Terms and Conditions

GENERAL INFORMATION

SatchelPay, UAB, legal entity code 304628112, registered address at Upes g. 21, Vilnius, Lithuania (the “Satchel”), e-mail address info@satchel.eu is a licensed electronic money institution, license No 87, supervised by the Bank of Lithuania. The supervising authority overseeing activities of Satchel is the Bank of Lithuania. The data about Satchel is collected and stored at the Register of Legal Entities of the Republic of Lithuania.

These General Terms and Conditions (the “General Terms”) apply for the provision of the Services. The General Terms should be treated as the Services’ agreement.

1. Services

1.1. Satchel offers the following services:

a) personal and business accounts;
b) incoming and outgoing transfers in various currencies, including SEPA and SWIFT payments;
c) eWallet services, including loading of eWallets through outside parties;
d) payments by card;
e) cash withdrawals via ATM.

1.2. By approving these Terms and Conditions, the Client also approves

a) Rules for Using Payment Cards;
b) Rules on Investigation of Complaints;
c) Privacy Policy;
d) Acceptable Use Policy;

2. Definitions

2.1. Application means a mobile application for Account management, installed and used in mobile devices.

2.2. Account means an account opened within Satchel in the name of the Client.

2.3. Business Day means a day, when Satchel provides its services, set by Satchel. Satchel can set different business days for different services.

2.4. Client means a natural (personal), business or merchant who has registered in the System and to whom Satchel provides services to.

2.5. Commission Fee – the amount of money charged by Satchel from the Client for provision of Satchel’s Services to the Client.

2.6. Consumer means a natural person who buys Services for his/her personal use.

2.7. Electronic Money means money credited/ transferred to and held on Account for executing Payment Services via the System.

2.8. European Economic Area Agreement means the Agreement on the European Economic Area, which entered into force on 1 January 1994.

2.9. EU Member State means the member state of the European Union.

2.10. Payment Operation means a money transfer, payment or withdrawal initiated by a payer or a payee.

2.11. Payment Order means an order from the Client for the execution of the Payment Operation.

2.12. Payment Service applicable within the context of these terms means: (i) execution of payment transactions, including transfers of funds on a payment account with the payment service provider of the payment service user or with another payment service provider: execution of payment transactions through a payment card or a similar device and/or execution of credit transfers, including standing orders; and/ or (ii) issuing of payment instruments and/ or acquiring of payment transactions; and/ or (iii) money remittance; and/ or (iv) services enabling cash to be placed on a payment account as well as all the operations required for operating a payment account; and/ or (v) services enabling cash withdrawals from a payment account as well as all the operations required for operating a payment account.

2.13. Payment Instrument means any payment instrument which allows to link to the Account and perform payment transfers using this payment instrument.

2.14. Satchel Account means an account opened in the System in the name of the Client and used to keep funds and make payment transfers.

2.15. Services means a service of issuance and redemption of Electronic Money, Payment Services and other services provided by Satchel.

2.16. Online Account means the result of registration in the computer system or Application, during which personal data of the registered Client is saved, a login name is assigned and the rights of the Client in the System are defined.

2.17. System means a software solution on Satchel web page and Application used for provision of Satchel services.

2.18. Password (Passwords) means any code of the Client created in the System or provided to the Client by Satchel for the access to the Online Account and/ or Account or initiation and management of separate services provided by Satchel and/ or initiation, authorization, implementation, confirmation and reception of Services.

2.19. Party means Satchel or the Client (jointly known as Parties).

3. Registration in Satchel system

3.1. The Client who wants to start using the System has to go through the registration process. Satchel onboard the Client remotely. In addition, the description of the Client’s identification procedure is provided within the Rules on Anti-money Laundering and Terrorist Financing Prevention of Satchel.

3.2. The Client obligates to ensure security and secrecy of the Password and the Unique Identifier granted to the Client. In case the Password becomes (or possibly becomes) known to the third parties, the Client obligates to immediately change the Password and/or Unique Identifier.

3.3. The Client obligates to ensure security and secrecy of the details about his/ hers Payment Instrument, including payment card number and Card Verification Value (CVV) code.

3.4. While registering in the System, the Client obligates to provide correct and complete data about himself/ herself during the registration process. The Client obligates to immediately, however, no later than 1 Business Day, inform Satchel about any change of information and documents provided to Satchel during the registration process, including, but not limited to, change of the e-mail, phone, information on the representative and etc.

3.5. Satchel has the right to request the Client additional information and/ or documents related to the operations of the Client and to request the Client to fill such information periodically.

3.6. If the Client does not provide requested information and/ or documents within the terms specified by Satchel, Satchel has the right to suspend the Client registration process.

3.7. After being duly onboarded and granted the access to the account, the Client is obliged to activate the compulsory Two Factor Authentication security feature following the instructions provided in https://satchel.eu/blog/satchel-two-factor-authentication-2fa-user-guide/ If the Two Factor Authentication is not activated within 3 days, Satchel has the right to suspend the account until the Two Factor Authentication is activated.

3.8. The Client might enter into legal relations with Satchel directly and/ or through the Client’s Representatives.

4. Payment Services and account Opening Rules

4.1. Account allows the Client to deposit, transfer, keep funds in the Account for transfers, local and international money transfers executions, contribution payments, also receive money to the Account, settle for goods and services, and perform other operations directly related to money transfers.

