Terms & Conditions
Applicable as of October 13, 2025
PREAMBLE 3
TITLE I — GENERAL PROVISIONS 4
Article 1 — Definitions 4 Article 2 — Purpose and scope 5 Article 3 — Acceptance and Enforceability 5
TITLE II — ACCESS, VERIFICATION, COMPLIANCE 5
Article 4 — Account Opening and Identification Diligence 5 Article 5 — Top-ups, issuance, and availability of balances 6 Article 6 — Apple Pay and Google Pay Integration — Unverified Users 6 Article 7 — Recurring Payments and Subscriptions 6 Article 8 — Fees, Commissions, and Debit Order 7 Article 9 — Risk control and decline rate management 7 Article 10 — Duty of care and trade secrets 8
TITLE III — OPERATIONS, SECURITY, AND TRACEABILITY 8
Article 11 — Operational integrity, maintenance, and continuity 8 Article 12 — Data, confidentiality, and protection at the DIFC 9 Article 13 — Anti-money laundering and illicit financing 9
TITLE IV — MEASURES, LIABILITY AND DISPUTES 10
Article 14 — Suspension, Freezing of Funds and Closure 10 Article 15 — Limitation of Liability 10 Article 16 — Indemnification and allocation of costs 10 Article 17 — Applicable law, jurisdiction, and arbitration 10 Article 18 — Forfeiture, inadmissibility, and security for costs 11 Article 19 — Amendments, Assignment and Subcontracting 11 Article 20 — Final provisions 11
ANNEXES 12
Appendix 1 — Financial Schedule and Collection Procedures 13 Appendix 2 — Risk management framework and operational discipline 14 Appendix 3 — Prohibited Activities and Related Measures 15 Annex 4 — Excluded territories and jurisdictions 16 Appendix 5 — AML/CFT guidelines at the DIFC 17 Normative references (indicative) 18
PREAMBLE
These terms and conditions and its appendices (the "Terms") constitute, between kardpay FZCO ("kardpay"), a company established and governed by the laws of the Dubai International Financial Centre ("DIFC"), and any natural or legal person accessing its services (the "User"), the sole, complete, and comprehensive agreement governing the opening and operation of an account, the issuance and use of prepaid payment instruments (physical or virtual), the management of balances and reloads, the integration of mobile wallets, and any related transactions.
In the interests of legal certainty and regulatory consistency, the contractual relationship is governed exclusively by DIFC law; jurisdiction lies with the DIFC Courts, without prejudice to kardpay's right to refer the matter to the Dubai International Arbitration Centre (DIAC), DIFC seat, in accordance with its own rules.
Any proceedings brought in any other jurisdiction shall be deemed null and void and inadmissible.
The User acknowledges that the provision of the Services is based on a multi-party operational chain including a network-licensed issuer and processing providers (collectively, the "Network Providers").
The technical, prudential, anti-fraud, and compliance requirements issued by Network Providers, an issuer, or a competent authority recognized by the DIFC (the "Third Party Rules") are incorporated herein by reference and are binding on the User in the same manner as the provisions below.
For reasons of confidentiality and security, the identity of Network Providers is not disclosed or communicable; any attempt at identification, circumvention, solicitation, or misappropriation is prohibited and will result in immediate action.
TITLE I — GENERAL PROVISIONS
Article 1 — Definitions
For the purposes hereof:
"Account" means the secure interface assigned to the User for the administration of payment instruments, balances, top-ups, and security settings;
"Card" means the physical or virtual payment instrument linked to the Account and usable within the limits of available balances and applicable limits;
"Wallet" means a sub-account denominated in fiat currency or digital assets authorized by the DIFC;
"Authorization Fee": refers to the amount due for each transaction attempt, whether successful or not, currently set at USD 0.25;
"Chargeback" means a chargeback initiated by a cardholder or their institution, resulting in the collection of a flat fee of USD 30 per case, without prejudice to the disputed amounts;
"Decline rate" means the refusal rate assessed by reference to the amounts refused over a specified period;
"Services" refers to all the features provided by kardpay, including the issuance and use of Cards, reloads, Apple Pay and Google Pay integrations, and related transactions.
