Terms of Service

Terms of Service — ZovoPay

Effective Date: 4 July 2026
Last Updated: 4 July 2026

Operating Entity: EHSAN FALCON HOLDING LIMITED ("EFH LTD")
Registered in the United Kingdom
Company Registration Number (Companies House): 17091849
Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

Introduction and Acceptance

EHSAN FALCON HOLDING LIMITED ("EFH LTD"), a company registered in the United Kingdom, operates the ZovoPay digital wallet and financial solutions platform, including the User App, the unified Business App, and the website zovopay.com (collectively, the "Services"). EFH LTD provides financial services to customers across the Middle East, Turkey, and the United Kingdom. EFH LTD is referred to hereinafter as "we," "us," or "the Company."

By registering an account, clicking "I Agree," or using any part of the Services, you confirm that you have read, understood, and accepted these Terms and any policies they reference (including the Privacy Policy), and that you are legally bound by them. If you do not agree to any provision, you must refrain from using the Services.

1. Eligibility and Identity Verification Requirements

1-A. General Eligibility

To open an account and use the Services you must:

• Be 18 years of age or older (or the legal age for financial eligibility in your country of residence if higher)
• Have the legal capacity to enter into binding contracts in your country of residence
• Not be subject to any prohibition from using financial services by court or regulatory order
• Not have been convicted of money laundering, financial fraud, or terrorism financing

1-B. Identity Verification (KYC)

Identity verification is a mandatory — not optional — requirement for using the financial Services. It includes:

• Submission of a valid, government-issued identity document
• A selfie photograph for identity matching
• Additional documents may be requested in accordance with applicable compliance requirements

The Company may decline or suspend accounts that do not meet KYC requirements, or where submitted documents are found to be inconsistent or fraudulent.

1-C. One Account per Person

You may not create more than one personal account. Creating multiple accounts to circumvent transaction limits or compliance requirements is an explicit violation subject to immediate closure.

2. Account Responsibilities and Security

2-A. Your Responsibility

You are solely responsible for:

• Maintaining the confidentiality of your login credentials (password and PIN)
• All activity occurring through your account, whether or not you authorised it
• Notifying us immediately at support@zovopay.com if you suspect your account has been compromised

2-B. Two-Factor Authentication

We strongly encourage enabling two-factor authentication (2FA). If you suffer a loss as a result of not enabling it despite its availability, this may affect the scope of our liability.

2-C. Accuracy of Information

You undertake that all information you provide is accurate and current. Submitting misleading or falsified information constitutes a violation subject to immediate account termination and reporting to competent authorities.

3. Services Provided

ZovoPay Services that are currently available on the platform include:

For Individual Users:

• Digital wallet: balance loading and funds management
• Person-to-person (P2P) money transfers, domestic and international
• Money requests and payment links
• QR code payment receiving
• International remittances
• Bill payments (utilities, services, and telecommunications)
• Mobile top-ups
• Digital gift cards
• Virtual card: issuance, management, and funding
• Currency exchange
• Savings and budgeting (savings vaults and budget tracking)
• Loyalty points and rewards
• Digital marketplace
• P2P Trade / Marketplace
• Cash deposit and withdrawal via agents
• Travel and booking services (subject to availability)

For Merchants:

• Payment acceptance via permanent QR code
• Payment links
• Digital Point-of-Sale (POS) and inventory management
• Sales analytics
• Periodic settlement

For Agents:

• Customer cash deposit and withdrawal
• International remittance processing
• Float management
• Periodic settlement

Services are offered subject to actual availability at each phase and in each geographic region. This list does not constitute a commitment to the availability of all Services for all users at all times.

4. Acceptable Use and Prohibited Activities

4-A. Acceptable Use

You agree to use the Services for lawful and legitimate purposes only.

4-B. Expressly Prohibited Activities

Financial prohibitions:

• Money laundering or transferring proceeds of unlawful activities
• Terrorism financing or financing individuals or entities subject to international sanctions
• Financial fraud of any kind, including fictitious transfer requests, forgery, and impersonation
• Transaction structuring to avoid reporting thresholds
• Using the account as a front for unregistered third-party transactions

Technical prohibitions:

• Attempting to breach or test system vulnerabilities without explicit written authorisation
• Using automated tools (bots) to access the Services
• Reverse engineering the application or API
• Any activity that interferes with the integrity or security of the platform

General prohibitions:

• Infringing the intellectual property rights of ZovoPay or any third party
• Harassing or abusing other users or staff
• Violating any applicable law or regulation

5. Fees and Charges

Applicable fees and limits are displayed within the app before you confirm each transaction. These Terms do not contain fixed fee figures, as fees vary by service type, currency, and corridor. Always check the fee displayed on the confirmation screen before completing any transaction.

