Credit Terms
Terms of Use


VOLOPAY Revolving Credit Facility – Corporate Cards


IMPORTANT NOTE


  1. Please read and understand the terms of use, before availing of the services. In case You have any doubt, please check our volopay.co or contact us through [email protected]

  2. Upon your request for the service, we presume that You have agreed to the terms, unconditionally.

  3. These are the additional specific terms for the services of Revolving Credit facility. Besides these terms, the general terms of use ("Terms") are applicable to Users.

  4. The words and phrases used in this Agreement shall have the meaning generally understood and universally accepted in the financial and information technology industries.

  5. The Terms of Use may be amended by Volopay from time to time and the User can view the updated terms in the website.


  1. Definitions:

    1. "Authorized Purposes" As per Article 3.4 hereto.


  1. "Credit Limit" the maximum amount of credit extends to the User. Credit Limit is being determined based on the information given by the User, from time to time.


  1. "Debt" any amount of money due and payable by the User to VoloPay related to the services.


  1. "Excluded MoneyLender": VoloPay is an excluded moneylender under the Moneylenders Act (Cap. 188)


  1. "Facility Charges": the fee and charges collected by VoloPay towards the services. The Facility charges are not refundable.


  1. "Partners": VoloPay may offer services like corporate card issuance, digital wallet (e-money) along with its partners including NIUM, Wallex etc. This services and partner may change from time to time and would be mentioned in the general terms ("Terms").


  1. "Partner's Terms": the terms of use prescribed by the Partners which are binding upon the User. NIUM & Wallex.


  1. "Revolving Credit Facility: RCF": RCF allows the User to make purchases up to the Credit Limit and the User shall pay down the debt each month along with stipulated Facility Charges. The User can spend through the facility until the spending cap is exhausted. The User does not have to pay off the total amount borrowed every month, but any balance that carries over month to month is the revolving balance.


  1. "Services" the revolving credit services provided by VoloPay to the Users;



  1. "User" means the corporate entities in the form of pvt limited companies (Pte Ltd), limited liability companies (LLC), limited liability partnership (LLP) etc. in whose name VoloPay opens the credit account. VoloPay reserves its right to accept or reject any entity at its discretion. User is liable for the Debt on the credit account. The term "User" used in this Terms of Use does not include a guarantor.


  1. "User's Plan" the plan agreed between VoloPay and the User.


  1. "VoloPay Corporate Card" are the Physical/ Virtual card issued by its Partners from time to time as a part of the "Services" defined in general terms of use ("Terms")


  1. The VoloPay Corporate Card:


  1. The VoloPay Corporate Card issued to the User is the property of the Partner and/or VoloPay.

  2. VoloPay merely grants a 'right to use' license to the User for using the card.

  3. The right of issuance of the card remains with its Partners and VoloPay is acting as a program manager.

  4. The VoloPay Corporate Card shall be withdrawn from the use any time, without an intimation to the User, in case the VoloPay is of the considered view that the VoloPay Corporate Card is being used for unauthorized purposes and the User fails to comply with the Terms of Use.

  5. Under the VoloPay Corporate Card, the VoloPay is offering RCF to Users as per the agreed terms & conditions as an Excluded Moneylender.


  1. Use of VoloPay Corporate Card:


  1. As long the VoloPay Corporate Card is in the possession of the User, it is the duty of User to keep it safe and it has not been used for any unauthorised purposes.

  2. If the VoloPay Corporate Card is being lost or stolen, the User shall take immediate steps to inform VoloPay or the Partner and shall comply with the Partner's Terms.

  3. The usage of VoloPay Corporate Card shall be governed by the applicable laws of Singapore. Any change in Applicable Laws may affect the usage at any point of time. VoloPay may intimate the User about such changes.

  4. The VoloPay Corporate Card can be used for any day-to-day corporate expenses including the following purposes (but not exhaustive & limited):


  1. Travel expenses

  2. Salary disbursement

  3. Digital marketing expense

  4. Vendor payments

  5. Office Subscription

  6. Any other purpose(s) which is included by VoloPay at a later time.

  1. Any use or attempt to use of the VoloPay Corporate Card for any other purposes shall be a material breach and the service shall be withdrawn, forthwith.

