Terms &
Conditions.

00Version History

01About Kintro and these Terms

1.1These Terms and Conditions ("Terms") are a contract between you and Kintro Ltd ("Kintro", "we", "us"), a company registered in England and Wales. They govern your use of the Kintro mobile and web applications, our website at kintro.money, and any related services (together, the "Service").

1.2By creating a Kintro account, ticking the box to accept these Terms during onboarding, or by using the Service, you confirm that you have read these Terms and agree to be bound by them.

1.3These Terms are written in English and we communicate with you in English. The Privacy Policy (KIN-DPA-002) explains how we use personal data and is incorporated into these Terms by reference.

1.4If any provision of these Terms is found to be invalid or unenforceable, the rest of the Terms remain in force.

02The Regulated Firms Behind the Service

2.1During the alpha phase of the Service, the regulated payment services and e-money issuance you use through Kintro are provided by an FCA-authorised payment institution / electronic money institution (the "Principal"). Kintro acts as the Principal's agent, registered on the FCA Financial Services Register. We tell you the Principal's name, FCA reference number and contact details inside the Kintro app on the "About" screen and at kintro.money/legal/principal.

2.2Where these Terms describe a regulated activity — issuing e-money, executing payments, providing account information or payment initiation services — that activity is performed by the Principal, with Kintro acting as the operational and customer-facing agent.

2.3Kintro's medium-term aim is to obtain direct FCA authorisation as an Account Information Service Provider and an authorised Payment Initiation Service Provider. We will tell you well in advance of any change to who provides the regulated parts of the Service, and you will be free to close your account if you do not agree to the change.

03Definitions

Account

Your Kintro account, including your e-money wallet, any Group Wallets you participate in, and any Open Banking connections.

AISP Service

The Account Information Service operated under the Principal's permissions under Part 6 of the Payment Services Regulations 2017.

Business User

A sole trader, partnership, limited company, charity or other organisation using the Service for purposes related to its trade, business, craft or profession.

Consumer

An individual using the Service for purposes wholly or mainly outside of any trade, business, craft or profession.

E-Money

Electronic money issued by the Principal in exchange for funds you transfer to be loaded onto your Account.

EMRs 2011

The Electronic Money Regulations 2011.

FCA

The UK Financial Conduct Authority.

FSCS

The Financial Services Compensation Scheme.

Group Wallet

A shared e-money wallet operated through Kintro's multi-signature consensus engine, allowing two or more members to hold and transact funds together under approval rules they choose.

PISP Service

The Payment Initiation Service operated under the Principal's permissions under Part 6 of the Payment Services Regulations 2017.

PSR 2017

The Payment Services Regulations 2017.

SCA

Strong Customer Authentication, as required by Regulation 100 of PSR 2017.

You

The individual or organisation that holds an Account.

04Who Can Use the Service

4.1To open a consumer Account, you must:

• Be aged 18 or over.
• Be resident in the United Kingdom.
• Be using the Service in your own name and for your own benefit.
• Have legal capacity to enter into a contract.

4.2To open a business Account, the organisation must be incorporated, registered or otherwise established under the law of the United Kingdom and be using the Service in the course of its trade or business. The individual opening the Account must be duly authorised to act for the organisation and must complete identity and authority verification on its behalf.

4.3We cannot open an Account for you if you are subject to UK or other applicable sanctions, are listed on a sanctions list we are required to screen, or if our financial-crime checks indicate that doing so would breach applicable law.

4.4You may only hold one consumer Account, unless we expressly agree otherwise.

05Opening Your Account

5.1To open an Account, you must provide the information we ask for during onboarding, including your name, date of birth, address, contact details and a government-issued identity document. For business users, we will additionally require company information, beneficial ownership and authorised signatories.

5.2We are required by the Money Laundering Regulations 2017 to verify your identity before we open your Account, and to perform ongoing customer due diligence. We may ask you for further information at any time during our relationship. If you do not provide it, we may refuse to open or have to close your Account.

5.3We will tell you when your Account is open and ready to use. Until then, you cannot load funds or make payments.

06The E-Money Wallet

6.1Your wallet allows you to hold e-money issued by the Principal in exchange for funds you load. The balance shown in the Kintro app represents that e-money.

6.2We do not pay interest on e-money balances. E-money is not a deposit and is not protected by FSCS — see Section 23 for what protections do apply.

6.3You can request redemption of e-money in full or in part at any time, free of charge while your Account is open. Redemption is paid out to the linked bank account you have verified.

07Loading Funds (Top-Ups)

7.1You can load funds into your wallet by:

• Bank transfer from a UK bank account in your name.
• Open Banking payment from a linked external account using our PISP service.
• Any other method we tell you about inside the app.

7.2Funds are credited to your wallet as soon as they are received and confirmed by the Principal.

7.3We may refuse a top-up if it does not match the registered account holder, if it appears unusual, or if completing it would breach applicable law. Where we refuse, we will tell you the reason unless we are legally prevented from doing so.

08Making Payments

8.1Once your Account is funded you can make payments from your wallet to other Kintro users, to UK bank accounts via Faster Payments, or by other rails we tell you about inside the app. You can also use our PISP service to initiate a payment directly from your linked external bank account.

8.2You authorise a payment by entering payment details and completing SCA when prompted. Your consent for a payment is given when you confirm with SCA. You can withdraw consent at any time before the payment is executed; for Faster Payments, this is typically only possible before you tap Confirm.

8.3We will execute payments in the timescales set out by the relevant payment scheme — for UK Faster Payments, the funds will reach the payee's bank by the end of the next business day, and typically within seconds for live participants.

8.4We may refuse to execute a payment in the limited circumstances set out in Regulation 82 of PSR 2017 — for example if we reasonably suspect fraud, if executing the payment would breach law, or if you have insufficient funds. Where we refuse, we will notify you in the app, give you the reason where we can, and tell you how to put any factual error right.

09Account Information (AISP)

9.1You can connect external bank accounts to Kintro using our AISP service so we can show you balances and transactions in one place and inform the savings-goal features described in Section 11.

9.2Each connection requires your explicit consent at your bank's authentication page. Consent lasts up to 90 days under PSR 2017 reg. 36, after which you will be asked to renew it. You can revoke consent at any time inside Kintro or with your bank.

9.3We rely on your bank's API to deliver data on time. If the bank is slow or unavailable, the information shown in Kintro may be delayed.

10Payment Initiation (PISP)

10.1The PISP service lets you instruct a payment from your external bank account directly through Kintro, without giving us your bank login credentials.

10.2You initiate the payment at Kintro, then approve it inside your bank. The legal payment is made by your bank from your account; Kintro and the Principal are the regulated parties that initiated it on your behalf.

10.3If something goes wrong with the payment after it leaves your bank, your bank remains your first point of contact under PSR 2017. We will help you investigate and recover the funds wherever we can.

11Group Wallets, Multi-Sig and Savings Goals

11.1A Group Wallet is a shared wallet where two or more members hold and transact e-money together. Each Group Wallet has its own approval rules — for example, two-of-three signatures required for any withdrawal — configured when you set it up.

11.2Approvals are recorded by Kintro's multi-signature consensus engine and cryptographically signed (HMAC-SHA256) into an integrity-protected ledger. The owner who sets up the Group Wallet must accept these Terms on behalf of the Wallet; every additional member must individually accept these Terms before they can transact.

11.3Savings goals are non-binding targets you set inside your wallet or a Group Wallet. They do not segregate funds into a separate legal pot; they are an organisational and visualisation feature on top of your e-money balance.

11.4If a Group Wallet member loses access to their device, the remaining members can continue to operate the Wallet under the approval rules. We will help re-onboard a member onto a new device subject to identity verification.

12Fees and Charges

12.1The Service is free to use at this time, except where we explicitly tell you otherwise inside the app. A current Fees Schedule is set out in Appendix A and at kintro.money/legal/fees.

12.2Third parties (such as your bank, currency-conversion provider or card scheme) may charge their own fees for processing payments. Those fees are not set by Kintro.

12.3We will give you at least two months' notice before introducing any new fee or increasing an existing fee that materially affects you, in line with Regulation 50 of PSR 2017. If you do not agree to the change, you may close your Account, free of charge, before it takes effect.

13Security and Unauthorised Transactions

13.1You must keep your Kintro app credentials, your device and any one-time codes secret. You must enrol Strong Customer Authentication on your device when prompted and keep it active.

13.2If you think your Account or device has been lost, stolen, misused or compromised, you must tell us as soon as possible using the in-app "Help → Report a Problem" flow, by emailing security@kintro.money, or by calling the number printed in the app.

13.3Where you tell us about an unauthorised payment, we will refund it without undue delay and by no later than the end of the next business day, in line with Regulation 76 of PSR 2017, unless we have reasonable grounds to suspect fraud and notify the FCA accordingly. The refund restores your Account to the state it would have been in if the unauthorised payment had not taken place.

13.4You may be liable up to £35 for losses arising from an unauthorised payment that resulted from the use of a lost or stolen credential before you notified us, except in the circumstances set out in Regulation 77 of PSR 2017 (for example where the loss was due to our failure to provide adequate means of notification, or where SCA was not applied).

13.5You will be liable for all losses arising from an unauthorised payment where you have acted fraudulently, or where you have intentionally or with gross negligence failed to keep your Account safe.

13.6Where you complete SCA but later allege you did not authorise the payment, the use of SCA is not in itself sufficient to prove you authorised the payment, in line with Regulation 75 of PSR 2017.

14Disputes and Refunds

14.1If a payment was authorised by you but the amount was not specified at the time of authorisation, exceeded what you could reasonably have expected, and was within eight weeks of the debit, you may be entitled to a refund under Regulation 79 of PSR 2017. We will respond within 10 business days of receiving your refund request.

14.2If you receive a payment in error, we may reverse the credit and return it to the payer in line with Regulation 90 of PSR 2017. We will tell you when this happens.

14.3Chargebacks are not available for e-money wallet payments. If you have a dispute with a merchant, you should raise it with the merchant directly. We will help you to the extent we can.

15Fair Treatment and the Consumer Duty

15.1The Service is designed with the FCA Consumer Duty (PRIN 2A) in mind. Through the Principal, we aim to deliver good outcomes for retail customers across the four outcomes of products and services, price and value, consumer understanding and consumer support.

15.2If you are or become a customer in vulnerable circumstances — for example because of bereavement, ill health, financial difficulty or a recent shock — please tell us. We will adapt how we communicate and what support we offer.

16Your Responsibilities and Acceptable Use

16.1You must use the Service honestly, lawfully and only for the purposes set out in these Terms.

16.2You must not, and must not allow any third party to:

• Use the Service to commit fraud or financial crime, including money laundering, terrorist financing, sanctions evasion or tax evasion.
• Use the Service to handle the proceeds of a crime.
• Reverse engineer, decompile, scrape or interfere with the security or integrity of the Service.
• Use the Service to send abusive, threatening or unlawful messages to other users.
• Allow anyone else to use your credentials or access your Account, unless you are a business user permitting an authorised employee or representative.
• Use the Service in a way that breaches sanctions, anti-bribery or any other applicable law.

17Suspension and Closure

17.1You can close your Account at any time by following the in-app flow under Settings → Close Account, or by emailing support@kintro.money. We will redeem your e-money balance to your linked verified bank account once outstanding transactions have settled.

17.2We can suspend your Account (in whole or in part), block specific transactions, or close your Account where:

• We reasonably believe your Account is being used for fraud or financial crime.
• Continuing the relationship would put us, the Principal, or another customer at material risk.
• You have materially breached these Terms and have not put the breach right within a reasonable period after we have told you about it.
• We are legally required to do so — including under sanctions, tax-information-exchange or court order.
• You no longer meet the eligibility criteria in Section 4.

17.3We will close your Account for any other reason on at least two months' written notice. We will not close it on short notice except where we have a legal or regulatory reason to do so.

17.4After closure, your obligations under these Terms in respect of past transactions, indemnities, and confidentiality continue.

18Our Liability to You

18.1We do not exclude or limit our liability to consumers for: death or personal injury caused by negligence; fraud or fraudulent misrepresentation; any breach of your statutory rights under the Consumer Rights Act 2015; or any other liability that we are not permitted to exclude or limit by law.

18.2Subject to Section 18.1, our total liability to a consumer in connection with these Terms is limited to the amount of any direct loss reasonably foreseeable when the relevant payment instruction was given, or £5,000, whichever is greater.

18.3Subject to Section 18.1, our total liability to a business user in any 12-month period is limited to the greater of (a) the total fees, if any, you have paid Kintro in that period and (b) £5,000. We exclude liability to business users for any indirect, consequential, special or punitive loss, or for loss of profits, revenue, goodwill or anticipated savings.

18.4We are not liable to anyone for any failure or delay to the extent it is caused by an event outside our reasonable control, including failures of the public payments infrastructure, regulatory action, or major incidents affecting our cloud provider or the Principal.

19Events Outside Our Control

19.1Where an event outside our reasonable control prevents or delays us from meeting our obligations under these Terms, we will tell you as soon as practical, take reasonable steps to mitigate the effects, and resume normal service as soon as we can. Our incident-response and business-continuity arrangements are set out in KIN-SEC-002 and KIN-BCP-001.

20Changes to These Terms

20.1We may change these Terms from time to time, including to reflect changes in law, regulation, the way the Service works, or the identity of the Principal. We will give you at least two months' written notice of changes that affect payment-services elements regulated under PSR 2017.

20.2For other changes that are materially adverse to you, we will also give you at least two months' notice. For changes that are favourable to you, neutral, or required by law on a shorter timescale, we will give you as much notice as we can.

20.3If you do not agree with a notified change, you may close your Account free of charge before the change takes effect. If you keep using the Service after the change takes effect, you are taken to have accepted it.

21Communications

21.1Most communications between you and us will happen inside the Kintro app or by email to the address you registered. We may also send SMS for security alerts and one-time codes.

21.2You agree to receive contractual documents (including these Terms, the Privacy Policy, the Fees Schedule and any notices) in electronic form. You can ask us for a copy in another reasonable format at any time.

21.3You must keep your contact details up to date inside the app. We are not liable for missed communications caused by out-of-date contact details that we did not know about.

22Assignment and Third Parties

22.1You may not transfer your Account or any of your rights or obligations under these Terms to anyone else without our written consent.

22.2We may transfer our rights and obligations under these Terms to another business — for example as part of a corporate restructure or sale — provided that the transfer does not materially reduce the protections you have under these Terms. We will tell you in advance.

22.3A person who is not a party to these Terms has no rights under the Contracts (Rights of Third Parties) Act 1999, except that the Principal may enforce any provision of these Terms that benefits or affects it.

23Safeguarding and FSCS

23.1The Principal is required by Regulation 20 of the EMRs 2011 and Part 7 of PSR 2017 to safeguard customer funds. Safeguarding usually involves segregating funds in a designated client account with a UK credit institution or holding them in qualifying liquid assets covered by an insurance policy or comparable guarantee.

23.2Safeguarding is different from FSCS protection. E-money issued by an electronic money institution is not covered by FSCS. If the Principal becomes insolvent, the safeguarded funds form a pool that is paid out to customers in priority to other creditors, but you may receive less than the full balance and there can be a delay.

23.3You can find further information about safeguarding in the FCA's webpage "How to keep your money safe — the FCA's safeguarding requirements for payment and e-money firms" and on the Principal's website.

24Additional Terms for Business Users

24.1The following terms apply in addition to the rest of these Terms where you use the Service as a business user. Where there is an inconsistency between this Section 24 and any other section, this Section 24 prevails for business users.

24.2Some PSR 2017 provisions can be disapplied in respect of payment services provided to a business that is not a micro-enterprise or charity (Regulation 63). For those business users, the following are disapplied to the extent permitted by law: Regulations 66(1), 67(3) and (4), 75, 77, 79, 80, 83, 91, 92 and 94. Where you are a micro-enterprise or charity, the full PSR 2017 protections continue to apply.

24.3You confirm that any person you authorise to act on the Account has the necessary authority to bind the business. You are responsible for the actions of your authorised users.

24.4You agree to provide such financial-crime information as we reasonably request to keep your file up to date, including any change of beneficial ownership, change of registered office or change of regulated status.

24.5Where the Service is used in connection with the business's regulated activity, you remain responsible for compliance with any rules that apply to you in your own right. Nothing in these Terms relieves you of that responsibility.

25Governing Law and Jurisdiction

25.1These Terms, and any non-contractual obligations arising out of or in connection with them, are governed by the law of England and Wales.

25.2You and we agree that the courts of England and Wales have exclusive jurisdiction to settle any dispute arising out of or in connection with these Terms, except that if you are a consumer resident in Scotland or Northern Ireland you may also bring proceedings in your home jurisdiction.

26How to Complain

26.1If something has gone wrong, please tell us first so we can try to put it right. You can complain inside the app via Help → Make a Complaint, by emailing complaints@kintro.money, or in writing to the address on the Kintro website.

26.2We will acknowledge your complaint promptly and issue a final response within eight weeks, in line with the FCA's DISP rules. We will tell you what we have decided and explain why.

26.3If you are not satisfied with our final response, or if eight weeks have passed without one, you may refer your complaint to the Financial Ombudsman Service:

• Online: financial-ombudsman.org.uk
• Telephone: 0800 023 4567
• Post: Financial Ombudsman Service, Exchange Tower, London E14 9SR

26.4If your complaint is about how we use your personal data, you can complain to the Information Commissioner's Office (ico.org.uk). See the Privacy Policy (KIN-DPA-002) for details.

AAppendix — Fees Schedule (Alpha)

BAppendix — Limits

CAppendix — Regulatory Anchors

DAppendix — Document Control