1. PURPOSE

1.1 These Cardholder Terms (“Card Terms”) set out the terms and conditions governing the issue and use of any card made available in connection with services provided by Digital Capital Ltd.

1.2 The purpose of these Card Terms is to:

• explain how cards may be issued, activated and used

• define the rights and obligations of the cardholder

• explain the circumstances in which transactions may be authorised, declined, delayed, reversed or disputed

• set out the security and fraud prevention requirements applicable to card use

• clarify the relationship between Digital Capital Ltd, the cardholder, merchants, processors and payment schemes

• ensure that card-related services are governed by a clear, fair and operationally robust framework

1.3 These Card Terms are intended to operate as a dedicated card services layer within Digital Capital’s wider legal and regulatory framework.

2. RELATIONSHIP WITH OTHER DOCUMENTS

2.1 These Card Terms form part of the broader legal framework applicable to your use of Digital Capital services.

2.2 They must be read together with, where relevant:

• the Account and Payment Services Agreement

• the Fees and Limits Schedule

• the Fraud, Unauthorised Payments and Reimbursement framework

• the Privacy Notice

• the Acceptable Use Policy

2.3 Where there is a conflict between these Card Terms and the general account agreement in relation to card-specific matters, these Card Terms take precedence to the extent of that conflict.

2.4 Nothing in these Card Terms displaces any rights or obligations that apply under mandatory law.

3. REGULATORY AND OPERATIONAL POSITIONING

3.1 Digital Capital Ltd is an authorised Electronic Money Institution.

3.2 Cards made available under these Card Terms are linked to services provided within Digital Capital’s regulated operating model.

3.3 Card services may be supported by third-party issuers, processors, scheme participants, programme managers, BIN sponsors or other service providers as part of the operating model.

3.4 The existence of such supporting parties does not mean that the cardholder contracts directly with all of them for all purposes.

3.5 Card transactions may be subject to scheme rules, processor requirements, fraud controls, legal obligations and operational restrictions in addition to these Card Terms.

4. WHO THESE TERMS APPLY TO

4.1 These Card Terms apply to:

• individual cardholders

• business customers receiving cards for their authorised users

• any authorised user to whom a card is issued or made available

• any person using a card or card credentials issued within the permitted scope of the relevant account relationship

4.2 Where a business customer is the account holder and a card is issued to an authorised user, both the business customer and the relevant user may be responsible for compliance with these Card Terms.

4.3 The business customer remains responsible for ensuring that authorised users understand and comply with applicable card obligations.

5. DEFINITIONS

5.1 In these Card Terms, unless the context requires otherwise:

“Account” means the relevant Digital Capital account, wallet or e-money balance to which the card is linked.

“Authorised User” means a person authorised by the account holder to use a card or card-linked service.

“Card” means any physical, virtual, tokenised or otherwise enabled payment card linked to the relevant Account.

“Card Credentials” means card number, expiry date, CVV/CVC, PIN, token, passcode or any other card security or authentication data.

“Cardholder” means the person in whose name the card is issued or the person authorised to use it.

“Card Transaction” means any payment, authorisation request, cash withdrawal, pre-authorisation, recurring card payment, card-not-present payment, tokenised payment or other card-linked transaction.

“Merchant” means a person or business accepting the card as a means of payment.

“Payment Scheme” means the relevant card network or scheme through which card transactions are processed, including Mastercard where applicable.

“Strong Customer Authentication” or “SCA” means authentication procedures required by applicable law or operational controls.

“Unauthorised Card Transaction” means a card transaction made without the required consent of the cardholder or account holder, subject to applicable law.

6. CARD TYPES

6.1 Cards may be made available in one or more of the following forms:

• physical cards

• virtual cards

• tokenised cards used through wallets or devices

• single-use or limited-use card credentials, where applicable

• supplementary or user-specific cards linked to a business account, where applicable

6.2 Cards may vary by:

• functionality

• permitted use cases

• spending limits

• geographic scope

• card-present or card-not-present capability

• cash withdrawal capability

• wallet enablement

• expiry profile

• product configuration

6.3 Not all card features are available for all customers, geographies or products.

7. ELIGIBILITY FOR CARD SERVICES

7.1 Card services may only be made available where Digital Capital determines that the relevant account, customer type, jurisdiction, compliance profile and product configuration support the issuance or provision of card functionality.

7.2 Digital Capital may refuse to issue, enable or continue a card for reasons including:

• regulatory requirements

• fraud or financial crime concerns

• risk profile

• customer type restrictions

• operational limitations

• card programme constraints

• account status or account restrictions

7.3 Eligibility may be reassessed on an ongoing basis.

8. ISSUE OF CARDS

8.1 A card may be issued or made available to you following approval of the relevant account and satisfaction of applicable onboarding, verification, risk and operational requirements.

8.2 A card may be issued:

• in your name

• to an authorised user nominated by the account holder

• through a digital flow allowing virtual card issuance or activation

• through a replacement or renewal process

8.3 Digital Capital may decide whether to issue a physical card, virtual card or both.

8.4 A card remains subject to activation, controls and ongoing eligibility checks.

9. CARD OWNERSHIP AND STATUS

9.1 The card itself, the card number range, and the related card infrastructure remain subject to the rights and control of the issuing and programme structure through which the card is made available.

9.2 The cardholder receives a right to use the card in accordance with these Card Terms, but does not acquire ownership of the scheme relationship, programme infrastructure or card issuance rights.

9.3 Digital Capital may require a card to be suspended, cancelled, replaced, returned, destroyed or disabled where appropriate.

9.4 Digital Capital may also reissue cards, migrate card products or update card credentials where required for operational, scheme, security or regulatory reasons.

10. CARD DELIVERY AND AVAILABILITY

10.1 Physical cards may be delivered to an address approved by Digital Capital or made available through an approved distribution process.

10.2 Virtual cards may be displayed, generated or enabled through a secure digital interface.

10.3 Delivery timeframes are indicative only and may be affected by:

• production constraints

• compliance reviews

• verification status

• postal or courier delays

• country restrictions

• technical factors

10.4 Digital Capital is not liable for delays outside its reasonable control.

11. CARD ACTIVATION

11.1 A card must be activated before it can be used, unless it has already been activated through an approved digital issuance flow.

11.2 Activation may require:

• secure login

• confirmation of receipt

• identity or user verification

• PIN setup

• device validation

• other authentication steps

11.3 Digital Capital may refuse or delay activation where:

• fraud or misuse is suspected

• the cardholder or account status has changed

• compliance concerns arise

• operational restrictions apply

12. LINK TO ACCOUNT BALANCE

12.1 Card transactions are linked to the relevant Account and may be funded from the e-money balance or other permitted balance structure associated with that Account.

12.2 Availability of funds for card use depends on:

• the available balance

• outstanding authorisations

• pending transactions

• fees

• reversals

• restrictions or holds

• delayed or offline processing

12.3 Displayed balances may not always reflect all pending authorisations, delayed postings or scheme timing effects.

12.4 It is your responsibility to maintain sufficient available funds where the card is intended to be used.

13. GENERAL RULES OF CARD USE

13.1 You may only use the card:

• lawfully

• for the purposes permitted by these Card Terms

• in accordance with applicable laws, regulations and scheme restrictions

• in accordance with the Acceptable Use Policy

13.2 You must not use the card in connection with:

• prohibited or unlawful activity

• activity restricted under the Acceptable Use Policy

• attempts to circumvent controls, limits or restrictions

• activity likely to expose Digital Capital to fraud, legal or reputational risk

• misuse of pre-authorisation, dispute or chargeback processes

13.3 Use of the card is subject to merchant acceptance and technical availability.

14. CARD-PRESENT, CARD-NOT-PRESENT AND TOKENISED USE

14.1 The card may, depending on configuration, be used for:

• in-person card-present transactions

• online or app-based card-not-present transactions

• recurring merchant instructions

• digital wallet or tokenised transactions

• contactless transactions

• ATM withdrawals, where enabled

14.2 Specific transaction types may be enabled, restricted or disabled depending on:

• customer risk profile

• geography

• merchant type

• card product settings

• legal or regulatory restrictions

• fraud controls

14.3 Digital Capital may disable or restrict particular transaction channels without prior notice where necessary.

15. BUSINESS USE AND AUTHORISED USER CONTROLS

15.1 Where a card is linked to a business account, the business customer may be able to issue or request cards for authorised users.

15.2 In such cases, the business customer is responsible for:

• ensuring that each user is properly authorised

• ensuring that use of the card is within internal business permissions

• promptly notifying Digital Capital of role changes, misuse or withdrawal of authority

• monitoring activity relevant to its own users to the extent functionality is provided

15.3 Digital Capital may impose additional controls on business account cards, including:

• per-user limits

• merchant restrictions

• geography restrictions

• category restrictions

• virtual-card-only issuance

• restricted withdrawal rights

15.4 The business customer remains liable for card use by its authorised users unless mandatory law provides otherwise.

16. CARD SECURITY OBLIGATIONS

16.1 You must keep the card and all card credentials safe and secure at all times.

16.2 You must take all reasonable steps to prevent:

• loss or theft of the card

• unauthorised disclosure of card credentials

• unauthorised access to devices used for card authentication or wallet access

• use of the card by unauthorised persons

16.3 In particular, you must not:

• share your PIN or security credentials

• write down or store PINs or security data in an insecure manner

• disclose the CVV/CVC, one-time passcodes or authentication credentials to unauthorised persons

• leave a physical card unattended in insecure circumstances

• allow another person to use the card unless expressly authorised under the relevant account structure

16.4 You must also take reasonable care to detect phishing, impersonation, social engineering and other fraud attempts.

17. DIGITAL WALLET AND DEVICE SECURITY

17.1 Where the card is used through a digital wallet or device, you are responsible for ensuring that the relevant device is appropriately secured.

17.2 This includes:

• enabling device access controls

• protecting wallet access

• reporting loss or compromise of the device

• removing the card from compromised or transferred devices where possible

17.3 Digital wallet use may be subject to additional wallet-provider conditions and technical requirements.

17.4 Digital Capital is not responsible for the independent operation of third-party wallet providers.

18. PIN, PASSWORD AND AUTHENTICATION CARE

18.1 You must use reasonable care when creating, storing and using all card-related security credentials.

18.2 Where multi-factor authentication, SCA or additional security prompts are used, you must follow the relevant instructions and not attempt to bypass them.

18.3 Failure to use authentication measures responsibly may affect fraud outcomes, liability assessment and continued access to card services.

19. LOST, STOLEN OR COMPROMISED CARDS

19.1 You must notify Digital Capital immediately if:

• the card is lost

• the card is stolen

• card credentials are disclosed or suspected to be compromised

• a device linked to the card is lost or compromised

• unauthorised use is suspected

19.2 Prompt notification is a critical control and may materially affect risk, losses and, where relevant, liability analysis.

19.3 On receiving notification, Digital Capital may:

• block the card

• suspend wallet usage

• stop further transactions where possible

• investigate recent activity

• issue a replacement card or credentials

20. RIGHT TO BLOCK, RESTRICT OR REPLACE A CARD

20.1 Digital Capital may block, restrict, suspend, cancel, replace or reconfigure a card where this is justified by:

• security concerns

• suspected fraud

• suspicious activity

• sanctions or legal restrictions

• breach of these Card Terms or other applicable terms

• changes in account status

• operational or scheme requirements

• card programme changes

• product migration or renewal

20.2 Where legally and operationally appropriate, Digital Capital may inform you of the action taken and the reasons for it.

20.3 In some circumstances, Digital Capital may be restricted from giving full reasons, including where doing so would prejudice fraud prevention, investigations or legal obligations.

21. LIMITATIONS OF MERCHANT ACCEPTANCE

21.1 The fact that a card has been issued does not guarantee that every merchant, ATM, website, wallet provider, terminal, processor or country will accept it.

21.2 Acceptance depends on factors including:

• merchant acceptance rules

• scheme participation

• technical compatibility

• local restrictions

• transaction type

• card configuration

• fraud controls

21.3 Digital Capital is not responsible for a merchant’s refusal to accept the card.

22. GENERAL LIMITS ON CARD FUNCTIONALITY

22.1 Digital Capital may apply limits or restrictions to card usage, including limits based on:

• transaction amount

• daily or periodic spend

• ATM withdrawals

• geography

• merchant category

• device usage

• customer type

• risk level

22.2 Such limits may change over time and may be applied dynamically without prior notice where appropriate.

22.3 Limits are a control measure and do not create a commitment that transactions within those limits will always be approved.

23. FEES AND CHARGES APPLICABLE TO CARD USE

23.1 Card use may involve fees and charges as set out in the Fees and Limits Schedule.

23.2 These may include, where applicable:

• issuance fees

• replacement fees

• ATM fees

• foreign exchange charges

• express delivery fees

• dispute or exceptional handling fees where legally and contractually applicable

• third-party charges not imposed directly by Digital Capital

23.3 Charges applicable to card use must be read together with the Fees and Limits Schedule, which forms part of the overall legal framework.

24. FOREIGN USE OF THE CARD

24.1 The card may be used internationally where supported by the relevant card programme, legal requirements, fraud controls and scheme availability.

24.2 International use may involve:

• currency conversion

• merchant location risk controls

• increased fraud screening

• country-based restrictions

• third-party or scheme limitations

24.3 Use in some jurisdictions may be restricted or declined.

25. NO RELIANCE ON CARD AS EMERGENCY OR GUARANTEED ACCESS TOOL

25.1 The card should not be relied upon as the sole or guaranteed means of access to funds in all circumstances.

25.2 Card access may be affected by:

• technical issues

• merchant rejection

• fraud controls

• scheme outages

• account restrictions

• delayed or offline posting

• cash withdrawal unavailability

25.3 It is your responsibility to manage your funds and payment arrangements prudently.

26. CHANGES TO CARD FEATURES AND FUNCTIONALITY

26.1 Digital Capital may add, remove, amend or restrict card features over time.

26.2 Changes may affect:

• wallet enablement

• withdrawal capability

• transaction categories

• tokenisation

• controls and limits

• geographic usage

• virtual or physical issuance

26.3 Where required by law, material changes will be notified in advance.

26.4 Some changes may be made immediately where required for security, fraud prevention, scheme compliance, legal reasons or urgent operational needs.

27. RECORDS OF CARD USE

27.1 Digital Capital maintains records of card activity, authorisations, postings, reversals, disputes and related events.

27.2 Those records may be used for:

• account information

• investigations

• dispute review

• fraud analysis

• legal and regulatory compliance

• operational review

27.3 Such records may include scheme and processor data, authentication records, device indicators and merchant-related information where available.