  2. The VoloPay Corporate Card shall be issued to the Users and not directly to the employees or the representatives of Users. The Terms of Use shall be binding upon the User on behalf of its employees or representatives and the User shall not be absolved from any of the responsibilities even the VoloPay Corporate Card is not being used, directly.

  3. VoloPay shall not enter into any separate contract with the beneficiaries of the User.

  4. VoloPay expects the User should monitor, supervise and control the use of VoloPay Corporate Card and shall ensure that the VoloPay Corporate Card has been used only for the Authorized Purposes.

  5. The User agrees that the PIN and Password attached to VoloPay Corporate Card are confidential and secure. Hence, the User shall keep the PIN and Password separate from the VoloPay Corporate Card (including the account number the Card) at all times.

  6. None has been permitted to know or use the PIN or Password other than the User. User must not voluntarily disclose the PIN or Password to any person.



  1. Partners Terms:



  1. VoloPay has associated with the Partners to provide Corporate Card as its Services (defined under general terms of use) as per the mutually agreed terms.

  2. User should read and understand the Partner Terms [NIUM & Wallex] and comply with the same. Please note that the Partner Terms shall primarily regulate the VoloPay Corporate Card usage. User shall accept the Partner Terms unconditionally. The Partner shall, at its discretion, amend the plan and terms of the User without any intimation to the User.


  1. Credit Limit


  1. VoloPay will set a Credit Limit for User's credit account.

  2. The credit limit shall be covered under the statements of the User's Account.

  3. VoloPay can reduce the Credit Limit or allow the User to exceed the Credit Limit, without prior notice.

  4. VoloPay may refuse to honour any use of the credit account which would cause User to exceed the Credit Limit, though VoloPay is not obligated to do so.

  5. VoloPay can, without a prior notice, reduce the Credit Limit, including to zero, for any reason, even if the User is not in default.


  1. Debt:


  1. User understands that the amount of money due and payable towards the use of the VoloPay Services as permitted by VoloPay is a Debt.


  1. VoloPay will add interest, charges or other fees (including annual fees) as agreed mutually to the Debt.


  1. User agrees to repay the Debt owed to VoloPay within the agreed time frames.


  1. Default

    1. VoloPay may add the legal cost and related expenses incurred to it for the Debt recovery action from the User as and when the User defaults the payment. The User agrees that it will compensate VoloPay against such expenses. Such expenses, cost, interest and any amount payable by the User shall be collected prior to the collection of the principal amount.

    2. The User understands that if the User defaults the payments, VoloPay may require the third party services to enforce the terms of contracts agreed between VoloPay and the User.

    3. Without notice or demand, VoloPay may terminate the services and withhold the use of VoloPay Corporate Card and in such an event, the User must pay the total Debt forthwith, if the User does not carry out its obligations under the contract which includes but not limited to the following events:

a) the User fails to make the payments when it is due;

b) the breach of terms agreed mutually.

d) User become insolvent or bankrupt;

e) any other event that VoloPay believes that it endangers the Users ability to pay;


  1. VoloPay Decisions:



  1. All decisions, determination and/or calculation made by VoloPay including but not limited to the selection of the Users, the Credit Limits approvals, withdrawal of the facility are in good faith and shall be final, conclusive and binding upon the User.

  2. VoloPay shall not be liable for any loss of money or any violations of the Applicable Laws while using the VoloPay Corporate Card. No claim, whatsoever in nature can be made against VoloPay if the VoloPay Corporate Card is being used for any unauthorised or unlawful purposes.

  3. The User shall submit the necessary documents related to 'Know Your Customer' (KYC) formalities.

  4. User understands that VoloPay shall not be liable to scrutinise such documents on behalf of the representatives of the User.

  5. Upon submission, the User represents to VoloPay that the documents are genuine and the information provided therein are true and correct.

  6. The User shall be responsible if such documents and information are found to be bogus or incorrect by VoloPay or any relevant agencies.

  7. The User should indemnify VoloPay against all losses and damages, if the VoloPay Corporate Card has been obtained by the User by submitting fake documents.

  8. User shall not assign its right to use of the VoloPay Corporate Card to any person without express prior consent of VoloPay.

