Zasady użytkowania Rebell Pay app

1. Definitions

Terms used in the content of these Terms and Conditions of use of Rebell Pay app (the Terms and Conditions) have the meaning given below:

1. Bank – the issuer of the Payment Card to the User,
2. Card Network – Visa, Mastercard or other card networks (also known as card associations) that act as intermediaries between an acquirer and an issuer to process credit and debit card transactions,
3. Company – Elixir Group S.A., a Polish company having its registered office and postal address at ul. Burakowska 16B lok. U1, 01-066 Warsaw, Poland, KRS (National Court Register) No. 0001109236, being the developer and the owner of the Rebell Pay app,
4. Rebell Pay app – the software platform developed by the Company in order to facilitate different features that help Users to send, receive and/or manage their money easily through variety of features described in detail on the basis of these Terms and Conditions,
5. Payment Card – a payment instrument issued under the system of the Payment Organization,
6. Payment Organization – Mastercard Europe SPRL; Visa International; and other card organizations; an organization granting a license for issuing Payment Cards and handling transactions with such cards,
7. PCI DSS – Payment Card Industry Data Security Standard, which is an information security standard for organizations that handle branded credit cards from the major card schemes,
8. PSP – Fenige S.A., a Polish company having its registered office at ul. Promienna 38/1, 03-672 Warsaw, Poland, KRS (National Court Register) No. 0001057371, licensed payment services provider engaged by the Company that provides the Transaction Authentication and Transaction Settlement services, operates pursuant to the PCI DSS, meaning that it keeps the highest security standards in Payment Card data processing,
9. C2C Recipient – A natural person, a holder of a Payment Card who doesn’t have to be Rebell Pay app User and who receives a “card to card payment” from the C2C Sender through the use of Rebell Pay app,
10. C2C Sender – the User of the Service that uses Rebell Pay app to make a “card to card payment” to the C2C Recipient,
11. P2P Recipient – A natural person, a holder of a Rebell Pay app account with balance (individual bank account) who receives a P2P payment from the P2P Sender through the use of Rebell Pay app,
12. P2P Sender – the User of the Service that uses Rebell Pay app account with balance (individual bank account) to make a P2P payment to the P2P Recipient,
13. Quicko – Quicko sp. z o.o., a Polish company having its registered office at Sienkiewicza 49, 42-600 Tarnowskie Góry, Polska, Poland, KRS (National Court Register) No. 0000350151, licensed payment services provider engaged by the Company that provides the opening and maintaining payment Accounts, issuing and servicing Quicko Cards and execution of Transactions from User Accounts.
14. Quicko Agreement – collective definition of the Framework Agreement and Agreements concluded with the customer in its execution, i.e. an agreement for a Mastercard Payment Card, for opening and maintaining a payment account, for providing access to payment services with use of the Rebell Pay Profile.
15. P100 – P100 Sp. z o. o, a Polish company having its registered office at Adama Matuszczaka 14 / 2, 35-083 Rzeszów, Poland, KRS (National Court Register) No. 0000974431 and is in the business of buying and selling cryptocurrencies with Digital Asset Provider registration number RDWW-392 under Polish law: https://www.gov.pl/web/finanse/rejestr-dzialalnosci-w-zakresie-walut-wirtualnych
16. Partners – meaning collectively PSP, Quicko and P100
17. Service – services facilitated by the Rebell Pay app could be understand together or separate depending on User’s actions in the Rebell Pay app:
    1. ”card to card payment” developed by the Company in cooperation with PSP, consisting of debiting the Payment Card account of the C2C Sender upon his/her order and crediting the Payment Card account of the C2C Recipient;
    2. Account - Account written with a capital A means an individual bank account maintained for the customer by Quicko on the basis of the Quicko Agreement on Opening and Maintaining a Payment Account with a unique number assigned.
    3. Quicko Card – Payment Card connected to Account issued by Quicko.
    4. P100 Service – a custodial wallet that allows Users to store and manage Digital Assets, including:
       1. Conversion of Digital Asset into other Digital Asset and fiat currency;
       2. Conversion of fiat currency into any type of Digital Asset to be held in custodial wallet;
       3. Digital Asset transfer service under which User may transfer any Digital Asset to another recipient, which may be the Digital Asset wallet of another User or an external recipient;
18. Third Party Provider - GetID OÜ, an Estonian company having its registered office at Maakri 30, 17th floor, 10145 Tallinn, Estonia and/or UAB “iDenfy” Baršausko street 59, 51423 Kaunas, Lithuania services provider engaged by the Company that provides Full ID Verification service, as defined in paragraph 11 of these Terms and Conditions,
19. Transaction Authentication – verification of the Payment Card and its holder and obtaining a confirmation from the Payment Organization that the C2C Sender ’s Payment Card may be debited and that the C2C Recipient’s Payment Card may be credited;
20. Transaction Settlement – organizing debiting C2C Sender ’s side and crediting C2C Recipient’s side with the Payment Organization,
21. 3DS (3D Secure) – an authenticated payment system to improve online transaction security. The objective is to provide a safe and secure online payment experience using a password that is validated by the Payment Card issuer and further checked by all other parties involved in the transaction.
22. Profile or User - a natural person, a holder of access to the Rebell Pay Service registered under phone number and/or email address, that uses a Service through Rebell Pay app and enters into a contract with the Company, PSP, Quicko and/or P100 on the basis of these Terms and Conditions,

2. General Provisions

1. These Terms and Conditions regulate the use of the Rebell Pay app by the Users.
2. The Rebell Pay app is a software platform aimed at facilitating Service. The Company is an information technology company that has developed and owns the Rebell Pay app.
3. In connection with the execution of the Service, the Company and Partners come into possession of the User's data, however PSP and Quicko come into possession of the Payment Card data provided by the User in the Rebell Pay app, which constitutes the provision of technical services supporting the provision of payment services within the meaning of Article 6.10 of the Polish Act of 19th August 2011 on payment services.
4. For the avoidance of doubt, neither the Company nor the PSP is involved in either the debiting or the crediting of the Payment Cards and at no point in time during the provision of the Service the Company and/or the PSP get hold of the Users’ funds. In addition, neither the Company nor the PSP will gain access to the Payment Card accounts of the Users. The Transaction Settlement shall be effected directly between the C2C Sender ’s Bank and the C2C Recipient’s Bank and arranged by the Payment Organization.

3. Purpose of the Terms and Conditions

The purpose of these Terms and Conditions is to define the principles of using the Service by the Users via the mobile app.

4. Downloading of Rebell Pay app

1. The User may only use the Service via the Rebell Pay app.
2. The Rebell Pay app is designed to work with smartphones running Android 12+ and iOS 14+. Rebell Pay app may as well run on older version of Android and iOS as well as other devices, such as tablets, however, the Users are hereby expressly notified that the Rebell Pay app and its functionalities are intended to be used only via smartphones with mentioned versions of operating systems, and that its use through any types of different platforms, including, but not limited to, personal computers, laptops, tablets, etc. may cause considerable errors and disabilities towards usage of the Rebell Pay app and its functionalities. The Company, therefore, does not assume any risks and/or liabilities which could arise from the use of Rebell Pay app and its functionalities via any types of platforms other than smartphones and via smartphones with older operating software than mentioned above.
3. The User may need to upgrade the operating system on his/her device if the Company changes the version(s) that the Rebell Pay app supports. The User may not be able to install or use the Rebell Pay app on a jail-broken or rooted device or use the Rebell Pay app in older versions than mentioned on Google Play and Apple App Store or use the Rebell Pay app installed from other sources than Google Play or Apple App Store.
4. Downloading of the Rebell Pay app requires internet access, as the Rebell Pay app is only distributed via proprietary app marketplaces, i.e. Apple App Store and Google Play Store. The User’s telecommunication service provider may charge the User for internet access on the User’s device.
5. When the Rebell Pay app is downloaded and the User opens it for the first time, he/she first needs to complete the registration process in order to open Rebell Pay app Profile. It consists of the following steps:
   1. indicating his/her country and phone number
   2. entering a confirmation code received by SMS
   3. creating a four-digit passcode which could be supported by biometric login (upon User’s approval) which the User will then have to enter every time he/she opens the Rebell Pay app on his/her device.
   4. Providing his/her personal details, that are complete and true on the day of registration, including:
      1.  full name;
      2. date of birth;
      3. email address;
      4. residential address;
      5. declarative source of funds;
      6. tax residency country, where applicable
6. Additionally, to use the Service, User will need to go through full ID verification for which Company use Third Party Provider. If any of the mentioned step is missed, the Rebell Pay app cannot be used and will not work for the User. Furthermore, according to Anti-Money Laundering Act, the Company can ask a user to provide additional documents to verify provided information such as but not limited to proof of residence and/or source of funds and only after positive verification all or some functionalities of the application may be accessible by the User.
7. One User can have only 1 (one) Rebell Pay app profile.

5. Adding of Payment Cards to Rebell Pay app

1. For the execution of the selected Services, the User will be required to add one or several Payment Card(s) to the Rebell Pay app for the sending and receiving funds. Payment Cards that can be added to the Rebell Pay app are debit and credit cards, as well as prepaid cards with a name on them. Some of the cards may be unsupported by the Rebell Pay app for technical, regulatory or other reasons. The Company has the discretion to decide which Payment Cards are supported and which are not, without being obliged to provide any explanations to the Users. At this stage, business cards are not supported on the Rebell Pay app.
2. The process of adding a Payment Card(s) involves indicating card number, expiration date, and CVV/CVC number. This can be done manually.
3. The User will be required to indicate the base currency of the card in order to avoid double conversion exchange rates applied by the issuing Banks while charging or crediting Users’ card.
4. The Company will pass all the information on the Payment Card(s) collected on the Rebell Pay app to the PSP, which will save such data using PCI DSS standards. The Company will retain and store only partial Payment Card number (only first 4 or 6 digits and last 4 digits) as well as the expiration date of the Payment Card.
5. Once the Payment Card details are entered, the card will be verified by the PSP. Payment Card verification covers two aspects:
   1. verification of the issuing country of the card;
   2. that the card added is supporting outgoing and/or incoming transactions (debiting and crediting). The verification process might include charging and refunding or funding the relevant Payment Card by the Company with certain minimal amounts in the currency of the Payment Card. The verification will allow categorizing the Payment Card as a “card for sending and receiving”, “card for sending” or “card for receiving”. The cards not supporting incoming transactions will be added on the Rebell Pay app for the purposes of sending funds only, the cards marked as for receiving will be added on the Rebell Pay app for the purposes of receiving funds only
   3. Rebell Pay app may, from time to time, use other methods or procedures for the card verification to provide Users with updated categorized status for relevant Payment Card. The User will be notified every time the Payment Card receives updated status.
6. Payment Card verification normally takes a few seconds, after which the Payment Card added by the User appears on the relevant dashboard.
7. The last verified Payment Card classified as the “card for receiving” or “card for sending and receiving” added by the User will be automatically determined by the Rebell Pay app’s system as a default card for receiving of funds, in case if the Payment Card of the C2C Recipient, who is also a Rebell Pay User, is not specified at the time of initiation of the transaction by the C2C Sender.
8. In a situation when User will create/issue new Quicko Card for him/herself the card will be automatically added to PSP following selected points written in this section without the need of entering card details manually. In such a case communication will be automatically done between Quicko and PSP.
9. Every operation on cards are handled by PSP or Quicko which is fully described in other points of this document.

