Global Privacy Policy

A-Express Remit Pte Ltd Direct Services Agreement

Last updated: June 19, 2024

Welcome to A-Express Remit Pte Ltd !

This A-Express Remit Pte Ltd Direct Services Agreement, any applicable Schedule(s) and any Fee Schedule(s) (together, this “Agreement”) sets out the terms and conditions for the Client to receive the Services (defined below) that may be offered by A-Express Remit Pte Ltd .

In this Agreement, the “Client” is the entity that is requesting access to the Services offered by A-Express Remit Pte Ltd . If a person makes that request on behalf of the Client, that person asserts that they are authorized and empowered to make the request on behalf of the Client. “A-Express Remit Pte Ltd ” is the A-Express Remit Pte Ltd entity described in the applicable Fee Schedule (defined below), and the Client and A-Express Remit Pte Ltd are each a “Party,” and together, the “Parties”.

The Client will access and use Services offered by A-Express Remit Pte Ltd strictly in accordance with this Agreement, any Fee Schedule and the Documentation (defined below).

This Agreement consists of the following components:

• a. The General Terms;
• b. The Definitions set forth in Appendix A;
• c. The International Jurisdiction Additional Terms and Conditions set out in Appendix B;
• d. The Fee Schedule separately entered into between the Client and A-Express Remit Pte Ltd (“Fee Schedule”);
• e. The Pay Out Service Terms and Conditions;
• f. The The Pay In Service Terms and Conditions;
• g. The The Data Protection Agreement; and
• h. Any other agreements or documents expressly referenced in this Agreement.

GENERAL TERMS

1. General.

a. Definitions. Capitalized terms in this Agreement not defined inline are defined in Appendix C.

b. Interpretation. In the interpretation of this Agreement, the following provisions apply unless the context requires otherwise:

• I. headings are inserted for convenience only and do not affect the interpretation of this Agreement.
• II. a reference in this Agreement to any law, legislation or legislative provision includes any statutory modification, amendment or re-enactment, and any subordinate legislation or regulations issued under that legislation or legislative provision.
• III. a reference to a section, part, schedule or attachment is a reference to a section, part, schedule or attachment of or to this Agreement.
• IV. a word which denotes the singular denotes the plural, a word which denotes the plural denotes the singular, and a reference to any gender denotes the other genders.
  
  unless the context indicates otherwise, a reference in this Agreement to “person” is deemed to include a natural person, corporation, company, firm, partnership, limited partnership, limited liability company or limited liability
• V. partnership or other similar organization.
• VI. references to the word ‘include' or ‘including' are to be construed without limitation.
• VII. in the event of any inconsistency between these terms and conditions and any Schedule or Appendix, the provisions of such Schedule or Appendix will prevail to the extent of such inconsistency.

c. Precedence of TermsIf any terms in any components of this Agreement conflict, then unless terms of lower precedence expressly state to the contrary, the order of precedence is: (1) International Jurisdiction Additional Terms and Conditions (Appendix B); (2) these General Terms; (3) all other components; and (4) any other agreements or documents expressly referenced in this Agreement.

2. Term of Agreement.

a. Initial Term. Unless otherwise terminated under Section 16, this Agreement comes into force on the Effective Date and shall continue for the Initial Term starting on the Effective Date.

Sb. ubsequent Term. Upon expiration of the Initial Term, this Agreement shall automatically continue for successive one (1) year terms (each a “Subsequent Term”), until either Party exercises its termination right under this Agreement.

3. Provision of the Services.

a. Services General Terms. A-Express Remit Pte Ltd agrees to make available, and the Client agrees to accept, the Services in accordance with the terms of this Agreement.

b. Licensed Jurisdiction. The Services are offered and made available by A-Express Remit Pte Ltd from its jurisdiction of incorporation (“Licensed Jurisdiction”). A-Express Remit Pte Ltd does not intend to solicit, target or market the Services to any third party (including the Client) outside of its Licensed Jurisdiction.

c. Other Costs. Other than the A-Express Remit Pte Ltd Platform, the Client shall be solely responsible, at its own cost, for the provision of all equipment, infrastructure, software, systems and facilities which are necessary to enable the Client to use the Services.

4. Integration.

a. Direct Integration. The Client will comply with all Documentation, instructions, guidelines and requirements relating to its use of the Services and its integration to the A-Express Remit Pte Ltd Platform. The Client will ensure that its integration to and use of the A-Express Remit Pte Ltd Platform does not create material technical problems, damage, interruption, or degradation of the A-Express Remit Pte Ltd Platform. Upon the occurrence, or A-Express Remit Pte Ltd ’s reasonable belief of the occurrence, of such an event, A-Express Remit Pte Ltd may immediately suspend the Client’s use of the A-Express Remit Pte Ltd Platform to the extent necessary to mitigate the consequences of the event, and the Client will take all necessary steps to remediate the event, including steps reasonably requested by A-Express Remit Pte Ltd .

b. Approved Third Party Integration. The Client shall not integrate any API into the Services, A-Express Remit Pte Ltd Platform or A-Express Remit Pte Ltd, unless Client has received the prior written approval by A-Express Remit Pte Ltd for (i) the API to be an Approved Third Party API and (ii) the party to be an Approved Third Party. A-Express Remit Pte Ltd may revoke its approval of any Approved Third Party or Approved Third Party API at any time, in A-Express Remit Pte Ltd ’s sole discretion. Unless otherwise agreed between the Parties in writing, this Agreement and the Services shall automatically terminate upon such revocation of approval by A-Express Remit Pte Ltd .

• I. The Client will be responsible for its own development work and bear its own costs in relation to the integration of the Approved Third Party API.
• II. The Client will comply, and will ensure that the Approved Third Party and the Approved Third Party API comply, with all Documentation, instructions, guidelines and requirements for use of the Services via the Approved Third Party API.
• III. The Client acknowledges that A-Express Remit Pte Ltd has no responsibility or liability for the Client’s access to and use of the Approved Third Party API or any system or platform provided by an Approved Third Party. A-Express Remit Pte Ltd makes no representations or warranties as to the adequacy, commercial value, completeness or reliability of any Approved Third Party API, or any system or platforms provided by the Approved Third Party.
• IV. The Client will ensure that its use of the Approved Third Party API and the A-Express Remit Pte Ltd Platform does not create material technical problems, damage, interruption or degradation of the A-Express Remit Pte Ltd Platform. Upon the occurrence, or A-Express Remit Pte Ltd ’s reasonable belief of the occurrence, of such an event, A-Express Remit Pte Ltd may immediately suspend the Client’s use of the A-Express Remit Pte Ltd Platform to the extent necessary to mitigate the consequences of the event and the Client will take all necessary steps to remediate the event and as otherwise reasonably requested by A-Express Remit Pte Ltd .
• V. The Client consents and authorizes the Approved Third Party to provide to and receive from A-Express Remit Pte Ltd all information, communications, and Instructions in connection with the Services. The Client further consents and authorizes A-Express Remit Pte Ltd to accept, rely and act upon any information, communications and Instructions transmitted by the Approved Third Party to A-Express Remit Pte Ltd . Where A-Express Remit Pte Ltd receives any information, communication or Instruction from the Approved Third Party, A-Express Remit Pte Ltd shall be entitled to treat such information, communication or Instruction as having been received from the Client. The Client shall be bound as though the Client itself had given or received the information, communication or Instruction. A-Express Remit Pte Ltd is under no obligation to check the authenticity or accuracy of any information, communication or Instruction received from the Approved Third Party and will not be liable for any Losses incurred or suffered by the Client, or any person, for complying with such information, communication or Instruction.

5. A-Express Remit Pte Ltd Platform.

a. Client Access Codes. A-Express Remit Pte Ltd will provide the Client with a unique identification number and/or password to enable the Client to access and use the A-Express Remit Pte Ltd Platform (“Access Codes”). The security and confidentiality of the Access Codes will at all times remain the sole responsibility of the Client. The Client will ensure that none of the Access Codes is disclosed to any person, except on a need to know basis to Client Authorized Representatives. The Client will ensure that each Client Authorized Representative is aware of the requirement to keep the Access Codes secure and confidential. Breach of this Section constitutes a material breach incapable of being remedied and entitling A-Express Remit Pte Ltd to terminate this Agreement immediately pursuant to Section 16.

b. Authorized Representatives. A-Express Remit Pte Ltd is entitled to rely upon the Instructions provided by a Client Authorized Representative until such time as the Client notifies A-Express Remit Pte Ltd in writing that the Client Authorized Representative is no longer authorized, and A-Express Remit Pte Ltd has a reasonable opportunity to act upon the notification. A-Express Remit Pte Ltd may at its sole discretion and without liability decline to accept or cancel the authority of any Representative nominated by the Client as a Client Authorized Representative.

c. Instruction Information. Prior to submitting an Instruction to A-Express Remit Pte Ltd , the Client must ensure that all information contained in the Instruction is complete and accurate. If the Client subsequently learns of any error in the Instruction, the Client must immediately notify A-Express Remit Pte Ltd in writing. Where A-Express Remit Pte Ltd receives an Instruction from a person using an Access Code, A-Express Remit Pte Ltd may assume that the Instruction has been given by a Client Authorized Representative. A-Express Remit Pte Ltd is under no obligation to check the authenticity or accuracy of any Instruction or data received, or assumed to be received, from a Client Authorized Representative, and will not be liable for any Losses incurred or suffered by the Client or any other person as a result of A-Express Remit Pte Ltd acting on an Instruction received, or assumed to be received, from a Client Authorized Representative.

d. Processing Delay or Failure. If the Client fails to provide a timely, accurate and complete Instruction, A-Express Remit Pte Ltd may be unable to process, or may have to delay the processing of, such Instruction. A-Express Remit Pte Ltd will not be liable for any Losses incurred or suffered by the Client or any person as a result of a delay or failure in processing an Instruction.

e. Refusal to Act. A-Express Remit Pte Ltd may refuse to act upon any Instruction received from the Client that A-Express Remit Pte Ltd believes: (i) may violate this Agreement or other agreements the Client or its Affiliates may have with A-Express Remit Pte Ltd ; (ii) is unauthorized, fraudulent or illegal; or (iii) expose the Client, A-Express Remit Pte Ltd or others to risks unacceptable to A-Express Remit Pte Ltd .

f. Unauthorized Use. The Client will notify A-Express Remit Pte Ltd immediately in the event of any suspected or actual unauthorized use of the Access Codes or unauthorized access to the A-Express Remit Pte Ltd Platform. Notwithstanding such notification, the Client is solely responsible for all acts or omissions of any person that accesses the A-Express Remit Pte Ltd Platform through the Access Codes and agrees to be bound by the terms of all transactions or Instructions submitted through the A-Express Remit Pte Ltd Platform using the Access Codes.

g. Records. The Client is responsible for maintaining its own records relating to the Services and for reconciling such records against any entries made available on the A-Express Remit Pte Ltd Platform. The Client must notify A-Express Remit Pte Ltd promptly, and in any event, no later than sixty (60) days (or any longer minimum period prescribed by Applicable Laws) after any unauthorized, incorrect or disputed transaction or entry is entered on the A-Express Remit Pte Ltd Platform. Following the expiry of this period, any such entry in the A-Express Remit Pte Ltd Platform will be deemed agreed.

6. A-Express Remit Pte Ltd Account.

a. Generally. The Client shall be granted one or more A-Express Remit Pte Ltd Accounts for the purposes of the Services. Each A-Express Remit Pte Ltd Account is denominated in a Supported Currency and facilitates the Client’s use of the Services including viewing the Available Balance in the relevant Supported Currency. Where foreign currency conversion is required in respect of any Available Balance, A-Express Remit Pte Ltd shall apply the prevailing exchange rate, which at the Effective Date, is based on the rates published on the Reuters platform on a Business Day plus a percentage (recognized as a markup), as set out in the Fee Schedule for such conversion.

b. Client Responsibility. The Client shall be solely responsible for keeping, and shall take all steps to keep, any A-Express Remit Pte Ltd Account opened and maintained with A-Express Remit Pte Ltd safe at all times. The Client undertakes to notify A-Express Remit Pte Ltd immediately upon becoming aware of or reasonably suspecting that any A-Express Remit Pte Ltd Account has been misappropriated, used without authorization or otherwise compromised. Any delay in or failure to notify A-Express Remit Pte Ltd shall result in the Client being liable for any Losses that arize in connection therewith.

c. Access and Use. The A-Express Remit Pte Ltd Account shall be operated and accessed solely by the Client or a Client Authorized Representative. The Client shall be fully liable for any acts and omissions of any Client Authorizsed Representative or persons acting or purported to act on its behalf. If the Client allows any other third party (other than a Client Authorized Representative) to have access to or to operate any A-Express Remit Pte Ltd Account for whatever reason, the Client shall be deemed to have authorized such use and shall be liable for all Losses and fees incurred by such use.

d. Funding. The Client or, if approved in writing by A-Express Remit Pte Ltd , an authorized third party, may fund the Available Balance in any Supported Currency into a Settlement Account. In order to facilitate the provision of the Services, except to the extent prohibited by Applicable Laws, the Client instructs and authorizes A-Express Remit Pte Ltd to hold funds on behalf of the Client in one or more Settlement Accounts maintained by A-Express Remit Pte Ltd and its Affiliates that are located outside of the Licensed Jurisdiction for the purpose of acting on the Client's Instructions provided to A-Express Remit Pte Ltd pursuant to the Pay Out Service.

e. Acknowledgement of Risks. The Client acknowledges and agrees that:

• I. maintaining an Available Balance in multiple currencies carries foreign exchange risks, for example it is possible that the exchange rate improves over time and the Client will not receive the benefit of such fluctuations. The Client agrees to assume the aforementioned foreign exchange risks and waive all claims against A-Express Remit Pte Ltd with respect to such risks; and
• II. it does not own or operate any Settlement Account or have any other interest in any Settlement Account and any interest earned on monies held in any Settlement Account is not payable to the Client.

f. Shortfall. A-Express Remit Pte Ltd shall not be liable to make up for any shortfall in any Available Balance received by A-Express Remit Pte Ltd (including due to bank or payment network charges) unless such shortfall is due to the gross negligence or wilful default of A-Express Remit Pte Ltd .

g. Reserves. The Client agrees that A-Express Remit Pte Ltd may, from time to time, establish and withhold from the Available Balance such reserve amounts (“Reserves”), to cover any obligations of the Client (including, but not limited to, outstanding Fees, Pay In Reversals, Pay In Refunds, or Assessments) under this Agreement or any other agreement that Client or its Affiliates may have with A-Express Remit Pte Ltd or its Affiliates. A-Express Remit Pte Ltd may additionally fund the Reserves through: (i) the funds provided by the Client at A-Express Remit Pte Ltd ’s request; (ii) any amount owed by A-Express Remit Pte Ltd or an Affiliate of A-Express Remit Pte Ltd to the Client or an Affiliate of the Client; and/or (iii) debiting the bank account of the Client. A-Express Remit Pte Ltd may, at its option, vary the rate or terms of the Reserves. A-Express Remit Pte Ltd ’s rights with respect to the Reserves shall survive the termination of this Agreement. A-Express Remit Pte Ltd will notify the Client in the event that it establishes the Reserves.

h. Termination. Upon the termination or expiry of this Agreement, the Client may request for the return of any Net Available Balance by way of a written notice to A-Express Remit Pte Ltd . Within thirty (30) days of receipt of such written notice and subject to satisfactory due diligence checks and Applicable Laws, A-Express Remit Pte Ltd will initiate a refund of the Net Available Balance to the Client (“Available Balance Refund”). Where foreign currency conversion is required, A-Express Remit Pte Ltd shall apply the prevailing exchange rate at the time such Available Balance Refund is made. In the event A-Express Remit Pte Ltd is not able to return the funds to the Client, A-Express Remit Pte Ltd shall, to the extent permissible by Applicable Laws and to the extent practicable for A-Express Remit Pte Ltd , notify the Client of the reasons.

7. Direct Debit Services.

If direct debit services have been made available to the Client by A-Express Remit Pte Ltd , the Client agrees to the Direct Debit Terms.

8. Unauthorized Transactions.

a. Notification. Unless stated otherwise in this Agreement, the Client must notify A-Express Remit Pte Ltd no later than 60 days from the date of transaction or any longer minimum period prescribed by applicable laws (“Notification Deadline”) of any transaction recorded to the Client’s A-Express Remit Pte Ltd Account that has not been authorized by the Client or has been otherwise incorrectly executed by A-Express Remit Pte Ltd (each an “Unauthorized Transaction”). If notification is not provided by the Notification Deadline, such transaction will be deemed as agreed.

b. Suspension of the Services;. The Client must suspend its use of the Services and notify A-Express Remit Pte Ltd immediately if (i) the Client believes the security of any payment instrument (including any A-Express Remit Pte Ltd Account or associated payment card) issued by A-Express Remit Pte Ltd in connection with any Services has been compromised (for example, if an unauthorized Representative or a third party has gained access to any security credentials); and/or (ii) the Client has identified an Unauthorized Transaction. The Client may be asked to provide details of the reported issues, and any supporting documentation, such as a copy of a police report, to confirm the theft of the A-Express Remit Pte Ltd Account.

c. Investigation. A-Express Remit Pte Ltd will have the right to investigate any transaction reported by the Client as an Unauthorized Transaction. A-Express Remit Pte Ltd may ask the Client to provide it with supporting information and documentation to help it with its investigation and the Client agrees to cooperate with A-Express Remit Pte Ltd and provide all information and documentation it reasonably requires for this purpose. the Client also agree to cooperate with any regulatory authorities involved in A-Express Remit Pte Ltd ’s investigation.

d. Liability for Unauthorized Transactions:

• I. A-Express Remit Pte Ltd will not be liable for any Unauthorized Transaction that has resulted from (A) the Client’s A-Express Remit Pte Ltd Account being misappropriated or the security of the Client’s A-Express Remit Pte Ltd Account otherwise being compromised, except the extent that such misappropriation or compromise is caused by a security breach of the A-Express Remit Pte Ltd Platform not caused by the Client’s acts or omissions, (B) the Client failure to use the Services in accordance with this Agreement or (C) the Client’s fraudulent acts or omissions;
• II. A-Express Remit Pte Ltd will not be liable for any Unauthorized Transaction that has been notified to A-Express Remit Pte Ltd after the applicable Notification Deadline;
• III. A-Express Remit Pte Ltd will not be liable for any Unauthorized Transaction, other than a transaction that was incorrectly executed by A-Express Remit Pte Ltd in accordance with a valid Instruction provided by the Client, that occurred prior to A-Express Remit Pte Ltd being notified by the Client that one or more Unauthorized Transactions have been recorded to its A-Express Remit Pte Ltd Account. Once the underlying issue (for example a compromise of the Client’s security credentials) of the Unauthorized Transactions have been resolved and A-Express Remit Pte Ltd has advised the Client that it can resume use of the Services, A-Express Remit Pte Ltd will not be liable for any future Unauthorized Transactions unless and until the Client has notified A-Express Remit Pte Ltd of the occurrence of additional Unauthorized Transactions in accordance with this Section 8;

e. Reversal of Refund If A-Express Remit Pte Ltd refunds the Client for a transaction that the Client reported as anas Unauthorized Transaction and A-Express Remit Pte Ltd subsequently determines that such transaction was not an Unauthorized Transaction or A-Express Remit Pte Ltd was not otherwise liable to refund the Client for such Unauthorized Transaction in accordance with section 8.d. above, A-Express Remit Pte Ltd will deduct the amount refunded to the Client from (i) the Client’s A-Express Remit Pte Ltd Account, or (ii) funds provided to A-Express Remit Pte Ltd as financial assurance for the Client’s obligations under this Agreement. If there are not sufficient funds in the Client’s A-Express Remit Pte Ltd Account or otherwise available to A-Express Remit Pte Ltd to reverse the applicable refund, the Client shall immediately transfer such amount to A-Express Remit Pte Ltd upon its request.

9. Representations and Warranties.

a. Mutual Representations and Warranties. Each Party represents and warrants to the other Party that:

• I. it is duly organized, registered and validly existing under the Applicable Laws of its jurisdiction of organization;
• II. it has all the requisite corporate power, approvals and authority to execute, deliver, receive and perform its obligations under this Agreement;
• III. it has obtained and shall maintain all governmental, regulatory and other third party licenses, authorizations, approvals, consents or permits required to perform its obligations under this Agreement and to use or provide the Services;
• IV. it is not identified on any of the OFAC Lists, and none of its directors, officers, employees, or holders of equity or debt securities, are identified on, or are 50% or more owned, directly or indirectly, by any person identified on any of the OFAC Lists;
• V. neither Party has received or been offered any illegal or improper bribe, kickback, payment, gift or thing of value from an employee or agent of the other Party in connection with this Agreement. Reasonable gifts and entertainment provided in the ordinary course of business that comply with Applicable Laws do not violate the above restriction; and
• VI. it will provide the other Party with reasonable assistance as the other Party may require, from time to time, in connection with this Agreement and the activities contemplated hereunder.

b. Client Representations and Warranties. The Client represents and warrants that it will:

• I. use the Services only for lawful purposes and in compliance with all Applicable Laws;
• II. use the A-Express Remit Pte Ltd Platform in accordance with the terms of this Agreement and the Documentation and in compliance with all Applicable Laws;
• III. and previously has, accurately identified itself, and it has not provided any inaccurate information about itself or its End Customers to or through the Services, and that it has the right to use and disclose such information to A-Express Remit Pte Ltd ;
• IV. comply with all applicable Sanctions and export control laws and will not provide the Services, End Customer Services or any other services provided to an End Customer to any parties that, at the time such Services or End Customer Services are provided, are (A) located or resident in any country or territory that is subject to a U.S. trade embargo or other applicable Sanctions prohibiting such services, including but not limited to, the Crimea, Donetsk and Luhansk regions of Ukraine, Cuba, Iran, North Korea, and Syria; and (B) included on any U.S. lists of prohibited parties including, the OFAC Lists or any other applicable Sanctions list prohibiting such services;
• V. not (directly or indirectly) sell, export, reexport, transfer, divert or otherwise dispose of any Services received from A-Express Remit Pte Ltd in contradiction with the laws and regulations described in subpart (iv) above;
• VI. provide A-Express Remit Pte Ltd with all information in relation to this Agreement, the Services, and/or where applicable, any End Customer promptly and in any event not more than seven (7) days following the receipt of a request from A-Express Remit Pte Ltd or such other longer period as agreed between A-Express Remit Pte Ltd and the Client, and that all such information provided to A-Express Remit Pte Ltd by the Client, or any third party on behalf of the Client, is accurate in all material respects, and that such information does not, and the Client will not, omit or withhold any information which would make such information inaccurate in any material respect;
• VII. notify A-Express Remit Pte Ltd in writing immediately (A) when there are changes to any information (including but not limited to information pertaining to the Client, (where applicable) End Customers or in connection with any Services) which the Client has previously provided to A-Express Remit Pte Ltd ; and (B) if the Client becomes aware of any event, suspicious activity, investigation or occurrence relating to Anti-Money Laundering/Combating the Financing of Terrorism Laws, or Sanctions thatpotentially involves or implicates A-Express Remit Pte Ltd , any of A-Express Remit Pte Ltd ’s officers, directors, employees or agents, or any Services (and, where applicable, provide details of transactions processed in connection with such Services in the preceding twelve (12) month period);
• VIII. ensure that any payments or transactions made pursuant to any Services are not in any way associated with the activities, entities or industries listed in the prohibited list provided by A-Express Remit Pte Ltd to the Client from time to time.
• IX. comply with all Applicable Laws and A-Express Remit Pte Ltd ’s anti-money laundering policies as provided to Client from time to time;
• X. to the extent permitted by Applicable Laws, immediately notify A-Express Remit Pte Ltd if it detects any suspicious, fraudulent or other form of criminal activity relating to any payments or transactions made pursuant to any Services and cooperate with A-Express Remit Pte Ltd to investigate and/or prevent such further activity;
• XI. establish, apply and maintain robust security systems and procedures to effectively monitor access to and use of the Access Codes and the A-Express Remit Pte Ltd Platform;
• XII. ensure that any data that has been accessed, printed or otherwise downloaded from the A-Express Remit Pte Ltd Platform is retained securely at all times; and
• XIII. provide to A-Express Remit Pte Ltd such information or documents in such format and within such time limit as A-Express Remit Pte Ltd may reasonably require in connection with this Agreement or the Services.

c. A-Express Remit Pte Ltd Representations and Warranties. A-Express Remit Pte Ltd represents and warrants that it will:

• I. comply with all Applicable Laws in fulfilling its obligations under this Agreement and the provision of the Services;
• II. implement, maintain and comply with policies and procedures that are designed to detect and prevent money laundering, terrorist financing, fraud and/or other crimes or Sanctions and shall review and update such policies as necessary to reflect any changes in Applicable Laws; and
• III. have in place reasonable business continuity and disaster recovery policies and at all times, maintain, test and comply with such policies.

d. DISCLAIMER FOR ALL OTHER WARRANTIES FOR SERVICES. The Services are provided “AS IS”. Except as otherwise expressly provided under this Agreement, A-Express Remit Pte Ltd makes no representations or warranties of any kind, whether express, implied, statutory or otherwise regarding the Services, including any warranty that the Services or A-Express Remit Pte Ltd Platform will be uninterrupted, error free or free of harmful components, or that any data or information, including Client or End Customer confidential information or data, will be secure or not otherwise lost or damaged. Client acknowledges that A-Express Remit Pte Ltd does not control or monitor the transfer of data over the internet, and that internet accessibility carries with it the risk that Client’s (or End Customer’s) privacy, confidential information and property may be lost or compromised. Except to the extent prohibited by Applicable Laws, A-Express Remit Pte Ltd disclaims all warranties, including any implied warranties of merchantability, title, fitness for a particular purpose, non-infringement and any warranties arising from a course of dealing, usage or trade practice.

10. End Customer Authorization.

The Client authorizes A-Express Remit Pte Ltd to, and where applicable, shall procure the necessary authorization from any End Customer for A-Express Remit Pte Ltd to, directly or through third parties, make any inquiries A-Express Remit Pte Ltd considers necessary for the purpose of this Agreement and/or any Services, including to validate the Client’s or, where applicable, any End Customer’s identity. This may include making periodic searches of, and providing information (including Confidential Information) about the Client, or where applicable, an End Customer to, (i) a Network, (ii) a credit reference, market research, customer feedback, or a fraud prevention agency, (iii) an Affiliate of A-Express Remit Pte Ltd , (iv) its Representatives, or (v) any other third parties involved in the provision of services under any Services for any purpose in connection with this Agreement.

11. Fees and Other Amounts Payable to A-Express Remit Pte Ltd .

a. Payment of Fees. The Client will pay the Fees as set out in the Fee Schedule and any other amounts due and payable to A-Express Remit Pte Ltd under this Agreement to A-Express Remit Pte Ltd in full within seven (7) days (“Payment Date”) from the date of invoice. Breach of any paragraph of this Section 9 constitutes a material breach entitling A-Express Remit Pte Ltd to terminate this Agreement in accordance with Section 16. If any amount due to A-Express Remit Pte Ltd pursuant to this Agreement is not paid by the Client in full on or before the Payment Date for whatever reason, the Client shall pay A-Express Remit Pte Ltd a finance charge equal to two per cent (2%) per month (or the highest rate permitted by Applicable Laws, whichever is lower) on any unpaid amount from the date such payment was due until the date paid. Client will be responsible for all reasonable expenses (including attorneys’ fees) incurred by A-Express Remit Pte Ltd in collecting past due amounts.

b. Setoff. A-Express Remit Pte Ltd may from time to time, without notice, set-off or deduct by whatever means, the whole or any part of the liabilities of the Client or its Affiliates under this Agreement or any other agreement between A-Express Remit Pte Ltd and/or its Affiliates and the Client and/or its Affiliates (whether such liabilities are present, future, actual or contingent or potential, liquidated or unliquidated and irrespective of the currency of their denomination) against any amounts (i) held by A-Express Remit Pte Ltd on behalf of the Client or by an Affiliate of A-Express Remit Pte Ltd on behalf of another Affiliate of the Client, or (ii) owed by A-Express Remit Pte Ltd to the Client under this Agreement or by any Affiliate of A-Express Remit Pte Ltd to any Affiliate of the Client under the relevant agreement.

c. Taxes. All Fees, and any other amounts due under this Agreement shall be paid by the Client in full without any deductions (including deductions in respect of applicable Taxes, charges and/or duties). Any Tax payable in respect of any payments made under this Agreement (other than Tax payable on A-Express Remit Pte Ltd ’s net income, profits or gains) shall be borne by the Client.

d. Changes In Third Party Fees. In the event that any third party fees that apply to the Services are imposed or changed after the date of this Agreement, A-Express Remit Pte Ltd may charge the Client for such third party fees on a pass-through basis by giving written notice to the Client of such fees.

