These general terms and conditions (the ”Terms”) regulate the use of the app Betalo (the ”App” or ”Betalo”) and other services provided through the app and web by Betalo AB (publ) 559245-2931, (the ”Company”). Please read these terms carefully and contact us if you have any questions.

Betalo is a service that makes it possible to make payments to Swedish Plusgiro and Bankgiro and to Swedish bank accounts (”Domestic payments”). Domestic payments are collectively referred to as ”Payments”. The description in this paragraph is hereinafter referred to as the ”Service”.

The Terms and Conditions apply to the payment service user (”User”) of the Service. By registering for the Service and accepting the Terms, the User and the Company enter into an agreement that entitles the User to use the Service in accordance with the Terms.

1.1 The company holds authorization from the Swedish Financial Supervisory Authority (”FI”) to provide payment services as a payment institution. The company is under FI’s supervision and is subject to, among other things, the regulations established in the Payment Services Act (2010:751) and the Swedish Financial Supervisory Authority’s regulations and general advice on payment institutions and registered payment service providers (FFFS 2010:3).

1.2 Users can access these Terms and information regarding the Service via Betalo’s App, Betalo’s website, or via Betalo’s customer service. Information in accordance with the Payment Services Act (2010:751) is made available to the User in these Terms and is updated continuously in the event of any changes.

2. Notices and language

For the contractual relationship and communication between the User and the Company, the Swedish language is used.

Written notices from Betalo to the User are sent by e-mail to the e-mail address provided by the User when registered and shall be deemed to have been received by the User no later than the following day. Messages that are not considered urgent can alternatively be displayed in the User’s account by logging in to the app.

3. Prerequisites for the Service

3.1 You must be at least 18 years old to create an account with Betalo and use the Service. The service is currently only offered to customers who are registered in Sweden and who have a Swedish social security number. The service is currently not offered to persons with protected personal data. Betalo accepts Payments with the following debit cards, debit cards and credit cards – Visa, Mastercard and, in the case of Payments to PlusGiro/BankGiro, also American Express (”Card”).

3.2 You as a User undertake to notify Betalo if you are or have been a person in a politically exposed position* (”PEP”) and thus have or have held a high political or governmental position, or if you are related and/or known associate of a PEP. Such notification shall be sent to Betalo by e-mail to info@betalo.se and contain information about social security number, address, function, title and country of business or organization regarding you or the PEP to which you are related and/or known employee. You further undertake to notify Betalo of any changes regarding the conditions set out in this section 3.2.

3.3 Betalo offers Domestic payments to both Plusgiro and Bankgiro and thereby offers Domestic payments to all recipients approved as companies in Bankgirocentralen’s (BGC) bankgiro number file and Plusgirot’s number file (Nordea) over companies approved and listed by Swedish banks with associated bankgiro and associated bank account and plusgiro account. Betalo also offers Domestic payments to Swedish bank accounts.

3.4 Betalo does not offer Payments with Plusgiro or Bankgiro to debt collection companies or the Swedish Enforcement Authority. Furthermore, Betalo reserves a discretionary right to refuse Payments to recipients including, but not limited to, banks and credit institutions, to which Betalo from time to time, through customized recipient lists for individual card issuers and through Betalo discretion, does not offer Payments to when using the Service.

3.5 Users who intend to use the Service to make Payments that may exceed SEK 500,000 on an annual basis, must contact Betalo customer service before the Service is used. By accepting the Terms, the User confirms that the Service will not be used for illegal purposes, such as money laundering, terrorist financing or fraud. The Service may also not be used to dispose of, acquire, possess or use funds derived from criminal activities.

4. Execution of payment transactions

4.1 In order for a payment order to be executed correctly, the User must follow the instructions given at the time of payment in the App.

4.2 When making payments, the User is responsible for ensuring that payment information such as the correct Bankgiro/Postgiro number or bank account number of the recipient, OCR number and amount are correctly filled in. Betalo is not responsible for any incorrect payments due to the User having filled in incorrect information or that the recipient cannot place the payment.

