Terms and conditions individuals

Who we are and how to read these terms

These Terms and Conditions (the “Terms”) form a binding agreement between you (the “Customer”, “you”, specifically referring to the individual account holder acting in a personal capacity) and Konfido Ltd, a company incorporated in England and Wales (company number 14478524), registered office 30 Welbeck Street, London W1G 8ER, United Kingdom (“Konfido”, “we”, “us”).

Important – what Konfido is. Konfido is not a bank, e-money institution or payment institution and is not authorised or regulated to provide payment, e-money, card or crypto asset services. The regulated financial services described in these Terms are provided to you directly by the licensed Service Providers listed in Annex A, under those providers’ own terms and conditions. Konfido operates the website and app, manages the customer relationship and facilitates your introduction and onboarding to the relevant Service Provider.

These Terms must be read together with: (a) the terms and conditions of each Service Provider that applies to you (Annex A), which you accept when your account is opened; (b) our Privacy Policy; (c) our Complaints Policy; and (d) the Fee Schedule (Annex B). Where a Service Provider’s terms apply to a regulated service, those terms govern that service.

1. Definitions

Term Meaning
Account / Wallet A personal FIAT wallet, crypto wallet and/or card account made available to you by a Service Provider and accessed through the Konfido app or dashboard.
Service Provider A licensed third party that provides a regulated service to you, as listed in Annex A.
Services The financial services provided by the Service Providers (FIAT wallet, crypto wallet/es-Currencies, debit/prepaid card and payment/transfer services) together with Konfido’s introduction, app and support services for individual consumers.
Provider Terms The terms and conditions of a Service Provider, incorporated into this agreement by reference under clause 4 for the services that provider delivers.
es-Currencies Electronic-money units denominated by reference to a fiat currency, issued by the Service Provider identified in Annex A.

2. Eligibility and opening an account

2.1 You must be at least 18 years old and have full legal capacity. The Services under this version of the Terms are offered strictly to consumers (individuals acting for reasons outside their trade, business, craft or profession); availability depends on your country of residence and on the Service Provider competent for that country (Annex A). Statutory consumer protection rights, including the 14-day statutory cooling-off/withdrawal right, apply fully to accounts opened under these individual terms.

2.2 To open an account, you register through the Konfido app/website and provide the personal information and documents required for individual onboarding. Customer due diligence (KYC- Know Your Customer), identity verification and account approval are performed by the Service Provider (Ephelia SwissTech SA), not by Konfido. Konfido pre-screens applications against its risk appetite before submission and relays the outcome to you.

2.3 The account is opened only once the Service Provider approves the application. Konfido and the Service Provider may decline an application, and (subject to applicable law) are not obliged to give reasons.

2.4 By opening an account you confirm that you have read, understood and accepted these Terms and the Service Provider(s) terms applicable to you, as set out in Annex A.

3. The Services and who provides them

Each Service is provided by the licensed Service Provider identified in Annex A on a white-label (“powered by”) basis. Konfido does not hold your funds at any time. Funds are safeguarded by an authorised e-money institution appointed by the Service Provider, as set out in their terms; es-Currencies and supported stablecoins are issued by the issuer identified in Annex A.

Products currently available provided to Konfido by the regulated partners

FIAT Wallet: Payment and transfer services – internal transfers, outbound transfers and currency exchange, provided by the Service Provider. Deposits and withdrawals by bank transfer (SEPA, Faster Payments), card top-up provided by the EMI(s) in Annex A. EEA, UK and CH via Ephelia SwissTech SA;

Products "soon to be available" provided to Konfido by the regulated partners

Crypto Wallet: (es-Currencies and supported stablecoins): UK and CH via Ephelia SwissTech SA as distributor (issuer: Ephelia PS US LLC). Not offered in the European Economic Area.

Debit/Prepaid Card: EEA, UK and CH with Ephelia SwissTech SA as programme manager.

Fees and terms will be notified before activation for the “soon to be available” products.

4. Provider Terms incorporated by reference

4.1 The Provider Terms of each Service Provider applicable to you (Annex A) are incorporated into this agreement by reference and govern the regulated Service that provider delivers. By accepting these Terms of use you confirm you have read, understood and accepted the relevant Provider Terms, which are accessible at the links in Annex A.

