PUBLIC OFFER

for the provision of money transfer services without opening an account.

This Offer contains the terms and conditions for concluding an Agreement for the provision of money transfer services without opening an account on behalf of an individual using a bank card on the website https://www.aqlupay.com/ (hereinafter referred to as the “Agreement”).

The text of this Offer below is an official public proposal addressed to individuals by “CAMFIELD INVESTMENTS” OOD (hereinafter referred to as the “Platform”) for concluding an agreement for money transfer services.

The Agreement is considered concluded and takes effect from the moment the individual performs the actions provided for in this Offer, which signify their unconditional acceptance of all the terms of this Offer without any exceptions or limitations on the terms of accession.

When jointly referred to in the text of the Agreement, “CAMFIELD INVESTMENTS” OOD and the Sender are referred to as the “Parties.”

The Offer is an official document of “CAMFIELD INVESTMENTS” OOD and is published on the official website https://www.aqlupay.com/.

Terms and Definitions:

• Subscriber Number – the phone number provided by the sender.

• Authorization – the procedure for obtaining permission to conduct transactions using the sender’s electronic payment instrument (including a bank card).

• Authentication Data – the access code to the account on the website https://www.aqlupay.com/, assigned to the Sender during registration and verified using the Subscriber Number used by the Sender.

• Transfer/Payment Currency – the currency in which the Transfer and/or Payment is made.

• Deduction Currency – the currency in which funds are debited from the sender’s electronic payment instrument (bank card) to make the Transfer and/or Payment. The Deduction Currency is the national currency of the Russian Federation.

• Verification – the procedure for verifying the Sender and bank card, conducted by the Operator using secure online payment technology through the 3D Secure security protocol, which includes two-factor authentication by the Sender’s confirmation of the Transfer via a one-time confirmation code sent to the Sender’s phone number.

• Agreement – an agreement concluded in the form of a public offer for the provision of money transfer services without opening an account using the Operator’s website, which includes these Rules and Tariffs and jointly regulates the relationship between the Operator and the Sender, constituting a contract of adhesion in accordance with Article 428 of the Civil Code of the Russian Federation.

• Sender – an individual who conducts a Transfer without opening a bank account.

• Payment Service – a service provided by the Operator of the Payment System allowing the Transfer and/or Payment to the Recipient from the Sender, including cross-border money transfers, in accordance with the Payment System Rules.

• Transfer – actions by the Bank and/or Payment Platform within the framework of applicable forms of non-cash settlements to provide funds from the Payer to the Recipients.

• Payment – actions by the Bank and/or Payment Platform within the framework of applicable forms of non-cash settlements to provide funds from the Payer to the Recipients.

• Recipient – an individual in whose favor the Sender conducts the Transfer and/or Payment.

• Order – an electronic document generated by the Sender in the form of an information message sent to the Bank via the operator, containing the necessary details to make the Transfer and/or Payment.

• Tariffs – the Operator’s fees (commissions) for making Transfers and providing other services.

• Settlement Participants – a term used to jointly refer to individuals either directly involved in non-cash settlements on the Transfers or providing information technology support for these settlements.

• Settlement Participants include operators of money transfers servicing the Sender/Recipients, or the Bank, and may also be referred to as:

• Acquirers – operators of money transfers servicing the Bank in accordance with interbank agreements for money transfers.

• Issuers/Operators – operators of money transfers servicing the Sender/Recipients under an agreement for the use of the corresponding electronic payment instrument.

• Electronic Receipt – an electronic document in the form established by the Bank confirming the money transfer upon the completion of the Transfer / refusal to complete the Transfer.

1. General Provisions

1.1. The Agreement between the Payment Platform and the Sender is concluded under the terms of this Offer.

The text of this Offer (the text of the Agreement) is posted on the website https://www.aqlupay.com/ and provided before the Sender forms the Order. The Sender, before submitting the Order, is required to familiarize themselves with the terms of the Agreement, Rules, and Tariffs and accept the terms of this Offer by marking their agreement with the terms of this Offer (acceptance of the Offer), including the Tariffs. Acceptance of the Offer is any action by the Sender, including registration and performing a transfer.

1.2. The Sender’s acceptance of the terms of this Offer (acceptance of the Offer) means acceptance of the procedure and conditions for conducting money transfers via the Payment Service, which are specified in the Rules posted on the website mentioned above.

1.3. The Agreement concluded under the terms of this Offer is a one-time agreement, meaning it is concluded between the Sender and the Operator for the purpose of making a single Transfer based on one Order.

1.4. The Payment Platform provides the Sender with access to the Payment Service based on the Agreement concluded with the Sender, under which the Payment Platform is responsible for forming and transmitting Orders considering the following features:

• 1.4.1. Data security during transactions using bank cards is ensured according to the accepted security standards for payment services.

• 1.4.2. The responsibility for the security of information messages (notifications) generated and transmitted via the website rests with the Operator, while the Sender, in turn, agrees to use the website functionality for the purposes specified in the Agreement (including consenting to the Payment Platform’s processing of personal data, in whole or in part, and information relevant to the agreement made by the Sender with the Operator for the provision of services).

1.5. The Payment Platform may engage third parties to provide services to the Sender under the Agreement.

1.6. Under the Agreement, the Sender has the right to issue an instruction and create, using the details of an electronic payment instrument (bank card), only such an Order for the Transfer (providing information on the Recipient’s details) as is supported by the website’s functionality, in favor of Recipients.

2. Procedure for Service Provision

2.1. After the Sender gains access to the website through authorization, the Sender is given the opportunity to create and send an Order.

2.2. Using the website, the Sender completes the following steps:

• Logs in to the website by entering their Authentication Data;

• The participants agree on the transaction terms and register it on the platform;

• Fills in the screen forms sequentially to complete the transfer details;

• The Platform monitors the fulfillment of all transaction conditions;

• Confirms their consent to the transfer details, fee amount according to the Tariffs, exchange rate (if applicable), terms of this Offer, and execution of the Transfer under these conditions via SMS.

2.2.1. The online T2T platform (trust-to-trust) operates on principles of mutual trust among participants, who rely on each other for bill payments abroad and money transfers. The platform acts as a guarantor of obligations between participants, ensuring transaction security.

2.3. Based on the results of the Authorizations performed, the Sender is notified of either the registration or refusal of the Order.

2.4. Information on the Transfer fee amount is provided on the website during Order formation and constitutes 9.5%, unless additional fees apply.

2.5. Before confirming the Order, the Sender has the right to cancel the Transfer.

2.6. The Operator is not liable if the Sender makes an error in entering the details of the electronic payment instrument (including the bank card) used by the Sender.

2.7. The payment platform Operator has the right to refuse the Sender in carrying out a Transfer to any Recipient if there are suspicions that the Transfer is made in violation of the legislation of the Russian Federation, the payment system rules, or appears fraudulent. If the Transfer is made in violation of the terms of this Offer/Rules or if there are doubts about the legality of the Sender’s actions, the Operator provides the Sender with information about any restrictions (ability to make Transfers) before the Transfer is made.

2.8. Irrevocability of the Transfer takes effect upon debiting the Sender’s bank account to carry out the Transfer. Finality of the Transfer occurs at the time the funds are received by the Recipient at a specified point in time.

3. Other Conditions

3.1. By agreeing to the terms of this Offer, the Sender confirms their awareness of potential additional risks associated with the website’s operation and Internet connectivity issues. The Sender bears all responsibility for the risks related to storing access data to their personal account on the website and is required to prevent third-party access to their account. Any losses and risks associated with restoring Internet access during Order transmission and other technical failures do not impose any obligations on the Payment Platform.

3.2. The Sender is required to:

• Timely and fully familiarize themselves with and comply with the terms of the Offer;

• Independently monitor the balance of funds on their electronic payment account during Transfers (including ensuring sufficient funds to cover fees as per the Tariffs);

• Verify the information specified in the Order, including the details of the Recipient for the Transfer;

• Independently track changes made to the Offer, Tariffs, and/or Rules.

3.3. All disputes and disagreements arising from this Offer at the Sender’s initiative, including cross-border transfers, are to be considered and resolved within 30 calendar days. If a dispute is not resolved within 60 days from the date the Sender’s claim is received, either Party has the right to bring the dispute to court at the Operator’s location.

3.4. In dispute resolution arising from the Agreement and/or related to website usage for Transfers, the documents confirming the facts claimed by a disputing party are:

• The electronic Order (electronic document);

• The Transfer register containing Transfer information for the billing period;

• The electronic log of the Sender’s actions and related events as recorded by the website’s technical devices and software.

In cases of discrepancies between these documents, the electronic document retained by the Operator or their Acquirer serves as the valid document confirming the Transfer and Agreement terms.

3.5. The Operator may unilaterally amend the Offer, Tariffs, and/or Rules by publishing the updated text on the website. Changes take effect upon publication unless a different effective date is specified in the publication.

3.6. The time of all operations is in Moscow time, determined by the server processing Order information and Transfers, unless another time determination method is agreed upon.

3.7. The relations between the Parties in fulfilling the Agreement are governed by the current legislation of the Russian Federation, the internal documents of the Platform, and this Offer.

3.8. If the Recipient does not receive the Transfer amount due to incorrect details, the funds will be returned to the Sender. In the event of a return due to incorrect Recipient details in the Transfer Order, the commission fee is not refunded to the Sender unless otherwise specified in the Agreement and/or Tariffs.

3.9. The Sender consents to the processing of their personal data, including collection, recording, systematization, accumulation, storage, updating, retrieval, usage, transfer (including dissemination, provision, access, reproduction, electronic copying, and cross-border transfer), anonymization, blocking, deletion, and destruction of personal data, with or without automation, for the purposes of Transfer execution or refund (if necessary). This consent is provided upon the Sender’s signing of the Transfer Order and is valid until revoked in writing by the Sender.

3.10. The Payment Platform is required to maintain the confidentiality of the Sender’s personal data and other information disclosed to the Operator, except when:

• Such information is publicly available;

• Such information is disclosed to Payment Participants as part of the Transfer process according to these Rules;

• Information is disclosed at the request or with the permission of the Sender;

• Disclosure is required by the legislation of the Russian Federation, suspicious transactions, or by requests from the court or authorized government bodies.

3.11. All claims, disputes, and disagreements between the Sender and the Recipient of the funds are resolved independently by them without the involvement of the Payment Platform or the Bank.

4. Restrictions on Money Transfers

4.1. Money transfers without opening a bank account within the Russian Federation or abroad by non-resident individuals in Russian or foreign currency to non-residents are allowed without restrictions, unless otherwise established by the Bank of Russia, the Payment Service, or Russian law.

4.2. Money transfers without opening a bank account in Russian or foreign currency by resident individuals to non-residents within the Russian Federation, or receipt of such transfers by resident individuals from non-residents, are conducted according to the procedures established by the Bank of Russia and Russian law, which may include restrictions on transfer and receipt amounts.

4.3. The Sender may revoke a Transfer before its Irrevocability, unless otherwise conditioned by the form of cashless payment used, involving a Bank as a participant.

4.4. A Transfer revocation is based on a properly completed Sender application in the prescribed form. Cancellation of a Transfer made via the Payment System is subject to the rules of the Payment Systems.

4.5. Transfer cancellation may occur in the following cases:

1. At the Sender’s initiative;

2. In the event of other circumstances preventing the Transfer’s issuance/crediting to the Recipient for reasons beyond the control of the Sender and Recipient.

4.4.1. A Transfer revocation application is accepted by the Operator provided that the Sender presents their passport or other identification document (or identification in the Mobile Application), and provided that the Transfer has not yet been executed at the time of application submission. The Operator provides the application form.

4.5. The refunded Transfer amount is credited to the Sender’s account from which the Transfer was made.

4.6. In the case of a refund, the Transfer is returned to the Sender in the Transfer currency debited from the Sender’s account.

5. Commission Fees

5.1. For the Transfer service, the Payment Platform charges (if established) a commission in accordance with the Tariffs posted on the website. If a commission fee applies, it is calculated as a percentage of the Transfer amount, included in the total Authorization amount debited from the Sender’s bank card, and deducted without additional instructions from the Sender beyond the Transfer amount. Tariff updates are automatically applied, with information on changes also published on the website.