"Third-Party Rules" means the aforementioned external requirements.
Any competing definition from another legal system shall have no bearing on the present agreement.
Article 2 — Purpose and scope
The purpose of the Terms and Conditions is to establish the contractual regime applicable to access to and use of the Services, from subscription to closure of the Account, including the obligations arising from Third Party Rules, risk management mechanisms, security rules, and protective measures.
They prevail over any prior or concurrent writing, exchange, usage, or tolerance; no indulgence in performance shall constitute a waiver or novation. Continued use after publication of an update constitutes irrevocable acceptance.
Article 3 — Acceptance and enforceability
Acceptance of the Terms and Conditions results from any positive act of commitment, such as opening an Account, activating a Card, reloading it, or executing a transaction.
The Terms and Conditions are enforceable as soon as they are published.
Any dispute brought before a court other than the DIFC Courts, or outside of DIAC arbitration based in the DIFC, shall be deemed inadmissible.
TITLE II — ACCESS, VERIFICATION, COMPLIANCE
Article 4 — Account Opening and Identification Diligence
The User shall provide, upon first request, accurate and verifiable information relating to their identity, domicile and, where applicable, their corporate form and beneficial owners, as well as the origin and destination of the funds.
kardpay may conduct enhanced due diligence (EDD), request bank statements, contractual supporting documents, and proof of wealth, organize a remote interview, and collect external documentary confirmations.
Failure to provide complete information within the specified time frame will result in the immediate suspension of Services, the freezing of funds and, where applicable, the closure of the Account without compensation.
Article 5 — Top-ups, issuance, and availability of balances
The issuance of a Card and the registration of a top-up are normally carried out within three to five minutes, this time frame being indicative and subject to variation depending on network load, compliance checks, and security.
Top-ups are carried out using authorized channels only.
No interest is paid on balances.
kardpay may defer the availability of an amount when a risk signal or control requirement is identified.
Article 6 — Apple Pay and Google Pay integration — Unverified users
When a user does not meet the standard cardholder verification process, manual approval requires the customer to provide their login email address, with activation possible within 24 business hours.
Successive attempts to connect or the use of "atypical" IP addresses may trigger anti-fraud mechanisms.
kardpay shall not be held liable for any resulting refusal, blocking, or closure.
Article 7 — Recurring payments and subscriptions
For subscription services, the use of cards linked to certain issuing bank identifications must be limited in order to avoid systematic reminders in the event of insufficient funds.
Repeated attempts to make a payment may result in a negative balance, which shall be borne entirely by the User, who remains responsible for terminating unwanted subscriptions in advance at and, in the event of a card being frozen or closed, for deleting any payment links registered with the merchant. (Redirection to card suspension)
Article 8 — Fees, commissions, and withdrawal orders
Each transaction attempt will incur an authorization fee of USD 0.25, including when the attempt is declined or when the instrument is blocked or canceled.
Top-ups are subject to a fee of 4% calculated on the amount credited.
Any chargeback will result in a flat fee of USD 30 being charged, without prejudice to the amounts in dispute.
Fees are deducted first from the balance of the Card concerned and then, if there are insufficient funds, from the overall balance of the Account, or by suspending services on the current "staking" of "KDY" or by any means allowing recovery without prior enforcement proceedings.
The fees charged are non-refundable.
Article 9 — Risk control and decline rate management
The decline rate is calculated by reference to the amounts declined, not the number of transactions.
A level above 25%, observed on several consecutive days, may result in measures imposed by a Network Provider, including lowered limits, targeted suspensions, in particular the deletion of cards or accounts, or penalties, without this list of sanctions being exhaustive.
