Terms of use
Effective from: 4 March, 2025
Updated Date: 4 March 2025
Spoynt Limited
Registered Office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Company Number: 14156599
1. Introduction
Spoynt Limited (hereinafter referred to as “Spoynt,” “we,” “us,” or “our”) is a private limited company incorporated under the laws of England and Wales, bearing Company Number 14156599, with its registered office located at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. We operate as an EMD Agent, gateway and introducer, providing a sophisticated platform and intermediary services that facilitate customer access to an extensive range of financial products and services offered by our partner institutions. These institutions include, but are not limited to, banks, Payment Service Providers (PSPs), Alternative Payment Methods Providers (APMs), and Electronic Money Institutions (EMIs).
Among our strategic partnerships, Spoynt Limited maintains a distinct relationship with Noveba Limited (“Noveba”), an Electronic Money Institution authorised and regulated by the Financial Conduct Authority (FCA) under Firm Reference Number (FRN) 900924. Spoynt Limited is registered with the FCA as an EMD Agent (FCA Reference Number 903071) of Noveba Limited, solely for the purpose of distributing and redeeming electronic money (“e-money”) issued by Noveba. This EMD Agent relationship is exclusive to e-money services provided by Noveba and does not extend to other financial services facilitated through our platform in collaboration with additional partner institutions.
These Terms & Conditions (hereinafter referred to as the “Terms”) constitute a legally binding agreement between you (hereinafter referred to as the “Customer,” “you,” or “your”) and Spoynt Limited. They govern your access to and use of our platform, the establishment and management of your Account, and your interaction with the financial services facilitated through us and our partner institutions. Where e-money services are provided via Noveba Limited and/or other Payment Service Providers (PSPs), Alternative Payment Methods Providers (APMs), and Electronic Money Institutions (EMIs), additional obligations and protections apply as stipulated herein and/or in Noveba’s own Terms & Conditions, which are incorporated by reference where applicable.
By accessing our platform, registering an Account, or utilizing any of our Services, you unequivocally acknowledge that you have read, understood, and agreed to be bound by these Terms, together with any ancillary policies, schedules, or agreements referenced herein, including but not limited to our Privacy Policy and Fee Schedule.
2. Service Model
Spoynt Limited operates under a dual framework as both a gateway and an introducer, delivering a seamless and compliant conduit for customers to engage with a diverse portfolio of financial services provided by our partner institutions. This hybrid model is designed to optimize user experience, ensure regulatory compliance, and enhance operational efficiency.
2.1 Gateway Role
As a gateway, Spoynt Limited provides a centralized technological platform that serves as the primary interface for customers to access and manage financial services offered by our partner institutions. This platform facilitates:
- Account Management: Enabling you to oversee your Account, monitor balances, and review transaction histories.
- Payment Processing: Allowing the initiation, execution, and tracking of Payment Transactions in real-time.
- Customer Support: Providing accessible support channels to address inquiries and resolve issues promptly.
- Security and Integration: Ensuring secure and efficient connectivity with the systems of our partner institutions.
Our gateway infrastructure integrates advanced technological solutions to harmonize interactions between customers and multiple financial entities, delivering a unified and secure user experience while adhering to stringent compliance standards.
2.2 Introducer Role
In our capacity as an introducer, Spoynt Limited undertakes the following responsibilities:
- Customer Acquisition and Onboarding: Identifying eligible customers and facilitating their introduction to the services of our partner institutions through a streamlined registration process.
- Regulatory Compliance: Conducting rigorous Know Your Customer (KYC), Anti-Money Laundering (AML), and Counter-Terrorist Financing (CTF) assessments to verify customer eligibility and ensure adherence to applicable laws and regulations.
- Relationship Management: Maintaining ongoing communication and support to foster a compliant and productive relationship between customers and our partner institutions.
This introducer function enhances our ability to connect customers with tailored financial solutions while upholding the highest standards of due diligence and customer care.
2.3 Specific EMD Agent Relationship with Noveba Limited
With respect to e-money services, Spoynt Limited operates as an EMD Agent of Noveba Limited under a contractual arrangement regulated by the FCA. In this capacity:
Spoynt Limited is authorised to distribute and redeem e-money issued exclusively by Noveba Limited.
Noveba Limited retains sole responsibility for the issuance of e-money, the safeguarding of customer funds in accordance with the Electronic Money Regulations 2011, and compliance with the Payment Services Regulations 2017.
Spoynt Limited does not issue e-money, hold customer funds, or assume liability for the safeguarding of such funds, as these obligations reside exclusively with Noveba Limited.
For all other financial services facilitated through our platform, Spoynt Limited collaborates with a broad network of partner institutions, including banks, PSPs, and APMs, to deliver a comprehensive suite of solutions tailored to your financial needs.
3. Definitions
To ensure clarity and precision throughout these Terms, the following definitions shall apply unless the context otherwise requires:
- “Account”: The personalized electronic account registered in your name with Spoynt Limited, through which you access and manage the Services.
- “e-money”: Electronically stored monetary value representing a claim on the issuer (e.g., Noveba Limited), issued in accordance with the Electronic Money Regulations 2011.
- “EMD Agent”: Spoynt Limited’s designated role as an agent of Noveba Limited, authorised to distribute and redeem e-money on Noveba’s behalf under FCA oversight.
- “Partner Institutions”: A collective term encompassing banks, PSPs, APMs, EMIs (including Noveba Limited), and other regulated financial entities with whom Spoynt Limited collaborates to provide Services.
- “Payment Transaction”: Any transfer, withdrawal, or deposit of funds initiated through the Services, whether involving e-money or other financial instruments.
- “Services”: The full range of financial solutions facilitated by Spoynt Limited, including payment processing, e-money distribution, account management, and ancillary support functions.
- “Unique Identifier”: A specific code, reference number, or credential assigned to you or your Account for the purpose of identifying and processing Payment Transactions.
Additional terms may be defined within specific sections of these Terms as necessary to address particular contexts or requirements.
4. Scope and Acceptance of Terms
4.1 Scope of Application
These Terms govern your access to and use of Spoynt Limited’s platform and the Services we facilitate in collaboration with our partner institutions. For e-money services provided through Noveba Limited, these Terms incorporate and are supplemented by Noveba’s specific terms and conditions, which shall take precedence in the event of any conflict pertaining to e-money matters.
4.2 Acceptance of Terms
By registering an Account, accessing our platform, or utilizing any of our Services, you irrevocably confirm your acceptance of these Terms in their entirety. This acceptance extends to any additional policies, schedules, or agreements referenced herein, including our Privacy Policy and Fee Schedule, which form an integral part of this contractual relationship.
4.3 Relationship with Partner Institutions
General Collaboration: Spoynt Limited engages with multiple partner institutions to offer a diverse array of financial services, each governed by the respective institution’s terms where applicable.
Specific Relationship with Noveba Limited: Our role as an EMD Agent of Noveba Limited is confined to the distribution and redemption of e-money, with all other obligations (e.g., issuance and safeguarding) resting with Noveba Limited.
Supplementary Terms: You are advised to review the terms and conditions of our partner institutions, including Noveba Limited’s Terms & Conditions, available at https://noveba.com/tcs/, for services specific to their provision.
5. Account Details
5.1 Nature of the Account
Your Account with Spoynt Limited is an electronic facility designed to facilitate access to the Services and is not a deposit-taking bank account. Accordingly, no interest shall accrue on any funds reflected therein.
For e-money services facilitated through Noveba Limited, funds are safeguarded by Noveba in segregated accounts as required by the Electronic Money Regulations 2011. Such funds are not protected by the UK Financial Services Compensation Scheme (FSCS).
5.2 Ownership and Control of Funds
All funds reflected in your Account remain your sole property and may not be transferred, assigned, or otherwise encumbered without our express prior written consent.
Spoynt Limited does not hold legal title to or beneficial interest in any funds credited to your Account.
5.3 Currency Options
Your Account may support transactions and balances in multiple currencies, subject to the capabilities of the relevant partner institution and the specific Services you elect to utilize.
Currency conversion fees may apply.
6. Registration and Maintenance
6.1 Registration Process
To access our Services, you must complete the registration process via our platform, providing accurate, current, and complete information as prompted.
Additional verification steps, including the submission of identification documents, may be required to comply with KYC, AML, and CTF obligations or to enable specific Services (e.g., e-money services via Noveba Limited). For these step we are contracted with Sum and Substance Ltd (UK) (SumSub) (https://sumsub.com).
6.2 Ongoing Maintenance and Compliance
You are obligated to promptly update any changes to your registration information, including but not limited to your name, address, email, or contact details.
Spoynt Limited reserves the right to periodically review your Account, request updated documents, monitor transactions, and conduct audits to ensure compliance with partner institution requirements and applicable laws, with your full cooperation required.
6.3 Suspension or Termination
Failure to provide requested information or maintain compliance may result in the suspension or termination of your Account, as detailed in Section 13.
7. Security Obligations
7.1 Customer Responsibilities
You are solely responsible for maintaining the confidentiality and security of your Account login credentials, including passwords, PINs, and any other access codes.
You must immediately notify us in writing at support@spoynt.com of any unauthorized access, suspected breach, or loss of credentials.
7.2 Spoynt Limited’s Security Measures
We employ industry-standard security protocols, including encryption and multi-factor authentication, to protect your Account and data.
Notwithstanding these measures, we shall not be liable for losses arising from your failure to safeguard your credentials unless such losses result from our gross negligence or willful misconduct.
8. Transactions
8.1 Initiating Payment Transactions
Payment Transactions are authorized by you through our platform using your Unique Identifier or other designated methods.
Processing times and completion deadlines vary depending on the partner institution involved and are subject to the terms of the relevant service provider.
8.2 Funding Your Account
Funds may be added to your Account using payment methods specified on our platform, such as bank transfers, card payments, or other approved mechanisms.
For e-money services, funds are credited as e-money issued and held by Noveba Limited, subject to their safeguarding obligations.
8.3 Transfers and Withdrawals
To execute a transfer or withdrawal, you must provide accurate recipient details, including any required Unique Identifiers.
Spoynt Limited facilitates these transactions through our partner institutions and is not liable for delays or errors attributable to incorrect information provided by you.
8.4 Transaction Limits
Transaction limits may be imposed based on regulatory requirements, partner institution policies, or our internal risk management protocols. Such limits will be communicated to you via the platform or upon request.
9. Prohibited Activities
9.1 General Prohibition
You are strictly prohibited from using our Services for any purpose that contravenes applicable laws, regulations, sanctions, or these Terms, including but not limited to money laundering, terrorist financing, fraud, or any activity deemed illegal in your jurisdiction.
9.2 Specific Restrictions
Prohibited activities include, without limitation:
Engaging in transactions involving sanctioned individuals, entities, or jurisdictions.
Using the Services for speculative trading, unlicensed financial activities, unlicensed gambling and gaming activities.
Attempting to circumvent security measures or tamper with our platform.
9.3 Enforcement
Spoynt Limited reserves the right to investigate suspected violations, assess, charge a penalty, suspend or terminate your Account, and report such activities to relevant authorities as required by law.
10. Fees and Charges
10.1 Fee Structure
Fees applicable to the Services are detailed in our Fee Schedule, accessible via our platform or upon request. Fees may vary depending on the partner institution, transaction type, currency, or service utilized.
All fees are payable in the currency specified and may be deducted directly from your Account balance.
10.2 Changes to Fees
We reserve the right to amend the Fee Schedule with prior notice of at least 10 days, unless such changes are necessitated by regulatory requirements or partner institution policies, in which case immediate effect may apply.
11. Liability and Indemnity
11.1 Limitation of Liability
For e-money services, liability for safeguarding and transaction errors rests with Noveba Limited, subject to their terms.
11.2 Customer Indemnity
You agree to indemnify and hold harmless Spoynt Limited, its affiliates, and partner institutions from any claims, losses, or damages arising from your breach of these Terms, misuse of the Services, or provision of inaccurate information.
12. Termination
12.1 Termination by Customer
You may terminate your Account by providing written notice to support@spoynt.com, subject to the settlement of any outstanding fees or transactions.
12.2 Termination by Spoynt Limited
We may terminate or suspend your Account with immediate effect if you breach these Terms, fail to comply with regulatory requirements, or engage in prohibited activities.
12.3 Post-Termination
Upon termination, access to your Account will cease, and any remaining funds will be returned to you, subject to applicable fees and legal obligations.
13. Governing Law and Dispute Resolution
13.1 Governing Law
These Terms are governed by and construed in accordance with the laws of England and Wales.
13.2 Dispute Resolution
Any disputes arising under these Terms shall be resolved through good-faith negotiation. If unresolved, disputes shall be submitted to the exclusive jurisdiction of the courts of London, England and Wales.
14. Miscellaneous
14.1 Amendments
We may amend these Terms with 30 days’ prior notice, unless immediate changes are required by law or partner institutions.
14.2 Contact
For inquiries, contact us at:
Spoynt Limited
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Email: support@spoynt.com