1.1 Definitions
In these Terms & Conditions (“Terms”), unless otherwise stated, the following definitions apply. Terms defined in the singular also include the plural and vice versa:

• “Account” or “Spush Payment Account”: The electronic money account registered in your name with Spoynt Limited, including any associated currency pockets, through which you access the Services (including Spush).
• “Agreement”: These Terms and any additional policies referenced herein, forming a binding agreement between you and Spoynt Limited.
• “AML”: Anti-Money Laundering, referring to regulations designed to prevent illicit funds from entering the financial system.
• “Authorised Transaction”: Any transaction that you explicitly approve via Spoynt Limited’s designated authentication methods (e.g., PIN, password, biometric prompt).
• “Business Day”: Any day (excluding Saturdays, Sundays, and public holidays) on which banks in England and Wales are open for normal business.
• “Client”, “Customer”, or “You”: The individual or entity opening or holding a Spush Payment Account with Spoynt Limited.
• “Confidential Information”: Non-public information exchanged between you and Spoynt Limited that is marked as confidential or that, by its nature, would reasonably be deemed confidential.
• “CTF”: Counter-Terrorist Financing, referring to measures designed to prevent funds from being used for terrorist activities.
• “Data Protection Laws”: All applicable data protection legislation in force in the UK, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
• “Dormant Account”: A Spush Payment Account that has had no client-initiated transactions for a continuous period as defined in Spoynt Limited’s internal policies or by applicable regulations.
• “Electronic Money” or “e-money”: Electronically stored monetary value issued by Noveba Limited pursuant to the Electronic Money Regulations 2011.
• “EMD Agent”: An entity listed on the Financial Services Register as an agent of an EMI, permitted to distribute and redeem e-money on behalf of that EMI. Here, Spoynt Limited is the EMD Agent, and Noveba Limited is the EMI.
• “EMI”: Electronic Money Institution, referring to Noveba Limited, which is authorised and regulated by the FCA under FRN 900924.
• “Fee Schedule”: A separate document (or webpage) detailing all fees, commissions, and charges applied by Spoynt Limited.
• “FCA”: The Financial Conduct Authority in the UK, or any successor body.
• “Noveba Limited” or “Noveba”: The FCA-authorized Electronic Money Institution (FRN: 900924) that issues e-money, holds the relevant funds, and safeguards them in accordance with applicable regulations.
• “Payment Instrument”: Any personalised device, credential, or authentication method (e.g., card, PIN, password, app login) used to initiate a transaction.
• “Privacy Policy”: Spoynt Limited’s policy describing how it processes personal data, accessible at [Privacy Policy URL or link].
• “Prohibited Transactions”: Transactions that violate applicable laws, regulations, sanctions, or these Terms (including but not limited to money laundering, terrorist financing, and illegal goods/services).
• “Services”: All payment and e-money related services provided by Spoynt Limited in its capacity as an EMD Agent on behalf of Noveba Limited, including the Spush web/digital wallet solution.
• “Spoynt Limited,” “we,” “us,” or “our”: The company incorporated in England and Wales (Company Number 14156599), which is an EMD Agent of Noveba Limited. Spoynt Limited’s FCA Reference Number is 903071. Registered Office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.
• “Spush”: The digital/web wallet product name operated by Spoynt Limited, accessible at https://spush.co.uk, Apple Store, Play Market.
• “Transaction Limit”: Any monetary cap on the volume or amount of transactions set by Spoynt Limited or Noveba based on risk assessments or regulatory obligations.

1.2 Interpretation

• References to “writing” include email unless otherwise specified.
• Section headings are for convenience only and do not affect interpretation.
• The singular includes the plural, and vice versa.

2.1 Scope of These Terms
These Terms govern the relationship between you and Spoynt Limited regarding the creation, maintenance, and use of your Spush Spush Payment Account and any related Services we offer as an EMD Agent on behalf of Noveba Limited (the EMI).

2.2 Acceptance of Terms
By opening a Spush Payment Account or otherwise using our Services, you represent that you have read, understood, and agree to be bound by these Terms, as well as any additional documents referenced herein (e.g., Fee Schedule, Privacy Policy, and Noveba’s Terms & Conditions).

