Terms of Use of the Global Simple Solutions Platform

The Company provides Users with access to a unified technological platform for managing financial operations.

The availability of particular services may depend on: the User's country of residence; the country of business registration; identity verification results; risk category; legal requirements;

and requirements of financial partners.

The Company does not guarantee that all services will be available to all Users.

The Company may establish limits relating to: account balances; incoming transfers; outgoing transfers; currency exchange transactions; and the number of transactions.

Such limitations may be modified without prior notice where necessary to comply with applicable law or the requirements of financial partners.

The Company shall take reasonable measures to ensure the continuous operation of the Platform.

Notwithstanding the foregoing, the Company does not guarantee the absence of: technical errors; communication interruptions; processing delays; software malfunctions; or temporary unavailability of specific functions.

The Company may temporarily suspend the operation of the Platform for maintenance, upgrades, or system updates.

To open an Account, the User must: be at least eighteen (18) years of age; have full legal capacity; be legally entitled to enter into binding agreements; not be subject to international sanctions; and not use the Platform for unlawful purposes.

A Corporate Client must be duly incorporated and registered in accordance with the laws of its jurisdiction.

To obtain access to the services, the User must complete the registration process.

The User shall provide accurate, complete, and up-to-date information during registration.

The Company may rely on the information provided by the User and shall not be liable for any consequences arising from inaccurate, incomplete, or misleading information.

The Company may request documents necessary to identify and verify the User.

For Personal Clients, the Company may request: passport; national identity card; residence permit; proof of residential address; and proof of source of funds.

For Corporate Clients, the Company may request: incorporation and registration documents;

information regarding directors; information regarding beneficial owners; information regarding business activities; financial documentation; and information regarding the source of funds.

The Company may refuse to open an Account without providing reasons where such refusal is required by applicable law, internal risk management procedures, or the requirements of financial partners.

The User acknowledges and agrees that the Company is not obligated to disclose its internal risk assessment criteria.

The Company complies with applicable laws and regulations relating to anti-money laundering (AML), counter-terrorist financing (CTF), and international sanctions compliance.

All Users must successfully complete identification and verification procedures before obtaining access to financial services.

The Company may use both automated and manual verification procedures.

Verification procedures may include: document verification; biometric identification; video verification; screening against sanctions lists; screening of politically exposed persons (PEPs);

and verification of source of funds.

The Company conducts ongoing monitoring of User transactions.

Any transaction may be reviewed for compliance with applicable law and the Company's internal policies.

The Company may request documents confirming: the economic purpose of a transaction; the origin of funds; and the identity of the sender or recipient.

Where elevated risk is identified, the Company may apply enhanced due diligence measures.

Such measures may include requests for additional documentation, temporary restrictions on access to services, or suspension of transaction processing pending completion of a review.

The Company may disclose information to competent governmental authorities where required by applicable law.

The User acknowledges and agrees that such disclosures may be made without prior notice where permitted or required by law.

Upon successful completion of the registration and verification procedures, the User may gain access to a Multi-Currency Account through the Platform.

The Multi-Currency Account is intended for the storage, receipt, transfer, and management of funds in currencies supported by the Company and its financial partners.

The list of available currencies is determined by the Company and may be modified at any time without prior notice to the User.

The Company does not guarantee the availability of any particular currency for all Users, countries, or customer categories.

User funds may be held through licensed banks, payment institutions, or electronic money institutions cooperating with the Company.

Funds displayed in a Multi-Currency Account do not constitute a bank deposit with the Company.

The Company does not pay interest on account balances unless expressly provided otherwise under separate service terms.

The User acknowledges and agrees that the servicing and safeguarding of funds are performed through the infrastructure of the Company's financial partners.

The Company may establish minimum and maximum limits on account balances.

The Company may restrict the use of specific currencies due to changes in legal requirements, partner requirements, or risk management considerations.

The Company maintains electronic records of all User transactions.

In the event of a technical error, the Company may adjust the User's balance accordingly.

If funds are mistakenly credited to the User's account, the Company may debit such funds without obtaining the User's prior consent.

The User must promptly notify the Company of any errors or discrepancies identified in their transaction history.

The User may not use a Multi-Currency Account for any purpose that violates these Terms or applicable law.

The Company may temporarily restrict the use of an account where there are suspicions of fraud, legal violations, or breaches of AML/KYC requirements.

The Company may provide Users with access to personal or corporate IBANs through its financial partners.

The provision of an IBAN is subject solely to the discretion of the Company and its partners.

The issuance of an IBAN is not a guaranteed right of the User.

The Company may refuse to provide an IBAN without explanation where such refusal is required by law, internal risk management procedures, or the requirements of financial partners.

The User shall use any assigned IBAN exclusively for lawful purposes.

The User agrees to use the IBAN only for activities consistent with the nature of the business or activity declared during registration.

A corporate IBAN must be used solely for the operations of the corresponding business.

A personal IBAN must not be used for commercial activities unless approved in advance by the Company.

