Terms & conditions

This document (“this Agreement”) contains the terms and conditions of the agreement between the user of the DigiDoe account service and the provider thereof (“DigiDoe”).

1. Framework agreement

This Agreement constitutes a framework agreement which sets out the terms of service that apply to Individual and Business clients with the use of the DigiDoe app and other DigiDoe Services.

Before you can enter into the DigiDoe app and benefit from the DigiDoe Services, you are required to read this Agreement and confirm your acceptance of it; provide us with such documentation, photographs and information as we may reasonably request to comply with our regulatory obligations; and, if you are a Business Client, deliver a signed board resolution or similar documentation appointing any Authorised Representatives, or, if you are an Individual Client, deliver your identification document and proof of address.

If you are a Business Client, you warrant that you are not an Individual, Micro-Enterprise or Charity, and agree that the Regulations which may be disapplied to non-Individual, non-Micro-Enterprise, non-Charity clients are so disapplied to the maximum extent possible. You confirm that neither you, nor (for Business Clients) any of your directors, shareholders, trustees, beneficial owners or Affiliates, are listed on or targeted by any sanctions list (a “Designated Person”), or owned or controlled by such a person.

By accepting this Agreement you are deemed to have accepted the terms and conditions of our third-party service providers. You confirm that the information you provided when creating your DigiDoe Account is correct, and you undertake to notify us immediately of any change; you bear any losses arising from invalid, incorrect or inaccurate information.

2. Commencement, term, regulatory information and how to contact us

This Agreement is between you and DigiDoe Limited and starts on the day DigiDoe confirms your account has been approved; it continues until terminated under Clause 30. DigiDoe Limited is a company incorporated in England and Wales (company number 11944257), registered address 80 Strand, London, WC2R 0RL. You can contact us by email at support@digidoe.com.

DigiDoe Limited is the issuer of electronic money in your DigiDoe account and performs the related payment services. DigiDoe Limited is authorised as an Electronic Money Institution by the FCA under the Regulations, and is included in the FCA’s Register of Electronic Money Institution firms (FRN 901043). We are also subject to the Regulations as amended and supplemented following the UK’s withdrawal from the European Union. “DigiDoe” is a trading name of DigiDoe Limited.

3. Your DigiDoe account

Your DigiDoe Electronic Money Account holds electronic money which DigiDoe has issued to you at par value in exchange for receiving money from you or on your behalf; you may use it to make transactions. You may be required to provide additional information to use all available functionality.

Where we are required to keep your funds separate, we place them in a segregated Safeguarding Account at partner banks. As an FCA-authorised electronic money institution, the funds you hold with us are not covered by the Financial Services Compensation Scheme; instead, safeguarding separates those funds from our other assets in the event of our insolvency, for repayment to you and other clients. Our partner banks provide the Safeguarding Accounts but do not oversee how we manage them; that responsibility is ours.

You may be able to store multiple currencies in your account, subject to change from time to time. We may stop your access to the DigiDoe app on reasonable grounds relating to security, suspected unauthorised or fraudulent use, or breach of sanctions, anti-money laundering or counter-terrorist financing legislation. We will inform you via email or the app if we do so.

4. The DigiDoe client portal

The DigiDoe app is our portal where you can perform top-ups and DigiDoe bank transfers, view your transaction history, and view your account balance and currency. You may change account details and verify your identity by emailing us. The app is accessible via web portal at platform.digidoe.com.

5. Verification of identity

Individual Clients under 18 cannot apply for a DigiDoe Account. In accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, we conduct customer due diligence on all new clients; for Business Clients this extends to any individual owning or controlling more than 15% of shares or voting rights, or exercising ultimate control. We may conduct enhanced due diligence where appropriate and reserve the right to request further information.

You agree to cooperate with all reasonable identification and verification requests, including through third-party databases; searches such as credit checks may leave a soft footprint that does not affect your credit rating. Business Clients must notify us within two Business Days of any change to directors, shareholders, trustees or ultimate beneficial owners. You must keep your account information accurate and up to date; we may periodically re-verify as part of our ongoing monitoring obligations.