2.3 Relationship with Noveba
2.3.1. Noveba Limited is the licensed EMI that actually issues the e-money, safeguards client funds, and is authorised by the FCA (FRN: 900924).
2.3.2. Spoynt Limited, as EMD Agent, facilitates the distribution and redemption of e-money and provides certain payment services on Noveba’s behalf.
2.3.3. As an EMD Agent, Spoynt Limited does not itself issue e-money or hold client funds; those functions are performed by Noveba.
2.3.4. Noveba’s Terms & Conditions govern the e-money issuance and safeguarding obligations. Click here to review them.
2.4. Additional Scope of Services Provided by Noveba to Spoynt (Under the EMD Agent Agreement
Noveba provides Spoynt Limited with connections to it’s digital banking and payment infrastructure that allows to:

• Issue and/or arrange for the establishment of an e-money account (an IBAN account);
• Issue and/or arrange the issuance of the e-money linked to such IBAN account;
• Execute the payment transactions linked to the IBAN account;
• Carry out money transfers linked to such IBAN account;
• Provide a technology for the above purposes, including back-end/back-office system access allowing IBAN account user(s) management, emergency support procedures (e.g., block/close IBAN account), sales-related materials, and price schedules.
• Provide all necessary administrative support for project implementation, including system user management, test and live IBAN accounts management, connectivity and integration work (if necessary), client and user documentation, and day-to-day IBAN account user support.

Additionally, Noveba makes available to Spoynt Limited’s Customers a solution, which includes:

• Client online onboarding process, including KYC/KYB checks;
• IBAN account issuing with a unique IBAN account number;
• IBAN account registration process;
• Funds loading (incoming payments) to e-wallet/IBAN account;
• e-wallet/IBAN account view;
• e-wallet/IBAN account transaction history (statements);
• Ordering and management of payment cards (subject to separate terms and conditions).

Noveba provides the digital banking and payment infrastructure (IBAN accounts, e-wallet functionality, etc.).
Spoynt Limited, as EMD Agent, integrates all these capabilities into its platform and handles day-to-day user support, KYC/KYB, administrative tasks, and business processes related to the IBAN account usage.

3.1 Non-Bank Status & FSCS Disclaimer
The Spush Spush Payment Account is not a bank account. Funds held on your Spush Spush Payment Account do not earn interest and are not covered by the UK Financial Services Compensation Scheme (FSCS).
Neither Spoynt Limited nor Noveba Limited is a bank; neither is insured by any government agency, nor subject to traditional banking regulations.

3.2 Ownership of Funds
The funds reflected on your Spush Spush Payment Account balance belong to the individual or legal entity registered as the Customer (Spush Payment Account holder).
Except in cases of legal succession, no other person has rights to the funds on your Spush Payment Account. You may not assign or transfer your Spush Payment Account to any third party, nor grant any third party a legal or equitable interest in it.

3.3 Default Currency & Multi-Currency
Your Spush Payment Account may initially be denominated in a default currency (e.g., EUR), or in multiple currencies if so provided.
You can add additional currency pockets to your Spush Payment Account, each constituting a separate sub-balance within the overall Spush Payment Account structure.

3.4 Multi-Currency Spush Payment Account
You may maintain several currency pockets (e.g., EUR, GBP) simultaneously. Each currency pocket is part of your Spush Payment Account functionality. The Spush Payment Account is composed of all these currency pockets.

3.5 Unique Identifier
Upon issuance and opening of a Spush Payment Account with Noveba (via Spoynt Limited), each Customer is assigned a Unique Identifier.
This Identifier is required to identify the Customer for each Payment Transaction (as payer or payee).

3.6 Noveba’s Responsibility & Liability
Noveba bears responsibility for funds that are under processing and kept on the Spush Spush Payment Account.
Noveba is not liable for funds prior to the commencement of the placement transaction into the Spush Spush Payment Account, or after the transfer Payment Transaction to an external Payment Service Provider has been processed.

3.7 Safeguarding of Relevant Funds
Noveba will hold all “Relevant Funds” (as defined by the Payment Services Regulations 2017) segregated from any other funds it holds.
If Noveba continues to hold Relevant Funds at the end of the business day following their receipt, Noveba will:

• (a) place them in a separate account with an authorised credit institution (client money account), or
• (b) invest them in secure, liquid assets approved by the FCA and place those assets in a separate account with an authorised custodian.

Any such account used for Relevant Funds or relevant assets will (i) be designated to show it is held for safeguarding, and (ii) be used only for holding those funds or assets.

3.8 No Third-Party Interests
Noveba guarantees that no person other than Noveba itself may have any interest or right over the Relevant Funds placed in a client money account, except as provided by regulation.

3.9 Record-Keeping
Noveba will keep a record of any segregated Relevant Funds placed in a client money account.

3.10 Net Basis Operation
The Spush Spush Payment Account operates on a net basis. Any current liabilities you owe (e.g., fees or repayment obligations) may be set off against the funds held on your Spush Payment Account.
Noveba (or Spoynt Limited acting on Noveba’s instructions) is entitled to settle any such liability from your Spush Payment Account balance without prior notice.