  9. VoloPay shall not be responsible if the VoloPay Corporate Card is not accepted by a merchant or a business.














16. Notices.

16.1 All notices and documents required to be given by us to you shall be sent by any one of following methods:

A. Ordinary or registered post to your last known address according to our record;

B. Electronic mail to your last known electronic mail address according to our record;

C. Posting notice or communication on the wallet website;

D. Notices placed with or in any of the wallet written communications to you;

E. Phone call to your last known phone number according to our records;

F. Notices placed through any media; or

G. Any manner of notification as we may at our absolute discretion determine.



16.2 Unless otherwise expressly provided in writing, our notices and communications to you are effective:

A. If sent by post to an address within your country, the following business day after posting;

B. If sent by post to an address outside of your country, 5 business days after posting;

C. If sent by fax, electronic mail or SMS, at the time of transmission;

D. If sent by hand, at the time of delivery or when left at the address;

E. If posted on our website, on the date of display or posting;

F. If advertised in the newspaper, on the date of advertisement; and

G. If broadcast via radio or television, on the date of broadcast.



17. Promotional offers, advertisements, and surveys.





You hereby consent that your Personal data will be collected, used and disclosed by us in accordance with the Personal Data Protection Act 2012, for the provision of all services. We may also send you marketing mailers by post or emails or via SMS text, telephone or fax. You hereby consent that we may disclose your Personal data to our business partners and third-party service providers for these purposes. Where there are joint account holders, you confirm that they have consented to our collection, use and disclosure of their Personal data. In this context, you agree that:

17.1 We may inform you about promotional offers through mail, email, fax, SMS, telephone, or any other means of communication. You agree that we and our affiliates, and third parties selected by any of them can offer specially selected products and services to you through any means of communication provided above. For this purpose, you agree that we may transfer and disclose customer information to our affiliates and third parties selected by any of them.

17.2 Third parties' services and links to other websites. You may be offered services, products and promotions provided by third parties and not by us. If you decide to use these services, you shall be responsible for reviewing and understanding the terms and conditions associated with these services. You agree that we are not responsible for the performance of these services.

17.3 Our website may contain links to third parties' websites as a convenience to you. The inclusion of any website link does not imply an approval, endorsement, or recommendation by us. You agree that you access any such website at your own risk, and that the site is not governed by the terms and conditions contained in this terms and conditions. We expressly disclaim any liability for these websites.

17.4 If you wish to be excluded from the recipient lists for our promotional offers, advertisements or surveys, or find any incorrect entry in the information held by us or in the information provided by us to third service providers, you have to immediately notify us by calling our customer service by dialing +65 68800668.



18. Consent to broadcast and sending of push messages.

You agree and consent to the sending by us and our affiliates of broadcast and push messages as well as notices and announcements to you via SMS/email blast. However, should you opt not to receive these messages, you may make a request to that effect by following the optout instructions regularly sent by us to you.



19. Compliance.

You shall comply with all laws and regulations related to the use of stored value facilities and the current anti-money laundering/counterterrorism financing legislation of your residence country.

You shall comply with all laws and regulations related to the use of services and the current anti-money laundering/ counterterrorism financing legislation required. For further information on anti-money laundering/counter terrorism financing legislation: https://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions



20. Limitation of liability.

A. The services are provided on an "as is" and "as available" basis. We do not warrant (i) the accuracy, adequacy or completeness of the services, and expressly disclaim any liability for errors, delays or omissions in the Website, or for any action taken in reliance on the Website; (ii) that the services will be provided uninterrupted or free from errors, or that any identified defect will be corrected, nor that the services and the Website are free from any computer virus or other malicious, destructive or corrupting code, agent, program or macros. No warranty of any kind, implied, express or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, satisfactory quality or fitness for a particular purpose, is given in conjunction with the services. In particular, you should be aware that where services are initiated or accessed via SMS, your mobile network operator's confirmation that any SMS you sent has been sent to us or our service provider does not guarantee that we have executed, or even received, the electronic instructions contained within such SMS.

B. We may, from time to time and without giving any reason or prior notice, upgrade, modify, suspend or discontinue the provision of or remove, whether in whole or in part, the services or any information, functionalities, services or products provided therein, and shall not be liable if any such upgrade, modification, suspension or removal prevents you from accessing the services or associated information, functionalities, services or products.