The Company may review any incoming or outgoing payment.

As part of such review, the Company may request documents confirming: the source of funds;

the purpose of the payment; the relationship between the parties to the transaction; and the legal basis for conducting the transaction.

The Company may suspend payment processing until the review has been completed.

The Company may return a payment to the sender or reject it entirely.

The Company may restrict or discontinue IBAN services at the request of a financial partner.

The Company may replace an IBAN if changes occur in the banking infrastructure.

The Company shall not be liable for the actions of correspondent banks or other financial institutions involved in payment processing.

The Platform may provide functionality allowing transfers between registered Users.

To use the service, both parties to the transfer must maintain active Accounts.

The Company may establish limits on the number and value of P2P Transfers.

A transfer is deemed initiated once it has been confirmed by the User.

Following confirmation, a transfer may become irrevocable.

The User is solely responsible for verifying recipient details before sending funds.

The Company shall not be liable for errors made by the User when selecting a recipient or specifying the transfer amount.

The Company may review any transaction.

Where indicators of fraud or other violations are identified, the Company may: delay execution of the transfer; request additional documentation; refuse to process the transaction; or restrict access to the P2P service.

The Company does not act as an intermediary in resolving private disputes between Users.

The User may initiate SEPA Transfers through the Platform within the scope of available functionality.

The Company provides access to SEPA infrastructure through its financial partners.

The availability of SEPA services depends on the service jurisdiction, User category, and applicable legal requirements.

The Company shall take reasonable measures to ensure the timely execution of payment instructions.

Transfer processing times may depend on: receiving banks; correspondent banks; public holidays; internal security reviews; and applicable legal requirements.

The Company does not guarantee that a transfer will be executed within any specific timeframe.

The Company may request documents confirming the purpose of a payment.

The Company may refuse to execute a transfer if the transaction appears suspicious or conflicts with applicable legal requirements.

The Company may restrict transfers to certain countries or regions.

The User is responsible for ensuring the accuracy of all payment details.

The Company shall not be liable for any consequences resulting from errors made by the User when completing a payment instruction.

In the event of an erroneous transfer, recovery of funds is not guaranteed.

The Platform enables Users to exchange one currency for another.

Currency exchange transactions are carried out through the Company's liquidity providers and financial partners.

Exchange rates are determined based on market conditions and may change in real time.

Before confirming a transaction, the applicable exchange rate will be displayed to the User.

By confirming a transaction, the User agrees to the displayed exchange rate and all applicable fees.

Once confirmed, the transaction becomes final and binding.

The Company is not required to cancel completed currency exchange transactions.

The Company may charge a fee for currency exchange services.

The exchange rate may include a foreign exchange spread.

Information regarding fees and the applicable exchange rate will be provided to the User before confirmation of the transaction.

The User acknowledges that exchange rates may fluctuate as a result of market conditions.

The Company does not guarantee that a quoted exchange rate will remain available until the transaction is confirmed.

The User independently decides whether to proceed with a currency exchange transaction and assumes all risks associated with fluctuations in currency exchange rates.

The Company may charge fees, commissions, and other charges for the use of the Platform and certain services in accordance with the applicable Fee Schedule.

The Fee Schedule forms an integral part of the contractual relationship between the Company and the User.

Current fees and charges are published on the Platform or otherwise made available to the User in a manner determined by the Company.

The User is responsible for reviewing the applicable Fee Schedule before using any relevant service.

The Company may charge fees for:

The User acknowledges and agrees that fees charged by correspondent banks, payment systems, or other financial institutions may be deducted from the transfer amount.

The Company may automatically deduct applicable fees from the User's funds.

The User must maintain a sufficient balance to cover all applicable fees.

If the available balance is insufficient to cover a fee, the Company may suspend the provision of the relevant service.

The Company may amend its Fee Schedule at any time.

Changes may result from market conditions, partner requirements, legal requirements, or the Company's operational costs.

Continued use of the Platform after revised fees become effective constitutes acceptance of such changes by the User.

The User agrees to use the Platform solely for lawful purposes and in accordance with these Terms.

The User may not use the Platform for activities that violate applicable law, the rights of third parties, or the Company's internal policies.

The User is prohibited from using the Platform for:

If indications of prohibited activity are identified, the Company may:

The User shall take reasonable measures to protect the security of their Account.

The User is responsible for safeguarding: passwords; verification codes; two-factor authentication devices; email accounts; and mobile phones used to access the Platform.

The User shall not disclose login credentials to any third party.

The Company may require multi-factor authentication for access to the Platform.

The Company may require additional identity verification before permitting certain transactions.

Any action performed using valid authentication credentials shall be deemed to have been performed by the User.

The User must immediately notify the Company if they suspect: password compromise; loss of a device; unauthorized access; or suspicious transactions.

The Company may temporarily restrict access to the Account until a security review has been completed.

The Company shall not be liable for losses resulting from the User's failure to comply with their security obligations.