All fees deducted in connection with a completed service are non-refundable except in cases of a proven error on our part.

We reserve the right to amend the fee structure with prior notice in accordance with Section 16 (Amendments to Terms).

6. Transactions, Disputes, and Refunds

6-A. Transaction Finality

Correctly executed financial transactions are final and cannot be reversed after completion. It is your responsibility to verify the accuracy of recipient details (phone number or username) before confirming any transaction.

6-B. Erroneous and Suspicious Transactions

If you send funds to the wrong recipient, or suspect an unauthorised transaction:

• Contact support immediately at: support@zovopay.com
• We will make reasonable efforts to recover the funds if they have not been spent
• We cannot guarantee recovery of funds sent to bona fide third parties

6-C. Disputes with Merchants

In case of a dispute relating to a product or service purchased from a merchant via the platform, you must first contact the merchant directly. If the dispute remains unresolved, contact ZovoPay support and we will facilitate a resolution within the available technical limits.

6-D. Refunds

As a general rule:

• Fees are non-refundable except in cases of a proven error on our part
• Transactions proven to have been executed without authorisation are subject to internal investigation procedures
• Approved refund requests are processed in accordance with applicable review timelines

6-E. International Remittances

International remittance transactions are subject to processing times that vary depending on the partner network and destination country. Fees are deducted at the moment of request confirmation. Estimated completion times are displayed before confirmation and may be affected by factors beyond our control.

7. Wallet and Balance Terms

7-A. Nature of Balance

Your ZovoPay wallet balance represents monetary value held by EFH LTD on your behalf. It is not a bank deposit and is not subject to government deposit guarantees. The balance is available for withdrawal and transfer in accordance with the applicable terms and procedures.

7-B. Balance and Transaction Limits

The wallet is subject to maximum balance limits and daily/monthly transaction count and value limits, which vary according to the level of identity verification completed. Limits are displayed within the app in your account settings.

7-C. Inactive Accounts

If an account is inactive for an extended period, we may send a notification to reactivate it. If inactivity continues, the balance may become subject to dormant funds procedures under applicable law, with prior notice.

7-D. No Interest

No interest is paid on balances held in the wallet.

8. Virtual Card Terms

8-A. Issuance

Virtual card issuance is conditional on completion of identity verification (KYC) and fulfilment of the certified card issuer partner's (Airwallex) technical requirements. We do not guarantee card issuance to all users in all circumstances.

8-B. Use

The virtual card is a digital payment instrument. It is your responsibility to verify that the merchant accepts the card and that it is valid in the country of use.

8-C. Freeze

We may temporarily freeze the virtual card in the event of:

• Suspected fraudulent activity
• Unpaid outstanding fees
• Regulatory authority request
• Discovery of a security breach

9. Agent Terms

9-A. Separate Agreement

Operation in the agent role is subject to a separate agency agreement executed with the Company. These Terms supplement that agreement.

9-B. Agent Obligations

The agent undertakes to:

• Verify customer identity before executing any cash transaction in accordance with the announced procedural requirements
• Maintain sufficient float to cover anticipated operations
• Not refuse to complete legitimate customer transactions without a technical or compliance justification
• Promptly report any suspicious transaction
• Comply with agreed commission and settlement schedules specified in the agency agreement

9-C. Agent Suspension

The Company may suspend or terminate an agent account immediately in case of violation, fraud, or failure to settle.

10. Merchant Terms

10-A. POS Use

Merchant access to the POS system is conditional on service activation in accordance with the applicable category. The merchant may use the system solely to sell their actual products and services.

10-B. Data Accuracy

The merchant bears responsibility for the accuracy of product information, prices, and inventory data entered into the system. EFH LTD is not responsible for any loss resulting from errors in merchant-entered data.

10-C. Merchant Settlement

Aggregated sales amounts are settled according to the schedule specified in the merchant agreement.

10-D. Customer Refunds

Managing customer refunds is the merchant's responsibility. ZovoPay does not intervene in disputes between the merchant and their customers except as an optional mediator.

10-E. API

For merchants using ZovoPay API to integrate with their systems: we may revoke API keys in case of misuse or breach of these Terms.