12. Right of Audit.

a. Audits. Upon receipt of prior reasonable notice, the Client will permit, and will cause each Subcontractor to permit, as applicable, A-Express Remit Pte Ltd and its authorized Representative or any Regulatory Body designated by A-Express Remit Pte Ltd to:

• I. access during business hours such premise systems and personnel on which the Client’s or, where applicable, Subcontractor’s business takes place or where the Client’s or, where applicable, Subcontractor’s records are located;
• II. take and retain copies of all such records, procedures, personnel and information to ascertain if the Client or, where applicable, Subcontractor are performing its obligations in accordance with this Agreement, A-Express Remit Pte Ltd Policies and Applicable Laws; and
• III. perform an assessment of the Client’s or, where applicable, Subcontractors’ policies, standards, systems and procedures to ascertain compliance with the terms of this Agreement.

b. Audit Costs. Where an audit is undertaken pursuant to a request by any Regulatory Body related to the Client or pursuant to an event giving rise to a breach of this Agreement by the Client (including security breach), the Client shall pay any cost and expense incurred by A-Express Remit Pte Ltd or its Representatives with respect to such audit.

13. Additional Security for Client Obligations.

In connection with the provision of the Services, A-Express Remit Pte Ltd may, from time to time, require the Client to provide A-Express Remit Pte Ltd with additional collateral, cash reserves, guarantees, indemnity, and/or other security (collectively, “Security”), in such form and amounts that are reasonably required to secure the performance of the Client’s existing or potential obligations under this Agreement. Client must provide A-Express Remit Pte Ltd with the Security no later than thirty (30) days after receipt of a written request for such Security.

14. Confidential Information.

a. Confidentiality Obligations. Each Party will, and will cause its Representatives to, keep confidential and not use or disclose the other Party’s Confidential Information except as permitted by this Agreement. Each Party agrees to limit access to the other Party’s Confidential Information to such of its personnel, agents, subcontractors, suppliers and/or consultants, if any, who have a need to access such information in accordance with the terms of this Agreement. Both Parties agree that all Confidential Information is proprietary to the disclosing Party and shall remain the sole property of the disclosing Party. The receiving Party will be liable to the disclosing Party for any unauthorized disclosure by its Representatives, or by the Representatives of its Affiliates.

b. Exceptions. This Section is not breached by uses or disclosures of Confidential Information that are (i) authorized in writing by the disclosing Party prior to the receiving Party’s use or disclosure; or (ii) required by Applicable Laws, or by a Regulatory Body (“Compelled Disclosure”) provided that, such Party will use reasonable efforts to provide the other Party with prior notice (to the extent legally permitted) in order to afford the other Party an opportunity to seek a protective order or otherwise challenge the Compelled Disclosure. The non-disclosing Party is solely responsible for any expenses incurred in seeking to prevent a Compelled Disclosure. After provision of such legally permissible prior notice, the disclosing Party will not be liable if such Party complies with the disclosure after giving the other Party a reasonable amount of time to respond.

c. Expiration or Termination of Services Agreement. Unless expressly permitted under this Agreement, on expiry or termination of this Agreement, at the written request of the disclosing Party, all Confidential Information must either be returned to the disclosing Party or destroyed by the receiving Party and its Representatives no later than fifteen (15) days after the written request; provided, however, that (i) the receiving Party and its Representatives, subject to the obligations of this Agreement, shall not be required to destroy electronic copies of any computer records or files containing the Confidential Information which have been created pursuant to automatic archiving or back-up procedures on secured central storage servers and which cannot reasonably be deleted, and (ii) the receiving Party may retain one (1) electronic copy of the Confidential Information (the “Retained Copy”), but the Retained Copy shall be accessed and used by the receiving Party solely for the purposes of (A) ensuring compliance with Applicable Laws and record retention policies, and (B) defending or maintaining any litigation with respect to the terms of this Agreement. At the request of the disclosing Party, the receiving Party will furnish a certificate, signed by the receiving Party, certifying that any Confidential Information not returned to the disclosing Party has been returned or destroyed by the Receiving Party in accordance with this Section 14.

d. Survival. The obligations set forth under this Section 14 will survive termination of this Agreement.

15. Intellectual Property Rights.

a. Ownership and Retention. A-Express Remit Pte Ltd reserves all right, title, and interest in and to any materials produced by A-Express Remit Pte Ltd including, without limitation, all of A-Express Remit Pte Ltd ’s Intellectual Property Rights. A-Express Remit Pte Ltd shall own and retain all right, title and interest in the Services, the A-Express Remit Pte Ltd, and all other Intellectual Property Rights of A-Express Remit Pte Ltd , and shall own and retain all improvements thereon. Other than the license granted during the term of this Agreement, as set forth in Section 13(b), Client shall not acquire any rights, title, or interest, express or implied, to the Services, A-Express Remit Pte Ltd, or other Intellectual Property Rights of A-Express Remit Pte Ltd , nor to any derivative works, modifications, enhancements, improvements, translations or other alterations thereto (“A-Express Remit Pte Ltd Derivative Works”). To the extent any assignment is necessary to evidence the intent of this Section, Client agrees to assign to A-Express Remit Pte Ltd all of its right, title, and interest in and to such A-Express Remit Pte Ltd Derivative Works, and any part thereof, and in and to all copyrights, patents and other proprietary rights they may have in such A-Express Remit Pte Ltd Derivative Works.

b. Access and Use. A-Express Remit Pte Ltd grants the Client during the term of this Agreement a limited, non-exclusive, worldwide, royalty-free, non-transferable, non-sublicensable license to electronically access and use the A-Express Remit Pte Ltd Platform and the Services solely in compliance with this Agreement. Except as expressly permitted by Applicable Laws, the Client must not: (i) work around any of the technical limitations of the A-Express Remit Pte Ltd Platform or the Services or enable functionality that is disabled or prohibited; (ii) reverse engineer or attempt to reverse engineer the A-Express Remit Pte Ltd Platform or the Services; or (iii) perform or attempt to perform any actions that interfere with the normal operation of the A-Express Remit Pte Ltd Platform or the Services or affect use of the A-Express Remit Pte Ltd Platform or the Services by A-Express Remit Pte Ltd ’s other customers.

c. Marketing Materials. Client consents to A-Express Remit Pte Ltd ’s use of Client’s name and logos in marketing materials, and A-Express Remit Pte Ltd may disclose the relationship with the Client (i) in customer reference lists and sales presentations, and (ii) via public disclosures (including but not limited to social media sites or on A-Express Remit Pte Ltd ’s website). A-Express Remit Pte Ltd and the Client may issue a mutually agreed press release on execution of this Agreement.

16. Indemnification.

a. Client Indemnification. The Client will, to the fullest extent permitted by Applicable Laws, indemnify, defend and hold harmless A-Express Remit Pte Ltd , its Affiliates, subcontractors and its and their Representatives (each a “A-Express Remit Pte Ltd Party”) from and against any and all Claims brought against a A-Express Remit Pte Ltd Party by a third party, and for any and all Losses incurred in connection with such third party Claims, based upon or arising out of:

• I. any breach of this Agreement by Client;
• II. the Client’s (or any End Customer’s) access to and/or use of the Services, the A-Express Remit Pte Ltd Technology, the A-Express Remit Pte Ltd Platform and/or the Documentation, whether or not such access or use was authorized or whether it was due to any act or omission on its part, including any fees, penalties or fines imposed on A-Express Remit Pte Ltd or its Affiliate by any payment network or any government entity;
• III. the Client’s (or its End Customer’s) noncompliance with Applicable Laws, including with respect to the Client’s (or its End Customer’s) access to and/or use of the Services;
• IV. the Client’s (or its End Customer’s) gross negligence or intentional misconduct;
• V. use of Client’s Intellectual Property Rights or any information provided by the Client in connection with this Agreement or the Services;
• VI. any request, Instruction or information given by the Client or where applicable, by an Approved Third Party or through an Approved Third Party API; or
• VII. any transaction pursuant to the Services.

The above defence and indemnification obligations do not apply to the extent of a Claim arising from A-Express Remit Pte Ltd ’s gross negligence or intentional misconduct.

b. A-Express Remit Pte Ltd Indemnification. Subject to Section17(b), A-Express Remit Pte Ltd will, to the fullest extent permitted by Applicable Laws, indemnify, defend and hold harmless the Client, its Affiliates, and their Representatives (each a “Client Party”) from and against any and all Claims brought against a Client Party by a third party, and any and all Losses incurred in connection with such third party Claims, based upon or arising out of:

• I. any breach of this Agreement by A-Express Remit Pte Ltd ;
• II. A-Express Remit Pte Ltd ’s noncompliance with Applicable Laws;
• III. A-Express Remit Pte Ltd ’s gross negligence or intentional misconduct; or
• IV. claims that A-Express Remit Pte Ltd ’s Intellectual Property Rights infringe on the Intellectual Property Rights of any third party.

If A-Express Remit Pte Ltd receives information about an infringement or misappropriation Claim related to the Services, A-Express Remit Pte Ltd may in its discretion, and at no cost to Client, (A) modify the applicable Service so that it is no longer claimed to infringe or misappropriate the Intellectual Property Rights of a third party, (B) obtain a license for Client’s continued use of the applicable Service in accordance with this Agreement, or (C) terminate this Agreement, in whole or in part, with respect to the applicable Service upon thirty (30) days’ written notice to the Client. The indemnification obligations set forth in this Section 14(b) do not apply if (I) the allegation does not state with specificity that the Service is the basis of the Claim against the Client Party, (II) a Claim against a Client Party arises from the use or combination of the Service or any part thereof with software, hardware, data, or processes not provided by A-Express Remit Pte Ltd , if the Service or use thereof would not infringe without such combination, (III) the alleged infringement arises from third-party materials or data, (IV) the alleged infringement arises from a modification of the materials other than by or on behalf of A-Express Remit Pte Ltd , (V) the alleged infringement arises from a failure to timely implement modifications, upgrades, replacements, or enhancements made available to the Client by or on behalf of A-Express Remit Pte Ltd , or (VI) the Claim ultimately arises from Client’s breach of this Agreement or Client’s gross negligence or intentional misconduct.

17. Exclusion and Limitation of Liability.

a. DAMAGES WAIVER. In no event will A-Express Remit Pte Ltd or any A-Express Remit Pte Ltd Party have any liability arising out of or related to this Agreement or the Services for any lost profits, revenues, goodwill, or indirect, special, incidental, consequential, cover, business interruption or punitive damages, whether an action is in contract or tort and regardless of the theory of liability, even if the Client or any Client Party has been advised of the possibility of such damages or if the Client’s or any Client Party’s remedy otherwise fails of its essential purpose. The foregoing disclaimer will not apply to the extent prohibited by Applicable Laws.

b. LIABILITY CAP. In no event shall the aggregate liability of A-Express Remit Pte Ltd , or any A-Express Remit Pte Ltd Party, arising out of or related to this Agreement, exceed the total Fees paid by the Client to A-Express Remit Pte Ltd under this Agreement for the preceding twelve (12) months from the date giving rise to such Claim (or, if such event occurs within the first twelve (12) months after the Effective Date, the average monthly Fees paid by the Client to A-Express Remit Pte Ltd during the term of this Agreement multiplied by twelve (12)); provided, however, that this limitation of liability shall not apply to (i) the obligations of A-Express Remit Pte Ltd to repay the Client’s Net Available Balance under Section 3 of the Pay Out Service Terms and Conditions or (ii) any act of willful misconduct or fraud by A-Express Remit Pte Ltd . The foregoing limitation will apply whether an action is in contract or tort and regardless of the theory of liability.

c. Acknowledgment. The Parties acknowledge and agree that the exclusion and limitation of liability in this Section 17 is reasonable having regard to all relevant factors, including the nature and cost of the Services provided and the allocation of risk and liability between the Parties.

18. Termination and Consequence of Termination.

a. Termination Without Cause by Either Party.

• I. In addition to the other rights set forth in this Section 16, either Party may terminate this Agreement at any time by giving the other Party at least thirty (30) days’ written notice of termination.
• II. Notwithstanding the foregoing, the Client may not exercise its rights under Section 16(a)(i) unless, where applicable, the Client has paid A-Express Remit Pte Ltd an early termination fee as set out in the Fee Schedule (“Early Termination Fee”). The Parties agree that the Early Termination Fee constitutes a fair and reasonable determination of the amount of actual damages which would be suffered by A-Express Remit Pte Ltd in such event, and that the Early Termination Fee does not constitute a penalty, but is liquidated damages, compensatory in nature.

b. Termination for Cause by Client. Without prejudice to any other rights and remedies under this Agreement, the Client may at any time immediately terminate this Agreement, in whole or in part, by written notice to A-Express Remit Pte Ltd if:

• I. A-Express Remit Pte Ltd commits a material breach of this Agreement, which is not capable of remedy, or if capable of remedy, is not remedied to the Client’s reasonable satisfaction within thirty (30) days of service of a notice requiring such remedy; or
• II. A-Express Remit Pte Ltd becomes the subject of a petition in bankruptcy or any other proceeding relating to insolvency, receivership, liquidation or assignment for the benefit of creditors (“Insolvency Proceeding”); or
• III. There is a termination or withdrawal, in whole or in part, of any license, registration, permission or authorization required for A-Express Remit Pte Ltd to operate its business in connection with the Services.

c. Termination for Cause by A-Express Remit Pte Ltd . Without prejudice to any other rights or remedies under this Agreement, A-Express Remit Pte Ltd may at any time immediately suspend or terminate this Agreement or the Client’s access to the Services, in whole or in part, if:

• I. the Client commits a material breach of this Agreement, which is not capable of remedy, or if capable of remedy, is not remedied to A-Express Remit Pte Ltd ’s reasonable satisfaction within thirty (30) days of service of a notice requiring such remedy;
• II. the Client files, or has filed against it, an Insolvency Proceeding;
• III. the Client is not paying its debts as they become due and payable;
• IV. an Affiliate of A-Express Remit Pte Ltd becomes entitled to terminate any agreement it has with an Affiliate of the Client;
• V. (A) A-Express Remit Pte Ltd is required to terminate this Agreement pursuant to an order from any Regulatory Body or the Network or otherwise pursuant to Applicable Laws; (B) A-Express Remit Pte Ltd reasonably believes that any Service is being used for a purpose contrary to Applicable Laws or for an unauthorized or fraudulent use; or (C) the security of any Service, the A-Express Remit Pte Ltd Platform has been compromised due to the actions or omissions of the Client;
• VI. the results of any “know your customer” or other similar checks or screenings under Applicable Laws or regulations conducted on the Client are unsatisfactory to A-Express Remit Pte Ltd in its sole discretion or continuing any Service could cause reputational, regulatory, financial or operational harm to A-Express Remit Pte Ltd ;
• VII. there is a withdrawal or termination, in whole or in part, of any license, permission or authorization required to operate the Client’s business;
• VIII. the Client undergoes a change of Control, or a sale or other disposal of any substantial division or part of the Client’s business without the prior written consent of A-Express Remit Pte Ltd ; or
• IX. A-Express Remit Pte Ltd has provided Client with a written revocation of its approval of an Approved Third Party or Approved Third Party API.

d. Termination of Services by Financial Partner of A-Express Remit Pte Ltd . A-Express Remit Pte Ltd may, at any time immediately terminate this Agreement or the Client’s access to the Services, in whole or in part, if the Financial Partner that offers services to A-Express Remit Pte Ltd , in connection with the Services, has either (i) terminated or suspended the performance of its services to A-Express Remit Pte Ltd or (ii) has directed A-Express Remit Pte Ltd to no longer permit the Client to utilize the Financial Partner’s services.

e. Effect of Termination.

• I. General. Upon termination or expiration of this Agreement, Client will (i) immediately discontinue or disable the integration of any Approved Third Party API developed hereunder; (ii) remove any reference to A-Express Remit Pte Ltd from any websites, software applications, marketing or advertising materials; and (iii) return and/or destroy any A-Express Remit Pte Ltd property (including intellectual property) or A-Express Remit Pte Ltd Confidential Information in accordance with the terms of this Agreement.
• II. Survival. Upon termination of this Agreement, all rights and obligations of any Party will cease to have effect immediately, save that the Sections which expressly or by implication have effect after termination will continue to be enforceable notwithstanding such termination (including Sections 1, 6(h), 12, 14 to 27, and any applicable Section set forth in Appendix B) and termination will not affect accrued rights, obligations and liabilities of any Party under this Agreement as at the date of termination.
• III. Effect of Termination for Cause by A-Express Remit Pte Ltd . If this Agreement is terminated by A-Express Remit Pte Ltd in accordance with the terms of Section 16(c), Client will pay A-Express Remit Pte Ltd the Minimum Monthly Fees for the remainder of the applicable Initial Term or Subsequent Term. In no event will termination relieve Client of its obligation to pay any fees Fees payable to A-Express Remit Pte Ltd for the period prior to the effective date of termination.

19. Notice.

All notices, requests, demands, or other communications under this Agreement (“Notices”) must be in writing and sent by email to the Party’s email address on the Fee Schedule (or any new email address that has been provided by the Party, by written Notice), and will be deemed to have been given on the date on which it has been sent. In the event that the sender receives a machine-generated notification that the email was not received by the recipient, Notice may be given by personal delivery, certified mail, or reputable overnight or international delivery service to the Party’s address on the cover page of this Agreement (or any new address that has been provided by the Party by written Notice) and shall be deemed have been given (i) in the case of personal delivery, when received, (ii) if sent domestically, the next Business Day, or (iii) if sent internationally, five (5) Business Days after it is sent.

20. Force Majeure.

A-Express Remit Pte Ltd will not be liable for any delay or failure to perform under this Agreement due to circumstances beyond A-Express Remit Pte Ltd ’s reasonable control, including acts of God, acts of government, flood, fire, earthquakes, civil unrest, pandemics, epidemics, quarantines, acts of terror, strikes or other labor problems, regional shortage of adequate power or telecommunications or transportation, internet or other service disruptions involving hardware, software or power systems not within A-Express Remit Pte Ltd ’s possession or reasonable control, and denial of service attacks.

21. Amendment; Changes In Services and Applicable Laws.

a. Amendment. Except for changes to the Fee Schedule, which shall be agreed to in writing by the Parties, A-Express Remit Pte Ltd may modify all or any part of this Agreement at any time by posting a modified version of this Agreement (including any terms incorporated by reference into this Agreement) on the A-Express Remit Pte Ltd website or by notifying the Client. The modified Agreement is effective upon posting or, if A-Express Remit Pte Ltd notified the Client, as stated in the notice. If the Client objects to any of the modified terms in the Agreement, the Client may terminate this Agreement in accordance with Section 16. By continuing to use the Services after the effective date of any modification to this Agreement, the Client agrees to be bound by the modified Agreement. It is the Company’s obligation to check the A-Express Remit Pte Ltd website regularly for modifications to this Agreement. A-Express Remit Pte Ltd last modified this Agreement on the date listed at the top of this Agreement. Except as this Agreement (including this Section) otherwise allows, this Agreement may not be modified except in writing by the Parties

b. Changes in Services. A-Express Remit Pte Ltd may from time to time, make changes to the Services. If such changes lead to a material change in the A-Express Remit Pte Ltd affecting the Client, A-Express Remit Pte Ltd will notify the Client as soon as reasonably practicable.

22. Assignment and Subcontracting.

a. Assignment by Client. The Client may not subcontract, assign, novate, charge, declare a trust over or transfer the benefit of all or any part of this Agreement without the prior written consent of A-Express Remit Pte Ltd .

b. Assignment by A-Express Remit Pte Ltd . A-Express Remit Pte Ltd may, without prior consent or notice, novate or assign any or all of its rights and obligations under this Agreement to any:

• I. of its Affiliates; or
• II. in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of its assets.

c. Subcontracting by A-Express Remit Pte Ltd . A-Express Remit Pte Ltd may subcontract its obligations under this Agreement to third parties.

23. Multiple Entities.

a. Multiple A-Express Remit Pte Ltd Entities. Where there is one or more Affiliates of A-Express Remit Pte Ltd providing services to the Client or its Affiliates, each Affiliate of A-Express Remit Pte Ltd will enter into a separate agreement with Client to provide services not as a partner or jointly with A-Express Remit Pte Ltd or the other Affiliates of A-Express Remit Pte Ltd , and such Affiliate of A-Express Remit Pte Ltd shall not be liable in connection with the Services provided by A-Express Remit Pte Ltd , whether jointly or severally;

b. Effect of Suspension or Termination. Any Affiliate of A-Express Remit Pte Ltd or Affiliate of the Client may suspend or terminate any Service, in whole or in part, in accordance with the terms of the applicable agreement. Any suspension or termination shall affect only such portion of that agreement which relates to the Service under suspension or termination, and shall not suspend, terminate, affect, impair, invalidate or render unenforceable any provisions of this Agreement in connection with any other Services.

24. Dispute Resolution.

a. Dispute Notice. Without prejudice to either Party’s rights or remedies under this Agreement, if any Party (each a “Disputing Party”) brings a dispute against the other Party arising out of or in connection with this Agreement (“Dispute”), such Disputing Party shall give to the other Party a written notice of the Dispute, setting out the nature and full particulars of such Dispute (“Dispute Notice”). Following service of the Dispute Notice, the parties shall attempt to resolve the Dispute in good faith.

b. Resolution Period. If the parties are unable to resolve the Dispute within twenty (21) days of service of the Dispute Notice or such other period as mutually agreed between the Parties (“Period”), either Party shall be entitled to commence proceedings in court, subject to Section 23

c. Settlement. If the Dispute is resolved within the Period, any settlement shall be recorded in writing and signed by the authorized representative of each Party.

25. Governing Law and Jurisdiction.

This Agreement shall be governed by and construed in accordance with the laws of the jurisdiction where A-Express Remit Pte Ltd is incorporated (“Governing Jurisdiction”) and the parties submit to the exclusive jurisdiction of the courts of the Governing Jurisdiction for any dispute which may arise out of or in connection with this Agreement.

26. Miscellaneous.

a. Entire Agreement. This Agreement, and all of its Appendices and Schedules, contain the entire understanding of the parties hereto with respect to activities contemplated by this Agreement and supersede all prior agreements and understandings, whether written or oral. Failure to exercise or enforce any right or provision of this Agreement shall not constitute a waiver of such right or provision. The parties intend this Agreement to be construed without regard to any presumption or rule requiring construction or interpretation against the Party drafting an instrument or causing any instrument to be drafted.

b. Equitable Remedies. Each Party acknowledges and agrees that, notwithstanding any other provisions of this Agreement, breach of this Agreement by a Party may cause the other Party irreparable damage for which recovery of money damages would be inadequate, and that the Party that has suffered the breach shall, therefore, be entitled to institute a suit and without posting bond, obtain an injunction against such Party, whether interlocutory or preliminary, and to any other equitable relief, before any court, restraining any such breach.

c. Further Assurances. The Client shall, at A-Express Remit Pte Ltd ’s request, execute or procure the execution of such documents and do or procure the doing of such acts or things as A-Express Remit Pte Ltd may reasonably require for the purpose of this Agreement.

d. Severability. Any term or provision of this Agreement that is invalid or unenforceable in any situation in any jurisdiction shall not affect the validity or enforceability of the remaining terms and provisions of this Agreement or the validity or enforceability of the offending term or provision in any other situation or in any other jurisdiction.

e. Independent Contractors. Unless expressly indicated otherwise in this Agreement, the relationship between the parties to this Agreement shall be that of independent contractors. Nothing in this Agreement shall be construed to create the relationship of employer and employee, a joint venture, a partnership or joint association between the parties to this Agreement and or any of their respective Affiliates.

f. No Third Party Beneficiaries. Except for the A-Express Remit Pte Ltd Party or Client Party, no other person will have any right whatsoever to enforce this Agreement or have the benefit of any of its terms.

27. Data Protection Agreement.

The Parties acknowledge and agree that each Party shall act as an independent controller with respect to any Personal Data collected or processed in connection with the Services. The Parties understand and agree that they (a) are acting, and shall act, independently of one another in their respective processing of such Personal Data, and are not and shall not be ‘joint controllers’ of such Personal Data within the meaning of Article 26(1) of the GDPR; (b) shall provide reasonable cooperation and assistance to the other Party as necessary for the other Party’s compliance with Applicable Laws (at the other Party’s reasonable expense) with respect to such Personal Data; and (c) shall be bound by the terms of the Data Protection Agreement, which is incorporated herein by reference. Each Party will comply with the terms of the Data Protection Agreement and will be responsible for its compliance with Applicable Laws.

APPENDIX A

DEFINITIONS

The following capitalized terms in the Agreement shall have the following definitions:

“Affiliate”	means any entity which Controls or is Controlled by or under common Control with or by a Party.
“API”	means a software application program interface.
“Applicable Laws”	means (a) any law or regulation in the relevant jurisdictions applicable to a Party and/or the Services from time to time; (b) the operating rules, regulations and guidelines and technical standards promulgated from time to time by any organization which apply in respect of the Services (including the Network Rules); and (c) any conditions placed on a license issued to A-Express Remit Pte Ltd by a Regulatory Body.
“Approved Third Party”	means a party that (i) is not the Client, A-Express Remit Pte Ltd , or an Affiliate of A-Express Remit Pte Ltd , and (ii) has received the prior written approval by A-Express Remit Pte Ltd to provide APIs or services that are to be integrated by Client into the Services, A-Express Remit Pte Ltd or A-Express Remit Pte Ltd Platform.
“Approved Third Party API”	means an API, created by an Approved Third Party, that has received the prior written approval by A-Express Remit Pte Ltd to be integrated into the Services, A-Express Remit Pte Ltd Technology or A-Express Remit Pte Ltd Platform.
“Approved Jurisdictions”	means those countries as notified by A-Express Remit Pte Ltd to the Client from time to time being where A-Express Remit Pte Ltd has the ability to facilitate the provision of the Services.
“Assessments”	means any assessment, fine, or similar charge of any nature which a Network, Payment Method Provider or Regulatory Body levies on the Client or A-Express Remit Pte Ltd at any time, directly or indirectly, in respect of the Services or any Transaction.
“Authorization”	means a confirmation from the Payment Method Provider that at the time of the Transaction there are sufficient funds available to pay for the relevant Transaction.
Available Balance"	means the total balance of cleared funds credited to the A-Express Remit Pte Ltd Account.
“Beneficiary”	means an individual or entity (which shall include the Client) holding a bank account or other form of stored value account located in an Approved Jurisdiction and identified by the Client in an Instruction as the recipient of a Pay Out.
“Business Day”	means a day, other than a Saturday or Sunday or public or bank holiday, when banks are open for the transaction of business in the country where A-Express Remit Pte Ltd is located.
“Cancellation”	means an Instruction given by the Client to A-Express Remit Pte Ltd to cancel a Pay Out before such Pay Out has been processed by A-Express Remit Pte Ltd .
“Claim”	means any claim, demand, lawsuit, sanction, judgement, all foreseeable or unforeseeable and alleged or actual action, causes of action or other similar proceeding.
“Client”	means the client whose details are described in the Fee Schedule as approved by A-Express Remit Pte Ltd to obtain the Services as set out in this Agreement (a) for its own purposes, or (b) to facilitate provision of End Customer Services to its End Customers.
“Client Authorized Representative”	means Representatives authorized by the Client to access and use the A-Express Remit Pte Ltd Platform.
“Client Bank Account”	means an account held in the name of the Client with a duly licensed financial institution in an Approved Jurisdiction used to receive a Pay Out pursuant to the Pay Out Service.
“Confidential Information”	means all information, data, practices and techniques relating to a Party’s or its Affiliates‘ clients, competitors, business, operations, strategies, computer systems, marketing systems and Intellectual Property Rights or other property, of which the other Party becomes aware in negotiating or performing this Agreement, but does not include information which is publicly available or was lawfully known at the time of disclosure or later becomes part of the public domain through no breach of this Agreement. This Agreement and the Fees are A-Express Remit Pte Ltd ’s Confidential Information.
“Control”	means direct or indirect ownership of more than 50% of the voting power or equity in an entity.
“Deductions”	means all amounts which A-Express Remit Pte Ltd is entitled to deduct from the Available Balance under Applicable Laws, and/or this Agreement including: (a) Fees, (b) Pay In Reversals, (c) Pay In Refunds, (d) Assessments, (e) Pay Outs, (f) Reserves and (g) Taxes.
“Documentation”	means A-Express Remit Pte Ltd ’s product support documentation, API documentation and applicable pages on its website, as updated by A-Express Remit Pte Ltd from time to time.
“EEA”	means the European Economic Area.
“Effective Date”	Means the “Effective Date” stated in the Fee Schedule.
“End Customer”	means, in the case that the Client is a Financial Institution, a person or entity that is a customer of the Client and to whom the Client provides payment or other services. For the avoidance of doubt, A-Express Remit Pte Ltd is not providing, and shall not be construed as providing, Services to any End Customer.
“End Customer Services”	means services independently provided by the Client to an End Customer under a separate agreement entered into between the Client and the End Customer.
“Fees”	means the amounts payable by the Client as set out in the Fee Schedule.
“Financial Institution”	means a bank, major payment institution, money services business, electronic money institution, or other type of financial services institution that is duly licensed under Applicable Laws by a government financial institution authority.
“Financial Partner”	means a Financial Institution that has entered into an agreement with A-Express Remit Pte Ltd to facilitate the provision of Services to the Client.
“FX Margin”	means the foreign exchange margin set forth in the Fee Schedule, subject to any FX Margin Volatility Adjustment, from time to time.
“FX Margin Volatility Adjustment”	means an adjustment to the FX Margin made by A-Express Remit Pte Ltd where, in its sole and reasonable discretion, it (a) determines that there is heightened market risk or volatility during a period of time and (b) provides prior written notice of the adjustment to the Client of such an adjustment that includes an estimate of the expected amount and duration of the adjustment.
“Initial Term”	means the “Initial Term” stated in the Fee Schedule.
“Instruction”	means an instruction from the Client directly or via an Approved Third Party to A-Express Remit Pte Ltd including any instruction made by telephone, letter, email or via the A-Express Remit Pte Ltd Platform.
“Intellectual Property Rights”	means any patent, right to invention, copyright, trademark, service mark, trade secret, trade dress, mask work, moral right, right of attribution or integrity, business names and domain names, goodwill and the right to sue for passing off or unfair competition, rights in computer software, database rights, right to use and protect the confidentiality of, confidential information (including know-how and trade secrets) and all other intellectual property or proprietary right arising under the laws of any jurisdiction (including, without limitation, all claims and causes of action for infringement, misappropriation or violation thereof and all rights in any registrations and renewals), which subsist or will subsist in the future in any part of the world, and whether registered or unregistered (including any applications and rights to be granted, renewals or extensions of, and right to claim priority from, such rights.
“Loss”	means any damages, awards, settlement amounts, fines, penalties, costs, fees and expenses (including, but not limited to, reasonable attorney’s fees and expenses) or other liabilities or losses of any kind whatsoever.
"Net Available Balance "	means the Available Balance, net of applicable Deductions.
“Network”	means Visa, MasterCard or any other association, payment network or similar entity.
“Network Rules”	means the operating rules, regulations and guidelines and technical standards promulgated from time to time by any Network which apply in respect of the Services
“A-Express Remit Pte Ltd Account”	means an account assigned to the Client by A-Express Remit Pte Ltd and denominated in a Supported Currency.
“A-Express Remit Pte Ltd Platform”	means the online dashboard, APIs and other A-Express Remit Pte Ltd systems made available to the Client.
“A-Express Remit Pte Ltd”	means all hardware, software, APIs, user interfaces (including the A-Express Remit Pte Ltd Platform), Documentation that A-Express Remit Pte Ltd owns or licenses and that A-Express Remit Pte Ltd uses to provide the Services.
“OFAC”	means the Office of Foreign Asset Control of the United States Department of the Treasury.
“OFAC Lists”	means the Sanctions lists maintained by OFAC, including the Specially Designated Nationals and Blocked Persons List, Foreign Sanctions Evaders List, and the Sectoral Sanctions Identifications List.
"Pay In"	means any funds received by A-Express Remit Pte Ltd on behalf of the Client, in each case, which relate to the Client or an Underlying Transaction.
“Pay In Refund”	means an Instruction initiated by the Client to return funds to the Payer in respect of a Pay In.
“Pay In Reversal”	means an instruction initiated by a Payer, the Payer’s financial institution or a Payment Method Provider to return funds to the Payer, the Payer’s financial institution or the Payment Method Provider in respect of a Pay In, including a dispute, chargeback, payment reversal, authorization reversal, error reversal, or any other type of reversal.
“Pay In Request”	means an Instruction submitted by the Client to A-Express Remit Pte Ltd to accept a Pay In into a VBAN.
"Pay In Service"	means the services provided by A-Express Remit Pte Ltd that enable the Client to (a)receive Client funds or a Pay In in a Supported Currency from a Payer to a VBAN, and (b) exchange the Client funds or Pay Ins from one Supported Currency to another Supported Currency.
"Pay Out"	means a transaction where A-Express Remit Pte Ltd transfers funds from the Client’s A-Express Remit Pte Ltd Account to a Beneficiary, in accordance with an Instruction.
“Pay Out Currency”	means the currency in which a Pay Out is settled to the applicable Beneficiary.
“Pay Out Location”	means the location of the Beneficiary of a Pay Out.
“Pay Out Return Amount”	means, in the event that a Pay Out is subject to a Return, an amount equal to (i) the amount of the Pay Out stated in the Instruction minus (ii) the Pay Out Return Fees.
"Pay Out Return Fees"	means the total amount of bank and Network fees, charges and administrative costs incurred with respect to the Return of a Pay Out.
"Pay Out Service"	means the services provided by A-Express Remit Pte Ltd that enable the Client to make a Pay Out.
"Payer"	means any person located in an Approved Jurisdiction that transfers funds to the Client via a Pay In. For the avoidance of doubt, A-Express Remit Pte Ltd is not providing and, shall not be construed as providing, Services to any Payer.
"Payer Bank Account"	means where applicable, a bank account or other form of stored value account held in the name of a Payer in an Approved Jurisdiction, which is used to send funds to a VBAN of the Client.
"Payment Method Providers"	means providers of payment methods which can be used by a Payer as a means of payment for Underlying Transaction including payment cards, bank transfers, direct debits, vouchers, post-pay solutions and wallets.
"Payment Trace Request”	means an Instruction given by the Client to A-Express Remit Pte Ltd to ascertain the status of a Pay Out processed by A-Express Remit Pte Ltd through either a trace request or a request for receipt of a proof of payment.
“Personal Data"	means any information that (a) identifies or relates to an individual who can be identified directly or indirectly from that data alone or in combination with other information in a Party’s possession or control or that such Party is likely to have access to, or (b) any other information that is defined as “personal information” or “personal data” under all laws and regulations that are applicable to the processing of Personal Data under this Agreement, including, but not limited to (i) the Personal Data Protection and Electronic Documents Act, S.C. 2000, c. 5 of Canada, (ii) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), (iii) the Singapore Personal Data Protection Act of 2012, (iv) the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses, provided by the United Kingdom's Information Commissioner's Office pursuant to Section 119A of the Data Protection Act 2018, (v) the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020, or, in each case, any successor laws and regulations that have the same general intent and effect.
"Recall"	means an Instruction given by the Client to A-Express Remit Pte Ltd to recall a Pay Out after such Pay Out has been processed by A-Express Remit Pte Ltd .
“Regulatory Body”	means any governmental, regulatory, or administrative authority, department, agency, commission, board, tribunal, crown corporation, or other law, rule or regulation making entity (including an applicable Network and any stock exchange) that any of the Parties and/or their Affiliate submit to, are regulated or governed by, or are subject to the jurisdiction of, in respect of this Agreement, and any successor or replacement of any of the foregoing.
“Representatives”	means with respect to a Party, the officers, directors, employees, agents, subcontractors and advisors of such Party.
“Reserves”	has the meaning given in Section 6(g) of the General Terms.
"Return"	means the Beneficiary bank has returned the funds received from A-Express Remit Pte Ltd or a Financial Partner in connection with a Pay Out to A-Express Remit Pte Ltd or such Financial Partner.
“Sanctions”	means any economic sanctions laws, regulations, embargoes or restrictive measures administered, enacted or enforced by: (a) Singapore, (b) the European Union, (c) the United States, (d) the United Kingdom, (e) the United Nations, or (f) any other relevant sanctions authorities.
“Security”	has the meaning given in Section 11 of the General Terms.
“Security Incident”	means (a) any actual, successful or suspected unauthorized access, use, disclosure, modification, or destruction of either (i) any End Customer Data or (ii) any Confidential Information of the other Party, or (b) interference with system operations in the information system of a Party that affects the provision of the Services to the End Customers; provided, however, this does not include trivial incidents that occur on a daily basis, such as scans, pings, or unsuccessful attempts to penetrate a Party’s computer network or server.
“Services”	means, collectively, the Pay Out Service, the Pay In Service, and any other services provided by A-Express Remit Pte Ltd to the Client under this Agreement.
"Settlement Account"	means a pooled bank account maintained by A-Express Remit Pte Ltd with a Financial Partner in which A-Express Remit Pte Ltd holds funds received from, or on behalf of, its customers, including the Client, for the purpose of providing the Services.
“Subcontractor”	means any third party which performs any obligations on behalf of or provides services to the Client to enable the Client to perform any of its obligations under this Agreement.
“Supported Currency”	means each type of currency that is permitted by A-Express Remit Pte Ltd , in its sole discretion, to fund a A-Express Remit Pte Ltd Account.
“Tax”	means and includes, in relation to any jurisdiction, whether levied during or after the expiry of the term, any applicable national, state, local or foreign income, gross receipts, license, payroll, employment, excise, business, corporate income, severance, occupation, premium, windfall profits, capital gains tax, entertainment tax, registration fees or stamp duties, works contract tax, advertising/sponsorship-related taxes, luxury tax, environmental, customs duties, tariffs, octroi, capital stock, wealth, land, franchise, profits, withholding taxes, fringe benefits, payroll, unemployment, disability, real property, personal property, sale, use, consumption, lease, research and development, service, transfer, recording, documenting, registration, sales tax, alternative or add-on minimum, estimated or other tax or duty of any kind whatsoever and includes any surcharge, excess, charge, levy, interest, fee, penalty, related to or in addition thereto (whether direct or indirect and wherever and whenever imposed or potentially imposed or any deposit of tax with the authorities by way of a guarantee or security pursuant to or without any tax claim (whether disputed or not, whether by way of withholding or deduction for or on account of tax or otherwise, on a normative or deemed basis or by applying any other method, and includes for the purpose of clarity, any tax levied pursuant to audit by the tax authorities under any of the processes prescribed under the relevant law) by any authorities).
"Underlying Transaction"	means any legitimate business transaction between the Client and a Payer.
"VBAN"	means a virtual bank account number that is a unique identification number associated with a Settlement Account, which enables A-Express Remit Pte Ltd to accept a Pay In from the Client or a Payer, on behalf of the Client.

Data Protection Agreement

Last updated: June 19, 2024

THIS DATA PROTECTION AGREEMENT (“DPA”) is subject to and forms part of the Services Agreement and/or Outsourcing Agreement (as applicable) entered into between the applicable A-Express Remit Pte Ltd entity (“A-Express Remit Pte Ltd ”) and the applicable client entity (“Client”) that is a party to that agreement. A-Express Remit Pte Ltd and Client shall be collectively referred to herein as “Parties” and individually as a “Party”.

1. DEFINITIONS

a. "Business” means the term as defined under the US CCPA.

b. “Business Purpose” means performance of the A-Express Remit Pte Ltd pursuant to any applicable Services Agreement or performance of the Client Services by the Client pursuant to any applicable Outsourcing Agreement.

c. “Client Services” means any services provided by Client to A-Express Remit Pte Ltd under the terms of any applicable Outsourcing Agreement.

d. “Controller” means the entity which determines the purposes and means of the Processing of Personal Data.

e. "Data Complaint” means a complaint or request relating to either Party’s obligations under the Data Protection Laws relevant to this DPA, including any complaint by a Data Subject or any notice, investigation, or other action by a supervisory authority.

f. “Data Incident” means any act or omission that compromises the security, confidentiality or integrity of Personal Data or the physical, technical, administrative or organisational safeguards put in place to protect it that rises to the level of a security breach or incident under the applicable Data Protection Laws. Data Incidents include accidental or unlawful acquisition, destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data.

g. “Data Protection Laws” means all applicable laws, regulations, and other legally-binding requirements in any jurisdiction relating to privacy, data protection, data security, breach notification, or the Processing of Personal Data under this DPA, including without limitation, solely to the extent applicable, the General Data Protection Regulation, Regulation (EU) 2016/679 (“EU GDPR”); the United Kingdom Data Protection Act of 2018 (“UK GDPR”); the Swiss Federal Act on Data Protection (“FADP”); the Personal Data Protection and Electronic Documents Act, S.C. 2000, c. 5 of Canada along with any successor laws and regulations that have the same general intent and effect (Canada PIPEDA), the Singapore Personal Data Protection Act of 2012 (“Singapore PDPA”), the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (as amended and together with its regulations, the “US CCPA”). For the avoidance of doubt, if a Party’s activities involving Personal Data are not within the scope of a given Data Protection Law, such law is not applicable for purposes of this DPA.

h. “GDPR” means the EU GDPR or the UK GDPR (as applicable).

i. “Data Subject” means the identified or identifiable person to whom Personal Data relates.

j. “Data Subject Request” means a request from a Data Subject relating to Processing of Personal Data in connection with a Services Agreement or the A-Express Remit Pte Ltd to exercise the Data Subject's right of access, right to rectification, right to restrict Processing, right of erasure (i.e. “right to be forgotten”), right to data portability, right to object to the Processing, right not to be subject to automated individual decision making, or another applicable data subject right available to such Data Subject under applicable Data Protection Laws.

k. “EU Standard Contractual Clauses” means (i) the Standard Contractual Clauses based on the Commission Decision C(2010)593 on standard contractual clauses, as set out in the Annex to Commission Decision (EU) 2021/914, on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, available at http://data.europa.eu/eli/dec_impl/2021/914/oj and completed as set forth herein, as amended and modified, and (ii) any successor standard contractual clauses that have the same general intent and effect.

l. "Outsourcing Agreement” means the outsourcing agreement entered into between the Parties, under the term of which NiIum receives certain outsourced services from Client.

m. “A-Express Remit Pte Ltd” means any services provided by A-Express Remit Pte Ltd to the Client under the terms of any applicable Services Agreement.

n. “Personal Data” means any information that (a) identifies or relates to an individual who can be identified directly or indirectly from that data alone or in combination with other information in a Party’s possession or control or that such Party is likely to have access to, or (b) any other information that is defined as “personal information” or “personal data” under any applicable Data Protection Laws, which is Processed by a Party in connection with the Services Agreement or Outsourcing Agreement (as applicable) and this DPA.

o. “Process” or “Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction, or any other activity that the relevant Data Protection Laws may otherwise include in the definition of processing.

p. “Processor” means the entity which Processes Personal Data on behalf of the Controller.

q. “Services Agreement” means a services agreement executed between the Parties, under the terms of which the Client receives A-Express Remit Pte Ltd or its affiliates, including, but not limited to, the A-Express Remit Pte Ltd Direct Services Agreement or the A-Express Remit Pte Ltd Platform Services Agreement.

r. “Service Provider” means a Processor Processing Personal Data for the Business Purpose and any other entity that is defined as a “service provider” or “contractor” under applicable Data Protection Laws.

s. “Standard Contractual Clauses” means (i) the EU Standard Contractual Clauses (where applicable) and (ii) the UK Standard Contractual Clauses (where applicable).

t. “Sub-Processor” means a third-party Processor engaged by a Processor.

u. “UK Standard Contractual Clauses” means (i) the UK Addendum to the European Union Standard Contractual Clauses, provided by the United Kingdom's Information Commissioner's Office, as amended and modified, and (ii) any successor standard contractual clauses that have the same general intent and effect.

2. PROCESSING OF PERSONAL DATA

a. Independent Controller Terms under a Service Agreement. Where the Parties Process Personal Data under or otherwise in connection a Service Agreement, the Parties understand and agree that they are acting, and shall act, independently of one another in their respective Processing of such Personal Data and that the following terms and the applicable parts of Appendix A as referenced shall apply with respect to the Processing of Person Data under the Service Agreement:

• I. Roles of the Parties as Independent Controllers. The Parties agree that in regard to the Processing of Personal Data under Data Protection Laws that define the Parties’ relationship as one between a Controller and a Processor (such as the GDPR), A-Express Remit Pte Ltd and Client shall both be considered independent Controllers, shall individually determine the purposes and means of their Processing of such Personal Data, and shall not be “joint controllers” of such Personal Data within the meaning of Article 26(1) of the GDPR. The Parties understand and agree that the applicable module of the Standard Contractual Clauses has been determined pursuant to the roles of the Parties as defined in this Section 2.A and the roles of the Parties as importer and exporter. The Parties agree that in regard to the Processing of Personal Data under Data Protection Laws that define the Parties’ relationship as one between a Business and a Service Provider (such US CCPA), neither Party shall be considered a Service Provider and each Party shall be considered the Business. The Parties agree that in regard to the Processing of Personal Data under Data Protection Laws that define the Parties’ relationship as one between a “organisation” and a “data intermediary” (such as Singapore PDPA), A-Express Remit Pte Ltd and Client shall both be considered independent organisations. Nothing in this DPA or in the Services Agreement or Outsourcing Agreement (as applicable) shall be construed as to state or imply that (i) A-Express Remit Pte Ltd has a direct relationship with the individual customers or users of Client, unless such direct relationship is specifically established under the terms of the Services Agreement or Outsourcing Agreement (as applicable), or (ii) that A-Express Remit Pte Ltd is acting as a Processor under Data Protection Laws. The Parties further agree and acknowledge that neither Party is responsible for determining the requirements of Data Protection Laws applicable to the other Party.
• II. Responsibility of the Parties. Without limiting the roles identified in Section 2.A (i) above, each Party agrees to: (i) maintain a publicly-accessible privacy policy on its sites that satisfies all applicable transparency and notice requirements as required by Data Protection Laws with respect to Processing of Personal Data, (ii) delete or destroy Personal Data, in accordance with the requirements of applicable Data Protection Laws, upon the conclusion of its purpose for Processing such Personal Data unless applicable law requires a longer retention period, and (iii) implement appropriate technical and organisational measures to protect the Personal Data.
• III. Data as Confidential Information in accordance with the terms of each Services Agreement or Outsourcing Agreement (as applicable). Each Party acknowledges and confirms that it will, only to the extent required under Data Protection Laws: (i) comply with applicable Data Protection Laws and this DPA in connection with its Processing of Personal Data; (ii) only give lawful instructions to any Processors and/or Service Providers; (iii) be responsible for determining the legal basis of its own Processing activities; and (iv) not attempt to re-identify any pseudonymized, anonymized, aggregate, or de-identified Personal Data without the other Party’s express written permission; and (v) provide the other Party with reasonable assistance, information and cooperation as such Party may reasonably request to ensure compliance with the Parties’ respective obligations under Data Protection Laws. Nothing in this DPA shall be construed to convey any ownership interest or license in the Personal Data that is contrary to the ownership interests and licenses set forth in the Services Agreement or Outsourcing Agreement.
• IV. Data Subject Requests. Each Party will, to the extent legally permitted, notify the other Party within a reasonable time period if the notifying Party receives a Data Subject Request. The notifying Party will use commercially reasonable efforts to assist the other Party in responding to such Data Subject Request, to the extent the notifying Party is legally permitted to do so and the response to such Data Subject Request is required under Data Protection Laws. The other Party shall be responsible for any costs arising from the notifying Party’s provision of such assistance.
• V. Data Incident. In the event that either Party suffers a Data Incident in connection with any A-Express Remit Pte Ltd, such Party shall notify the other Party without undue delay and the Parties shall reasonably cooperate with each other in taking such measures as may be necessary to notify affected Data Subjects, comply with each Party’s obligations under Data Protection Laws, and to mitigate or remedy the effects of such Data Incident. The Parties agree that, in the event of a Data Incident that is likely to result in a “risk to the rights and freedoms of natural persons” with respect to Personal Data (as defined in Recital 75 of the GDPR, or any successor rules or guidance), the Party experiencing the Data Incident shall notify the other Party no later than twenty (24) hours after discovery of the Data Incident.
• VI. Data Incident. In the event that either Party suffers a Data Incident in connection with any Nium Services, such Party shall notify the other Party without undue delay and the Parties shall reasonably cooperate with each other in taking such measures as may be necessary to notify affected Data Subjects, comply with each Party’s obligations under Data Protection Laws, and to mitigate or remedy the effects of such Data Incident. The Parties agree that, in the event of a Data Incident that is likely to result in a “risk to the rights and freedoms of natural persons” with respect to Personal Data (as defined in Recital 75 of the GDPR, or any successor rules or guidance), the Party experiencing the Data Incident shall notify the other Party no later than twenty (24) hours after discovery of the Data Incident.

b. Processor Terms under an Outsourcing Agreement. Where the Client Processes A-Express Remit Pte Ltd Personal Data under or otherwise in connection with an Outsourcing Agreement, the applicable parts of Appendix A as referenced, and the entirety of Appendix B applies.

3. COOPERATION

Each Party shall provide reasonable assistance to the other Party and cooperation with respect to any consultation or request by any regulatory or supervisory authority who has governance over such other Party related to the Processing of Personal Data, to the extent related to the A-Express Remit Pte Ltd required under Data Protection Laws.

4. INTERNATIONAL TRANSFERS

If Data Protection Laws restrict cross-border Personal Data transfers between two independent Controllers, each Party will only transfer Personal Data to the other Party under the following conditions: (a) the transferring Party, either through its location or participation in a valid cross-border transfer mechanism under Data Protection Laws, may legally receive that Personal Data, or (b) the transfer otherwise complies with Data Protection Laws. If any Personal Data transfer between the Parties, as two independent Controllers, requires execution of Standard Contractual Clauses in order to comply with Data Protection Laws, the Parties agree that the Standard Contractual Clauses, in their entirety and as applicable, are hereby incorporated into this DPA and shall govern. Pursuant to any Personal Data transfer between Client and A-Express Remit Pte Ltd that requires execution of Standard Contractual Clauses where this DPA fails to provide all necessary information to properly execute the applicable Standard Contractual Clauses, the Parties will take all actions required to legitimize the transfer, including, if necessary: (x) co-operating to register the Standard Contractual Clauses with any applicable supervisory authority; (y) procuring approval from any such supervisory authority; or (z) providing additional information about the transfer to such supervisory authority. As applicable, in the event of a conflict or inconsistency between this DPA and the Standard Contractual Clauses, the Standard Contractual Clauses shall prevail.

For transfers of Personal Data that are subject to the FADP, the EU Standard Contractual Clauses form part of this DPA as set forth above, but with the following differences to the extent required by the FADP: (1) references to the EU GDPR in the EU Standard Contractual Clauses are to be understood as references to the FADP insofar as the data transfers are subject exclusively to the FADP and not to the EU GDPR; (2) the term “member state” in EU Standard Contractual Clauses shall not be interpreted in such a way as to exclude data subjects in Switzerland from the possibility of suing for their rights in their place of habitual residence (Switzerland) in accordance with Clause 18(c) of the EU Standard Contractual Clauses; and (3) the relevant supervisory authority is the Swiss Federal Data Protection and Information Commissioner (for transfers subject to the FADP and not the EU GDPR), or both such Commissioner and the supervisory authority identified in the EU Standard Contractual Clauses (where the FADP and EU GDPR apply, respectively).

5. US CCPA

If a party discloses Personal Data ("Disclosing Party") to the other party ("Receiving Party"), the Parties agree that such disclosure shall not be considered a “Sale” or “Sharing” for purposes of “Cross-Context Behavioral Advertising” (as such terms in quotes are defined in the US CCPA), and that such disclosure will be solely for the parties' legitimate business purposes as detailed in the Services Agreement or Outsourcing Agreement (as applicable), and for purposes permitted by the US CPPA along with its legally binding amendments and regulations.  The Receiving Party represents and warrants that it will not retain, use, disclose, or process Personal Data obtained pursuant to the Agreement for any purpose other than for the specific purposes set forth herein, unless the Receiving Party has received appropriate consent under Data Protection Law from the individual about whom the Personal Data relates.  The Receiving Party represents and warrants that it will comply with all requirements of Data Protection Law, including but not limited to by:

• providing the same level of privacy protection to Personal Data as required of the Disclosing Party under Data Protection Law, and in no event less than a reasonable standard of care;
• providing any required disclosures, such as privacy policies, notices at collection, or opt out notices to individuals whose Personal Data it processes; and comply with any required opt out rights; and
• implementing appropriate technical and organizational measures to ensure a level of security for the Personal Data appropriate to the risk.
• Not “Selling” or “Sharing” for purposes of Cross-Context Behavioral Advertising Personal Data (as such terms are defined in the US CCPA).

The Disclosing Party has the right to take reasonable and appropriate steps to ensure that the Receiving Party uses Personal Data provided by the Disclosing Party under the Agreement consistent with Data Protection Law, and, upon reasonable advance notice, to take reasonable steps to stop and remediate any use of Personal Data by the Receiving Party that is inconsistent with applicable Data Protection Laws or this provision.

6. GENERAL PROVISIONS

a. Notice Requirements. Each Party agrees that it will notify the other Party if it determines that it cannot or will no longer meet the obligations set forth in this DPA or applicable Data Protection Laws with respect to the Business Purpose. All such notices shall be sent in accordance with the notice provision(s) set forth in the applicable Services Agreement or Outsourcing Agreement (as applicable).

b. Term. This DPA will remain in force and effect for the duration of (i) the Services Agreement or (ii) the Outsourcing Agreement, unless otherwise agreed in writing between the Parties.

c. Severability. If one or more provisions of this DPA are held to be unenforceable under applicable law, the Parties agree to renegotiate such provision in good faith. In the event that such provision was not required by the Data Protection Laws and the Parties cannot reach a mutually agreeable and enforceable replacement, then (a) such provision shall be excluded from this DPA, (b) the balance of this DPA shall be interpreted as if such provision were so excluded, and (c) the balance of this DPA shall be enforceable in accordance with its terms.

d. Limitation of Liability. Each Party’s liability arising out of or related to this DPA, whether in contract, tort or under any other theory of liability, is subject to the limitations of liability set forth in the applicable Services Agreement or Outsourcing Agreement and any reference in the Services Agreement or Outsourcing Agreement limiting a Party’s liability means the aggregate liability of that Party under the such agreement and this DPA.

e. Governing Law and Jurisdiction. This DPA shall be governed by and construed in accordance with the laws of the governing jurisdiction that is set forth in the applicable Services Agreement or Outsourcing Agreement (the “Governing Jurisdiction”), and the parties shall submit to the exclusive jurisdiction of the courts of the Governing Jurisdiction for any dispute which may arise out of or in connection with this DPA; provided, however, that (i) any dispute arising from the EU Standard Contractual Clauses shall be governed by and construed in accordance with the laws of Malta or Switzerland (as provided in Section 4 above in accordance with the FADP) and shall be subject to the jurisdiction of the courts of Malta and (ii) any dispute arising from the UK Standard Contractual Clauses shall be governed by and construed in accordance with the laws of England and Wales and shall be subject to the jurisdiction of the courts of England and Wales.

f. Remedies. A-Express Remit Pte Ltd and Client each agree that the obligations set forth in this DPA are necessary and reasonable in order to ensure that Data Subjects continue to benefit from effective safeguards and protection as required by the Data Protection Laws. A-Express Remit Pte Ltd and Client each expressly agree that due to the unique nature of the Personal Data covered hereunder, monetary damages would be inadequate to compensate either Party for any breach by the other Party of its covenants and agreements set forth in this DPA. Accordingly, A-Express Remit Pte Ltd and Client each agree and acknowledge that any such violation or threatened violation shall cause irreparable injury to a Party and that, in addition to any other remedies that may be available, in law, in equity or otherwise, such Party shall be entitled to obtain injunctive relief against the threatened breach of this DPA or the continuation of any such breach by the other Party, without the necessity of proving actual damages. Except as expressly set out in this DPA, each Party’s rights and remedies under this DPA are cumulative and not exclusive of any other rights or remedies to which the Party may be lawfully entitled under this DPA or at law, and each Party may pursue all of the Party’s rights and remedies concurrently, consecutively and alternatively.

g. Headings. The headings and subheadings within this DPA are for convenience only and do not define, limit, or enlarge the scope or meaning of this DPA or any of its provisions.

h. Counterparts. This DPA may be executed in two or more counterparts, each of which shall be deemed an original and all of which together shall constitute one instrument.

i. Amendment and Waiver. A-Express Remit Pte Ltd may modify all or any part of this DPA at any time by posting a modified version of this DPA (including any terms incorporated by reference into this DPA) on the A-Express Remit Pte Ltd Legal Page or by notifying the Client. The modified DPA is effective upon posting or, if A-Express Remit Pte Ltd notified the Client, as stated in the notice. If the Client objects to any of the modified terms in the DPA, the Client may terminate this DPA together with the Services Agreement. By continuing to use the Services after the effective date of any modification to this DPA, the Client agrees to be bound by the modified DPA. It is the Company’s obligation to check the A-Express Remit Pte Ltd Legal Page regularly for modifications to this DPA. A-Express Remit Pte Ltd last modified this DPA on the date listed at the top of this DPA. Except as this DPA (including this clause) otherwise allows, this Agreement may not be modified except in writing by the parties. Without limiting the foregoing, the Parties acknowledge that the Data Protection Laws and Standard Contractual Clauses have been incorporated into this DPA as amended and modified and include all implementing regulations enacted thereunder, as applicable. The Parties acknowledge and agree that amendments and modifications to the Data Protection Laws and Standard Contractual Clauses shall be automatically incorporated into this DPA; such amendments and modifications to the Data Protection Laws and Standard Contractual Clauses may change the Parties’ obligations under this DPA, but shall not be considered an amendment or modification of this DPA necessitating notice by A-Express Remit Pte Ltd . The Parties acknowledge and agree that the mere issuing of amendments and modifications to the Data Protection Laws and Standard Contractual Clauses shall not grant either Party the unilateral right to terminate any part of this DPA.

j. Survival. The provisions of this DPA survive the termination or expiration of the applicable Services Agreement or Outsourcing Agreement for so long as the Parties Processes Personal Data.

k. Entire Agreement. This DPA is the product of both of the Parties and constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes all other prior agreements and understandings, both written and oral, between the Parties with respect to the subject matter hereof. In the case of conflict or ambiguity between any provision in this DPA and the Services Agreement or Outsourcing Agreement, the provisions of this DPA will prevail.

APPENDIX A

ANNEXES I AND II TO EUROPEAN UNION STANDARD CONTRACTUAL CLAUSES

ANNEX I

A. LIST OF PARTIES

Data exporters and importers:

A-Express Remit Pte Ltd (Data Importer and Data Exporter)

Full Legal Name and Company Registration Number	The A-Express Remit Pte Ltd entity party to the Services Agreement or Outsourcing Agreement.
Address	A-Express Remit Pte Ltd ’s applicable address stated on aexpressremit.com
Contact details	A-Express Remit Pte Ltd Legal Department, contact@aexpressremit.com
Activities relevant to data transferred under these Clauses	When acting under Section 2.a (Independent Controller Terms under a Service Agreement) of the DPA, Services, under the terms of one or more Services Agreements, being provided by A-Express Remit Pte Ltd to Client. When acting under Section 2.b (Processor Terms under an Outsourcing Agreement) of the DPA, services being provided by the Client to A-Express Remit Pte Ltd under an executed Outsourcing Agreement.
Role (controller/processor)	Independent controller.
Signature and date:	Each party shall be deemed to have signed this Annex I on the same date as the Effective Date of the applicable Services Agreement or Outsourcing Agreement.

CLIENT (Data Importer and Data Exporter)

Full Legal Name and Company Registration Number	The Client entity party to the Services Agreement or Outsourcing Agreement (as applicable).
Address	The address provided to A-Express Remit Pte Ltd by the Client.
Contact details	The name, position and contact details provided to A-Express Remit Pte Ltd by the Client.
Activities relevant to data transferred under these Clauses	When acting under Section 2.a (Independent Controller Terms under a Service Agreement), Services, under the terms of one or more Services Agreements, being provided by A-Express Remit Pte Ltd to Client. With regards to Section 2.B of the DPA, services being provided by the Client to A-Express Remit Pte Ltd under an executed Outsourcing Agreement.
Role (controller/processor)	When acting under Section 2.A (Independent Controller Terms under a Service Agreement) of the DPA: Independent controller. When acting under Section 2.B (Processor Terms under an Outsourcing Agreement) of the DPA: Processor.
Signature and date:	Each party shall be deemed to have signed this Annex I on the same date as the Effective Date of the applicable Services Agreement or Outsourcing Agreement.

B. DESCRIPTION OF TRANSFER

Categories of data subjects whose personal data is transferred	When acting under Section 2.a (Independent Controller Terms under a Service Agreement), the Client’s end customers, representatives, and any natural person who accesses A-Express Remit Pte Ltd Services. With regards to Section 2.B of the DPA, the categories of data subjects as set out in Appendix D of the Outsourcing Agreement between A-Express Remit Pte Ltd and the Client
Categories of personal data transferred	When acting under Section 2.a (Independent Controller Terms under a Service Agreement), the categories of personal data required under the terms of the applicable Services Agreement, including account details, address, name, transaction details, device ID, email address, IP address/location, payment card details, tax ID/status, identity information including government issued documents (e.g., national IDs, driver’s licenses and passports). With regards to Section 2.B of the DPA, the categories of personal data as set out in Appendix D of the Outsourcing Agreement between A-Express Remit Pte Ltd and the Client.
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.	When acting under Section 2.a (Independent Controller Terms under a Service Agreement), the categories of sensitive data transferred may include racial or ethnic origin data. The data is transferred as part of compliance with anti-money laundering laws, sanctions laws, and financial institution laws. Access is restricted and protected in accordance with applicable law. With regards to Section 2.B of the DPA, the categories of any sensitive data as set out in Appendix D of the Outsourcing Agreement between A-Express Remit Pte Ltd and the Client.
The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis).	When acting under Section 2.a (Independent Controller Terms under a Service Agreement), data will be transferred on a continuous basis for the term of any applicable Services Agreement. With regards to Section 2.B of the DPA, data will be transferred on a continuous basis for the term of any applicable Outsourcing Agreement.
Nature of the processing	When acting under Section 2.a (Independent Controller Terms under a Service Agreement), A-Express Remit Pte Ltd will process personal data as necessary to provide the A-Express Remit Pte Ltd under each applicable Services Agreement. With regards to Section 2.B of the DPA, the nature of processing is set out in Appendix D of the Outsourcing Agreement between A-Express Remit Pte Ltd and the Client.
Purpose(s) of the data transfer and further processing	When acting under Section 2.a (Independent Controller Terms under a Service Agreement), the purposes of A-Express Remit Pte Ltd ’s Processing of Personal Data in its capacity as a Controller are: (i)  determining the Processing of Personal Data when providing A-Express Remit Pte Ltd, including when A-Express Remit Pte Ltd provides a payment method, and determining the third parties (banks and other service providers) to be utilized; (ii)  monitoring, preventing and detecting fraudulent transactions and other fraudulent activity in connection with A-Express Remit Pte Ltd ’s services; (iii)  complying with applicable law, including applicable anti-money laundering screening and know-your-customer obligations; and (iv)  analysing and developing A-Express Remit Pte Ltd ’s services. With regards to Section 2.B of the DPA, the purpose of processing is set out in Appendix D of the Outsourcing Agreement between A-Express Remit Pte Ltd and the Client.
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period	Personal Data will be retained for as long as necessary for the purpose for which it is collected. However, Personal Data may be retained longer, as may be required by law.
For transfers to Processors and Sub-Processors, also specify subject matter, nature and duration of the processing	As applicable, any transfers to processors and Sub-Processors will be subject to the same subject matter, nature, and duration as otherwise set forth in this Annex I.

C. COMPETENT SUPERVISORY AUTHORITY

Identify the competent supervisory authority/ies in accordance with Clause 13

The competent supervisory authority in accordance with Clause 13 is (i) for purposes of the UK GDPR, the United Kingdom Information Commissioner Office or (ii) for purposes of the EU GDPR, the Malta Information and Data Protection Commissioner or the Swiss Federal Data Protection and Information Commissioner as relevant in accordance with Section 4 of the Agreement.

ANNEX II

TECHNICAL AND ORGANIZATIONAL MEASURES INCLUDING TECHNICAL AND ORGANIZATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA

The technical and organizational measures of A-Express Remit Pte Ltd are as set forth below:

Annex II A-Express Remit Pte Ltd - Technical and Organizational Measures

Organizational Measures	Internal policies and procedures for data security for A-Express Remit Pte Ltd ’s employees. Employees are informed about the internal policies and procedures regulating Personal Data security. The internal policies and procedures related to the Processing of Personal Data are periodically revised and updated. The responsible employees are trained about Personal Data security and processing.
Management and Control of Access to Personal Data	Management and Control of Access to Personal Data The protection, management and control of access to Personal Data is ensured. Access to Personal Data is granted only to the person to whom the Personal Data is required to perform his / her functions in connection with the Services. Actions which can be taken while Processing Personal Data is limited by the scope of right that have been granted to a person. The requirements for the access to the Personal Data is ensured for the passwords: passwords’ confidentiality is ensured; passwords are unique; the passwords are changed periodically. In case the Personal Data is Processed in the internal network of computers, the protection of Personal Data is ensured from the illegal connection by electronic connections measures (e. g. the use of the firewall). Control of access to Personal Data. Recording and controlling the registration and access rights efforts. Determining the number of allowed failed connections. Recordings of logins to personal data: login ID, date, time, duration, connection result (successful, unsuccessful). Logs for personal data are stored. Login data and tools are intended for each user personally - it is forbidden for other persons to use one login account. When the access to the employee of the Data Processer becomes the unnecessary (e. g. the employment relationship is terminated or the nature of work is changed), the Data Controller shall be informed immediately about that, the access is cancelled, physical authentication tools are returned if such tools were provided.
Physical Access	The security of premises, where Personal Data is stored, is ensured physically by limiting the access of unauthorized persons to appropriate premises.
Receiving and Providing Personal Data Over Internet	If Personal Data is received or provided over the Internet: Data transmission channels are encrypted using cryptographic protocols (TLS, SSL). Logging is allowed from any IP address. Users are identified by a unique name / password / certificate.
Security Measures While Receiving or Providing Personal Data by Email and External Data Networks	If Personal Data is received or provided via email, security controls on Personal Data are ensured. If Personal Data is received or provided by external data transmission networks, secure protocols (e. g. TLS, SSL) / passwords are ensured.li>
Use of Computers and Software	The protection of computer hardware is ensured from malicious software (such as installing, upgrading, firewalls, and firewalls). Back-up copies of Personal Data, if any, are stored in other premises or geographic location than the active (working) database. Testing of information systems is not carried out with real Personal Data. The security updates are regularly automatically installed for computer systems. Complex and secure passwords are used to connect to the computer. When utilizing of or transferring a computer or data media for use by other persons, it must be ensured that all information relating to the Personal Data has been destroyed in a secure manner.
Protection of Servers and Databases	The following minimum-security requirements apply to the protection of servers and databases used to access or store the Processor’s information: Updated malware protection must be enabled and maintained. Access (physical and logical) must be allowed only to authorized personnel.
Security of Data Networks	The use of Processor information systems and data is allowed only with the use of properly protected networks, including: Direct connection of the computer to the internet is prohibited. The connection must be made by using an intermediate network security device - a router with address change (NAT) function or a firewall. Connection from data networks which security is unknown (e. g. public access points in cafes, hotels, etc.) is prohibited. If a local wireless connection (e. g. Wi-Fi) is used to connect the computer, the security and secrecy of the connection must be secured using secure authentication and encryption methods. All devices on the network are managed so that only authorized devices are accessed and unauthorized and unmanaged devices are detected and blocked.

APPENDIX B

Where the Client Processes A-Express Remit Pte Ltd Personal Data under or otherwise in connection with an Outsourcing Agreement, the Parties understand and agree that A-Express Remit Pte Ltd is the Controller and the Client is the Processor and that the Processing of Personal Data under the Outsourcing Agreement is subject to this Appendix B.

1. Role of the Client as a Processor. A-Express Remit Pte Ltd is the Controller and the Client is the Processor.

2. Instructions and Details of Processing. When the Client processes Personal Data on behalf of A-Express Remit Pte Ltd , the Client shall:

a. unless required to do otherwise by applicable laws, (and shall take steps to ensure each person acting under its authority shall) process the Personal Data only on and in accordance with this Agreement and Appendix D to the Outsourcing Agreement and any other documented instructions from A-Express Remit Pte Ltd (including with regard to any transfers to a third country or an international organisation) all as updated from time to time upon written agreement between the Parties (“Processing Instructions”);

b. if applicable laws require it to process Personal Data other than in accordance with the Processing Instructions, notify A-Express Remit Pte Ltd of any such requirement before processing the Personal Data (unless applicable laws prohibit such information on important grounds of public interest).

c. notify A-Express Remit Pte Ltd if it becomes aware that any of the Personal Data is inaccurate or has become outdated.

d. not share the Personal Data with any third party except as expressly authorised by A-Express Remit Pte Ltd and pursuant to Section 3 below.

e. not transfer, access or process Personal Data of A-Express Remit Pte Ltd outside of the UK and the EEA without obtaining the A-Express Remit Pte Ltd 's explicit written consent and without having in place such legally enforceable mechanism(s) for transfers of Personal Data as may be permitted under the GDPR from time to time, including those set out in Article 46 of the GDPR and the implementation of binding corporate rules pursuant to Article 47 of the GDPR.

3. Personnel and Other Processors.

The Client shall not engage a Sub-Processor to carry out any processing activities in respect of the Personal Data without notifying A-Express Remit Pte Ltd , seeking A-Express Remit Pte Ltd ’s prior written consent and subject to compliance by the Client with Section 3. A-Express Remit Pte Ltd is deemed to have provided its approval where it has not objected to the new proposed Sub-Processor within thirty (30) calendar days from the date the Client’s notice was received.

a. The Client shall:

• I. provide details to A-Express Remit Pte Ltd of any Sub-Processor. Any Sub-Processor agreed by A-Express Remit Pte Ltd as at the date of this Agreement is set out in Appendix D of the Outsourcing Agreement;
• II. notify A-Express Remit Pte Ltd 30 days in advance of any change in a Sub-Processor (through the addition or replacement of a Sub-Processor) and shall provide such information as necessary to enable A-Express Remit Pte Ltd to decide whether to consent to the change. A-Express Remit Pte Ltd shall be entitled to object to any change in the Sub-Processor and at its discretion (not to be unreasonably exercised) may elect to terminate the Agreement or that part of the Agreement that involves processing of the Personal Data by the Sub-Processor in the event that the Client fails to take the steps suggested by A-Express Remit Pte Ltd to address the objection and otherwise does not cease to use the relevant Sub-Processor;
• III. prior to the relevant Sub-Processor carrying out any processing activities in respect of the Personal Data, appoint each Sub-Processor under a written contract containing obligations which offer materially the same level of protection for the Personal Data as those set out in this Agreement, including an obligation on the Sub-Processor to provide sufficient guarantees to implement equivalent technical and organizational measures in accordance with Section 4 and to delete or return the Personal Data in accordance with Section 8. The contract with the Sub-Processor shall state that compliance with the obligations may be enforced by A-Express Remit Pte Ltd including if the Client ceases to exist or becomes insolvent. On request by A-Express Remit Pte Ltd , the Client shall provide a copy of the contract with the Sub-Processor. The Client may redact the text of the contract to the extent necessary to protect confidential information including any personal data; and
• IV. notify A-Express Remit Pte Ltd of any failure by a Sub-Processor to fulfil its contractual obligations.

b. The Client shall ensure that all persons authorised by it (or by any Sub-Processor) to process Personal Data are subject to an obligation to keep the Personal Data confidential. The Client shall grant access to the Personal Data to members of the personnel on an "as needed basis" and only for the purposes set out in Appendix D of the Outsourcing Agreement.

c. The Client shall remain fully liable to A-Express Remit Pte Ltd for any and all acts and omissions of any Sub- Processor, and any persons authorised by it (or by any Sub-Processor) to process Personal Data as if they were its own.

4. Technical and Organizational Measures. The Client shall implement and maintain appropriate technical and organizational measures in accordance with Appendix B, to:

a. ensure that the processing of Personal Data will meet the minimum requirements of the Data Protection Laws (including as set out in Article 32 GDPR) and ensure the protection of the rights of Data Subjects; and

b. provide reasonable assistance to A-Express Remit Pte Ltd in responding to Data Subject Requests relating to Personal Data.

5. Information and Audit.

a. The Client shall maintain complete, accurate and up-to-date written records of all categories of Processing activities carried out in accordance with the Data Protection Laws (the “Records”).

b. The Client shall, in accordance with the Data Protection Laws:

• I. as soon as reasonably practicable make available to A-Express Remit Pte Ltd such information as requested by it from time to time, including any Records, that is necessary to demonstrate the Client's compliance with its obligations under this Agreement and the Data Protection Laws, and it shall immediately inform A-Express Remit Pte Ltd if, in its reasonable opinion, an instruction infringes the Data Protection Laws or any applicable law; and
• II. allow A-Express Remit Pte Ltd (either itself or mandate an independent auditor to) inspect, test and audit, all facilities, premises, equipment, systems, documents and electronic data relating to the processing of A-Express Remit Pte Ltd ’s Personal Data by the Client, including where required by a supervisory authority. Such inspections and audits shall be at reasonable times and with prior written notice, subject to any inspection or audit required by a supervisory authority where this is not possible.

c. The Client shall:

• I. provide full cooperation and assistance in relation to such inspection, test and audit (subject to any confidentiality obligations) and on request shall provide copies of the results of any penetration and security testing procedures and third-party audit reports such as SOC II type audit reports (if such reports are available); and
• II. in the event that A-Express Remit Pte Ltd identifies any non-compliance with this Agreement as a result of an inspection, test or audit, the Client shall take such steps as A-Express Remit Pte Ltd may reasonably request in order to promptly remedy the non-compliance, at no further cost to A-Express Remit Pte Ltd .

d. All Parties shall be entitled to share any information referred to in this Section D including the results of any audit, with a competent supervisory authority as may be necessary from time to time.

6. Assistance and Data Subject Rights

a. The Client shall maintain a complete and accurate record of Data Subject Requests. Upon receipt of any Data Subject Request, the Client shall immediately (and no later than within 48 (forty-eight) hours of receipt) refer such Data Subject Request to A-Express Remit Pte Ltd and shall, at its own expense, promptly assist A-Express Remit Pte Ltd with such Data Subject Request to ensure that A-Express Remit Pte Ltd meets the response times under the Data Protection Laws. The Client shall not respond to a Data Subject Request without providing prior written notice to A-Express Remit Pte Ltd or as required by applicable laws, in which case the Client shall, to the extent permitted by applicable laws, inform A-Express Remit Pte Ltd of that legal requirement prior to the Client responding to such Data Subject Request.

b. The Client shall provide such assistance as reasonably required by A-Express Remit Pte Ltd to ensure compliance with A-Express Remit Pte Ltd ’s obligations under the Data Protection Laws with respect to:

• I. security of processing;
• II. data protection impact assessments (as such term is defined in the Data Protection Laws);
• III. prior consultation with a supervisory authority regarding high-risk processing;
• IV. notifications to the supervisory authority and/or communications to data subjects by A-Express Remit Pte Ltd in response to any Data Incident; and
• V. any remedial action to be taken in response to a Data Incident and/or a Data Complaint or request relating to either Party’s obligations under the Data Protection Laws relevant to the Agreement.

7. Breach Notification

a. In respect of any Data Incident, the Client shall, without undue delay but in no event later than 48 (forty-eight) hours (or earlier where possible) after becoming aware, notify A-Express Remit Pte Ltd of the Data Incident and provide A-Express Remit Pte Ltd with details of the Data Incident including the nature of the Data Incident, the categories and approximate volume of data subjects, the Personal Data records concerned, the likely consequences of the Data Incident and any measures taken or to be taken by the Client to mitigate the effects of the Data Incident. Where, and insofar as, it is not possible for the Client to provide all of this information at the same time, the initial notification will provide such information as available to the Client and the Client shall provide the further information as soon as it becomes available without undue delay (but in no event later than 24 (twenty-four) hours after it becomes available).

b. The Client shall immediately, at its own expense, investigate the Data Incident and take steps to identify, prevent and mitigate the effects of and to remedy any Data Incident. The Client shall not release or publish any filing, communication, notice, press release or report concerning any Data Incident without A-Express Remit Pte Ltd ’s prior written approval.

c. The Client shall promptly (but in no event later than 48 (forty-eight) hours after becoming aware) inform A-Express Remit Pte Ltd if it receives or becomes aware of a Data Complaint and shall not respond to the Data Complaint without A-Express Remit Pte Ltd ’s prior written approval.

8. Deletion or Return of Personal Data and Copies

a. The Client only shall process the Personal Data for the duration of the Outsourcing Agreement.

b. The Client shall ensure that any Personal Data (and all copies) are securely returned to A-Express Remit Pte Ltd or destroyed (at A-Express Remit Pte Ltd 's discretion and direction) in accordance with the instructions given by A-Express Remit Pte Ltd (unless storage is required by Applicable Laws and, if so, the Client shall inform A-Express Remit Pte Ltd of any such requirement) in the following circumstances:

• I. on termination of the Outsourcing Agreement or this DPA
• II. once processing of the Personal Data is no longer necessary for the purposes set out in Appendix D of the Outsourcing Agreement;

c. Following the destruction of the Personal Data in accordance with this Section 8, the Client shall certify to A-Express Remit Pte Ltd that the Personal Data in question has been destroyed in accordance with A-Express Remit Pte Ltd 's instructions.

A-Express Remit Pte Ltd Customer Protection Principles

Effective Date: 25 April, 2024

1. Background

These Principles shall apply where a Client (as defined in the relevant agreement between the Client and A-Express Remit Pte Ltd ) engages A-Express Remit Pte Ltd to facilitate access to End Customers in the UK for the provision of regulated payment services and/or any other services provided by A-Express Remit Pte Ltd from time to time (the "A-Express Remit Pte Ltd Service”).

These Principles are incorporated into and form part of any agreement between A-Express Remit Pte Ltd and the Client, including the A-Express Remit Pte Ltd Platform Agreement or A-Express Remit Pte Ltd Channel Partner Agreement (the “Agreement”). In the event of any conflict between these Principles and the Agreement, these Principles shall prevail.

2. Definitions

Capitalised words not defined in these Principles shall have the same meaning as defined in the Agreement.

“Non-Financial Costs” include things such as unclear or misleading information making it hard for a customer to assess their options, the time and effort it takes to access, assess and act to buy, amend, switch or cancel a product or A-Express Remit Pte Ltd ’s use of customer data where customers knowingly or unknowingly ‘pay’ with their data, privacy or attention.

“Vulnerable Customer” means a customer who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. All customers are at risk of becoming vulnerable and this risk is increased by characteristics of vulnerability related to 4 key drivers; health, life events; resilience and capability. “Vulnerability” and “Vulnerable” shall be interpreted accordingly.

3. Who do these A-Express Remit Pte Ltd Customer Protection Principles apply to?

A-Express Remit Pte Ltd requires all of its Clients to comply with these Principles.

4. The A-Express Remit Pte Ltd Customer Protection Principles

The Client shall, and shall ensure that any of its personnel, subcontractors and any other person acting on the Client’s behalf for provision of the A-Express Remit Pte Ltd to End Customers, ensure that:

a. the Target Market is defined at a sufficiently granular level and periodically reviewed and the relevant A-Express Remit Pte Ltd meets the needs and objectives of those in the Target Market;

b. the Client has in place processes to identify Vulnerable Customers and address customer vulnerability, which shall be provided to A-Express Remit Pte Ltd on request, and must include that the Client will actively encourage customers to share information about their needs and circumstances where relevant;

c. there are at least two channels for an End Customer to engage with or seek support from the Client in regard to the A-Express Remit Pte Ltd, including appropriate channels to provide support in End Customer emergencies or high-priority End Customer issues and any engagement channel used is:

• I. aligned with the nature of the product or service provided;
• II. easy to understand and use by customers in the target market; and
• III. suitable for any customer with a vulnerability;

d. the A-Express Remit Pte Ltd are regularly reviewed by the Client, and in any event no less than once every twelve (12) months;

e. pricing for the A-Express Remit Pte Ltd is fair and any End Customer fees configured by the Client shall be submitted to A-Express Remit Pte Ltd for approval and End Customers are notified in accordance with the applicable A-Express Remit Pte Ltd End Customer terms and conditions;

f. pricing information about the A-Express Remit Pte Ltd is shown at all relevant points during the customer journey and at a sufficiently granular level to allow each End Customer to fully understand the fees and/or charges, particularly where an End Customer is required to confirm acceptance and/or enter into a binding agreement;

g. all pricing about the A-Express Remit Pte Ltd is clearly displayed and disclosed to End Customers in a manner that is consistent with applicable law and regulations to ensure that sufficient information is shared with customers to enable them to efficiently compare the relevant product or service with any other competitors on the market;

h. unless differences in pricing are justifiable and demonstrated:

• I. End Customers using the same A-Express Remit Pte Ltd are paying the same price; and
• II. the Client’s pricing is not significantly higher than the pricing of any other competitors;

i. Non-Financial Costs incurred by customers are proportionate, justified and either better than or in line with industry standards;

j. any information provided about the A-Express Remit Pte Ltd is tailored to, and understood by, End Customers in the Target Market (including those with vulnerable characteristics) and allows such End Customers to make informed decisions;

k. timely, and at least annually, check-ins or reminders are to be sent to End Customers to ensure the A-Express Remit Pte Ltd provided continue to meet their needs and objectives;

l. the effectiveness of communications with End Customers is adequately tracked and recorded; and such records and communications are made available to A-Express Remit Pte Ltd upon request;

m. information on how to switch, complain and/or cancel the relevant A-Express Remit Pte Ltd is easily accessible by End Customers; and

n. The same or reasonably similar levels of support are provided to End Customers throughout the entire lifecycle of the A-Express Remit Pte Ltd.

5. Self-Assessment; Suspension of the A-Express Remit Pte Ltd

a. The Client must perform a self-assessment of its compliance with these Principles prior to going live ("Self-Assessment"). The Client’s ability to launch any program is subject to approval by A-Express Remit Pte Ltd , including demonstrating thrClient’s compliance with these Principles, including but not limited to compliance with paragraphs 4(b), 4(c), 4(f).

b. Upon request by A-Express Remit Pte Ltd , the Client must provide evidence of its compliance with these Principles, including having completed the Self-Assessment, along with providing any supporting documents as reasonably requested by A-Express Remit Pte Ltd .

c. A-Express Remit Pte Ltd reserves the right to suspend Client’s access to the A-Express Remit Pte Ltd Service at any time if it determines that Client is not in compliance with these Principles.

6. Exceptions

Exceptions may be considered by A-Express Remit Pte Ltd , on an End Customer level basis, where the Client requests and can demonstrate the End Customer does not fall into scope of these Principles.

7. Changes to These Principles

We may update or revise these Principles from time to time to keep up with changing laws and regulations and industry best practice. If we make any updates or changes, we will post a revised version of these Principles on this website and update the Effective Date at the top of these Principles. To stay up to date on any changes, check back periodically.

Direct Debit Terms

By agreeing to use direct debit services if made available to you as part of the Services provided by A-Express Remit Pte Ltd , you agree to these Direct Debit Terms and any applicable direct debit network rules. Capitalized terms not otherwise defined in these Direct Debit Terms have the meanings given in the A-Express Remit Pte Ltd Direct Services Agreement or the Terms and Conditions for Business Customers, as applicable.

I. Direct Debit in Countries excluding the United States.

In countries except for the United States, the following terms shall apply to debits via a direct debit network made (a) to your A-Express Remit Pte Ltd Account from your bank account with a third-party financial institution; or (b) from your A-Express Remit Pte Ltd Account to a bank account at a third-party financial institution.

A. Direct Debit Instructions. To use direct debit, you shall provide A-Express Remit Pte Ltd with instructions which authorizes A-Express Remit Pte Ltd and/or our financial partners, using a direct debit network, (i) to receive funds to your A-Express Remit Pte Ltd Account from an external bank account; or (ii) to send funds from your A-Express Remit Pte Ltd Account to an external bank account (“Direct Debit Instructions”). Direct Debit Instructions will be processed in accordance with the rules and timings set forth by the applicable direct debit network and/or our financial partner (as applicable).

B. Bank Account Eligibility and Details. To receive funds via direct debit to your A-Express Remit Pte Ltd Account, your Direct Debit Instructions must include your bank account details at a third-party financial institution, which may include but are not limited to, the name of your bank, the bank account number, routing number for your bank account, and the type of account, for example, checking or savings. You represent and warrant that your bank account is legitimate, open, and in good standing, and you understand that we will require you to verify your bank account details before you can initiate direct debit transactions. You agree to promptly update us if there are any changes to your bank account details.

Your bank account must be able to accept debits denominated in the currency indicated in the Direct Debit Instructions. You confirm that you are the only person required to authorize and you agree to authorize the direct debit from your bank account, such as in the form of a direct debit mandate, or, if applicable, you confirm that you have obtained the authorizations of all required parties to authorize the direct debit in accordance with the rules of the applicable direct debit network.

C. Sufficiency of Funds; Unpaid Direct Debits. It is your responsibility to ensure that there are sufficient funds available in your bank account or A-Express Remit Pte Ltd Account, as applicable, in order to execute on your Direct Debit Instructions. Direct debits will be processed in accordance with the rules and general timings of the applicable direct debit network. The debited amount will be reflected in the debited bank account after a successful debit in accordance with the timing of the applicable direct debit network.

Where you have insufficient funds in your A-Express Remit Pte Ltd Account or where access to your A-Express Remit Pte Ltd Account has been suspended or terminated, we reserve the right to return a Direct Debit Instruction as unpaid in accordance with the rules of the applicable direct debit network rules. In the event that we process a Direct Debit Instruction that you are unable to pay via your A-Express Remit Pte Ltd Account for any reason, you will remain liable to us for the applicable direct debit amounts.

D. Direct Debit Authorization. Each time you choose to fund your A-Express Remit Pte Ltd Account via direct debit, you authorize us and/or our Financial Partner to debit your bank account up to such amount pursuant to your Direct Debit Instruction, including any applicable taxes and fees. Your authorization under these Direct Debit Terms will remain in full force and effect until the later of (i) the closure of your A-Express Remit Pte Ltd Account, or (ii) payment of all fees and other amounts you owe under the applicable services agreement between you and A-Express Remit Pte Ltd .

E. Correction of Errors. In addition to authorizing debits to the bank account, you also authorize us to credit your bank account if necessary to correct an erroneous direct debit in the amount necessary to correct the error. If we make an error when executing a Direct Debit Instruction, we will refund you the amount paid in accordance with applicable direct debit network rules and, if provided for under such rules, the direct debit guarantee. If you receive a refund you are not entitled to, you agree to pay it back A-Express Remit Pte Ltd immediately.

F. Fees Chargeable. If your bank rejects a direct debit transaction or if a direct debit transaction is subsequently disputed by you or your bank for any reason other than as a result of our error, we may charge you additional administration fees to investigate the issue.

G. Revoking Direct Debit. Subject to applicable direct debit network rules, we may revoke your ability to use direct debit at any time for any reason, including if (i) we are unable to debit your bank account or A-Express Remit Pte Ltd Account, as applicable, for any reason; (ii) you have requested a direct debit refund of any amount that has been properly paid, or if determined in our discretion that any errors in the direct debit transaction were caused by you; (iii) you breach these Direct Debit Terms or any applicable services agreement; (iv) we determine your use of direct debit may cause us to breach or incur liabilities under the applicable direct debit network rules or our obligations to our Financial Partners; or (v) requested by a direct debit network.

H. Amending or Cancelling Direct Debit Instructions. You can amend or cancel a Direct Debit Instruction by providing A-Express Remit Pte Ltd with written notice in accordance with the timelines notified to you in the direct debit mandate, or by arranging it through your bank.

I. No Liability. A-Express Remit Pte Ltd is not liable to you for any losses suffered by you due to any Direct Debit Instruction failing to be processed for any reason other than due to our error.

II. ACH Debit Authorization Agreement – United States.

Transactions transmitted through an automated clearing house (“ACH”) shall be subject to the applicable the laws of the United States and ACH Operating Rules (the “ACH Rules”) of the National Automated Clearing House Association (“NACHA”). You agree to comply with and be bound by the ACH Rules. We can reject an ACH transaction if it is not in compliance with the ACH Rules or applicable laws.

A. Entries. To use direct debit, you shall provide A-Express Remit Pte Ltd and/or its Financial Partners with instructions which authorizes A-Express Remit Pte Ltd via the ACH (i) to receive funds to your A-Express Remit Pte Ltd Account from an external bank account; or (ii) to send funds from your A-Express Remit Pte Ltd Account to an external bank account (“Entries”). Entries will be processed in accordance with the rules and timings set forth by the ACH Rules and/or our Financial Partner (as applicable).

B. Bank Account Eligibility and Details. To receive funds via direct debit to your A-Express Remit Pte Ltd Account, your Entries must include all information required by the ACH Rules, including but not limited to your bank account details at a third-party financial institution, which may include but are not limited to, the name of your bank, the bank account number, routing number for your bank account, and the type of account, for example, checking or savings. You represent and warrant that your bank account is legitimate, open, and in good standing. You understand that we will require you to verify your bank account details are accurate and valid before you can initiate direct debit transactions. You agree to promptly update us if there are any changes to your bank account details.

Your bank account must be able to accept debits denominated in the currency indicated in the Entries. You confirm that you are the only person required to authorize and you agree to authorize the direct debit from your bank account in accordance with the ACH Rules. You agree to maintain such authorizations and provide proof of such authorization immediately upon request.

C. Sufficiency of Funds; Unpaid Direct Debits. It is your responsibility to ensure that there are sufficient funds available in your bank account or A-Express Remit Pte Ltd Account, as applicable, in order to execute on your Entry. Direct debits will be processed in accordance with the rules and general timings of the ACH Rules. The debited amount will be reflected in the debited bank account after a successful debit in accordance with the timing of the ACH Rules.

Where you have insufficient funds in your A-Express Remit Pte Ltd Account or where access to your A-Express Remit Pte Ltd Account has been suspended or terminated, we reserve the right to return an Entry as unpaid in accordance with the ACH Rules. In the event that we process an Entry that you are unable to pay via your A-Express Remit Pte Ltd Account for any reason, you will remain liable to us for the applicable direct debit amounts.

D. Direct Debit Authorization. Each time you choose to fund your A-Express Remit Pte Ltd Account via direct debit, you authorize us to debit your bank account up to such amount pursuant to your Entries, including any applicable taxes and fees. Your authorization under these Direct Debit Terms will remain in full force and effect until the later of (i) the closure of your A-Express Remit Pte Ltd Account, or (ii) payment of all fees and other amounts you owe under the applicable services agreement between you and A-Express Remit Pte Ltd .

E. No Notification; Correction of Errors. After you authorize an Entry, you will not receive a separate notice from us of the amount, timing of the debit, or any other information about the debit, before we process and debit your account. To determine if a transfer has been credited to your A-Express Remit Pte Ltd Account, you can review the transactions on your A-Express Remit Pte Ltd Account.

In addition to authorizing debits to the bank account, you also authorize us to credit your bank account if necessary to correct an erroneous direct debit in the amount necessary to correct the error. If we make an error when executing an Entry, we will refund you the amount paid in accordance with. If you receive a refund you are not entitled to, you agree to pay it back A-Express Remit Pte Ltd immediately.

F. Reinitiation of Debit Entries. If we are unable to collect the amount of any debit due to insufficient funds in your bank account, then we may reinitiate that debit in the same amount up to a maxiumum of two (2) additional times in accordance with the ACH Rules.

G. Fees Chargeable. If your bank rejects a direct debit transaction or if a direct debit transaction is subsequently disputed by you or your bank for any reason other than as a result of our error, we may charge you applicable fees.

H. Revoking Direct Debit. We may revoke your ability to use direct debit at any time for any reason, including if (i) we are unable to debit your bank account or A-Express Remit Pte Ltd Account, as applicable, for any reason; (ii) you have requested a direct debit refund of any amount that has been properly paid; (iii) you breach these Direct Debit Terms, the ACH Rules, or any applicable services agreement; (iv) we determine your use of direct debit may cause us to breach or incur liabilities under the ACH Rules or our obligations to our Financial Partners; or (v) requested by NACHA or our bank partners.

I. Amending or Cancelling Entries. You can amend or cancel an Entry by providing A-Express Remit Pte Ltd with written notice in accordance with the timeline provided by the ACH Rules, or by arranging it through your bank.

J. No Liability. A-Express Remit Pte Ltd is not liable to you for any losses suffered by you due to any Direct Debit Instruction failing to be processed for any reason.

Wallet Account Agreement

Last updated: April 22, 2024

IMPORTANT - PLEASE READ CAREFULLY. THIS AGREEMENT CONTAINS AN ARBITRATION PROVISION REQUIRING ALL CLAIMS TO BE RESOLVED BY WAY OF BINDING ARBITRATION.

This agreement (the “Agreement”) contains the terms and conditions governing the wallet account (the “Account”) made available and provided by Column National Association, a nationally chartered depository financial institution and a member of the Federal Deposit Insurance Corporation (“FDIC”) (the “Bank”) in partnership with A-Express Remit Pte Ltd (“A-Express Remit Pte Ltd”), the service provider responsible for performing certain services related to your Account on our behalf. “We,” “our,” and “us” refer to the Bank. “Account Owner” refers to the legal owner of the Account. “You” and “your” means the Account Owner, authorized signer, and any other person authorized to operate your Account. When we say “We may” or “Bank may” do something, that means you authorize us and agree to such action. You may submit a request to open the Account via the A-Express Remit Pte Ltd Platform (as defined in this Agreement). Bank may refuse to process any transaction(s) that it believes may violate the terms of this Agreement or Applicable Law.

By agreeing to these terms, you agree to be bound by Bank’s Privacy Notice and Servicer’s Privacy Notice (available at https://aexpressremit.com/privacy-polic).

1. Definitions

“Applicable Law” means, with respect to either party and as may be amended and in effect from time to time, any applicable laws, statutes, regulations, rulings, orders, and/or guidance, including the Rules.

“Authorized Users” means individuals for whom you may request and assign Login Credentials to access your Account.

“Business Day” means Monday through Friday, excluding federal holidays.

“Eligible Instruction” means any transaction request, payment instruction, or other instruction related to your and your Authorized Users' use of the Account that is submitted in compliance with the Security Procedures through the A-Express Remit Pte Ltd Platform.

“Login Credentials” are the unique username and password that you create for access to your Account through the A-Express Remit Pte Ltd Platform.

“Security Procedures” means the Login Credentials and Servicer’s dual-factor authentication process for use in securely accessing your Account through the A-Express Remit Pte Ltd Platform.

“A-Express Remit Pte Ltd Platform” means Servicer’s software application or application program interface that allows you to access your Account, including via the A-Express Remit Pte Ltd Website.

“A-Express Remit Pte Ltd Website” means Servicer’s website at aexpressremit.com .

“USD” means United States Dollars.

2. General provisions

a. Account Terms & Eligibility

The Account is a stored value account, which is a means of storing funds on a prepaid basis. Your Account balance is representative of USD funds that are maintained at Bank in an omnibus account established in Bank’s name and for your benefit and the benefit of other customers of Servicer (the “Omnibus Account”) and attributable to you. The Account is not a deposit account at Bank. You may access the funds in your Account via the A-Express Remit Pte Ltd Platform.

The Account is available to legal entity commercial customers located in the fifty United States, its territories, and the District of Columbia. No sole proprietorships or foreign businesses are eligible. We may decline to open an Account for you for any reason, or for no reason; this includes if you have had or currently have any other relationships or accounts that you did not maintain in a satisfactory manner. We are not liable for any damages or liabilities resulting from the refusal of Account. You must agree to accept electronic, rather than paper communications and can retrieve account information through the A-Express Remit Pte Ltd Platform.

By requesting the Account, you acknowledge and agree:

• That your use of the Account is for a commercial or business purpose and you will not use the Account for any consumer (personal, family, or household) purpose.
• That if you are an individual executing this Agreement on behalf of, or for the benefit of, any corporation, partnership, or other entity with which you are associated, that you represent and warrant that you have the legal authority to bind such organization to this Agreement.
• That you are of legal age in the jurisdiction where you live and have the legal capacity to enter into this Agreement.

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT. TO HELP THE GOVERNMENT FIGHT THE FUNDING OF TERRORISM AND MONEY LAUNDERING ACTIVITIES, FEDERAL LAW REQUIRES ALL FINANCIAL INSTITUTIONS TO OBTAIN, VERIFY, AND RECORD INFORMATION THAT IDENTIFIES EACH PERSON WHO OPENS AN ACCOUNT. WHAT THIS MEANS FOR YOU: WHEN YOU OPEN AN ACCOUNT, WE WILL ASK FOR INFORMATION THAT WILL ALLOW US TO IDENTIFY YOU, INCLUDING CERTAIN IDENTIFYING DOCUMENTS. WE MAY USE INFORMATION FROM THIRD PARTIES TO HELP US DETERMINE IF WE SHOULD OPEN YOUR ACCOUNT OR KEEP YOUR ACCOUNT OPEN.

b. Electronic documents

To the fullest extent permitted by law, this Agreement, notices and other communications (collectively, “Communications”) from Bank to you regarding your Account(s) and related services with Bank may be provided to you electronically, and you consent and agree to receive those communications in an electronic form. You may print a paper copy of or download any electronic communication and retain it for your records. All Communications in electronic format will be considered to be “in writing,” and to have been received on the day of posting, whether or not you have received or retrieved the Communication. Bank reserves the right to provide Communications in paper format at its discretion. Your consent to receive Communications electronically is valid until you revoke your consent by notifying Bank of your decision to do so by contacting Servicer through the email address above. If you revoke your consent to receive Communications electronically, Bank reserves the right to terminate your right to use the Account and related services, and you accept sole liability resulting from such termination of your Account and related services, to the extent permitted by law. Except as expressly provided otherwise in this Agreement, Bank may mail, send electronically, or otherwise make Communications available to you. If Communications are mailed to you, they will be delivered to you at the postal address on file. If Communications are sent to you electronically, they will be delivered to you at the email address on file or otherwise made available to you, including through the A-Express Remit Pte Ltd Platform. Bank retains printable versions of notices to the extent required by Applicable Law. Regardless of the method in which a Communication is delivered or made available to you, you agree to review Communications promptly.

c. Communication

By providing a phone number, you are expressly consenting to receive Communications at that number from Bank and Bank’s agents, including Servicer. Such Communications may include, but are not limited to, text messages, prerecorded or artificial voice message calls and/or calls made by an automatic telephone dialing system. This express consent applies regardless of the call’s purpose.

d. Telephone monitoring / recording

Bank and Servicer may monitor and/or record telephone calls between you and Bank or Servicer, including to assure the quality of Bank's or Servicer’s Account service team or as required by Applicable Law. You agree that any recorded communications may be admitted as evidence in any litigation, arbitration, controversy, hearing, or other proceeding.

e. Non-Interest Bearing Account

The Account is non-interest bearing.

f. FDIC Insurance

The Omnibus Account, in which the Account is maintained, has been established in a manner to make available pass-through FDIC insurance coverage up to $250,000 per depositor for each insurable capacity in which the deposits are held (e.g., individual account, joint account, etc.) (the “Deposit Limit”). The availability of pass-through FDIC insurance to your Account funds is contingent upon Bank and Servicer having correct and up-to-date information about you, maintaining accurate records, and on determination by the FDIC as receiver, at the time of Bank entering into receivership. Servicer is not an FDIC-insured bank. Information and tools describing how deposit insurance coverage works are provided by the FDIC at www.fdic.gov or by calling 1-877-ASK-FDIC or 1-800-925-4618 (for the hearing impaired).

g. Deposit Sweep Program

When you open an Account, you agree to participate in Bank’s Deposit Sweep Program and agree to be bound by the Deposit Sweep Program terms and conditions (the “Sweep Agreement”). Pursuant to the Sweep Agreement, you agree to appoint Bank as your agent and custodian for the purpose of depositing Account funds into deposit accounts (“Deposit Accounts”) at one or more other depository institutions (each, a “Destination Institution”). Deposits that we place for you in Deposit Accounts will be “deposits,” as defined by federal law, at the Destination Institutions. Subject to the terms and conditions of the Sweep Agreement, your deposits may be eligible for FDIC insurance coverage up to the Deposit Limit for each Deposit Account opened on your behalf.

3. Account ownership and use

a. Purpose

Your Account is subject to the terms and conditions set forth in this Agreement. If you open multiple Accounts with us, this Agreement will cover all of your Accounts with us.

Your Account is offered under this Agreement for the purposes of conducting deposit, withdrawal, and funds transfer transactions in USD. Bank does not offer foreign exchange or currency conversion services to you in connection with the Account and you agree that Bank shall have no responsibility or obligations, and makes no representations, to you regarding the accuracy, determination, or reflection of foreign currency exchange rates or your Account balance in non-USD currency (“FX Rate Determinations”). You agree that Servicer is solely responsible for FX Rate Determinations in connection with the Account and you shall indemnify and hold Bank harmless from any and all liability arising from, or related to, any errors, omissions, complaints, or liability related to Servicer’s FX Rate Determinations.

The individual executing this Agreement must provide us, through the A-Express Remit Pte Ltd Platform, with evidence to our satisfaction of the authority of the individuals who act on behalf of the Account Owner. With regard to any transactions or other matters involving the Account, we may act on the instructions of the person(s) authorized in the resolutions, banking agreement, or certificate of authority to act on behalf of the Account Owner. You agree to notify us in writing of any changes in the person(s) authorized or the form of ownership. If we receive conflicting instructions or a dispute arises as to authorization with regard to the handling of the Account, you agree we may place a hold on the Account until such conflict or dispute is resolved to our satisfaction and we will not be liable for dishonored items as a result of such hold.

You are liable to us for all debit balances in the Account, including, without limitation, overdrafts and account charges, and promise to pay, upon demand, any and all debit balances, all fees and charges, and Bank's reasonable attorneys’ fees and costs and expenses of collection, including, but not limited to, those incurred at trial and on any appeal.

b. Ownership

Your Account shall be owned and titled in the name of one (1) legal entity who shall solely retain the right to direct the deposit or transfer of funds. c. Use Your use of the Account is subject to all applicable rules and customs of any clearinghouse or other association involved in transactions.

4. Security procedures

a. General

You may only access your Account through the A-Express Remit Pte Ltd Platform and subject to the Security Procedures.

b. Login Credentials

You are solely responsible for safeguarding your Login Credentials.

c. Authorized Users

In addition to your own Login Credentials, you may request and assign Login Credentials to a maximum of four (4) Authorized Users. You are solely responsible for causing your Authorized Users to safeguard their Login Credentials and to use them only in accordance with this Agreement, and you are solely responsible for disabling Login Credentials for any individual that is no longer authorized to access the A-Express Remit Pte Ltd Platform and initiate transactions on your Account on your behalf. You, and not Bank, are responsible for any use or misuse of your or your Authorized Users’ Login Credentials, and you must promptly notify Servicer of any confidentiality breach or unauthorized use of your Login Credentials or your Account.

d. Eligible Instructions

Any instruction communicated to Bank will be effective as your instruction, whether or not authorized, and regardless of the actual identity of the sender thereof, if it is an Eligible Instruction accepted by Bank in good faith. Bank is not obligated to act on any instruction other than Eligible Instructions. You are solely responsible for the accuracy and completeness of each Eligible Instruction.

5. Rate and fee schedule

Information on applicable rates and fees in connection with your use of the Account, if any, will be made available through the A-Express Remit Pte Ltd Platform.

6. Deposits

The following terms apply to deposits made to your Account:

a. Deposit Methods

The only method available for depositing funds to your Account is to initiate a funds transfer to the Account.

b. Cash, Check, ATM, or Foreign Currency Deposits

You cannot deposit cash, deposits by check(s), or any form of deposit denominated in a foreign currency into your Account. Any attempt to mail us any deposit consisting of cash, check(s), or foreign currency will be sent back to the address we have on file for you. We are not liable if you do not receive the returned funds. You may not make deposits into your Account at any automated teller machine (“ATM”).

c. Right to Refuse Deposits

We may refuse a deposit, or part of a deposit, at any time and for any reason. We also may refuse a deposit after initially accepting it. We will not be liable to you for refusing a deposit, even if it causes us to decline any transactions you have already made.

d. Deposit Discrepancies

When you make a deposit to your Account, we will credit your Account for the amount of the deposited items. We reserve the right to review the deposit and confirm the amount you deposited but are not required to do so. If after any review we determine that the amount credited to your Account is incorrect, we may adjust your Account for the amount of the discrepancy but reserve the right not to do so if the discrepancy would not be a disadvantage to you.

e. Deposit Liability

Bank is not liable for any deposits not received by Bank.

7. ACH Transactions

The ACH is an electronic funds transfer system allowing money to be transmitted between participating banks. These transfers are governed by the operating rules, guidelines, and guidance in effect from time to time of the National Automated Clearing House Association (“NACHA”) (collectively, the “Rules”). Unless otherwise defined, all capitalized terms used in this section have the meanings assigned in the Rules.

In connection with ACH transactions on your Account, you agree that:

a. Applicable Law

We may accept on your behalf payments to your Account, which have been transmitted through ACH and which are not subject to the Electronic Fund Transfer Act. Your rights and obligations with respect to such payments shall be construed in accordance with and governed by the laws of the State of California, which are applicable to ACH transactions involving your Account. You authorize any ODFI to initiate, pursuant to the Rules, ACH debit entries to your Account.

b. Provisional Credit

If your Account receives funds via ACH, then any credit to the Account for such funds is provisional until Bank receives final settlement through a Federal Reserve Bank or has otherwise received payment as provided under the Uniform Commercial Code, Section 4A-403(a), as adopted by the State of California. If Bank does not receive final settlement or payment of an ACH credit, you are hereby notified and agree that Bank is entitled to recover from the Account or you, without prior notice or demand, the amount of the provisional credit, in whole or in part, and any applicable returned fee (even if it results in an overdraft on your Account) and the party originating the payment will not be considered to have paid you the amount of the credit.

c. Notices

We are not required to give you a separate notice of our receipt of an ACH transfer. To determine if a transfer has been credited to your Account, you can review transactions on your Account via the A-Express Remit Pte Ltd Platform or you can contact Servicer at the contact information above.

8. Withdrawals

The following terms apply to withdrawals from your Account

a. Manner of Withdrawal

You may make withdrawals from your Account by initiating a funds transfer from the Account. Withdrawals and transfers from your Account may be restricted as provided in the Agreement or by Applicable Law.

b. Withdrawal Restrictions / No Overdrafts

We may refuse or restrict withdrawals and transfers from your Account in our sole discretion for any purpose permitted by Applicable Law. You are not permitted to overdraw your Account. If there are available funds to cover some, but not all, of the withdrawals or other debits to your Account on a single business day, we may post the withdrawals or debits in any order we may choose at Bank’s sole discretion.

If there are insufficient funds available in your Account to cover a withdrawal or debit presented against your Account, we may reject such withdrawals in our sole discretion. Even if we choose to pay one or more overdrafts as a courtesy to you, in our sole discretion, we are not obligated to cover any future overdrafts and fees or interest may apply to any overdraft we permit. If your Account balance becomes negative for any reason, you must make a deposit immediately to cover the negative balance. If your Account has a negative balance for thirty (30) calendar days or more we reserve the right to close the Account. In the event you fail to pay the amount of any overdraft and Bank refers your overdrawn Account to an attorney for collection, you agree to pay all reasonable expenses, including, but not limited to, reasonable attorneys’ fees and court costs incurred by Bank as a result of your account being overdrawn.

c. Request for Information

Before permitting a withdrawal or other transaction, we may request that you provide us with additional information or documentation that we deem necessary to confirm your identity or to prevent illegal activity. We may refuse the transaction if you do not comply with our request.

d. Check Withdrawals

You may not make a withdrawal from your Account by cheque.

e. Stop Payment Order

A stop payment request against an item payable from your Account will be effective if we receive the order at such time and in such manner as to afford us a reasonable opportunity to act upon the order. A stop payment order against an item payable from your Account is effective for six (6) months, but it lapses after fourteen (14) calendar days if the original order was oral and was not confirmed in writing within that period. A stop payment order against an item payable from your Account may be renewed for additional six (6) month periods if renewed during a period within which the stop payment order is effective. All stop payment order requests will require you to provide the date, the amount, and the number of the item or authorization, together with the name of the payee. If you give us incomplete or incorrect information, Bank and Servicer will not be liable for failing to stop payment on the item or authorization. Our acceptance of a stop payment order will not constitute a representation that the item or authorization has not already been paid or that we have a reasonable opportunity to act upon the order. You may not request us to stop payment if we have otherwise become accountable for the item or authorization. In addition, you may not stop payment on payment methods governed by a separate agreement. Further you may not stop payment on an item or authorization after acceptance of the same by us.

9. Funds Availability

a. Transaction posting order

Bank reserves the right to decide the order of the items Bank will pay and which items will be returned (if any). Bank’s posting order may not be the same as the order in which you conducted a transaction and could result in overdraft fees if you do not have available funds at the time the item is paid. Generally, Bank posts the following transaction types (to the extent applicable to your Account) after the close of each Business Day in the following order:

• Deposits and credits Bank receives before the close of each Business Day will be posted before any withdrawals.
• Your debits and withdrawals will be posted in date/time order, based on the date and time associated with each transaction.

b. Funds Availability

Bank makes funds available according to the type of deposit and when the funds are applied or credited to your Account and in accordance with Applicable Law. Some types of deposits may not be available for immediate use. When Bank delays the availability of funds or places a hold on a deposit made to your Account, you may not withdraw those funds, and Bank will not use them to pay any debits. Bank has the right to refuse any deposit. The length of the delay in the availability of funds varies depending on the type of deposit. If final payment is not received on any item you have deposited into your Account, you agree to pay Bank the amount of the returned item if such item has already been credited to your Account. You may only deposit funds that are immediately available.

Bank receives deposits each Business Day. If you make a deposit by electronic payment before 5pm Pacific Time on a Business Day, we will consider that day to be the day of your deposit. However, if you make a deposit after 5pm Pacific Time or on a non-Business Day, we will consider that the deposit was made on the next Business Day.

Deposits made by electronic payment, excluding those by ACH debit transactions, will be made available to you the day that the deposit is received but no later than the first Business Day after the day that the deposit is made.

Deposits made by any other permissible deposit method, will be made available no later than the second Business Day after the day that the deposit is made.

We reserve the right, subject to Applicable Law, to hold funds pending settlement or for such period of time as we deem necessary, in our sole discretion, to cover items which may be returned unpaid.

c. Special rules for new accounts

Accounts open less than thirty (30) days may be limited in functionality. Funds credited to your Account may be made available provisionally or delayed for a reasonable amount of time in accordance with Applicable Law. Certain transfer limits may be lower during this time for certain features and services, or as allowed under Applicable Law or regulation.

10. Funds transfers

a. Initiating funds transfers

You may only initiate funds transfers (through any method permitted for your Account) by submitting Eligible Instructions and you authorize Bank to honor, accept, execute, and initiate any Eligible Instructions it receives. You acknowledge and agree that the submission of Eligible Instructions represents a commercially reasonable method of providing security against unauthorized transactions. Bank has no obligation, and shall not be liable or responsible for its refusal to act on any instruction or transaction request that is not an Eligible Instruction. You acknowledge that the purpose of transacting through Eligible Instructions is to verify authenticity and not to detect an error in the transmission or content of a transaction or instruction. You and Bank have not agreed upon any procedures for the detection of errors and you are solely responsible for any errors not caused by Bank.

Bank may screen and reject any funds transfer request in good faith, including because Bank believes that the funds transfer, if executed, would not comply with Applicable Law or would exceed the amount of funds in your Account or any established limits on your Account. Bank is not liable for failing to complete a transaction from your Account on-time or in the correct amount.

b. Limitation on amount of transactions

Bank may impose and adjust transaction limits on your Account, in its sole discretion. Applicable transaction limits will be disclosed to you through the A-Express Remit Pte Ltd Platform.

c. Accuracy of information

When you originate any funds transfer request through any method made available to you by Bank (including wire or automated clearinghouse transfers), you are responsible for providing accurate payment information. Bank and any other financial institution involved in the transaction may rely on all identifying numbers (e.g., account and routing numbers) you provide to make payment. Bank may rely on the number even if it identifies a financial institution, person or account other than the one named. Bank will process the funds transfer request based solely on the information you provide to us and expressly disclaims any obligation to review any such request for errors or inconsistent or duplicative information. It is your obligation to verify the information you provide to us including, but not limited to, the identity and relationship of the receiving party, account number, and routing number. Bank is not responsible for any loss or damage you incur from your request for a funds transfer.

d. Bank's liability for failure to complete transactions

You acknowledge that you are responsible for reconciling all transactions and balances against those maintained by Bank.

e. Wire transfers

If enabled by Bank for your Account, you may be able to send or receive a wire transfer request. You acknowledge that Bank may, in its sole discretion, clear and settle any payment order arising from a wire transfer request through one or more intermediary banks, including through the use of correspondent accounts held at such banks. You agree to reimburse Bank for all costs, fees, and other expenses incurred by Bank in transmitting any payment order through any such intermediaries. You further agree to indemnify Bank and hold it harmless for all of Bank’s liabilities, including any claims, and other obligations that it may have to such intermediaries. You acknowledge that any payment orders governed by this Agreement may be governed by the rules of any funds transfer system through which any payment order is made, including the Fedwire Funds Service, National Settlement Service, any other Federal Reserve payment system, NACHA, the Clearing House Interbank Payments System (“CHIPS”), the Society for Worldwide Interbank Financial Telecommunications (“S.W.I.F.T.”), or any other funds transfer system (each and collectively a “Funds Transfer System”). By submitting a wire transfer request, you agree to and accept any rule of such Funds Transfer System, to the extent applicable to any transaction. The beneficiary’s bank must be a member of the Federal Reserve System, CHIPS, or S.W.I.F.T., or ultimately have a correspondent bank that is a member or participant of the Federal Reserve System, CHIPS, or S.W.I.F.T., as applicable to the transfer request.

Please be advised that wire transfer requests may not be recalled or amended once they have been sent to Bank. Wire transfer requests will only be accepted and processed if you have sufficient and available funds in your Account at the time the request is received and processed. Bank reserves the right to reject or cancel any wire transfer in our sole discretion and will not be held liable for any losses or damages that may arise due to our right to cancel or reject the wire transfer.

f. ACH transactions

If enabled by Bank for your Account, you may be able to initiate funds transfers through automated clearinghouse (“ACH”) transactions, pursuant to Bank’s terms and conditions for ACH Origination (See Exhibit 1).

g. Your liability for unauthorized transfers

You agree to be bound by all Eligible Instructions accepted by Bank in good faith and will be liable for all losses, expenses, and liability, resulting from, related to, or caused by Bank's processing or execution of an Eligible Instruction, regardless of whether such losses, expenses, or liability occur due to unauthorized, incorrect, incomplete, or fraudulent transactions. You acknowledge and agree that because this is a commercial-purpose account, the Electronic Funds Transfer Act and any similar protections available under consumer financial protection laws do not apply to your Account. Contact Servicer immediately if you believe your Login Credentials have been compromised or if you believe someone has transferred or may transfer money from your Account without your permission. You are responsible for monitoring and reconciling all activity in your Account. You must report any suspected unauthorized transaction to us immediately.

11. Customer Service Contact Information & Notice

Except as otherwise provided in this Agreement, in the event you must contact Bank or send Bank any notice required by this Agreement, you must do so by contacting Servicer. Servicer’s contact information is set forth below:

Servicer: A-Express Remit Pte Ltd

Mailing address: 304, orchard Road Lucky plaza #02-28 Singapore 238863

Support email: contact@aexpressremit.com

Except as otherwise expressly provided in this Agreement, Bank is not required to act upon any communication, notice, or instruction received from you or any other person or to provide any notice or advice to you or any other person with respect to any matter. Not with standing the foregoing, if Bank acts upon any communication, notice, or instruction, then Bank has a reasonable time in which to act, after actual receipt of the notice or instruction.

12. Miscellaneous provisions

a. No waiver

Bank does not waive its rights by delaying or failing to exercise them at any time.

b. Illegal transactions, account restrictions, account closures

You may not use your Account for any illegal or unlawful transaction, and we may decline to authorize any transaction that we believe poses an undue risk of illegality or unlawfulness. We reserve the right to place a hold on your Account if we suspect irregular, fraudulent, suspicious, unlawful or otherwise unauthorized activity. We may attempt to notify you of such a hold but are not required to provide notice prior to placing the hold or thereafter. We also may attempt to contact you to obtain additional information regarding the activity in your Account. We reserve the right to maintain any hold and restrict access to the Account until we receive the requested information. You agree that we may maintain such hold until all issues, including claims against you or us, concerning the funds held in your Account have been resolved fully to our sole satisfaction. We also reserve the right to reject any incoming credit transaction that we suspect is involved in fraudulent or suspicious activity. Bank will not be held liable for any loss you incur if your Account is restricted or subject to a hold. Notwithstanding the foregoing, we may collect on any debt arising out of any illegal or unlawful transaction, to the extent permissible under Applicable Law.

c. Unlawful internet gambling transactions prohibited

You certify that you do not engage in, and during the life of this Agreement will not engage in, any activity or business that is unlawful under the Unlawful Internet Gambling Enforcement Act of 2006, 31 USC 5361, et seq., (the “UIGEA”). You may not use your Account or any other service we offer to receive, transfer, or credit funds, instruments or proceeds that arise out of a business that is unlawful under the UIGEA. You agree that if anyone asks us to process a transaction that we believe is restricted under the UIGEA, we may block the transaction and take any other action we deem to be reasonable under the UIGEA and this Agreement. You may not use your Account for online gambling or any illegal transactions. Bank may refuse to process any transaction that it believes may violate the terms of this Agreement or Applicable Law. You acknowledge and agree that Bank has no obligation to monitor, to review or to evaluate the legality of your transactions. To the fullest extent permitted by law, you agree to pay for any transaction that you authorized, even if that transaction is determined to be illegal.

d. Holds

We may place administrative holds on the funds in your Account (refuse payment or withdrawal of the funds) if they become subject to a claim adverse to (A) your own interest; (B) others claiming an interest as survivors or beneficiaries of your Account; or (C) a claim arising by operation of law. The hold may be placed for such period of time as we believe reasonably necessary to allow a legal proceeding to determine the merits of the claim or until we receive evidence satisfactory to us that the dispute has been resolved. We will not be liable for any items that are dishonored as a consequence of placing a hold on funds in your Account for these reasons.

e. Right to set off

If your Account balance becomes and remains negative or you are determined to owe Bank any amounts for any reason, Bank can use the funds in your Account or any other account that you own at the Bank to repay any amount owed without further notice to or demand on you. This means Bank has the right to set off any liability, direct or contingent, past, present or future that you owe against any account you have with Bank. Further, you grant Bank a lien on and security interest in the funds on deposit in each of your Account(s) as security for the entirety of your liabilities and obligations to Bank, now or in the future.

f. Backup withholdings

You acknowledge that this Account cannot be opened if you are currently subject to backup tax withholding.

g. Legal processes affecting accounts

If legal action such as a garnishment, levy or other state or federal legal process (“Legal Process”) is brought against your Account, Bank may refuse to permit (or may limit) withdrawals or transfers from your Account until the Legal Process is satisfied or dismissed. Regardless of the terms of such garnishment, levy or other state or federal process, Bank has first claim to any and all funds in your Account for your liability under this Agreement. Bank will not contest on your behalf any such Legal Process and may take action to comply with such Legal Process as Bank determines to be appropriate in the circumstances without liability to you, even if any funds Bank may be required to pay out leaves insufficient funds to pay a transaction that you have authorized. Payment is made after satisfying any fees, charges or other debts owed to Bank. You agree that you are responsible for any expenses, including legal expenses and fees Bank incurs due to any Legal Process on your Account. Bank may charge these expenses to your Account. You will indemnify Bank for any losses if it does this.

h. Account inactivity and escheatment

An Account that is inactive for eighteen (18) months may be considered dormant. Each state has varying laws as to when an account is subject to escheatment and Bank may be required to send the balance in your Account to the state of your last known address. You understand that if your Account is inactive (dormant), we may close your Account. We reserve the right to refuse to return any unused balance amount less than $1.00. You agree that we are relieved of all responsibility if your Account balance is escheated in accordance with applicable state law. Your Account will become inactive unless you have conducted activity in your Account, such as depositing or withdrawing funds.

i. Confidentiality

Bank may disclose information to third parties about your Account or the transactions:

• To Servicer, as necessary to provide the services to you.
• Where it is necessary for completing transfers.
• In order to verify the existence and condition of your Account for a third party, such as a credit bureau or merchant.
• In order to comply with government agency, court order, or other legal or administrative reporting requirements.
• If you consent by giving Bank your written permission.
• To Bank's employees, auditors, affiliates, service providers, or attorneys as needed.
• Otherwise as necessary to fulfill Bank or Servicer's obligations under this Agreement.

j. Account termination, cancellation, or amendment

Bank may amend or change the terms and conditions of this Agreement at any time by posting the amended Agreement on the A-Express Remit Pte Ltd Platform, and any such amendment shall be effective upon such posting to the A-Express Remit Pte Ltd Platform, unless additional advanced notice is required under Applicable Law. You will be notified of any amendment(s) in the manner provided by Applicable Law prior to the effective date of the amendment(s). However, if the amendment(s) is made for security purposes or your benefit, Bank may implement it without prior notice. Bank may cancel or suspend your Account or this Agreement at any time. You may cancel this Agreement by contacting Servicer to close your Account. Your cancellation of this Agreement will not affect any of Bank's rights or your obligations arising under this Agreement prior to cancellation.

If your Account is cancelled, closed or terminated for any reason, we will return the remaining balances to you via ACH transfer to one of your external accounts on Bank's records or via paper check to the address on file. For security purposes, you may be required to supply identification, external account, and address verification documentation prior to issuing an ACH refund or refund check. Bank reserves the right to refuse to return any unused balance amount less than $1.00.

k. No warranty of availability or uninterrupted use

From time to time, services related to the Account may be inoperative. You agree that, except as required by Applicable Law, Bank will not be responsible for temporary interruptions in service due to maintenance, website changes, or failures, nor shall Bank be liable for extended interruptions due to failures beyond Bank's control, including, but not limited, to the failure of interconnecting and operating systems, computer viruses, forces of nature, labor disputes and armed conflicts.

l. Bank's relationship with you

This Agreement and the deposit relationship do not create a fiduciary or agency relationship with Bank. The relationship between Bank and you is that of creditor and debtor and under no circumstances will Bank owe you any fiduciary or other duty.

m. Systems and software

We shall not be responsible to you for any loss or damages suffered by you because of the failure of systems and software used by you to interface with our systems or systems and software utilized by you to initiate or process banking transactions whether such transactions are initiated or processed directly with our systems or through a third-party service provider. You acknowledge that you are solely responsible for the adequacy of systems and software utilized by you to process banking transactions and the ability of such systems and software to do so accurately.

n. No warranty regarding goods or services

Bank is not responsible for the quality, safety, legality, or any other aspect of any goods or services you purchase using your Account.

o. Survival

All provisions of this Agreement shall survive the termination of this Agreement or closure of your Account by either party for actions arising in connection with this Agreement or your Account(s).

p. Governing law

This Agreement shall be governed by federal law and, to the extent not superseded by federal law, the laws of the State of California. You understand that we must comply with applicable laws, regulations, and rules, as well as the operating rules of any applicable Funds Transfer System. You agree that if there is any inconsistency between the terms of the Agreement and any applicable law, regulation, or rule, the terms of the Agreement will prevail to the extent any such law, regulation, or rule may be modified by agreement. If otherwise, Applicable Law shall govern but only to the extent of such inconsistency.

q. Severability

If any provision of this Agreement shall be determined to be invalid or unenforceable under any rule, law, or regulation of any governmental agency, local, state, or federal, the validity or enforceability of any other provision of this Agreement (or any prior agreement you may have had with us) shall not be affected.

r. Assignability

The Account established under this Agreement are not assignable or transferable except with our consent. We must approve any pledge of the Account and any such pledge remains subject to any right we have under the Agreement and applicable state and federal law. If ownership is proposed to be transferred, we may require the Account be closed and a new account opened in the name of the transferee or pledgee.

13. Limitation of liability

Except as required by applicable law, Bank shall have no liability to you if Bank is unable to complete a transaction for any reason beyond Bank's control. Except as otherwise expressly provided in this Agreement or as otherwise required by Applicable Law, Bank, Bank's affiliates, Servicer, and the parties with whom Bank contracts in order to offer your Account and related services are neither responsible nor liable for any indirect, incidental, consequential, special, exemplary, or punitive damages arising out of or relating in any way to your Account, any products or services purchased using Account, or this Agreement (as well as any related or prior agreement you may have had with Bank). You waive all claims and any right to recover from Bank on any claim of negligence, breach of any implied covenant, breach of fiduciary duty, commercial unreasonableness, loss of business, or loss of business opportunity or advantage. Except as otherwise required by Applicable Law, Bank’s liability for any act or omission will not exceed your direct losses.

14. Indemnification

You agree to defend, indemnify, and hold harmless Bank and its subsidiaries, affiliated companies, employees, contractors, officers, and directors against any and all claims, suits, damages, costs, lawsuits, fines, penalties, liabilities, and expenses (including, without limitation, reasonable attorneys' fees) that arise from your use of the Account, your acts or omissions, or your violation of this Agreement, Applicable Law, or any third-party rights or your fraud or willful misconduct. Bank reserves the right to assume the exclusive defense and control of any matter subject to indemnification by you, in which event you will cooperate in asserting any available defenses.

15. Dispute resolution

YOU AGREE THAT, BY ENTERING INTO THIS AGREEMENT, YOU AND BANK ARE EACH WAIVING THE RIGHT TO A TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION, COLLECTIVE ACTION, PRIVATE ATTORNEY GENERAL ACTION, OR OTHER REPRESENTATIVE PROCEEDING OF ANY KIND. YOU CAN OPT OUT OF THIS CLASS ACTION WAIVER BY CONTACTING BANK AT 304, orchard Road Lucky plaza #02-28 Singapore 238863 WITHIN THIRTY (30) DAYS AFTER YOU FIRST ACCEPT THE TERMS OF THIS AGREEMENT, STATING THAT YOU (INCLUDE YOUR FIRST AND LAST NAME) DECLINE THIS CLASS ACTION WAIVER.

EXCEPT FOR DISPUTES THAT QUALIFY FOR SMALL CLAIMS COURT, ALL DISPUTES ARISING OUT OF OR RELATED TO THIS AGREEMENT OR ANY ASPECT OF THE RELATIONSHIP BETWEEN YOU AND BANK, WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE), STATUTE, FRAUD, MISREPRESENTATION, OR ANY OTHER LEGAL THEORY, WILL BE RESOLVED THROUGH FINAL AND BINDING ARBITRATION BEFORE A NEUTRAL ARBITRATOR INSTEAD OF IN A COURT BY A JUDGE OR JURY AND YOU AGREE THAT BANK AND YOU ARE EACH WAIVING THE RIGHT TO TRIAL BY A JURY. YOU AGREE THAT ANY ARBITRATION UNDER THIS AGREEMENT WILL TAKE PLACE ON AN INDIVIDUAL BASIS; CLASS ARBITRATIONS AND CLASS ACTIONS ARE NOT PERMITTED AND YOU ARE AGREEING TO GIVE UP THE ABILITY TO PARTICIPATE IN A CLASS ACTION.

The arbitration will be administered by JAMS under its Comprehensive Arbitration Rules and Procedures (“Comprehensive Rules”). The Comprehensive Rules are available online at http://www.jamsadr.com/rulescomprehensive-arbitration/. Any in-person appearances will be held at a location which is reasonably convenient to both Parties with due consideration of their ability to travel and other pertinent circumstances. If the Parties are unable to agree on a location, such determination should be made by JAMS or by the arbitrator. The arbitrator's decision will follow this Agreement and will be final and binding. The arbitrator will have authority to award temporary, interim, or permanent injunctive relief or relief providing for specific performance of this Agreement, but only to the extent necessary to provide relief warranted by the individual claim before the arbitrator. To reduce the time and expense of the arbitration, the arbitrator will not provide a statement of reasons for his or her award unless requested to do so by all Parties. The award rendered by the arbitrator may be confirmed and enforced in any court having jurisdiction thereof. An arbitration award and any judgment confirming it apply only to that specific case; it cannot be used in any other case except to enforce the award itself. Notwithstanding any of the foregoing, nothing in this Agreement will preclude you from bringing issues to the attention of federal, state, or local agencies and, if the law allows, they can seek relief against Bank for you.

This Dispute Resolution Provision will survive termination of your Account, this Agreement and any bankruptcy by you or us. If any portion of this Dispute Resolution Provision is deemed invalid or unenforceable under any principle or provision of law or equity it will not invalidate the remaining portions of this Dispute Resolution Provision, this Agreement or any prior agreement you may have had with us, each of which will be enforceable regardless of such invalidity.

IF YOU DO NOT AGREE TO THE TERMS OF THIS AGREEMENT, DO NOT ACTIVATE OR USE THE ACCOUNT.

EXHIBIT 1

ACH ORIGINATION ADDENDUM

This ACH Origination Addendum (“ACH Addendum”) establishes the terms and conditions under which Column National Association (“Bank”) acting as Originating Depository Financial Institution (“ODFI”) agrees to process automated clearinghouse (“ACH”) transactions you originate as Originator (the “ACH Services”). This ACH Addendum supplements, amends, and forms a part of your Wallet Account Agreement with Bank (the “Agreement”). If there is any conflict between this ACH Addendum and the Agreement, this ACH Addendum shall govern with regard to the ACH Services, but only to the extent of such inconsistency. By using the ACH Services, you agree that you are bound by and will comply with the terms and conditions of this ACH Addendum, as well as the Agreement, Applicable Law, and any other terms, conditions, or agreements pertaining to Bank’s provision of the ACH Services to you.

1. Definitions

Unless otherwise defined in this ACH Addendum, all capitalized terms have the meanings assigned in the Agreement and/or the Rules.

“ACH Security Framework Rule” means the security requirements set forth in Section 1.6 of the Rules.

“Admin Users” means a User that you have authorized to activate and deactivate other Users and exercise administrative privileges on your Account through the A-Express Remit Pte Ltd Platform.

“Cut-Off Time” means 5pm Pacific Time on a Business Day.

“Login Credentials” means each username and password (or other credentials) used by any User to access your Account through the A-Express Remit Pte Ltd Platform.

“Losses” means any and all causes of action, charges, suits, assessments, damages, claims, demands, losses, liabilities, fines (including fines levied in connection with Rules violations), unauthorized Return Entry fees and expenses (including attorney’s fees and court costs).

“NACHA” means the National Automated Clearinghouse Association.

“Person” means any individual or legal entity, including a general partnership, limited partnership, corporation, company, limited liability company, joint venture, trust, or unincorporated organization.

“Protected Information” means the non-public personal information, including financial information, of a natural person used to create, or contained within, an Entry and any related Addenda Record, as set forth in the Rules.

“Regulatory Authority” means any federal, state, or local regulatory or other government agency or authority with jurisdiction over a party.

“Rules” means the rules, regulations, guidelines, advisories, policies, or instructions of NACHA in effect from time to time, including the operating rules thereof.

“Settlement Date” with respect to a credit or debit Entry, the date an exchange of funds with respect to an Entry is reflected on the books of the applicable Federal Reserve Bank(s), and with respect to a Non-Monetary Entry, the date specified in the

“Settlement Date” field of the Entry.

2. Customer Obligations

In using the ACH Services, you will comply, and cause your employees, officers, directors, and agents, including your Authorized Users, to comply with (1) Applicable Law, (2) the Rules and any related advisories, policies, or instructions issued by NACHA, Bank, or any regulatory authority; and (3) the Agreement and this ACH Addendum. You adopt and make to Bank all representations and warranties of an Originator under the Rules, including that you will not initiate Entries in violation of Applicable Law. You acknowledge that you have access to a copy of the Rules, have reviewed your obligations thereunder, and have subscribed to receive revisions to the Rules directly from NACHA.

You are responsible for all tariffs, duties, or taxes that may be imposed by a Regulatory Authority in connection with your use of the ACH Services.

You agree to provide Bank such information as Bank may reasonably request in connection with the underwriting process. In addition, you agree to provide such other information as Bank may reasonably request in connection with your use of the ACH Services.

You acknowledge and agree you are not authorized to act as a Third-Party Sender pursuant to this ACH Addendum not to submit for processing any Entries for which you are not the Originator.

Entries you initiate shall be in accordance with the procedures and specifications set forth by Bank in the Agreement, this ACH Addendum, and the A-Express Remit Pte Ltd Platform.

Entries accepted and processed by Bank will be reflected in the transactions on your Account viewable via the A-Express Remit Pte Ltd Platform. You shall review the transactions on your Account on the A-Express Remit Pte Ltd Platform and notify Servicer of any discrepancies or errors, including unauthorized Entries, as set forth in the Agreement.

You agree not to transmit an Entry to Bank or to otherwise use or attempt to use the ACH Services to: (i) engage in any illegal purpose, transaction, or activity or to violate any Applicable Law, (ii) breach any contract or agreement by which you are bound; (iii) engage in any internet or online gambling transaction, whether or not gambling is legal in any applicable jurisdiction; or (iv) engage in any transaction or activity that is not specifically authorized and permitted by this Addendum. You acknowledge and agree that Bank has no obligation to monitor your use of the ACH Services for transactions and activities that are impermissible or prohibited under the terms of this ACH Addendum; provided, however, that Bank reserves the right to decline to execute any transaction or activity that Bank believes violates the terms of this ACH Addendum.

3. Processing

You authorize Bank to and agree that Bank shall process Entries, including debit and credit Entries, received in accordance with this ACH Addendum, transmit such Entries as an ODFI to the Federal Reserve Bank as the ACH Operator, and settle such Entries as provided in the Rules.

Bank shall transmit such Entries to the ACH Operator prior to the effective entry date shown in the Entries, provided that: (i) such Entries are received by Bank on a Business Day before Bank’s daily Cut-Off Time; (ii) the effective entry date is at least two (2) days after such Business Day; and (iii) the ACH Operator is open for business on the effective entry date. Any Entry or File initiated after the Cut-Off Times will be deemed made on the next Business Day.

The ACH Services are subject to the Bank’s daily Cut-Off-Time. Any Entry or File initiated after the Cut-Off Times will be deemed made on the next Business Day. Entries shall be deemed received by Bank at such times as the applicable requirements have been met with respect to such Entries. If you fail to comply with any Bank procedure or requirement set forth by Bank in the Agreement, this ACH Addendum, and the A-Express Remit Pte Ltd Platform, Bank may, but shall not be required to, process such Entries.

4. Permissible Entry Types

You may elect to originate a Same Day Entry, which may trigger fees for same day processing.

An Entry received for credit to an account maintained with Bank (an “On-Us Entry”) shall not be transmitted to the ACH Operator but shall be credited or debited to the Receiver’s account in the amount of such Entry on the effective entry date contained in such Entry. An On-Us Entry may not be processed through the ACH Network, but Client is deemed to make all representations and warranties as if the Entry were not an On-Us Entry.

You may only initiate Entries for Standard Entry Class (“SEC”) Codes that have been approved by Bank in writing. Approved SEC Codes include CCD and PPD but may be restricted or amended by Bank in its sole discretion.

You will comply with account validation requirements under the Rules for Debit WEB Entries.

You are not permitted to originate International ACH Transactions (“IAT”) and Bank shall have no obligation to act on IAT Entries or Entries Bank determines should have been coded as IAT Entries.

5. Accuracy of Information and Bank Reliance

In using the ACH Services, you are responsible for providing accurate information. Bank, Servicer, and any other financial institution involved in an ACH Services transaction is entitled to rely without confirmation on any information provided by you, included in an Entry, request, or on any written notice or other written communication believed by it in good faith to be genuine and authorized by you. Bank may rely on a number you provide even if it identifies a financial institution, Person, or account other than the one named. Bank will process your Entries, requests, and any other communications based solely on the information you provide to us and Bank expressly disclaims any obligation to review any such request, Entry, or communication for errors or inconsistent or duplicative information. It is your obligation to verify the information you provide to us including, but not limited to, the identity and relationship of the receiving party, account number, and routing number.

6. Returned Entries

Servicer shall notify you of a Returned Entry within one (1) Business Day of the receipt of such Returned Entry from the ACH Operator. Bank shall have no obligation to retransmit a Returned Entry.

Servicer shall notify you of any Notification of Changes (“NOC”), including refused NOCs or corrected NOCs received by Bank no later than two (2) Business Days after receipt. You must respond to NOCs by investigating incorrect data and making corrections within six (6) Business Days of receipt of the NOC information or prior to initiating another Entry to the Receiver’s account, whichever is later. You shall indemnify and hold harmless Bank against any Losses incurred by Bank, Servicer, or any other Person arising out of your failure to make such change as required by this ACH Addendum or Applicable Law. This indemnification obligation will survive any termination of the ACH Services.