C. Risks and expenses relating to the use of the internet and other telecommunication systems: we do not warrant the security of any information transmitted by you or to you through the services and you accept the risk that any information transmitted or received through the services may be accessed by unauthorised third parties. Transactions over the internet as well as messages sent via SMS may be subject to interruption, transmission blackout, delayed transmission due to internet traffic or incorrect data transmission due to the public nature of the internet and the SMS system. You shall be responsible for obtaining and using the necessary services, software and/or device, hardware and/or equipment necessary to obtain access to the services at your own risk and expense (including all costs levied by your mobile network operator).

D. Exclusion of liability: we shall in no event be liable to you or any other person for any loss, damages or expenses whatsoever or howsoever caused and regardless of the form of action (including tort or strict liability) arising directly or indirectly in connection with any access, use or inability to use the services, or reliance on any materials, even if we or our agents or employees may have been advised of, or otherwise might have anticipated, the possibility of the same. We shall not at any time be liable for indirect or consequential losses, damages or expenses, even if foreseeable, within our contemplation or if we may have been advised of, or otherwise might have anticipated, the possibility of the same.

E. Information available through the services: information displayed at the services or sent to you in connection with the services, may be from a variety of sources. All data and/or information contained in the services or sent to you in connection with the services is provided for informational purposes only. We make no representations as to the accuracy, timeliness, adequacy or commercial value of all such information and/or data. You should not act on data or information obtained through the services or sent to you in connection with the services, without first independently verifying its contents.

F. Refund. We will refund to you any benefit which we receive as a result of any breach of our agreement with you (this means that, for example, where a money transfer has failed, in such circumstances we will refund to you the transaction amount and the service fee). We do not, in any event, accept responsibility for: (i) any failure to perform your instructions as a result of circumstances which could reasonably be considered to be outside our control; (ii) malfunctions in communications facilities which cannot reasonably be considered to be under our control and that may affect the accuracy or timeliness of messages you send to us; (iii) any losses or delays in transmission of messages arising out of the use of any internet service provider or caused by any browser or other software which is not under our control; and (iv) errors on the website or with the service caused by incomplete or incorrect information provided to us by you or a third party.

G. In no event shall we be liable for damages whether caused by negligence on the part of our employees, suppliers or agents or otherwise, beyond the sum of SGD 500. In no event shall we or our agents be liable for any indirect, special, incidental, consequential, exemplary or punitive damages, or the like.



21. Non-waiver of rights.

No failure or delay on the part of us in exercising any right or power given here shall operate as a waiver of that right or power, and nor shall any partial or single exercise of any such rights or powers preclude any of the other rights or powers provided here. Moreover, no waiver by us or any of its rights or powers under this wallet agreement shall be deemed to have been made unless expressed in writing and signed by its duly authorized representative.



22. Other means of communication.

You undertake to notify us of any additional means of communicating with you aside from those disclosed in your wallet application. Pursuant to such undertaking, you authorize us at its discretion but without any obligation to do so, to secure information from third parties such as but not limited to utility companies, insurers, and financial intermediaries, and to receive information on how and where you can be contacted.



23. Assignment of waiver.

You agree that we, without notice to you, may assign, discount, or otherwise transfer part of all of its rights or obligations here or under any wallet transaction. In the event of such assignment, you irrevocably agree not to assert against the assignee setoff rights of any obligation that may be owed by us to you. You may not assign your rights and obligations under these terms and conditions without our prior consent.



24. Your complaints.

Any complaint regarding your wallet and related services or their use, or both, shall be communicated to the wallet hotline or contact us or other means in accordance with these terms and conditions. If we deem necessary, we will conduct an investigation of the complaint for its prompt resolution and communicate its findings to you. You agree to fully cooperate with any such investigation by providing the necessary or required data, information, and documents. You must resolve any complaint against any merchant or other party directly with them. You cannot setoff against us any claim you have against them. If there is a dispute with any merchant in respect of a payment, a refund for the transaction will be made to you only after the merchant has refunded the payment to us.



25. No deposit insurance coverage.

Funds stored on the MatchMove Mobile Wallet and stored value Card provided in conjunction with the Mobile Wallet are not insured deposits under the Deposit Insurance and Policy Owners' Protection Schemes Act (Chapter 77B of the Singapore Statutes) and are ineligible for protection by the Deposit Insurance Scheme.



26. Disclosure.

We shall keep all your files and records in strictest confidence in accordance with the provisions of your residence country's legislation and its privacy policy.