3.11 Independent Role of Noveba
You acknowledge that Noveba (and by extension, Spoynt Limited) operates solely and independently as a payment intermediary. Noveba does not function as a seller, buyer, dealer, retailer, broker, agent, auctioneer, or merchant of any products or services procured by the Customer through the Spush Spush Payment Account.
Noveba makes no representations or warranties, nor ensures quality, safety, or legality of products or services purchased with funds on your Spush Spush Payment Account.

3.12 Disputes on Goods/Services
Any dispute regarding products or services purchased using the Spush Spush Payment Account (or Noveba’s payment services) is strictly between the payer and payee. Noveba (or Spoynt Limited) is not a party to such disputes, including those over performance, liability, or quality of goods/services.
You shall indemnify Noveba (and Spoynt Limited) against any claims brought by third parties relating to your use of products/services purchased with Spush Payment Account funds, and you shall reimburse the full costs of any legal defence.

4.1 Registration Process
To use the Spush Payment Account (including Spush), you must register by providing details on our website or platform (e.g., completing a registration form). You must accept these Terms, and you must have the legal authority to do so.
If registration is successful, you will obtain credentials for your new Spush Payment Account and a Unique Identifier, which we will send to your registered email and/or display on your Spush Payment Account screen.

4.2 Corporate Registration
If you register a Spush Payment Account as a legal entity, you must fill out and provide a corporate Spush Payment Account opening application form, plus supporting documents/information deemed necessary by Spoynt Limited or Noveba.

4.3 Verification & “Not Verified” Status
Newly registered Spush Payment Accounts have a “Not Verified” status. You cannot initiate any Payment Transactions until you complete the verification procedure and provide all documents/information required for AML/CFT compliance.
Verification data must be accurate and complete to meet anti-money laundering (AML) and counter-terrorism financing (CTF) requirements.

4.4 Legality of Registration
You may only register a Spush Payment Account if it is legal to do so in your country of residence. By registering, you warrant that creating and using the Spush Payment Account does not violate any laws or regulations applicable to you.
You shall indemnify us for any losses incurred due to your breach of this representation.

4.5 One Account per Person or Entity
You may hold only one Spush Payment Account per individual or legal entity. Spoynt Limited (or Noveba) may refuse creation of duplicate Spush Payment Accounts and may close or merge them at its sole discretion.

4.6 Accuracy of Information
All information you provide must be accurate and truthful. You must promptly update any details if they change.

4.7 Business vs. Private Use
During registration, you must declare whether you intend to use your Spush Payment Account for private or business purposes (or both). We reserve the right to determine, in our reasonable opinion, if your Spush Payment Account is used for business purposes.
Funds you receive or send under a business context should be legal and based on a valid agreement between you and your client(s). If in doubt, contact Customer Support. You must inform us of any future changes to your usage.

4.8 Licenses & Authorisations
If you use the Spush Payment Account for business purposes, you must comply with all applicable laws, obtain and maintain all legally required licenses, authorisations, and permits, and ensure ongoing compliance for the business activities tied to the Spush Payment Account.

5.1 KYC and AML Checks
Before executing any Payment Transaction, Spoynt Limited or Noveba may perform various checks to prevent money laundering or fraud. This may include requesting further KYC (Know Your Customer) or CDD (Customer Due Diligence) documents from you.

5.2 Prompt Updates
You must notify us within 30 (thirty) calendar days of any changes to information provided at registration. We shall not be liable for any loss arising from your failure to do so.
We may also request periodic reconfirmation of your details or additional evidence to meet AML/CFT obligations.

5.3 Authorised Use
You must not provide any name, bank account, or credit card information you are not legally authorised to use.

5.4 Transaction Records
All operations (Payment Transactions) appear in your online Payment Transaction history, accessible via the Spush (Spoynt) platform. Each transaction has a unique ID; quote this ID when contacting us about a specific transaction.
You should regularly check your Spush Payment Account balance and transaction history to identify and report any irregularities or questions.

5.5 Electronic Communications
We will transmit reports, statements, notices, and other communications electronically (e.g., by posting in your Spush Payment Account area or emailing your registered email address). These communications are considered delivered when sent, regardless of whether you actually receive or view them.

5.6 Contact Issues
If we attempt to contact you using the details you have provided but cannot reach you, we may terminate any pending Payment Transaction immediately, without liability. You remain liable for any losses incurred due to such termination.

5.7 Inactive & Closure Criteria
If there are no Payment Transactions on your Spush Payment Account for 90 consecutive calendar days, your Account may be deemed “Inactive.”
If your Spush Payment Account remains inactive for 12 consecutive calendar months, Noveba (or Spoynt Limited on Noveba’s behalf) may close your Spush Payment Account without liability. These Terms of Use will be deemed terminated in such a scenario.

