Effective for MITOcrowd depositors

1. About MITOcrowd

1.1 MITOcrowd is a fixed-term deposit and crowdfunding platform operated in connection with MITOmoney, a trading name of Funtech Global Communications Ltd (company number 07979772), authorised and regulated by the UK Financial Conduct Authority (FCA) for payment services (FRN: 815146, MLR NO: 12803115).

1.2 MITOcrowd allows verified depositors to fund a general pool by placing fixed-term deposits in a personal wallet. Deposits earn simple, non-compounding interest on the principal for the chosen lock period. Money movement (collection and payout) is processed through MITOmoney’s regulated payment infrastructure.

1.3 These MITOcrowd Deposit Terms apply specifically to your use of the deposit, interest, rollover, and payout features on MITOcrowd. They are read together with the MITOcrowd Risk Disclosure, MITOmoney Payment Services Terms, and MITOmoney Privacy Policy. If there is a conflict between these Deposit Terms and the payment-services terms, these Deposit Terms govern your deposit relationship on MITOcrowd.

2. Eligibility & onboarding

2.1 You must be at least 18 years old and legally capable of entering a binding agreement.

2.2 Before making a deposit you must verify your email address and mobile phone number, complete Know Your Customer (KYC) checks (which may be processed via MITOmoney), register a verified bank account for payouts, and accept the current legal document bundle.

2.3 We may refuse or suspend access if verification fails, information is inaccurate, or we suspect fraud, money laundering, or breach of these terms.

3. Deposits & lock periods

3.1 Each deposit is a separate transaction with its own principal, annual interest rate, lock term, and maturity date. Multiple deposits may exist in the same wallet.

3.2 Available lock terms are currently: 3 months, 6 months, 9 months, 12 months. The minimum deposit is ₦1,000.

3.3 Once funded, principal is locked until maturity unless an early payout is approved under clause 6. You cannot transfer funds out of MITOcrowd yourself; this restriction is a deliberate security control.

3.4 Deposited funds are pooled to support MITOcrowd’s general funding activities. Your entitlement is to repayment of principal (subject to these terms) plus accrued simple interest, not to any specific underlying asset.

4. Interest

4.1 Interest is simple and non-compounding. It accrues only on the original principal of each deposit, not on previously credited interest.

4.2 The annual interest rate depends on the lock term you choose. Longer commitments may earn a higher rate. The rates in effect at the time you create a deposit are:

• 3 months: 10% p.a.
• 6 months: 10% p.a.
• 9 months: 10% p.a.
• 12 months: 10% p.a.

4.2.1 The rate applicable to your chosen term is locked for that deposit for its full duration. Changes to platform rates (including promotional rates) apply only to deposits created after the change; existing deposits are never affected.

4.3 Interest is calculated and credited to your wallet daily, on a 365-day-year basis. Each completed day earns interest equal to: principal × (annual rate ÷ 365). Interest accrues only during the lock term and never beyond the maturity date.

4.4 You will receive interest update notifications (in-app, and by email if you opt in) showing wallet totals and per-deposit breakdowns. You can choose to receive these updates daily, weekly, or monthly in your notification preferences. Accrued interest is included in your payout quote at maturity or on approved early withdrawal.

5. Fees at payout

5.1 Payouts at or after your deposit’s maturity date are free of any transaction (transfer) fee. You receive your principal plus accrued interest, less only any withholding tax required by law.

5.2 A transaction (transfer) fee applies only to early withdrawals (funds paid out before the maturity date). The fee depends on the deposit’s lock term:

• lock term under 6 months: 2%;
• lock term of 6 to 12 months: 1%;
• lock term over 12 months: 0.333%.

5.3 Where charged, the fee is calculated on the amount being withdrawn at the time of payout.

6. Maturity, rollover & payouts

6.1 At maturity you may request payout of principal and accrued interest (less applicable fees and taxes) to your pre-verified bank account, or roll the deposit into a new term.

6.2 If you enable auto-rollover, we may automatically roll a matured deposit into a new term on your behalf using the options you selected, unless you instruct otherwise before maturity.

6.3 You cannot initiate a bank transfer from your MITOcrowd interface. All payouts are reviewed and initiated by authorised administrators and processed via MITOmoney. This protects depositors from unauthorised outbound transfers.

6.4 Payouts are made only to the verified bank account on your profile. We are not responsible for delays caused by incorrect bank details you supplied.

7. Early withdrawal

7.1 Before the agreed maturity date you may request to withdraw all or part of the current value of an individual deposit (its principal plus interest accrued to date). Early withdrawals are subject to administrator review and approval and are not guaranteed.

7.2 If an early withdrawal is approved, an early-withdrawal penalty of 5% applies in addition to the transaction fee in clause 5, and any withholding tax on the interest portion. These charges are calculated on the amount you choose to withdraw, and the net amount payable to you is shown before you confirm.

7.3 The penalty and transaction fee are charged on each withdrawal transaction. If you make several separate withdrawals from the same deposit, the charges apply each time. Where you withdraw only part of a deposit, the remaining balance stays locked and continues to earn interest until its original maturity date.

