Wirex may limit the number of Cards per account based on risk assessment or operational capacity, notifying you via Spush if a limit is reached or an application is declined.
6. Card Activation and Initial Setup
Activating your Card is a critical step to enable its use within the Spush ecosystem, ensuring that it is secure and personalised to you as the Cardholder. For physical Cards, upon delivery to your registered address, you must activate the Card through Spush or the Personal Panel by entering an activation code, or via biometric activation, aligning with Strong Customer Authentication (SCA) requirements under the Payment Services Regulations 2017. Activation requires a stable internet connection to verify your identity with Wirex’s systems.
Virtual Cards are pre-activated upon issuance. Once approved, Wirex generates the virtual Card details, which are immediately available in Spush under the “Cards” section, accessible after passing a security check. These details include the 16-digit Card number, expiry date, and CSC Code, all encrypted and viewable only within your secure Spush session.
Wirex issues a unique PIN for each physical Card, delivered securely via SMS to your registered mobile number. You may change the PIN at any time through Spush. Virtual Cards do not have a PIN, as they are designed for online and contactless Transactions authenticated via Spush.
To enable contactless functionality on a physical Card, you must complete an initial chip-and-PIN Transaction, activating the Card’s NFC chip for contactless payments up to the applicable regulatory limit. If the Card arrives damaged or you suspect tampering, do not activate it; contact Spoynt immediately via support@spush.co.uk to request a replacement.
7. Fees and Charges
Using the Card and Spush may incur various Fees, which are designed to cover operational costs, ensure service sustainability, and comply with the pricing transparency requirements of the Payment Services Regulations 2017. Fees relating to the Card (for example currency conversion) are set out in the Wirex Terms and in the fee schedule published at https://spush.co.uk/fees; Fees relating to your Spoynt Account are deducted from your Spoynt Account by Noveba Limited on behalf of Spoynt. All applicable Fees are shown in Spush before you incur them.
Fees are automatically deducted at the time of the triggering event from the balance to which they relate. If that balance is insufficient, the Transaction or service may be declined and Spush will notify you. Spoynt may adjust its Fees to reflect changes in operational costs, regulatory requirements, or market conditions, providing 30 days’ notice unless the change is mandated by law or beneficial to you; Wirex may change its Fees in accordance with the Wirex Terms. Non-payment of Fees may result in Card suspension or account restrictions until resolved, as detailed in Section 14.
8. Using the Card via Spush and Digital Wallets
Spush transforms your mobile device into a payment tool by integrating your Card into a digital wallet. To begin, add your Card to Spush by selecting “Add Card” from the app’s main menu. Virtual Cards are automatically synced to Spush upon issuance.
You can execute Transactions via Spush in several ways: contactless payments at NFC-enabled terminals; online purchases using your Card details with OTP confirmation; and in-app payments within supported third-party apps. Virtual Cards are restricted to online or remote Transactions and cannot be used where physical presentation is required. For physical Cards, Spush allows you to freeze/unfreeze the Card instantly.
Spush provides real-time Transaction history, custom spending limits, and push notifications for every Transaction, ensuring you have full visibility and control over your Card usage.
Adding your Card to Apple Pay or Google Pay. You can add your Card to a Digital Wallet. Wirex facilitates the provisioning of your Card to the Digital Wallet; the Card is legally issued by Wirex Limited. The Digital Wallet is a service provided by Apple Inc. or Google LLC and is subject to their separate terms and conditions. When you add your Card, a device-specific token replaces your actual Card number and is linked to your existing Card account; use of the token is subject to the same conditions as your Card, as set out in the Card Agreement. Using the token through a Digital Wallet is valid authorisation for a Transaction, and you can withdraw your consent by removing your Card from the Digital Wallet at any time.
You are responsible for keeping your device and credentials secure. If your device is lost, stolen or compromised, you must inform Wirex immediately and freeze your Card in Spush (see Section 11). Your liability for unauthorised Transactions is determined under the Card Agreement and applicable law (see Section 13). Certain personal and transaction data may be shared with Apple or Google to support wallet functionality, as described in Section 17. Wirex may suspend or terminate use of your tokenized Card in line with the Card Agreement. When you add your Card to a Digital Wallet you will also be asked to accept Wirex’s Issuer Terms and Conditions – Tokenized Card Use (UK & EEA), which apply in addition to these Terms.