If an Entry is returned as unauthorized or authorization is revoked, you will contact the necessary parties and resolve any dispute. During this process, you may ask Bank via Servicer to request from the RDFI a copy of the “Written Statement of Unauthorized Debit.” Bank will attempt to obtain the form and deliver it to you. You agree not to re-originate any transaction returned as unauthorized or as authorization revoked unless and until the Receiver reauthorizes the Entry or Entry stream. In the event the rate of unauthorized transactions exceeds the permissible limit based on the calculations noted in the Rules, you will share the data requested by Bank based on the Rules and will immediately begin the process of bringing the rate below that threshold.

7. Rejection, Correction of Entries

Bank may reject any Entry for any reason whatsoever. Servicer shall notify you of such rejection no later than the Business Day such Entry would otherwise have been transmitted by Bank to the ACH Operator or, in the case of an On-Us Entry, its effective entry date. Bank shall have no responsibility or liability to you in connection with the rejection of any Entry or for failing to provide notice of a rejection. Bank is not obligated to pay you interest for the period before you receive the notice of rejection. If an Entry is rejected for any reason, it is your responsibility to correct the Entry that you intend to resubmit. If the amount of any Entry or Entries received by Bank does not agree with any corresponding transmittal information provided by you pursuant to this Addendum, Bank may in its sole discretion reject or correct the Entry or Entries. If Bank determines in its sole discretion to correct an Entry, you shall be deemed for purposes of this Addendum to have delivered the Entry to Bank as it has been corrected by Bank pursuant to this section.

8. Cancellation, Reversal, or Amendment by You

You shall have no right to cancel, reverse, or amend any Entry after its receipt by us. However, if a request for cancellation, reversal, or amendment is received by Bank prior to transmitting the Entry to the ACH Operator, Bank may use reasonable efforts to act on such a request but shall have no liability if such request is not or cannot be effected. Your request must include the reason for the cancellation, reversal, or amendment. You agree to indemnify Bank in connection with any such request from you. Obligations under this section will survive the termination of this Service.

9. Authorization

Prior to submitting an Entry, you will obtain written authorization as required by the Rules and Applicable Law from the Receiver. The authorization must have clear and understandable terms and inform any consumer Receiver of the method and terms for revoking such authorization. The authorization must identify the Receiver’s account and the RDFI where such account is maintained. With respect to any Entries involving consumer accounts, you shall comply with any applicable requirements of the federal Electronic Funds Transfer Act and its implementing rules under Regulation E.

10. Credit Entries

Credit Entries you initiate may be transmitted through the ACH system. Your rights and obligations as the Originator of such Entries are governed by and construed in accordance with the laws of the State of California. Any credit given by the RDFI to the Receiver of your credit Entry is provisional until the RDFI has received final settlement through a Federal Reserve Bank or otherwise has received payment as provided for in Section 4A-403(a) of Article 4A of the UCC. If the RDFI does not receive payment for the Entry, the RDFI is entitled to a refund from the Receiver in the amount of the credit to the Receiver’s account and you will not be considered to have paid the amount of the credit Entry to the Receiver.

11. Provisional Credit

Bank shall not be required to pay you the amount of any Debit Entry or credit reversal before Bank receives final settlement for such Entry. Any payment by Bank as credit to your Account prior to final settlement shall be provisional and Bank shall have the right, without prior notice or demand by Bank, to immediate repayment by you of the amount of such credit upon Bank’s receipt of notice that final settlement has not occurred. In addition, Bank shall have the right, without notice or demand, to immediate repayment by you of the amount of any Debit Entry returned or rejected and any adjustment Entry for which Bank is required to settle under the Rules and for which you have previously received credit, at the time Bank receives such rejection, return, or adjustment Entry, as applicable, or notice thereof.

12. Bank’s Right to Debit.

Bank may, without prior notice or demand, obtain payment of any amount due and payable to it under this Addendum by debiting your Account, even if such debit results in an overdraft on your Account.

With respect to a Debit Entry that is returned, reversed, or adjusted for any reason by the RDFI, you specifically authorize Bank to debit your Account for such Debit Entry, plus any related costs incurred by Bank, or take such other action as would be appropriate under the circumstances. Bank will notify you accordingly. If your Account does not have adequate funds to cover return, reversal, or adjustment of such Debit Entry, then Bank may either (i) overdraw your Account or (ii) debit your Collateral Account to cover the return, reversal, or adjustment of such Entry.

If Bank releases funds after your death and is required to pay tax or reclamation claims to a government agency as a result, your estate is responsible for reimbursing Bank for an amount equal to the cost of such claims.

13. Notice

Except as otherwise expressly provided herein, Bank shall not be required to act upon any notice or instruction received from you or any other Person, or to provide any notice or advice to you or any other Person with respect to any matter.

14. Security Procedures.

You may only submit ACH Entries through the Security Procedures defined in the Agreement. You agree to comply with the Security Procedures and you acknowledge that such security procedures are acceptable and a commercially reasonable method of providing security against unauthorized Entries. Bank reserves the right to change the Security Procedures in its sole discretion. You acknowledge that the purpose of the Security Procedures is to verify authenticity and not to detect an error in the transmission or content of an Entry. Bank and you have not agreed upon any procedures for the detection of errors and you are solely responsible for any errors not caused by Bank.

Any Entry (or request for cancellation or amendment of an Entry) communicated to Bank will be effective as your instruction, whether or not authorized, and regardless of the actual identity of the sender thereof, if it is an Eligible Instruction accepted by Bank in good faith. Bank is not obligated to act on any instruction other than Eligible Instructions. You are solely responsible for the accuracy and completeness of each Eligible Instruction.

You agree to and will cause your Third-Party Service Providers (if applicable), to develop, implement, and update policies, procedures, and systems as necessary to ensure compliance with the ACH Security Framework Rule and to protect the integrity and confidentiality of Protected Information. You will not, and will ensure any Third-Party Service Providers do not, disclose Protected Information except as necessary and permitted by the Rules to facilitate the ACH Services. You agree to keep your Login Credentials safe and secure and not disclose them to anyone other than a Person authorized and permitted by you to send Entries to Bank on your behalf. You will immediately give notice to Bank via Servicer upon determining that any breach of confidentiality has occurred, including because any unauthorized Person has gained access to Protected Information.

15. Risk Exposure Limits and Prefunding

Your use of the ACH Services may be subject to underwriting criteria imposed by Bank from time to time in its sole discretion. Bank may establish limits on your use of the ACH Services for any reason, including based on your financial condition or historical or anticipated transaction levels. These limits may include limits on the size, frequency, or number of transactions you may make in a given period. Any limits will be disclosed to you through the A-Express Remit Pte Ltd Platform. You acknowledge that any limit imposed is solely for the protection of Bank and its assets. Bank may suspend or reject processing of any Entry or File that exceeds any applicable limits Bank has imposed. You may not reinitiate Entries except as permitted by the Rules. You understand that requests for Entries exceeding any limits are honored solely at the discretion of Bank. Requests not honored may be communicated by Bank to you. Regardless of any limits imposed by Bank, you are required to pre-fund your Account prior to the Settlement Date of any Credit Entries you initiate to ensure adequate funds are available. In addition, Bank may require, in its sole discretion, that you establish reserves with the Bank prior to any continued use of the ACH Services.

16. Record Retention

You shall retain data on file adequate to permit remaking of Entries for five (5) days following the date of their transmittal by Bank and shall provide such data to Bank upon request. You will maintain records of: (1) information provided to Bank in connection with an Entry for a period of six (6) years after the date of submission; and (2) each authorization in its original form while it is in effect and an original form or copy for two (2) years after termination or revocation of the authorization, or such longer period as may be required by the Rules. Upon request, you will provide such records to Bank via Servicer promptly, but no later than five (5) days following the date of the request.

All Entries, Security Procedures, and related records used by Bank for transactions contemplated by this Addendum shall be and remain Bank’s property. Bank may, at its sole discretion, make available such information upon your request. You shall pay any expenses incurred by Bank in making such information available to you. You and Bank agree that all telephone conversations or data transmissions between you and Bank made in connection with this Addendum may be electronically recorded and retained by Bank by use of any reasonable means. Bank shall not be obligated to make such recordings.

17. Compensation and Fees

Fees for the ACH Services are set forth in the Agreement.

18. Representations, Warranties, and Covenants

You represent and warrant to Bank that:

• a. You have access to a current version of the Rules, including any revisions to the Rules that may be made from time to time, and have reviewed your obligations thereunder;
• b. In using the ACH Services, regardless of whether an Entry is sent through the ACH network, you will comply and will cause your directors, officers, employees, and agents to comply with Applicable Law, the Agreement, and this Addendum;
• c. You adopt and make to Bank all representations and warranties of an Originator under the Rules;
• d. Each Person identified as the Receiver on an Entry submitted to Bank has authorized the Entry pursuant to the Rules, such authorization has not been revoked, and you shall furnish the original or a copy of the authorization to Bank or any other affected Participating DFI immediately upon request;
• e. Each Entry contains all information required by the Rules;
• f. Each credit Entry is timely and each debit Entry satisfies an obligation, corrects an error, or reclaims an amount received after death or legal incapacity;
• g. Banking information for the Entry is transmitted securely;
• h. You have used commercially reasonable procedures to verify that all information contained in an Entry, including routing numbers, is accurate and valid; and
• i. Entries transmitted to Bank are limited to those types of Entries set forth by Bank in the Agreement and this ACH Addendum.

19. Authorized Users

You may appoint Authorized Users pursuant to this Addendum and the terms governing your use of the A-Express Remit Pte Ltd Platform. You agree that you are solely liable for:

• a. Your Authorized Users’ compliance with your obligations under this Addendum;
• b. All transactions initiated by your Authorized Users, unless you have given notice that an Authorized User is no longer authorized to use the ACH Services as provided in this Addendum; and
• c. ny Losses Bank incurs as a result of the activities or omissions of your Users. It is your responsibility to train Authorized Users on their obligations and to appropriately safeguard Login Credentials.

20. Audit and Risk Assessments

If required by the Rules, you agree to conduct an annual audit of your compliance with the Rules and shall retain documentation supporting such audits for six (6) years from the date of the audit. You shall provide such documentation upon request by Bank or NACHA within five (5) Business Days of such request. In addition, you agree that Bank or a third party appointed by Bank shall have the right to audit your compliance with the Rules upon not less than ten (10) Business Days prior notice.

21. Termination

Bank may terminate or suspend the ACH Services and this ACH Addendum at any time in its sole discretion, including for breach of the Rules, in a manner that permits Bank to comply with the Rules. This Addendum may be terminated by you at any time by giving Servicer not less than thirty (30) days’ prior written notice. Your obligations arising under this Addendum survive termination and this Addendum shall continue in full force and effect with respect to all Entries and transactions which were in process.

22. Amendments

Bank may amend, revise, supplement or otherwise modify this Addendum from time to time upon notice to you through the A-Express Remit Pte Ltd Platform. Your continued use of the ACH Services thereafter shall constitute your acceptance of any modified terms.

23. Indemnification

You agree that you shall indemnify and hold Bank and Servicer harmless from and against any and all Losses, which may be claimed against Bank for any alleged or actual breach of warranty relating, directly or indirectly, and in whole or in part, to an Entry transmitted by you to Bank or for any other act or omission of Bank pursuant to this Addendum.

24. Limitation of Liability

Bank shall not be responsible for your acts or omissions including the amount, accuracy, timeliness of transmittal or due authorization of any Entry received from you or the acts or omissions of any other Person, including without limitation any ACH Operator, including transmission or communications facilities, any Receiver or RDFI, including the return of an Entry by such Receiver or RDFI, and no such Person shall be deemed Bank’s agent.

NONE OF BANK, ITS AFFILIATES, SERVICER, NOR ANY OF ITS OR THEIR AGENTS SHALL BE RESPONSIBLE FOR OR SHALL INCUR ANY LIABILITY (WHETHER ARISING BY CONTRACT, TORT, STATUTORY DUTY, OR OTHERWISE) TO YOU, THE RECEIVER, OR ANY OTHER PARTY FOR: (1) THE PERFORMANCE OF, OR DELAYS IN, OR FAILURE TO EXECUTE, ANY OF ITS OR THEIR UNDERTAKINGS UNDER THIS ADDENDUM; OR (2) ANY INDIRECT, SPECIAL, PUNITIVE, EXEMPLARY, OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH THIS ADDENDUM, EXCEPT: (i) WHERE SUCH LIABILITY IS ATTRIBUTABLE TO BANK, OR ITS AFFILIATES’, OR ANY OF ITS OR THEIR AGENTS’ FRAUD, GROSS NEGLIGENCE, OR WILLFUL MISCONDUCT; OR (ii) WHERE SUCH LIABILITY MAY NOT BE EXCLUDED OR LIMITED BY LAW. BANK’S, ITS AFFILIATES’, AND ITS OR THEIR AGENTS’ AGGREGATE LIABILITY IN CONNECTION WITH ANY ENTRY SHALL NOT EXCEED THE AMOUNT OF SUCH ENTRY. YOU SHALL REMAIN SOLELY AND EXCLUSIVELY RESPONSIBLE FOR ANY AND ALL FINANCIAL TRANSACTION RISKS ASSOCIATED WITH YOUR ACCOUNT, INCLUDING, BUT NOT LIMITED TO, INSUFFICIENT FUNDS, FRAUDULENT TRANSACTIONS, AND TRANSACTIONS RESULTING FROM IMPROPER INPUT DATA ASSOCIATED WITH THE ACH SERVICES.

1. The Account.

In order to provide the payment services requested by you, shall allow you to deposit United States Dollars (“USD”) into a custodial account held by (“Account”) in accordance with these Terms (“Pay In Services”). You agree that may hold your USD in the Account with that of other customers. The Account will be held for the benefit of you and such other customers. The balance of your cleared USD funds in the Account shall be referred to as your “Available Balance.” We may also allow you to or the transfer of the Available Balance to yourself or to a third-party beneficiary located in a jurisdiction approved by us (“Pay Out Service”).

The only method available for depositing funds to your Account is to initiate a funds transfer to the Account. You cannot deposit cash or mailed or electronic checks.

may refuse a deposit, or part of a deposit, at any time and for any reason. We also may refuse a deposit after initially accepting it. We will not be liable to you for refusing a deposit, even if it causes us to decline any transactions you have already made.

2. Client Obligations.

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT. TO HELP THE GOVERNMENT FIGHT THE FUNDING OF TERRORISM AND MONEY LAUNDERING ACTIVITIES, FEDERAL LAW REQUIRES ALL FINANCIAL INSTITUTIONS TO OBTAIN, VERIFY, AND RECORD INFORMATION THAT IDENTIFIES EACH PERSON WHO OPENS AN ACCOUNT.

WHAT THIS MEANS FOR YOU: WHEN YOU OPEN AN ACCOUNT, WE WILL ASK FOR INFORMATION THAT WILL ALLOW US TO IDENTIFY YOU, INCLUDING CERTAIN IDENTIFYING DOCUMENTS. WE MAY USE INFORMATION FROM THIRD PARTIES TO HELP US DETERMINE IF WE SHOULD OPEN YOUR ACCOUNT OR KEEP YOUR ACCOUNT OPEN.

In order to use the Account, you agree:

• 1. You shall only use the Account in compliance with applicable laws;
• 2. You can use the Account as authorized and only for business purposes. You must not use the Services for personal, family or household purposes;
• 3. Where a Pay In arises from an underlying transaction between you and a Payer, does not have any control of, nor any liability for, such underlying transaction or any goods, products or services provided to the Payer by you; and
• 4. may, in our sole discretion and for any reason, refuse to provide the Account to you.

3. Security of Account.

You shall be solely responsible and shall take all steps to keep the Account safe at all times. The Account shall be operated and accessed by you or user authorized on your behalf, and you are shall be fully liable for any acts and omissions of any persons acting or purported to act on your behalf. You shall notify A-Express Remit Pte Ltd immediately upon becoming aware of or reasonably suspect the Account has been misappropriated, compromised or used without authorization. Any delay in or failure to notify A-Express Remit Pte Ltd shall result in you being liable for any Losses that arise in connection therewith.

4. Privacy.

may collect personal data about you as part of your use of the Account. For information please see the Privacy Policy located at https://www.aexpressremit.com/privacy.

5. ACH Transactions.

Transactions transmitted through an automated clearing house (“ACH”) shall be subject to the applicable laws of the United States and ACH Operating Rules (the “ACH Rules”) of the National Automated Clearing House Association (“NACHA”). You agree to comply with and be bound by the ACH Rules. Unless otherwise defined in this Agreement, all capitalized terms in this subsection have the meanings assigned in the ACH Rules.

When you submit an ACH Transaction to us, you assume the responsibilities of an Originator under the ACH Rules and authorize to process your ACH transactions on your behalf in accordance with the instructions you provide. You may not originate ACH transactions on behalf of, or for the benefit of, any entity other than yourself, unless you have received prior written authorization from to do so. You agree to obtain proper authorizations and maintain proper confidential records of such authorizations from the Receiver for ACH Transactions and to provide with timely, accurate, and complete information as required by the ACH Rules. You agree that such records are confidential information, you will safeguard such information, and you will be liable to for the failure to comply with such obligations.

may limit your ACH transaction and may establish exposure transaction limits related to the amount of ACH transactions transmitted by you. may review and adjust these periodically. may block or reject any ACH Transaction that exceeds a limit we have established and can reject an ACH Transaction if it does not comply with these Terms, the ACH Rules, or applicable laws.

You further agree to the following:

• A. Entries. To use direct debit, you shall provide with instructions which authorize (i) to receive funds to your Account from an external bank account; or (ii) to send funds from your Account to an external bank account (“Entries”). Entries will be processed in accordance with the rules and timing set forth by the ACH Rules.
• B. Entries; Bank Account Eligibility and Details. To receive funds via direct debit to your Account, your Entries must include all information required by the ACH Rules, including but not limited to your bank account details at a third-party financial institution, which may include but are not limited to, the name of your bank, the bank account number, routing number for your bank account, and the type of account, for example, checking or savings. You represent and warrant that you will submit Entries bank account is legitimate, open, and in good standing. You understand that we will require you to verify your bank account details are accurate and valid before you can initiate direct debit transactions. You agree to promptly update us if there are any changes to your bank account details.
  Your bank account must be able to accept debits denominated in the currency indicated in the Entries. You confirm that you are the only person required to authorize and you agree to authorize the direct debit from your bank account in accordance with the ACH Rules. You agree to maintain such authorizations and provide proof of such authorization immediately upon request.
• C. Sufficiency of Funds; Unpaid Direct Debits. It is your responsibility to ensure that there are sufficient funds available in your bank account or Account, as applicable, in order to execute on your Entry. Direct debits will be processed in accordance with the rules and general timings of the ACH Rules. The debited amount will be reflected in the debited bank account after a successful debit in accordance with the timing of the ACH Rules.
  Where you have insufficient funds in your Account or where access to your Account has been suspended or terminated, we reserve the right to return an Entry as unpaid in accordance with the ACH Rules. In the event that we process an Entry that you are unable to pay via your Account for any reason, you will remain liable to us for the applicable direct debit amounts.
• D. Direct Debit Authorization. Each time you choose to fund your Account via direct debit, you authorize us to debit your bank account up to such amount pursuant to your Entries, including any applicable taxes and fees. Your authorization under these Terms will remain in full force and effect until the later of (i) closure of your Account, or (ii) payment of all fees and other amounts you owe under the applicable services agreement between you and A-Express Remit Pte Ltd .
• E. No Notification; Correction of Errors. After you authorize an Entry, you will not receive a separate notice from us of the amount, timing of the debit, or any other information about the debit, before we process and debit your account. To determine if a transfer has been credited to your A-Express Remit Pte Ltd Account, you can review the transactions on your Account or contact A-Express Remit Pte Ltd for more information.
  In addition to authorizing debits to the bank account, you also authorize to credit your bank account if necessary to correct an erroneous direct debit in the amount necessary to correct the error. If we make an error when executing an Entry, we will refund you the amount paid in accordance with. If you receive a refund you are not entitled to, you agree to pay back immediately.
• F. Reinitation of Debit Entries. If is unable to collect the amount of any debit due to insufficient funds in your bank account, then we may reinitiate that debit in the same amount up to a maximum of two (2) additional times in accordance with the ACH Rules.
• G. Fees Chargeable. If your bank rejects a direct debit transaction or if a direct debit transaction is subsequently disputed by you or your bank for any reason other than as a result of our error, may charge you applicable fees.
• H. Refusing an Entry; Termination of Direct Debit. may refuse to process an Entry or revoke your access to the ACH network at any time for any reason, including if (i) we are unable to debit your bank account or Account, as applicable, for any reason; (ii) you have requested a direct debit refund of any amount that has been properly paid; (iii) you breach these Terms, the ACH Rules, or any applicable services agreement; (iv) we determine your use of direct debit may cause us to breach or incur liabilities under the ACH Rules; or (v) requested by NACHA.
• I. Amending or Cancelling Entries. You can amend or cancel an Entry by providing A-Express Remit Pte Ltd with written notice in accordance with the timeline provided by the ACH Rules.
• J. No Liability. You agree to be bound by all Entries accepted by in good faith and will be liable for all losses, expenses, and liability, resulting from, related to, or caused by 's processing or execution of an Entry, regardless of whether such losses, expenses, or liability occur due to unauthorized, incorrect, incomplete, or fraudulent transactions.

6. UCC Article 4A Disclosure.

Your credit entry may be transmitted through the ACH network. Your rights or obligations, as an Originator, concerning the credit entry are governed by and construed in accordance with the laws of the State of New York, unless you and the originating depository institution have agreed that the laws of another jurisdiction govern their rights and obligations. Credit given by the receiving depository financial institution (“RDFI”) to the receiver for the entry is provisional until the RDFI has received final settlement through a Federal Reserve Bank or through a funds transfer system in accordance with Section 4A-403(a) of UCC Article 4A. If the RDFI does not receive such payment for the entry, the RDFI is entitled to a refund from the receiver in the amount of the credit to the receiver’s account, and the originator will not be considered to have paid the amount of the credit entry to the receiver.

7. Right to Audit.

You agree to promptly provide information may request from you to confirm your compliance with these Terms, including the ACH Rules and applicable law. may immediately suspend or terminate your access to the Account, including the ACH network, if you fail to provide information or documentation by requests under this section.

8. Right to Set-off:

If your Account balance is negative or you are determined to owe Bank any amounts for any reason, can use the funds in your Account or any other account that you own at to repay any owed amount without further notice to or demand on you. has the right to set off direct or contingent, past, present or future liability that you owe against any account you have with . You hereby grant a lien on and security interest in the funds on deposit in each of your Account as security for the entirety of your liabilities and obligations to .

9. Limitation of Liability.

Except as required by applicable law, shall have no liability to you if is unable to complete a transaction for any reason. Except as otherwise expressly provided in these Terms or as otherwise required by applicable law, and the parties with whom Bank contracts in order to offer your Account and related services are neither responsible nor liable for any indirect, incidental, consequential, special, exemplary, or punitive damages arising out of or relating in any way to your Account, any products or services purchased using Account, or these Terms.

10. Indemnity.

You agree to defend, indemnify, and hold harmless , and its subsidiaries and affiliates employees, contractors, officers, and directors against any and all claims, suits, damages, costs, lawsuits, fines, penalties, liabilities, and expenses (including, without limitation, reasonable attorneys' fees) that arise from your use of the Account, including but not limited to your acts or omissions, or your violation of these Terms, applicable law, or your fraud or willful misconduct.

11. Termination, Suspension, Closure of the Account.

Notwithstanding anything in these Terms, may, in its sole and absolute discretion and without notice or liability to you, refuse to open, suspend, or terminate the Account at any time and for any reason. may close or suspend your use of the Account if you violate these Terms any other agreement you enter into with or A-Express Remit Pte Ltd or as required by applicable law, law enforcement, or any regulatory authority.

12. Governing Law.

Any dispute arising under these Terms shall be governed by and construed and enforced in accordance with the laws of the State of New York without reference to the conflicts of laws principles thereof. You and hereby waive trial by jury in any court action or proceeding to which they may be parties, arising out of, in connection with or in any way pertaining to, these Terms.

Prohibited & Restricted Business Categories

Last updated: June 4, 2024

A-Express Remit Pte Ltd reserves the right to decline services to any jurisdiction, organization, or individual whose activities are illegal, prohibited by A-Express Remit Pte Ltd , or may cause A-Express Remit Pte Ltd reputational, regulatory, financial or operational harm. This includes restricting where/who A-Express Remit Pte Ltd clients can send money to, from, or on behalf of.

This page provides information on the types of businesses, products, and industries that are prohibited or restricted for use as part of A-Express Remit Pte Ltd ’s services. To use A-Express Remit Pte Ltd ’s services, you must remain compliant with these rules and restrictions.

The lists of jurisdictions, persons, businesses, and activities described on this page are representative but not exhaustive and subject to change.

High Risk Jurisdictions and Persons

Use of A-Express Remit Pte Ltd ’s services for any dealings, engagement, or sale of goods/services directly or indirectly with the following are prohibited:

• Jurisdictions A-Express Remit Pte Ltd has deemed high risk, including but not limited to Cuba, Iran, North Korea, Syria, Russia, Belarus, and the Crimea, Donetsk, and Luhansk regions of Ukraine.
• Organizations, business, or individuals or associated with terrorism and crimes, including financial and environmental crimes and activities
• Foreign governments, embassies, and consulates

Prohibited Businesses

You must not use A-Express Remit Pte Ltd ’s products or services for the following activities or in the following manner:

• in any way that breaches any applicable local, national, or international law or regulation, or causes A-Express Remit Pte Ltd to breach any applicable law or regulation;
• in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;
• for any violence-related activities, including the creation, facilitation, sale, or distribution of any material that promotes violence or hatred, including for the purpose of harming or attempting to harm minors in any way;
• for any unsolicited or unauthorized advertising, promotional material, or any other form of spam;
• to deal in harmful programs such as viruses, spyware, or similar computer code designed to adversely affect the operation of any computer software or hardware;
• in any way that would locally or internationally evade any applicable taxes or facilitate tax evasion

Regulated or illegal products and services

• Adult entertainment and content, including but not limited to, pornography and other visual content depicting explicitly sexual acts, services of sexual nature (webcam shows, live chats, prostitution, escorts, etc.), sexually-oriented establishments (massage parlors, strip clubs, gentleman’s clubs), adult live chats, sexually motivated dating services, and pornographic pay per view services
• Drugs, drug paraphernalia, controlled substances; or other products that present a risk to consumer safety, such as raw material, chemicals, psychoactive products, and addictive substances
• Human organs and remains
• Nuclear chemicals or materials, poisonous, radioactive, or hazardous chemicals, highly toxic pesticides, flammable or explosive chemicals.
• Gambling, foreign casinos, internet gambling, lotteries, fantasy sports, games of chance
• Weapons, including but not limited to, firearms, simulation weapons, ammunitions and explosives, and military or semi-military goods, military software, or technologies, including dual-use goods, or fireworks and firecrackers, explosives and explosive devices.
• Trade of restricted and/or endangered animal species and products derived from them
• Pyramid schemes

Products and services that infringe intellectual property right

• Any products or services that directly infringe or facilitate infringement upon the trademark, patent, copyright, trade secrets, proprietary or privacy rights of any third party
• Counterfeit goods, illegally imported or exported products

Financial and other professional services

• Investment & credit services, securities broker, mortgage consulting or debt reduction or collection services, credit counselling or repair, real estate investments
• Lending, including lending instruments, crowdfunding, or fundraising activities
• Trading and exchange and wealth management, including investment, stocks, securities, spot, and futures services
• Using the A-Express Remit Pte Ltd account as an escrow or safeguarding account

Technology and network

• Businesses that provide hacking related services or sell hacking related software, malware, software services which jeopardize companies or its related party.
• Spy equipment and weapons, including hidden cameras, GPS trackers, listening and encrypted communication devices
• Decryption and descrambler products and services, devices designed to block, jam or interfere with cellular and personal communications

Restricted Businesses

You must not use A-Express Remit Pte Ltd ’s products or services for the following activities, unless you have received prior written approval from A-Express Remit Pte Ltd . Due to card network rules, requirements of financial partners, and our own compliance and legal obligations, if your business falls into one of the categories below, A-Express Remit Pte Ltd may not be able to approve your business’s use of our products or services.