4.2. Money held on the Client’s Account is considered Electronic Money which Satchel issues after the Client transfers or deposits money to his/ her Account. After the Client deposits/ transfers money to his/ her Account and Satchel receives the money, Satchel credits it to the Client’s Account, at the same time issuing Electronic Money at the nominal value. The Electronic Money is credited to and held on the Client’s Account.

4.3. The specific method of depositing/ transferring funds to the Account is selected by the Client in the Online Account by selecting the “Funding instructions” section, which contains instructions for depositing money for each method of payment.

4.4. The nominal value of Electronic Money coincides with the value of money deposited/ transferred to the Account (after deduction of standard Commission Fee appropriate for a particular payment method, if applicable).

4.5. Electronic Money held on the Account is not a deposit and Satchel does not, in any circumstances, pay any interest for Electronic Money held on the Satchel Account and does not provide any other benefit associated with the time period the Electronic Money is stored.

4.6. At the request of the Client, Electronic Money held on his/ her Account shall be redeemed at their nominal value at any time, except for cases set forth in the General Terms.

4.7. The Client submits the request for redemption of Electronic Money by generating a Payment Order to transfer Electronic Money from his/ her Account to any other account specified by the Client or withdrawing Electronic Money from his/ her Account by other methods supported by Satchel and indicated in the System. Satchel has the right to apply limitations for redemption of Electronic Money.

4.8. No specific conditions for Electronic Money redemption that would differ from the standard conditions for transfers and other Payment Operations performed on the Account shall be applied. The amount of redeemed/ transferred Electronic Money is chosen by the Client.

4.9. No additional fee for Electronic Money redemption is applied. In the event of redemption of Electronic Money, the Client pays the usual Commission Fee for a money transfer or withdrawal which depends on the method of Electronic Money transfer/ withdrawal chosen by the Client. Standard Satchel Commission Fees for money transfer/ withdrawal are applied.

4.10. Provided that the Client terminates the General Terms and agreements concluded, and applies with the request to close his/ her Account and delete his/ her Online Account from the System, or Satchel terminates the provision of Services, money held on the Client’s Account shall be transferred to the bank account or to the account within other electronic payment system indicated by the Client. Satchel has a right to deduct first the funds that belongs to Satchel (fees for Services provided by Satchel and other unpaid amounts, including but not limited to, fines and damages incurred by Satchel due to the breach of the General Terms or other obligations committed by the Client, which have been imposed by international payment card organizations, other financial institutions and/ or state institutions). In the event of a dispute between Satchel and the Client, Satchel has the right to detain money under dispute until the dispute is resolved.

4.11. The Commission Fees for special categories of Clients may differ from the standard Commission Fees. The aforementioned categories of Clients are determined in Satchel’s policies.

4.12. Satchel reserves the right not to open an account and/ or close an account without providing a reason.

4.13. To use Payment services via Satchel System the Client’s equipment shall be in compliance with the following minimum system requirements:

4.13.1. Desktop: Minimum: Processor: Intel Core i3 or better Memory: 2 GB RAM;

4.13.2. OS: Windows 7 / Linux up to date distro Browser: Firefox / Chrome / Edge;

4.13.3. Mobile devices: iOS 10 or higher / Android 6.0 or higher.

5. Usage of the Account

5.1. The Client may manage the Account via the internet by logging in to his/her Online Account with his/her login name and Password or via Application.

5.2. Payment Transfers from the Client’s Account may be executed:

5.2.1. to another user of the System;

5.2.2. to the Lithuanian, EU and foreign bank accounts (except for banks in foreign countries to which the Payment Transfers are forbidden; Satchel informs the Client about such countries in the System);

5.2.3. to accounts in other electronic payment systems specified in the System;

5.3. Funds may be transferred to the Account in different currencies. The Client will be shown the currency exchange rate valid at the moment of conversion before making any transaction in a different currency within the System. The exchange rate is constantly updated on the System.

5.3.1. Satchel ensures that for payment transactions in euros, initiated within the Republic of Lithuania or to other member states, the transaction amount will be credited to the recipient’s payment service provider’s account no later than the end of the next working day following the receipt of the payment instruction.

5.3.2. When credit transfers in the Republic of Lithuania are made in euros, the payer’s payment service provider must ensure that after receiving the payment order, the amount of the payment transaction is credited to the recipient’s payment service provider’s account on the same working day, if the payment order is received before 12 o’clock on that working day. If the moment of receipt of the payment order is after 12 o’clock, the payer’s payment service provider must ensure that the amount of the payment transaction is credited to the payee’s payment service provider’s account no later than the next business day.

5.3.3. For transactions in non-eurozone member state currencies conducted within the Republic of Lithuania or to other member states, Satchel is entitled to complete the transaction within a period not exceeding four working days.

5.3.4. For payment transactions in currencies that are not currencies of EU/EEA Member States, or for payment transactions to recipients located outside the EU/EEA, the execution time limits set out in Clauses 5.3.1–5.3.3 do not apply

5.3.5. Additionally, the time limits do not apply in case that any data required to proceed the transaction which was given to Satchel by the Client, is erroneous.

5.3.6. Satchel is committed to adhering to the specified time limits for processing transactions as detailed in General Terms. However, these time frames may not apply in instances where Satchel undertakes Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) activities or conducts investigations into specific transactions. In such circumstances, Satchel will ensure that the transactions are executed within a reasonable period of time, without undue delay, to maintain compliance with regulatory requirements and safeguard the integrity of our financial operations.

5.4. A bank or another electronic money transfer system may apply fees for transferring money from/ to Client’s Account to the Client’s bank account, card or a payment account of another electronic payment system.

5.4.1. Satchel may charge additional fees if received funds have to be converted to another currency before it is possible to credit them to the Client’s account. The Client will be informed about additional fees in advance.

5.5. Fees for the Services of Satchel are deducted from the Client’s Account. In case the amount of money on the Account is less than the amount of the Payment Transfer and the price of the Service of Satchel, the Payment Transfer is not executed.

5.6. In case the Client indicates incorrect data of the recipient and the Payment Order is executed according to the data provided by the Client (e.g. the Client indicates a wrong account number), it shall be considered that Satchel has fulfilled its obligations properly and shall not repay the transferred amount to the Client. The Client shall directly contact the person who has received the transfer regarding the return of the money.

5.7. The Client is obliged to provide a Payment Order for the execution of the Payment Transaction in accordance with the instructions specified in the System and valid at the moment of transfer.

5.8. If the Payer submits an incorrect Payment Order or indicates incorrect data for the Payment Transfer, but the Payment Transfer has not been executed yet, the Client may request to correct the Payment Order.

5.9. If Satchel cannot credit funds indicated in the Payment Order to the recipient due to errors of the Client made in the Payment Order, the Payment Order may be cancelled and funds may be returned to the Client if it is technically possible.

5.10. In all cases, when Satchel receives a Payment Order but funds cannot be credited due to errors in the Payment Order or insufficiency of information, Satchel undertakes all possible measures to track the Payment Operation in order to receive accurate information and execute the Payment Order.

5.11. The Client, having noticed that money has been credited to his/ her Account by mistake or in other ways that have no legal basis, is obliged to notify Satchel about it immediately, however, no later than within 1 Business Day after noticing the wrongly credited money. The Client has no right to dispose of money that does not belong to him/ her. In such cases Satchel has the right and the Client gives an irrevocable consent to deduct the money from the his/ her Account without the Client’s order. If the amount of money on the Client’s Account is insufficient to debit the money credited by mistake, the Client unconditionally commits to repay Satchel the money credited by mistake in 3 (three) Business Days from the receipt of such request from Satchel.

5.12. The Client has the right to change the limits on Payment Transfers for the Account by completing an additional Online Account confirmation in accordance with the procedure established in the System and setting other limits for transfers by completing an additional confirmation. The Client may set the limits at his own discretion, however Satchel has the right to limit the size of the limits at any time. The Client may check the applied limits in the System. The Client will be notified about the limit’s entry into force by e-mail and through the System.

5.13. The Client may check the Account balance and history by logging in to the Online Account or the Application. The Client can also find information about all applied fees and other fees deducted from the Account of the Client during a selected period of time.

5.14. The Client’s confirmations, orders, requests, notifications and other actions performed through websites of third persons or other places by logging in to his/ her Account and identifying himself/ herself in this way are treated as conclusion of an agreement.

5.15. The management of the Account via the internet:

5.15.1. In order to execute a Payment Operation via the internet, the Client must fill in a Payment Order in the System and submit it for execution, electronically confirming in the System his/ her Consent to execute the Payment Order.

5.15.2. Submission of the Payment Order in the System is an agreement of the Client to execute the Payment Operation and cannot be cancelled (cancellation of the Payment Order is only possible until the execution of the Payment Order has been started – status of the Payment Order and possibility of cancellation are visible on the Online Account of the Client).

5.15.3. In case the amount of money on Account of the Client is insufficient to execute the Payment Transfer, the Payment Transfer is cancelled. The Client can file in the Payment Order again once the amount of money on Account becomes sufficient. If the amount of money on Account is insufficient in one currency, but there is a sufficient amount of money in another currency, the Payment Transfer shall not be executed until the Client converts other currency to the currency of the payment (except for cases, when the Client has ordered an automatic currency exchange feature or the transfer is intended for paying for goods or services via System).

5.16. The Payment Order (from the Account opened within Satchel to the other Account opened within Satchel) is considered received (calculation of the time period of execution of such Payment Order starts) on the day of its reception, or, if the moment of reception of the Payment Order is not a Business Day, the Payment Order is considered received on the nearest Business Day.

5.17. The Payment Order (outside the System) which was received by Satchel on a Business Day but not on business hours set by Satchel, is considered received on the nearest Business Day of Satchel.

5.18. All of the Payment Orders that the System receives are placed in a priority-based queue. Subsequently, Payment Orders are executed according to the queue, with execution occurring either immediately or as soon as preceding Payment Orders are completed.

5.19. Satchel has the right to record and store any Payment Order submitted by any of the means agreed on with Satchel, and to record and store information about all Payment Operations performed by the Client or according to Payment Orders of the Client. Records mentioned in the present clause may be submitted by Satchel to the Client and/ or third persons, who have the right to receive such data under the basis set forth in the legislation, as evidence confirming the submission of Payment Orders and/ or executed Payment Operations.

5.20. Payment Orders submitted by the Client shall comply with requirements for submission of such Payment Order and/ or content of the Payment Order set by the legal acts or by Satchel. Payment Orders submitted by the Client shall be formulated clearly, unambiguously, shall be executable and contain clearly stated will of the Client. Satchel does not undertake responsibility for errors, discrepancies, repetitions and/ or contradictions in Payment Orders submitted by the Client, including but not limited to, correctness of requisites of the Payment Order submitted by the Client. If the Payment Order submitted by the Client does not contain enough data or contains deficiencies, Satchel, regardless of the nature of deficiencies in the Payment Order, can refuse to execute such Payment Order, or execute it in accordance with data given in the Payment Order.

5.21. Satchel has the right to refuse to execute a Payment Order in case of a reasonable doubt that the Payment Order has been submitted by the Client or an authorized representative of the Client, Payment Order or the submitted documents are legitimate. In such cases, Satchel has the right to demand from the Client to additionally confirm the submitted Payment Order and/ or submit documents confirming the rights of persons to manage the funds held on the Account or other documents indicated by Satchel in a way acceptable to Satchel at expense of the Client. In cases mentioned in this point, Satchel acts with the aim to protect legal interests of the Client, Satchel and/ or other persons, thus, Satchel does not undertake the responsibility for losses which may arise due to the refusal to execute the submitted Payment Order.

5.22. Before executing the Payment Order submitted by the Client, Satchel has a right to demand from the Client documents which prove the legal source of money related to the Payment Order. In case the Client does not submit such documents, Satchel has the right to refuse to execute the Payment Order of the Client.

5.23. Satchel may use intermediary financial institutions to execute the Client’s Payment Orders. Satchel’s liability for proper execution is governed by Clause 12.19 and the Law on Payments. If an intermediary suspends or delays a Payment Order, Satchel will, on the Client’s request and free of charge, trace the payment and inform the Client of the outcome.

Satchel may also suspend or refuse a Payment Order if (i) required by applicable law, including AML/CTF, sanctions or fraud-prevention requirements, (ii) the Payment Order is incomplete or unverifiable, or (iii) abnormal circumstances beyond Satchel’s reasonable control prevent execution. In all such cases Satchel will notify the Client of the reason without undue delay, where permitted by law.

5.24. In case Satchel has refused to execute the Payment Order submitted by the Client, Satchel shall immediately inform the Client thereon or create necessary conditions for the Client to get acquainted with such notification, except when such notification is technically impossible or forbidden by legal acts.

5.25. Satchel shall not accept and execute Payment Orders of the Client to perform operations on the Account of the Client if funds on the Account are arrested, the right of the Client to manage the funds is otherwise legally limited, or in case operations are suspended by applicable legal acts.

5.26. If money transferred by the Payment Order is returned due to reasons beyond the control of Satchel (inaccurate data of the Payment Order, the account of the recipient is closed, etc.), the returned amount is credited to the Account of the Client. Fees paid by the Payer for the Payment Order execution are not returned, and other fees related to the returning of money and applied to Satchel can be deducted from the Account of the Client.

5.27. Where Satchel reasonably suspects that an incoming payment is connected to fraud, money laundering, terrorist financing, sanctions violations or other unlawful activity, or where Satchel is required to do so by applicable law or by instructions of competent authorities, Satchel may return the payment to the payer’s payment service provider in accordance with Article 51(3) of the Law on Payments. Where verifiable third-party costs (such as SWIFT confirmation or intermediary bank fees) are incurred in connection with the return, such costs may be deducted from the returned amount before it is sent back, in line with the Pricing.

5.28. The Client agrees that Satchel will transfer Personal Data of the Client to persons directly related to the execution of the Payment Operation, such as international payment card organizations, companies processing information about payments by payment cards, the provider of Payment Services of the recipient, the operator of the payment system for execution of the Payment Operation, intermediaries of the provider of Payment Services of the Client and the recipient.

5.29. If necessary and/ or required by institutions of other states, Satchel has the right to receive additional information (e.g. name and surname/ title of the Payee, a payment code) required for the appropriate execution of the Payment Order.

5.30. When executing Payment Orders initiated by the Client, Satchel shall transmit to the Payment Service provider the information (including Personal Data of the Client) specified by the Client in the Payment Order.

5.31. In case of the death of the Client (where a client is a natural person), the Account of the Client will be closed and the funds held by the Client will be transferred to the account indicated by the successor. The actions indicated in this Clause will be implemented following the procedure provided under the applicable laws.

5.32. Satchel will charge all appropriate fees related to the closure of the Account. If no successor claims the remainder of the funds (i.e. it is not indicated where the funds should be transferred) in the Account within 12 months, Satchel will also charge the funds in the Account with a 0.15% daily fee.

5.33. The Client agrees that Satchel, when providing Services, may use services by the counterparties (including but not limited to, banks, electronic money institutions, payment institutions and other financial institutions). Satchel is entitled to attract the counterparties for the provision of Services without prior agreement with the Client.

5.34. Certain clients may be subject to the advance payment requirement which allows Satchel a better protection against possible risks and expenses associated with particular Accounts. Satchel notifies such Clients of the requirement and the advance payment is only imposed with prior agreement by the Client.

5.34.1. Advance payment is kept for 45 calendar days after the Account has been closed. If additional expenses associated with the Account emerge after the Account has been closed, Satchel may retain the advance payment longer than 45 calendar days. Satchel also has a right to charge emerged expenses from the advance payment. If the amount of the advance payment is not enough, Satchel might claim other expenses appeared from the activity of the Client in the court.

5.34.2. Satchel may release the advance payment before the Account is closed.

5.34.3. Satchel does not pay any interest on advance payment.

6. Pricing

6.1. Standard Pricing. The standard pricing of Satchel’s Services (the “Pricing“) is published on https://satchel.eu/fees/ and forms part of these General Terms.

6.2. Individually agreed pricing. Satchel may apply pricing terms different from the standard Pricing where individually agreed with the Client or communicated by Satchel or its authorized commercial representative to and accepted by the Client at onboarding, including terms reflecting the Client’s profile, the Services used, transaction volume or due diligence outcomes. Such individual pricing forms part of these General Terms and prevails over the standard Pricing.

6.3. Amendment of Pricing. Satchel may unilaterally amend the Pricing by giving the Client 60 (sixty) calendar days’ prior notice through the System or another agreed communication channel. The Client may terminate the Agreement free of charge before the new Pricing takes effect; otherwise the amendments are deemed accepted.

6.4. Payment of fees. Fees payable by the Client are deducted from the Account balance in EUR. Where the Account does not hold sufficient funds in EUR, Satchel may convert funds from another currency held on the Account to EUR using the exchange rate published in the System. Where the Account holds Electronic Money in a non-EUR currency, Satchel may convert it to EUR for the purpose of paying fees.

6.5. Sufficient balance. The Client shall ensure that the Account holds sufficient funds to pay fees as they fall due. If a fee remains unpaid after the due date, Satchel may charge interest on the overdue amount at the statutory default interest rate established under the Civil Code of the Republic of Lithuania.

6.6. Refunds. All fees paid to Satchel are non-refundable. The only exception is that, where the Client has paid the monthly account maintenance fee in advance for the current billing period and the Agreement is terminated before that period ends, the proportional unused part of that monthly fee shall be refunded to the Client in accordance with Article 15(8) of the Law on Payments. For the avoidance of doubt, no refund is made of: (a) account opening, activation, setup, due diligence, KYC verification, onboarding or any other one-time fees; (b) card issuance, replacement or delivery fees; (c) transaction-based fees, currency conversion fees and third-party costs; and (d) fees charged under individually agreed pricing arrangements, the refundability of which is governed exclusively by the terms of such arrangement.

7. Prohibited actions

7.1. The Client is prohibited to:

7.1.1. violate the rights of Satchel to trademarks, copyrights, commercial secrets and other intellectual property rights;

7.1.2. provide false, misleading or incorrect information;

7.1.3. refuse to provide information requested by Satchel;

7.1.4. transfer and/or receive money acquired in illegal manner;

7.1.5. refuse to cooperate with Satchel in investigation of violations;

7.1.6. spread computer viruses and undertake other measures which could cause System malfunctions, damage or destroy information, as well as cause other damage to systems, equipment or information;

7.1.7. undertake any other deliberate measures which could cause System malfunctions, damage or destroy information, as well as cause other damage to systems, equipment, information or third parties;

7.1.8. organise illegal gambling, trade of guns, drugs, prescription medicine, steroids, pornographic production, unlicensed lottery, illegal trade of software or other products or services prohibited by the law;

7.1.9. provide financial services without a prior consent of Satchel;

7.1.10. provide services which are prohibited by the laws or conflict with the public order and/ or good morals.

8. Communication

8.1. The Client confirms that he/ she agrees with provision of communication by Satchel on the System. The Client confirms that communication presented in through the System shall be considered submitted properly. It is considered that the Client has received notification within 24 (twenty four) hours after they have been published on the System.

8.2. All communication between the Client and Satchel shall be performed in the language to which the Client and Satchel agreed.

8.3. The Client obligates to keep telephone number, email address and other information submitted while creating Satchel Account up to day and immediately, however, no later than within 5 Business Days inform Satchel about any change.

8.4. The Client also confirms that he/ she has an access to the internet and agrees that Satchel may provide Clients with non-confidential and/ or not personally addressed information by publishing it on the website www.satchel.eu

8.5. Satchel are able to change the information on their website at any time. Satchel also have no obligations to notify Clients about such changes.

8.6. Under the request by the Client, Satchel will provide the Client with the copy of the agreement (i.e. the General Terms and other documentation) on paper or in another durable medium.

8.7. The durable medium provided by Satchel according to the clause 8.6. of the General Terms shall comply with the following requirements:

8.7.1. the durable medium shall be addressed personally to the Client;

8.7.2. the technical characteristics of the durable medium shall allow the Client to store it as well as to have an access to it during the period adequate for the purpose of the information disclosure; 8.7.3. the technical characteristics of the durable medium shall allow the Client the unchanged reproduction of the information stored in the durable medium.

9. Client Information

9.1. Satchel attaches the supreme importance to privacy and adopts severe rules of confidentiality about current and former Clients. Satchel 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 required by the law.

9.2. Satchel 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.

9.3. Satchel cannot guarantee that the information sent over the Internet when using the Satchel website is totally secure. Clients provide information at their own risk.

9.4. Satchel stores the personal information about the Client and history of transactions as required by law. Closing a Satchel Account does not result in the annulation of such data, unless the Client requests such annulation in pursuit of his/her legal rights.

10. Amendments. Termination of the agreement

10.1. These General Terms are subject to change at any time in order to: 10.1.1. reflect new business, legal requirements and other developments affecting Satchel; 10.1.2. make the General Terms more clear for the Clients and, if needed, to correct any mistakes; 10.1.3. ensure reasonable and competitive business operations; 10.1.4. represent changes in market conditions, banking practices or cost of services.