28. OVERVIEW OF CARD TRANSACTIONS

28.1 A card transaction may involve multiple stages, including:

• authorisation

• clearing

• settlement

28.2 These stages may occur:

• immediately

• with delay

• across different systems and institutions

28.3 The timing and outcome of a card transaction depend on:

• merchant systems

• payment scheme rules

• processor behaviour

• fraud controls

• network availability

29. AUTHORISATION OF CARD TRANSACTIONS

29.1 A card transaction is authorised when you:

• use your card at a merchant

• provide card credentials

• authenticate the transaction

• approve via Strong Customer Authentication where required

29.2 Authorisation may involve:

• PIN entry

• contactless usage

• one-time passcodes

• biometric authentication

• device-based approval

29.3 Once authorised, a transaction may proceed to clearing and settlement.

30. STRONG CUSTOMER AUTHENTICATION (SCA)

30.1 Where required, transactions may be subject to Strong Customer Authentication.

30.2 Failure to complete authentication may result in:

• transaction decline

• transaction delay

30.3 Additional authentication may be required at any time for risk or regulatory reasons.

31. TRANSACTION DECLINES

31.1 A transaction may be declined for reasons including:

• insufficient available funds

• fraud or risk concerns

• failed authentication

• system or network issues

• merchant rejection

• scheme rules

• regulatory restrictions

31.2 A declined transaction does not necessarily indicate an error.

31.3 Digital Capital is not liable for losses arising from declined transactions.

32. PRE-AUTHORISATIONS

32.1 Some merchants may request a pre-authorisation.

32.2 This is common in:

• hotels

• car rentals

• fuel stations

• travel services

32.3 A pre-authorisation may:

• reserve an amount

• reduce available balance

32.4 The final transaction amount may:

• differ from the pre-authorised amount

33. RELEASE OF PRE-AUTHORISED FUNDS

33.1 Reserved funds are released when:

• the merchant completes or cancels the transaction

• the authorisation expires

33.2 Release timing depends on:

• merchant behaviour

• scheme rules

33.3 Digital Capital cannot control how quickly a merchant releases a pre-authorisation.

34. OFFLINE TRANSACTIONS

34.1 Some transactions may be processed offline.

34.2 This means:

• authorisation may not occur in real time

• transactions may be processed later

34.3 Offline transactions may:

• exceed the available balance at the time

• appear after a delay

34.4 You remain responsible for such transactions.

35. DELAYED TRANSACTION POSTING

35.1 Transactions may be posted after a delay due to:

• offline processing

• merchant submission timing

• scheme processing cycles

35.2 Your available balance may not reflect these pending transactions.

36. RECURRING PAYMENTS

36.1 You may authorise recurring card payments.

36.2 These may include:

• subscriptions

• memberships

• merchant billing arrangements

36.3 You are responsible for:

• managing and cancelling recurring payments

36.4 Digital Capital cannot cancel recurring payments on your behalf without appropriate instruction.

37. MERCHANT RELATIONSHIP

37.1 Card transactions involve a direct relationship between you and the merchant.

37.2 Digital Capital:

• does not supply goods or services

• is not responsible for merchant performance

37.3 Any disputes about goods or services must be addressed with the merchant first.

38. FX (FOREIGN EXCHANGE) FOR CARD TRANSACTIONS

38.1 Where a card transaction involves currency conversion:

• an exchange rate is applied

• a margin may be included

38.2 The exchange rate may:

• differ from mid-market rate

• be determined by the card scheme or processor

39. FX DISCLOSURE

39.1 FX information may include:

• exchange rate

• applicable margin

39.2 The final amount charged may differ from the original amount due to FX.

40. MULTI-CURRENCY AND DCC (DYNAMIC CURRENCY CONVERSION)

40.1 Some merchants may offer Dynamic Currency Conversion (DCC).

40.2 This allows payment in your home currency at the merchant’s rate.

40.3 You should consider carefully whether to accept DCC.

40.4 Digital Capital does not control DCC rates.

41. PARTIAL AUTHORISATIONS

41.1 In some cases, a transaction may be partially authorised.

41.2 This may occur where:

• available balance is insufficient

42. SPLIT TRANSACTIONS

42.1 Merchants may split transactions.

42.2 This may result in:

• multiple charges

43. REVERSALS AND ADJUSTMENTS

43.1 Transactions may be reversed or adjusted.

43.2 This may occur due to:

• merchant correction

• refunds

• processing errors

44. TRANSACTION CONFIRMATION

44.1 Confirmation of a transaction does not guarantee:

• final settlement

• successful completion

44.2 Settlement depends on scheme completion.

45. TRANSACTION LIMITATIONS

45.1 Transactions may be subject to:

• card limits

• regulatory restrictions

• risk controls

46. FRAUD AND RISK CONTROLS

46.1 Digital Capital may:

• delay transactions

• request verification

• block transactions

46.2 These measures are designed to:

• prevent fraud

• protect customers

47. SCHEME DEPENDENCY

47.1 Card transactions depend on:

• payment scheme rules

• processors

• third parties

47.2 Digital Capital is not responsible for failures of these parties.

48. TECHNICAL FAILURES

48.1 Transactions may fail due to:

• system errors

• network issues

49. RECORD OF TRANSACTIONS

49.1 Transaction records are maintained.

49.2 These may be used for:

• dispute handling

• investigations

50. FINAL POSITION

50.1 Card transactions are subject to multiple operational layers.

50.2 Outcomes may vary based on:

• scheme rules

• merchant behaviour

• technical factors

51. OVERVIEW OF DISPUTES

51.1 A dispute may arise where:

• you do not recognise a transaction

• you did not authorise a transaction

• there is an issue with goods or services

• a transaction has been incorrectly processed

51.2 Disputes may be handled through:

• merchant resolution

• scheme processes

• internal review

52. MERCHANT DISPUTES

52.1 Where a dispute relates to goods or services:

• you must first contact the merchant

52.2 Digital Capital:

• does not supply goods or services

• is not responsible for merchant performance

52.3 Failure to resolve with the merchant may allow escalation.

53. CHARGEBACK PROCESS

53.1 Chargebacks are handled in accordance with card scheme rules.

53.2 The process may include:

• claim submission

• evidence collection

• merchant response

• scheme review

• arbitration

53.3 The outcome depends on:

• scheme rules

• evidence provided

54. CHARGEBACK ELIGIBILITY

54.1 A chargeback may be available where:

• a transaction is unauthorised

• goods/services not received

• transaction processed incorrectly

54.2 Chargeback eligibility is not guaranteed.

55. EVIDENCE REQUIREMENTS

55.1 You may be required to provide:

• receipts

• communication with merchant

• proof of non-delivery

55.2 Failure to provide evidence may result in:

• rejection of claim

56. TIME LIMITS

56.1 Claims must be submitted within applicable timeframes.

56.2 Time limits depend on:

• scheme rules

• transaction type

57. SCHEME DEPENDENCY

57.1 Chargebacks depend on:

• payment scheme rules

• merchant bank response

57.2 Digital Capital does not control:

• scheme outcomes

• merchant decisions

58. PROVISIONAL REFUNDS

58.1 We may provide provisional refunds.

58.2 These may be reversed if:

• claim is not upheld

59. FINAL OUTCOME

59.1 Final outcomes depend on:

• investigation

• scheme process

LIABILITY FRAMEWORK

60. UNAUTHORISED TRANSACTIONS

60.1 A transaction is unauthorised where:

• you did not consent

61. REFUNDS FOR UNAUTHORISED TRANSACTIONS

61.1 Where required by law, we will:

• refund unauthorised transactions

• restore your balance

62. CONDITIONS FOR REFUND

62.1 Refunds may depend on:

• prompt notification

• compliance with security obligations

63. CUSTOMER LIABILITY

63.1 You may be liable where:

• fraud

• gross negligence

64. LIMITATION OF LIABILITY

64.1 Subject to law, liability is limited.

65. AUTHORISED TRANSACTIONS

65.1 Transactions you approve are considered authorised.

65.2 Authorised transactions are not refundable unless required by law.

66. DISPUTES VS UNAUTHORISED

66.1 Merchant disputes are not the same as unauthorised transactions.

FRAUD AND SCAM PROTECTION

67. FRAUD DETECTION

67.1 We monitor transactions for fraud.

68. SECURITY CONTROLS

68.1 We may:

• block transactions

• apply verification

69. APP FRAUD

69.1 APP fraud occurs where:

• you are deceived into making a payment

70. APP FRAUD LIABILITY

70.1 Reimbursement is not automatic.

70.2 Assessment is case-by-case.

71. CUSTOMER RESPONSIBILITY

71.1 You must:

• verify transactions

• avoid scams

72. FAILURE TO TAKE CARE

72.1 Ignoring warnings may affect outcomes.

73. FRAUD INVESTIGATION

73.1 We may investigate:

• transaction data

• behaviour

74. COOPERATION

74.1 You must cooperate.

75. ACCOUNT RESTRICTIONS

75.1 We may restrict accounts.

76. REPORTING

76.1 Fraud may be reported to authorities.

FINAL PROVISIONS

77. DISPUTE ESCALATION

77.1 Complaints may be raised under Complaints Policy.

78. FINANCIAL OMBUDSMAN

78.1 Eligible customers may escalate.

79. RECORD KEEPING

79.1 We maintain records of disputes.

80. FINAL POSITION

80.1 Card use involves:

• scheme rules

• operational factors

• risk controls