6. Effecting “Card to Card Payments” on Rebell Pay app

1. Only after the User has downloaded and installed the Rebell Pay app, has registered in, logged in and accepted these Terms and Conditions and Privacy Policy, and has added Payment Card(s) which have been duly verified, the User can act as the C2C Sender and initiate payments from his/her Payment Cards (classified as the “card for sending” or “card for sending and receiving”) to the C2C Recipients.
2. The C2C Recipients, for whose benefit the payment is being initiated do not have to be the Rebell Pay app User. In this case he/she receives a notification through sms on a phone number provided by the C2C Sender. It includes a secure link (with short validity) under which, he/she self-identifies using the verification code supplied in the SMS notification and can then provide his/her Payment Card number to be credited to accept the incoming payment.
3. The C2C Sender can also use the Rebell Pay app to send funds to other cards of his/her own which were verified as valid for receiving funds.
4. When the C2C Sender wants to make a payment, the process is as follows:
   1. the C2C Sender logs in to the Rebell Pay app;
   2. the C2C Sender manually inserts an amount that he/she wishes to transfer;
   3. the C2C Sender selects a Payment Card from which he/she wants to make a payment;
   4. The C2C Sender selects a C2C Recipient. C2C Sender  can send A. Internal transfer on one of his own cards from the list and which were verified as valid for receiving funds. B. phone number from his contact list (All the C2C Sender ’s contacts that also are the Users of the Rebell Pay app will be listed above all the other contacts, under the condition that the valid prefix is included before the number in the contact list), C. new phone number entered manually D. directly on a card number of the C2C Recipient, provided manually.
   5. the Rebell Pay app will display the amount to be charged from the C2C Sender ’s Payment Card, the fees to be paid, and the currency exchange rate with amount after currency conversion when applicable;
   6. the C2C Sender needs to confirm the transaction by entering CVV/CVC of the card from which the transfer will be made and by tapping the execution button. Where the C2C Sender  does not confirm the transaction within 15 minutes, the transaction will be declined.
5. The execution of payment may require additional verification of the transaction by 3DS protocol in the manner normally applied by the Bank. The execution of payment may also be blocked or rejected by the Bank due to any reasons at its discretion, in which case the C2C Sender should contact his/her Bank for further information and action.
6. Upon receipt of the C2C Sender’s confirmation of the payment, the Company sends, via PSP, to the Payment Organization a message concerning:
   1. the amount to be debited from the C2C Sender’s Payment Card account. The amount to be debited shall correspond to the amount of the transaction initiated by the C2C Sender , taking into account the currency exchange rate when applicable, and increased by the transaction fees if any of such fees are on the C2C Sender ’s part;
   2. the amount to be credited to the C2C Recipient’s Payment Card account. The amount to be credited shall correspond to the amount of the transaction initiated by the C2C Sender , taking into account the currency exchange rate when applicable, without the transaction fees if any of such fees are on the C2C Recipient’s part. The amount actually credited to the C2C Recipient’s Payment Card account may be slightly different than displayed within the Rebell Pay app due to exchange rate display limitations (only 2 digits after the decimal separator are displayed on the Rebell Pay app).
7. The Payment Organization transfers the information indicated in item 6 above to the Card Network. Provided that the Card Network confirms the possibility of debiting the C2C Sender’s Bank and crediting the C2C Recipient’s Bank, the Service will be provided successfully.
8. On the C2C Recipient’s side, the C2C Recipient, in case he/she also has the Rebell Pay app, is notified of the incoming payment. The notice will indicate the person sending the money, the amount, the currency exchange rate (if applicable) and the purpose of payment if such was indicated by the C2C Sender , also the transaction fees if these shall be paid by the C2C Recipient. The payment will be credited, after the currency exchange rate is applied, when applicable, to a default card for receiving of funds, in case if the Payment Card of the C2C Recipient, who is also a Rebell Pay User, was not specified at the time of initiation of the transaction by the C2C Sender .
9. Once the payment is initiated and authorized by the C2C Sender for processing, information about the transaction will appear on the history of the C2C Sender ’s outgoing transactions. Should the recipient be the Rebell Pay user, it will equally appear on the history of the C2C Recipient’s incoming transactions on the Rebell Pay app, once it has been successfully processed.
10. The Service may only be executed within the limits of transaction number or amount determined by the Company for each User on a customized basis. The limits indicated in the table of limits appended to these Terms and Conditions reflect the standard limits, and the Company may at its sole discretion provide different limits for different Users, which will vary across currencies, amounts, and types of Payment Card (prepaid, debit or credit cards). The User may at any time see the minimum and maximum limits applicable to him/her in the settings of the Rebell Pay app. Where the amount of the initiated transaction exceeds the applicable limit, a message will be displayed on the screen of the Rebell Pay app and the payment with the relevant Payment Card will not be affected at all, i.e. the payment will not be effected within the allowed limits as well. In order to perform the transaction, the User might be offered to perform additional identification.
11. The payments on Rebell Pay app can be made 24/7.
12. The term for the provision of Service shall normally not exceed 30 minutes and in most cases will take a few seconds. In any case, the funds shall reach the C2C Recipient no later than until the end of the next working day following the day of the confirmation of the payment by the C2C Sender and only in rare cases, the process may take longer. The exact time on which a transaction will be credited to the Payment Card account of the C2C Recipient depends on the C2C Recipient’s Bank.
13. In some cases, the C2C Sender ’s or the C2C Recipient’s Bank or PSP may block, stop or reject transactions for security or other reasons. It is also possible that funds are blocked as a result of a cancelled or unsuccessful transaction. The Company is not responsible for the Banks’ or PSP’s policies and shall not be liable for any security blocking performed by the Banks.
14. All the fees displayed by the Company to the User are the only fees charged by the Company for the Service. The Company is not liable for any other additional fees applied by the Issuing Bank or receiving Bank and those will not be displayed on the Rebell Pay app.
15. Due to the complete execution of every transaction as a part of the Service at the request of the C2C Sender who is a consumer, before the statutory deadline for withdrawing from these Terms and Conditions, i.e. the deadline of 14 days from the date of accepting these Terms and Conditions, there is no right to withdraw from the Terms and Conditions after such transaction has been executed.
16. Every card to card transfers done via Rebell Pay app are fully operated by PSP.
17. Every other type of fiat currency transfer via Rebell Pay app is fully operated by Quicko.

7. User’s Obligations

1. The User is obliged to:
   1. comply with any restrictions on using the Rebell Pay app, downloading or otherwise exporting the Rebell Pay app;
   2. only download the latest Rebell Pay app from proprietary app marketplaces, i.e. Apple App Store and Google Play Store;
   3. comply with these Terms and Conditions including documents that this Terms and Conditions refers to especially Partners Terms and Conditions as well as Privacy Policy.
   4. provide true, complete and up-to-date data when ordering the Service, in particular, the data on the C2C Sender and the C2C Recipient, which is consistent with the data appearing on the C2C Sender ’s and C2C Recipient’s cards;
   5. ensure that the Payment Card number, mobile number and other details he/she provides are correct and up to date, and notify the Company as soon as these change;
   6. exercise due care for the purpose of protecting a device where the Rebell Pay app is downloaded or on which he/she enters the data to the Rebell Pay app against unauthorized access, and notify the Company immediately in case of any actual or suspected unauthorized access to the device with the installed Rebell Pay app or in case of the disclosure of login data for the Company to be able to block any operations from the User’s profile.
2. The Users shall in no case:
   1. use the Rebell Pay app in any unlawful manner, for any unlawful purpose, or in any manner inconsistent with these Terms and Conditions, or act fraudulently or maliciously for example by hacking into the Rebell Pay app or device where it is installed;
   2. use the Rebell Pay app for any illegal activities, including collecting payments that are not owed to them;
   3. use the Rebell Pay app in a way that could damage, disable, overburden, impair or compromise the Service, Company’s systems or security or interfere with other Users.

8. Suspension of Service

1. The Company may temporarily withhold the execution of the Service, reject execution of the Service or block the possibility of initiating the User’s transactions in the future in the following situations:
   1. the User’s non-compliance with the provisions of these Terms and Conditions;
   2. not receiving from the User correct or complete data necessary for the execution of the Service at the time allotted to introduce such data (including when the confirmation of the transaction is not provided within the specified time);
   3. invalidity or cancellation of the Payment Card of the C2C Sender or the C2C Recipient;
   4. refusal of execution of the transaction by the Bank;
   5. an attempt to make payments in breach of the relevant applicable law, including the suspected unauthorized use of the Payment Card, fraud, illegality of payment itself, and in particular due to the provisions of the Polish Act of March 1, 2018 on Anti-Money Laundering and Countering the Financing of Terrorism and PSP's internal procedure on anti-money laundering and countering the financing of terrorism;
   6. a command of public administration authority or law enforcement agencies.
   7. If a chargeback has been initiated or a suspicious activities has been noticed on the account
   8. violation of paragraph 23 p. 11 of the Regulations;
   9. if a User who is a P2P Recipient referred to herein accepts and then cancels or fails to complete at least 3 (three) Offers;
2. The Company shall not be liable for any loss incurred by the User due to unavailability of the Service on the basis of any of the situations listed above.
3. In case of account being suspended the Company has a right to limit the withdrawal of the funds from Account up to 90 days. The proper communication will take place between User and Company to inform about the situation.

9. Security

1. Rebell Pay app can be used to make payments from the User’s Payment Card account, the User must keep his/her device secure and not logged into the Rebell Pay app when it is not being used.
2. Rebell Pay app can be used to receive information about the balance of individual bank account (IBAN) as well as the details of Account on which the User can collect money according to Point 21. To do so the User has to provide the full details of the account including IBAN, bank details as well as SWIFT code if needed that can be found in the applications account details section. Rebell Pay app can also be used to receive information about the details of Quicko Card such as card number, CVV/CVC or date of expiry after additional verification. Rebell Pay is only facilitating the access to mentioned information which is managed by Quicko. The User must keep his/her device secure and not logged into the Rebell Pay app when it is not being used.
3. If the User suspects that someone else knows his/her passcode and/or CVV/CVC numbers of Payment Cards added on the Rebell Pay app, or other security details enabling making payments through the Rebell Pay app, he/she must contact the Company immediately by the details provided in these Terms and Conditions, and the Company will block the User’s profile. At the same time, where the Payment Cards or any security details relating thereto become available to the third parties, the Users must immediately contact bank that issue such card and block the Payment Cards. If such a situation occurred regarding the Quicko Card User must immediately block card through dedicated screen in the application or contact Rebell Pay team via support [at] rebellpay.com. If the User fails to do so, or until the User does so, he/she will be liable for any unauthorized transactions on their account which are a result of their security details becoming known to someone else. The Company will not be liable for any unauthorized transactions on the User’s Profile or by using Quicko Card which are a result of their security details becoming known to someone else, during the time where the User has already notified the Company about such security breach but has not yet blocked his/her Payment Cards.
4. After the User’s initial registration the Company will never contact the Users to request their security details and will not ask anyone else to do so on the Company’s behalf. If the User receives such a request then it is likely to be fraudulent and the User must not supply his/her security details in any circumstances. Any such activity should be reported to the Company immediately.
5. Company has a right to deactivate or block the Profile if suspected activity has been noticed. The Company has a full flexibility to define suspected/not normal activity.

10. Liability

1. When making a payment or creating an offer for P2P Service, the user, which is a Sender, must ensure that recipient’s information (depending on the transaction type it might include phone number, payment card number, IBAN, payment amount and/or any extra information required to make or enable the payment) is current and correct, otherwise, the payment may be aborted or made to the wrong recipient. The Company will not be liable to the Users if the payment is sent to the wrong person as a result.
2. Unless the Company is at fault, the Company will not be liable for any losses the Users might suffer or costs they incur because:
   1. the User is unable to access or use Rebell Pay app for any reason or there is a delay in its use;
   2. the Rebell Pay app is used on a device other than a smartphone;
   3. any device, hardware or software the Users use in connection with the Rebell Pay app is damaged or corrupted or fails to work;
   4. the Rebell Pay app does not meet the User’s requirements or expectations;
   5. there is a reduced level or failure to provide the Service caused by any third-party service providers including software providers and mobile operators.
3. Due to the fact that under provision of the Service the Company does not take possession of funds of the C2C Sender or the C2C Recipient, the Company’s liability is in any case limited to default by sending of incorrect message to the Payment Organization via the PSP or to Quicko about debiting the C2C Sender ’s Payment Card account and / or crediting the C2C Recipient’s Payment Card account. Account offer provided by Rebell Pay is managed by Quicko and rules written in Point 21 are applicable.
4. More information could be found in Terms and Conditions of a single transactions mentioned in point 20.

11. User Identification Requirements

1. In executing the Service, the Company verifies the identity of User and applies appropriate financial security measures referred to in the Polish Act of March 1, 2018 on Anti-Money Laundering and Countering the Financing of Terrorism, in cooperation with the Third Party Provider.
2. In addition to the information collected on the User when downloading, installing and using the Rebell Pay app, additional data is required to proceed KYC procedure.
3. Additional data to be requested by the Third Party Provider acting on behalf of the Company in order to carry out the Full ID Verification will be the following:
   1. photo of the front and the end (if applicable) of the original ID, Passport, Driving License or Resident Permit document, taken and transmitted real-time to the Company through the Rebell Pay app. No photos of the copy of the mentioned documents and no uploading of the previously made photos/copies will be accepted, the original original ID, Passport, Driving License or Resident Permit document needs to be photographed real time for Full ID Verification purposes;
   2. photo of the face of the User (“selfie”), taken and transmitted real-time to the Company through the Rebell Pay app. No photos of the photos and no uploading of the previously made photos will be accepted, the User needs to take a photo of himself/herself real time for Full ID Verification purposes;
4. The information referred to in item 3 above, once collected, is subject to the similarity check held by the Third Party Provider. After such checks are performed, the Company will be notified by the Third Party Provider if they were successful, and if they were, the User will receive a notification that his/her ID Verification has been successful and will then be entitled to send funds and create Account and issue Quicko Card (if ID Verification will be concluded with acceptable by regulatory document: International Passport or Resident Permit issued in EU for none EU resident or International Passport, ID, Resident Permit for EU resident). Where the similarity checks were not successful, the User may not get access to any of mentioned features. The number of attempts to pass Full ID Verification is not limited, however, the Company might block the User’s account or contact the User for additional information in case of any suspicious behavior on the User’s side.

12. Personal Data Processing

1. Providing personal data to the extent necessary indicated in these Terms and Conditions is a necessary for the conclusion and performance of the Service.
2. Personal data is processed according to the Privacy Policy.
3. In order to use the Rebell Pay app, the User has to provide the following data that is processed by the Company acting as the controller of personal data:
   1. full name;
   2. date of birth;
   3. adres e-mail;
   4. photo of the face of the User;
   5. photo of ID, Passport, Driving License or Resident Permit (front and rear side);
   6. actual residence address, country and geolocation;
   7. declared tax residency country
   8. declared source of funds
   9. phone number;
   10. data of the Payment Cards of the C2C Sender and the C2C Recipient: number, validity date, CVV/CVC number;
   11. additional information requested under item 2 of paragraph 11 of these Terms and Conditions in case of Full ID Verification, such as the User’s identity card or passport data;
   12. data about the initiated transaction.
4. The User, by registering and logging in to Rebell Pay app and by introducing the above data on the Rebell Pay app, expresses his/her consent for the controlling and processing of such data by the Company and Partners for the purpose of execution of the Service. In the same time User accept this Terms and Conditions as well as Privacy Policy.

13. Fees

1. The use of the Service is subject to the transaction fee. The amount of the fee will in each case depend on the type of Service selected, and may further depend on the amount of the transaction, currency, and/or countries between which the payments will be made, and may not necessarily be set as a fixed amount in advance. The fee for each relevant transaction will be displayed to the User before approving the transaction. Finalizing the transaction means that User accepts the transaction fees.
2. Transactions can be made in the currency of the card indicated by the User while adding the Payment Card to the Rebell Pay app, however, where the currency of the transaction differs from the base currency of the Payment Card, the currency exchange of the Issuing Bank will apply. The Company is not liable for the Banks’ currency rates, therefore the User is required to insert correct base currency of the card to avoid double conversion. While making transaction the currency exchange rate and amount after currency conversion with respect to each relevant transaction will be displayed to the User before approving the transaction.
3. Any fees user need to pay for the facilitation of the Service on the Rebell Pay app shall be deducted from the Sender’s balance or Payment Card (depending on the Service type and where it is on the Sender ’s part).
4. Fees for facilitating Account and/or Quicko Card are listed in the Appending in Table of the Commissions.
5. Rebell Pay have a right to change all the fees in any time after prior notification to the User before concluding transfer.

14. Complaints, Communication, and Language

1. Complaints concerning non-execution of the Service or its execution not in line with the principles defined in these Terms and Conditions may be submitted via Help Centre of the Rebell Pay app or website of the Company rebellpay.com or send directly to support [at] rebellpay.com
2. The complaint should contain:
   1. an indication of the Users’ full name, phone number, email and additional information regarding the complaint eg. transaction number (available in the User’s transaction history);
   2. a description of the subject of the complaint;
   3. all evidence supporting the complaint;
   4. transaction details (if applicable) such as date, time, amount and last 4 digits of the card involved if the faulty Service related to a transaction;
   5. a return address, to which a response is to be sent if the User wishes to receive a response otherwise than through the channel through which the complaint was submitted.
3. The Company will accept complaints in English and Polish.
4. Complaints are examined and responded by the Company immediately, no later than within 15 business days from the date of receipt of the complaint and in particularly complicated cases, 35 business days. The deadline is deemed observed after sending, prior to its expiry, a response to the User via Help Centre of the Rebell Pay app and via other channels according to the User’s Notification Settings of the Rebell Pay app.
5. Notices concerning leakage of a passcode, CVV/CVC numbers or other security details etc., which require action by the Company with respect to blocking the Profile, shall be submitted via Help Centre of the Rebell Pay app or website of the Company rebellpay.com. These will be managed immediately, no later than within 2 business days from the time of receipt of the blocking request.
6. The Company may as well always be contacted by its correspondence address indicated in these Terms and Conditions or by email at support [at] rebellpay.com

15. Out-of-court dispute settlement

1. After the complaint procedure is completed, the consumer has the right to use out-of-court methods of dealing with complaints and pursuing claims. Consumer:
   1. is entitled to apply to the permanent amicable consumer court operating at the Trade Inspection with a request to settle a dispute arising from the concluded Agreement;
   2. is entitled to apply to the voivodship inspector of the Trade Inspection with a request to initiate mediation proceedings regarding the amicable settlement of the dispute between the Consumer and the Service Provider;
   3. may obtain free assistance in resolving the dispute between the Consumer and the Service Provider, also using the free assistance of the poviat (municipal) consumer ombudsman or social organization whose statutory tasks include consumer protection (including the Consumer Federation, Association of Polish Consumers). Advice is provided by the Consumer Foundation at the consumer helpline number 801 440 220 and 22 290 89 16 and by the Polish Consumers Association at the email address: porady@dlakonsumentow.pl.
2. The list of institutions dealing with out-of-court resolution of consumer disputes, together with a list of types of cases, is available on the website of the Office of Competition and Consumer Protection at https://www.uokik.gov.pl/rejestr_podmiot_uprawonych.php.
3. The consumer may use extrajudicial means of dealing with complaints and pursuing claims also using the ODR platform, in accordance with Regulation (EU) No. 524/2013 of the European Parliament and of the Council of 21 May 2013 on online dispute resolution for consumer disputes and amending the Regulation (EC) No. 2006/2004 and Directive 2009/22/EC (Regulation on ODR in consumer disputes). The ODR platform is intended to facilitate independent, impartial, transparent, effective, fast and fair out-of-court online resolution of disputes between consumers and entrepreneurs regarding contractual obligations arising from online sales contracts or contracts for the provision of services concluded between consumers residing in the European Union and entrepreneurs established in the European Union (https://webgate.ec.europa.eu/odr/main/index.cfm?event=main.home.show&lng=PL).
4. The use of available out-of-court means of dealing with complaints and pursuing claims is voluntary, which means that both parties must agree to it.

