Partner Terms and Conditions


1.1 The Partner shall refer potential customers who meet the Qualifying Criteria to the Company using a format and method agreed by the Parties from time to time.

1.2 The Company shall notify the Partner in writing of any changes in the Qualifying Criteria.

1.3 The Company shall review all Referrals made by the Partner and advise the Partner (and keep records indicating) which Referrals have been accepted as Qualifying Leads.

1.4 The Partner acknowledges that the arrangements between it and the Company are not exclusive and that the Company may accept a referral from another intermediary or partner at any time until that referral becomes a Qualifying Lead.

1.5 The Partner acknowledges that the Company is under no obligation to follow up on any Referral or to enter into a contract with any Referral or Qualifying Lead.


Subject to clause 8, these Terms shall continue in force until terminated by either Party giving the other Party not less than 10 Business Days' written notice of termination.


3.1 Referral Fees shall be calculated by the Company based on a percentage of Profit and/or Turnover as set out in the ’Referral Letter.

3.2 The Partner shall be entitled to Referral Fees for all Qualifying Leads, with the exception of any Referral Fee where the Company identifies any suspected fraudulent or illegal activity concerning the Qualifying Lead. Any Referral Fees already paid in circumstances where the Company has identified fraudulent or illegal activity shall be repaid to the Company by the Partner. The repayment shall be made within 10 Business Days of the Partner receiving an invoice for the same.

3.3 Within 30 days following the end of each reporting period (being a month or such other period as the Company may from time to time determine) the Company shall send the Partner a statement listing all Qualifying Leads identified during that period and setting out the Referral Fees due. Other than in the case of manifest error, each of these statements shall be binding on the Partner. Subject to clause 3.4, Referral Fees shall be paid to the Partner at the account and in the currency set out in the Referral Letter within 30 Business Days of the statement being issued by the Company.

3.4 If the Partner stops making Referrals under these Terms for a period of 365 days or more, then the Company may accrue Referral Fees which remain due but unpaid at the end of that 365 day period and shall pay them when Referrals resume and a statement is issued in accordance with clause 3.3 . If no further Referrals are made, accrued Referral Fees may, after a further 180 day period has elapsed, be retained by the Company and paid into its own account.

3.5 Referral Fees are inclusive of all taxes and charges (including value added tax) wherever imposed and any such taxes and charges applied to the Referral Fees shall be the sole liability of the Partner. The Partner agrees to pay all such taxes and charges promptly to the relevant authority.


4.1 The Parties represent and warrant to each other on the date of the Referral Letter and on each date that a Referral is made under these Terms that:

(a) all licences, consents, registrations and regulatory permissions (including registration with the Information Commissioner’s Office) required by the Party to make or accept Referrals and to perform its obligations under these Terms are in full force and effect;

(b) no legal action, intervention or investigation by the police or any Regulatory Body in any jurisdiction is being carried out in relation to the Party or any of its directors or officers or (to the best of its knowledge) is threatened against it or any of its directors or officers;

(c) it has the power and authority to enter into these Terms and the Referral Letter; and

(d) these Terms and the Referral Letter are legally binding on the Party and enforceable against it.

4.2 The Partner represents and warrants to the Company on the date of the Referral Letter and on each date that a Referral is made under these Terms that all responses to the most recently completed Partner Questionnaire remain accurate and complete.


The Partner undertakes to the Company that it shall:

(a) act in good faith when dealing with the Company;

(b) carry out its business and make referrals to the Company under these Terms in accordance with Law and, in particular, shall observe all Laws relating to the prevention of money laundering and financial crime and shall pay all taxes properly levied on it by the due date;

(c) use reasonable efforts to market and promote the Company and its business in accordance with these Terms;

(d) comply with all reasonable and lawful instructions given by the Company in connection with these Terms;

(e) act in good faith towards, and in such a way as to deliver good outcomes for, Referrals and potential Referrals;

(f) disclose the fact that it acts as an introduction agent for the Company and receives Referral Fees to potential Referrals prior to making any referral;

(d) ensure that all Personal Data and other details supplied by it to the Company in connection with Referrals are complete and accurate in all material respects;

(e) screen each Referral in order to ensure compliance with the Qualifying Criteria prior to making any referral of that person under these Terms;

(f) obtain consent from each Referral before referring them under these Terms, such consent to comprise a positive recorded response to the question "Is it okay for me to share your name and contact details with [name of the Company] so that they can contact you about their money transfer service?"

(g) notify the Company immediately in writing if it identifies any Referral or Qualifying Lead as being vulnerable or potentially involved in fraud or other illegal activity;

(h) maintain and prominently display an accurate privacy notice which informs individuals about how their Personal Data will be used, including a specific reference to the making of referrals to the Company, and shall supply a copy of that notice to the Company upon request;

(i) ensure that its website (including any links contained in the website) is free of viruses and safe to use and that its website and communications do not contain any material likely to bring it or the Company into disrepute;

(j) maintain appropriate safeguards designed to protect consumers from fraud and shall warn Referrals and Qualifying Leads in writing of the risk of authorized push payment fraud and specifically of the danger of payee details being intercepted; (k) share the Company’s account details with third parties only by means of secure transfer and not by email or text;

(k) not pass itself off as the Company or as a member of the Company’s Group or present itself as being in a joint-venture with, or as an affiliate, agent or endorsee of any of them or represent itself as being a regulated entity if it is not or as being authorized to bind the Company or create a domain name which is similar to any domain name used by the Company or any of its Group members;

(l) not make any representations or promises about the Company’s services that are not contained in the Company’s own marketing material; and

(m) shall notify the Company immediately in writing if any representation or warranty made by it in clause 5 becomes incorrect or it breaches any undertaking made by it in these Terms.


Each Party undertakes not to engage (and undertakes to procure that none of its directors, agents, contractors or employees engage) in any activity, practice or conduct which would constitute an offence under the Bribery Act 2010 or under any broadly equivalent laws of any other jurisdiction and undertakes to maintain in place throughout the Term, and to enforce, policies and procedures designed to ensure compliance with that Act and those other laws and, as regards the Partner, to counter the risk of conflicts of interest arising in relation to its making of referrals under these Terms.


7.1 Each Party agrees to comply with Data Protection Legislation in connection with the Relevant Personal Data which it processes.

7.2 Each Party agrees that Relevant Personal Data may be shared between the Parties and that each Party shall act as Data Controller in relation to Relevant Personal Data processed by it.

7.3 Each Party shall:

(a) implement all appropriate technical and organisational measures to ensure that the Relevant Personal Data is at all times kept secure, confidential and protected against unauthorised processing and against accidental loss, damage or destruction;

(b) ensure that it has all necessary consents in place and can demonstrate appropriate lawful bases to process the Relevant Personal Data;

(c) ensure that all transfers of Relevant Personal Data by it are carried out in a secure manner and where sent by email, ensure that the details are contained in a zipped file with a password sent separately;

(d) maintain a secure email system protected by end-to-end encryption;;

(e) cooperate with and assist the other Party in responding to any complaints or requests made by any person in connection with Relevant Personal Data under Data Protection Legislation and in responding to any queries made by, and ensuring compliance with instructions given by, any Regulatory Body in connection with Relevant Personal Data;

(f) notify the other Party promptly upon becoming aware of any breach of Data Protection Legislation in relation to Relevant Personal Data and cooperate with the other Party to make any notifications to the data subjects concerned and to the relevant Regulatory Bodies; and

(g) keep records of consents obtained by it in connection with Relevant Personal Data (including consents to referral under these Terms) and make those records available to the other Party promptly upon request.

