General conditions

These general terms and conditions ("Terms") constitute the legal framework for the use of

the Gubira Pay website, mobile applications, products and services. You are strongly advised

to read these Terms carefully, and if you have any questions, please do not hesitate to

contact us. GUBIRA PAY AKTIEBOLAG, registered under Swedish organization number

559190-1318, with registered office at Karlbergsvägen 26 T, 113 27 Stockholm, Sweden,

hereinafter referred to as "Gubira Pay", "we", "us", "our" or "our". We offer a digital money

transfer service that allows customers to send money to their loved ones from a computer,

tablet or smartphone, hereinafter "Administrator".

These Terms apply to users of the Service, defined below. By registering for the Service, the

user confirms that he/she has accepted these Terms and Conditions and provides the

necessary customer information as defined in section V below. This constitutes the

agreement between the user and Gubira Pay and entitles the user to use the Service in

accordance with these Terms and Conditions. This agreement shall be considered a

framework agreement in accordance with the Payment Services Act (2010:751).


I (First) Basic principles

GUBIRA PAY AB is a registered payment service provider in FI. With Organization number

559190-1318, LEI code 894500CTGKBO5YF4I426, Institution number at FI 71197 Status

Active since 2023-06-26. Gubira Pay offers a digital money transfer service through our

website and mobile applications (the "Service"), which allows natural persons ("User" or

"you") to make money transfers (as defined in the Swedish Payment Services Act (2010:751),

hereinafter "Money Transfer") from our sending country to our receiving countries (as shown

in the Service from time to time).Payment of a Money Transfer can be made with a bank or

credit card issued in our sending country, by direct bank transfer or by other digital options.

The Service contains information on accepted bank and credit cards, applicable direct bank

transfers and other digital payment options. Depending on the location of the recipient, a

Money Transfer may be directed to a bank account or other digital options, or be available

for cash withdrawal. The duration of a Money Transfer varies depending on the recipient

country and distribution channel, with additional information available within the Service.

GUBIRA Pay does not provide payment accounts as defined in the Payment Services Act.

Users can access and download these Terms and Conditions and information about the

Service from the GUBIRA Pay website at their convenience.


II (second) Communication and language

The original versions of these Conditions have been formulated in Swedish. Versions of the

Conditions and other guidelines in languages other than Swedish, such as English in this case,

are provided for your convenience only. In case of inconsistencies or discrepancies, the

Swedish version shall prevail. Communication between a User and Gubira Pay may take place

in Swedish, English and Mongolian. Notices from Gubira Pay to you shall be delivered by

email or SMS to the contact details provided in the Service and shall be deemed to have

been received on the same day. If necessary, messages and notifications may also be sent

directly to your account in the Service. Written correspondence from you to Gubira Pay ABshall be addressed to Gubira Pay with the information specified in the introduction above or

sent by email to info@gubirapay.com.

Gubira Pay reserves the right to record or otherwise document telephone conversations or

other oral communications between a User and Gubira Pay.


III (Third parties) Contracts with third parties

To use our services, you may need to enter into agreements with other service providers,

which we call "Third Party Providers". For example, if you use our services via our mobile

application, you may need to enter into agreements with your mobile phone manufacturer

and network operator. By using our services, you agree to be bound by the terms of any

agreements you enter into with Third Party Providers in connection with your use of our

services.


IV (fourth) Conditions of service

Age and residency requirements: Users must be at least 18 years old and resident in Sweden

to create an account and access the service.

User responsibility and payment methods: Users are responsible for their actions when using

the service and may only use authorized payment methods linked to their own account.

Money transfers and use: Users undertake to transfer money only to people they know

personally and to ensure that the recipients use the money for their own purposes.

The use of this service is specifically designed for personal transactions and does not include

commercial or business transactions. This means that users may not use the Service to

transfer money to legal entities, including, but not limited to, companies, corporations or any

type of organization. In addition, the importance of security and trust in transactions is

emphasized, which clearly states that purchases of goods and/or services through this

service should be limited to those made with persons known or trusted by the user. The

platform is not designed to be used as a means of making purchases or acquiring services

from third parties with whom the user has no prior knowledge or assurance of their identity

and reputation. This approach is intended to minimize the risks associated with fraud, scams

or misunderstandings that may arise in transactions with unknown parties.

Anonymity tools: The use of anonymity tools is strictly prohibited.

Account registration: Users may only register one account, unless otherwise agreed in

writing. We reserve the right to refuse registration of multiple accounts and may terminate

or merge duplicate accounts.

Politically exposed person (PEP): Users must inform our support team in writing if they are or

have been a politically exposed person (PEP) or are associated with one. Users must also

update us on any changes to this status. In this document you will find a more

comprehensive definition of "PEP" and "family members and close associates".Compliance with Sanctions and Prohibited Use: By agreeing to these terms and conditions,

users acknowledge their compliance with the sanctions imposed by the EU, UN, UK and/or

US.

The Service may not be used for illegal activities such as money laundering, terrorist

financing or fraud. Funds obtained through criminal activities may not be transferred or used

through the service.


V (fifth) Our customer Due Diligence Compliance principle

Under current regulations, we are required to carry out background checks on our customers

before activating our services. When you register, you must confirm your identity by means

of electronic identification or by providing a valid document according to our instructions.

Physical document verification will be performed by Gubira Pay AB to activate your account.

It is necessary to maintain a verifiable identity at all times to avoid automatic account

blocking.

It is your responsibility to ensure that the registration information is accurate and up-to-date.

Any changes or inaccuracies should be reported immediately. Our records are kept up to date

by official or external sources and any errors should be reported to Customer Services.

We conduct regular audits against sanctions and PEP lists, which are managed by a trusted

third party, and monitor all transactions for anomalies. We reserve the right to request

additional information to validate your account, and failure to comply may result in

restrictions on your account or cancellation of transactions.


VI (sixth) Transfer process

To make a financial transfer, it is necessary to follow the instructions on our platform. You

must confirm that funds are available and that you have entered all the necessary

information correctly, such as recipient details, amount and reason for the transaction. We

are not responsible for any errors in the information you provide.

Once the transaction has been approved and processed by the payment provider, it is only

possible to cancel a money transfer if the recipient has not yet received the money. If the

transfer has been sent to a bank account, the transaction can be reversed as long as the

receiving bank has not completed the transfer process.

To request a refund, you have the option to contact our customer service by phone, 08-

4648191 or, if you made the transaction in person, return to our office to request a refund.

Our office hours are Monday to Friday from 10:00 to 18:00.

You will receive a notification when the transfer has been processed. The recipient must

meet any identity verification or information requirements necessary to complete the receipt

of funds.


VII (seventh) Charges and exchange rates

Current rates and exchange rate are provided on our platform. The exchange rate is set based

on the market and may include a surcharge for Gubira Pay AB. Exact details of fees and

exchange rate will be presented before you finalize your transaction.

We are not responsible for additional costs imposed by third parties, such as banking or

communication costs.

If the beneficiary chooses a different currency than the one initially selected, the

corresponding exchange fees will be applied by the payment processor.


VIII (eighth) Gubira's liability for money transfers

We undertake to properly execute all money transfers that you initiate. In the event that a

transfer fails or malfunctions, Gubira Pay will take responsibility for investigating the incident

free of charge and will provide you with the results of the investigation at your request.

Cancellation or rejection of a money transaction may be due to a number of reasons. These

include situations where: a) we identify that the information provided is incorrect or

insufficient; b) we detect a security risk related to the service; c) we observe a breach of our

terms and conditions or policies; d) we find a violation of applicable laws or regulations; e)

making the transfer would result in a legal violation by Gubira Pay or a third party; f) we

receive a request or recommendation from competent authorities.

In addition, a transaction can be declined if it exceeds set limits or if more information about

you or the recipient is required.

If we cannot complete a transaction, we will notify you and refund any amounts received,

unless we are legally prevented from doing so.

Gubira Pay does not guarantee that the payer has sufficient funds in the specified currency. If

there are insufficient funds and the beneficiary chooses an alternative currency, we will not

bear the costs of currency exchange.


IX (Ninth) Access

The service is available 24/7, but there may be interruptions due to maintenance or technical

errors. Gubira Pay is not responsible for interruptions affecting transfers.


X (Tenth) Obligations of the user

You must comply with the Conditions and applicable laws and ensure that the information

provided is accurate and complete. It is important to protect your information from access by

unauthorized third parties and to immediately notify our customer service of any security

breaches. You are liable for any failure to comply with security measures.

If you detect an incorrect or unauthorized transfer, please report it immediately to request a

correction and cooperate with our investigations.


XI (Eleventh) Exemption from obligations and liability for Gubira Pay

We are not responsible for external errors or consequential damages. Our liability is limited

to processing transfers, excluding incidents involving third party products or services. We are

exempt from liability for force majeure or unforeseen circumstances. Compliance with

relevant legislation releases us from obligations.

Exceptions for Force Majeure

We are not liable for damages resulting from government action, war, pandemic, strike,

boycott or unforeseen events beyond our control, including those in which we participate.

The immunity also includes actions in accordance with Swedish or EU law.

If the above-mentioned factors prevent the implementation of a transfer or other action, the

action will be postponed until the obstacle is removed.


XII (twelfth) Validity of the conditions

The conditions are valid indefinitely until they are changed or terminated.


XIII (thirteenth) Amendments to conditions

We may change the Conditions with a minimum of 60 days' notice. Fees and exchange rates

are subject to change without notice and apply upon approval. Legal adjustments may be

made without prior notice, as long as they are not detrimental to you. Updates to products

and services on our website and apps may be made without notice, with information

available on the Service.


XIV (Fourteenth) Termination and right of withdrawal

You may terminate your agreement with us and close your account at any time by sending a

written request to our customer service department. We may terminate this agreement and

close your account or related services by giving you 60 days' notice.

We reserve the right to suspend or limit your account without prior notice in case of

violation of terms and conditions or policies, security risk, at the request of authorities or in

case of abuse of the service (fraud, money laundering, etc.). Suspension may also occur if

your ID expires without renewal, if there are no transactions within 24 months or if you

threaten or harass our staff.

We will report any action on your account as soon as it is legally allowed, and will lift the

suspension when the reasons disappear.

You have a statutory right to withdraw from the contract within 14 days of signing, which

applies only to the main contract and not to services already provided. Exercise this right by

notifying us in writing.


XV (fifteenth) Intellectual property rights

All content and copyrights in the Service belong to us, our affiliates or partners, and no

licenses or rights are granted to you except as expressly stated. Use of the Service is limitedto personal use in accordance with these Terms, and commercial use or research of the

Service is prohibited.

It is prohibited to modify, reverse engineer, copy or create derivative works from the Service

without written permission.


XVI (Sixteenth) Transfer of rights

We reserve the right to delegate all or part of our responsibilities and rights set out in these

Conditions to an external entity. We may also use subcontractors to fulfill our contractual

obligations. You are prohibited from transferring or delegating your rights and obligations

under these Terms to another party.


XVII (Seventeenth) Processing of personal data

We process users' personal data in our capacity as data controllers for purposes such as

fulfilling our contracts and delivering services, as well as complying with legal requirements.

For more information on how we handle personal data, we invite you to read our privacy

policy on our website or to contact our customer service.


XVIII (eighteenth) Complaints procedure

If you experience any inconvenience with the Service or if the solution offered by our

support team does not meet your expectations, you have the possibility to send your

complaint directly to this e-mail address: complaints.officer@gubirapay.com.

or send your complaint in writing to


GUBIRA PAY AB

Complaints Officer.

Karlbergsvägen 26 T,

113 27 , Stockholm.

Sweden.


They will investigate your complaint and provide you with a written solution within 15

working days of receiving your complaint.

You agree that any communication in response to your complaint will use the methods set

out in the Communication and Language section.

If, after contacting our customer service, you consider that the solution offered is not

sufficient, you have the right to submit your complaint to the Swedish Authority for the

Resolution of Consumer Disputes (ARN) or a competent court. For more information visit

www.arn.se


XIX(Nineteenth) Customer Support Guide: How and when to get support

Gubira Pay ABKarlbergsvägen 26 T. 113 27 Stockholm.

Our office is located in the metro station "Odenplan".

Our opening hours are: Monday to Friday from 10:00 to 18:00 Sweden.

Headquarters telephone number: 08-4648191

Mobile, WhatsApp: +46767038767

You can contact us via the following email addresses depending on your needs:

Customer service: info@gubirapay.com

Complaints Officer: complaints.officer@gubirapay.com


XX(Twentieth) Individualized User Experience Orientation.

At Gubira Pay AB, we deeply understand the value of human interaction and personalized

service in the digital world. Our philosophy is based on the belief that technology should act

as a bridge, not a barrier, between us and you, our valued customer.

A digital service with a human heart

Although we offer our services through digital platforms, we strive to ensure that every

customer feels heard, valued and understood. Digitalization brings us efficiency and

accessibility, but it is the human touch and personal attention that truly defines our essence.

Always within reach

We are committed to maintaining open and accessible communication channels, so that you

never hesitate to contact us. Whether you need help, have questions or just want to share

your experience, Gubira Pay AB is dedicated to building and maintaining a genuine and

lasting relationship with you.