At a minimum, the User must:
cancel unnecessary subscription authorizations, particularly for advertising accounts;
(ii) maintain, prior to any transaction, a balance greater than or equal to 110% of the amount in question;
(iii) refrain from immediately restarting a declined transaction without prior diagnosis; and
(iv) delete any payment link with a merchant if the Card is frozen or closed.
The persistence of abnormal indicators gives kardpay the right to restrict, suspend, or close the Account.
Article 10 — Obligations of prudence and business secrecy
The User shall keep their login details and authentication devices safe, notify any anomalies without delay, and apply minimum security measures (up-to-date operating system and browser, active antivirus software, no anonymization tools).
They shall refrain from identifying or soliciting a Network Service Provider, attempting to circumvent the operational chain, aggregating or reusing information on flows or infrastructure; they acknowledge that the supply chain constitutes a trade secret, the violation of which justifies any protective measures and penalties.
TITLE III — OPERATIONS, SECURITY, AND TRACEABILITY
Article 11 — Operational integrity, maintenance, and continuity
Operations are carried out primarily with integrity and compliance objectives in mind; security takes precedence over speed.
kardpay may temporarily interrupt access to the Services for corrective or preventive maintenance, security updates, incident response, or in execution of an instruction from a Network Provider or a competent authority; such interruptions shall not give rise to any right to compensation.
Article 12 — Data, confidentiality, and protection at DIFC
Each kardpay Customer has SECURITY DATA (username, password, codes received by phone or email, etc.) that allows them to use our services. This SECURITY DATA:
are strictly PERSONAL and CONFIDENTIAL;
must NEVER be DISCLOSED to third parties;
will NEVER be REQUESTED by kardpay;
are under YOUR SUPERVISION and YOUR RESPONSIBILITY.
kardpay processes personal data within the framework and in accordance with the protection standards in force at the DIFC.
The User authorizes the necessary communications to Network Providers and competent authorities when required by regulation. Information relating to operational architecture, partners, and flows is confidential; its unauthorized disclosure or use may result in suspension and liability actions.
Article 13 — Combating money laundering and illegal financing
kardpay applies initial and ongoing due diligence procedures, implements enhanced controls when required by the profile, transaction, or jurisdiction, prohibits the use of anonymization mechanisms such as mixers and tumblers, and retains records for at least five years after closure.
Provisional freezes may be imposed where there are serious indications; notifications may be omitted where permitted by law.
TITLE IV — MEASURES, LIABILITY, AND DISPUTES
Article 14 — Suspension, Freezing of Funds, and Closure
kardpay may, with or without notice, suspend access to the Services, freeze funds, or close an Account in the event of non-compliance, suspected fraud, instructions from a Network Provider or authority, sustained exceeding of risk thresholds, or when required to protect the ecosystem.
The return of a net balance may be deferred to satisfy legal and contractual verifications; fees and deductions due are charged as a priority.
Article 15 — Limitation of Liability
The Services are provided "as is." To the maximum extent permitted, kardpay excludes all express, implied, or statutory warranties.
Kardpay's overall liability is limited to an amount equivalent to the total fees actually paid by the User during the three months preceding the event giving rise to the liability, excluding any indirect, consequential, or punitive damages, and any loss of profit, customers, data, or opportunities.
Article 16 — Indemnification and cost allocation
The User indemnifies kardpay against any financial consequences arising from a breach of the Terms and Conditions or Third Party Rules, including scheme fines, chargebacks, collection costs, and reasonable expert fees.
In the event of legal proceedings, the losing party shall bear the reasonable costs and fees of the winning party, subject to the rules applicable to the DIFC and, where applicable, the arbitration rules.
Article 17 — Applicable Law, Jurisdiction, and Arbitration
The applicable law is exclusively that of the DIFC.
The DIFC Courts shall have exclusive jurisdiction and venue, and the User irrevocably waives any objection based on lack of jurisdiction, convenience of forum, or any similar grounds.
kardpay may, at its sole discretion, submit a dispute to DIAC arbitration, DIFC seat, English language; the award rendered shall be final and binding.