4.3 Consent to make a Payment is given at the time of payment by the User. Users who wish to reverse a completed Payment must contact Betalo and make such a request in” logged in” mode in the Betalo app. If it is possible to cancel the Payment, Betalo shall carry through this at the User’s request and refund/credit the User’s Card. A refund can be made if the user contacts Betalo no later than 15 minutes before customer service closes, one (1) banking day before payment day. If the payment has left Betalo, it is the user’s responsibility to contact the recipient about a return. In case of refund, the service fee will not be refunded according to paragraph 8.2.

4.4 A payment order shall be deemed received when the User has approved the Payment and received a confirmation thereof in the form that the payment can be considered pending in the app.

4.5 A Payment is normally made within three (3) but latest (7 banking days). Betalo is not responsible for any delays caused by third parties.

4.6 The User may cancel Payments up to and including one (1) business day before the payment date according to 4.3 above. Users who wish to cancel a Payment should contact Betalo’s customer service in logged in mode with BankId in the Betalo app.

5. Betalo’s responsibility for the execution of Payments

5.1 Betalo is responsible to the User for ensuring that a payment order approved in accordance with the Terms and Conditions that the User has initiated is executed correctly. If the payment order has been executed correctly by Betalo, the recipient is responsible to the User for ensuring that the transaction is delivered correctly.

5.2 If a payment transaction cannot be executed, Betalo shall restore the User’s card balance as soon as possible.

5.3 If a payment transaction initiated by the User is not executed or executed defectively, Betalo shall, at the request of the payer, try as soon as possible to trace the initiated payment transaction and notify the User of the result.

5.4 The Payment Service Providers are liable to their Users for such fees and interest that Users must pay as a result of the payment not being made or executed defectively, provided that Betalo has failed to perform. If the User is responsible for the transaction not being completed, Betalo is not responsible for such fees and interest that the User must pay as a result of the payment not being made or completed inadequately.

5.5 Registered Payments may be refused if the information provided is incorrect and thus not accepted by the banking system. In the event of declined Payments, Betalo will notify the User and credit the amount to the User’s payment source. In this case, the service fee will not be refunded.

6. Responsibilities of the User

6.1 The User is responsible for ensuring that there is coverage for the submitted payment order and that the information provided in the payment order is sufficient and correct.

6.2 The User undertakes to act on its own behalf when using the Service. The User may only use Cards issued in his/her own name. The User may not use the Service to make Payments of bills originating from the Card used to make the Payment.

6.3 The User is responsible for ensuring that sensitive information such as login information, passwords and the like is used and handled in a secure manner and kept secret so that they remain inaccessible to unauthorized persons. If unauthorized transactions from an account holder’s account have been able to be carried out as a result of the account holder not having protected his personal authorization function, the account holder is liable for the amount according to LBT. If unauthorized transactions from an account holder’s account have been able to be carried out as a result of an obligation being disregarded through gross negligence, the account holder is liable for the entire amount.

6.4 The User shall notify Betalo as soon as possible by email if there is reason to believe that an unauthorized person has gained access to or knowledge of passwords and/or other sensitive information about the User’s card. If the User fails to follow the security instructions as above (section 6.3), the User is always liable for damage caused to Betalo charges that arise as a result of unauthorized use of the Service. In case of unauthorized debit of card/account, this must be directly notified to the relevant bank to block the card/account and make a complain about the payment.

6.5 The User shall immediately access and review the information about completed Payments made available to the User by Betalo in the mobile application. The User shall, without undue delay from the time the User becomes aware of unauthorized or incorrect Payments, and no later than 13 months after the debit date, notify Betalo thereof and request correction by making a complaint.

6.6 It is the User’s responsibility to always be updated on any changes to the Terms.

6.7 It is the User’s responsibility that the Betalo App is updated to the latest version available on the Apple App Store and Google Play Store.