7.4 Withdrawal requests are processed to your verified bank account after administrator authorisation, ordinarily within two working days. Until authorised and transferred, the requested amount is shown as “in transfer” and cannot be withdrawn again.

8. Statements & records

8.1 We maintain a double-entry ledger of all money in and out. You may access periodic statements through your account.

8.2 Interest updates and maturity reminders may be sent in-app and by email according to your notification preferences.

9. Referrals

9.1 MITOcrowd may offer a referral programme. Referral codes are for personal invitation only and must not be used for spam or misleading marketing. We may modify or withdraw the programme at any time.

10. Your responsibilities

10.1 You must keep your login credentials secure. Optional two-factor authentication (2FA) is available and recommended.

10.2 You must provide accurate personal, KYC, and bank information and notify us of material changes.

10.3 You must not use MITOcrowd for money laundering, terrorist financing, fraud, or any unlawful purpose.

11. Limitation of liability

11.1 MITOcrowd and MITOmoney do not guarantee any minimum return. Your deposit is subject to the risks described in the Risk Disclosure.

11.2 To the fullest extent permitted by law, we are not liable for indirect or consequential loss, or for failure caused by events outside our reasonable control. Nothing in these terms excludes liability for death or personal injury caused by negligence or for fraud.

12. Changes & governing law

12.1 We may update these Deposit Terms. Material changes will be communicated and may require your re-acceptance before further deposits.

12.2 These terms are governed by English law. Disputes are subject to the exclusive jurisdiction of the English courts, without prejudice to mandatory consumer protections in your country of residence where applicable.

13. Contact

Questions about your MITOcrowd deposit: help@mito.money · +44 (0) 208 731 4574

Funtech Global Communications Ltd, Devonshire House, Manor Way, Borehamwood, Hertfordshire, WD6 1QQ, United Kingdom.

Important — please read carefully

Depositing through MITOcrowd involves financial risk. You should not deposit money you cannot afford to lock away for the full term, and you should seek independent advice if you are unsure whether this product is suitable for you.

1. Not a bank savings account

MITOcrowd is a fixed-term deposit and crowdfunding arrangement, not a traditional bank savings account. Your funds are not covered by the UK Financial Services Compensation Scheme (FSCS) or equivalent deposit-insurance schemes. Repayment of principal and payment of interest depend on the continued operation of MITOcrowd and MITOmoney.

2. Capital at risk

The value of your deposit and any accrued interest could be affected if the platform, its operators, or counterparties experience financial difficulty, insolvency, fraud, or operational failure. You may lose part or all of your deposited capital.

3. No guaranteed returns

Advertised or historical interest rates do not guarantee future performance. The annual rate is fixed per deposit at the time it is created, but the platform rate for new deposits may change. Interest projections shown in the app are estimates only.

4. Liquidity & lock-up

Funds are locked for the term you select (minimum 3 months). You should assume you will not have access to your money until maturity. Early withdrawal is discretionary, may be refused, and if granted will attract penalties and fees that reduce your payout.

5. Fees, penalties & tax

Transaction fees apply on payout. Early-withdrawal penalties apply if funds are released before maturity. Withholding tax or other duties may reduce the interest you receive. Fee and tax rates are disclosed in the Deposit Terms and may change for future activity.

6. Pooled funding risk

Deposits are pooled to fund MITOcrowd’s general activities. You do not acquire a charge over specific assets. Your rights are contractual against the platform, not ownership of underlying investments.

7. Operational & technology risk

System outages, processing delays, cyber incidents, or third-party payment failures could delay deposits, interest accrual notifications, or payouts. While we use security controls (including optional 2FA and admin-approved payouts), no system is immune from attack or error.

8. Regulatory & legal risk

Laws governing deposit-taking, crowdfunding, tax, and cross-border payments may change. MITOmoney is FCA-authorised for payment services; MITOcrowd deposit-taking may be subject to additional licensing requirements in your jurisdiction. It is your responsibility to ensure participation is lawful where you live.

9. Third-party & concentration risk

Collection and payout of funds rely on MITOmoney and its banking partners. Failure or delay by any partner could affect your ability to deposit or receive funds.

10. Acknowledgement

By accepting the legal document bundle and making a deposit, you confirm that you understand these risks, have had the opportunity to read the MITOcrowd Deposit Terms, and accept that you are solely responsible for your decision to participate.

If you have questions, contact help@mito.money before depositing.

Mito.Money's Terms of Use

Contract Formation & Overview

1.1 These Terms and Conditions govern the terms under which you may access and use this website and the services associated with it (together, the “Service”). By accessing, registering with and using the Service, you agree to be bound by the terms of the Terms and Conditions. If you do not wish to be bound by the Terms and Conditions do not access, register with or use the Service. The language of these Terms and Conditions is English and all Services, instructions and transactions carried out in connection with it shall be in English.

