1. About SatchelPay
Updated – October 23, 2017
1.1. SatchelPay Ltd is a company incorporated under the laws of England and Wales with registration number 09808376, whose registered office is at Room 102, Wellington House, East Road, Cambridge, United Kingdom CB1 1BH. We are regulated by the Financial Conduct Authority (FCA) under the Payment Service Regulations 2009 for the provision of payment services. Our FCA registration number is 735365.
1.2. SatchelPay Ltd offers payment services as a Small Payment Institution and it is not offering banking services.
2. Scope of these Terms and Conditions
2.1. These Terms and Conditions are prepared and shall be governed by and interpreted in accordance with the laws of England and Wales. These Terms and Conditions state the basic rights and obligations of the contractual relationship between SatchelPay Ltd and individual Clients. This document is a part of any contractual relationship between SatchelPay Ltd and the Clients and in relation to the Contract, or other documents governing the terms of cooperation between the Client and SatchelPay Ltd by general provisions.
These Terms and Conditions also include provisions of using Payment Cards.
2.2. You are advised to read these Terms and Conditions carefully as it is obligatory for all parties to this contract from the date of the first expression of the intentions of Clients to establish a contractual relationship with SatchelPay Ltd.
2.3. You are also advised to print and/or download and keep a copy of these Terms and Conditions for future reference. You can always view the current Terms and Conditions on this Website.
2.4. It is considered, that you agree to the applicable in this document Terms and Conditions, if you are using any account or service provided by SatchelPay Ltd.
2.5. You also confirm that you have an access to the Internet and agree that SatchelPay Ltd may provide non-confidential and/or not personally addressed information to you by publishing it on the website www.satchelpay.com.
2.6. English is the original language of these Terms and Conditions. The original version may be translated into other languages. In case of discrepancy or contradictions between the original version and any other translated version of these Terms and Conditions, the English language version shall be perceived as prevailing.
2.7. No person other than you shall have any rights under these Terms and Conditions. The provisions of the Contracts (Rights of Third Parties) Act 1999 are excluded.
2.8. Any dispute under these Terms and Conditions or otherwise in connection with your SatchelPay account will be brought under exclusive jurisdiction of the courts of England and Wales with the exception of the cases prohibited by EU law.
2.9. If any part of these Terms and Conditions is recognized invalid, unlawful or unenforceable by a court of competent jurisdiction, such part shall be severed from the remainder of the Terms and Conditions, which shall continue to be valid and enforceable to the extent permitted by law.
3. SatchelPay account
3.1. SatchelPay account is user account that enables you to make money transfers.
3.2. SatchelPay offers accounts to both individual and corporate Clients as long as they meet its requirements.
3.3. You can open and operate a SatchelPay account in a currency of your choice, as selected by you from the available currencies.
3.4. You will not be eligible to open an account with SatchelPay, if you are under the age of 18.
3.5. You will not be eligible to open an account with SatchelPay, if you are a resident, a citizen or a company, incorporated in the countries, which appear in the ANNEX 1 to these Terms and Conditions.
3.6. We will provide you with a copy of these Terms and Conditions, when you apply to open an account. You will need to read, agree and accept all of the conditions contained therein, sign it and return to us. Agreement to these Terms and Conditions is confirmed by the returning the Application Form from your side.
3.7. Before the opening of an account we:
3.7.1. Process an Application Form;
3.7.2. Check the personal and/or business information of the client by verifying the relevant documentation;
3.7.3. Receive your transaction covering the price of the service package.
3.8. We can call upon other procedures for verifying the identity of the account holder. In case the officials of SatchelPay Ltd request certain information during the verification process, you will be required to cooperate with them.
3.9. You are required to notify SatchelPay Ltd concerning any updates to the data you provided in the Application Form e.g. legal name, nature of business, information about its owners or directors, contact details (such as phone and fax numbers, electronic and physical mailing addresses). All the changes must be provided in writing via email or letter.