27. Severability clause.

If any provision of the terms and conditions is found by an arbitrator or court of competent jurisdiction to be invalid, the parties nevertheless agree that the arbitrator or court should endeavour to give appropriately valid effect to the intention of the terms and conditions as reflected in the provision, and the other provisions of the terms and conditions shall remain in full force and effect.



28. Dispute resolution.

MatchMove and you shall attempt to resolve any controversy or claim arising out of or relating to the creation, performance, termination and/or breach of these terms and conditions in the first instance through good faith negotiation or mediation between the parties. Any claims or disputes arising from or related to these terms and conditions shall be resolved through binding arbitration via the Singapore international arbitration center located in Singapore and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. Notwithstanding the foregoing, and solely with respect to breaches or threatened breaches of these terms and conditions, either party to these terms and conditions may seek a temporary restraining order and injunction to protect its legal rights or interests, without the need to post bond in any court having jurisdiction.



29. Miscellaneous article

29.1 Governing laws. This terms and conditions and any and all amendments thereto shall be governed by and construed in accordance with the substantive laws of Singapore, without reference to its conflicts of law provisions.

29.2 Act in good faith. We may act in any instruction we believe in good faith has been given by you according to the operating mandate.

29.3 Dispute resolution. Any dispute arising from or relating to MatchMove services shall be resolved by final and binding arbitration. The arbitrator shall also decide what is subject to arbitration. The arbitration will be administered by Singapore International Arbitration Centre under ("SIAC") in accordance with the arbitration rules of the SIAC ("SIAC rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause.

29.4 indemnity. You agree to indemnify us and all our servants, employees, nominees, directors and agents for any loss and embarrassment suffered by us (other than such loss and embarrassment arising from us or our employees' and agents' willful misconduct or negligence) in connection with:

A. Any wallet account, related services or transaction;

B. Acting on or carrying out or delaying or refusing to act on any instruction you give us;

C. Searches and enquiries we make in connection with you, or a security provider;

D. The provision of any service to you and the performance of our functions;

E. Any service provided by any third party;

F. Any default or the preservation or enforcement of our rights under the terms of these terms and conditions or any other applicable terms and conditions in connection with any wallet or related services or as a result of your noncompliance with any of these terms;

G. Any action by us or any party against you relating to any wallet, wallet account or services;

H. Any involvement by us in any proceeding of whatever nature for the protection of or in connection with the wallet, wallet account or services;

I. Our compliance with any existing or future law or regulation or official directive in respect of any of these terms;

J. Taxes payable by us in connection with your wallet account; and

K. Any increased cost in our funding if there is a change in law or circumstances.

29.5 Waiver. Any failure or delay by us in exercising or enforcing any right we have under the terms of these terms and conditions does not operate as a waiver of and does not prejudice or affect our right subsequently to act strictly in accordance with our rights.

29.6 Illegality. We may close and revoke any wallet account or related services with or without notice to you if, because of any change to any applicable law, regulation, regulatory requirement or judicial decision, or in our opinion, maintaining or performing any obligation under the terms in these terms and conditions becomes illegal, or we are otherwise prohibited from doing so. If this happens, you must pay us all liabilities on demand.

29.7 General construction and interpretation. In our opinion: when we determine a matter in our opinion, the determination is made at our absolute discretion. When we act or refuse to act: on any matter including any instruction or transaction, we do not need to provide any reason for our act or refusal unless required by the law. Timing: if we receive any instruction on a nonbusiness day or after the specified clearance or cutoff times, we may treat the instruction as received on the following business day.

29.8 Amendments. We reserve the right to amend these terms and conditions at any time and for whatever reason it may deem proper, and any such amendment shall be binding upon notice to you by publication or other means of communication, electronic or otherwise. This is unless you object to those amendments by manifesting the intention to terminate your membership in writing within five (5) days from notice of the amendment. Your failure to notify us about this intention to terminate your membership as provided, and your continued use of your wallet and related services, or both, shall be taken as your conclusive acceptance of the amendments.

29.9 Any external links to third-party websites on the website are provided as a convenience to you. These sites are not controlled by us in any way and we are not responsible for the accuracy, completeness, legality or any other aspect of these other sites including any content provided on them. You access such websites at your own risk.