6.1 Security Credentials
You must safeguard your login details (username, password, PIN, etc.) and any two-factor authentication tools.
Never share these credentials with third parties. Spoynt Limited (Spush) will never request your full PIN or password by email or phone.

6.2 Unauthorised Access
If you suspect your Spush Payment Account credentials have been compromised or notice unauthorised transactions, contact us immediately at support@spush.co.uk

6.3 Liability for Breach
If you fail to take reasonable precautions to protect your credentials, you may be liable for losses from unauthorised transactions until you notify us.

7.1 Payment Orders & Authorisation
You must provide us with a Payment Order to authorise us to process a Payment Transaction or a series of recurring Payment Transactions.
Any Payment Order may be given and authorised by logging into your online account (Spush), entering your PIN or password, and confirming the transaction; or by using your card and entering its PIN or secure code.
By clicking the “Confirm” button, or entering your card PIN code or secure code, you give irrevocable consent to process the Payment Transaction. After authorisation, the Payment Order generally cannot be revoked.
If a Payment Order is initiated by or through the payee, you may not revoke it after it has been processed.
Where you agree on a specific day for a Payment Transaction, you may not revoke the Payment Order after the end of the business day preceding that agreed day.
Once funds are credited to the payee’s account, the transaction is irreversible. If funds go to a payee’s external account with another Payment Service Provider, once Spoynt Limited (on Noveba’s behalf) executes the Payment Order, the funds are treated as no longer under our control.

7.2 Standing Payment Orders
If you instruct us to process recurring (standing) Payment Transactions, each transaction is deemed received on the day agreed for that transaction.
You can revoke a standing Payment Order up until the close of business on the day before the agreed execution date. Revoking a recurring Payment Order cancels your consent for future transactions in that series as well.

7.3 Time of Receipt
We do not execute a Payment Transaction until we have received the Payment Order. The time of receipt is when the Payment Order is received (directly from you or through a payee).
If you and we agree the transaction should take place on a certain day (or the last day of a period, or the day you put funds at our disposal), the time of receipt is deemed that day—or the next Business Day if the agreed date is not a Business Day.

7.4 Refusal to Execute
If we refuse to execute a Payment Order, we will notify you (where lawful) of:

• (a) the refusal,
• (b) the reasons (if possible), and
• (c) the procedure for rectifying any factual errors that led to refusal.

This notice will be provided at the earliest opportunity, at the latest by the end of the Business Day following the time of receipt of the Payment Order. A refused Payment Order is deemed not received.

7.5 Execution of Payment Orders
Execution may vary depending on the method specified in the Payment Order:

• a) If the payee’s account is also with Noveba, the Payment Order will typically be processed on the same day, and the payee’s account is credited instantly (unless otherwise stated on our website).
• b) If the payee’s account is with another Payment Service Provider, the Payment Order is executed on the same or next Business Day from receipt, and the amount is debited from your Spush Payment Account instantly upon execution. The funds usually reach the payee’s external account within 1–5 Business Days, depending on the payment method (SEPA, SWIFT, etc.) and the external provider’s own policies.

7.6 Accuracy of Payee Details
We only process Payment Transactions to a payee if the correct Unique Identifier or other required payment details are provided.
You must ensure that the payee’s Unique Identifier/payment details are accurate. We are not liable for errors caused by incorrect details you submit.
If we cannot locate the payee based on the details you provide, the funds may be returned to you, and an administration fee may apply.

8.1 Placing Funds
You can add funds to your Spush Payment Account by visiting our website or Spush interface, logging in, and following the relevant instructions. Third parties can send you funds using the payment details shown in your account area.

8.2 Recipient Status
For funds placement, Noveba (via Spoynt Limited) acts as the payment recipient, not as a Payment Service Provider to the payer.

8.3 Adding New Currency Pockets
Initially, your Spush Payment Account may have only one currency pocket by default. You can add additional pockets by placing funds in a new currency. Successful processing of this request automatically adds the new currency pocket to your Spush Payment Account.

8.4 Placement Methods
You may have multiple methods available (e.g., bank transfer, card payment), depending on your country of residence. We do not guarantee continuous availability of any specific placement method. We are not responsible for your funds until we (or Noveba on our behalf) actually receive them.

8.5 Placement Flow
When placing funds, you (or a third party) must use the correct payment details (including your Unique Identifier) or follow the instructions in your online area.
You must authorize the placement transaction using your Payment Instrument (e.g., card or bank details).

8.6 Chargebacks & Reversals
If you use a payment method that allows chargebacks (e.g., certain cards), you agree not to exercise chargeback rights except in cases of unauthorised use.
We may charge you any fees or expenses incurred due to a chargeback or reversal, including the right to deduct such amounts from your Spush Payment Account balance or block your account.

8.7 Negative Balance
A chargeback or reversal may result in a negative balance on your Spush Payment Account. You must promptly deposit sufficient funds to cover any negative balance. Failure to do so is a breach of these Terms, and we reserve the right to pursue debt collection or block your account.

8.8 Notification of Placement
Placed funds are credited to your Spush Payment Account, and a notification (e.g., “Money Placed”) appears in your transaction history once the funds are received.

8.9 Timeframes
Placement transactions (e.g., by credit/debit card or SEPA transfer) are usually credited within 1 (one) Business Day from when we receive them.

8.10 Account Ownership
You must not make a placement from any bank account or Payment Instrument that is not in your name (unless explicitly authorised by us).

8.11 Placement Limits
Placement methods may be subject to security or legal limits. You can check these limits at your Payment Service Provider’s website or in your account interface.

8.12 Reversal on Suspicion
The fact that funds are credited to your Spush Payment Account does not guarantee the transaction cannot be reversed. Noveba (via Spoynt Limited) may reverse a payment if the sender or the sender’s Payment Service Provider initiates a chargeback, or if we have reasons to believe the funds are fraudulent.

8.13 Fees for Placement
Placements may be subject to fees (e.g., currency conversion) depending on the method used. These fees may be deducted from the placed amount before it appears in your Spush Payment Account.

9.1 Instructions for Transfer
To send funds to a third party, you must give us a Payment Order specifying:

• a) The payee’s Unique Identifier or other payment details (if external).
• b) The currency.
• c) The amount.
• d) Authorise the transaction with your PIN code (or equivalent).

9.2 Additional Security
We may send a confirmation link via email for added security. You must click this link before we queue the transaction for processing.

9.3 Processing Time
Once you confirm, the transaction goes into a “pending” status and is typically processed within 1 (one) Business Day. You can generally cancel the Payment Order while it is still “pending” (and revocable under Section 7.1).

9.4 Incorrect Payee Details
If the payee’s Unique Identifier or details are incorrect, we will notify you, cancel the transaction, and return the funds. An administration fee may apply.

9.5 Card-Based Transfers
You can also send funds with a card, requiring PIN or secure code authorisation. Processing times depend on the payment network (e.g., Visa/Mastercard).

9.6 Currency Conversion
If the transfer currency differs from your Spush Payment Account currency pocket, funds are converted at the stated exchange rate (see website). Additional fees may apply.

9.7 Transfer Limits
Transfers are subject to dynamic limits based on your verification status. Ensure you have enough limit to cover both the transfer and any fees. The recipient may also have limits.

9.8 Fees for Transfers
Third-party Payment Service Providers or banks may charge fees for receiving or converting funds. These fees may be deducted from the transferred amount.

9.9 Overseas Transfers & Data Sharing
For cross-border transfers, we may need to share your personal information with banks or entities outside the EEA, which may not have equivalent data protection laws. By using our services, you consent to such data sharing for the purpose of processing your transactions.

9.10 Transfers to Your Own Bank Account
You may withdraw funds to your bank account at any time, provided you have sufficient balance and you pass any required identity checks. The minimum transfer amount is typically zero (unless specified otherwise), but you must cover fees.

9.11 Payment Recipient Status
For transfers to your external bank account, Noveba (via Spoynt Limited) acts as the payer, not as your Payment Service Provider.

9.12 Accuracy of External Payment Details
You must ensure the external bank account details are correct. We are not liable if funds are sent to the wrong account due to incorrect payment details.

9.13 Revoking Transfer Consent
You can withdraw consent to a Payment Transaction at any time before it moves beyond the revocation window described in Section 7.1. We mark your transaction “pending” while it can still be cancelled.

9.14 Limit Exceedance
If a transfer exceeds your current limit, we may decline it and request additional verification (e.g., proof of identity or address).

9.15 Delayed Credit
If your wire transfer does not arrive within 10 (ten) Business Days, you may request an investigation. Such investigations may incur fees payable by you unless the delay is due to our error.

9.16 Third-Party Fees
Additional fees or currency conversion costs may apply depending on the method chosen. They may be deducted from the transferred amount.

9.17 AML/Fraud Checks
We reserve the right to conduct AML/CTF checks before authorising any transfer. This may include requesting additional documentation or information from you.

10.1 Intra-Account Transfers
You can move funds between currency pockets within your Spush Payment Account by following the on-screen instructions.

10.2 Exchange Rate & Fees
Such conversions use the rates displayed on our website, plus any additional commission we publish. The converted amount is reflected in the target currency pocket.

11.1 Restricted Goods & Services
We strictly prohibit Payment Transactions relating to the sale or supply of items that violate any law, including but not limited to:

• Tobacco, prescription drugs, controlled substances;
• Weapons, firearms, satellite/cable descramblers;
• Pornography (including child pornography);
• Adult material inciting violence, hatred, or racism;
• Government IDs/licenses, illegal lotteries or gambling, unregistered charity services;
• Any counterfeit or IP-infringing goods;
• Any activity or product that facilitates fraud or money laundering.

11.2 High-Risk or Sanctioned Countries
Our services are unavailable for residents of high-risk or sanctioned jurisdictions identified by FATF, the United Nations, the EU, or other authorities. We may suspend or terminate accounts in these jurisdictions without notice.

11.3 US Persons
Our services may not be available to US residents or other “US Persons,” as defined under applicable US laws.

11.4 Business Categories Requiring Approval
Certain business types require prior approval (e.g., money exchange, donation collection, sales of precious metals, etc.). If in doubt, contact us. We may add new categories at our discretion.

11.5 Consequences of Violations
If you attempt or conduct a prohibited transaction, we may:

• a) Reverse the payment;
• b) Suspend/close your Spush Payment Account;
• c) Report the transaction to relevant authorities;
• d) Claim damages from you;
• e) Charge an administration fee (see Fee Schedule).

11.6 Customer Responsibility
You bear full responsibility for ensuring your transactions comply with law. Holding a Spush Payment Account does not validate the legality of your underlying transactions.

11.7 Policy Updates
We may update our list of prohibited transactions or categories at any time, either in these Terms or via a published acceptable use policy.

12.1 Reporting & Refund Window
To claim a refund for an unauthorised or incorrectly executed Payment Transaction, you must notify us without undue delay and no later than 13 (thirteen) months after the debit date.

12.2 Immediate Refund
If a Payment Transaction was not authorised using your login credentials, password, PIN, etc., we will promptly:

• (a) refund the unauthorised transaction amount, and
• (b) restore your Spush Payment Account to the state it would have been in had the transaction not occurred, unless we suspect fraud on your part.

12.3 Timing of Refund
We provide this refund as soon as practicable, typically by the end of the Business Day following when we become aware of the unauthorised transaction, unless we have reasonable grounds to suspect fraudulent behavior, which we will notify you of in writing.

12.4 Liability for Lost or Stolen Credentials
You are liable for losses arising from the use of lost or stolen credentials, or misappropriation of your Spush Payment Account/Credentials, unless the loss results from acts/omissions by Noveba or its agents.

12.5 Compensation
You must compensate us for damages or losses we incur from an unauthorised transaction arising from your lost or stolen credentials or misappropriated Spush Payment Account details.

12.6 Exceptions
Clauses 12.4 and 12.5 do not apply if the loss was caused by Noveba’s (or its employees/agents’) negligence.

12.7 Incorrect Payee Details
If you provide an incorrect Unique Identifier or other payment details, Noveba is not liable for non-execution or defective execution. We will, however, make reasonable efforts to recover the funds if they went to another Noveba Customer. A fee of 5% of the transaction amount (minimum 100 EUR) may apply for recovery attempts.

13.1 Fees Overview
Provision of the Spush Payment Account and related services (including Spush) is subject to fees (“Fees”) described in our Fee Schedule (e.g., [URL or link]). Fees may vary based on whether your Spush Payment Account is personal or business.

13.2 Account Opening Fee
We may charge a one-time Spush Payment Account opening fee, debited after your first deposit of funds. Details are in our Fee Schedule.

13.3 Transaction Fees
Each Payment Transaction may incur fees disclosed in our Fee Schedule. By initiating a transaction, you agree to pay these fees.

13.4 Immediate Deduction
You authorise us to deduct Fees from your Spush Payment Account balance at the time of execution. If your balance is insufficient, we may refuse the transaction. Reversal or chargeback fees will be deducted when incurred.

13.5 Negative Balance
If deducting Fees leads to a negative balance, you must immediately top up your Spush Payment Account to cover it. Failure to do so is a breach of these Terms. We may take legal or collection actions.

13.6 Monthly Maintenance Fee
We may charge a monthly maintenance fee at the end of each month, as outlined in our Fee Schedule.

13.7 Fee Changes
We may change fees at our sole discretion with 60 days’ notice, usually by posting on our website or emailing you. You are advised to regularly check for updates.