3.10. SatchelPay account is personal to the Client and the Client may not assign any rights under these Terms and Conditions to any third party. Among other things, it means, that we receive the instructions regarding an account only from the signatory.
3.11. In case of death or bankruptcy of the signatory, SatchelPay will follow the directions of the one who is authorised by the account holder. SatchelPay may close or redeem the signatory’s account as instructed, only after the verification of the authorized person’s competency.
3.12. SatchelPay reserves the right to not open an account and/or close an account without providing a reason.
4. Operation with SatchelPay accounts
4.1. A fund transfer, whether external or internal cannot be cancelled. There is only a possibility to change an instruction of transfer and/or to provide new instructions. We cannot be liable for any loss resulted by failure or inability to provide new instructions in order to cancel or change a funds’ transfer from your side.
4.2. If the Client has multiple SatchelPay accounts, we can merger these as and when we see fit. One SatchelPay account may receive credit for an amount, that SatchelPay is indebted to the other SatchelPay account hold by the same Client.
4.3. In case of receiving an inquiry related to the ability of a Client to complete certain transactions, SatchelPay will respond to it in a general manner, and only after receiving the Client’s written consent.
4.4. SatchelPay can transfer the right to claim or any other rights to a third party at any time. In this case, we report details of the Client’s account as we regard as necessary, to this party.
4.5. If there are reasonable grounds, SatchelPay will be able to limit the access to the account and/or withdrawals, close an account of any Client at any time and at its sole discretion for any or for no reason with no foregoing notification and payment of any funds held in custody.
These reasonable grounds are assumed under, but are not limited to the following:
4.5.1. Failing to observe any part of these Terms and Conditions;
4.5.2. Violation of any current laws and/or regulations;
4.5.3. Submitting false, counterfeited or changed documents in process of verification;
4.5.4. Returning an incoming money transfer caused by insufficient funds in the account or an incorrect bank routing, name or number of account;
4.5.5. Using SatchelPay account in order to contribute to fraudulent activity and/or receive potentially fraudulent funds;
4.5.6. If there are reasons to believe, that SatchelPay account has been compromised;
4.5.7. If there are reasons to think, that SatchelPay account has been using an unauthorized or unusual method;
4.5.8. When there is an abuse of the charge back (reversal) process;
4.5.9. In case of using an anonymous proxy;
4.5.10. In case of receiving excessive customers’ complaints about a particular account, business or service;
4.5.11. If Clients send unsolicited emails or post referral links on websites, where they are prohibited;
4.5.12. For any other security reasons.
4.6. When we reasonably suspect, that SatchelPay account has been used or is being used fraudulently, we will notify the Client before the suspension. In case the preceding notification is impossible, we will notify the Client straight after the suspension.
4.7. SatchelPay Ltd will use all the acceptable efforts in order to investigate cases, where SatchelPay accounts are subject to access limitations until the final decision reached. SatchelPay Ltd will retain all funds for a period until the problem is resolved.
4.8. SatchelPay Ltd stores the personal information about the Client and history of transactions as required by law, but not less than five years. Closing a SatchelPay account does not result into the annulation of such data.
4.9. SatchelPay Ltd reserves the right to suspend or restrict the operation of the account or the provision of any other services immediately, at its sole discretion and without prior notification in the next cases:
4.9.1. We became aware of the Client’s or his guarantor’s death, lack of legal capacity, bankruptcy or an insolvency;
4.9.2. We became aware of the dispute over the operation of Client’s account or Client’s ownership of funds on the account;
4.9.3. We became aware that a third party claimed an interest in Client’s account;
4.9.4. We have grounds to think that Client or third persons have used or are still using account illicitly or fraudulently;
4.9.5. We have grounds to believe that Client or third persons behave incorrect e.g. in a frightening, threatening or aggressive manner towards the officials of SatchelPay Ltd;
4.9.6. We have grounds to think that Client or third persons have used or are still using corporate accounts, while the competency of the person, that represents particular legal entity raises doubts;
4.9.7. We became aware that the Client violated these Terms and Conditions;
4.9.8. We have reasons to believe that the Client, or payments in or out of his account, are subject to an international payments sanction regime;
4.9.9. Client’s account has never been used, or has not been used for an extended period of time;
4.9.10. Client is failing to provide to SatchelPay Ltd the information and/or documentation required under these Terms and Conditions to enable the provision of the services either when required or in a form, which is acceptable to SatchelPay Ltd;
4.9.11. We have a reasonable confirmation concerning the dishonesty of the Client’s actions;
4.9.12. We have reasons to believe that there is a legal requirement to do so, or a court or any other authority requires suspending or restricting the operation of the account or the provision of any other services.
4.10. In cases mentioned above, SatchelPay Ltd reserves the right to expect a requirement or an authorization of the corresponding Authority or a Court order, before ending the suspension or restriction of operating of Client account’s operation or the provision of any other product or service.
4.11. The Client takes responsibility to supply updates of documents required for the account operating. The outdated or invalid documents may cause the measures designated in points 4.5., 4.9.
5. Prohibited transactions
5.1. SatchelPay aims to maintain a reputation of a reliable, trustworthy, professional Payment Institution with a high status. Therefore, we do not conduct deals with potentially risky Clients. We do not cooperate with Clients who carry out suspicious operations or/and transactions. Consequently, we reserve the right to prohibit any internal or external transaction that may fund the purchase or sale of below listed goods and services, or may be linked to the following activities:
5.1.1. Drugs or drug paraphernalia e.g. narcotics, steroids and other controlled substances presenting a risk to the well-being of a Client;
5.1.2. Particular kinds of firearms, ammunition, weapons or knives;
5.1.3. Child pornography or related hardcore content or services;
5.1.4. Trading of items or support of organizations that promote hate, violence, or racial intolerance;
5.1.5. Illegal gambling;
5.1.6. Forex, involving or not binary options and binary options trading platforms, using currency exchangers or aggregation, unless approved by SatchelPay Ltd;
5.1.7. Any activities with cumulative incoming transfers from individuals, unless in the ordinary or normal practice of the declared business and approved by SatchelPay Ltd;
5.1.8. Government identification documents and licenses, including replicas and novelty items;
5.1.9. Illegal downloads or any other goods and services infringing intellectual property rights of a third party (e.g. trademark, patent, copyright);
5.1.10. Illicit or illegally possessed goods or services;
5.1.11. Other goods or services violating applicable laws, statutes, ordinances or regulations.
5.2. We have the right to add categories of prohibited transactions by updating a list of such categories in these Terms of Conditions at sole discretion.
5.3. If the Client conducts or attempts to conduct any transaction in violation of the prohibitions mentioned above, SatchelPay Ltd has the right to:
5.3.1. Reverse transaction;
5.3.2. Close or suspend account;
5.3.3. Report the transaction to the relevant law enforcement authority;
5.3.4. Claim damages from the Client;
5.3.5. Charge the Client an administration fee of up to GBP 10,000 in case of applying any of the above mentioned.
5.4. Client and only the Client reserves the responsibility to ensure that he/she only receives and sends funds to legal entities or persons in order to sell or purchase goods and/or services that he/she provides or receives in full compliance with the relevant laws and regulations. The conduction of the transaction through SatchelPay Ltd alone does not signify the legality and legitimacy of the goods/ services supplied/received. In case of any concerns regarding the legality of such goods/services it is suggested not to proceed with the transaction.
5.5. SatchelPay Ltd has the right to return to the issuing side any incoming transaction, which appears suspicious in any way, and charge the relevant fees from the Client’s account. The latter concern the standard charges for a wire transfer or a SWIFT confirmation procedure to identify the account number of the issuer and allocate the returned funds there. The cost of the transfer may be additionally applied depending on the destination and currency and if applies foreign currency conversion.
6. Limitation of liabilities
6.1. SatchelPay Ltd cannot be held liable for any failure to fulfil its responsibilities under these Terms and Conditions caused by fail to function normally and/or satisfactorily of the equipment or systems utilised by our affiliates or us.