29.10 Subcontracting and delegation: we reserve the right to use any service providers, subcontractors and/or agents on such terms as we think appropriate.

29.11 Force majeure: we shall not be liable for any nonperformance, error, interruption or delay in the performance of its obligations or in the services' operation, or for any inaccuracy, unreliability or unsuitability of the materials or any of the services' contents if this is due, in whole or in part, directly or indirectly to an event or failure which is beyond its reasonable control (which includes without limitation acts of god, natural disasters, acts of any government or authority, power failures, and the acts or a party for whom we is not responsible for).

29.12 We take security very seriously at MatchMove, and we work hard, using state-of-the-art security measures, to make sure that your information remains secure. The MatchMove service is a safe and convenient way to send money to friends and family and to other people that you trust. However, we do advise you to consider very carefully before sending money to anyone that you do not know well. In particular, you should be very cautious of deals or offers that seem too good to be true they may be scams. If you are aware of anyone or any entity that is using the service inappropriately, please email us using our contact form. Similarly, if you receive any emails, purporting to be from us, which you suspect may be "phishing" (fake) emails, please forward them to us using our contact form.

29.13 Contact information

Any questions, notices, and requests for refunds or further information should be directed to us by contacting our customer service at +65 3129 2319




ADDITIONAL TERMS FOR USER PROTECTION PURSUANT TO E-PAYMENTS USER PROTECTION GUIDELINES ISSUED BY MONETARY AUTHORITY OF SINGAPORE



30. Account Holder to provide contact information and monitor notifications

30.1 The Account Holder of a Protected Account shall be required to provide us with contact details as required by us in order to send the Account Holder transaction notifications. Where the Protected Account is a joint account, the Account Holders should jointly give instructions to us on whether we should send transaction notifications to any or all the Account Holders. The duties of the Account Holders in this Section will apply to all the Account Holders that the responsible FI has been instructed to send transaction notifications to.



30.2 The Account Holder shall be required at a minimum to provide the following contact information which must be complete and accurate, to us:

(a) where the Account Holder has opted to receive transaction notifications by SMS, his Singapore mobile phone number; or

(b) where the Account Holder has opted to receive notification by email, his email address.



30.3 It is the Account Holder's responsibility to enable transaction notification alerts on any device used to receive transaction notifications from us and to monitor the transaction notifications sent to the contact address. We may assume that the Account Holder will monitor such transaction notifications without further reminders or repeat notifications.



31. Transaction Notifications

31.1 We will provide Transaction Notifications that fulfil the following criteria to you that we have been instructed to send, in respect of all transactions (of any amount) made to or from your account ("Notifiable Transaction").

(a) the Transaction Notification will be sent to your contact address. If you have provided more than one contact address to us, the Transaction Notification will be sent to every contact address selected by you to receive such notifications.

(b) the Transaction Notification will be sent on a real time basis for each transaction or on a batched basis at least once every 24 hours to consolidate every notifiable transaction made in the past 24 hours. We may but are not obligated to send both real time notifications and daily batched notifications to you.

(c) the Transaction Notification will be conveyed to the Account Holder by way of SMS or email. An in-app notification will be accompanied by an SMS or email notification that meets the deadline in sub-paragraph (b) above.

(d) the Transaction Notification will contain the following information, but we may omit any confidential information provided that the information provided to you still allows you to identify the transaction as being an authorized transaction or Unauthorized Transaction: (i) information that allows you to identify the Protected Account such as the Protected Account number; (ii) information that allows you to identify the recipient whether by name or by other credentials such as the recipient's account number; (iii) information that allows us to later identify you, the Protected Account, and the recipient account such as each account number or name; (iv) transaction amount; (v) transaction time and date; (vi) transaction type; (vii) if the transaction is for goods and services provided by a business, the trading name of the merchant and where possible, the merchant's reference number for the transaction.





32. Account user to protect access codes and access to protected account

32.1 You should not do any of the following:

A voluntarily disclose any Access Code to any third party;

B disclose the Access Code in a recognizable way on any Wallet, Authentication Device, or any container for the Wallet; or

C keep a record of any Access Code in a way that allows any third party to easily misuse the Access Code.

32.2 If you keep a record of any Access Code, you should make reasonable efforts to secure the record, including:

A keeping the record in a secure electronic or physical location accessible or known only to the Account User; and

B keeping the record in a place where the record is unlikely to be found by a third party.

