Vance Money Services LLC

Terms and conditions

Important notice: These terms and conditions contain an arbitration agreement, waiver of class action rights, limitations of liability, disclaimers of warranties, and other important terms that affect your rights. Please review carefully.

1. Agreement to terms and conditions

1.1 Acceptance of terms

This Agreement (the “Terms” or “Agreement”) governs the access to and use of the services provided by Vance Money Services LLC, a Delaware limited liability company, (“Aspora”, “we”, “our”, or “us”). By accessing or using our website, mobile application (“Aspora App”), or any other platforms and associated services (collectively, the “Services”), you (the “User”, “you”, or “your”) agree to be legally bound by these Terms, together with our Privacy Policy, E-Sign Consent, CookiesPolicy and any additional terms or policies referenced herein or provided to you in connection with specific Services. Unless provided otherwise, this Agreement between you and us shall continue indefinitely until terminated either by you or us.

By creating an account with Aspora, initiating a transaction, or otherwise accessing or using our Services, you agree to comply with and be bound by this Agreement, as well as:

(a) The Privacy Policy (applicable to all U.S. customers with certain exceptions for bank-partnered states),

(b) Any state-specific notices required by law,

(c) Any additional disclosures provided to you before or during a transaction (e.g., fee schedules, exchange rates, delivery estimates), and

(d) Our Electronic Communications Policy, which governs how we communicate with you electronically.

(e) Cookies Policy.

By downloading the Aspora app, registering, creating an account, accessing, or using our services, you confirm that you have read, understood, and agreed to be bound by this agreement, including any policies, notices, and other documents incorporated herein by reference.

1.2 Modifications to the Agreement

The Aspora reserves the right to amend, modify, or replace this Agreement at any time, in its sole discretion. Any material changes will be communicated to Users via email, on our website, on Aspora App or through the Services 30 days’ notice prior to taking effect. Continued use of the Services after any changes become effective constitutes your acceptance of the revised Agreement. You can review the most current version of the Agreement at any time on our website or on Aspora App. If you do not agree with the updated terms, you must discontinue use of the Services. We encourage you to review these Terms periodically for updates.

1.3 Partner Terms and Disclosures

In addition to this Agreement, your use of the Services may be subject to additional terms, conditions, policies, and disclosures of Business Partners engaged by Aspora. Such Partner Terms are incorporated by reference and may include banking partner terms, payment processor terms, compliance service provider privacy policies, and payout network terms.

2. Definitions

For the purpose of this Agreement, the following terms shall have the meanings set forth below:

(a) Aspora Account: A user profile created with Aspora either by registering on its website or by downloading the Aspora App to access and use the Services as defined below.

(b) Affiliate: Any entity that directly or indirectly controls, is controlled by, or is under common control with Aspora.

(c) ACH Entry: Means a specific electronic payment transaction transmitted via the ACH network under the NACHA Operating Rules on your behalf.

(d) ACH Entries: Means entries transmitted through the Automated Clearing House network on your behalf for the purpose of electronically transferring funds, initiated through the Enabled Services under this Agreement.

(e) Applicable Laws: Any statute, regulation, ordinance, rule, code, treaty, or other legal requirement applicable to the Services, including but not limited to the laws of the United States.

(f) Authorization: Means your approval or permission that you provide as required under Applicable Law and the NACHA Rules, to allow us and Column Bank to initiate Payment Orders and ACH Entries on your behalf.

(g) Business Day: Any day other than a Saturday, Sunday, or public holiday in the jurisdiction where Aspora operates i.e. Wilmington, Delaware, USA.

(h) Business Partner: Any third-party entity that Aspora engages to provide services necessary for the operation of the Services, including but not limited to banking institutions, payment processors, correspondent banks, money transfer operators, payout networks, compliance service providers, identity verification services, and technology infrastructure providers.

(i) Confidential Information: Any non-public information disclosed by one party to another, including business plans, technical data, customer lists, and pricing information.

(j) Enabled Services: Means the services enabled for your account, as agreed upon in writing between you and us, allowing you to initiate Payment Orders through our platform with Column Bank.

(k) Entry: Means an ACH entry as defined in the NACHA Operating Rules, representing your electronic payment or transfer instruction transmitted through the ACH network.

(l) Exchange Rate: The rate at which one currency is exchanged for another, which may include a margin above the market rate.

(m) Incorporation by Reference: The legal mechanism by which external documents, terms, policies, or disclosures are made part of this Agreement without reproducing them in full herein.

(n) KYC (KnowYour Customer): The process of verifying the identity of Users, as required under applicable anti-money laundering (AML) regulations.

(o) MoneyTransfer: A financial transaction that transmit money from a User (“Sender”) to a designated recipient (“Recipient”).

(p) NACHA Operating Rules (orNACHA Rules): Means the National Automated Clearing House Association OperatingRules and Guidelines, as amended from time to time, which govern ACH transactions including Third-Party Sender activities.

(q) Network Institutions:Means other depository financial institutions where Column Bank, acting as our agent and custodian on your behalf, may deposit funds swept from your accounts.

(r) Originator: Means you or your designated party who initiatesPayment Orders or ACH Entries for processing through our platform and Column Bank.

(s) PartnerTerms: The terms and conditions, service agreements, user agreements, or similar governing documents of Business Partners that apply to services provided to or through Aspora.

(t) Payment Instrument: Any authorized payment method linked to a User’ account, including but not limited to, bank accounts, credit cards, debit cards, or other digital payment methods as accepted by Aspora.

(u) Payment Orders: Means your instructions or requests to transfer funds to or withdraw funds from another financial institution by use of the Enabled Services. Payment Orders include ACH Entries.

(v) PaymentServices: Means the suite of services we provide to facilitate your use of the Enabled Services insubmitting Payment Orders, including processing through Column Bank.

(w) Payout Amount: The amount delivered to the Recipient, after conversion (if applicable), fees, and any applicable taxes or deductions.

(x) Protected Information: Means any non-public personal information, including financial or sensitive data, related to you or your transactions with us, including information contained within Payment Orders and any related documentation.

(y) Recipient: The individual designated to receive funds through a MoneyTransfer.

(z) Receiver: Means the individual or entity that is authorized to receive funds or payments via the Payment Orders or ACH Entries you initiate through the Enabled Services.

(aa) Sender: A User who initiates a Transaction through the Services for the purpose of transferring funds to a Recipient.

(bb) Services: All services offered by Aspora, including but not limited to money transfers.

(cc) Service Fee: means the fee charged by Aspora for processing aTransaction, as disclosed prior to confirming the Transaction.

(dd) SettlementDates: Means the dates on which the exchange of funds related to your Payment Orders is reflected on thebooks of the applicable Federal Reserve Bank(s), as determined by ApplicableLaw and banking rules.

(ee) Third-PartySender (TPS): Means our role, authorized by Column Bank, to initiate ACH transactions through the NACHA network on your behalf, as described under the NACHA Operating Rules.

(ff) TPS Registration: Means the registration process mandated by the NACHA Rules under which youprovide us with information necessary to enable us to register as a Third-PartySender with Column Bank and NACHA.

(gg) User: Any individual who accesses or uses the Services in any manner, whether as a Sender or Recipient.

(hh) Transaction: Any remittance, money transfer, or payment transfer request initiated by a Sender and processed through the Services, whether completed or pending.

(ii) Transaction Amount: The amount of money you request to send, before any fees, exchange rates, or other deductions.

3. Banking services and Column Bank disclosure

3.1. Banking Partner

Certain services offered by Aspora may involve banking products or services provided by Column National Association (“Column Bank”), a nationally chartered bank, Member FDIC. When you access or use any service that involves Column Bank, you acknowledge and agree that such services are provided by Column Bank, subject to their terms, regulatory requirements, and oversight.

3.2. Program Management Agreement

Aspora acts as a program manager and service provider for Column Bank with respect to designated banking services. The provision of such services is governed by a Program Management Agreement between Aspora and Column Bank, which may impose additional requirements and restrictions.

3.3. FDIC Insurance

Funds held in accounts with Column Bank may be eligible for FDIC insurance coverage, subject to the applicable rules and limits established by the Federal Deposit InsuranceCorporation (FDIC). Aspora does not guarantee the availability or amount ofFDIC insurance for any funds not directly held at Column Bank.

3.4. BankOversight and Regulatory Compliance

All banking services provided by Column Bank are subject to their regulatory oversight, compliance requirements, and operational controls. Aspora and its users must comply with all applicable laws, regulations, and policies as required by Column Bank.

4. Your representations, obligations, and compliance with payment orders

The provisions in this Section 4 apply whenever you use the Enabled to submit Payment Orders or ACH Entries. Capitalized terms have the meanings given in Section 2 (Definitions).

4.1 Representations, Obligations, and Compliance: You acknowledge and agree that Column Bank does notmaintain a separate agreement with you regarding any Payment Orders we transmit to Column Bank on your behalf. You may only submit Payment Orders under this Agreement. You must ensure that: (a) You are bound by all Applicable Law and will comply therewith; (b) You authorize Column Bank to process Payment Orders for the Enabled Services; (c) You will not originate Payment Orders that: (i) violate Applicable Law; or (ii) are on behalf of, or for the benefit of, any party other than yourself; (d) You will not use Payment Services to send or receive funds to or from any business listed in Annexure A (Prohibited Businesses); (e) You will respect any exposure limit on your Payment Orders, which we set and review periodically, covering aggregate dollar amounts transmitted to Column Bank across multiple Settlement Dates; (f) You will safeguard Protected Information and all related records or authorizations, using protections no less stringent than those in this Agreement, and you are jointly and severally liable with us for any failure to protect or comply; (g) You permit both us and Column Bank to audit your compliance with Applicable Law and your Agreement, including audits of your Payment Orders; (h) You agree to promptly notify Column Bank of any changes to the information you have provided; (i) You acknowledge and accept that Column Bank may refuse to process any Payment Order from you; and (j) You authorize us to act as your agent and custodian solely to enter into agreements with Column Bank to sweep your funds held at Column Bank to other depository institutions (“Network Institutions”); and you understand that: (i) Column Bank acts as our agent and custodian for purposes of establishing and maintaining deposits at Network Institutions; (ii) You have no direct relationship with Column Bank or the Network Institutions; (iii) Your cash balances information is available from us, not from Column Bank or Network Institutions; (iv) You acknowledge our right to suspend or terminate your Customer Agreement upon your breach of Applicable Law or the Customer Agreement, in a way that enables us or Column Bank to comply with Applicable Law; (v) Your Agreement includes any other provisions required by Applicable Law; and (vi) Your Agreement includes any other provisions required for the Enabled Services. 4.2. Third-Party Sender (TPS) Rules: Column Bank authorizes us to act as a Third-Party Sender under the Nacha Operating Rules when we initiate ACH Entries on your behalf. Except as otherwise provided herein, all other terms of this Agreement apply regardless of whether you act as an Originator, or we act as a Third-Party Sender. When we act as a Third-Party Sender on your behalf, the following provisions apply: (a) Authorization: On your behalf, we authorize Column Bank to process ACH Entries that we submit to Column Bank; (b) User Agreement Requirements: In addition to the requirements of Section 4.1, you must ensure that: (i) You assume all Originator responsibilities under the Nacha Rules and comply with Applicable Law; (ii) You obtain and retain valid authorization from each Receiver for every Entry we transmit on your behalf. (iii) You permit us and Column Bank to audit you and your Entries, including audits for compliance with the Nacha Rules. (iv) You promptly notify Column Bank of any changes to information provided for Nacha registration purposes; (v) You permit us to suspend or terminate your Agreement for any breach of the Nacha Rules in a manner that enables us or Column Bank to comply with the Rules; (vi) You acknowledge having access to the current Nacha Rules; and (vii) Your agreement includes any other provisions required by the Nacha Rules. (c) TPS Registration: You must promptly provide us all information necessary to register us as a Third-PartySender with Column Bank in accordance with the Nacha Rules. Column Bank will complete our registration within thirty (30) days after we transmit our first ACH Entry on your behalf and will update the registration with in the required timeframes so long as we provide timely and complete information.

5. Business partner framework

5.1. Business Partner Engagement

Similar to our banking relationship with Column Bank described in Section 3, Aspora engages various Business Partners to provide essential services required for the operation of the Services. These Business Partners are organized into the following categories:

(a) Banking and Financial Partners: Including correspondent banks (such as Column Bank), payment processors, settlement networks, foreign exchange providers, and other financial institutions.

(b) Compliance and Risk Management Partners: Including identity verification services, fraud prevention providers, sanctions screening services, and anti-money laundering (AML) service providers.

(c) Technology and Infrastructure Partners: Including cloud service providers, cybersecurity providers, API integration partners, and analytics providers.

(d) Payout and Distribution Partners: Including cash pickup networks, mobile wallet providers, bank deposit networks, and last-mile delivery partners.

(e) CustomerService Partners: Including call center providers, communication platforms, and document processing services.

(f) Incorporation by Reference: Just as Column Bank’s terms and regulatory requirements apply to banking services under Section 3, you acknowledge andagree that your use of the Services may be subject to additional Partner Terms of other Business Partners. Such Partner Terms are hereby incorporated by reference into this Agreement.

5.2. Access to Partner Terms

Current Partner Terms and related disclosures are available at: Our website at Aspora Partners.

Through the Aspora App in the “Partner Information” section

By contacting customer service at legal@aspora.com or (888) 261-7110

6. Account creation, security, and termination

6.1 Eligibility

Certain money transfer and remittance services offered through Aspora may be provided in partnership with Column Bank, a nationally chartered bank, Member FDIC. Use of such services is subject to additional terms and regulatory requirements imposed byColumn Bank.

To access and use the Services provided by Aspora, you must be an individual who is at least eighteen (18) years of age or the legal age of majority in your jurisdiction, whichever is greater, and who possesses the legal capacity to enter into binding contracts under Applicable Laws.

By registering for and using the Services, you represent and warrant that you meet these eligibility criteria and are not subject to any legal or regulatory prohibitions that would disqualify you from engaging in financial transactions, including but not limited to, sanctions imposed by the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury, or any other governmental authority.

6.2 Restrictions on Use in Certain Jurisdictions

The Services are subject to geographic restrictions. Aspora does not offer the Services to Users in certain jurisdictions where the provision or use of the Services is prohibited or restricted by Applicable Laws. It is your responsibility to ensure that your use of the Services complies with all applicable laws and regulations in your jurisdiction. By accessing or using the Services, you represent and warrant that you are not located in, or a national or resident of, any country or jurisdiction subject to OFAC sanctions or similar restrictions.

Aspora reserves the right, in its sole discretion, to suspend or terminate your access to the Services if we determine that you are using the Services in a manner that violates any geographic or regulatory restrictions.

6.3 Account Registration

In order to access certain features of the Services, including initiating Transactions, you must register for an account with Aspora (“Account”). The User agrees to provide accurate, current, and complete information during registration, including full legal name, date of birth, contact information, and payment details. The User further agrees to update this information as necessary to maintain its accuracy. The user is required to create security credentials, such as a password or personal identification number, that Aspora deems necessary (“Security Credentials”). Your Aspora Account allows us to record certain information about you, as explained in our Privacy Policy.

Please also be aware that we will never ask for your Aspora account password.

6.4 Identity Verification

In accordance with applicable AML (Anti-Money Laundering), CFT (Counter-Financing of Terrorism), and KYC laws, Aspora requires Users to provide verification documents, such as government-issued identification and proof of address. Aspora may also, at its sole discretion and at any time, require you to provide additional information and documentation to verify your identity, the legitimacy of your payment sources, and your compliance with Applicable Laws.

You acknowledge and agree that failure to provide requested information may result in suspension or termination of your Account or delayed or declined Transactions.

6.5 Account Security

You are solely responsible for maintaining the confidentiality of their login credentials including your username, passwords and any activities that occur under your Account. You agree to use these services for yourself only, and you will not create Aspora Account or use the Service for another person, and you can’t share your Aspora Account information, especially your Aspora Account password, with anyone else to allow them to use the Service for you. You agree to notify Aspora immediately of any unauthorized use of their Account.

You acknowledge that you are fully responsible for all activities that occur under your Account, whether or not authorized by you. Aspora shall not be liable for any loss or damage arising from your failure to comply with these security obligations.

6.6 Account Suspension and Termination

Aspora may suspend or terminate a User’s Account with or without prior notice, at its sole discretion, for reasons including, but not limited to:

(a) Violation of this Agreement or any incorporated policies.

(b) Failure to meet KYC/AML obligations.

(c) Fraudulent, illegal, or suspicious activity.

(d) Risk mitigation measures required by law or regulatory authorities.

Upon termination of your Account, your right to use the Services shall immediately cease. Any pending Transactions may be canceled at Aspora’s discretion, and any remaining funds may be refunded subject to compliance with Applicable Laws and these Terms. Termination of the Account may result in forfeiture of any unredeemed loyalty rewards and suspension of access to Services.

7. Services

7.1 Money Transfer Service

Aspora provides money transfer and remittance services, enabling Senders to initiate Transactions for Recipients in eligible jurisdictions. The Services are designed to facilitate the secure and efficient transfer of funds from the Sender’s Payment Instrument to the Recipient through authorized payout methods, including but not limited to, bank deposits, cash pickups, as made available by Aspora in the Recipient’s jurisdiction.

The Services are provided solely for lawful personal or commercial remittance purposes and must not be used for any prohibited activities, including but not limited to, purchasing prohibited goods/services (e.g., controlled substances, firearms), illegal activities (e.g., money laundering, terrorism financing, gambling, fraud), money laundering, terrorist financing, fraud, or any other illegal or unauthorized purpose.

7.2 Service Limitation

Aspora makes reasonable efforts to ensure that the Services are available for use by Users in eligible jurisdictions; however, availability may vary due to factors including but not limited to regulatory requirements, currency availability, payment method restrictions, third-party provider limitations, or technical issues.

Aspora does not warrant or guarantee continuous, uninterrupted, or error-free access to the Services, and reserves the right to modify, suspend, or discontinue any aspect of the Services, in whole or in part, at any time and without prior notice, subject to compliance with Applicable Law. Aspora reserves the right to decline, delay, or cancel Transactions for reasons including, but not limited to, fraud prevention, regulatory compliance, or policy violations.

Aspora imposes limits on the amount, frequency, and types of Transactions that Users may initiate through the Services. These limits vary based on verification status, regulatory requirements, risk assessments, and state-specific laws. Enhanced limits may be available upon providing additional verification. These limits are established to ensure compliance with Applicable Laws, manage transactional risk, and protect both Users and Aspora from potential fraud or misuse of the Services. Aspora reserves the right, at its sole discretion and without prior notice, to adjust, increase, reduce, or impose new limits on the Services at any time, subject to compliance with Applicable Laws.

7.3 Prohibited Usage of the Services

You agree that you shall not use the Services for any purpose that violates Applicable Law or these Terms. Prohibited activities include, but not limited to:

(a) Money laundering, terrorist financing, or any other activity designed to conceal or disguise the proceeds of illegal activity;

(b) Transactions related to illegal gambling, narcotics trafficking, human trafficking, child exploitation, or firearms sales;

(c) Transactions intended to evade taxes, circumvent sanctions, or otherwise engage in fraudulent conduct;

(d) Use of the Services to transfer funds on behalf of third parties without their consent or for unlicensed financial services.

You represent and warrant that all information provided to Aspora in connection with your use of the Services, including the purpose of the Transaction and the identity of the Recipient, is truthful, accurate, and complete.

Aspora reserves the right to monitor, review, and investigate all Transactions to ensure compliance with these Terms and Applicable Laws. This includes the right to:

(i) Request additional information to comply with AML, sanctions screening, or fraud prevention;

(ii) Refuse to process, suspend, or cancel any Transaction that, in Aspora’s sole discretion, is suspected of violating these Terms, Applicable Laws, or regulatory guidelines, pending investigation;

(iii) Report suspicious transactions to regulatory or law enforcement authorities, including the Financial Crimes Enforcement Network (FinCEN);

(iv) Freeze or close Accounts involved in prohibited activities.

If Aspora identifies that you have engaged in prohibited conduct, it reserves the right to take any appropriate action, including but not limited to:

(i) Terminating your Account without prior notice;

(ii)Forfeiting any funds associated with prohibited Transactions, where required by Applicable Laws;

(iii) Pursuing legal remedies against you for any damages, losses, or liabilities arising from your violation of these Terms.

Aspora will not process transactions involving individuals or entities on any U.S. government sanctions lists, including the Office of Foreign Assets Control (OFAC), Specially Designated Nationals (SDN) List, or transactions destined for prohibited jurisdictions.

8. Fees, exchange rates, and payment terms

8.1 Disclosure of Fees

Aspora charges fees for the use of its Services, which may include transaction fees, currency conversion fees, or payment method surcharges. These fees vary based on factors such as the transaction amount, destination country, payment method, and payout method selected.

Prior to confirming a Transaction, Aspora will disclose to you a detailed summary of the applicable fees, the total amount payable, and any additional costs that may be incurred. You acknowledge and agree that by confirming a Transaction, you consent to the application of the disclosed fees.

8.2 Exchange Rate Determination

If a Transaction involves currency conversion, Aspora will apply an exchange rate determined at its sole discretion, based on prevailing wholesale exchange rates and inclusive of a margin or markup to cover associated risks and costs.

The exchange rate applicable to your Transaction will be disclosed to you prior to confirmation of the Transaction. You acknowledge and accept that the disclosed exchange rate may differ from rates available elsewhere or in real-time foreign exchange markets.

All currency conversions executed by Aspora are final and non-reversible once the Transaction is confirmed by you. You acknowledge that exchange rates fluctuate and that the rate applicable to your Transaction may differ from the rate applicable at a future time, even within the same day.

Aspora reserves the right to modify its fees, exchange rate methodologies, and fee structures at any time, subject to applicable disclosure requirements under Applicable Laws.

Any changes to fees or exchange rates will become effective upon posting on Aspora’s website, Aspora App or as otherwise communicated to you, and will apply to Transactions initiated after such changes take effect.

Aspora will not retroactively adjust fees or exchange rates for Transactions that have already been confirmed.

8.3 Authorization to Charge Payment Instrument

By initiating a Transaction, you expressly authorize Aspora to charge your designated Payment Instrument for the total amount of the Transaction, including the transfer amount, fees, currency conversion charges, and any applicable third-party costs. If the payment authorization is declined or cannot be processed for any reason, the Transaction will not proceed, and Aspora shall have no obligation to complete the Transaction.

8.4 Payment Terms

To fund a Transaction, you authorize Aspora to debit or charge your designated payment instrument (such as a bank account, debit card, or credit card) for:

(a) The Transaction Amount,

(b) Any applicable Service Fees,

(c) Any currency conversion costs, and

(d) Any additional charges disclosed prior to confirmation.

Payments must be made in full and in the currency designated by Aspora at the time of the Transaction. Partial payments or payments in alternative currencies will not be accepted.

Certain payment methods (e.g., credit cards) may be treated as cash advances by your financial institution, potentially subjecting you to additional interest charges or fees from your card issuer. Aspora bears no responsibility for such charges.

All payments to Aspora are due immediately upon Transaction confirmation, unless otherwise expressly agreed in writing.

8.5 Payment Failures and Liability

If, after disbursement of funds to the Recipient, Aspora is unable to successfully collect payment from your designated funding source (including but not limited to Automated Clearing House (ACH) bank transfers, debit cards, or credit cards) due to insufficient funds, a declined transaction, chargeback, reversal, or any other failure, you remain fully liable to reimburse Aspora for the full Transaction Amount, along with any applicable fees, costs, or expenses incurred.

You acknowledge that certain payment methods, such as ACH transfers (electronic bank debits), may take several business days to fully settle. During this period, funds may be advanced to the Recipient before the settlement completes. Similarly, credit card payments may be authorized at the time of the transaction, but the final settlement can be declined later by your card issuer (e.g., due to disputes, insufficient credit, or account issues). In any such case, where Aspora has delivered funds but failed to receive payment from you, Aspora reserves the right to:

(a) Reattempt collection from your funding source,

(b)Initiate collections proceedings, and/or

(c) Exercise any other legal remedies available to recover the shortfall.

This obligation to reimburse Aspora survives the completion, cancellation, or termination of the transaction.

9. Transaction processing, errors, cancellation, and refund

9.1 Transaction Process and Completion

To initiate a Transaction, the Sender must provide all necessary details, including the Recipient’s information, transfer amount, currency, payout method, and Payment Instrument. Aspora will provide the Sender with a transaction summary displaying the applicable fees, exchange rate, estimated delivery time, and payout method prior to confirmation. By confirming the Transaction, the Sender authorizes Aspora to process the Transaction and to deduct the total amount, including applicable fees, from the designated Payment Instrument.

Payout methods and delivery times vary based on the Recipient’s location, payment network availability, and regulatory environment. While Aspora endeavors to meet estimated delivery times, such estimates are not guaranteed. Aspora shall not be held liable for delays in Transaction delivery arising from factors outside its control, including but not limited to, delays by financial institutions, payment networks, or regulatory authorities.

Where required byColumn Bank, Aspora will implement and enforce additional anti-money laundering(AML), know your customer (KYC), and sanctions screening procedures, includingbut not limited to enhanced due diligence, transaction monitoring, and regulatoryreporting, in accordance with Column Bank’s compliance program and applicablefederal banking regulations.

9.2 Error Resolution (Remittance Rule Compliance)

In accordance with the Electronic Fund Transfer Act (EFTA) and 12 C.F.R. Part 1005 (Regulation E), you have rights regarding errors in your transactions.

If you believe an error occurred (e.g., incorrect amount sent, unauthorized transaction), contact Aspora within 60 days of the transaction date at:

Email: legal@aspora.com

Phone (toll-free): (888) 261-7110

Mail: Office number 1236, 1000 N. West Street, Suite 1200 Wilmington Delaware 19801, United States of America

Upon receipt of your claim, Aspora will promptly initiate an investigation into the matter and provide you with a written response within ninety (90) days, although most claims are resolved sooner. If the investigation determines that an error occurred, Aspora will take appropriate corrective action, which may include refunding any applicable fees paid.

9.3 Cancellation of Transactions by User

You may request to cancel a Transaction if it has not yet been processed or completed by Aspora or the Third-Party Providers involved. To request cancellation, you must contact Aspora’s customer support through the designated communication channels provided in these Terms. Cancellation requests are subject to timing and may not be honored if the Transaction has been processed, paid out, or converted to a different currency.

9.4 Refunds for Cancelled or Failed Transactions

In the event of a cancelled or failed Transaction (whether initiated by you or Aspora), any amounts collected from your Payment Instrument that have not been disbursed to the Recipient will be refunded to you, less any non-refundable fees, exchange rate adjustments, or third-party costs incurred. Refunds will be processed through the original Payment Instrument used for the Transaction, unless otherwise required by Applicable Laws or agreed upon by Aspora. Refund processing times may vary depending on banking institutions, payment networks, and currency settlement periods. Aspora will not be liable for delays caused by third-party financial institutions.

10. Compliance and legal obligations

10.1 Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Compliance

Aspora is fully committed to complying with all Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) regulations in every jurisdiction where it operates, including but not limited to compliance with the Bank Secrecy Act (BSA), the USA PATRIOT Act, and applicable regulations issued by the Financial Crimes Enforcement Network (FinCEN) in the United States. As part of this commitment, Aspora maintains a comprehensive AML/CFT compliance program, which includes:

(a) Customer Due Diligence (CDD) and, where applicable, Enhanced Due Diligence (EDD) procedures, requiring Users to provide appropriate identification and verification documentation;

(b) Transaction monitoring systems designed to detect, prevent, and report suspicious activities, including those potentially linked to money laundering, terrorist financing, fraud, or other illegal activities;

(c) Ongoing training programs for employees, agents, and affiliates to ensure awareness of AML/CFT obligations, emerging risks, and regulatory developments;

(d) Timely filing of Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), and other regulatory filings with the appropriate authorities, as required by Applicable laws and regulations.

10.2 Sanctions Compliance (OFAC Regulations)

Aspora strictly adheres to all economic and trade sanctions programs administered by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury and any other applicable international sanctions authorities. Accordingly:

(a) Users are prohibited from initiating or participating in Transactions that involve sanctioned countries, territories, individuals, or entities identified on the Specially Designated Nationals (SDN) List, Non-SDN Lists, or any other relevant sanctions lists maintained by OFAC or other competent authorities;

(b) Aspora reserves the right to block, freeze, reject, delay, or report Transactions involving sanctioned jurisdictions, individuals, or entities, and may act in accordance with regulatory directives or enforcement actions;

(c) Aspora may, at its sole discretion, take proactive measures to ensure compliance with sanctions laws, including suspending or terminating User Accounts or rejecting Transactions suspected of violating such regulations.

10.3 Reporting Obligations and Cooperation with Authorities.

Aspora reserves the right to monitor all Transactions and Account activities for compliance purposes and to report any suspicious or unlawful activities to relevant regulatory and law enforcement authorities, including but not limited to FinCEN, OFAC, and other domestic or international bodies, as required under Applicable laws. By using the Services, you acknowledge and consent that Aspora may share your personal information, transaction details, and account records with such authorities without prior notice or consent, where necessary to comply with legal or regulatory obligations.

10.4 Recordkeeping Requirements

Aspora maintains comprehensive records related to Transactions, User identification, compliance reviews, and regulatory filings in accordance with applicable recordkeeping laws and regulations, including but not limited to AML/CFT statutes. Such records are retained for a minimum of ten (10) years from the date of the Transaction, closure of the Account, or filing of a report, or longer if required by Applicable laws or regulatory authorities. These records may be accessed and disclosed as needed for compliance audits, regulatory inspections, or legal proceedings.

11. Prohibited uses of Services

11.1 You agree not to use Aspora’s Services for any activities that:

(a) Violate Applicable laws or regulations, including but not limited to anti-money laundering (AML), counter-terrorism financing (CTF), and sanctions laws,

(b) Involve fraudulent, deceptive, or manipulative practices,

(c) Support illegal gambling, pornography, controlled substances, firearms, or counterfeit goods,

(d) Facilitate pyramid schemes, Ponzi schemes, or similar activities,

(e) Involve the purchase, sale, or exchange of cryptocurrencies without Aspora’s written consent,

(f) Engage in money mules or sending funds to unknown individuals for unclear purposes,

(g) Circumvent transaction limits or attempt to evade identity verification (e.g., by creating multiple accounts).

11.2 Aspora will not process transactions to or from:

(a) Individuals or entities on the OFAC Specially Designated Nationals (SDN) List,

(b) Persons identified by sanctions programs administered by FinCEN, OFAC, U.S. Department of State, or United Nations,

(c) Prohibited jurisdictions subject to comprehensive sanctions (e.g., North Korea, Iran, Syria, etc.).

11.3 If you engage in prohibited activities, Aspora may:

(a) Cancel or reverse transactions,

(b) Suspend or terminate your account,

(c) Report suspicious activity to relevant regulatory or law enforcement agencies.

12. Intellectual property rights

12.1 Intellectual Property Rights

All content, trademarks, service marks, trade names, logos, graphics, page headers, button icons, scripts, software, technology, source code, architecture, systems, text, images, and other materials (collectively, the “Intellectual Property”) made available or used in connection with Aspora’s Services, website, mobile application, or marketing materials are the sole and exclusive property of Vance Money Services LLC d/b/a Aspora or are licensed to Aspora by third parties. These assets are protected under United States intellectual property laws, including but not limited to copyright, trademark, trade secret, and patent laws, as well as international treaties and other applicable legal frameworks.

Subject to your compliance with this Agreement, Aspora grants you a limited, non-exclusive, non-sublicensable, non-transferable, and revocable license to access and use the Services solely for your personal, non-commercial purposes. This license does not grant any rights of ownership or entitlement in the Intellectual Property. Except for the limited rights expressly granted herein, no other rights are conveyed or implied, and all rights, title, and interest in and to the Intellectual Property remain solely with Aspora and its licensors.

You agree that any unauthorized use, reproduction, distribution, modification, adaptation, translation, reverse engineering, decompilation, or creation of derivative works from the Services or Intellectual Property, in whole or in part, is strictly prohibited and constitutes a material breach of this Agreement. Specifically, you shall not:

(a) Use framing techniques or meta-tags to enclose any Aspora trademark, logo, or proprietary information,

(b) Utilize automated systems such as bots, spiders, or scrapers to access or extract data from the Services,

(c) Challenge, contest, or assist others in contesting Aspora’s rights in any intellectual property,

(d) Remove, obscure, or modify any copyright, trademark, or other proprietary notices affixed to or contained within the Services, or

(e) Use any Aspora intellectual property in connection with any product or service that is not authorized or provided by Aspora, or in any manner likely to cause confusion**.**

12.2 Third-Party Software Disclaimer

Aspora’s Services may include or incorporate software, code, libraries, or other materials that are owned by third parties and licensed to Aspora (“Third-Party Software”). Your use of such Third-Party Software is subject to the license terms provided by those third parties, which may impose additional restrictions or grant additional rights beyond those described in this Agreement. Aspora makes no representations or warranties regarding any Third-Party Software and disclaims all liability related to its use, functionality, or availability. You agree to comply with all applicable third-party license terms when using the Services.

12.3 Enforcement and Jurisdiction

Aspora reserves the right to enforce its intellectual property rights to the fullest extent permitted by law, including seeking injunctive relief, damages, attorneys’ fees, and other available legal remedies. You acknowledge that any unauthorized use of Aspora’s Intellectual Property may cause irreparable harm that monetary damages alone may not adequately remedy. Accordingly, in the event of such a breach or threatened breach, Aspora is entitled to seek equitable relief, including temporary restraining orders or preliminary injunctions, without the necessity of posting bond or proving actual damages, in addition to pursuing any other legal or equitable remedies.

This Intellectual Property clause, and any disputes relating to it, are governed by the laws of the State of Delaware, United States of America, without regard to conflict of law principles, and subject to the Dispute Resolution provisions set forth in this Agreement. The rights and remedies set forth herein are cumulative and do not limit any other rights or remedies available to Aspora under law or in equity.

13. Warranties and disclaimers

13.1 No Warranty of Service Availability or Error-Free Performance

The Services provided by Aspora are offered on an “as is” and “as available” basis, without any warranties or representations of any kind, express or implied, including but not limited to, merchantability, fitness for a particular purpose, or non-infringement. Aspora does not warrant that the Services will be uninterrupted, error-free, or secure, or that defects, if any, will be corrected. We do not guarantee the timeliness, accuracy, or reliability of any information or processing provided through the Services.

13.2 Force Majeure Disclaimer

Aspora shall not be held liable for any failure, delay, suspension, or interruption in the performance of its obligations under this Agreement or in the provision of Services, to the extent that such failure or delay is caused by or results from circumstances beyond Aspora’s reasonable control (“Force Majeure Events”). These events include, but are not limited to:

(a) Acts of God, such as floods, hurricanes, earthquakes, tornadoes, wildfires, or other natural disasters,

(b) Public health emergencies, including but not limited to pandemics, epidemics, outbreaks of contagious diseases (e.g., COVID-19), and any resulting governmental restrictions or quarantine measures,

(c) Government actions, such as embargoes, sanctions, regulatory changes, licensing restrictions, or orders of courts or administrative agencies,

(d) Military conflicts, wars (declared or undeclared), invasions, terrorist acts, civil unrest, or insurrections,

(e) Labor disputes, strikes, lockouts, or industrial actions, whether involving Aspora’s personnel or third parties,

(f) Failures of essential services, including but not limited to power outages, water supply disruptions, or failures of telecommunications, internet service providers, hosting services, or data centers,

(g) Cybersecurity incidents, such as Distributed Denial-of-Service (DDoS) attacks, hacking, malware infections, or other malicious activities that impair system operations,

(h) Technological failures outside Aspora’s control, including outages or malfunctions of software platforms, APIs, mobile networks, banking systems, or payment processing networks (e.g., ACH, Visa, MasterCard, SWIFT),

(i) Supply chain disruptions affecting necessary third-party services, materials, or labor essential to Aspora’s operations.

In any such event, Aspora’s obligations will be deemed suspended for the duration of the Force Majeure Event, and Aspora shall not be liable for any damages, losses, or penalties arising from such delays or failures. Aspora will use commercially reasonable efforts to mitigate the impact of the Force Majeure Event and resume normal operations as soon as practicable. However, such efforts do not guarantee immediate resumption or performance.

If a Force Majeure Event continues for a period exceeding sixty (60) consecutive days, either party may terminate this Agreement with written notice to the other, without liability for such termination (excluding payment obligations accrued prior to the Force Majeure Event)

14. Limitation of liability and indemnification

14.1 Limitation of Liability

To the maximum extent permitted by Applicable laws, Vance Money Services LLC d/b/a Aspora, including its affiliates, directors, officers, employees, agents, licensors, contractors, and third-party service providers (collectively, the “Aspora Parties”), shall not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages. This includes, but is not limited to, loss of profits, loss of business opportunity, loss of revenue, loss of goodwill or reputation, data loss, corruption of data, system failure, or business interruption, arising out of or related to:

(a) Your use of or inability to use the Services,

(b) Delays, interruptions, errors, or failures in the processing, transmission, or completion of Transactions,

(c) Any unauthorized access to, use of, or alteration of your Account, personal data, or transaction information,

(d) The conduct, errors, omissions, or actions of third-party service providers, including payment processors, payout partners, telecommunications providers, financial institutions, or regulatory bodies, even if Aspora has been advised of the possibility of such damages, and

(e) Any force majeure event as defined herein in this Agreement.

Such limitations apply regardless of the form of action, whether based on contract, tort (including negligence), strict liability, or any other legal theory.

In no event shall the total aggregate liability of Aspora Parties arising out of or related to any single transaction, event, or series of related transactions under this Agreement exceed the total amount of fees paid by you to Aspora in connection with the specific Transaction(s) giving rise to the claim. This limitation applies cumulatively, meaning that multiple claims arising from a single Transaction or related series of Transactions will not exceed this cap.

You acknowledge that this limitation of liability is a fundamental part of the bargain between you and Aspora, and without it, Aspora would not be able to offer its Services.

15. Dispute resolution

You and Vance Money Services LLC d/b/a Aspora agree that any dispute, claim, or controversy arising out of or relating to these Terms, the Services, or any Transaction, whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory (collectively, “Disputes”), shall be resolved through final and binding arbitration rather than in court, except as expressly provided below. This arbitration agreement is intended to be interpreted broadly and applies to all Disputes between you and Aspora, including its affiliates, officers, directors, employees, agents, successors, and assigns.