1.2 In these Terms and Conditions, the terms “Mito.Money”, “we”, “us”, and “our” refer to Mito.Money, together with its employees, directors, affiliates, successors, and assigns.

Mito.Money™ is a trading name for Funtech Global Communications Ltd UK company registration number 07979772 in England and Wales, with its registered office at Devonshire House, Manor way, Borehamwood, Herts, WD6 1QQ. Funtech is Authorised and Regulated by the Financial Services Authority (FCA) under the Payment Service Regulations 2009 for the provision of payment services. Registration details: FRN: 815146 MLR NO: 12803115

1.3 The terms “you” and “your” refer to users of the Service, whether in their capacity as Senders, Recipients, or visitors to this website.

1.4 These Terms and Conditions are effective from 11 February 2016. The Terms and Conditions may change from time to time, but changes will only be effective from the date they are made and will not change the terms on which you previously used the Service.

1.5 The Service was created to assist customers to send money to their family and friends, and to receive money from family and friends, around the world. For security reasons, we recommend that you only send money through the Service to people you know personally. You must not use the Service to send money to strangers for example sellers of goods and/or services, private or retail.

Definitions

In this Terms and Conditions:

2.1 “Destination Country” means the country in which the Recipient receives money through the Service.

2.2 “Local Taxes” means any taxes or charges payable in the Destination Country.

2.3 “Payment Instrument” means a valid instrument of payment such as a bank account, debit card or credit card.

2.4 “Payout Amount” means the amount paid out to the Recipient, after any foreign exchange conversion and excluding Local Taxes.

2.5 “Recipient” means someone who receives money through the Service.

2.6 “Sender” means someone who uses the Service to send money.

2.7 “Service Fee” means the fee plus any additional charges applicable to each Transaction.

2.8 “Service Provider” means a local bank, money exchange house, or other third party service providers in the Destination Country with whom Mito.Money works in providing the Service.

2.9 “Transaction” means a specific instruction to send money through the Service.

2.10 “Transaction Amount” means the amount of money that the Sender wishes to send to the Recipient, excluding any applicable fees and prior to any foreign exchange conversion.

Our Obligations

3.1 Subject to these Terms and Conditions, we agree to provide the Service to you using reasonable care. The Service may not be available in whole or in part in certain regions, countries, or jurisdictions.

3.2 We are not obliged to process any particular Transaction. When you submit a Transaction, you are requesting that we process the Transaction on your behalf. We may, in our sole discretion, choose whether or not to accept the offer to process that Transaction. However, if we decide not to process the Transaction, we will notify you promptly of that decision and repay the money paid to us.

Your Obligations

4.1 You agree to provide true, accurate, current, and complete information about yourself as requested by us during the registration or Transaction process. You also agree to update this information as required to keep it true, accurate, current, and complete.

4.2 You agree to comply with all applicable laws, regulations, and guidelines, including but not limited to financial regulations in the countries where you send and receive money.

4.2.1 we reserve the right to apply a convenience fee for processing credit cards in certain jurisdictions at our discretion;

4.3 in connection with your registration and use of the Service, you will:

4.3.1 provide us with true, accurate, current and complete evidence of your identity, and promptly update your personal information if and when it changes;

4.3.2 provide our merchant with details of one or more Payment Instruments; and

4.3.3 provide us with true, accurate, current and complete information for all Transactions. We do not accept any liability for damages resulting from non-payment or delay in payment of a money transfer to a Recipient or failure to perform a transaction under the Service by reason of any of these matters.

4.4 when you pay for a Transaction in one currency and the Recipient is paid in another currency, there will be a difference between the exchange rate at which we buy foreign currency and the exchange rate provided to you. Mito.Money and its Service Providers usually make a small profit in these circumstances. If such account is denominated in another currency the amount to be received by the Recipient will be reduced by the amount of extra charges incurred by reason of the incorrect information given by you and we will have no obligation to make good such reduction.

4.5 when you are sending money under these Terms and Conditions, it is your responsibility to make sure all the Transaction details are accurate before submission. Once a Transaction has been submitted for processing it is not normally possible to change any of its details. You will be given the opportunity to confirm Transactions before submission and you must check the details carefully.

4.6 Mito.Money will have no responsibility for any fees or charges you may incur by the use of a particular Payment Instrument to fund a Transaction. These may include but are not limited to unauthorised overdraft fees imposed by banks if there are insufficient funds in your bank account or “cash advance” fees and additional interest which may be imposed by credit card providers if they treat use of the Service as a cash transaction rather than a purchase transaction.

4.7 you will only use the Service to send money to people that you know personally and not to pay for goods or services. If, in breach of this clause, you choose to pay third parties for goods and services using the Service, you acknowledge that Mito.Money has no control over, and is not responsible for, the quality, safety, legality, or delivery of such goods or services and that any such use of the Service is entirely at your own risk. If Mito.Money reasonably believes you are using the Service to purchase goods or services, we reserve the right to cancel your Transaction(s).

4.8 both you and the Recipients will only act on your own behalf. You may not submit or receive a Transaction on behalf of a third person. If you intend to submit or receive a Transaction on behalf of a company, business or any entity other than a human individual, you must first inform Mito.Money of your desire to do so and provide us with any additional information about the entity we may request in order that we may decide whether to permit the Transaction.

4.10 when using our website or the Service or when interacting with Mito.Money, with another user or with a third party, you will not:

• 4.10.1 breach this Terms and Conditions, or any other agreement between you and Mito.Money;
• 4.10.2 open more than one account, without our prior written permission;
• 4.10.3 provide false, inaccurate, or misleading information;
• 4.10.4 allow anyone else access to your registration details, and will keep those details secure;
• 4.10.5 refuse to provide confirmation of any information you provide to us, including proof of identity, or refuse to co-operate in any investigation;
• 4.10.6 use an anonymising proxy (a tool that attempts to make activity untraceable); or
• 4.10.7 copy or monitor our website using any robot, spider, or other automatic device or manual process, without our prior written permission.

4.11 Mito.Money may, as necessary in providing the Service, store all information required of a Recipient to prove his or her identity or associated with their specific Transaction. Such proofs may include a suitable form of valid, unexpired identification from a list of acceptable papers provided by the Service Provider, and/or a Transaction tracking number, a personal identification number (PIN), a “password”, a “secret word”, or other similar identifiers.

Cancellation & Refunds

5.1 If you have any problems using the Service you should contact us through the channels listed at the end of this Terms and Conditions.

5.2 You have the statutory right to cancel your agreement with us after you have submitted a transaction. This right of cancellation continues until fourteen days after you have submitted the transaction, or until we have completed the contract by paying the Pay-out Amount to the Recipient, whichever is the earlier. If you exercise your right to cancel under this clause, we may make a cancellation charge.

5.3 If you wish to exercise your right to cancel under this clause, you must submit a written request to one of the contact points listed at the bottom of this Terms and Conditions, giving the Sender's full name, address, and phone number, together with the Transaction tracking/reference number, Transaction Amount, and the reason for your refund request.

5.4 Any refunds will be credited back to the same Payment Instrument used to fund the Transaction and in the same currency. No adjustment will be made for any currency fluctuations, which may have occurred in the meanwhile.

5.5 Refunds once approved are initiated on the same business day but could take 2-5 working days to reflect in your account.

Collection of Information

6.1 Customer Identification Program. UK law requires all financial institutions to assist in the fight against money laundering activities and the funding of terrorism by obtaining, verifying, and recording identifying information about all customers. We may therefore require you to supply us with personal identifying information and we may also legally consult other sources to obtain information about you.

6.2 Verification and Checks. We will verify your residential address and personal details in order to confirm your identity. We may also pass your personal information to a credit reference agency, which may keep a record of that information. You can be rest assured that this is done only to confirm your identity, that a credit check is not performed and that your credit rating will be unaffected. All information provided by you will be treated securely and strictly in accordance with the Data Protection Act 1998.

6.3 By accepting these Terms and Conditions you authorise us to make any inquiries we consider necessary to validate the information that you provide to us. We may do this directly, for example by asking you for additional information, requiring you to take steps to confirm ownership of your Payment Instruments or email address; or by verifying your information against third party databases; or through other sources.

6.4 Data Privacy Policy. You consent to our processing your personal information for the purposes of providing the Service, including for verification purposes as set out in this clause. You also consent to the use of such data for communicating with you, and for statutory, accounting and archival purposes. You acknowledge that you have read and consented to Mito.Money's Data Privacy Policy.

6.5 Government Disclosures. We may be required by law to provide information about you and your Transactions to government or other competent authorities as described in our Data Privacy Policy. You acknowledge and consent to our doing this.

Intellectual Property Rights

7.1 The Mito.Money website and the Mito.Money Service, the content, and all intellectual property relating to them and contained in them (including but not limited to copyrights, patents, database rights, trademarks and service marks) are owned by us, our affiliates, or third parties. All right, title and interest in and to the Mito.Money Online Site and the Mito.Money Online Service shall remain our property and/or the property of such other third parties.

7.2 The Mito.Money website and the Mito.Money Service may be used only for the purposes permitted by these Terms and Conditions or described on this website. You are authorized solely to view and to retain a copy of the pages of the Mito.Money website for your own personal use. You may not duplicate, publish, modify, create derivative works from, participate in the transfer or sale of, post on the internet, or in any way distribute or exploit the Mito.Money website, the Mito.Money Service or any portion thereof for any public or commercial use without our express written permission. You may not: (a) use any robot, spider, scraper or other automated device to access the Mito.Money website or the Mito.Money Service; and/or (b) remove or alter any copyright, trademark or other proprietary notice or legend displayed on the Mito.Money website (or printed pages of the website). The name Mito.Money and other names and indicia of ownership of Mito.Money's products and/or services referred to on the Mito.Money website are our exclusive marks or the exclusive marks of other third parties. Other product, service and company names appearing on the website may be trademarks of their respective owners.

Warranties & Liability

8.1 We will refund to you any benefit, which we receive as a result of any breach of our agreement with you (this means that, for example, where a money transfer has failed in such circumstances we will refund to you the Transaction Amount and the Service Fee).

8.2 If a money transfer is delayed or fails, you may have a right to receive a refund under laws relating to the provision of international money transfer services. We will provide you with the details of your rights to a refund if you contact us using the contact details at the end of this agreement.

8.3 Any claim for refund made by you and/or a Recipient (who is not registered with us) must be supported by any available relevant documentation.

8.4 If any loss which you or a Recipient (who is not registered with us) suffers is not covered by a right to payment under the laws referred to in clause 8.2, we will only accept liability for that loss up to a limit which is the greater of: (a) the amount of any service charge; and (b) €500, unless otherwise agreed by us in writing. Our cap on our liability only limits a claim for loss arising out of any single transaction or related transactions, or (if a loss does not arise out of a transaction or transactions) any single act, omission or event or related acts, omissions or events. This means that if, for example, you suffer loss by reason of our failure to perform our agreement with you under two unrelated transactions, you might be able to claim up to €1000.

8.5 We do not, in any event, accept responsibility for:

• 8.5.1 Any failure to perform your instructions as a result of circumstances which could reasonably be considered to be outside our control;
• 8.5.2 Malfunctions in communications facilities which cannot reasonably be considered to be under our control and that may affect the accuracy or timeliness of messages you send to us;
• 8.5.3 Any losses or delays in transmission of messages arising out of the use of any internet service provider or caused by any browser or other software which is not under our control;
• 8.5.4 Errors on the website or with the Service caused by incomplete or incorrect information provided to us by you or a third party.

8.6 Nothing in this clause 8 shall (a) exclude or limit liability on our part for death or personal injury resulting from our negligence; or (b) exclude liability for our fraud.

8.7 Where you are sending a money transfer to a Recipient who is not registered with us, you agree to accept the provisions of this clause 8 not only for yourself, but also on behalf of the Recipient.

8.8 Your relationship is with Mito.Money only. You agree that no affiliate or agent of Mito.Money owes you any duty of care when performing a task which would otherwise have to be performed by Mito.Money under its agreement with you.

8.9 You agree to indemnify and hold harmless Mito.Money, our subsidiaries, affiliates, officers, directors, employees, agents, independent contractors, advertisers, partners, and co-branders from all loss, damage, claims, actions or demands, including reasonable legal fees, arising out of your use or misuse of this website or Service, all activities that occur under your password or account email login, your violation of this Terms and Conditions or any other violation of the rights of another person or party.

Electronic Communications

9.1 You acknowledge that this Terms and Conditions shall be entered into electronically, and that the following categories of information (“Communications”) may be provided by electronic means:

• 9.1.1 This Terms and Conditions and any amendments, modifications or supplements to it.
• 9.1.2 Your records of transactions through the Service.
• 9.1.3 Any initial, periodic or other disclosures or notices provided in connection with the Service, including without limitation those required by law.
• 9.1.4 Any customer service communications, including without limitation communications with respect to claims of error or unauthorised use of the Service.
• 9.1.5 Any other communication related to the Service or Mito.Money.

9.2 The Service does not allow for Communications to be provided in paper format or through other non-electronic means. You may withdraw your consent to receive Communications electronically, but if you do, your use of the Service shall be terminated. In order to withdraw your consent, you must contact us using our contact information at the end of this Terms and Conditions.

9.3 In order to access and retain Communications, you must have or have access to the following:

• 9.3.1 An Internet browser that supports 128-bit encryption, such as Internet Explorer version 4.0 or above.
• 9.3.2 An email account and email software capable of interfacing with Mito.Money's e-mail servers.
• 9.3.3 A personal computer, operating system and telecommunications connections to the Internet capable of supporting the foregoing.
• 9.3.4 Sufficient electronic storage capacity on your computer's hard drive or other data storage unit.
• 9.3.5 A printer that is capable of printing from your browser and e-mail software. In addition, you must promptly update us with any change in your email address by updating your profile at www.Mito.Money.

Termination

10.1 Either party may terminate these Terms and Conditions on one day's written notice.

10.2 We may terminate this Terms and Conditions with immediate effect if you:

• 10.2.1 become, or are likely to become, insolvent or are declared bankrupt;
• 10.2.2 are in breach of any provision of this Terms and Conditions;
• 10.2.3 your use of the Service or the website is disruptive to our other customers, or you do anything which in our opinion is likely to bring us into disrepute;
• 10.2.4 breaches or attempts to breach the security of the website (including but not limited to: modifying or attempting to modify any information; unauthorised log-ins, unauthorised data access or deletion; interfering with the service, system, host or network; reverse engineering of any kind; spamming; hacking; falsifying data; introducing viruses, Trojan horses, worms or other destructive or damaging programs or engines; or testing security in any way);

Complaints

11.1 If you wish to make a complaint about any aspect of the Mito.Money service, please send your complaint in writing to the address shown on the Contact Us page or use our contact form on this website.

11.2 We will acknowledge receipt of your complaint within 5 business days. We will investigate your complaint and come back to you with the results of our investigation no later than 10 business days of receipt of your complaint. If you are not satisfied with the manner in which we have dealt with your complaint, or the outcome, then you may refer the matter to the Financial Ombudsman Service, South Quay Plaza, 183 Marsh Wall, London E14 9SR, Tel No 08000234567, Email: complaint.info@financial-ombudsman.org.uk

General

12.1 Governing law: this Agreement will be governed by English law and the parties submit to the exclusive jurisdiction of the English Courts.

12.2 No Waiver: The failure of Mito.Money to exercise or enforce any right or provision of the Terms and Conditions shall not constitute a waiver of such right or provision.

12.3 Modification: We may modify this Terms and Conditions from time to time without notice to you, except as may be required by law. You can review the most current version of the Terms and Conditions at any time by reviewing this website. You may terminate your use of the Service if you do not agree with any modification or amendment. If you use the Service after the effective date of an amendment or modification, you shall be deemed to have accepted that amendment or modification. You agree that you shall not modify these Terms and Conditions and acknowledge that any attempts by you to modify these Terms and Conditions shall be void.

12.4 Entire Agreement: This agreement constitutes the entire agreement between the parties and supersedes all prior understandings or agreements relating to the subject matter of this agreement.

12.5 Severability: If any provision of the Terms and Conditions is found by an arbitrator or court of competent jurisdiction to be invalid, the parties nevertheless agree that the arbitrator or court should endeavour to give appropriately valid effect to the intention of the Terms and Conditions as reflected in the provision, and the other provisions of the Terms and Conditions shall remain in full force and effect.

12.6 Any external links to third-party websites on the website are provided as a convenience to you. We do not control these sites in any way and we are not responsible for the accuracy, completeness, legality or any other aspect of these other sites including any content provided on them. You access such websites at your own risk.

Security

We take security very seriously at Mito.Money, and we work hard, using state-of-the-art security measures, to make sure that your information remains secure. The Mito.Money Service is a safe and convenient way to send money to friends and family and to other people that you trust. However, we do advise you to consider very carefully before sending money to anyone that you do not know well.

If you are aware of anyone or any entity that is using the Service inappropriately, please email us using our contact form. Similarly, if you receive any emails, purporting to be from Mito.Money, which you suspect may be “phishing” (fake) emails, please forward them to us using our contact form.

Contact Information

Questions, notices, and requests for refunds or further information should be sent to Mito.Money, as follows:

By Email: help@mito.money

By telephone/WhatsApp: +44 (0) 208 731 4574

By post: Mito.Money C/O Funtech Global Communications Ltd, Devonshire House, Manor Way, Borehamwood, Hertfordshire, WD6 1QQ.

Last updated: 21/05/2018

Trust and security are a big part of what makes Mito.Money the best way to send money internationally.

Your privacy is very important to us, so we’d like to tell you what we do to keep your data safe and secure.

In this policy, we explain how Mito.Money collects, manages, uses, and protects your data.

What is Mito.Money?

Mito.Money is an online money transfer service with the mission to make life easier for everyone transferring money around the world.

Mito.Money is a trademark owned by Funtech Global Communications Ltd. A registered payment institution in the UK with registration details FRN: 815146 MLR NO: 12803115. Mito.Money is powered by Funtech’s Universal Remittance Portal (FURP), which is built to manage cross-border payments and aggregate multiple payment partners worldwide.

In this Privacy Policy, terms such as “we”, “us” and “Mito.Money” refer to Funtech Global Communications Ltd (Company Number 07979772) with its registered office located at Devonshire House, Manor way, Borehamwood, Hertfordshire, WD6 1QQ, United Kingdom.

The term “Service” refers to money transfers enabled from our website.

In the language of data protection regulation, Mito.Money is the “data controller” of your personal data and you, our customer, are the “data subject”. This means that Mito.Money determines the purposes and means of processing your personal data, while respecting rights concerning your privacy.

What data do we collect?

Like most companies, we collect various types of data about our customers. Some of it may be considered personal data, which means data that makes you identifiable as an individual.

As a regulated financial institution, we are bound by the legal requirement to collect, verify, and record certain data about you or recipients of your transactions. All types of data we gather may be used to prevent or detect crime.

We may collect and use the following data:

Basic personal data, such as (but not limited to):

• Date of birth
• Address
• Phone number
• E-mail address

This data is necessary for Mito.Money to provide the Service to you. We will request this data when you sign up, before the Service is provided.

Data for ‘Know Your Customer’ (KYC) regulations, such as (but not limited to):

• Proof of your identity, like a passport, driving licence, national ID card or residence permit
• Proof of your address, like a utility bill or bank statement
• Additional details on the source of funds being sent, like a payslip, credit card statement, tax rebate receipt or bank loan agreement

This data will sometimes be needed to conduct Know Your Customer (KYC), Customer Due Diligence (CDD), and security checks, as required by local and international regulations. This helps us keep your money safe, and we will only request these details when necessary.