Every Transaction using your Card requires authorisation to ensure security and compliance with the Payment Services Regulations 2017, processed by Wirex in coordination with Spoynt’s systems. Authorisation methods vary by Transaction type:
- In-Person (Physical Card): Insert or tap your Card at a POS terminal and enter your PIN, which Wirex verifies against its database. Contactless Transactions below the prevailing regulatory limit require no PIN after initial activation.
- Online (Physical/Virtual Card): Enter the Card number, expiry date, and CSC Code on a merchant’s website, followed by an additional security check (e.g., 3D Secure), where Spush sends an OTP to your device for confirmation.
- Spush Mobile Payments and Digital Wallets: Use NFC or in-app payment options, authenticated by biometric scan, device passcode or a Spush-specific PIN, aligning with SCA requirements.
Default Transaction Limits are set by Wirex when your Card is issued, based on risk profiles and regulatory guidelines. You can view your limits in Spush. Where Spush lets you change them, any change remains subject to Wirex’s limits and approval.
Transactions exceeding your available Card balance or your limits are declined by Wirex, with Spush notifying you and suggesting a balance top-up or limit adjustment. Funds may be reserved for pending Transactions and are released as set out in the Card Agreement. Wirex processes approved Transactions in real-time, typically reflecting in Spush within seconds.
Wirex or Spoynt may refuse authorisation for Transactions suspected of fraud, exceeding limits, or violating AML/CTF regulations, notifying you via Spush unless restricted by law.
10. Security Responsibilities
Maintaining the security of your Card, Spush, and Spoynt Account is a shared responsibility, with specific obligations placed on you as the Cardholder to prevent unauthorised access and use. You must safeguard your physical Card, PIN, CSC Code, and Spush login credentials at all times, storing physical Cards securely and never writing the PIN on the Card or storing it with it.
On your Spush-enabled device, enable robust security features: a strong device PIN, biometric authentication, and automatic locking after a short inactivity period. Install Spush only from official app stores and keep your device’s operating system and Spush updated to the latest versions. If you jailbreak or root your device, Spush’s security may be compromised — and given that your Card’s cryptographic keys are generated and held via Privy, a jailbroken or rooted device may also compromise the integrity of that key infrastructure — and Spoynt reserves the right to suspend services until restored to a secure state.
Report any suspected security breaches affecting Spush or your Spoynt Account immediately via Spush’s “Report Issue” feature or by emailing support@spush.co.uk. For anything affecting your Card, also follow Section 11. Spush allows instant Card freezing with a single tap, effective until you unfreeze or request a replacement. Failure to comply with these security measures may shift liability for unauthorised Transactions to you, as outlined in Section 13, especially if deemed grossly negligent under Regulation 77 of the Payment Services Regulations 2017.
Spoynt employs industry-standard security protocols, including end-to-end encryption for data transmission, tokenization of Card details in Spush, and multi-factor authentication, to protect your information.
Prompt action is essential if your Card or Spush device is lost, stolen, compromised, or you suspect unauthorised use. Immediately freeze the Card in Spush by selecting “Freeze Card” under “Card Settings”, which suspends Transactions within seconds and tell Spush support. If your device is lost, stolen or compromised, also remove your Card from any Digital Wallet on it. You can contact support@spush.co.uk for help with Spush itself.
When reporting, provide your full name, the date and time you noticed the issue, the circumstances, and any recent Transactions you suspect as unauthorised. Wirex handles the report, blocks and replaces the Card, and investigates in accordance with the Card Agreement. If the Card is found after freezing, you can unfreeze it via Spush after verifying your identity, unless Wirex has cancelled it; a Card that has been reported lost or stolen must not be used. A replacement Card is issued by Wirex under the Card Agreement and may be subject to a Fee, which will be shown in Spush before you confirm. Virtual Cards are replaced with new details in Spush once issued.
If unauthorised Transactions occur before you report, tell Wirex without undue delay and no later than 13 months after the debit date to preserve your rights (see Sections 12 and 13).
12. Transaction Disputes and Refunds
Spoynt encourages proactive monitoring of your Card activity to quickly identify and resolve discrepancies. Review your Transaction history regularly in Spush’s “Transactions” tab or the Personal Panel, and keep your receipts and records. If you detect an unauthorised or incorrect Card Transaction, tell Wirex without undue delay and in any event within 13 months of the transaction, as the Card Agreement requires; if you do not, Wirex may treat the Transaction as correct. You can notify Wirex through Spush Support channel. Provide a detailed explanation and supporting evidence, such as receipts or correspondence with the merchant.