5.2. The Transfer commission amount is disclosed to the Sender during Order processing.

5.3. For Transfers in foreign currency, the commission is charged in the Transfer currency or in Russian rubles at the exchange rate set by the Bank on the day the funds are deposited for Transfer.

5.4. The Tariffs determine whether an additional fee is charged for the refund (cancellation) of a Transfer.

6. Rights and Obligations of the Parties

6.1. The Payment Platform must:

6.1.1. Execute the Transfer Order within 3 business days following the date of receipt.

6.1.2. Provide the Sender with the following information for the Transfer:

• the possible currency for the Transfer;

• the transfer fee according to the Rates;

• any applicable restrictions on sending the Transfer.

6.1.3. Review written inquiries (claims) from the Sender regarding the quality of services within 30 calendar days from the date of receipt of the inquiry (claim) by the Bank, and within 60 calendar days for cross-border transfers.

6.2. The Payment Platform has the right to:

6.2.1. Require the Sender to provide an identification document, as well as any necessary documents and information.

6.2.2. Charge a commission fee for conducting money transfers without opening an account, according to the Rates effective at the time of the Transfer.

6.2.3. Unilaterally modify these Rules, the Agreement, and the Rates and establish new ones, notifying the Sender by publishing the Rules, Agreement, and Rates on the website.

6.2.4. Refuse to execute the Sender’s Transfer Order if there is a suspicion that the operation is conducted for the purpose of money laundering, financing terrorism, or financing the proliferation of weapons of mass destruction, or if it poses reputational risks.

6.2.5. Deny the Sender the ability to send the Transfer amount in cases of:

• unsuccessful Verification results;

• exceeding the transfer limit according to the Rates;

• denial of Authorization (including due to insufficient funds for the Transfer);

• if the purpose of the Transfer relates to business activities by the Sender or contradicts current law;

• if the Transfer Order lacks necessary information for execution, including the Recipient’s details (or contains false information);

• if the Sender has not paid the transfer fee in accordance with the Rates;

• other reasons.

6.3. The Sender must:

6.3.1. Become fully acquainted with the Rules, the Agreement, and the Rates before completing the Transfer.

6.3.2. Provide, upon request:

• documents and information required to identify the Sender

• documents and information justifying the Transfer.

6.3.3. Pay the commission fee in accordance with these Rules, the Agreement, and the Rates at the time of service/providing the operation.

6.4. The Sender has the right to:

6.4.1. Conduct money transfers without opening an account in accordance with these Rules.

6.4.2. Receive necessary information from the Payment Platform as part of the execution of the Transfer Order.

6.4.3. Submit a written inquiry (claim) regarding the quality of the services provided.

6.4.4. Obtain information on the results of the review of the submitted inquiry (claim).

7. Liability of the Parties

7.1. The Payment Platform is not liable for the inability to make the Transfer or delays in execution if such non-performance is caused by reasons beyond the Operator’s control.

7.2. The Payment Platform is not liable when the deposit/disbursement of funds to the Recipient is conducted in violation of the deadlines and other requirements established by Payment System rules, Russian legislation, or the legislation of the foreign state of the Recipient.

7.3. The Payment Platform is responsible for ensuring that the purpose of the Transfer complies with Russian legislation.

8. Dispute Resolution

8.1. In case of a dispute, the Sender has the right to submit an inquiry (claim).

8.2. The Payment Platform provides the Sender with the opportunity to receive information on the results of reviewing submitted claims, including in writing upon request, within 30 calendar days from the receipt of such an inquiry by the Bank, or within 60 calendar days for cross-border transfers.

8.3. All questions, disputes, or claims arising during the provision of the Transfer service or in connection with it must be resolved through negotiations. If it is impossible to resolve disputes through the claims process, the following applies.

8.4. The Parties recognize that data received via electronic document exchange, electronic information, and electronic documents generated using the website, as well as the software and hardware systems of the Bank, Payment Systems, and Settlement Participants involved in providing Transfer services, will be accepted as evidence in dispute resolution, including in court proceedings.