The Company processes personal data in accordance with Regulation (EU) 2016/679 (GDPR), the laws of the Republic of Poland, and other applicable legal requirements.

By using the Platform, the User consents to the processing of personal data to the extent necessary for the provision of services.

The Company may process personal data for the following purposes:

The Company may disclose personal data to:

The User has the right to:

All rights relating to the Platform, software, design, databases, interfaces, trademarks, logos, text, graphics, and other materials belong to the Company or its licensors.

Use of the Platform does not grant the User any ownership rights in any intellectual property.

The User shall not:

If the User provides suggestions, recommendations, comments, or feedback regarding the Platform, the Company may use such materials without payment of compensation and without restriction.

The Company shall take reasonable measures to ensure the proper operation of the Platform and the provision of services in accordance with these Terms and applicable law.

Notwithstanding the foregoing, the Platform is provided on an "as is" and "as available" basis.

The Company does not guarantee that the Platform will operate uninterrupted, error-free, or without delays or technical failures.

The Company does not guarantee the availability of any specific functionality, service, currency, service jurisdiction, or financial partner at any given time.

The Company shall not be liable for the acts or omissions of banks, payment institutions, electronic money institutions, liquidity providers, KYC/AML service providers, internet service providers, telecommunications operators, payment systems, or any other third parties.

The Company shall not be liable for delays, errors, or the inability to execute transactions resulting from the actions or omissions of third parties.

The Company shall not be liable for decisions made by financial partners to refuse services to a User.

The Company shall not be liable for losses resulting from fluctuations in currency exchange rates.

The Company shall not be liable for the User's investment decisions.

The Company shall not be liable for indirect damages, loss of profits, loss of business reputation, loss of customers, or loss of anticipated revenue.

The Company shall not be liable for consequences arising from the User's use of inaccurate information or incorrect payment details.

To the fullest extent permitted by law, the Company's total aggregate liability to the User shall be limited to the amount of fees actually paid by the User to the Company during the twelve (12) months preceding the event giving rise to the claim.

This limitation shall not apply where applicable law expressly prohibits such limitation of liability.

The Company may, at any time, restrict the User's access to the Platform in whole or in part.

Such measures may be taken for the purposes of: compliance with legal requirements;

compliance with financial partner requirements; fraud prevention; protection of the Platform;

protection of Users; and conducting internal investigations.

The Company may restrict the use of an Account if:

The Company may terminate services provided to a User at any time where necessary to comply with legal requirements or manage risk.

The User may close their Account provided that no outstanding debts or unfulfilled obligations remain.

Following termination, the Company may continue to retain documents and information for the period required by applicable law.

Termination of services does not release the User from obligations arising prior to the termination date.

The Company may retain funds until all required reviews have been completed and legal obligations have been fulfilled.

The Company shall not be liable for any total or partial failure to perform its obligations where such failure results from circumstances beyond its reasonable control.

Force Majeure events include, but are not limited to:

During the existence of a Force Majeure event, the Company's performance of its obligations may be fully or partially suspended.

The Company shall take reasonable measures to minimize the consequences of such circumstances.

The User may submit complaints, inquiries, and claims to the Company.

A complaint must contain sufficient information to identify the User and describe the circumstances giving rise to the complaint.

The Company may request additional documents and information in order to review the complaint.

The Company shall review complaints within the timeframes prescribed by applicable law.

Where additional review is required, the review period may be extended to the extent permitted by applicable law.

The Company shall provide its response by email or through other communication channels used by the User.

The parties agree to make good-faith efforts to resolve disputes through negotiation before commencing legal proceedings.

The User agrees to provide the Company with a reasonable opportunity to review and resolve any claim.

These Terms shall be governed by and construed in accordance with the laws of the Republic of Poland.

Any matters not expressly regulated by these Terms shall be governed by the laws of the Republic of Poland and applicable European Union legislation.

If a dispute cannot be resolved through negotiation, it shall be submitted to the competent courts of the Republic of Poland.

Unless otherwise required by mandatory consumer protection laws, the venue for dispute resolution shall be Poznań, Republic of Poland.

The User agrees that the Company's electronic records, transaction logs, authentication data, communications, and other electronic evidence may be used as evidence in judicial and administrative proceedings.

If any provision of these Terms is found to be invalid or unenforceable, the validity of the remaining provisions shall remain unaffected.

Any invalid provision shall be replaced by a provision that most closely reflects its intended economic and legal purpose.

The Company may assign its rights and obligations under these Terms to its affiliates, successors, financial partners, or other entities as part of a business reorganization.

The User may not assign their rights or obligations without the Company's prior written consent.

These Terms, together with the Privacy Policy, Fee Schedule, AML/KYC Policy, Personal Data Processing Policy, and other Company documents, constitute the entire agreement between the User and the Company.

These Terms supersede any prior agreements or understandings between the parties concerning the use of the Platform.

Global Simple Solutions Sp. z o.o. 28 Czerwca 1956 r 223/229 61-485 Poznań Poland Email: [email protected]