11. P2P Trade / Marketplace

11-A. ZovoPay's Role as Platform

ZovoPay is a platform that enables trading between users. It is not a party to contracts between users and does not guarantee the completion of any transaction.

11-B. Trading Rules

• Trade offers must be honest and accurate
• Price manipulation or coordination to influence the exchange rate is prohibited
• Submitting falsified payment proof constitutes fraud and will result in immediate account closure and legal reporting
• Repeated transaction cancellations without justification may lead to account restriction

11-C. Trade Dispute Resolution

In a dispute between the parties to a transaction, ZovoPay provides an internal mediation mechanism based on evidence review. The decision of the disputes team is final within the framework of the announced policy.

11-D. Trading Risks

Exchange rates fluctuate. EFH LTD is not responsible for any loss resulting from rate fluctuations between the submission of an offer and the completion of a transaction.

12. Intellectual Property

All platform content (the ZovoPay name, logo, designs, interfaces, and source code) is owned by EHSAN FALCON HOLDING LIMITED and is protected by applicable intellectual property laws. Your use of the Services grants you no ownership rights therein.

13. Liability and Disclaimers

13-A. Services Provided "As Is"

The Services are provided "as is" and "as available." We do not warrant that the Services will be available without interruption or error-free at all times.

13-B. Limitation of Liability

To the maximum extent permitted by applicable law, EFH LTD shall not be liable for:

• Indirect, consequential, or incidental losses
• Lost profits or missed business opportunities
• Losses arising from your use of the Services for purposes not authorised under these Terms

The maximum aggregate liability to you in any circumstance shall not exceed the total fees you paid us in the twelve months preceding the incident.

13-C. Force Majeure

We are not liable for any delay or failure in service delivery resulting from events beyond our reasonable control, such as natural disasters, widespread network disruptions, or government decisions.

13-D. No Investment Advice

ZovoPay services are payment, transfer, and savings services. No information or content on the platform constitutes investment advice or financial consultation. Trading decisions are entirely your responsibility.

14. Privacy

The processing of your personal data is governed by the Privacy Policy published at zovopay.com/privacy, which forms an integral part of these Terms.

15. Suspension and Termination

15-A. Termination at Your Initiative

You may close and delete your account at any time through any of the following:

• In-app: Settings → Account → Delete Account
• Web: zovopay.com/account-deletion
• Email: support@zovopay.com

Before closure you must withdraw any available balance and settle any pending transactions or disputes. The Account Deletion Policy applies, including retention of financial and verification records for the legally required period (anti-money laundering).

15-B. Our Suspension of Your Account

We may suspend, restrict, or terminate your account without prior notice in the following circumstances:

• Suspected violation of these Terms or fraud
• Regulatory or legal authority request
• Suspected money laundering or terrorism financing
• Failure to pass identity verification

In less severe cases we will notify you by email and may provide a response window. In all cases, you may contest any suspension or restriction and inquire about its reasons by contacting support: support@zovopay.com.

15-C. Balance of Terminated Account

Upon account termination for legitimate reasons (not involving a violation), your net balance will be returned to you after deduction of any outstanding amounts, in accordance with the applicable procedures.

16. Amendments to Terms

We reserve the right to amend these Terms at any time. In the event of amendment:

• We will notify you via your registered email or an in-app notification
• Notification will precede the effective date of material amendments by thirty (30) days
• Emergency amendments (e.g., for security or regulatory reasons) may take effect immediately
• Your continued use of the Services after an amendment takes effect constitutes acceptance of it

17. Governing Law and Dispute Resolution

17-A. Governing Law

These Terms are governed by and construed in accordance with the laws of England and Wales, being the jurisdiction of registration of EHSAN FALCON HOLDING LIMITED. Nothing in this clause limits or excludes any mandatory consumer-protection rights afforded to users under the applicable laws of their country of residence.

17-B. Dispute Resolution

In the event of a dispute between us:

1. An amicable resolution will first be sought by contacting the support team at support@zovopay.com, or for formal matters at info@efhlimited.com
2. If an amicable resolution is not reached within thirty (30) days, the matter may be referred to the courts of competent jurisdiction under the governing law set out above

For complaints relating to data protection, you may contact the Information Commissioner's Office (ICO) in the United Kingdom, or the competent data-protection authority in your country of residence.

18. Contact Us

For any enquiry or complaint relating to these Terms:

• Customer Support Email: support@zovopay.com
• Corporate / Legal Email: info@efhlimited.com
• Postal Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom