Privacy Control

1. General Disclaimer

This platform does not offer financial services, issue payment instruments, nor hold or process customer funds. It is a user interface that facilitates access to third-party card programs. These services are operated and issued entirely by regulated financial institutions outside the European Economic Area. By using the platform, users acknowledge that they are entering into a contractual relationship directly with the card issuer or service provider, not with the platform operator.

2. Description of Service

This platform is a technology interface that enables users to access card services provided by authorized third-party financial providers located in jurisdictions such as Hong Kong. The platform does not issue cards, manage funds, or operate as a financial institution. Cards are issued and operated by regulated partners under their own licenses.

3. Role of the Operator

The platform is operated by a technology company registered in Dubai, UAE. The operator provides only the platform interface and does not have access to user funds, card infrastructure, or transactional flows. All financial services are provided by third-party issuing partners.

The platform is not a card issuer, financial institution, or electronic money institution. The cards accessible through this interface are issued by third-party providers operating under their own licensing and regulatory frameworks. The operator provides no guarantee, control, or liability regarding the compliance of such providers with local regulations in the user's country of residence. Users are solely responsible for ensuring their own legal and fiscal compliance in their jurisdiction.

4. Registration and Verification (Soft KYC)

In compliance with international regulatory obligations, all users must complete a Soft KYC process in order to activate and use the card services accessible through the platform. This verification is performed through an external third-party provider and is designed to meet minimum compliance standards while preserving user privacy.

The operator does not access, store, or directly control any personal identity data collected during the verification process. The identity of users remains unknown to the operator unless there is a legally binding requirement to obtain and disclose it in connection with a specific official request or investigation involving an individual user or a selected group of users.

As long as users engage with the platform lawfully and responsibly, no personal information will be proactively or voluntarily disclosed to any public or governmental institution.

This privacy-by-design approach enables the platform to offer one of the most privacy-conscious card experiences available while remaining compliant with the applicable legal frameworks of its financial partners.

5. Use of the Card

Cards accessed via this platform are governed by the terms and conditions of the issuing partner. Usage limits, acceptance, and settlement are controlled solely by the issuer. The platform does not impose or manage any card limits or functionality.

6. Regulation and Jurisdiction

6.1 The service offered through this platform is operated by external third-party providers duly authorized in their respective jurisdictions, currently in Hong Kong. The platform does not act as a financial entity nor does it issue cards directly, and it holds no contractual relationship with the user regarding the custody or management of funds.

6.2 The platform does not actively promote or offer its services in jurisdictions where financial services may be restricted, licensed, or regulated, including but not limited to countries under international sanctions, or jurisdictions requiring prior regulatory authorization for the offering of financial instruments.

6.2 bis The operator and its providers reserve the right to restrict or suspend access to the platform, in whole or in part, for users who reside in, access from, or attempt to operate from jurisdictions included in international sanctions lists, such as those issued by the U.S. Office of Foreign Assets Control (OFAC), the European Union, the United Nations, or other relevant authorities. This restriction applies even if the individual user is not personally sanctioned, in order to comply with internal risk policies and the compliance obligations of the issuing partners.

6.3 Any use of this platform by citizens or residents of the European Union, the United States of America, or other regulated jurisdictions is the sole responsibility of the user. The user acknowledges their duty to comply with applicable local laws, especially those related to taxation and capital controls.

6.4 These Terms and Conditions shall be governed by and construed in accordance with the laws of the jurisdiction in which the financial service providers operate (currently Hong Kong), expressly excluding the application of any other law or forum.

7. Deposits, Holds and Refunds

7.1 Top-ups and Issuer Responsibility
When a user tops up a card through the platform, the deposit is made directly to the third-party card issuer, a regulated financial entity independent from the operator. The platform acts solely as a technology interface and does not manage, receive, or hold any funds. The legal relationship regarding the custody, availability, and conditions of the topped-up balance exists exclusively between the user and the issuer, according to the issuer's internal policies and terms.

7.2 Processing of Refunds
Refunds related to card transactions (such as purchase cancellations or merchant reimbursements) are handled entirely by the merchant and the issuer. The user acknowledges and agrees that the refunded amount may take between 7 and 45 business days to be credited back to their card balance from the moment the merchant initiates the refund. The platform has no control over this timeframe and cannot expedite it.

7.3 Offline Purchases and Temporary Holds
Certain types of merchants, particularly those operating offline or prepaid systems (such as gas stations, parking lots, hotels, toll booths, or terminals with delayed settlement), may initiate a 100% hold of the estimated amount of the transaction. These temporary holds may remain in place for 7 to 45 days, even if the final amount charged is lower.

Users are strongly advised not to use the card in such environments due to the risk of prolonged balance holds, which cannot be contested or released earlier.

7.4 Compliance and Audit Holds
The user understands and agrees that upon depositing funds to the card, the issuer may place a temporary hold or freeze on the balance for reasons including but not limited to audits, fraud prevention, BIN verification, or internal compliance reviews.

Such holds may be:

• Randomized or risk-based;
• Applied to specific users or card groups;
• Triggered by issuer-side operational requirements.

During such audits or internal reviews, funds may remain frozen for up to 90 calendar days without the possibility of withdrawal, reversal, or dispute. The platform has no influence or access to these processes and bears no responsibility for delays or inconveniences resulting from them. The user expressly waives any claim against the platform for such events.

8. Termination

The operator reserves the right to suspend or deactivate user access in case of suspected abuse, breach of platform use, or compliance risk. No justification is required for suspension.

9. Amendments

These Terms may be updated from time to time. Continued use of the platform implies acceptance of any changes.