4.2 If your country of residence changes and this results in a change of Service Provider; the transfer may take place in accordance with applicable law and the Provider Terms; we will inform you where required. Current services are available to UK, EU and Swiss clients.

5. Fees

Fees for the Services are set out in the Fee Schedule (Annex B) and, where applicable, in the Provider Terms.

5.1 Service Fees. The User agrees to pay Konfido the applicable setup, coordination, and operational fees associated with the selected personal service category as detailed in the Pricing Annex B below. Service fees consist of a one-time structural Setup Fee due upon registration and an Annual Coordination Fee payable in advance of each service term. All fees are strictly net of Value Added Tax (VAT) or applicable local indirect taxes, which shall be calculated and levied based on the Client’s institutional status or country of residence. The set-up and annual fees are non-refundable, except as expressly set out in clause 5.2.

5.2 Cross-Border Coordination Model. The User expressly acknowledges that Konfido’s fee structure is established on a multi-jurisdictional infrastructure coordination model rather than single-account payment volumes. The Annual Coordination Fee guarantees the provision of centralised compliance documentation, global payments relationship maintenance, ongoing periodic reviews, and institutional escalations. Discontinuation, technical freezing, or unilateral closure of an underlying regulated service provider does not invalidate or discharge the User’s payment obligations to Konfido under this agreement, the set-up fee is non-refundable and any refund is based on a pro-rata of the unused annual coordination fee only and triggered solely if the service is unavailable for more than 60 consecutive days.

5.3 Operational Flow & Overages. Each service category encapsulates a baseline tier of monthly transactional routing operations (‘Flow Tier’). Transaction volume executing inside this allocated boundary incurs no incremental charge. Transactional volumes exceeding the baseline monthly allocation will automatically trigger per-unit overage charges as defined in the Pricing Annex B, or can optionally be pre-empted by purchasing specific auxiliary volume packages (‘Boost Packs’) or committing to monthly tier upgrades.

5.4 Payment and Default. Annual fees and initial setup costs are automatically invoiced upon contract execution. Pay-as-you-go transactional overages, continuous monthly upgrades, and Boost Packs will be billed on a recurring monthly cycle or at the point of transactional purchase. Failure to settle outstanding balances within fourteen (14) business days of the invoice date constitutes a material breach of terms, entitling Konfido to suspend service and dashboard access.

6. Your responsibilities and security

6.1 You must keep your security details (passwords, PINs, devices and authentication factors) safe, use the Services lawfully, and provide accurate information. You must notify us and the Service Provider promptly if you suspect loss, theft or unauthorised use.

6.2 You are liable for all losses arising from use of the Services if you have acted fraudulently, or have intentionally or with gross negligence failed to keep your security details safe, to the extent permitted by applicable law and the Provider Terms.

6.3 Where you use the Services to pay a merchant, any dispute about the goods or services is between you and the merchant; Konfido and the Service Provider are not responsible for the merchant’s goods or services but may help by providing transaction details.

7. Suspension, refusal and investigation

7.1 Konfido or the relevant Service Provider may suspend your access to, or refuse to complete, a transaction or Service where there are reasonable security or fraud concerns, suspected unauthorised or unlawful use, insufficient funds, a material breach of these Terms or the Provider Terms, or where required by law. Unless unlawful to do so, you will be told as soon as reasonably practicable, with reasons and how to correct any factual error.

7.2 If an investigation shows a disputed transaction was authorised by you, or that you acted fraudulently or with gross negligence, you may be liable for the resulting losses, including reasonable investigation costs, to the extent permitted by law.

8. Right of withdrawal (cooling-off)

Where applicable under the law of your country of residence, you have 14 days from acceptance of these Terms to withdraw from this agreement without penalty and without giving a reason. Withdrawal does not affect transactions already carried out during the 14-day period. This does not limit any longer or additional rights you have under the mandatory consumer law of your country of residence

9. Changes to these Terms

We and the Service Providers may change these Terms, the Fee Schedule and limits by giving you up to 60 days’ prior notice by durable communication, except where a change is required by law or makes the Terms more favourable to you, in which case it may take effect sooner. The current version is always available in the app/website. If you do not accept a change, you may close your account before it takes effect, free of charge. Konfido and the Customer may vary, rescind or terminate this agreement without the consent of any third party.

10. Term, dormancy, closure and redemption

10.1 This agreement continues until closed by you or by us/the Service Provider. You may close your account at any time, subject to settlement of pending transactions and fees.

10.2 Dormancy. An account with no transactions for 12 months may be treated as dormant; you may be asked to provide refreshed documents, and (where there is no response) the account may be blocked and closed in accordance with the Provider Terms and the Client Account Maintenance Policy.

10.3 Closure by us / the Service Provider. The account may be closed for reasons including risk-appetite, suspicious activity, sanctions/PEP exposure or breach. On closure, the Service Provider reconciles the account, settles fees and remits any remaining balance to an account in your name, and a final statement is provided. Konfido does not hold or remit your funds; it relays instructions and communications.

10.4 Redemption/expiry of es-Currencies and card balances is governed by the Provider Terms.

11. Liability

11.1 Konfido is responsible for its own services (the app, website, introduction and support) with reasonable care and skill. Konfido is not the provider of the regulated Services and is not liable for the provision, execution, safeguarding or availability of those Services, which are the responsibility of the relevant Service Provider under the Provider Terms.

11.2 To the fullest extent permitted by law, Konfido is not liable for indirect or consequential loss, or loss of profit, data or goodwill. Nothing in these Terms excludes or limits liability that cannot be excluded or limited by law, including liability for death or personal injury caused by negligence, for fraud, or under the mandatory consumer-protection law of your country of residence.

11.3 Each service provider may set liability caps dependant on their own Terms of Use.

12. Complaints

12.1 If you have a complaint, contact Konfido first at complaints@konfido.vip. We will acknowledge within 5 business days and aim to send a final response within 8 weeks.

12.2 Where your complaint concerns a regulated Service, it may also need to be handled under the relevant Service Provider’s complaint process and the dispute-resolution/ombudsman scheme applicable to that provider for example the scheme applicable to Ephelia SwissTech SA, which is a financial intermediary affiliated with the self-regulatory organisation Polyreg (not a bank). See Annex A.

12.3 Nothing limits your right to use any dispute-resolution scheme or to take legal action available to you under the mandatory law of your country of residence.

13. Privacy

Personal data is processed in accordance with our Privacy Policy. Onboarding documents are provided to, and verified by, the Service Provider, which acts as controller for customer due diligence. Data may be transferred to Switzerland and other Service-Provider jurisdictions under a lawful transfer mechanism, as described in the Privacy Policy.

14. General

14.1 Intellectual property. All content in the app and website is owned by or licensed to Konfido and may not be reproduced or exploited without consent.

14.2 Third-party links. We are not responsible for third-party sites linked from our app or website.

14.3 Force majeure. Neither party is liable for failure caused by events beyond its reasonable control.

14.4 Severance. If any provision is found unenforceable, the remainder continues in force.

14.5 Assignment. You may not assign your rights without our consent; we may assign or transfer our rights subject to your rights under these Terms and applicable law.

14.6 Entire agreement. This agreement, together with the documents referred to in it (Annex A and the Fee Schedule in Annex B), constitutes the entire agreement between you and Konfido on its subject matter. Nothing in this clause limits or excludes liability for fraud, nor affects your mandatory rights under the consumer-protection law of your country of residence.

14.7 No waiver. No failure or delay by us in exercising any right or remedy under these Terms constitutes a waiver of it, nor does any partial exercise preclude any further exercise.

14.8 Survival. Termination or expiry of these Terms does not affect rights or obligations that have accrued up to that date. Provisions intended by their nature to survive including clauses on accrued fees, liability, privacy, governing law and the FSCS notice continue to apply.

15. Governing law and jurisdiction

5.1 These Terms (including non-contractual matters arising from or connected with them) are governed by the laws of England and Wales, and disputes between you and Konfido fall within the jurisdiction of the courts of England and Wales – without prejudice to clauses 15.2 and 15.3.

15.2 Consumer protection. This choice of law and jurisdiction does not deprive you of the protection of the mandatory consumer-protection rules of the country where you are habitually resident, and you may bring proceedings in the courts of that country where the law so provides.

15.3 Provider services. The governing law and dispute-resolution provisions in each Service Provider’s Provider Terms (Annex A) apply to the Services that provider delivers – in particular, the services provided by Ephelia SwissTech SA are governed by Swiss law.