Wirex investigates and decides Card Transaction disputes under the Card Agreement. If you are entitled to a refund for an unauthorised Transaction, Wirex will make it no later than the end of the next business day under the Card Agreement. Disputes about goods or services must in the first instance be taken up with the merchant, and a refund for a purchase must be requested from the merchant; Wirex may, but is not required to, raise a formal dispute with the merchant on your behalf, through Visa’s dispute processes where applicable. If a complaint remains unresolved, see Section 20.
13. Liability and Indemnity
Your liability as a Cardholder hinges on responsible usage and timely reporting. You are liable for all authorised Transactions — those you initiate or approve via PIN, CSC Code, Digital Wallet, or Spush authentication — regardless of outcome, as Spoynt and Wirex facilitate payment, not product guarantees. Maintaining a sufficient balance on your Wirex-held Card account is your responsibility; if a Card balance becomes negative, you must top it up immediately, and the Card Agreement sets out what Wirex may do in that case.
Under the Card Agreement, unless you have acted fraudulently or with intent or gross negligence, your liability for unauthorised Transactions is limited to a maximum of £35 (or the equivalent in the currency of your Card) up until the time you inform Wirex that your Card has been lost or stolen, and you are not liable for losses that occur after you have informed Wirex. If you fail to keep your credentials and device secure as required by Section 10, or do not report promptly, you may bear the resulting losses to the extent the Card Agreement and applicable law allow.
Spoynt and Noveba Limited disclaim liability for losses from third-party actions — e.g., merchant refusals or network outages — unless directly caused by our gross negligence, and Wirex’s liability is as set out in the Card Agreement. Force majeure events exempt us from liability if services are disrupted. We are not responsible for indirect losses or merchant disputes over goods/services, which you must resolve directly with the seller.
You indemnify Spoynt and Noveba Limited against losses arising from your breach of these Terms or fraudulent activity, reimbursing us within 10 business days of demand via Spoynt Account deduction or bank transfer. Your obligations to Wirex are set out in the Wirex Terms. This indemnity ensures our financial stability while encouraging lawful Card use, with disputes handled per Section 20.
14. Card Suspension and Revocation
Wirex may suspend or revoke your Card in accordance with the Card Agreement to protect security, comply with legal obligations, or enforce its terms. Spoynt may also suspend your access to the Card within Spush to protect security, comply with legal obligations, or enforce these Terms, and will pass relevant information to Wirex where required. Suspension occurs if we or Wirex suspect fraud, detect a security breach, or receive a regulatory directive; we will notify you via Spush push alert or email within 1 business day unless prohibited by law.
Failure to activate your Card within 6 months of issuance prompts automatic suspension, with Spush emailing a 30-day warning beforehand. Breaches like exceeding Transaction Limits repeatedly or using the Card for prohibited activities also justify suspension. During suspension, all Card Transactions are blocked, but your Spoynt Account remains accessible for balance checks and top-ups.
Reactivation requires resolving the issue. Where Spoynt imposed the suspension, Spoynt will reinstate your access within 3 business days of resolution; where Wirex imposed it, reinstatement is at Wirex’s decision. If unresolved, the Card is revoked permanently, requiring a replacement request per Section 11. Expired or revoked physical Cards must be destroyed by cutting through the chip and magnetic stripe, or returned to Spoynt.
Revocation may also occur by Wirex’s decision or by regulatory mandate, with immediate effect and notice provided unless restricted. This process balances security with your ability to restore service, ensuring compliance with the Electronic Money Regulations 2011 and Payment Services Regulations 2017.
15. Spush Application Usage Terms
Spush is a cornerstone of your Card experience, licensed to you by Spoynt Limited under specific terms to ensure lawful and secure usage. Upon downloading Spush from the Apple App Store or Google Play Store, Spoynt grants you a non-exclusive, non-transferable, revocable license to use the app solely for personal, non-commercial purposes related to managing your Card and Spoynt Account.
You must download Spush exclusively from official stores, avoiding third-party sources that may contain malware or unauthorised modifications. Spoynt releases regular updates, which you must install promptly to maintain compatibility and protection.
Spoynt retains full ownership of Spush’s intellectual property. You may not modify, reverse-engineer, decompile, or distribute Spush. Attempts to bypass security features violate these Terms, triggering immediate suspension of Spush access and Card services.
Spush access may be interrupted for scheduled maintenance, announced in advance via push notifications. This license expires upon termination of these Terms (Section 19), requiring you to delete Spush from all devices.
16. Card Funds and Electronic Money Management
Card funds are held separately from your general Spoynt Account Electronic Money balance. Your Card draws on an account created for you by Wirex, to which only you have access; Spoynt does not hold or have access to these funds. Each Card Transaction is authorised and signed using cryptographic keys generated and held via Privy (see Section 17), not by Spoynt or Noveba Limited. Funds held for your Card do not earn interest, are not bank deposits and are not covered by the Financial Services Compensation Scheme; how Wirex safeguards them is described in the Card Agreement.
Card balances. Your Card has two balances: EUR and USD.
Topping up your Card. You can top up your Card in two ways: (a) from your Spoynt Account (your Spush eWallet) by SEPA transfer; or (b) directly via crypto networks, using the networks and tokens made available in Spush at the time. A top-up in USDC or USDT updates your USD balance. A top-up in EUR, or by SEPA transfer, updates your EUR balance.
Currency conversion. If you pay in a currency other than the currency of your Card balances, or the balance in the currency needed is not enough, your Card automatically converts and uses another available balance, at the exchange rate and subject to the Fees applicable at the time (see Section 7 and the Card Agreement).
Noveba Limited, as Spoynt’s EMI partner, continues to issue and manage Electronic Money in your general Spoynt Account for non-Card purposes (e.g., IBAN transfers). This Electronic Money earns no interest, per EMI regulations, and is safeguarded in segregated accounts under Regulation 20 of the Electronic Money Regulations 2011, protecting it from Spoynt’s or Noveba’s insolvency.
17. Data Protection and Privacy
Spoynt prioritises your privacy, processing personal data in strict compliance with the UK GDPR and Data Protection Act 2018, as detailed in our Privacy Policy at https://spush.co.uk/privacy-policy. We collect data such as your full name, address, email, phone number, date of birth, ID documents, Transaction history, IP address, and device information during registration, Card usage, and Spush interactions. This data enables service provision, KYC/AML compliance, fraud prevention, and customer support, with legal bases including contract necessity (Article 6(1)(b) UK GDPR) and legitimate interests (Article 6(1)(f)).
Data is shared with Noveba Limited for Electronic Money management, and with Wirex Limited, the Card issuer, for Card onboarding checks, Card issuance and Transaction processing. For this purpose, we share with Wirex the KYC information we hold about you so that Wirex can complete its own checks, and we may ask you for further information that Wirex requires. Wirex and Spoynt each act as an independent controller of the personal data they process; Wirex’s use of your data is described in the Wirex Privacy Policy. When you add your Card to a Digital Wallet, certain personal and transaction data may also be shared with Apple or Google to support wallet functionality, as described in Wirex’s issuer terms for tokenized card use.
We also share your email address and your device-registered wallet address (an Externally Owned Account, or “EOA”) with Privy, a third-party infrastructure provider engaged to generate and manage the cryptographic keys underlying your Card account. Your email is used solely as an identifier to link you to your keys. Privy generates keys only — it does not hold or provide wallet storage, and neither Spoynt nor Wirex has access to funds through Privy’s infrastructure; each Transaction is signed using keys held on Privy, and funds themselves are held in an account created by Wirex to which only you have access.
Third-party processors (e.g., payment gateways, analytics providers) may access anonymised data under strict data processing agreements per Article 28 UK GDPR, ensuring confidentiality and security. International transfers outside the UK/EEA use Standard Contractual Clauses, with impact assessments ensuring equivalent protection, per Chapter V UK GDPR.
We keep records relating to your Card, including the information we provide to Wirex, for at least five years after your relationship with Wirex for the Card ends, so that we can make it available to Wirex on request, and otherwise in line with the retention periods in our Privacy Policy.
Spoynt records Spush interactions and support calls for quality assurance and dispute resolution, and stores them securely for no longer than necessary for those purposes and in accordance with statutory retention rules and our Privacy Policy. You consent to this recording via these Terms. Access your data rights — view, correct, delete, restrict, or port data — by emailing privacy@spush.co.uk with your Spoynt Account number; we respond within 1 month, extendable to 2 for complex requests, per Article 12 UK GDPR.
Data breaches are reported to the Information Commissioner’s Office (ICO) within 72 hours per Article 33 UK GDPR, with high-risk incidents notified to you via Spush/email. Security measures include AES-256 encryption, regular audits, and staff training.