32.3 You shall at the minimum do the following where a device is used to access the Protected Account:

A update the device's browser to the latest version available;

B patch the device's operating systems with regular security updates provided by the operating system provider;

C install and maintain the latest anti-virus software on the device, where applicable; and

D use strong passwords, such as a mixture of letters, numbers and symbols.

32.4 You should inform all other Account Users, if any, of the security instructions or advice provided by us. An Account User should follow security instructions or advice provided by us to you.





33. Report and provide information of Unauthorized Transactions

33.1 You should report any Unauthorized Transactions to us as soon as practicable after receipt of any Transaction Notification alert for any Unauthorized Transaction.

33.2 Where you are not able to report the Unauthorized Transaction to us as soon as you receive any Transaction Notification alert for any Unauthorized Transaction, you should if we so request, provide us with reasons for the delayed report. This includes the time periods or circumstances where it would not be reasonable to expect us to monitor Transaction Notifications. The report should be made in any of the following ways:

A by reporting the Unauthorized Transaction in the communications channel as set out in this agreement; or

B by reporting the Unauthorized Transaction to us in any other way and where we acknowledge receipt of such a report.

33.3 You should within a reasonable time provide us with any of the following information as requested by us:

A the Protected Account affected;

B your identification information;

C the type of Authentication Device, Access Code and device used to perform the payment transaction;

D the name or identity of any Account User for the account;

E whether an account, Authentication Device, or Access Code was lost, stolen or misused and if so: (i) the date and time of the loss or misuse, (ii) the date and time that the loss or misuse, was reported to us, and (iii) the date, time and method that the loss or misuse, was reported to the police;

F where any Access Code is applicable to the account, (i) how you or any Account User recorded the Access Code, and (ii) whether you or any Account User had disclosed the Access Code to anyone; and (iii) G any other information about the Unauthorized Transaction that is known to you.

33.4 You should make a police report if we request such a report to be made to facilitate the claims investigation process.





34. Recipient credential information

34.1 Where transactions are made by way of internet banking, any mobile phone application or device arranged for by us for payment transactions, including a payment kiosk, we will provide an onscreen opportunity for any Account User of a Wallet to confirm the payment transaction and recipient credentials before we execute any authorised payment transaction. The onscreen opportunity will contain the following information:

(a) information that allows the Account User to identify the Protected Account to be debited;

(b) the intended transaction amount;

(c) credentials of the intended recipient that is sufficient for the Account User to identify the recipient, which at the minimum should be the recipient's phone number, identification number, account number or name as registered for the purpose of receiving such payments; and

(d) a warning to ask the Account User to check the information before executing the payment transaction.







35. Reporting channel

35.1 We will provide Account Holders of Protected Accounts with a reporting channel for the purposes of reporting unauthorised or erroneous transactions.



35.2 The reporting channel should have all the following characteristics.

(a) The reporting channel may be a manned phone line, phone number to receive text messages, online portal to receive text messages, or a monitored email address.

(b) Any person who makes a report through the reporting channel will receive a written acknowledgement of his report through SMS or email.

(c) We will not charge a fee to any person who makes a report through the reporting channel for the report or any service to facilitate the report.

(d) The reporting channel shall be available at any time every calendar day, unless it is a manned phone line, in which case that reporting channel shall be available during business hours every business day.



36. Claim Investigation

36.1 We will while acting reasonably at our sole discretion assess any claim made by you in relation to any Unauthorized Transaction ("Relevant Claim") for the purposes of assessing your liability. Where we have assessed that the relevant claim does not fall within Unauthorized Transaction, we will resolve such a claim in a fair and reasonable manner. We will communicate the claim resolution process and assessment to you in a timely and transparent manner.

36.2. We may require that you furnish a police report in respect of Unauthorized Transaction claim, before we begin the claims resolution process. Upon enquiry by you, we will provide you with relevant information that we have of all the Unauthorized Transactions which were initiated or executed from a Protected Account, including transaction dates, transaction timestamps and parties to the transaction.

