Account Terms

1.1 These Terms of Service, together with the Privacy Policy, Cookie Policy, Complaints Policy, Fee Schedule, Crypto Terms, and any other policies or notices published on the Website, form a binding agreement between you and Pure Payments Inc. (the “Terms”).

1.2 By registering for, accessing, or using the Services through the Pure App, you agree to these Terms.

1.3 If you do not agree to these Terms, you must not use the Services.

1.4 We may amend these Terms from time to time. We will notify you of proposed changes before they take effect. If you continue to use the Services after the changes take effect, you accept the amended Terms. If you do not accept the changes, you must stop using the Services and may request closure of your business relationship in accordance with these Terms.

“Business Day” means a day other than Saturday, Sunday, or a public holiday in Ontario, Canada.

“Customer”, “you”, or “your” means an individual or legal entity that has entered into a business relationship with Pure Payments.

“Fiat Funds” means funds denominated in EUR, USD, or another fiat currency supported by Pure Payments.

“Pure App” means the Pure Payments mobile application used to access the Services.

“SEPA” means the Single Euro Payments Area.

“Services” means services described in Section 3.

“SWIFT” means the international financial messaging network used for cross-border payments.

“Third-Party Payment Provider” means a licensed payment or electronic-money institution, bank, payment processor, or other financial-services provider engaged by Pure Payments to hold, safeguard, transmit, or process Fiat Funds.

“Third-Party Service Provider” means a service provider engaged by Pure Payments to support identity verification, screening, compliance, technology, payment processing, funds holding, or other Services.

“Virtual IBAN” or “vIBAN” means an IBAN formatted payment identifier assigned to a Customer for the purpose of receiving and reconciling inbound fiat payments. A vIBAN is linked to an underlying account maintained by a Third-Party Payment Provider. A vIBAN is not a bank account, deposit account, payment account, or electronic-money account held by Pure Payments and does not itself represent a separate claim against a bank.

“Website” means https://purewallet.global/.

“We”, “us”, or “our” means Pure Payments Inc., 30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario, L4B1B9, Canada, incorporation number 1001061641.

3.1 Pure Payments provides the following Services, subject to availability, eligibility checks, and these Terms:

• Receipt of fiat deposits by SEPA/SWIFT transfers in EUR or USD;
• Fiat withdrawals by SEPA/SWIFT transfers in EUR or USD;
• Provision of virtual IBANs;

3.2 Pure Payments does not provide bank accounts, deposit accounts, credit, loans, investment advice, tax advice, legal advice under these Terms.

3.3 Cryptoasset services, including USDC deposits and withdrawals, fiat to USDC conversion, USDC to fiat conversion, and staking, are governed by the separate Crypto Terms, where applicable.

3.4 We may add, modify, suspend, discontinue, or restrict any Service at any time, including where required by law, regulation, a third-party provider, a third-party service provider or our risk-management requirements.

4.1 Pure Payments Inc. is registered with the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) as a money services business under incorporation No. 1001061641.

4.2 We use third-party providers to deliver parts of the Services. Pure Payments does not guarantee the availability, solvency, performance, or regulatory status of any third-party provider.

5.1 You may use the Services only if you are at least 18 years old and have full legal capacity to enter into a binding agreement.

5.2 The Services are available to individuals and legal entities, subject to successful completion of onboarding, identity verification, screening, and risk assessment.

5.3 The Services are not available to customers located in:

• The United States;
• North Korea;
• Russia;
• Iran;
• Any other jurisdiction that we reasonably determine cannot be served for legal, regulatory, sanctions, or risk-management reasons.

5.4 We may refuse, restrict, suspend, or terminate access to the Services if you do not meet our eligibility requirements or if we reasonably determine that providing Services to you would create legal, regulatory, reputational, financial, fraud, sanctions, or AML/CTF risk.

6.1 You may access the Services only through the Pure App using the credentials and security methods we provide or approve.

6.2 You may hold only one Customer profile. You may not create duplicate profiles or use another person’s profile.

6.3 Legal entities may be represented by a duly authorized representative. We may require evidence of your authority to act for the legal entity.

6.4 We may request updated identification information, such as: corporate, beneficial ownership, contact, source of funds, source of wealth, or transaction information at any time.

6.5 You must keep your login credentials, passwords, one-time codes, devices, and other security features confidential. You must notify us immediately if you believe they have been lost, stolen, compromised, or used without authorization.

6.6 We may suspend or block access to the Pure App where we reasonably suspect unauthorized access, fraud, security risk, sanctions concerns, or a breach of these Terms.

7.1 You must:

• Provide accurate, complete, and current information;
• Promptly update changes to your identity, contact details, ownership, control, business activity, or risk profile;
• Provide identity, beneficial ownership, source of funds, source of wealth, transaction, or other information we reasonably request;
• Use only bank accounts and payment details that belong to you;
• Comply with all applicable laws, sanctions, tax, and regulatory requirements;
• Keep your Pure App access and security features secure;
• Promptly notify us of unauthorized access, fraud, errors, or suspected security incidents.

7.2 You must not:

• Use the Services for unlawful activity, fraud, terrorist financing, money laundering, sanctions evasion, or other prohibited conduct;
• Use the Services to circumvent financial, currency, exchange control, tax, or sanctions laws;
• Provide false, misleading, or incomplete information;
• Attempt to manipulate payments, exploit technical errors, or interfere with the Website, Pure App, or Services;
• Use the Services if you are prohibited from doing so under these Terms or applicable law.

7.3 We do not accept third-party payments or third-party withdrawals. Fiat Funds must be sent from, and withdrawn to, a bank account in your name, unless we expressly approve otherwise in writing.

8.1 Before providing Services, we may require you to complete customer due diligence, including identity verification, address verification, screening, and assessment of the purpose and intended nature of the business relationship.

8.2 For legal entity Customers, we may require information about directors, senior managing officials, authorized representatives, beneficial owners, controlling persons, ownership structure, business activities, expected transaction activity, and source of funds.

8.3 We may use Third-Party Service Providers to verify your identity and screen you against sanctions, politically exposed person, adverse media, and other risk lists.

8.4 We may request additional information at any time, including information about the source of funds, source of wealth, expected activity, transaction counterparties, or the reason for a transaction.

8.5 We may delay, limit, decline, suspend, or terminate Services if:

• Required information is not provided;
• Information cannot be verified;
• Verification or screening results are unsatisfactory;
• We suspect money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful activity;
• A third-party provider or applicable law requires action.

9.1 Fiat Funds received from you in connection with the Services are held by a Third-Party Payment Provider.

9.2 Pure Payments maintains records that identify the balance attributable to each Customer separately.

9.3 Funds held by a Third-Party Payment Provider may constitute Electronic Money. Electronic Money is not a bank deposit, does not accrue interest, and is not covered by the deposit-guarantee scheme applicable to deposits held with credit institutions.

9.4 A Third-Party Payment Provider is required to safeguard client funds in accordance with applicable regulatory requirements. Safeguarding arrangements are intended to keep client funds separate from the provider’s own funds and are not equivalent to deposit insurance.

9.5 In the event of a Third-Party Payment Provider’s insolvency, operational disruption, regulatory intervention, legal restriction, or other exceptional circumstances, temporary limitations on access to, transfer of, or disposal of client funds may arise.

9.6 Pure Payments does not hold client Fiat Funds as bank deposits and does not provide deposit insurance. Pure Payments makes no representation that client Fiat Funds are protected by any deposit-guarantee scheme.

9.7 The availability, execution, and settlement of payment services may depend on Third-Party Payment Providers, correspondent banks, payment systems, and other third-party financial institutions. Pure Payments shall not be liable for delays, restrictions, or failures caused by such third parties, except to the extent caused by Pure Payments’ own breach of these Terms.

10.1 You may deposit Fiat Funds using the SEPA or SWIFT payment details made available through the Pure App.

10.2 You must use only the payment details provided for your own transactions. Payments sent using incorrect details, from a third-party account, or in an unsupported currency may be delayed, returned, rejected, or subject to additional verification.

10.3 We may apply limits, holds, verification requirements, or delays on deposits for AML/CTF, sanctions, fraud, security, operational, liquidity, or legal reasons.

10.4 We may return, hold, reject, or request verification for a payment where the sender or receiver cannot be identified, the payment breaches these Terms, or additional due diligence is required.

10.5 A deposit is credited only when the relevant funds have actually been received into the client-funds safeguarding arrangement maintained by the applicable Third-Party Payment Provider.

10.6 Applicable fees, limits, and processing times are set out in the Fee Schedule.

11.1 You may request withdrawal of all or part of your available balance through the Pure App.

11.2 Withdrawals are processed by SEPA or SWIFT transfer.

11.3 Withdrawals will be made only to a verified bank account in your name, unless we expressly approve otherwise in writing.

11.4 We may require evidence that the receiving bank account belongs to you before processing a withdrawal.

11.5 We may delay, reject, suspend, or request additional information for a withdrawal where required for AML/CTF, sanctions, fraud, security, operational, liquidity, or legal reasons.

11.6 You are responsible for providing correct beneficiary name, account number, IBAN, SWIFT/BIC, bank details, and any other required payment information.

11.7 We are not responsible for losses caused by incorrect or incomplete payment details provided by you.

12.1 You may use the Services to make outbound payments and receive inbound payments by SEPA or SWIFT transfer.

12.2 You must ensure that every payment instruction is lawful, accurate, complete, and unambiguous.

12.3 Once a payment instruction has been submitted and authorized, it may not be cancelled or amended, except where we reasonably determine that cancellation or amendment is possible and appropriate.

12.4 If a payment is executed using the beneficiary details you provided, we may treat the payment as properly executed even if those details identify a different person or account than you intended.

12.5 We may assist in attempting to recall or recover a payment, but we do not guarantee successful recovery. Additional fees may apply.

12.6 We may refuse, delay, or suspend a payment where reasonably necessary due to concerns about:

• The authenticity or authority of the instruction;
• The legality of the transaction;
• Sanctions compliance;
• AML/CTF requirements;
• Insufficient, inconsistent, or unverifiable supporting information;
• Security concerns;
• Other objectively justified compliance or operational grounds.

12.7 We may request documents or information about the origin, ownership, legality, purpose, and economic rationale of funds or payments. If you do not provide the requested information, we may refuse or delay the payment.

13.1 We may charge fees for the Services, including deposit, withdrawal, transfer, payment-processing, and other service fees.

13.2 Our fees, limits, and any applicable charges are set out in the separate Fee Schedule published on the Website.

13.3 We may deduct applicable fees from a transaction amount, your available balance, or a withdrawal amount.

13.5 We may change fees, limits, or charges from time to time. We will inform you before material changes take effect. The notice period will be reasonable and may be shorter where required by law, regulation, security, sanctions, or other justified operational circumstances.

14.1 We are required to comply with applicable Canadian AML/CTF, sanctions, and regulatory requirements.

14.2 We may conduct identity verification, sanctions and PEP screening, adverse media screening, transaction monitoring, ongoing due diligence, and source of funds or source of wealth checks.

14.3 We may delay, hold, decline, suspend, or reverse a transaction, or restrict or close your access to the Services, where required or reasonably justified for AML/CTF, sanctions, fraud, security, legal, regulatory, or risk management reasons.

14.4 We may report transactions or activities to FINTRAC or other competent authorities where required by law.

14.5 We may retain information and records after closure of your business relationship where required by law or necessary for legitimate compliance purposes.

15.1 We may suspend, restrict, delay, or terminate your access to the Services, in whole or in part, where we reasonably determine that:

• You have breached these Terms;
• Information provided by you is false, incomplete, or misleading;
• A transaction or account activity is suspicious, unlawful, fraudulent, or associated with sanctions concerns;
• Required KYC, source of funds, or other information has not been provided;
• A regulatory report, legal order, sanctions requirement, or third-party provider requirement applies;
• Continued provision of Services would create legal, regulatory, financial, reputational, or operational risk.

15.2 We may close your business relationship and return available Fiat Funds, subject to applicable law, third-party provider requirements, verification, and our risk-management procedures.

15.3 We may retain information and records after closure where required by law or necessary for legitimate compliance purposes.

15.4 We are not liable for losses caused by a suspension, restriction, delay, or termination where taken in accordance with these Terms or applicable law.

16.1 You are responsible for the accuracy and completeness of all instructions, payment details, beneficiary information, and transaction requests submitted by you or by a person authorized to act on your behalf.

16.2 If you believe a transaction was unauthorized, made in error, or was not properly executed, you must contact us promptly at support@purewallet.global.

16.3 We may investigate and, where appropriate, correct, reverse, return, or report a transaction. We may require information and cooperation from you during an investigation.

16.4 We may suspend access or require additional verification where we detect unusual activity, security concerns, or suspected unauthorized use.

17.1 You may submit a complaint by email to support@purewallet.global.

17.2 Please include your name, registered email address, transaction reference, date of the issue, and a clear description of the complaint.

17.3 Pure Payments’ customer support and compliance teams will review complaints relating to the Services.

17.4 Our complaint handling process and timelines are set out in our Complaints Policy.

18.1 Our collection, use, disclosure, retention, and transfer of personal information are described in the Privacy Policy.

18.2 You acknowledge that we may share your information with banking and payment partners, technology providers, regulators, and law-enforcement or other competent authorities where necessary to provide the Services, comply with law, prevent fraud, or manage risk.

19.1 The Website, Pure App, their content, branding, software, and related materials are owned by Pure Payments or its licensors.

19.2 You may use the Website, Pure App, and Services only for their intended purpose. You may not copy, modify, distribute, reverse-engineer, scrape, or exploit them without our prior written consent.

20.1 The Services are provided on an “as is” and “as available” basis, subject to these Terms.

20.2 We do not guarantee uninterrupted or error-free access to the Website, Pure App, or Services.

20.3 Cryptoasset services involve significant risk, including volatility, technology failure, cybersecurity risk, regulatory risk, and irreversible transaction risk. Those services are governed by the Crypto Terms.

21.1 To the maximum extent permitted by law, Pure Payments shall not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages, loss of profit, loss of revenue, loss of business, loss of goodwill, or loss of data.

21.2 We are not liable for delays, failures, or losses caused by banks, payment providers, correspondent institutions, Third-Party Payment Providers, Third-Party Service Providers, other third parties, force majeure events, or your breach of these Terms.

21.3 Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law.

22.1 You agree that we may provide agreements, notices, disclosures, statements, transaction information, and other communications electronically through the Pure App, email, or other electronic means.

22.2 You are responsible for maintaining a valid email address and for regularly reviewing communications sent to you.

22.3 You agree that we may record chats, support communications, and other communications for compliance, security, quality-assurance, dispute-resolution, and recordkeeping purposes, subject to applicable law.

23.1 These Terms are governed by the laws of Canada and the laws of the Province of Ontario, without regard to conflict of laws rules.

23.2 Any dispute arising from or in connection with these Terms or the Services shall be subject to the exclusive jurisdiction of the courts located in Ontario, Canada, unless applicable law provides otherwise.

24.1 If any provision of these Terms is invalid or unenforceable, the remaining provisions will remain in force.

24.2 Our failure to enforce a provision does not waive our right to enforce it later.

24.3 You may not assign or transfer these Terms without our prior written consent. We may assign or transfer our rights and obligations to an affiliate or in connection with a corporate transaction.

24.4 These Terms, together with the documents referenced in them, constitute the entire agreement between you and Pure Payments regarding the Services.

Pure Payments Inc.

30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario, Canada

FINTRAC MSB Registration No.: M21207804

Email: support@purewallet.global

Website: https://purewallet.global/