Arbitration shall be administered either by the American Arbitration Association (AAA) in accordance with its Consumer Arbitration Rules or Commercial Arbitration Rules (as applicable), or by Judicial Arbitration and Mediation Services (JAMS) in accordance with its Streamlined Arbitration Rules (SAR) or Comprehensive Arbitration Rules (CAR) (as applicable), each as modified by this Agreement. The choice of AAA or JAMS may be made by the party initiating the arbitration or mutually by both the parties. The arbitration will be conducted by a single neutral arbitrator, selected in accordance with the applicable forum’s rules. Unless otherwise agreed by the parties, the arbitration shall be conducted in the State of Delaware, though proceedings may be conducted via videoconference or teleconference where appropriate to reduce costs and facilitate accessibility.

The arbitrator shall have the authority to award any relief available under Applicable laws, including injunctive relief, declaratory relief, and statutory damages, and must issue a written decision outlining the essential findings and conclusions supporting the award.

For claims of $10,000 or less, Aspora will pay all arbitration filing, administrative, and arbitrator fees, unless the arbitrator determines the claim is frivolous or brought in bad faith. For claims above $10,000, fees will be shared in accordance with the rules of the chosen arbitration provider (AAA or JAMS). However, Aspora will consider reasonable requests to advance or reimburse fees in cases of financial hardship. Each party is responsible for its own attorneys’ fees and costs, unless the arbitrator awards otherwise under Applicable laws.

You may opt out of this arbitration agreement by sending a written notice to Aspora at legal@aspora.com within thirty (30) days of accepting these Terms. The notice must include your full name, address, phone number, email address, and a clear statement that you wish to opt out of arbitration. Opting out will not affect the remaining provisions of this Agreement.

This arbitration agreement and any Dispute shall be governed by the laws of the State of Delaware, together with applicable federal laws of the United States, without regard to conflict of laws principles. Where arbitration is not applicable, the exclusive venue for any legal proceedings shall be the state or federal courts located in Delaware, and the parties’ consent to the personal jurisdiction of such courts.

There shall be no right or authority for any claim to be arbitrated or litigated on a class action, private attorney general, or any other representative basis. You and Aspora agree that any claim will be resolved by individual, binding arbitration. You and Aspora thereby each agree to waive any right to a jury trial and agree that you and we may bring claims against each other only in an individual capacity, and not as a plaintiff or class member in any purported class or representative proceeding.

16. Third-party providers

Aspora engages third-party providers (collectively, “Third-Party Providers”) to perform certain functions on its behalf, including but not limited to, payment processing, fund transfers, currency conversion, regulatory compliance services, identity verification, payout facilitation, (“Third-Party Services”). These Third-Party Providers may include financial institutions, correspondent banks, payment networks, money transfer operators, mobile wallet providers and identity verification agencies.

Aspora conducts reasonable due diligence and exercises commercially reasonable care in the selection of its Third-Party Providers. This includes ensuring that such providers comply with industry standards, Applicable Laws, and regulatory requirements relevant to the services they perform on behalf of Aspora. While Aspora endeavors to ensure the reliability and integrity of its Third-Party Providers, Aspora shall not be held liable for any acts, omissions, delays, errors, or failures by Third-Party Providers that are outside of Aspora’s reasonable control. This includes, but is not limited to:

(a) Delays in Transaction processing or payout caused by financial institutions, payment networks, or regulatory agencies;

(b) System outages or technical malfunctions experienced by Third-Party Providers;

(c) Incorrect information provided by Third-Party Providers that results in delays or errors in Transactions;

(d) Delay in delivery of the products or services by the Third-Party Providers under the loyalty reward program of Aspora.

By using the Services, you acknowledge and agree that certain aspects of your Transaction may be subject to the terms and conditions, privacy policies, and operating rules of Third-Party Providers engaged in facilitating your Transaction. It is your responsibility to review and accept any such third-party terms, where applicable.

17. Data privacy and protection

Aspora is committed to safeguarding your personal information and data privacy. Our collection, use, storage, disclosure, and protection of your personal information are governed by our Privacy Policy, which is incorporated by reference into these Terms. By agreeing to these Terms and using the Services, you also agree to the terms set forth in the Privacy Policy. You acknowledge that you have reviewed and understand how your personal data is handled.

Aspora reserves the right to update its Privacy Policy or privacy practices. Notice of material changes will be provided through the Services or via email. Continued use of the Services after such notice constitutes acceptance of the updated practices.

18. Miscellaneous

18.1 Entire Agreement

These Terms, along with the Privacy Policy, E-Sign Consent, CookiesPolicy and any other documents expressly incorporated by reference, constitute the entire agreement between you and Aspora regarding your use of the Services. They supersede any prior agreements, communications, or understandings (whether oral or written) between you and Aspora relating to the subject matter herein.

18.2 Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable under Applicable Laws, such provision shall be modified to the minimum extent necessary to make it enforceable, or if modification is not possible, deemed severed from the Agreement. The remaining provisions shall remain in full force and effect.

18.3 No waiver

Failure by Aspora to enforce any right or provision under these Terms shall not constitute a waiver of such right or provision. Any waiver must be in writing and signed by an authorized representative of Aspora to be effective.

18.4 Assignment

You may not assign or transfer your rights or obligations under these Terms without the prior written consent of Aspora. Aspora may assign or transfer its rights and obligations under these Terms, in whole or in part, without restriction or prior notice to you, including to any affiliate, subsidiary, or in connection with a merger, acquisition, or sale of assets.

19. Contact information

For questions, concerns, or to exercise any rights under these Terms, you may contact Aspora at:

Vance Money Services LLC (Aspora)

Office number 1236, 1000 N. West Street

Suite 1200 Wilmington

Delaware 19801 USA

Email: legal@aspora.com

Phone: (888) 261-7110