16. Marketing

1. The Company may contact the Users from time to time about the Rebell Pay app, including marketing messages relating to the Rebell Pay app. The Company will do this electronically, for example by email, SMS, in-app notifications or other messages on the Rebell Pay app or device or by telephone. All such communications will come from the Company. The Company will never pass Users’ information to a third party for them to use in their own direct marketing without the Users’ consent.
2. The User may notify the Company at any time if he/she does not wish to receive marketing messages from the Company by contacting the Company as set out in these Terms and Conditions or by following any instructions the Company may include in the message it sends to the User. Also, marketing notifications may be de-activated in the settings of the Rebell Pay app, and all in-app marketing notifications may be de-activated by the User in the settings of his/her mobile device.

17. Changes to the Terms and Conditions

1. These Terms and Conditions may be amended for important reasons, which are:
   1. the necessity to adapt Terms and Conditions to current regulations in order to maintain their compliance with the law,
   2. the need to adjust Terms and Conditions to the provisions, orders, decisions, rulings, recommendations of authorized public authorities,
   3. change in the functionality of Service or Partners requirements.
   4. change in the User's registration process,
   5. the need to clarify ambiguities and correct errors or typing mistakes,
   6. change of contact data and other identification data of the entities.
2. The Company can change these Terms and Conditions at any time by notifying the Users of a change when the User next opens the Rebell Pay app and/or by email. The new Terms and Conditions may be displayed on–screen and the User may be required to read and accept them to continue the use of the Rebell Pay app in other cases using Rebell Pay means accepting the new Terms and Conditions.
3. From time to time, updates to the Rebell Pay app may be issued via the Apple App Store or Google Play Store. Depending on the update, the User may not be able to use the Rebell Pay app until he/she has downloaded the latest version and accepted any new Terms and Conditions.

18. Language

1. Due to the worldwide availability of the Rebell Pay app, these Terms and Conditions are prepared in the English language, and the Rebell Pay app also operates in English, Polish, Russian and Ukrainian. By accepting these Terms and Conditions and using the Rebell Pay app, the User confirms that he/she understands the English language and agrees to communicate with the Company in the English and/or Polish language as far as the Rebell Pay app and legal relations arising under these Terms and Conditions are concerned.

19. Final Provisions

1. These Terms and Conditions are governed by the Polish law and the court competent to deal with disputes arising out of the performance of these Terms and Conditions shall be the court with jurisdiction of the seat of the Company.
2. These Terms and Conditions are available at all times for each User on Rebell Pay app and the Company’s website.

20. Terms of Card to Card transaction services

1. All actions related to card to card transactions or card management that are concluded in the application and required license to do so are fully covered by PSP.
2. In order to add card or transfer money the User accept Single Transaction Agreement that could be found here: https://www.rebellpay.com/wp-content/uploads/2023/07/TC-Fenige-single-transaction.pdf
3. By accepting the Terms and Conditions, the C2C Sender (Payer) requests that the complete execution of the Single Transaction Agreement, and thus the execution of the Transaction itself, take place before the expiration of the statutory deadline for withdrawal from this type of agreement, i.e., the deadline of 14 days from acceptance of the Single Transaction Agreement that is happening every time user want to initiate payment.
4. The User (Payer) agrees that PSP may disclose to the Partner information and data concerning his person, Transactions ordered by him on the Service and complaints submitted by him, i.e. information and data protected by professional secrecy as referred to in Article 11 of the Act (payment secrecy). The Partner processes these data as their controller in accordance with the applicable data protection regulations.

21. Terms of Account and Quicko Card

1. All actions that are concluded in the application in relation to Account or Quicko Card and require banking license are fully covered by Quicko.
2. In order to set up Account or issue Quicko Card the User accept Quicko Terms of Service - https://www.rebellpay.com/wp-content/uploads/2023/10/Quicko-Terms-of-Service.pdf as well as Framework agreement for opening and keeping a payment account, for payment card and access to payment services using the RebellPay, rebellpay.com - https://www.rebellpay.com/wp-content/uploads/2023/10/Quicko-Framework-agreement.pdf which are integral part of this Teams and Conditions
3. The User agrees that Quicko may disclose to the Partner information and data concerning his person, Transactions, Balance or Account details as well as complaints submitted by him, i.e. information and data protected by professional secrecy as referred to in Article 11 of the Act (payment secrecy). The Partner processes these data as their controller in accordance with the applicable data protection regulations

22. Terms of custodial wallet that allows to store, manage, and trade Digital Assets

1. All actions that are concluded in the application in relation to Digital Assets management refer to P100.
2. In order to open custodial wallet within Rebell Pay app to store, manage and trade Digital Assests (including converting fiat currency into Digital Asset or in the opposite direction, making a Digital Asset transfer to another recipient, which may be a Rebell Pay User or an external recipient, as well as all other Services concluded by P100), User is accepting that Rebell Pay app on his/her behalf is creating a dedicated User’s account in P100. To do so User’s data is shared with P100. That is why the following terms and conditions - https://www.p100.io/terms-and-conditions are integral part of this document as well as https://www.p100.io/privacy-policy with expectations that P100 will not be performing direct contact with the User.
3. The User agrees that P100 may disclose the information and data concerning his person, Transactions, Balance or Account details to allow by GDPR party.
4. By creating an order to do conversion between Fiat currency and Digital Assets, User automatically sends Rebell Pay and Partners a request to collect the Fiat currency on his/her EUR Account.
5. Delivery time for conversion between Digital Assets and fiat currency takes usually a few minutes, but on a rare occasion may take up to 3 business days. In case of the Digital Assets transfer, delivery time depends on the current network congestion.

