Customer Vulnerability

1. Business-to-Business Services Only

Cash Me provides its services primarily on a business-to-business basis, unless expressly agreed otherwise in writing. Our services are intended for businesses, merchants, fintech platforms, financial operators, programme managers, software providers, commercial intermediaries and institutional or commercial clients, and are not designed as direct consumer financial services unless specifically stated.

The customer remains solely responsible for its own business activities, products, services, marketing, contractual arrangements, customer onboarding, customer due diligence, ongoing compliance and interactions with its own end users, merchants, sub-merchants, users, account holders or counterparties.

2. High-Risk Business Model Acknowledgement

The customer acknowledges that Cash Me may support or provide solutions to businesses operating in sectors, jurisdictions, geographies or commercial models that may be classified by financial institutions, card schemes, payment processors, banking partners, regulators or service providers as higher-risk.

Such classification may result in enhanced due diligence, additional monitoring, rolling reserves, delayed settlements, account limitations, higher fees, rejected applications, restricted functionality, service suspension or termination by Cash Me or by any third-party provider connected to the services.

Cash Me does not guarantee that any customer, transaction flow, jurisdiction, business model or end-user segment will be accepted, maintained or supported on an ongoing basis.

3. No Responsibility for Customer’s End Users or B2B Clients

Cash Me is not responsible for the acts, omissions, misconduct, fraud, misrepresentation, abusive practices, chargebacks, complaints, disputes, non-delivery, non-performance, unlawful conduct, regulatory violations or reputational events caused by the customer, the customer’s end users, merchants, sub-merchants, affiliates, partners or any other third parties engaged by the customer.

Where the customer operates as a platform, intermediary, software provider, payment facilitator, agent, programme manager, reseller or service distributor, the customer is solely responsible for:

• the conduct of its own clients, merchants, sub-merchants and users;
• ensuring that its own clients and users comply with all applicable laws and regulations;
• monitoring business activity conducted through its infrastructure;
• handling complaints, refunds, disputes, consumer protection obligations and remediation;
• implementing adequate fraud prevention, KYC/KYB, AML, sanctions screening, transaction monitoring and internal controls where required.

Cash Me shall have no liability for losses arising from the business conduct of the customer or the customer’s own clients.

4. Vulnerable Customers and End-User Protection

If the customer serves, targets, acquires or interacts with individuals or entities that may be considered vulnerable, including persons with limited financial sophistication, reduced capacity, distress, dependency, digital vulnerability, language barriers, age-related vulnerability, health-related vulnerability or other circumstances requiring enhanced care, the customer is solely responsible for implementing appropriate protections, disclosures, suitability controls, support channels and escalation procedures.

Cash Me does not assume responsibility for assessing the vulnerability, suitability, capacity, affordability or appropriateness of the customer’s products or services for the customer’s own end users, unless expressly agreed in writing.

The customer must ensure that its commercial practices, customer support, disclosures, risk warnings, complaint handling and marketing communications are fair, lawful, accurate and appropriate for the relevant audience.

5. No Guarantee or Warranty

To the fullest extent permitted by applicable law, Cash Me provides its services “as is” and “as available” without guarantees, representations or warranties of any kind, whether express, implied, statutory or otherwise.

In particular, Cash Me does not warrant that:

• the services will be uninterrupted, error-free, always available or free from delays;
• any application, onboarding, merchant approval, account opening, card programme, payment flow, crypto-related service or provider service will be approved or maintained;
• any third-party provider will continue to support the customer’s business model;
• the services will meet the customer’s specific commercial, legal, regulatory, operational or risk-management needs;
• transactions will always be processed, settled, executed, cleared or completed;
• fraud, chargebacks, abuse, cyber incidents, sanctions issues or compliance failures will be prevented.

Any timelines, onboarding expectations, service scope descriptions or commercial estimates are indicative only and do not constitute a warranty or guarantee.

6. Third-Party Providers and Dependencies

Many Cash Me services rely on third-party partners, including but not limited to banking partners, EMI institutions, payment institutions, card issuers, BIN sponsors, acquirers, payment processors, compliance providers, liquidity providers, crypto infrastructure providers, KYC/KYB vendors, fraud tools, technology vendors and regulated institutions.

The customer acknowledges that access to certain services may depend on the policies, approvals, technical availability, commercial decisions, jurisdictional restrictions and risk appetite of such third parties.

Cash Me is not liable for any refusal, delay, limitation, freezing, suspension, enhanced review, reserve requirement, transaction rejection, account closure or service withdrawal imposed by any third-party provider.

7. Customer Compliance Responsibility

The customer is solely responsible for ensuring that its business, operations, products, content, marketing, jurisdictions, transaction flows, customer base and use of the services comply with all applicable:

• anti-money laundering laws;
• counter-terrorist financing laws;
• sanctions and export control rules;
• anti-bribery and anti-corruption laws;
• consumer protection rules;
• licensing and registration requirements;
• data protection and privacy laws;
• card scheme rules;
• financial promotions and advertising rules;
• crypto and virtual asset regulations;
• local laws applicable to its industry and end users.