18. Amendments to Terms
Spoynt may amend these Terms to reflect operational, legal, or customer-focused changes, ensuring compliance with Regulation 51 of the Payment Services Regulations 2017. Amendments are notified with 2 months’ advance notice via Spush push notifications and the Personal Panel’s “Announcements” section, linking to the updated Terms. Wirex may update the Wirex Terms in accordance with their provisions; where Wirex notifies us of an update, we will present it to you in Spush and may ask you to accept it before you continue to use the Card.
Immediate amendments apply without notice if mandated by law or if beneficial to you. Continued Card use or Spush activity post-notice constitutes acceptance of amendments. To reject, terminate before the effective date by following Section 19.
19. Termination of Agreement
Termination of these Terms may occur by your choice or Spoynt’s initiative. To cancel your Card, notify Spoynt via Spush’s “Close Card” option or contact Wirex customer support; cancellation of the Card is handled by Wirex under the Card Agreement, which also gives you a 14-day right to cancel. Termination of these Terms takes effect 30 calendar days after your notice, allowing time to settle obligations or redeem Electronic Money per Section 16. You must destroy physical Cards by cutting through the chip and stripe, and delete Spush from your device post-confirmation.
Spoynt may terminate with 2 months’ notice for operational reasons, per Regulation 51. Immediate termination occurs for breaches like fraud, AML violations, or legal orders. Wirex deactivates the Card instantly, and Spush restricts Transaction access, retaining balance visibility for redemption.
Post-termination, redeem the Electronic Money in your Spoynt Account within 30 days via Spush’s “Withdraw Funds”, subject to any Fee shown in the fee schedule. Unredeemed balances after 30 days incur any holding Fee shown in the fee schedule, deducted by Noveba Limited until exhausted or withdrawn. Spoynt may waive Fees for Consumers terminating after 6 months, refunding pro-rata pre-paid amounts, per Regulation 46. Obligations like indemnities (Section 13) survive termination.
20. Governing Law, Complaints, and Final Provisions
The Card. The Card Agreement, including its governing law and dispute resolution provisions, governs your agreement with Wirex, and is governed by English law. If you are resident in the EEA, nothing in the Card Agreement or in these Terms removes any right you have under the mandatory consumer protection law of your country of residence, including, where it applies, the right to bring proceedings in the courts of the country where you are domiciled or resident.
These Terms. For UK Cardholders, these Terms are governed by the laws of England and Wales, and disputes fall under the exclusive jurisdiction of English courts, with proceedings conducted in London unless otherwise agreed. For EEA Cardholders resident outside the UK, disputes under these Terms fall under the jurisdiction of the courts of your own country of domicile or residence, unless applicable mandatory law requires otherwise.
Complaints about the Card. Complaints about the Card, Card Transactions or Wirex’s services are handled by Wirex. Contact Wirex at customercomplaints@wirexapp.com; Wirex responds within 15 business days and in any event within 35 business days, as set out in the Card Agreement. If you are a UK Cardholder and your complaint is not resolved to your satisfaction, you may refer it to the Financial Ombudsman Service — www.financial-ombudsman.org.uk, 0300 123 9123, Exchange Tower, Harbour Exchange, London E14 9SR — free for Consumers and Micro-enterprises. If you are an EEA Cardholder, Wirex’s complaints procedure and the rules of your country of residence explain the alternative dispute resolution options available to you.
Complaints about Spush and Spoynt’s services. Contact Spoynt at support@spush.co.uk or via app support functionality, submitting your Spush Account number, issue details, and evidence. We respond within 15 business days, extendable to 35 days for complex cases, per FCA Dispute Resolution rules (DISP 1.6). Unresolved issues can be referred to the Financial Ombudsman Service within 6 months of our final response, using the details above.
Spoynt and Noveba Limited may assign rights to third parties without consent, notifying you via Spush, and Wirex may assign as set out in the Card Agreement; your assignment needs written approval from support@spush.co.uk. If a provision is unenforceable, others remain effective, with courts adjusting to reflect intent. Notices are sent via Spush, email, or post to 71-75 Shelton Street, London, WC2H 9JQ, ensuring compliance with Regulation 58 transparency requirements.
Contact Information
Spoynt Limited 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, UK Email: support@spush.co.uk
Noveba Limited (EMI Partner) https://noveba.com
Wirex Limited (Card Issuer) 9th Floor, 107 Cheapside, London, EC2V 6DN, UK https://wirexapp.com Customer support: https://wirexapp.com/help/request/create Complaints: customercomplaints@wirexapp.com
Privy (Key Management Infrastructure Provider)