Onboarding requirements. Individual Clients within the UK/EEA may qualify for Simplified Due Diligence using a biometric passport, Biometric Residence Permit, or EU Settlement Scheme card, proof of address (not older than 3 months), and a selfie holding the ID. SDD accounts are limited to incoming payments of £5,000/€5,000 per month and cross-border transactions of £1,000/€1,000 per month, and may be placed on hold if enhanced due diligence becomes necessary. Individual Clients outside the UK/EEA require a valid passport or national ID, a selfie with the document, proof of address, purpose of account, and source of wealth. Requirements for Business Clients vary by jurisdiction of incorporation; DigiDoe applies a risk-based approach and may request additional documentation at its discretion. Enquiries: compliance@digidoe.com.

6. Top-ups to your DigiDoe electronic money account

A mandatory minimum balance must be maintained on your account , see “Fees and Pricing” on our website. Top-ups are made via a User Bank Transfer, Third-Party Bank Transfer, or other method we make available. On receipt of cleared funds we issue the corresponding value of electronic money to your account. We may set limits on amounts received through the DigiDoe Services at our reasonable discretion, for example to limit fraud or credit risk.

7. DigiDoe transactions

An “Electronic Money Exchange” uses electronic money in one currency to purchase electronic money in another at our Exchange Rates. A “DigiDoe Bank Transfer” redeems electronic money from your account, with or without an associated exchange, and transfers the equivalent amount to the Counterparty Bank Account. DigiDoe may refuse to execute a transaction at any time in accordance with our policies and regulations, and generates virtual receipts for successful transactions.

8. Exchange of electronic money for foreign currency

You can request an exchange of electronic money to another currency by emailing sales@digidoe.com. Available currencies are limited to those specified in the DigiDoe app and may change without prior notice. Before sending funds for exchange you will be informed of the amount used and the amount and currency purchased; see “Fees and Pricing” for applicable fees. You are solely responsible for engaging in an Electronic Money Exchange; DigiDoe is not liable for resulting losses.

9. DigiDoe bank transfer and monetary exchange

Requests are made by logging into the DigiDoe app and entering the Counterparty Bank Account details; it is your responsibility to ensure these “Unique Identifiers” are correct, and we are not responsible for losses from incorrect details. Before confirming, you will be shown the Counterparty account, the amount and currency, and any fees, and asked to confirm via two-factor authentication.

For Sterling or Euro payments, we use reasonable commercial endeavours to credit the Counterparty’s provider by the end of the following Business Day; for other EEA-located currencies, by the end of the fourth Business Day; for non-EEA destinations, as soon as reasonably possible. Where currencies differ, we perform a Monetary Exchange at the applicable Exchange Rate before sending funds, and inform you of that rate beforehand. Once initiated, a transfer cannot generally be cancelled, though you may revoke a future-dated instruction before it is processed. If funds are returned to DigiDoe, they are reconverted at the prevailing rate, which may result in a higher or lower amount than originally sent; DigiDoe is not liable for the difference.

10. Receive electronic money

Electronic money received into your account will be displayed in your DigiDoe Transaction History as soon as reasonably practicable.

11. Exchange rates

Live exchange rates for each currency are shown on the DigiDoe app, and you will be informed of the exact rate for each transaction before entering into it. It is your responsibility to be satisfied with the rate offered before proceeding. Any additional fees are shown in the Fees and Pricing section on our website.

12. Auto conversion

If you receive funds in a currency different from the one selected for your account, they are automatically converted to your selected currency at the Auto Conversion Rate specified under “Fees and Pricing” on www.digidoe.com.

13. Your balance and negative balance

Balances shown on the DigiDoe app are approximate real-time figures and may not reflect settled balances or pending debits/credits. If your balance falls below the applicable minimum for any reason, including technical errors, you agree to top up immediately without prior notice. If you fail to do so, we may exercise our right of set-off (Clause 18), request a top-up to receive the monthly management fee, initiate a chargeback for the transaction that caused the negative balance, or pursue debt collection, including through agencies, solicitors, or the courts, at your expense.

14. Security

You (and, for Business Clients, your Authorised Representatives) must take reasonable steps to keep login details and access to the DigiDoe app safe and secure, including logging out after use, securing your mobile device, never sharing login details, changing your password regularly, never responding to phishing requests for credentials, and keeping your email account secure. Notify customer services immediately if you believe your login details have been compromised.