7.4 The obligations of a Party under this clause shall survive any termination of these Terms and continue for so long as that Party continues to process any Relevant Personal Dat


Either Party may terminate these Terms in accordance with clause 2 or with immediate effect by written notice to the other Party if either of the following events occur:

(a) the other Party commits a material breach of these Terms which is incapable of remedy or is capable of remedy but is not remedied within10 Business Days of the breach occurring; or

(b) any representation or warranty made by the other Party in these Terms is untrue in any material respect.


9.1 Upon termination of these Terms, all licences granted under clause 10 shall terminate, the Partner shall immediately re-deliver to the Company or delete (at the Company’s option) all materials and data provided by the Company to the Partner in connection with these Terms and shall remove all links to the Company’s website and all Company Marks from the Partner’s website and from other marketing communications.

9.2 Termination of these Terms shall not prejudice any rights of either Party that have accrued before the date of termination and these Terms shall continue to apply to all Referrals made prior to the date of termination.


10.1 Nothing in these Terms shall operate to transfer any Intellectual Property Rights belonging to a Party to the other Party.

10.2 The Company may from time to time consent in writing to the Partner using certain Company Marks for the purpose of marketing the Company’s services and the Company hereby grants to the Partner, for the duration of the Term, a non-exclusive, revocable, royalty free, non-transferable licence to use those Company Marks exclusively for that purpose.

10.3 All advertising, marketing, newsletters, promotions, communications and website pages used by or on behalf of the Partner and which refer to the Company or any of its Group members or which feature any of the Company’s or Group member’s Marks, together with the scope,nature and duration of any marketing campaign featuring any of the foregoing, must be approved in writing by the Company.before release or publication. The Partner hereby authorizes the Partner to hyperlink its website to the Company’s website for the purpose of promoting the Company’s business.

10.4 The Partner shall ensure that all electronic marketing carried out by it complies with Data Protection Legislation.

10.5 The Partner shall not duplicate any materials supplied by the Company or obtained from the Company’s website on its own website or in its own communications without obtaining the Company’s prior consent.


Each Party shall keep all confidential information relating to the other Party's business which comes into its possession secure and confidential and will not disclose it to third parties, provided that it may disclose the information on a confidential basis to its directors, officers, employees, contractors, insurers and professional advisers and, in the case of the Company, to its Group members and each Party may also disclose the information if required to do so by law, regulation, court order or as a result of a request made by a Regulatory Body. Information which is already in the public domain other than as a result of a breach of these Terms or which has been independently produced by the Party concerned or which was in the relevant Party’s possession prior to the date of the Referral Letter is not ‘’confidential information’’ for the purposes of this clause. The obligations contained in this clause shall survive for two years after the termination of these Terms for any reason.


12.1 Subject to clause 12.2, each Party (the ‘’First Party’’) shall indemnify the other Party for any costs, claims or damages suffered by the other Party, including reasonable legal fees and expenses but excluding any consequential costs, as a direct result of a breach by the First Party of any of these Terms except where such breach results from the gross negligence or willful default of the other Party.

12.2 The maximum aggregate liability of a Party under or in connection with these Terms in respect of all acts or omissions shall not exceed the total Referral Fees paid or payable by the Company in the 12-month period immediately preceding the circumstances giving rise to the claim.

12.3 This clause shall survive any termination of these Terms.


13.1 Neither Party shall be entitled to assign, transfer or sub-contract any of its rights or obligations under these Terms, without the prior written consent of the other Party.

13.2 Any notice given under these Terms shall be in writing, delivered by email to the email set out in the Referral Letter (or such other email address as is notified by one Party to the other from time to time for the purpose of receiving notices) or by first class post or courier to the address given at the start of these Terms. Notices sent by email on a Business Day shall be deemed received on that Business Day or if sent on a non-Business Day, on the next Business Day. Notices sent by first class post shall be deemed to have been given two Business Days after the date of posting and notices sent by courier shall be deemed received on the next Business Day.

13.3 The Company may vary these Terms from time to time by serving at least 5 Business Days’ prior written notice on the Partner, setting out details of the variation.