15.4 Language and translation. In the event that Konfido makes one or more translations of these Terms of Use available to the Customer, such translations will be considered equivalent to the original. In the event of any conflict of interpretation between the English version of these Terms of Use and any translations, the English version will prevail.

16. Legal Disclaimers

16.1 Statutory Consumer Protections: These terms are drafted in accordance with the UK Consumer Rights Act 2015 and the EU Alternative Dispute Resolution (ADR) Directive. No provision within these Terms restricts, excludes, or seeks to modify statutory guarantees or mandatory consumer privileges provided under local municipal legislation.

16.2 Financial Services Compensation Scheme (FSCS) Notice: Konfido is not a licensed credit institution. Your funds are not deposits and are not protected by the UK Financial Services Compensation Scheme (FSCS), the European Deposit Guarantee Schemes Directive (Directive 2014/49/EU) (DGSD), or the Swiss Federal Act on Banks and Savings Banks (Banking Act, Art. 37a) deposit protection scheme (esisuisse). Client funds are safeguarded via isolated, ring-fenced institutional trust accounts maintained by the authorised electronic money institution(s) appointed by the Service Provider, as set out in the Provider Terms (Annex A), in strict compliance with the UK Electronic Money Regulations 2011, the EU Payment Services Directive (Directive (EU) 2015/2366) (PSD2), and applicable Swiss Federal Acts governing non-banking financial intermediaries.

16.3 Limitation of Third-Party Rights: Pursuant to the Contracts (Rights of Third Parties) Act 1999, no individual who is not a direct signatory to this agreement possesses any legal entitlement to enforce its provisions.

Annex A: Service Providers

Term Meaning
Account / Wallet A personal FIAT wallet, crypto wallet and/or card account made available to you by a Service Provider and accessed through the Konfido app or dashboard.
Service Provider A licensed third party that provides a regulated service to you, as listed in Annex A.
Services The financial services provided by the Service Providers (FIAT wallet, crypto wallet/es-Currencies, debit/prepaid card and payment/transfer services) together with Konfido’s introduction, app and support services for individual consumers.
Provider Terms The terms and conditions of a Service Provider, incorporated into this agreement by reference under clause 4 for the services that provider delivers.
es-Currencies Electronic-money units denominated by reference to a fiat currency, issued by the Service Provider identified in Annex A.

Annex B: Fee Schedule (Individual Client)

This Pricing Annex is incorporated into and forms an integral part of the Konfido Terms of Use. All listed prices are net of applicable statutory taxes.

2.1 Baseline Service Categories & Structural Core Fees

Service Category Target Profile Allocation Setup Fee (Year 1) Annual Fee (Advance) Renewal Cost (Year 2+)
Personal International Affluent individuals with multi-jurisdictional assets, assets across multiple borders, and multi-currency compliance needs. €2,500.00 €4,500.00 €4,500.00

2.2 Bundled Transactional Parameters ('Flow Tiers') & Overages

Service Category Target Profile Allocation Setup Fee (Year 1) Annual Fee (Advance) Renewal Cost (Year 2+)
Personal International Affluent individuals with multi-jurisdictional assets, assets across multiple borders, and multi-currency compliance needs. €2,500.00 €4,500.00 €4,500.00

Standard Pay-As-You-Go Overage Fees:

  • Additional SEPA routes are billed at €1.50 per transaction.

  • Additional SWIFT routes are billed at €30.00 per transaction.

  • Foreign Exchange transactions are consistently calculated using a fixed 0.60% FX margin included in the rate provided by the Service Provider and disclosed to you before each transaction.

2.3 One-Off Volume Enhancements ('Boost Packs')

Boost Pack Designation Structural Content Allocation One-off Cost Validity Window
SEPA Boost 50 50 incremental SEPA clearings mapped on top of active monthly allowance €60.00 12 Months
SWIFT Boost 20 20 incremental SWIFT wire routings mapped on top of active monthly allowance €480.00 12 Months
FX Volume Pack 100k Preferential reduction of the FX margin to 0.30% for a maximum aggregate notional ceiling of €100,000.00 €250.00 12 Months
Mixed Pack 30 incremental SEPA clearings + 10 incremental SWIFT wire routings €250.00 12 Months