23. P2P payments in the Rebell Pay app

1. Within the Service, a User may make currency sale with another User, provided that the P2P Sender and P2P Recipient have an account on the Rebell Pay app, have met the requirements and have been properly verified in accordance with the provisions of these Terms and Conditions (the "P2P Service").
2. The provisions of the Services shall apply mutatis mutandis to the P2P Service.
3. Prior to a User's access to the P2P Service, the Company may require additional verification of the User, including the User's identity, the source of the money or proof of residence.
4. The P2P Service may be provided only in the currencies and transaction amount limits specified by the Company for each User individually. The Company may, at its sole discretion, introduce different currencies and limits for different Users. The User may check the available currencies and the applicable minimum and maximum limits at any time in the Rebell Pay app. If the amount of the initiated transaction exceeds the applicable limit, a message will appear on the Rebell Pay app screen. The User may be offered additional identification to complete the transaction.
5. The P2P Service consists of an offer made by the P2P Sender to sell one currency in exchange for payment by the P2P Recipient in another currency, as specified by the P2P Sender, provided that the sale of the currency takes place through the Rebell Pay app and the payment for the acquisition of the currency takes place in a manner chosen by the P2P Sender, in particular through another app or bank.
6. When the P2P Sender wishes to make an P2P Service, the process is as follows:
   1. the P2P Sender logs into the Rebell Pay app;
   2. the P2P Sender selects the payment account available in Rebell Pay from which he wants to transfer funds to another user of the Rebell Pay app;
   3. the P2P Sender selects the P2P Service function on the Rebell Pay app;
   4. the P2P Sender creates an offer to sell currency, which include (i) the currency he/she wants to sell, (ii) the amount specified in that currency he/she wants to sell, (iii) the currency he/she wants to buy, (iv) own margin he/she wants to impose on the exchange rate, and (v) the method of payment of the selling price and, if applicable, (vi) notes on the method of payment (the "Offer"). The Offer is published by the Company on the Rebell Pay app. The Offer may be cancelled by the P2P Sender at any time before it is accepted by another user in accordance with these Regulations;
   5. the P2P Recipient has access to all available Offers that meet his search criteria. The P2P Recipient may select the Offer he wishes to execute by accepting it in its entirety or by selecting the amount range, if any, entered by the P2P Sender;
   6. after the P2P Recipient accepts a given Offer, Quicko verifies whether the P2P Sender has sufficient funds in the account in the Rebell Pay app to complete the Offer, if the verification is positive Quicko will debit funds from the P2P Sender's account consistent with the Offer to the technical account maintained by Quicko to secure the execution of the transaction (the "Deposit"), to which the P2P Sender agrees to by submitting the Offer;
   7. The P2P Recipient shall receive information on how to pay the price for the purchase of currency from the P2P Sender, in particular: the P2P Sender's information, the P2P Sender's bank account number or other data enabling payment, and payment notes (if entered by the P2P Sender);
   8. the P2P Recipient has 30 minutes to make the payment in accordance with point g) of this provision, once the payment is made, the P2P Recipient shall confirm the execution of the payment in the Rebell Pay app; If the P2P Recipient does not confirm the payment or report the transaction through the dedicated buttons in the app within 30 minutes, the transaction will be terminated and the Deposit will be returned to the P2P Sender, therefore case the Offer may be executed by another user;
   9. the P2P Recipient confirms the sending of the payment while the P2P Sender confirms the receipt of the payment from the P2P Recipient in the Rebell Pay app;
   10. Quicko transfers the Deposit amount to the P2P Receiver;
   11. the P2P Sender and P2P Recipient, after the transaction is completed, can rate each other by selecting from 1 (one) to 5 (five) stars, based on the progress of the transaction. A User's average rating is visible to other Users.
7. The exchange rates specified in each Offer are provided by a third-party provider (https://openexchangerates.org/). The exchange rates are updated on a regular basis. The Company is not responsible for any irregularities appearing on the exchange rates, however, if within 1h the exchange rate changes in value by more than 2%, the P2P Sender has the right to cancel the transactions (stop payment of the Deposit), but only after returning the funds to the P2P Recipient (if there was a transfer).
8. The Company has the right to cancel any Offer if the P2P Sender does not have sufficient funds in the account to cover the Deposit. 
9. Quicko will collect a fee from the Deposit and transfer it to the Company's account if the transaction as a result of the P2P Service is executed, the User will be informed of the exchange rates before the transaction is accepted.
10. The Deposit will be:
    1. returned to the P2P Sender if, within 30 minutes, the P2P Recipient does not confirm payment of the price to the P2P Sender and the P2P Sender does not confirm receipt of the price from the P2P Recipient (combined);
    2. transferred to the P2P Recipient if the P2P Sender confirms receipt of payment from the P2P Recipient;
    3. retained for factual clarification if the P2P Recipient confirms payment of the price to the P2P Sender and the P2P Sender does not confirm receipt of the price.
11. In the case referred to in paragraph 10(c) of this section, the Company may, at its discretion, call upon the P2P Recipient to provide the Company with confirmation of payment, in particular by providing a transfer confirmation or an account statement for the relevant period, and/or call upon the P2P Sender to provide the Company with confirmation of non-receipt of payment, in particular by providing an account statement for the relevant period.
    1. If both the P2P Recipient provides the Company with a credible confirmation of payment and the P2P Sender provides the Company with a credible confirmation of non-receipt of payment, the Company may require the P2P Sender and/or the P2P Recipient (i) to file an appropriate complaint with the payment provider and/or (ii) to grant the Company a power of attorney, the contents of which are attached hereto, to contact the institution through which the payment was made in order to clarify the circumstances of the transaction;
    2. If the P2P Sender or P2P Recipient fails to respond to at least 2 requests from the Company by serving a power of attorney or relevant evidence (as requested by the Company), including the filing of a complaint, the Company may resolve the matter in favour of the other party, provided that at least 14 days have passed since the date of the first request. Communication between the parties will be made by sending a message from the Company to the P2P Sender's and/or P2P Recipient's email address provided during account registration in the Rebell Pay app.
12. The P2P Recipient absolutely undertakes to make payment for the Offer from an account or other means of payment that he owns, without exceptions it is prohibited to make payments from accounts or means of payment other than those belonging to the P2P Recipient. In the case referred to in point 11 of this section, the Company will not accept a payment confirmation received from the P2P Recipient in which the sender of the payment will be a person other than the P2P Recipient.
13. In the event that the P2P Sender receives funds for the performance of the Offer from a person other than the P2P Recipient or becomes doubtful about the sender of the funds, the P2P Sender shall immediately notify the Company of such a situation, thereby providing evidence of the above ("Notification").
14. Upon receipt of the Notification, the Company shall initiate investigation activities, point 11 of this paragraph shall apply accordingly. The Company may require the P2P Sender to immediately return the funds to their sender thereby returning the amount of the Deposit to the P2P Sender, without charging the fees referred to in point 9 of this paragraph.
15. The P2P Sender or the P2P Recipient, as the case may be, shall bear all costs that may arise as a result of the activities referred to in points 11-14 of this paragraph.

Appendix to the Terms and Conditions of use of Rebell Pay mobile application

Commissions related to Service are always presented live in the Rebell Pay app via calculator or any other associated screen before transaction is confirmed. This is due to constant commissions changes.