We want to be more than a digital company; we want to be your trusted partner, with

friendly faces and real voices always ready to help you. At Gubira Pay AB, digital innovation

and personalized service go hand in hand, ensuring that no matter how high-tech we get,

there's always a place for human warmth in every interaction.

Moving forward together

We are convinced that mutual success is based on this synergy between the digital and the

personal. Gubira Pay AB is not just a service provider; we are your partner every step of the

way, determined to offer you not only solutions, but also support, guidance and a

relationship based on trust and mutual respect.


XXI (twenty-first) Our commitment, the added value of the Gubira Pay AB brand:

Transparency, personalized service and excellence in innovation.


Commitment to transparency


Gubira Pay AB is distinguished by its unwavering commitment to transparency. We

understand the importance of keeping our users informed about all aspects of our

transactions. From fees to transfer processes, we strive to ensure that you always know

exactly what to expect. This transparent approach not only builds trust, but also enables you

to make more informed financial decisions.


Customized support


At Gubira Pay AB, we value the individuality of each user. Our customer service is not a one-

size-fits-all model, but a personalized experience designed to meet your specific needs.

Whether you need help with a transfer or have questions about our services, our dedicated

team is ready to provide you with quick and efficient solutions, demonstrating our

commitment to being there for you every step of the way.


Innovation and security


Our platform stands out not only for its ease of use and efficiency, but also for its continuous

innovation in terms of security measures. Gubira Pay AB invests in state-of-the-art

technology to protect your data and transactions, ensuring your experience is safe from start

to finish. This proactive approach to digital security sets us apart and gives you peace of mind

that your money and personal information are in safe hands.


Global accessibility


We understand the importance of accessibility in today's globalized world. That's why Gubira

Pay AB makes international transfers easy, connecting you to loved ones and business

partners around the world quickly and smoothly. Our extensive and ever-growing network

reflects our commitment to providing a truly global service, removing barriers and bringing

the world closer to you.


Social contribution and sustainability


Gubira Pay AB is committed to positive social impact and goes beyond financial transactions.

We actively participate in sustainability initiatives and community support, contributing to abetter future. By choosing us, you are not only choosing an exceptional service, you are also

joining us on this journey towards creating a positive social impact.


At Gubira Pay AB, we believe in the power of collaboration to create meaningful change. If

you are involved in or know of projects that focus on the development and support of

migrant communities in Sweden, or any initiative that aims to promote a positive impact on

our society, we invite you to share your ideas and projects with us. We are particularly

interested in exploring how, within our capabilities, we can contribute and participate in

these worthwhile initiatives.


Your active participation not only enriches our commitment to

sustainability and social well-being, but also strengthens our mission to create positive

impact beyond financial services. Together we can work towards a better and more inclusive

future for Swedish society. Do not hesitate to contact us at info@gubirapay.com or 08-

4648191.


XXII (twenty-second) Existing legal framework

Swedish law shall govern the interpretation of these conditions and the agreement between

the user and GUBIRA PAY AB, except in cases where mandatory law in favor of the user takes

precedence.

Compliance: Compliance with local and international regulations:

Gubira Pay continuously reinforces its commitment to comply with all applicable laws and

regulations, in particular those relating to financial and money transfer services in Sweden

and in the jurisdictions where it operates. These amendments aim not only to meet legal

requirements, but also to increase transparency and user confidence in the Gubira Pay

service by ensuring that the parties understand their rights and obligations.


Politically exposed persons (PEP)


In accordance with the Swedish ordinance (2017:630) on measures against money

laundering and terrorist financing, we are obliged to ask if you identify yourself as a

Politically Exposed Person (PEP). This refers to individuals, their close family members and

close associates, who, due to their significant roles in the public sphere or in international

organizations, may be in a position to be used for activities such as corruption.

Definition of politically exposed person

Politically exposed persons are individuals who hold or have held significant public office in a

country or leadership roles in international organizations. The category 'significant public

office' includes:

Heads of state or government, ministers and deputy ministers;Parliamentarians;

Members of the boards of political entities;

Judges of the Supreme Court, Constitutional Courts or other high courts whose decisions are

virtually unappealable;

Senior officials of supervisory authorities and central banks;

Ambassadors, senior commanders and senior military personnel;

Managers and supervisors of public enterprises.

Family and partners

For a PEP, 'family members' include spouses, cohabitants, children and their respective

partners, and parents.

The term "close associates" refers to individuals who:

Own or control entities together with a PEP;

Has control or significant influence over entities created for the benefit of a PEP;

They have or have had direct business or close relationships with a PEP, not necessarily

limited to business relationships, which may increase the risk of being involved in money

laundering or terrorist financing.