13.4 If any provision of these Terms is found by any court of competent jurisdiction to be illegal, invalid or unenforceable, such illegality, invalidity or unenforceability shall not affect the other provisions of these Terms which shall remain in full force and effect.

13.5 No failure or delay in exercising any right under these Terms shall be treated as a waiver of that right and all waivers given under these Terms shall be in writing.

13.6 A person who is not party to these Terms shall have no rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any provision of these Terms.

13.7 The Parties are independent of each other, do not act as agent and principal and nothing in these Terms is intended to create a partnership or joint venture between them.

13.8 These Terms, the Referral Letter and the terms contained on the registration section of the Partner Portal on the Company’s website contain the whole agreement between the Parties and in the event of any conflict between terms, these Terms shall prevail unless the Parties expressly otherwise agree in writing.

13.9 Any reference to these Terms or the Referral Letter includes those Terms or Referral Letter as amended, updated or re-issued from time to time.

13.10 These Terms, the Referral Letter and any matter arising from or in connection with them shall be governed by and construed in accordance with the law of England and Wales. Each Party irrevocably agrees to submit to the exclusive jurisdiction of the Courts of England and Wales regarding any claim or matter arising from or in connection with these Terms or the Referral Letter.


In these Terms, the following words and phrases have the following meanings:

"Business Day" means any day other than a Saturday or Sunday or public holiday in England and Wales;

"Data Controller" has the meaning set out in the Data Protection Act 2018;

"Data Protection Legislation" means any law or regulation relating to the processing or use of personal data in any relevant jurisdiction, including the Data Protection Act 2018, UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, each as amended or re-enacted from time to time;

"Group" means the Company, its parent undertaking, its subsidiary undertakings and the subsidiary undertakings of its parent undertaking from time to time, as those terms are defined in the Companies Act 2006.

"Intellectual Property Rights" means rights of ownership in respect of any Marks or other intellectual property rights;

"Law(s)" means any applicable law or statute or any legally binding regulation or a requirement of any Regulatory Body;

"Marks’’ means any logo, branding, service marks, design rights, copyright, domain or business names, tradenames or trademarks from time to time;

"Party" means the Company or the Partner and ‘’Parties’’ means both of them;

"Partner Questionnaire" means a questionnaire supplied by the Company and completed by the Partner from time to time in connection with these Terms;
Personal Data" has the meaning given to it in the Data Protection Act 2018.

"Profit"[means the profit less appropriate expenses generated by the Company from business directly resulting from foreign exchange transactions entered into by it with Qualifying Leads as calculated by the Company in GBP .

"Qualifying Criteria" means the criteria set by the Company for the acceptance of Referrals, including the requirements that a Referral is aged at least 18 at the date of referral, has not previously been a client of the Company or been referred to the Company and who has consented to having their name and contact details shared with the Company by the Partner in accordance with clause 5, as such criteria may be amended by the Company from time to time;

"Qualifying Lead" means a Referral who meets the Qualifying Criteria and with whom the Company makes contact in person or by email or letter, as identified in a statement delivered under clause 3.3;

"Referral" means any person (including an individual, partnership or company) referred by the Partner to the Company under these Terms on or after the date of the Referral Letter and prior to termination of these Terms;

"Referral Fee" means the fee or commission set out in the Referral Letter;

"Referral Letter" means the letter setting out Referral Fees addressed by the Company to the Partner in connection with these Terms;

"Regulatory Body" means government agencies and other entities entitled to regulate or investigate the matters dealt with in these Terms, including the Financial Conduct Authority and the Information Commissioner’s Office;

"Relevant Personal Data" means Personal Data relating to a Referral;

"Term" means the duration of these Terms;

"Turnover" means the total amount received by the Company from foreign exchange transactions entered into by it with Qualifying Leads calculated by the Company in GBP; and

"UK GDPR" means Regulation (EU)2016/679 of the European Parliament and Council of 27 April 2016 (General Data Protection Regulation) as it forms part of the law of England and Wales.