All transactions are processed by automated methods, so anyone with your access credentials could transact without your permission. Report misuse, theft or unauthorised use immediately to support@digidoe.com, and contact your local police if you suspect identity theft.

15. Restrictions on the use of the DigiDoe services

Your account is subject to the Restricted Activities in Schedule 2. Subject to the Regulations, we may refuse a payment instruction if we consider you in violation of this Agreement or reasonably believe the payment illegal, and will notify you where legally permitted. If we believe you have violated this Agreement, we may close, suspend or limit your account, contact other users, your bank, law enforcement or third parties, correct inaccurate information, take legal action, terminate this Agreement, reverse a transaction, or block your access temporarily or permanently.

For Business Clients, we may refuse transactions associated with a Designated Person or that risk violating sanctions, AML or counter-terrorism legislation. If you become a Designated Person, your accounts will be frozen and reported to the relevant authority (in the UK, the Office of Financial Sanctions Implementation). You must ensure all transactions comply with applicable law; accepting payment via DigiDoe is not an indication of the legality of the underlying supply.

16. DigiDoe transaction limits

Transactions may be subject to funding, payment or conversion limits for security and legal reasons, at our reasonable discretion. We will provide written notice as soon as reasonably possible after imposing such limits, where we are legally able to.

17. Suspending your use of the DigiDoe services

We reserve the right to change, suspend or discontinue any aspect of the DigiDoe Services, in whole or for a specific user, at any time, without notice and without liability.

18. Our right to set-off

Where any event entitles us to compensation from you, we may recover the sum due by retaining part or all of any funds you have lodged with us; you have no equivalent right of set-off. This includes offsetting a negative or owed balance in one currency against funds you hold in another currency, or against incoming or outgoing transfers. Where the owed amount is in a different currency, we convert using our Exchange Rates without needing to notify you.

19. Our liability

Except where you have acted fraudulently, you are not liable for losses from an unauthorised DigiDoe Bank Transfer reported to us without undue delay, and in any event within 13 months of the debit date. We are not liable for non-execution or defective execution of a transfer made in accordance with a Unique Identifier that proves incorrect, though we will make reasonable efforts to recover the funds (which we may charge for). We are not liable where we can show the payee’s provider received the payment on time.

DigiDoe is not liable for delay or failure caused by matters beyond our reasonable control (Force Majeure, bank or postal delay, transmission failure, and similar), or for losses arising from our own regulatory obligations. Individual Clients may only use the account for payments in which they are the named payer or payee; DigiDoe is not liable for loss of profit, business or opportunity arising from our refusal, delay or reversal of a payment, or from misuse of a personal account, save where liability cannot lawfully be excluded. You are solely responsible for your own tax reporting and payment obligations.

As an Individual Client, this Agreement does not diminish your statutory consumer rights (see the Competition and Markets Authority or Financial Ombudsman Service for more information); we remain liable for reasonably foreseeable loss caused by our breach or failure to exercise reasonable care, but not for loss arising from causes beyond our reasonable control or that were unavoidable despite our diligence.

You are responsible for all liabilities arising from your breach of this Agreement or use of the DigiDoe Services, and agree to reimburse DigiDoe, other users or third parties accordingly; this liability survives termination, suspension or closure of your account. You alone are responsible for compliance with the laws of your jurisdiction, including tax and import/export rules, and agree to indemnify DigiDoe against third-party claims arising from your breach. Nothing in this Agreement excludes liability for death, personal injury, fraud, or any liability that cannot lawfully be excluded. DigiDoe is not liable for loss of profits or special, incidental or consequential damages, nor for losses arising from your inability to use the Services, service disruption, malicious software, system errors, third-party actions (including a partner bank freezing a Safeguarding Account), account suspension, policy changes, or the illegal actions of third parties using counterfeit or illegally obtained documents.

20. Withdrawing funds

You may withdraw funds by entering into a DigiDoe Bank Transfer to a User Bank Account, or by any other method made available or notified to you. DigiDoe is not responsible for a withdrawal once funds are received by your payment service provider, as DigiDoe acts as payer, not as the receiving provider.

21. Closing your account

Your account closes at the end of this Agreement’s term or upon termination under Clause 30. If a balance remains at closure, you may be asked to withdraw it within a reasonable period; after that period you may still withdraw remaining funds for up to six years by contacting customer service. Closing an account within six months of its funding date may incur an early closure fee reflecting unpaid monthly fees for that period. You may not close your account to evade an investigation; DigiDoe may freeze the account in that case, and you remain liable for obligations arising before closure.

22. Notice and communications

You consent to receive all communications electronically, via the DigiDoe app or to your registered email address, and agree to keep copies of them. It is your responsibility to log in and review the app, the website and your email regularly, and to promptly report questions, errors or unauthorised transactions; failure to do so in a timely manner may result in loss of funds or rights. You may contact us via the chat function in the DigiDoe app.

23. Data

DigiDoe and you act as independent controllers in relation to Shared Personal Data provided for the Agreed Purposes (the provision of the services under Clause 1.1), and DigiDoe processes it in accordance with the DigiDoe Privacy Policy as amended from time to time. You must comply with all obligations imposed on a controller under the Data Protection Legislation (UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003); an unremedied material breach gives us grounds to terminate this Agreement.

You must ensure you have all necessary notices, consents and lawful bases for transferring Shared Personal Data to Permitted Recipients, give data subjects full information about the processing (including retention/transfer on termination), promptly inform us of any data subject rights request, assist us with our own obligations (including breach notification and DPIAs), notify us without undue delay of any breach, and maintain records demonstrating compliance. By accepting this Agreement, you agree to our use of your information to make and receive payments and to perform our contractual and regulatory obligations, including sharing data with fraud prevention agencies; see our Privacy Policy for detail. You indemnify us against losses arising from your breach of the Data Protection Legislation. We may record and retain telephone calls at our discretion.

24. Intellectual property

The DigiDoe app, the website and all intellectual property contained in them, including the “DigiDoe” name, logos, page headers, custom graphics, button icons and scripts, are owned or licensed by us; you may not copy, imitate or use them without our prior written consent. We reserve all our rights in this intellectual property. Nothing in this Agreement grants you any rights beyond what is necessary to access the DigiDoe app, and you agree not to circumvent or remove any notices or security embedded within it.

25. Requesting information

You may at any time request a copy of this Agreement and any information set out in Schedule 4 of the Payment Services Regulations 2017.

26. Customer support and complaints

Complaints should be addressed to support@digidoe.com, clearly marked as a complaint. We will send a final response, or an explanation of why one has not been completed, within 15 Business Days (or in exceptional circumstances within 35 Business Days, in which case we will notify you). If you remain unhappy after our final response and your complaint falls within its jurisdiction, you may refer it to the Financial Ombudsman Service (0800 023 4567; financial-ombudsman.org.uk; Exchange Tower, London E14 9SR). If you are not eligible for the FOS, the parties will attempt mediation under the CEDR model mediation procedure before any unresolved dispute is finally settled by the courts of England and Wales.

27. Amendments to this agreement

We may amend this Agreement unilaterally with two weeks’ written notice; continued use after that period is deemed acceptance. If you do not accept a change, you must notify compliance@digidoe.com before the notice period expires, which we treat as notice to close your account. Amendments required by law, or that add services or otherwise do not reduce your rights or increase your responsibilities, may take effect without prior notice. For Individual Clients, favourable changes may be made without notice; unfavourable changes require two months’ notice, and you may close your account without charge if you disagree.

28. Fees

Fees are set out under “Fees and Pricing” on www.digidoe.com and may be amended with two weeks’ written notice, following the same acceptance mechanism as Clause 27. Transactional fees are shown in the app before you complete an action. Monthly management fees are paid in advance, from the 15th of the preceding month to the 15th of the relevant month, and are deducted from your account in a currency of our choosing, converting balances as needed. We may suspend access if fees are unpaid.

Accounts may be subject to an annual compliance, security and testing review at an additional charge depending on risk score, which may be waived for active accounts. If our compliance or senior management teams must address legal proceedings, regulatory or law enforcement requests, or client legal/management matters concerning your account, we reserve the right to charge additional compliance fees (GBP 120 to 240 plus VAT per hour) or senior management fees (GBP 1,800 plus VAT per day, or GBP 250 plus VAT per hour), plus any outside legal counsel fees we incur. Undisclosed material information that would have placed you in a different client category, or precluded you as a client altogether, may result in retrospective correction of fees or account closure.

29. No warranty

The DigiDoe Services are provided on an “as is” and “as available” basis, without warranty of any kind. For Individual Clients, we remain accountable for reasonably foreseeable loss arising from our breach or failure to provide services with reasonable care and skill. DigiDoe does not warrant uninterrupted or error-free service, does not control the products or services paid for using the DigiDoe Services, and is not responsible for their quality, performance or consequences.

30. Termination

DigiDoe may terminate this Agreement with two weeks’ written notice; you may terminate with two weeks’ written notice to compliance@digidoe.com. Either party may terminate with immediate effect for an unremedied material breach (after 30 days’ notice), repeated breach, insolvency-type events, or where performance becomes unlawful. We may additionally terminate immediately if we cannot verify your information, an insolvency officer is appointed over you, you become a Designated Person, your use damages our systems, your transaction volume fluctuates significantly, your conduct risks our reputation or increases our liability, a third party fails to supply us, or you breach the Agreement, including by non-payment; in the latter cases we may also report you to the relevant authorities and seek damages. Termination requires closing your account under Clause 21; surviving terms remain in effect.

31. Miscellaneous

Use of other DigiDoe functions may require acceptance of further terms. Eligibility requires passing our due diligence checks, not breaching this Agreement, and not having had a previous account closed by us. This Agreement is governed by the laws of England, subject to the exclusive jurisdiction of the Courts of England & Wales, and confers no third-party rights under the Contracts (Rights of Third Parties) Act 1999. You may not transfer, assign or grant any interest in your account without our written consent; we may transfer or assign this Agreement at any time. Electronic money belongs to the registered account holder only.

You are solely responsible for determining, reporting and remitting any taxes on your transactions. Our failure to enforce a right is not a waiver of it. We may comply with any subpoena or legal process we believe valid, and may change third-party service providers, or edit or remove content we consider objectionable or unlawful, without liability. If any provision is held invalid, the remainder continues in effect. We provide execution-only service and do not give advice; you must make your own independent assessment before any transaction, informed by your own advisers as necessary. Headings do not affect interpretation; the Schedules form part of, and singular/plural and gender references apply equally throughout, this Agreement, which is governed and interpreted in the English language.

Schedule 2 , restricted activities

See our Risk Appetite statement on www.digidoe.com for country and activity restrictions. It is not permitted to use the DigiDoe Services: for any illegal purpose, including fraud, money laundering, unlawful sexually-oriented material, counterfeit goods, unlawful gambling, terrorist financing, or unlawful trade in tobacco, firearms, prescription drugs or controlled substances; in breach of any applicable sanctions, AML or counter-terrorist financing law; in a way that benefits a Designated Person; to circumvent merchant usage restrictions or avoid paying amounts due; in breach of this or any other agreement with DigiDoe; to open more than one account without our written consent; to trade in adult entertainment, auction houses, chemicals, dating/escort services, binary options, political or religious organisations, video game arcades, or purported prime bank instruments; to infringe intellectual property or publicity/privacy rights; to act defamatorily, threateningly or in a harassing manner; to provide false or misleading information; to conduct debt collection; to send or receive suspected fraudulent funds; to double-claim funds for the same transaction from DigiDoe and a merchant; in a manner likely to generate disputes, chargebacks, fines or penalties; to hold a negative or below-minimum balance; to impose unreasonable load on our infrastructure, introduce malware, use anonymising proxies, or scrape the website; to cause loss of our supplier services; to circumvent account restrictions (including by using another person’s identity or account); to harass DigiDoe staff, agents or other users; to refuse cooperation with an identity or information request; to breach payment network or card scheme rules; to trade FX speculatively or for arbitrage; to refuse reasonable information requests about you or your business; to generate a disproportionate rate of claims or chargebacks; or where a third-party credit score indicates an elevated risk level.

Contact

Questions about these terms can be sent to support@digidoe.com. DigiDoe Ltd, 80 Strand, London, England, WC2R 0RL. FCA-authorised EMI, FRN 901043.