6.2. SatchelPay Ltd does not bear responsibility in case any failure, inconvenience, damage, delay, or loss in the transmission, receipt or execution of your payments, orders, deliveries of information resulted from events beyond our control, including the behavior of third parties that may influence the services provided e.g. the actions and inefficiencies of correspondent financial institutions, political events and instability, armed conflict, environmental disasters etc.
6.3. SatchelPay Ltd is not liable for any loss resulted from the provision of incorrect information by the Client, at the moment of opening an account or further.
6.4. SatchelPay Ltd is also not liable for any losses or inconvenience in result of damage or loss of a SatchelPay Payment Card, through a personal identification number (PIN) or compromising of credentials in Internet Transfer Services.
6.5. By signing these Terms and Conditions, you agree not to violate any law or regulation. Using services of SatchelPay Ltd, and you meet all liability that might arise from the use of these services.
6.6. The Client is solely and fully liable for the payment of taxes in the country of the Client’s tax residency.
6.7. The Client is solely liable for the registration/declaration of the Client’s accounts according to the legislative acts of the country of the Client’s residency.
6.8. If the Client or his actions resulted in SatchelPay Ltd incurring losses, fines or legal costs, SatchelPay Ltd has the right to debit the funds from the Client’s account(s). In the event that these funds are not enough to cover losses, fines and expenses for any legal dealings, SatchelPay can apply to the court.
6.9. By signing these Terms and Conditions, you agree to provide us immunity against and indemnify any claim against us released by a third party as a consequence of your use of SatchelPay Ltd services respective to all damages, losses, proceedings, claims, expenses or any other harm whatsoever suffered and howsoever incurred by SatchelPay Ltd in consequence of your violation of agreement to these Terms and Conditions.
7. Identification and anti-money laundering provisions
7.1. By signing these Terms and Conditions, you understand and agree to the following:
7.1.1. International sanctions may prevent the free movement of funds and delivery of products and/or services to and from certain countries, legal entities or private individuals. The latter may therefore influence our services along with your corporate operations;
7.1.2. Applicable laws, rules and policies that concern money laundering;
7.1.3. SatchelPay Ltd reserves an exclusive right to refuse the provision of services, which may violate or contradict any valid legislation or AML policy.
7.2. We adhere “Know Your Customer” (KYC) policy and we collect full information about our Clients in order to be certain about their identity. Therefore, we reserve the right:
7.2.1. To ask our Clients to answer all related questions;
7.2.2. To apply any Clients’ identification procedure to meet this legal objective;
7.2.3. To apply “face to face” identification procedure;
7.2.4. To apply control of the passport or other identification documents to confirm that these documents carry security marks and features, and that they are undoubtedly authentic.
7.3. SatchelPay Ltd accepts to open an account remotely. However, by signing these Terms and Conditions, you accept to go through a “face to face” identification procedure within 6 months from the date of SatchelPay account opening or at any time we request you to do so.
7.4. By signing these Terms and Conditions, you also consent to submit yourself to a physical identification procedure. In order to perform this procedure you can either be required to have a meeting with a SatchelPay Ltd representative and use online identification tool with our official who will process to the identification procedure with a video call. Therefore, in order to be identified through a video call, you accept to have access to a computer and a webcam. You are required hold your passport or other Identification Documents in your hands and show them to our identification agent. You are also obliged to help us (or our trusted partners) to check the security features of your Identification Document by tilting it, if necessary.
7.5. You give us a consent to record voice and video at any time we will ask to identify it. This way we fight against theft of Identification Documents and operation of accounts by third persons. Only authorized and identified Clients have the right to manage their SatchelPay accounts. Failure to satisfy a “face to face” or “video call” identification procedure as well as refusal to be identified entails such consequences as suspension of the account and freezing of funds. SatchelPay Ltd reserves the right to cease the identification process and to report a fraudulent action to competent authorities, when the face of Client and the photo in the Passport or other Identification Documents do not match or are significantly different.