14.1 Unauthorised or Incorrect Transactions
If we improperly execute a Payment Transaction or it was unauthorised, we will refund you promptly under Section 12, except where you failed to keep your Credentials safe or failed to report timely (within 13 months).

14.2 No Liability for Certain Errors
We are not liable for losses resulting from:

• a) Errors in the payee’s details provided by you;
• b) Goods/services purchased with your account (including partial or non-performance by the merchant);
• c) A payee’s refusal to accept payment;
• d) System errors, network failures, or interruptions beyond our control;
• e) Delays or errors by intermediary service providers or internet disruptions;
• f) Malicious code (e.g., viruses, hackers) outside our reasonable control.

14.3 Unauthorised Use
We are not liable for any unauthorised use of your Spush Payment Account. You indemnify us against all losses from such use until you notify us of the compromise.

14.4 Third-Party Software or Services
If any third-party software or services are used to enforce these Terms, you agree to indemnify and hold them harmless from any claims due to your misuse.

14.5 No Liability for Third-Party Charges
We are not liable for charges or deductions by third parties (e.g., external banks).

14.6 Delays at External Providers
We are not liable for Payment Transaction delays caused by external Payment Service Providers or other third parties.

14.7 Force Majeure
We are not liable for failing to perform obligations due to events beyond our reasonable control (e.g., natural disasters, terrorism, government action).

14.8 No Indirect or Consequential Damages
We are not liable for indirect or consequential losses, such as lost profit or business.
14.9 Taxes
We are not liable for assessing or paying any taxes arising from transactions between you and third parties.

14.10 Indemnification
You agree to defend, reimburse, and hold us harmless from any claim, demand, or cost arising from your breach of these Terms or applicable law.

14.11 Aggregate Liability Cap
Except where prohibited by law, our total liability to you for Spush Payment Account services is capped at the total Fees you’ve paid us in the preceding 6 (six) months.

15.1 Customer Status
You represent and warrant that you:

• a) are of sound mind, legal age (18 years old), and legally competent;
• b) are the sole party with an interest in your Spush Payment Account;
• c) are suitable to enter these Terms;
• d) provided true, accurate, and complete information in the account setup process;
• e) are not receiving funds in connection with illegal, fraudulent, or manipulative acts.

15.2 Consent to Disclosure
You expressly consent that communications related to any disputes or legal proceedings (including public statements, court decisions) may be disclosed by us at our discretion if we deem it necessary for legal or regulatory reasons.

16.1 Electronic Statements
You will receive electronic statements for your Spush Payment Account, accessible via our online (Spush) platform. It is your responsibility to regularly review these statements for accuracy and promptly notify us of any discrepancies.

16.2 Transaction Confirmations
•We may provide transaction confirmations via email, SMS, or in-app notifications. Keep your contact details updated to ensure you receive such communications.

17.1 Contact Details
You must maintain valid contact information (email, phone, address) in your Spush Payment Account profile. We will use these details to send important notices about your account.

17.2 Methods of Communication
We may communicate with you via email, phone, SMS, in-app messages, or postal mail. Official communications are typically in English unless otherwise agreed.

17.3 Deemed Receipt
Communications are deemed received on the same Business Day if sent before our cut-off time, or the next Business Day if sent afterward, unless you prove otherwise.

18.1 Governing Law
These Terms and any disputes arising out of or in connection with them are governed by and construed in accordance with the laws of England and Wales.

18.2 Jurisdiction
The courts of England and Wales have exclusive jurisdiction over any disputes, unless otherwise required by consumer protection laws.

19.1 Enforceability
These Terms are binding on you and Spoynt Limited, as well as our respective successors and permitted assigns.

19.2 Entire Agreement
These Terms, the Fee Schedule, Privacy Policy, and Noveba’s Terms & Conditions supersede any prior agreements regarding your Spush Payment Account or Spush services.

20.1 Closure by You
You may close your Spush Payment Account at any time by withdrawing all e-money and providing written notice, subject to the payment of outstanding fees.

20.2 Closure by Us
We may suspend or terminate your Spush Payment Account if you breach these Terms, fail AML checks, engage in Prohibited Transactions, or if required by law or regulation.
We may also terminate with two months’ notice for operational reasons.

20.3 Effect of Closure
Pending transactions may be cancelled if still revocable.
Any remaining e-money will be redeemed at par value (less applicable fees) into your verified bank account.

21.1 General Indemnity
In addition to Section 14.10, you agree to indemnify and hold Spoynt Limited harmless from any third-party claims, damages, or expenses (including legal fees) arising from your breach of these Terms, negligence, or misuse of Services.