Data from other third-party sources, such as (but not limited to):

• Facebook, Twitter or Google profile images and names
• Banks and payment service providers used to transfer money to us
• Advertising networks
• Search engines providers (such as Yahoo.com or Google)
• Credit reference agencies

Mito.Money collects this data only when you provide the relevant permission to social media sites.

Technical data, such as (but not limited to):

• Page views
• App downloads
• Operating system
• Browser type

This data is used to help us to understand how you use our Service, so that we can improve it.

Why do we collect your data?

We collect your data to personalise and improve our service for you. The specific purposes for which we collect your data include:

Transactional purposes

We need to collect data in order to process your transactions. Without data such as you and your beneficiaries' bank account details or full name and address, we would be unable to transfer money for you.

Regulatory purposes

As regulated financial institutions, both Mito.Money and our partners are required to conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) checks. These help prevent money laundering and fraud.

These include our requirements under Anti Money Laundering (AML) and Counter Terrorist Financing (CTF) legislation. All of this helps us keep our Service safe and secure.

Marketing purposes

We may process your personal data to provide you with certain types of marketing communication that we believe will be relevant and of interest to you. This helps us provide you with a more personalised service. This kind of activity is permitted by our ‘legitimate interest’ (for more information on legitimate interest, please see Section 8 of this Policy). We will always endeavour to make these communications relevant and un-intrusive, and you are able to object to marketing communication from us at any time.

Analytical purposes

We may collect and analyse data such as website or app visit logs to improve the quality of our service.

You do not have to disclose any of the above data to us. However, if you choose to withhold certain data, we may not be able to provide you with our Service.

How do we keep your data safe and secure?

All the data that you provide to us is encrypted on our secure servers. We restrict access to your data to specific employees of Mito.Money who have an important business-related reason for handling it. Our communications are encrypted using encryption technologies which are based on standard algorithms such as DES, RSA and IDEA. These algorithms represent the actual cipher used for an approved application. For example, Secure Socket Layer (SSL) uses RSA encryption.

All the data we collect from you or from other sources will always be stored in accordance with this Privacy Policy.

Definitions

An algorithm is a procedure or formula for solving a problem. A computer program can be viewed as an elaborate algorithm.

A cipher is any method of encrypting data (concealing its readability and meaning).

Data is defined as any information within the organisation’s purview, including customer record data, personnel data, financial data (budget and payroll), departmental administrative data, legal files, research data, proprietary data, and all other data that pertains to, or supports the administration of the organisation.

Data Encryption Standard (DES) is a widely used method of data encryption using a private (secret) key.

Electronic Information Resources include data, networks, computers, and other devices that store, or display data, communications devices, and software used on such devices.

International Data Encryption Algorithm (IDEA) is an encryption algorithm developed at ETH in Zurich, Switzerland. It uses a block cipher with a 128-bit key and is generally considered to be very secure. It is considered among the best publicly known algorithms.

Rivest-Shamir-Adleman (RSA) is an Internet encryption and authentication system that uses an algorithm developed in 1977 by Ron Rivest, Adi Shamir, and Leonard Adleman. The RSA algorithm is the most commonly used encryption and authentication algorithm and is included as part of the Web browsers.

How long do we keep your data?

Depending on what purpose your data is used for, the length of time we keep it may vary. Either way, we will only hold your data if necessary, to serve the purpose it is used for.

Regulatory

We are legally required to keep the data obtained for Know Your Customer (KYC), Customer Due Diligence (CDD) and security purposes (including transaction records and our communications with you) for at least five years after the most recent transaction.

Legitimate Interest

When the five years’ retention period and/or legitimate interest no longer apply, we will remove your data from our system. For more information on legitimate interest, please see Section 8 of this Policy.

Consent

In situations where you give us specific consent to process certain kinds of data, you can withdraw that consent at any time. We will then stop processing your data and, if the five years’ retention period and/or legitimate interest retention period does not apply, we will also erase your data from our system.

We may retain any data mentioned above for a longer period, if required to protect the rights, property or safety of Mito.Money or of the Service provided by us or our partners.

Who do we share your data with?

We share your personal data with third parties only when it is necessary for the fulfilment of the Service or to comply with applicable laws.

We will never sell your personal data to other organisations.

We work with partners who help us to complete your transactions. If they are based outside the EEA, we will share your personal data with them only when they apply essential safeguards, or if it has been established by EU institutions that the relevant country has an appropriate data protection regime in place, or when we otherwise ensure that the appropriate level of protection is applied for data processing.

The following are some purposes for which we may share your data with third parties:

To fulfil the contract between you and Mito.Money

We may share your data with third parties, such as our partners and intermediaries, when they are necessary for the fulfilment of the Service.

When required by law

We may share your data when required by law, for example for the purposes of security, taxation and criminal investigations.

For marketing and communication

We may share your data with third parties such as providers of customer service tools, marketing campaign tools, email communication tools, analytics software (for marketing purposes) and data visualisation tools (for analytical purposes).