8. SatchelPay Fees
8.1. Fees depend on whether you are using your SatchelPay account for personal or commercial purposes.
8.2. All fees can be viewed at any time in the “Fees” section of our Website. SatchelPay Ltd may periodically change the amount, frequency or time frames for payment of any fees and/or charges relating to services we provide.
8.3. All fees are non-refundable.
8.4. All fees are due immediately except monthly fees, which are due at the beginning of every month. First monthly fee is paid at the beginning of the month following the account opening.
8.5. If the balance on your SatchelPay account is insufficient, you permit SatchelPay Ltd to debit the fees and/or charges from another account or from this account later.
8.6. If you close your SatchelPay account, SatchelPay Ltd will debit all fees and/or charges from the balance to be transferred. When the balance is less than the amount that you are indebted to SatchelPay Ltd, you remain obliged to pay the net amount due.
8.7. SatchelPay Ltd reserves the right to charge you for and debit your SatchelPay account for any costs we incur to recover the amounts that you are indebted to us. SatchelPay Ltd is entitled to debit the remuneration due to SatchelPay Ltd at the moment when the assets are credited to accounts; besides, SatchelPay Ltd may charge the remuneration due for any past period.
8.8. SatchelPay Ltd may charge you the expenses, which it has reasonably incurred because of any collection of debts or enforcement efforts. In this case, expenses may include legal fees.
8.9. SatchelPay Ltd may also charge you for and debit your SatchelPay account for any expenses it meets in order to comply with any requests issued under a statutory or court authority for information or documents respecting your SatchelPay account.
8.10. SatchelPay Ltd will re-credit the relevant sum to your SatchelPay account after receiving the funds, in case a payment you have made or instructed us to make is returned because of either an error or providing insufficient information from your side.
SatchelPay Ltd will send back the relevant sum to the payer, if a payment that we have received for crediting to your SatchelPay account is refused due to prohibited transactions.
Under these circumstances, you will be liable for any incidental fees arising or charges incurred.
8.11. SatchelPay Ltd will charge back from your SatchelPay account all fees charged by the correspondent financial institution from SatchelPay Ltd in case of rejection of payment by the correspondent financial institution refusing to process a transfer on behalf of the Client.
8.12. Additional fees may be charged, if funds may have to be converted to another currency so that they can be credited to your SatchelPay account.
9.1. These Terms and Conditions are subject to change at any time in order to:
9.1.1. Make these Terms and Conditions more clear for the Clients;
9.1.2. Correct any mistakes;
9.1.3. Reflect new developments;
9.1.4. Provide new services or products;
9.1.5. Ensure reasonable and competitive business operations;
9.1.6. Represent changes in market conditions, banking practices or cost of services;
9.1.7. Comply with any current legislation or avoid contradictions with any applicable law or regulation;
9.1.8. Take into account any court ordinance or international sanctions that affect SatchelPay Ltd and any our services.
9.2. Any amendments shall be effective immediately upon either posting of the updated Terms and Conditions on our Website or notifying Clients.
9.3. We usually send our Clients an email to inform them about any amendment or modification in these Terms and Conditions.Nevertheless, we do not commit ourselves to sending such an email.
9.4. You agree to review the Terms and Conditions periodically to be aware of such modifications and your continued access or use of this Website shall proceed under your acceptance of the modified Terms and Conditions.
9.5. We will not be liable for any loss or inconvenience resulted from your incapability to keep yourself informed of these Terms and Conditions.
10. Your data
10.2. SatchelPay Ltd attaches the supreme importance to privacy and adopts severe rules of confidentiality about current and former Clients. SatchelPay Ltd does everything reasonable to protect securely any information held about Clients in the accordance with the applicable laws. We do not disclose information about Clients to anyone unless authorised by the Client or is required by the law.
10.3. We comply with all rules of banking confidentiality, which apply to us.
10.4. SatchelPay Ltd reserves the right to store information about Clients on both physical and electronic information carriers, including remote facilities.