22.1 Internal Complaints Procedure
If you have a complaint, contact our Customer Support at [support@spush.co.uk]. We aim to acknowledge within [5] Business Days and resolve within [15–35] Business Days depending on complexity.

22.2 Financial Ombudsman Service
If you remain dissatisfied or if your complaint is not resolved within eight (8) weeks, you may be able to refer it to the Financial Ombudsman Service, Exchange Tower, London E14 9SR; Phone: 0800 023 4567; www.financial-ombudsman.org.uk.

23.1 Refunds on Transactions
If refunds are warranted by law (e.g., proven unauthorised transactions) or by our discretion, we process them according to applicable regulations and our internal policies.

23.2 Currency and Fees
Refunds may be subject to currency exchange and relevant fees, disclosed either in the Fee Schedule or at the time of the transaction.

24.1 Interpretation
Section headings are for convenience only and do not affect the meaning of these Terms.

24.2 Severability
If any part of these Terms is deemed invalid or unenforceable by a competent authority, the remaining sections stay in full force and effect.

25.1 Call Recording
We may record telephone or electronic communications for quality assurance, security, and regulatory compliance.

25.2 Consent
By contacting us via these methods, you consent to such recordings, which are handled in accordance with our Privacy Policy and any applicable laws.

26.1 Right to Amend
We may amend or update these Terms to reflect changes in the law, market conditions, or business practices.

26.2 Notice
We will provide at least two months’ notice (if required by law) before any material changes take effect, usually via email or Account notification. Continued use of the Services after the effective date constitutes acceptance of the changes.

27.1 Privacy Policy
All personal data is processed in accordance with our Privacy Policy (https://spush.co.uk/privacy-policy) and the Data Protection Laws. By using our Services, you consent to this processing.

27.2 Third-Party Sharing
We may share data with third-party processors (e.g., ID verification providers) or authorities as required by law or for legitimate business interests (e.g., fraud prevention).

28.1 Regulatory Compliance
We comply with AML/CTF regulations. You must provide all information or documents we request to satisfy these obligations.

28.2 Monitoring and Reporting
Transactions are monitored for suspicious activity. We will report suspicious transactions to relevant authorities when required by law, without notice to you.

28.3 Refusal or Closure
Failure to provide AML documents or suspicion of unlawful activity may lead to refusal of transactions, freezing of funds, or Spush Payment Account closure.

29.1 Ownership
All trademarks, service marks, and trade names used by Spoynt Limited (including “Spoynt” and “Spush”) are the property of Spoynt Limited or its licensors, protected under applicable laws.

29.2 License to Use
We grant you a non-exclusive, revocable license to refer to our trademarks solely for lawful use of our Services. You must not misuse or alter these marks.

30.1 By Spoynt Limited
We may assign or transfer our rights and obligations under these Terms in connection with a merger, acquisition, or restructuring, provided such transfer does not reduce your statutory rights.

30.2 By You
You may not assign or transfer your rights or obligations under these Terms without our prior written consent.

31.1 Your Responsibility
You are responsible for any taxes that arise from your use of the Services or transactions conducted via your Spush Payment Account.

31.2 Withholding
We may be required to withhold or report taxes to authorities. You agree to provide any information or documentation necessary for compliance.

32.1 Obligation
Both parties shall treat each other’s Confidential Information with the same degree of care as they treat their own, but not less than reasonable care.

32.2 Exceptions
Confidential Information does not include information that:

1. Is or becomes publicly available without breach of these Terms;
2. Is lawfully obtained from a third party not under confidentiality obligations;
3. Must be disclosed by law or regulatory authority.

33.1 Compliance
We handle personal data in compliance with the UK GDPR, the Data Protection Act 2018, and related laws.

33.2 Data Subject Rights
You may exercise your rights to access, rectify, or erase personal data, as well as object or restrict processing, subject to legal and contractual limitations. For more details, refer to our Privacy Policy.

34.1 No Waiver
Failure by Spoynt Limited to exercise or enforce any right or provision shall not constitute a waiver of such right or provision.

34.2 Survival
Provisions that by nature should survive termination (e.g., confidentiality, liability, indemnities) shall remain in effect.

34.3 Force Majeure
We are not liable for delays or failures due to events beyond our reasonable control (e.g., natural disasters, cyberattacks, government actions).

34.4 Contact Us
Spoynt Limited (Operating Spush)
FCA Reference Number: 903071
Registered Office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: support@spush.co.uk
Website: spush.co.uk

By opening or using a Spush Payment Account with Spoynt Limited (EMD Agent of Noveba Limited) or accessing the Spush digital/web wallet, you acknowledge that you have read, understood, and agree to be bound by these Terms & Conditions, as well as Noveba’s Terms & Conditions.