Use of Cash Me’s services does not constitute regulatory approval, licensing coverage, legal advice or compliance certification for the customer’s business.

8. Fraud, Abuse and Prohibited Activity

The customer shall not use, and shall not permit any third party to use, the services for unlawful, deceptive, abusive, fraudulent, misleading, exploitative, prohibited or non-compliant activity.

Cash Me reserves the right, at its sole discretion and without liability, to:

• request additional information or documents;
• conduct enhanced due diligence;
• monitor account and transaction activity;
• delay, reject, reverse or block transactions where legally permitted;
• impose limits, reserves or operational controls;
• suspend or terminate access to the services;
• report suspicious or unlawful activity to relevant providers, financial institutions, regulators or authorities where required or permitted.

9. Customer Assumes Commercial and Regulatory Risk

The customer understands and accepts that operating in payments, embedded finance, card issuance, IBAN/account services, digital assets, crypto on-ramp/off-ramp or other regulated or high-risk industries involves substantial commercial, operational, regulatory, legal and reputational risks.

These risks may include fraud and cybercrime, chargebacks and transaction disputes, account freezes or reviews, enhanced due diligence requests, delayed settlements or reserves, changes in law or regulation, third-party offboarding, sanctions exposure, customer complaints and remediation costs, data breaches or operational failures, cross-border restrictions and licensing or authorisation issues.

The customer assumes full responsibility for evaluating and accepting these risks in connection with its business model.

10. Limitation of Liability

To the maximum extent permitted by law, Cash Me shall not be liable for any indirect, incidental, consequential, special, punitive or exemplary damages, including loss of profits, revenue, business, goodwill, data, opportunity, clients, contracts or anticipated savings, arising out of or in connection with:

• the customer’s business operations;
• the acts or omissions of the customer’s end users or clients;
• fraud, abuse, scams or misconduct by third parties;
• service interruptions or technical failures;
• regulatory actions or investigations affecting the customer;
• decisions or actions of third-party providers;
• refusal, blocking, reversal, suspension, reserve imposition or termination of services;
• customer non-compliance with law or provider rules.

Nothing in this section excludes liability that cannot legally be excluded under applicable law.

11. Indemnity

The customer agrees to defend, indemnify and hold harmless Cash Me, its affiliates, directors, officers, employees, contractors, partners and service providers from and against any claims, liabilities, damages, losses, penalties, fines, costs and expenses, including reasonable legal fees, arising from or related to:

• the customer’s breach of these terms;
• the customer’s business activities or business model;
• the acts or omissions of the customer’s end users, merchants, sub-merchants or partners;
• any fraud, misrepresentation, unlawful activity or regulatory breach connected to the customer;
• complaints, disputes, refunds, chargebacks, investigations, enforcement actions or third-party claims caused by the customer’s conduct or that of its clients.

12. No Fiduciary Relationship

Nothing in Cash Me’s services creates any fiduciary, advisory, trustee, agency, partnership or joint venture relationship between Cash Me and the customer, unless expressly agreed in writing.

Cash Me does not act as the customer’s legal adviser, compliance officer, financial adviser, regulated representative or risk guarantor.

13. Customer’s Duty to Provide Accurate Information

The customer must provide complete, accurate and up-to-date information at all times, including ownership information, licensing status, business activities, target markets, jurisdictions, transaction types, expected volumes, websites, policies and supporting documents.

Any omission, misrepresentation, concealment or inaccurate statement may result in rejection, suspension, termination, reporting or other protective action.

14. Right to Refuse or Terminate

Cash Me reserves the right to refuse onboarding, decline any request, restrict use, suspend access or terminate services at any time where, in its reasonable opinion, the customer presents legal, regulatory, fraud, operational, reputational or commercial risk, or where continued service is no longer feasible through Cash Me or its partners.

15. Independent Legal and Compliance Advice

The customer is strongly advised to obtain its own independent legal, regulatory, tax and compliance advice before launching, marketing or operating any financial, payment, card, crypto, custody or cross-border service using Cash Me’s solutions.

Cash Me does not guarantee that the customer’s use of the services is lawful or suitable in any specific jurisdiction or for any specific activity.

16. Governing Law and Jurisdiction

Unless mandatory local law requires otherwise, these Customer Vulnerability terms shall be governed by the laws of the Republic of Lithuania.

Any dispute arising out of or in connection with these terms shall be submitted to the competent courts of Lithuania, unless a separate written agreement provides for a different dispute resolution mechanism or mandatory law requires otherwise.

17. Contact

If you have any questions about these Customer Vulnerability terms, please contact Cash Me through its official communication channels.