• Alcohol, cigarettes, tobacco, e-cigarettes, cigars
• Marijuana-related businesses including medical marijuana, cannabis, and THC or CBD
• Medical and pharmaceutical, including medicines, drugs, equipment, prescription devices and medications
• Cryptocurrencies/digital assets, including store-value virtual currencies, stablecoins, non-fungible tokens (NFTs)
• Precious metals and stones including raw materials, such as gold, jewels, gems, mining
• Oil and petroleum products such as gasoline (petrol), diesel, jet fuel, kerosene, fuel oil, and any other type of petrochemical or residual fuel
• Multi-level marketing services or commission-based sales
• Nonprofits and charities

Global Privacy Policy

Last updated: April 15, 2024

Privacy and security are very important to us at A-Express Remit Pte Ltd . This Global Privacy Policy (“Privacy Policy” or “Policy”) is intended to help you understand how we collect, use, and share your personal information when you use our products or services.

A-Express Remit Pte Ltd its affiliates and subsidiaries worldwide, including entities.

You should read this Privacy Policy carefully as it contains important information about your privacy rights and choices. If you do not agree to this Privacy Policy, please do not use the Services.

A-Express Remit Pte Ltd obtains information about you from various sources. “You” may be a visitor on the Site, a user of our Services, including as a customer of A-Express Remit Pte Ltd (“A-Express Remit Pte Ltd Client”) or an end user of a A-Express Remit Pte Ltd Client (“End Customer”), or a recipient/beneficiary of one of our Services. If you are an End Customer, your use of the Services will also be subject to the applicable agreement between us and the applicable A-Express Remit Pte Ltd Customer.

If you have obtained a financial product or service in the United States with A-Express Remit Pte Ltd , to be used primarily for personal, family, or household purposes, we will use and share personal information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice.

Information We Collect

The personal information that we collect about you depends in relation to your use of the Services, the choices that you make, your location, and applicable law.

Information You Provide to Us Directly

We collect the information directly from you when you use our Site and/or Services.

• Identifiers, including name, address, email address, phone number, age, date of birth, gender, citizenship, account credentials; geolocation, unique device identified, network information or internet protocol (IP) address
• Government identifier Information, including national identification card information; driver’s license, state identification, passport, visa, Social Security number, tax identification, etc.
• Employment Information, including occupation, employer, or salary range
• Company Information, including information about your company, company name, location
• Payment Information, including your payment transactions and transaction history regarding the Services
• Financial Information, including your financial and bank name, account number, and routing number and card details
• Verification Information to verify your identify, including information for fraud checks and other information you provide, including images of yourself;
• Sensitive Personal Information: Social Security number, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
• Other information that you voluntarily provide to us related to the Services or otherwise or that we may collect as permitted by law and with your consent where required by law

If you do not provide us with the information below, we may not be able to provide the Services to you, or your use of the Services may be restricted.

In addition to information you provided us in connection with your use of the Services, you may also choose to submit information to us via other methods, including but not limited to in response to marketing or other communications; through social media or online forums; through participation in an offer, program, or promotion; in connection with an actual or potential business relationship with us; or by connecting with us at industry events or conferences.

Information We Collect Automatically Based on Your Activity on Our Services

We may collect certain information automatically when you use our Site or Services. For example, we collect information about your device you use to access the and use the Sites and Services, such as your IP address, general geographical location, browser or device information, operating system version, and Internet service provider. We may also automatically collect information regarding your use of our Site, such as pages that you visit before, during and after using our Site, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Site.

We may use third parties to engage in such collection activities on our behalf. 

We also partner with third parties to manage our advertising on other websites and evaluate the overall performance of our Services.

In accordance with applicable law (which may include obtaining your consent depending on your jurisdiction of residence, such as in the EU or UK), we and our advertising partners and service providers use technologies such as cookies, beacons, tags, scripts, and similar technologies to analyze trends, administer our Services, track use of the Services, and gather demographic information about our user base as a whole. We may receive reports on this activity on an individual and aggregated basis.

Our third-party partners may also use cookies and pixels to gather information about your activities on our Services and other sites in order to provide you advertising based upon your browsing activities and interests or help us track the success of our advertising efforts. Cookies are also used to gather statistical data, such as which pages are frequently visited, what is downloaded, and the address of sites visited immediately before or after coming to our Services.

For more information about our use of cookies and how to opt-out of certain cookies, please see our Cookies Notice. If you disable certain cookies, your ability to use some features or parts of the Services may not be accessible to you and/or the performance, features, or Services may not function as intended.

Information We Collect from Third Parties

In addition to the information we collect directly and automatically from you, we may also receive information about you from our customers, business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. We may also receive information about you from other sources, such as business partners, marketers, researchers, analysts, social network services, and other parties to help us supplement our records.

How We Use Your Information

A-Express Remit Pte Ltd uses the information we collect in connection with offering the Services, and for related business purposes as follows:

• Provide the Services, including performing any agreement we have entered into with a A-Express Remit Pte Ltd Client or End Customer and manage your account, provide, operate, monitor, maintain and administer our Site and Services;
• Communicate with you about the Services, including any technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests;
• Send marketing communications about products, services, and events offered by A-Express Remit Pte Ltd and others, and provide news and information we think will be of interest to you, in accordance with applicable legal requirements;
• Promote the security of Services, including to detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of A-Express Remit Pte Ltd and others;
• Improve the Services, including internal operations, troubleshooting, testing, research, and de-bugging errors and developing new products and services;
• Comply with laws, rules and regulations, including to verify your identity and any disclosure or reporting obligations (including in connection with anti-money laundering, sanctions, and counter-terrorism financing rules/laws);
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Create de-identified data sets to analyze and improve our Services;
• Any other purpose described to you at the time the information was collected; and
• For other purposes where you provide your consent.

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal basis for processing your information as described in this Privacy Policy are as follows:

• Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the Services you’ve requested from us, or to comply with our terms of service and other legal terms.
• Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate our business and our Services, make and receive payments, defend our legal rights, and prevent fraud.
• Where we use your information to comply with applicable legal obligations. For example, keeping track of purchases for tax and auditing purposes and comply with applicable sanctions and anti-money laundering rules.
• Where you have consented to our processing of your information for a particular purpose.

For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Information We Disclose

A-Express Remit Pte Ltd may use and disclose your information to provide the Services to you and in accordance with applicable law. We do not share or sell your personal information with any third party other than as described in this Privacy Policy.

We may disclose your information with the following third parties in the following instances:

• Affiliate entities, as permitted by law;
• Third-party partners and service providers, including financial institutions, card networks, contractors, service providers, as necessary to provide the Services to you, as needed to perform such services, which may include, payments, service fulfillment, web hosting, security and fraud prevention services, credit reference, or marketing or analytic services.
• Marketing, referral, or advertising and analysis partners that we partner with to market you
• Law enforcement, government officials, or other third parties as required by law and when we believe that such disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, regulatory request or other legal process;
• Third parties when we have a legitimate business purpose as permitted by law;
• Companies, organizations, or individual in connection with a business transaction, such as a merger, sale of some or all of our assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business or in the event of a bankruptcy or related or similar proceedings.
• Other third parties with your consent or authorization.

We may also use or disclose aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you, to the extent permitted under applicable law.

Your Privacy Rights and Choices

Privacy Rights

Depending on your jurisdiction of residence, you (or an authorized agent acting on your behalf) may be able to make certain requests based on the following rights related to your information, subject to certain exceptions and limitations:

• Right to Know and Access. You may request to know and receive a copy of the personal information we hold about you. You can also request to port your information to another entity, where technically feasible.
• Right to Delete. You may request deletion of certain information we have about you.
• Right to Correct. You may request to correct or update personal information held by us that is incomplete or inaccurate.
• Right to Object or Restrict Processing. You may have the right to restrict or object to your personal information being processed for certain purposes.
• Right to Withdraw your Consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. However, please note that we may not be able to continue providing the Services to you as a result.
• Right to Opt-Out. You have the right to opt out from the sale and sharing of your personal information, including the processing of your personal information for purposes of targeted advertising.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights provided under the law.
• Right to Lodge a Complaint. You may lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country or state.
• Right to Appeal. As provided by applicable law, you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

We also will take reasonable steps to verify your identity before responding to a request. If we are unable to verify your identity, we shall have the right, but not the obligation, to request additional information from you. If you are an End Customer, we may need the assistance of the A-Express Remit Pte Ltd Client to complete your request.

To exercise your rights, please contact us at contact@aexpressremit.com

Marketing/Advertising Opt Out Rights

You can opt-out of marketing communications with us as provided under applicable law. For example, if you do not want to receive promotional emails from us, you may stop receiving such emails by clicking on the “unsubscribe” link provided in such emails. You may not, however, opt out of service-related emails and communications. Please note that it may take some time to process your request in accordance with applicable law.

Please refer to our Cookie Notice for more information on how you can opt-out of certain cookies.

Our Sites do not respond to Do Not Track signals. We honor global privacy signals in accordance with applicable law.

Retention of Your Information

We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy, and in accordance with our internal data retention policies. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. For example, A-Express Remit Pte Ltd is required to collect and hold certain information under the Anti-Money Laundering and Counter-Terrorism Financing rules and other subordinate instruments (AML/CTF Laws). There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.

International Transfers

We operate globally and in accordance with applicable law, may transfer, store, and/or process your information to or with other entities within the A-Express Remit Pte Ltd or other third parties such as trusted service providers and partners in locations around the world, including the United States, Canada, Australia, the European Union, United Kingdom, Hong Kong, India, Indonesia, Malaysia, Malta, and Singapore for the purposes described in this Privacy Policy. The data protection laws of these locations may not provide the same protections as the data protection laws in the jurisdiction where you reside. Wherever your information is transferred, stored or processed by us, we take reasonable steps to protect your information in accordance with this Privacy Policy and applicable laws. These measures may include implementing Standard Contractual Clauses and/or international data transfer agreements to govern the transfer of your information, or other means recognized by applicable laws. By providing us with your information, you acknowledge and agree to any such transfer, storage, or processing.

If you have any concerns or complaints about our data processing activities, we urge you to first try to resolve such issues directly with us. However, if applicable, you may make a complaint to the data protection supervisory authority in the country where you are based, or seek a remedy through local courts if you believe your rights have been breached.

California Privacy Notice

If you are a California resident, the California Consumer Privacy Act (“CCPA”), as amended from time to time, requires us to provide you with certain notices prior to our collection and use of your personal information.

Purpose of Collection and Disclosure of Personal Information

We have collected and disclosed the below categories for personal information to provide the Services; communicate with you; marketing and advertising; Improve the Services; and for the business and commercial purposes as described in the “How We Use Your Information”. We do not collect, use, or disclose sensitive personal information for purposes other than those specified in this Privacy Policy, to provide the Services, or as permitted under applicable law.

Collection and Disclosure of Personal Information

In the past 12 months, we have collected the below categories of personal information:

• Identifiers;
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e);
• Professional or employment-related information; and
• Internet or other network or device activity (e.g., browsing history or usage information and associated device IDs and IP addresses.

We have disclosed the specific types of personal information described in the “What Information We Collect” section with affiliated entities; third-party partners and service providers; marketing partners; entities for legal purposes; and entities for business transactions further described in the “Information We Disclose” section.

Collection and Disclosure of Sensitive Personal Information

In the past 12 months, we have collected and disclosed the following sensitive personal information with affiliated entities; third-party partners and service providers; marketing partners; entities for legal purposes; and entities for business transactions further described in the “Information We Disclose” section:

• Social Security number, driver's license, state Identification card, or passport number; and
• Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

Your Rights and Choices under the CCPA

You may submit a verifiable request for information regarding the categories of personal Information collected, sold, or disclosed by us; purposes for which categories of personal information are collected or sold by us; categories of sources from which we collect personal information; categories of third parties with whom we disclosed or sold personal information; and specific pieces of personal information we have collected about you during the past 12 months. Such information is set forth above in this Privacy Policy. 

Please see the “Your Privacy Rights and Choices” section for information about the additional rights you have with respect to your personal information under California law and how to exercise them. We do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.

Financial regulations, including the Gramm-Leach-Bliley Act, may permit us to deny certain requests by California residents. If you are an individual located in the United States who applies for or obtain our financial product or service to be used primarily for personal, family, or household purposes, your personal information is subject to our U.S. Consumer Privacy Notice.

Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not currently disclose personal information for these purposes.

Information Security

We maintain a variety of administrative, physical, and technical safeguards designed to prevent unauthorized use, access, processing, destruction, loss, alteration, or disclosure of the information we process. In the event that any information under our control is compromised as a result of a breach of security, we will investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any information.

Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 16 or knowingly allow such persons to register for our Services. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 16, please contact us using the contact information below.

Third-Party Links and Features

This Services may contain links to, and incorporated features from, other websites or third parties that are not owned or maintained by us. Unless otherwise stated, we make no warranties or representations regarding such links or features, or the products or services offered by them. We do not control the privacy or security practices of third parties, or the locations where they process data. You should read the privacy and security policies of such third parties, as their practices may differ from ours.

Contacting Us

If you have any questions about this Privacy Policy or our data processing activities, please contact us at contact@aexpressremit.com or send physical mail to the relevant entity provided in this section that is the data controller of your information. You can also contact our Data Protection Officer by emailing contact@aexpressremit.com

You can contact the applicable supervisory authority or other public body with responsibility for enforcing privacy laws in the countries or regions that we operate in the event that you feel we have not resolved your inquiry:

Country or Region	A-Express Remit Pte Ltd Controller Entity	Registered address	Data Protection Authority
Singapore	A-Express Remit Pte Ltd.	304, orchard Road Lucky plaza #02-28 Singapore 238863	Personal Data Protection Commission

Cookie Notice

Last updated: April 15, 2024

A-Express Remit Pte Ltd uses cookies, web beacons, and other similar technologies (collectively “Cookies”) when you visit our websites such as aexpressremit.com and any other A-Express Remit Pte Ltd -managed website that links to this Notice or when you use any A-Express Remit Pte Ltd mobile site or mobiles app (collectively the "Services"). This Notice explains what Cookies are, why we use them, and how you can manage their use.

1. What are Cookies?

Cookies are text files containing small amounts of information which are automatically downloaded to your computer or device when you visit a website. Cookies send data back to the originating website on each subsequent visit, or share data with other websites that recognize that cookie.

Cookies are useful because they allow a website to recognize a user's device over time. They can be used for lots of different activities, such as letting you navigate between pages efficiently, remembering your preferences, personalizing your online experience, and generally improving the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.

2. How do we use Cookies?

In accordance with our Global Privacy Policy, we use Cookies for a variety of purposes — to remember your preferences, provide product and site functionality, analyze use of the Services, enhance and personalize your experience, and provide online advertising that is more tailored to your interests.

We use the following types of Cookies:

Strictly Necessary Cookies. These are Cookies that are required for the operation of our Services (e.g., to enable you to log-in to secure areas of our websites or use a shopping cart). Without these Cookies, many of the services that you have asked for cannot be provided.  We want you to understand these essential Cookies, and why we use them, but we don't need to get your consent to use them on our Services as we use these Cookies only to provide you with services that you have requested. You cannot opt out of these Cookies.

Functionality Cookies. These Cookies allow our Services to remember choices you make, such as remembering your username, preferences and settings; remembering if you've filled in a survey or taken part in a poll or contest or otherwise reacted to something on or through the Services, so you're not asked to do it again; remembering if you've used any of our Services before; restricting the number of times you are shown a particular advertisement; and remembering your location. The aim of these Cookies is to provide you with a more personal experience so that you don't have to reset your preferences each time you use our Services. We also use these Cookies to provide enhanced services such as enabling you to view a video through the Services. As described below, you may disable these Cookies; but if you do so, then various functions of our Services may be unavailable to you or may not work the way you want them to.

Performance Cookies. These Cookies collect information about how visitors use and interact with our Services, for instance which pages they go to most often. These Cookies also enable us to personalize content and remember your preferences (e.g., your choice of language, country, or region). These Cookies help us improve the way our Services work and provide a better, personalized user experience.

Targeting Cookies. These Cookies record your visit to our websites, the pages you have visited, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a website. We (and third-party advertising platforms or networks) may use this information to make our websites, content, and advertisements displayed on our Services and other websites more relevant to your interests (this is sometimes called "behavioral" or "targeted" advertising). These types of Cookies are also used to limit the number of times you see an online advertisement as well as to help measure the effectiveness of advertising campaigns.

Our third-party service providers, including for example, advertising networks and providers of external services like web traffic analysis services, may also use Cookies on our Services. We used trusted partners to help us serve advertising and assist with analytics so we can understand which pages our users view, which are most popular, what time of day our websites are visited, whether visitors have been to our websites before, what website referred the visitor to our websites, and other similar information.

3. How long do Cookies stay on my device?

The length of time a Cookie will stay on your browsing device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you close your browser. Persistent cookies are set to automatically expire after a defined duration (for example, a few days, weeks or months).

4. How to manage Cookies

You can manage what Cookies are set on your devices.

You can enable or disable categories of cookies by setting Your Privacy Choices through our Cookie preference manager. Your web browser may also allow you to manage your cookie preferences, including disabling or deleting Cookies. To do this, follow the instructions provided by your browser help menu. If you choose to disable certain Cookies, some features of the Services may not be available to you or may not operate as intended.

If you are interested in additional tools to manage third-party cookies, you can visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs.

Candidate Privacy Notice

Last updated: April 22, 2024

This Candidate Privacy Notice (“Notice”) describes how A-Express Remit Pte Ltd Pte. Ltd. and its subsidiaries and affiliates (collectively, “A-Express Remit Pte Ltd ”, “we”, “us” and “our”) collects, uses, and discloses information about individuals who apply for positions at A-Express Remit Pte Ltd (“you”, “your”, “yours”).

1. Types of Personal Information We Handle

We collect, use, and store various types of information that identifies, relates to, or could reasonably be linked to you (“personal information”) in connection with your application for employment with us. We collect such information either directly from you or (where applicable) from another person or entity, such as professional networking websites, job posting websites, employment agencies, recruitment companies, academic institutions, background check providers, or your professional references. We may collect additional personal information throughout the course of your application process.

The information we collect from and about you includes, where applicable:

• Identifiers, such as first and last name, postal address, telephone number, and email address, and, if provided an offer, identifiers related to your citizenship documents, such as Social Security Number, national ID card, passport, and copies of work permits and birth certificates (which include date and place of birth).
• Professional or employment-related information, including:
  • Recruitment, employment, or engagement information, such as application forms and information included in a resume, cover letter, or otherwise provided through the application and recruitment process; information about your eligibility to work in the country where you are applying for a job, such as information related to citizenship and/or immigration status; references; our evaluations of your performance during the interview process; and if provided an offer, background screening results (including any criminal convictions).
  • Career information, such as past employers, titles, job history, work dates and work locations, salary expectations, notice period, and information about skills, qualifications, and experience.
• Education information, such as institutions attended, degrees, academic record, certifications, licenses, transcript information, and professional memberships.
• Business travel and expense information, such as travel itinerary information and expenses incurred for travel during the interview process.
• Audio or visual information, such as CCTV footage, as well as other information relating to the security of our premises collected during in-person interviews or other parts of the recruitment process, and video or audio recordings of events and recruitment activities.
• Internet and electronic network, and device activity and device information and related identifiers, such as information about your use of our network while you are on our premises, including IP address and device identifiers and attributes.
• Potentially protected classification information to the extent required or as permitted by law and voluntarily provided such as race/ethnicity, nationality, sex/gender, gender identity, citizenship, religion, marital status, military service, disability, race, accommodation information, and other information to help us monitor compliance with equal opportunity legislation.
• Other information that you may voluntarily choose to include on your resume, in connection with your application, or otherwise.

2. How We Use Personal Information

We may collect, use, disclose, and store personal information for our business purposes, which include, where applicable:

• Engaging in the recruitment process, including communicating with you, interviewing, and selecting and hiring new personnel.
• HR management and administration, including determining compensation, scheduling, IT and informational security purposes, fraud prevention, and conducting internal analyses and audits.
• Security operations, including detecting security incidents, debugging and repairing errors, and preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution; monitoring and controlling access to our premises and locations (including through use of CCTV); and safeguarding A-Express Remit Pte Ltd and its locations, services, and employees.
• Safeguarding A-Express Remit Pte Ltd and our services, including the protection of A-Express Remit Pte Ltd , our workforce, users, partners, and others.
• Safeguarding A-Express Remit Pte Ltd and our services, including the protection of A-Express Remit Pte Ltd , our workforce, users, partners, and others.
• At your request, to fulfil your instructions.
• Exercising our legal rights, including seeking legal advice from our external lawyers or in connection with litigation with a third party.

We may also use personal information for any other legally permitted purpose (subject to your consent, where legally required).

Some personal information we collect in the recruitment process, such as ethnicity and veteran status, may be considered “sensitive” under applicable law. We use such information only for equal employment opportunity purposes. Some “sensitive” information may be required for certain job applications.

Some jurisdictions require us to state our “legal bases” for processing your personal information as described in this Notice. These legal bases are:

• Contract: We may process your personal information as necessary to perform a contract with you, such as to administer payroll and provide benefits.
• Legal obligation: We may process your personal information to comply with a legal obligation or request, such as to comply with employment and tax regulations.
• Legitimate interest: We may process your personal information for purposes of our or another party’s legitimate interests, such as to maintain the security of our premises, personnel, and property.
• Consent: We may process your personal information consistent with your consent to the extent permitted by applicable law.

3. How We Disclose Personal Information

We may disclose certain personal information to the following types of entities or in the following circumstances, where applicable:

• Internally: To employees within A-Express Remit Pte Ltd who participate in the recruitment process, such as HR managers and employee interviewers, and among our corporate affiliates.
• Vendors: Such as background check companies, security providers, information technology providers, travel management companies, and employment businesses (e.g., recruiting contractors or agency workers) that provide us with services relevant to recruiting and hiring.
• Recruiters: To the extent you are working with a recruiter in connection with your application for employment and your recruiter is authorized by you to obtain feedback from us regarding your application and interview process.
• Legal compliance and exercising legal rights: (i) When required to do so by law, regulation, or court order, (ii) in response to a request for assistance by the police or other law enforcement agency; (iii) to seek legal advice from our external lawyers or in connection with litigation with you or a third party or (iv) as otherwise necessary to exercising our legal rights or to protect A-Express Remit Pte Ltd or its employees.
• Business transaction purposes: In connection with the sale, purchase, or merger of all or a portion of our company.
• Consent: With your consent and as permitted by law, we may disclose personal information to any other parties in any other circumstances.

4. Data Retention

The personal information we collect from you will be retained until we determine it is no longer necessary to satisfy the purposes for which it was collected and our legal obligations. As described above, these purposes include our business operations and complying with reporting, legal and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.

5. Personal Information Rights

Depending on your jurisdiction of residence, you may have certain rights regarding your personal information, subject to certain exceptions and limitations as provided by applicable law:

• Right to Know and Access: You may request to know and receive a copy of the personal information we hold about you. You can also request to port your information to another entity, where technically feasible.
• Right to Delete: You may request deletion of certain information we have about you.
• Right to Correct: You may request to correct or update personal information held by us that is incomplete or inaccurate.
• Right to Object or Restrict Processing: You may have the right to restrict or object to your personal information being processed for certain purposes.
• Right to Withdraw your Consent: To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. However, please note that we may not be able to continue providing the Services to you as a result.
• Right to Opt-Out: You have the right to opt out from the sale and sharing of your personal information, including the processing of your personal information for purposes of targeted advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your rights provided under the law.
• Right to Lodge a Complaint: You may lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country or state.
• Right to Appeal: As provided by applicable law, you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

Where we process your personal information based on your consent and not another legal basis, you may withdraw consent to further processing. However, withdrawing your consent only affects our processing after the withdrawal.

Exceptions: There are certain exceptions to the above rights. For instance, we may retain your personal information if it is reasonably necessary for us or our service providers to provide a service that you have requested, to comply with law, or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity. In addition, we reserve the right not to process requests that are manifestly unfounded or excessive, as provided in applicable law, or that we are not legally obligated to process.

Exercising your rights: To exercise your rights, please contact us and specify the right(s) you want to exercise and the personal information which you want to exercise such right(s). You can submit your request by emailing us at contact@aexpressremit.com We may take reasonable steps to verify your identity before responding to a request, and to do so, we may ask you for additional information to verify your identity.

California disclosure: California law places certain obligations on businesses that “sell” personal information to third parties or “share” personal information with third parties for “cross-context behavioral advertising” as those terms are defined under the California Consumer Privacy Act. We do not “sell” or “share” the personal information covered by this Notice and have not done so in the twelve months prior to the effective date of this Notice.

6. International Transfers

We operate globally and in accordance with applicable law, may transfer, store, and/or process your personal information to or with other entities within the A-Express Remit Pte Ltd or other third parties such as trusted service providers and partners in locations around the world. The data protection laws of these locations may not provide the same protections as the data protection laws in the jurisdiction where you reside. Wherever your information is transferred, stored or processed by us, we take reasonable steps to protect your information in accordance with this Notice and applicable laws. These measures may include implementing standard contractual clauses and/or international data transfer agreements to govern the transfer of your information, or other means recognized by applicable laws. By providing us with your information, you acknowledge and agree to any such transfer, storage, or processing.

7. Contact Us

If you have questions about our handling of personal information under this Notice, please contact us at contact@aexpressremit.com.

U.S. Consumer Privacy Notice

Last updated: April 15, 2024

This Consumer Privacy Notice applies to you if you are an individual who resides in the United States and obtains services from A-Express Remit Pte Ltd for your own personal, family, or household purposes.

Facts	What does A-Express Remit Pte Ltd , (“A-Express Remit Pte Ltd ”) do with your personal information?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and Transaction history Account balances and Account transactions Account information and Checking account information When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons A-Express Remit Pte Ltd chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does A-Express Remit Pte Ltd share?	Can you limit this sharing?
For our everyday business purposes—such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes—to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We don't share
For our affiliates’ everyday business purposes—information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes—information about your creditworthiness	No	We don’t share
For our affiliates to market to you	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

Questions?	For A-Express Remit Pte Ltd, contact contact@aexpressremit.com
Who we are
Who is providing this notice?	A-Express Remit Pte Ltd ,

What we do
How does A-Express Remit Pte Ltd protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does A-Express Remit Pte Ltd collect my personal information?	We collect your personal information, for example, when you Open an account or provide account information Show your government-issued ID or driver’s license or use your credit or debit card Tell us who receives the money or where to send the money Give us your wage statements or your contact information We also collect your personal information from others, such as affiliates or other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes—information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for your rights under state law.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with a A-Express Remit Pte Ltd or Ixaris name.
Non-affiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. A-Express Remit Pte Ltd does not share with non-affiliates so they can market to you.
Joint marketing	A formal agreement between non-affiliated financial companies that together market financial products or services to you. A-Express Remit Pte Ltd does not jointly market.

Other important information
California	We will not share nonpublic personal information we collect about you with non-affiliated third parties except as permitted by California law.
For Vermont Customers	We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information to nonaffiliated third parties to market to you, except as permitted by Vermont law, unless you authorize us to make those disclosures.