Table related to Card to Card transfers 

Commissions related to Account and Quicko Card

 Commissions related to Digital Assets and custodial wallet

Rebell Pay Website - Terms of Use

1. General Provisions

1. The subject of these Terms of Use is to define the terms and conditions of using the Website.
2. The entity that is the owner and administrator of the Website is the Company.
3. The condition for using the Website by the User is to read the content of these Terms of Use. The Terms of Use are made available free of charge in a visible place on the Website.

2. Definitions

The terms used in these Terms of Use have the following meaning:

1. Company – Elixir Group sp. z o.o., a Polish company having its registered office and postal address at ul. Burakowska 16B lok. U1, 01-066 Warsaw, Poland, KRS (National Court Register) No. 0000168006, REGON 473178243, NIP 9471899016;
2. Privacy Policy - the Website's privacy policy, publicly available on the Website;
3. Terms of Use – these Terms of Use
4. GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Regulation on data protection;
5. Website – website at rebellpay.com;
6. User - a natural person, legal person or organizational unit without legal personality using the Website.

3. General Provisions and Technical Conditions

1. The owner of the Website is the Company:
   1. correspondence address: Elixir Group Sp. z o. o. with its registered office in Warsaw at Burakowska 16B lok. U1, 01-066 Warsaw;
   2. data for current contact with the Company:
      e-mail address: support@rebellpay.com;
2. In order to properly use the functionality of the Website, it is necessary to meet the following conditions:
   1. Internet connection,
   2. possession of devices allowing the use of Internet resources,
   3. using a web browser that allows displaying hypertext documents on the device screen, linked on the Internet via a web service, supporting the JavaScript programming language and accepting cookies.
3. The website is generally available to all Users, in a way that allows opening in a web browser and free browsing of the content, subject to the provisions contained in this paragraph.
4. The Company uses the Website to inform about the services provided.
5. The User is authorized to use the Website only for his own personal use, for non-commercial purposes.
6. The User is obliged to use the Website in accordance with the provisions of the Terms of Use and generally applicable laws.
7. As part of the Website, it is forbidden for Users to use viruses, bots, worms or other computer codes, files or programs, in particular those that automate the processes of scripts and applications or other codes, files or tools.

4. Provision of Services by Electronic Means

1. Acceptance of the Terms of Use and the Privacy Policy is tantamount to concluding an agreement with the Company for the provision of electronic services in the scope of using the Website in a manner consistent with the Terms of Use.
2. The Company is a service provider of services provided electronically within the meaning of the Act of 18 July 2002 on the provision of electronic services.
3. The Terms of Use are also the regulations for the provision of electronic services within the meaning of art. 8 of the indicated act.
4. Through the Website, the Company provides the Users with the service of making the content of the Website available free of charge at the request of the User.
5. The contract for the provision of services referred to in par. 4 of this paragraph, is concluded between the Company and the User at the moment the Company begins to provide the service made available on the Website, i.e. at the moment of entering the Website and terminates when the User leaves the Website.
6. The Company provides the Website in Polish, English, Russian and Ukrainian.

5. Intellectual Property Rights

1. All content, graphics or other types of materials on the Website are subject to copyright or other intellectual property rights belonging to the Company or used by the Company under separate agreements.
2. The User may not use the content, graphics or other types of materials on the Website (in whole or in part) for commercial purposes without the prior consent of the Company, in particular the User may not print, copy, modify, download to a hard drive or other media data, as well as include in the content of other studies (e.g. paper documents, press publications, websites, blogs and social media) content, graphics or other types of materials on the Website (in whole or in part). 
3. The User may use the content, graphics or other types of materials on the Website (in whole or in part) without the prior consent of the Company for non-commercial purposes, in particular for educational, informational or other purposes permitted under applicable law.
4. The User is prohibited from providing, via or using the Website, illegal content, violating the principles of social coexistence or decency, including in particular content that is offensive, inciting hatred, vulgar, untrue, potentially misleading, containing viruses or malware or violating the rights of third parties, decency or untrue information detrimental to the good name of the Company.

6. Modernization Works

1. The Company is entitled to temporarily suspend the operation of the Website in the event of a failure, error, defect, as well as carry out modernization or repair works necessary to improve or restore the functionality of the Website, for a period not longer than necessary to improve or restore the functionality of the Website.
2. The Company is not obliged to inform Users in advance about the planned modernization works of the Website and the resulting temporary blocking of access to the Website.

7. User Responsibilities

1. The User is obliged to use the Website in accordance with the provisions of the Terms of Use and generally applicable laws.
2. The User is obliged to carefully read the Terms of Use before using the Website.
3. It is unacceptable for the User to take actions that may, in particular, hinder or destabilize the operation of the Website or expose the Company to the loss of its reputation or good name.
4. It is unacceptable for the User to take actions that could violate the privacy of other Users, e.g. by collecting, processing and disseminating information about other Users without their express consent.

8. Responsibility Policy

1. The Company is not liable for damages resulting from the Users' use of the Website in a manner inconsistent with the provisions of the Terms of Use or generally applicable laws.
2. The Company is not responsible for the actions of third parties operating the IT system of the Website, as well as for damages resulting from damage to the User's computer equipment or its data resources, during or in connection with the use of the Website, caused in particular as a result of computer viruses entering the User's IT system.
3. The limitations of liability referred to in these Terms of Use do not apply to Users who are Consumers to the extent provided for by the mandatory provisions of law.

9. Threats

You, like any other person using the Internet, are subject to risks in connection with the use of the Internet. The basic threat for every Internet User is the possibility of "infecting" the ICT system by software created mainly for the purpose of causing damage, such as viruses, "worms" or "Trojan horses". In order to avoid the risks associated with this, including those that appear when opening electronic messages, it is recommended that the User provide his computer (or other device) that he uses when connecting to the Internet to use the Website with an antivirus program and a firewall and constantly update it.

10. Personal Data Protection

The Company processes the User's personal data in accordance with the GDPR on the terms described in the Privacy Policy, which has been made available to Users by the Company on the Website in a way that allows it to be recorded and saved on a computer hard drive or other data carrier.

11. Final Provisions

1. The Company reserves the right to change the Terms of Use in justified cases.
2. The Terms of Use act as general terms and conditions of contracts within the meaning of the provisions of the Civil Code.
3. The Terms of Use have been published and made available in a form that allows its recording and saving on a computer hard drive or other data carrier.
4. Lack of acceptance of the new or amended Terms of Use by the User is tantamount to resignation from using the functionality of the Website.
5. An integral part of the Terms of Use is the Privacy Policy.
6. The Terms of Use come into force on the day of its publication.