7. Exchange rate

7.1 Betalo is not a platform for foreign exchange trade and the User undertakes not to use the Service for such purposes. In the event that Betalo discovers that Users use the Service for such purposes, Betalo may, at its own discretion, cancel Users’ Payments and/or terminate the User’s account. Betalo only carries out transactions in Swedish kronor, why no currency exchange takes place.

8. Fees

8.1. Interest charges

Betalo does not charge the User any cost for interest rates.

8.2 Service fee

Betalo offers a simple pricing model without fixed fees. For payments, Betalo charges a service fee based on the transaction amount. The service fee for each Card is stated on www.betalo.com. Betalo only offers payments in SEK and therefore does not charge any fee for currency exchange.

8.3 Betalo always has the right to make price changes with immediate effect. Current prices are updated continuously on https://www.betalo.com/priser/

9. Processing of personal data

9.1 Betalo is the data controller and processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (”GDPR”). For regulatory reasons, Betalo must save certain data. What these are can be obtained from Betalo’s customer service on request.

9.2 By accepting the Terms, the User agrees that Betalo processes such personal data that is necessary to fulfill an agreement with the User, including; name, address, social security number, e-mail address, IP address, browser, device information, telephone number, information about the User’s Payments and transactions and card details.

9.3 Betalo processes personal data in order to fulfill agreements entered into with Users, for identification of Users, development of Betalo’s services, to safeguard the customer relationship and for internal statistics and for analysis purposes. Where necessary, for example to investigate fraud and abuse of Betalo’s services, Betalo may also use personal data internally for identification purposes. Betalo also processes personal data to fulfill legal obligations, including for accounting purposes and to comply with consumer law and money laundering regulations.

9.4 Personal data may also be used for marketing purposes if the User has consented to such processing or based on a balance of interests.

9.5 Betalo only processes personal data for the purposes for which it has been collected and, where applicable, for other compatible purposes. The processing of personal data will only continue for as long as is justified with regard to the purposes of the processing, and the data will then be deleted without undue delay. Data is also retained to the extent necessary to fulfill legal obligations or to determine, exercise or defend legal claims.

9.6 If it comes to Betalo’s knowledge of unauthorized use of the User’s card or card details, the User will be informed by email.

9.7 For more detailed information about Betalo’s processing of personal data, such as purpose, exercise of the User’s rights, disclosure and transfer of personal data, see Betalo’s privacy policy.

10. Limitation of Betalo’s liability

10.1 Betalo is not liable for damage that may be caused to the User due to faults in electricity supply or telecommunications or Internet connections or other technical equipment that does not belong to Betalo.

10.2 Betalo is not liable for damage caused by law, government action, war event, lockout, strike, boycott and blockade or other unusual or unpredictable circumstance in Sweden or abroad over which Betalo has no influence and the consequences of which would have been impossible for Betalo to avert. The reservation regarding strikes, lockouts, boycotts and blockades applies even if Betalo itself is subject to such conflict action. If there is an impediment for Betalo to make Payments or to take any other action due to circumstances under this paragraph, the action may be postponed until the obstacle has ceased. Damage that may occur in other cases shall not be compensated by Betalo if Betalo has acted with normal care. In no case is Betalo liable for indirect damage.

10.3 Betalo is only responsible for mediating Payments and is not responsible for non-delivery of or errors in goods or services purchased by third parties through the use of the Service. Complaints and other claims that the User wishes to make in such cases shall be directed directly to third parties.

10.4. If a customer violates the Terms, Betalo has an obligation to supervisory authorities to examine whether the business relationship must be terminated. In such cases, Betalo has the right to inform the User of the violation and terminate the business relationship and the User’s account with Betalo with immediate effect. When Betalo receives funds with accountability, these funds are placed with a Swedish bank. Such a bank is appointed by Betalo of its choice. Placement with a bank normally takes place in the name of Betalo on behalf of the User. In doing so, the User’s funds are placed together with other Users’ funds. The User thus understands that his/her funds may be kept in a collection account with a bank. Whether the User has a right in rem protected right of separation in the event that Betalo or the bank should be declared bankrupt or suffer other measures with equivalent legal effects may vary and depends on applicable legislation. In Sweden, the right of separation exists as a general rule, provided that the funds are kept separate from Betalo’s own funds.