If we sell or buy any business or assets, we may be obliged to share your personal data with the prospective seller or buyer.

What are your rights?

The law gives you several important rights in relation to your personal data, which are listed below.

There are certain exceptions where these rights may be superseded by laws and other requirements applicable to regulated authorised payment institutions like Mito.Money. An example of this would be the obligatory retention period (seen Section 5), which supersedes the right to data erasure.

Your rights are:

• The right to be informed: the right to be informed about how we use your personal data
• The right of access and data portability: the right to request access to the data that we have about you, to obtain the data within a month of asking for it, and to use it for your own purposes
• The right to rectification: the right to correct, amend or update your personal data if it is wrong or has changed (this can usually be done using the settings provided on your account)
• The right to erasure: the right to ask us to remove the data we hold about you from our records
• The right to be forgotten: the right to request erasure of any links to your personal data, or of any copy or replication of any public personal data
• The right to restrict processing: the right to ask us to stop processing your personal data
• The right to object: the right to object to data processing, if you believe that our legitimate interest might infringe upon your rights
• Rights related to automated decision-making and profiling: the right not be subject to individual decisions made solely by automated means.
• The right to notification in the event of breach: the right to be immediately informed if we identify a data breach
• The right to raise a complaint: the right to contact our Data Protection Officer if you are not happy with how we have handled your personal data
• The right to lodge a complaint with a supervisory authority: the right to submit a complaint to the Information Commissioner’s Office (ICO) if you are not satisfied with our Data Protection Officer’s response, or if you believe that we are not processing your personal data in a lawful way (For more details please refer to the Commissioner’s Office website).

If you would like to read more about your rights in relation to your personal data, please refer to the Information Commissioner’s Office website.

Legitimate interest

Legitimate interest is a specific legal justification for the collection and processing of your personal data. It applies when we have reasonable grounds to collect and/or process your personal data to improve our Service, as long as this does not infringe on your rights.

Our legitimate interest may justify some examples of automated decision-making. One of those is our estimated transaction timing, which we use to determine the time in which the transfer will reach your beneficiary.

We believe that if you are an active customer of Mito.Money, it is in your interest to receive occasional information about our Service. We may therefore send you communications about offers or promotions that we believe are relevant for you based on your previous use of the Service. If we notice that you are having problems using our service, we may on our own initiative decide to contact you, in some cases by phone, to offer help

We may also process your data to help develop new product features that we believe will improve the Service. We may contact you occasionally to assess your satisfaction with the service. We may also use your data to determine the effectiveness of marketing or promotional campaigns. We may also contact you with information about any changes in the service, and/ or other important updates.

We will only share anonymised or encrypted data with the third parties. We may also provide our partners with anonymous aggregated data about our customers for marketing and analytical purposes, to help optimise our marketing communications.

You can object to data processing based on our legitimate interest at any time by contacting us at help@mito.money or by changing the settings on your Mito.Money account.

Cookies

Cookies are small text files which are stored on your device when you access Mito.Money. They allow us to recognise you and store data about your past activity and your preferences so that we can personalise and improve the service for you.

Cookies and other similar technologies may collect data such as language preference, country and previously viewed pages.

We use the following cookies:

• Necessary cookies: these cookies enable the basic use of our Service e.g. enabling content reserved for registered users
• Personalisation cookies: these cookies allow our Service to be personalised for you e.g. remembering your preferred language or sending country
• Analytical cookies: these cookies allow us to see how people use our Service so that we can understand how to improve it e.g. seeing how many people are logged in at a given time of day

By using our Service, you agree to place the cookies described above on your device. You have the right to withdraw your consent at any time. If you would like to delete our cookies, you can do so by changing the settings of your browser.

Blocking or deleting cookies may mean that some features of the Service may not be available to you.

Logging in to Mito.Money with your Facebook account

You can login to Mito.Money using your Facebook profile. This allows us to authenticate your identity by obtaining access to:

• Your e-mail address associated with your Facebook profile
• Your Facebook public profile

Any of your personal data that we receive from third parties will be subject to this Privacy Policy and the privacy policies of those third parties.

By using your Facebook login credentials, your personal data may be processed by Facebook marketing tools. An example of this is the Facebook tool called ‘Lookalike Audiences’. This helps us to identify people who have similar interests or behaviours to those of our customers. We may use similar tools provided by Facebook in the future.

Changes in Privacy Policy

Mito.Money may change this Privacy Policy from time to time. Any changes will be effective immediately unless stated otherwise. The date of the most recent update is displayed at the top of the page.

Any dispute or claim arising in connection with this Privacy Policy will be considered in relation to the English version only.

Contact details

• By post: Devonshire House, Manor way, Borehamwood, Hertfordshire, WD6 1QQ, United Kingdom.
• Via our website: www.mito.money

Mito.Money has a Data Protection Officer who is responsible for matters related to privacy, data protection and data security. Our Data Protection Officer can be contacted at privacy@mito.money