10.5. As a default, our Clients receive email newsletters that inform them about new product features, events, offers, special deals etc. By accepting these Terms and Conditions, you agree to receive such email newsletters on a regular basis. If you do not wish to receive any newsletters from SatchelPay Ltd, you can refuse at any time by contacting Customer Service. Any email newsletter you receive will also give you the option to unsubscribe from any future newsletter.
11. Telephone conversations and website access
11.1. SatchelPay Ltd may record and/or monitor telephone conversations between Clients and staff in order to improve the quality of services and/or for verification or training purposes.
11.2. We cannot guarantee that the information sent over the Internet is totally secure. Clients provide information at their own risk.
11.3. Access to website of SatchelPay Ltd may be unavailable or terminated at any time. These circumstances do not affect any disclaimer or limitation of liability.
11.4. We are able to change the information on this website at any time. We have no obligations to notify our Clients about such changes.
12.1. We will communicate to you in respect of your SatchelPay account and other services, in English and will always accept communications made to us in English.
12.2. SatchelPay Ltd uses the latest contact details provided by the Clients, while communicating with them. We cannot be held liable for any loss or inconvenience resulted from the inability of a Client to inform us in time of any change in contact details or any relevant details having an effect on the agreement between us.
12.3. We usually contact the Clients via email. For this purpose, you are required to check for incoming messages regularly and frequently. Apart from communicating via email, we may contact the Clients via letter or telephone, where appropriate.
12.4. You may contact us at any time by sending a message to Customer Service via the email or by calling +44 330 808 4400.
13.1. Any complaints about the services we provide should be addressed to SatchelPay Ltd in the first instance by contacting Customer Service.
13.2. You should indicate clearly that you are wishing to make a complaint to us and file a letter of complaint detailing issues you are facing by submitting an online form or by writing us an email.
13.3. In order to investigate your complaint fairly, we need the next information:
13.3.1. First name and family name;
13.3.2. Company name (if applicable);
13.3.3. Customer ID (number of account);
13.3.4. Copies of relevant documents (if appropriate);
13.3.5. A description of complaint and suggested solution;
13.3.6. Preferred way to receive a response.
13.4. SatchelPay Ltd does not consider anonymous complaints.
13.5. We endeavour to provide you with an answer or resolution to your complaint swiftly and with minimum inconvenience in compliance with the terms as outlined by the Financial Ombudsman Service.
13.6. Generally, the investigative process and providing a written response take around 5 working days but may take longer depending on the complexity of the case.
If we cannot resolve complaint within 5 working days, we will aspire to do it within 20 working days.
If this is impossible due to unforeseen circumstances or lack of information, officials of SatchelPay Ltd will contact you.
13.7. Once the complaint is resolved, we provide you with a response in written form.
14. Definition of terms
14.1. Various terms in these Terms and Conditions have a defined meaning as follows:
14.1.1. “Signatory”, “Client”, “You” means the holder of SatchelPay account, user of this Website, user of payment card and client of SatchelPay Ltd;
14.1.2. “SatchelPay”, “We”, “Us”, “Our” means SatchelPay Ltd, officials or representatives of SatchelPay Ltd;
14.1.3. “Terms and Conditions” refers to these Terms and Conditions, published on the website and as may be amended from time to time;
14.1.4. “Application Form” means the form that Client signs before the opening an account at SatchelPay Ltd;
14.1.5. “Agreement” is the contract between Client and SatchelPay Ltd, governed by these Terms and Conditions and legal information mentioned herein;
14.1.6. “Account”, “SatchelPay Account” mean user account opened in the name of the Client through the SatchelPay Ltd;
14.1.7. “Limit” is the maximum amount of money that the Client can transfer from SatchelPay account using the Internet Transfer Services, including internal (to other SatchelPay accounts) and external (to the accounts opened in other payment institutions) transfers;
14.1.8. “Business Day” is any day other than a Saturday or a Sunday or any public or bank holiday in England;
14.1.9. “Fees” refers to charges payable by the Client to SatchelPay Ltd for using our services.