10.2. Satchel shall notify the Client about any change of General Terms through the System no later than 60 (sixty) Business Days through authorized communication channels before intended changes. Information about the intended changes will be also announced on the website and Application of Satchel.

10.3. If the Client does not agree to the amendments or supplements proposed by Satchel, the Client may terminate the Agreement at any time before the proposed effective date of the changes by sending a notice through Satchel’s System. The legal effect of termination of the Agreement shall take effect on the date specified in the Client’s notice. Satchel shall complete the operational closure of the Account within a reasonable time after receiving the notice. The reasonable time required for operational closure does not affect or postpone the legal termination of the Agreement, and may include time necessary to (i) settle any pending payment transactions, (ii) complete any required anti-money laundering, sanctions, fraud-prevention or other regulatory checks, (iii) resolve any outstanding disputes or claims relating to the Account, and (iv) deduct any fees, charges or other amounts owed to Satchel. The remaining balance of the Account shall be transferred to the Client in accordance with Clause 4.10.

10.4. The notification period shall not apply and notification shall not be provided where: 10.4.1. General Terms were changed due to changes in laws; 10.4.2. the costs of the Services are reduced; 10.4.3. General Terms are changed in a way that put the Client in a more favourable position. 10.4.4. The Client agrees to review the General Terms periodically to be aware of such changes and continued access or use of Satchel Systems will proceed under Client’s acceptance of the modified General Terms.

10.5. The Client is entitled to terminate relations, including concluded agreements with Satchel, at any time by giving Satchel 30 (thirty) days’ prior notice through the System. Where the Client requests an earlier termination date, Satchel shall consider the request in good faith and may, where its operational capacity allows and provided that all pending payment transactions have been completed, payment instruments closed and any required anti-money laundering, sanctions and regulatory checks finalised, agree to terminate the relationship earlier than the 30-day notice period. Where applicable, termination fees may only be applied if the Agreement has been in force for less than 6 (six) months and such fees are proportionate and agreed in advance.

10.6. Satchel may terminate the Agreement and close the Account with immediate effect if any of the following occurs:

(a) the Client materially or repeatedly breaches the Agreement;

(b) the Client provides false, misleading or incomplete information, or refuses to provide information reasonably requested by Satchel;

(c) Satchel has reasonable grounds to suspect that the Account is being used for fraud, money laundering, terrorist financing, sanctions evasion or any other unlawful activity;

(d) continuing to provide the Services would expose Satchel to legal, regulatory, financial or reputational risk that cannot reasonably be mitigated;

(e) Satchel is required to terminate by law, court order or by a binding instruction of a competent authority.

10.7. Satchel is entitled to terminate relations, including concluded agreements (without any reason) with the Client, with a prior 60 (sixty) days’ notice.

10.8. The agreement for the provision of the Services is concluded for the unlimited period of time.

11. Suspensions of services

11.1. Satchel may suspend or restrict the use of a Payment Instrument or the provision of Payment Services where objectively justified and proportionate reasons exist, including:

(a) reasons related to the security of the Payment Instrument or the Account, including where personalised security features have or may have been compromised;

(b) suspected unauthorised, fraudulent or unlawful use of the Payment Instrument, the Account or the Services, including suspected use for money laundering, terrorist financing, sanctions evasion or other unlawful activity;

(c) where any ground for immediate termination set out in Clause 10.6 may apply, pending Satchel’s investigation;

(d) where suspension or restriction is required by applicable law or by an instruction of a competent authority.

Any suspension or restriction shall be applied only to the extent and for the time necessary, and shall be lifted as soon as the reasons for it no longer exist. Where the reasons for suspension are not resolved within a reasonable time, Satchel may terminate the Agreement under Clause 10.6.

11.2. Measures indicated in Clause 11.1 of the General Terms can be applied in the following cases:

11.2.1. if the Client violates the General Terms and/ or the suspicion arises that the Client violated the General Terms;

11.2.2. actions of the Client can harm reputation of Satchel or might cause losses, monetary sanctions or other negative consequences to Satchel;

11.2.3. provided payment instruction is incomplete and/ or incorrect;

11.2.4. the circumstances beyond the control of Satchel have occurred;

11.2.5. cases laid down by the applicable laws;

11.2.6. Satchel become aware of the Client’s death, lack of legal capacity, bankruptcy or an insolvency;

11.2.7. Satchel become aware of the dispute over the operation of Client’s account or Client’s ownership of funds on the Account or that an interest in Client’s account has been claimed by a third party;

11.2.8. Satchel have grounds to believe that the Client or related third persons behave in an incorrect manner towards the officials of Satchel (e.g. in a frightening, threatening or aggressive manner);

11.2.9. Satchel have grounds to think that the Client or related third persons have used or are still using business Accounts, while the competency of the person, that represents particular legal entity raises doubts;

11.2.10. Satchel have reasons to believe that the Client, or payments in or out of his Account, are subject to an international payments sanction regime;

11.2.11. Satchel have grounds to think that Client or related third persons have used or are using the Account illicitly or fraudulently;

11.2.12. the Client is failing to provide to Satchel the information and/ or documentation required under these General Terms to enable the provision of the services either when required or in a form, which is acceptable to Satchel;

11.2.13. the Client’s Account has never been used, or has not been used for an extended period of time;

11.2.14. Satchel have a reasonable confirmation concerning the dishonestly of the Client’s action; 11.2.15. Satchel have reasons to believe that there is a legal requirement to terminate relations with the Client, or a court or any other authority requires suspending or restricting the operation of the account or the provision of any other services;

11.2.16. Satchel reasonably suspects an unauthorized or fraudulent use of money on the Account and/ or the Payment Instruments.

11.3. Satchel shall inform the Client about the suspension of the Payment Instrument and the reasons for it before the suspension or immediately thereafter, unless such notification would compromise security or is prohibited by applicable law or instructions of supervisory authorities.

11.4. In case Satchel reasonably suspects that someone has hacked System and/ or Account and/ or Online Account and/ or Satchel suspects that there is a possible breach of the requirements under the applicable laws, Satchel has a right to immediately suspend the provision of some or all Services to the Client without a prior notification.

11.5. Suspension and/ or termination of the Services does not exempt the Client from the execution of all responsibilities to Satchel which have arisen till the termination.

11.6. When concluded agreements between the Client and Satchel are terminated, the Client shall choose a method for redemption of his/ her Electronic Money. The Client obligates to perform all necessary actions to redeem Electronic Money. In case the Client does not choose a method to redeem his/ her Electronic Money and/ or does not perform necessary actions to redeem his/ her Electronic Money, Satchel can redeem Electronic Money of the Client by the method of redemption of Electronic Money which is available at the moment of redemption.

11.7. Satchel can suspend Client’s access to Services without any prior notice in case the validity of the authorisation of the Client’s representative has expired or his/ her authorisation has been cancelled and Satchel was not identified about renewal of authorisation.

12. Liability of the parties

12.1. Each Party is liable for all fines, forfeits and other losses which the other Party incurs due to violation of the General Terms, other internal rules and/or agreements concluded by the guilty Party. The guilty Party undertakes to reimburse direct damage incurred to the affected Party. In all cases, Satchel’s liability is subject to the following:

12.1.1. Satchel shall be liable only for direct and proved damages caused by Satchel’s direct and essential breach of the General Terms, including breach of time limits for execution of Payment Operations, and only for damages which Satchel could have foreseen at the time of the breach;

12.1.2. Satchel shall not be liable for the Client’s loss of profit, loss of reputation, loss or failure of the Client’s business, or any other indirect damages;

12.1.3. The limitations in this Clause 12.1 do not apply where prohibited by mandatory law.

12.2. The Client shall hold Satchel and its partners harmless from any claim, expense or cost (including legal expenses and fines) that Satchel incurs due to the Client’s breach of the General Terms or applicable law. Satchel shall inform the Client about the total amount of any such claim, expense or cost.

12.3. Satchel does not guarantee uninterrupted operation of the System, as System operation may be affected by factors beyond Satchel’s control. Satchel shall use reasonable efforts to ensure smooth System operation, but shall not be liable for consequences of System disorders that occur without Satchel’s fault.

12.4. Temporary limitations of access to the System (not exceeding 24 hours) for maintenance, development or similar reasons, where Satchel notifies the Client at least 2 (two) Business Days in advance, shall not be considered System operation disorders.

12.5. Satchel’s mandatory liability under Clauses 12.7–12.9, 12.11–12.12 and 12.17–12.20 always applies. Subject to that, Satchel is not liable for:

(a) acts or omissions of merchants, payees or other counterparties of the Client;

(b) consequences of Satchel’s lawful suspension or termination of the Services;

(c) loss caused by the Client’s failure to keep Account information up to date;

(d) Satchel’s compliance with mandatory legal obligations or instructions of competent authorities;

(e) any indirect or consequential losses, including loss of profit, business or reputation, unless prohibited by mandatory law.

12.6. The Client is fully liable for correctness of data, orders and documents submitted to Satchel.

12.7. If the Client denies having authorised a Payment Operation or claims that a Payment Operation was executed improperly, Satchel shall prove that the Payment Operation was authenticated, properly recorded and not affected by any technical or other glitches.

12.8. The Client bears losses arising from unauthorized Payment Operations up to a maximum of 50 (fifty) EUR where such losses result from the use of a lost or stolen Payment Instrument or from the illegal acquisition of a Payment Instrument.

12.9. Client liability for unauthorized transactions.

(a) The Client bears losses up to 50 (fifty) EUR until notifying Satchel of the loss, theft or unauthorized use of the Payment Instrument; after notification, no further losses, unless acting fraudulently. The 50 EUR cap does not apply where the Client acted fraudulently or with intent or gross negligence.

(b) Satchel may investigate any reported unauthorized transaction. The Client shall cooperate in good faith and provide reasonable supporting evidence (police report, written statement, device or login data, or similar) within a reasonable time. Satchel may refuse the refund if the Client refuses to cooperate, gives false information or fails to provide evidence.

(c) If Satchel has reasonable grounds to suspect fraud and reports it to competent authorities, Satchel may withhold the refund pending investigation. Otherwise, Satchel refunds under Clause 12.17 and may recover the amount if fraud, intent or gross negligence is later established.

12.10. If the Client’s actions cause Satchel to incur losses, fines or legal costs, Satchel may debit the Client’s Account for the amount. If the Account balance is insufficient, Satchel may pursue the matter in court.

12.11. From the moment the Client notifies Satchel to block the Payment Instrument, Satchel shall bear any subsequent losses incurred due to the lost, stolen or illegally acquired Payment Instrument, except where the Client acted in bad faith.

12.12. If Satchel fails to provide the means for the Client to immediately notify of a lost, stolen or illegally acquired Payment Instrument, Satchel shall bear the losses arising from unauthorized use, except where the Client acted in bad faith.

12.13. The provisions implementing consumer protections under the Law on Payments (in particular Articles 36, 39, 41 and 51) apply only to Clients who are consumers. Where the Client uses the Account for business, commercial or professional purposes, those provisions do not apply and Satchel’s liability is governed by the remaining provisions of these General Terms and applicable law.

12.14. The Client shall check the Account at least once a month and notify Satchel of any unauthorized or improperly executed Payment Operation, or any error in the statement, without undue delay and no later than 13 (thirteen) months from the date of the relevant debit or credit. The Client shall cooperate with any investigation conducted by Satchel.

12.15. A Party is relieved from liability for failure to comply with these General Terms where it proves that performance was prevented by force majeure as established by law. The Client shall notify Satchel of any force majeure event in writing within 10 (ten) calendar days of its occurrence.

12.16. The Client is solely and fully liable for the payment of taxes (or any state duties) in the Client’s country of tax residency, and for the registration or declaration of the Account in accordance with the laws of that country.

12.17. Refund of unauthorized payment transactions. This Clause applies where the Client did not give consent to the payment transaction (for example, where a Payment Instrument is lost, stolen or used by an unauthorized third party).

Satchel shall, immediately and no later than by the end of the next business day after becoming aware of or being notified of the transaction, refund the amount and, where applicable, restore the Account balance to the position it would have been in had the unauthorized transaction not taken place. The Client shall notify Satchel without undue delay and no later than within 13 (thirteen) months from the debit date. Satchel shall not be obliged to refund where it has reasonable grounds to suspect fraud and reports such suspicion to the competent authorities in accordance with applicable law.

12.18. Refund of authorized transactions with unexpected amounts. This Clause applies where the Client gave consent to the payment transaction (for example, a recurring subscription, a hotel pre-authorization or another transaction initiated by or through a payee where the amount may vary), but the executed amount exceeded what the Client could reasonably have expected.

The Client shall be entitled to a refund where: (i) the exact amount was not specified at the time of authorisation, and (ii) the executed amount exceeded what the Client could reasonably have expected, taking into account the Client’s previous spending pattern and the circumstances of the case (excluding currency conversion).

The Client must request the refund within 8 (eight) weeks from the debit date and provide supporting evidence at Satchel’s request.

Satchel shall, within 10 (ten) business days of receiving the request, either refund the full amount or provide a reasoned justification for refusal and inform the Client of the dispute resolution bodies the Client may apply to.

12.19. Outgoing payments. When the Client sends a payment from the Account, Satchel is responsible for making sure the payment reaches the recipient’s payment service provider on time. If a payment is not executed, is executed late or is executed incorrectly, Satchel shall:

(a) refund the amount of the payment to the Account without undue delay;

(b) restore the Account balance to the position it would have been in if the error had not occurred;

(c) make sure the Client does not incur any losses related to interest payable to or receivable from Satchel; and

(d) refund any commissions and interest charged to the Client as a result of the failed or late payment.

Satchel will not be liable where

(i) Satchel can prove that the recipient’s payment service provider received the amount on time, or (ii) the Client provided an incorrect unique identifier (such as an IBAN or account number).

If an incorrect unique identifier was provided, Satchel will make reasonable efforts to trace and recover the funds and may charge a recovery fee under the Pricing. The Client may ask Satchel at any time to trace a missing or incorrectly executed payment. Satchel will do this immediately and free of charge and notify the Client of the outcome, regardless of whether Satchel is liable.

12.20. Incoming payments. When a payment is sent to the Account, Satchel shall:

(a) credit the amount to the Account immediately and make the funds available for the Client’s disposal, in line with Article 46 of the Law on Payments;

(b) if Satchel has received the payment but cannot credit it to the Account for reasons beyond Satchel’s control, return the amount to the payer’s payment service provider within 2 (two) business days;

(c) ensure that the Client does not incur any losses related to interest in case of late execution; and

(d) where the Client initiates a payment as payee, pass the payment order to the payer’s payment service provider without undue delay.

The Client may ask Satchel at any time to trace a missing or incorrectly executed incoming payment. Satchel will do this immediately and free of charge.

13. Final provisions

13.1. General Terms shall be governed by and interpreted in accordance with the laws of the Republic of Lithuania.

13.2. If any part of these General Terms is found invalid, unlawful or unenforceable, other terms and conditions shall continue to be valid and binding on Parties.

13.3. Lithuanian deposit guarantee scheme does not apply to the accounts opened within Satchel. However, Satchel ensures that Clients’ funds are kept in a segregated bank account opened for the benefit of Clients of Satchel and it will not be used to keep funds of Satchel or other parties which are not considered to be users of the services offered by Satchel.

13.4. In case the client is not satisfied by the financial services provided by Satchel, the Client has the right to submit an official complaint to Satchel. The rules on submission of such complaint, complaint resolution terms, the rights of the Client and other related provisions are indicated in the Rules on Investigation of Complaints Satchel.