11. Additions and amendments

11.1.In addition to what is otherwise stated in the Terms, Betalo has the right to make additions to and/or change the Terms by notifying the User of such additions and/or changes at least two months before the change takes effect. Information about changes to the Terms and Conditions will be provided via the Betalo’s app and/or e-mail to the User and updated Terms and Conditions will be made available on the Betalo’s website. Betalo always has the right to immediately make changes to these terms and conditions.

11.2 It is the User’s responsibility to read the Terms when logging in to the app. The user is deemed to have accepted the relevant Terms when the user has logged in via the app. If the User does not agree to the amended Terms, the User may request to close his/her account by the date on which the changes take effect.

11.3 Betalo always has the right to make such changes to the Terms (including price changes) with immediate effect as are caused by law, regulation or authority decisions.

12. Disputes and choice of law

On these Terms and in the contractual relationship between User and Betalo, Swedish law shall apply. In the event of a dispute, Betalo follows the recommendations of the General Complaints Board. Disputes arising from the Terms between Betalo and a User shall be tried at the Stockholm District Court as the first and only instance.

13. Term and termination

13.1 The Terms apply until further notice.

13.2 The User has the right to terminate the agreement regarding the Service at any time with immediate effect free of charge. The termination must be made in writing to Betalo in logged in mode with BankId through the Betalo app.

13.3 Betalo reserves the right to block the User’s account if there is a risk of an insecure use of the account or suspicion that the account has been used unauthorized. Betalo shall inform the User that the account is blocked and the reasons for such blocking. However, information to the payer may not be provided if it would be incompatible with other law or if it is justified on security grounds not to do so.

13.4 Betalo has the right to terminate the agreement regarding the Service in writing with a notice period of two months.

14. Complaints

In the event that the User wishes to make any complaints regarding the Service, the User shall contact the Betalo’s complaints officer by e-mail to klagomal@betalo.se and state ”Complaints” in the subject line.

Betalo AB (publ)

Org nr 559245-2931

Drottninggatan 33

111 51 Stockholm

* Politically exposed persons

The Act (2017:630) on Measures against Money Laundering and Terrorist Financing (”PTL”) contains certain provisions for establishing business relationships with politically exposed persons (”PEP”), including, among other things, requirements for stricter measures to achieve customer due diligence. The PTL defines PEP as ”a) natural person who has or has had an important public function in a state, and b) natural person who has or has had a function in the management of an international organization”. Furthermore, the measures listed above shall also apply to family members and known associates of a PEP. Finansinspektionen has issued supplementary regulations in this area (FFFS 2017:11).

An important public function refers to a function held by:

1. Heads of State or Government, Ministers and Deputy and Deputy Ministers;
2. members of the Parliament;
3. members of the executive committee of political parties;
4. judges of the Supreme Court, constitutional courts or other high-level judicial bodies whose decisions may be appealed against only exceptionally;
5. senior officials of audit institutions and members of central banks’ governing bodies;
6. ambassadors, heads of mission and senior officers of the armed forces;
7. persons who are members of the administrative, management or supervisory bodies of state-owned enterprises; and
8. persons at the head of international organisations.

Family members refer to:

1. spouse;
2. registered partner;
3. partner;
4. child;
5. children’s spouses, registered partners or cohabiting partners; and
6. parents.

Known employee means:

1. natural person who, as is known or reasonably believed, is jointly with a PEP the beneficial owner of a legal person or legal arrangement or who otherwise has or has had close links with a PEP; and
2. natural person who is the sole beneficial owner of a legal person or legal arrangement which, according to what is known or reasonably believed, has actually been established for the benefit of a PEP.

Close links in paragraph 1 refer to close business relationships and other connections that may cause the known employee to be associated with an increased risk of money laundering or terrorist financing.