36.3. We will complete an investigation of any relevant claim within twenty-one (21) business days for straightforward cases or forty-five (45) business days for complex cases. Complex cases may include cases where any party to the Unauthorized Transaction is resident overseas or where we have not received sufficient information from the Account Holder to complete the investigation. We will within these periods give each Account Holder that we have been instructed to send Transaction Notifications to in accordance with manner set out in these terms, a written or oral report of the investigation outcome and its assessment of your liability. We will seek acknowledgement (which need not be an agreement) from that Account Holder of the investigation report.

36.4. Where you do not agree with our assessment of liability, or where we have assessed that the claim falls outside of Unauthorized Transaction, the parties may proceed to commence other forms of dispute resolution including FIDReC.

36.5. We will credit your Protected Account with the total loss arising from any Unauthorized Transaction as soon as we have completed our investigation and assessed that you are not liable for any loss arising from the Unauthorized Transaction. We will disclose this arrangement to you at the time you report the Unauthorized Transaction to us and inform you of the timeline for completing our investigation.



37. Liability for losses arising from Unauthorized Transactions

37.1 You are fully liable for actual loss arising from an Unauthorized Transaction where any Account User's recklessness was the primary cause of the loss. Recklessness would include the situation where any Account User deliberately did not comply with requirements under these terms. You are required to provide us with information we may reasonably require to assist us to determine whether or not any Account User was reckless.

37.2 For the avoidance of doubt, where any Account User knew of and consented to a transaction ("Authorised Transaction"), such a transaction is not an Unauthorised Transaction, notwithstanding that the Account Holder may not have consented to the transaction. This would also include the situation where any Account User acts fraudulently to defraud any Account Holder or us. In such case, the Account Holder shall be solely liable for entire loss.

37.3. You are not liable for any loss arising from an Unauthorized Transaction if the loss arises from, solely on account of, any action or omission by us and does not arise from any failure by any Account User to comply with any duty in this agreement.

37.4. Any action or omission by us includes the following:

(a) fraud or negligence by us, our employee, our agent or any outsourcing service provider contracted by us to provide our services through the Protected Account;

(b) non-compliance by us or our employee with any requirement imposed by a regulatory authority on us in respect of our provision of any financial service;

(c) non-compliance by us with any duty set out in this agreement.

37.5. You are not liable for any loss arising from an Unauthorized Transaction that does not exceed $1,000, if the loss arises from any action or omission by any third party not referred to in paragraph 37.4 above and does not arise from any failure by any Account User to comply with any duty under this agreement.

37.6 Where the Protected Account is a joint account, the liability for losses set out in this section applies jointly to each Account Holder in a joint account.



38. Specific duties in relation to Erroneous Transactions

38.1 Where you inform us in accordance with this section that you or an Account User has initiated a payment transaction from a Protected Account such that money has been placed with or transferred to the wrong recipient ("Erroneous Transaction"), we will inform the wrongful recipient's FI of the Erroneous Transaction promptly as much as practicable, to the FI of the wrong recipient and shall make reasonable efforts to recover the sum sent in error.

38.2 For the purposes of paragraph above, reasonable efforts mean the following:

(a) where we are the FI of Account Holder:

(i) within two business days of receiving the necessary information from you under this section, we shall inform the recipient FI of the erroneous transaction;

(ii) within seven business days of informing the recipient FI, we shall ask the recipient FI for the recipient's response and provide you with any new relevant information to allow you to assess if you should make a police report about the erroneous transaction.

(b) where we are the FI of the wrong recipient:

(i) within two business days of receiving the necessary information about any Erroneous Transaction, we will:

I. Inform the recipient of the erroneous transaction and all necessary information that would allow the recipient to determine if the transaction was indeed erroneous;

Ii. Ask the recipient for instructions on whether to send the sum sent in error back to you; and

Iii. Inform the recipient that his retention or use of sums transferred to him erroneously where he has had notice of the erroneous transaction is an offence under the penal code.

(ii) within five business days of receiving the necessary information about any erroneous transaction, we will:

I. Ask the recipient for instructions whether to send the sum sent in error back to the Account Holder; and

Ii. Inform the other FI about the recipient's response, including nil responses.



For the purposes of assisting the FIs to recover sums sent in error, you should provide us with any of the following information as requested by us:

(a) all such information set out in section 33.3 as requested by us;

(b) the recipient's unique identifier, including account number, identification number, name or other credentials entered by the Account User; and

(c) the date, time, amount and purpose of the erroneous transaction insofar as such information is known to you.