Article 18 — Lapse, inadmissibility, and security for costs
Any claim must be brought within one month of an initial complaint and in the manner prescribed by the DIFC; otherwise, it shall be barred and inadmissible.
kardpay may apply to the DIFC Courts or the arbitral tribunal hearing the case for the allocation of security for costs where the User's financial situation, location outside the jurisdiction, or the nature of the dispute so warrants.
Article 19 — Modifications, assignment, and subcontracting
kardpay may modify the Terms and Conditions for reasons of compliance, security, or risk reduction; publication shall constitute notification and continued use shall constitute acceptance.
kardpay may assign or subcontract all or part of the Services; the User may not assign their rights and obligations without prior written consent.
Article 20 — Final provisions
The invalidity of any provision shall not affect the validity of the other provisions.
Failure to exercise a right shall not constitute a waiver.
The clauses relating to liability, compensation, confidentiality, jurisdiction, arbitration, and foreclosure shall survive the termination of the contractual relationship.
APPENDICES
Appendix 1 — Financial scale and collection methods
The applicable financial schedule includes, in particular, an amount of twenty-eight (28) for the issuance of a Virtual Card, a percentage of four percent (4%) on any credited reload, a fixed amount of zero point twenty-five US dollars ($0.25) for each authorization attempt, whether accepted or declined, and a flat fee of thirty US dollars per chargeback file.
Fees are deducted first from the balance of the Card concerned and then, if there are insufficient funds, from the overall balance of the Account.
They are non-refundable and may be subject to contractual compensation.
Appendix 2 — Risk management framework and operational discipline
The risk management system is based on monitoring the refusal rate assessed by amount, supplemented by indicators of behavior, merchants, and categories of expenditure.
When the level exceeds a threshold of twenty-five percent (25%) over a significant period, corrective measures may be imposed, such as reducing limits, selectively suspending instruments, restricting merchant categories, deactivating recurring authorizations, deactivating cards linked to an account, or even deleting the user account.
The User shall comply, without delay, with the requirements to maintain an operational reserve equal to or greater than one hundred and ten percent of the projected amounts, to refrain from immediately resubmitting a payment that has been refused without cause, and to remove any registered payment link when a Card is frozen or closed.
Appendix 3 — Prohibited Activities and Related Measures
The following are prohibited, without limitation: transactions involving illegal objects, services, or content; fraud; money laundering or the financing of prohibited activities; mechanisms for anonymizing flows; and, more generally, any activity that contravenes financial public policy as understood by the DIFC or by Third Party Rules.
The discovery of even a single instance of a prohibited activity authorizes the immediate suspension of Services, the freezing of funds, and reporting to the competent authorities.
Appendix 4 — Excluded territories and jurisdictions
Territories, states, areas, or jurisdictions subject to sanctions, embargoes, or restrictions recognized within the DIFC, as well as territories whose regulations differ from those of the DIFC or which do not recognize arbitration awards within the DIFC, are deemed to be excluded.
Any request made from or to such a territory is, by operation of law, null and void, without effect and inadmissible.
Appendix 5 — AML/CFT Guidelines in the DIFC
Prudential requirements include initial and ongoing identification, enhanced due diligence in the presence of aggravating factors, prohibition on the use of anonymization devices, and retention of records for a minimum of five years after closure.
kardpay cooperates with the recognized authorities at the DIFC and may refrain from alerting the User when required to do so by law.
Normative references (indicative)
Without prejudice to the interpretation adopted by the DIFC courts, the following are provided for information purposes only:
the DIFC Contract Law 2004,
the DIFC Regulatory Law 2004,
the DIFC Arbitration Law 2008,
the DIFC Data Protection Law 2020,
the DIFC Digital Assets Law 2024,
the documents and technical circulars issued by Network Providers recognized within the DIFC.
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