Website Terms of Use

Effective Date: 10 September 2026

1.1. These Website Terms of Use (the "Terms") set out the legal agreement between you and SMARTFLOW PAYMENTS LIMITED, trading as SENDS ("SENDS", "we", "our" or "us"), and they govern the way you access and use the SENDS website at www.sends.co (the "Website").

Where these Terms refer to the "Agreement", they mean the separate contract under which SENDS provides its regulated accounts and services, and where they refer to "Partner Terms", they mean the separate terms of a third-party product made available through SENDS.

1.2. These Terms establish the binding conditions that apply whenever you access or use the Website. They apply to everyone who uses the Website, whether you are simply browsing or you are a registered user of our services ("you"). By continuing to use the Website you accept these Terms, together with any amendments or updates we may make to them. The Terms take effect as soon as you begin using the Website, and if you do not accept any part of them you should stop accessing and using the Website straight away.

1.3. Please note that these Terms relate only to your use of the Website. These Terms are not a payment services agreement, an electronic money services agreement, and they should not be treated as any of those. They must not be confused with any other service agreement that SENDS may offer. These Terms do not govern, and are not an offer of, any financial product or service provided by SENDS. To obtain any regulated service from SENDS you must enter into the Agreement for that service, and to use any third-party product you must accept the relevant Partner Terms. Each of these is a distinct process, separate from your acceptance of these Terms.

1.4. By accessing or using the Website, you confirm that you have read these Terms, understood them, and agreed to be bound by them. If you are using the Website for a company or another organisation, you confirm that you are authorised to act for it and to commit it to these Terms.

1.5. So far as the law allows, you agree that using the Website amounts to your acceptance of these Terms. This acceptance applies to these Terms only. It does not sign or form the Agreement or any Partner Terms, which you accept separately, and it does not by itself amount to a binding electronic signature for those separate contracts.

1.6. We may revise or update these Terms at any time. Where a change is significant, we will bring it to your attention before it takes effect, for example by a notice on the Website. For other changes, the updated Terms apply from the date we publish them. We suggest that you check this page from time to time so that you are aware of any changes. If you keep using the Website after a change takes effect, you are taken to have accepted the revised Terms.

1.7. You confirm that you are aged 18 or over and that you are able and competent to enter into and comply with the commitments, statements and assurances contained in these Terms. SENDS does not provide services to anyone under the age of 18.

1.8. Your use of the Website is governed by these Terms. We ask you to read them with care, as they create a binding legal relationship between you and SENDS.

1.9. Where you are a consumer, nothing in these Terms removes or limits any right or remedy you have that cannot lawfully be excluded or limited, including your rights under the Consumer Rights Act 2015. Any term of these Terms applies to you only to the extent that it does not conflict with those rights.

2.1. The Website sets out information about the products and services that SENDS provides.

2.2. SENDS offers electronic money accounts and payment services to both individuals and businesses.

2.3. SENDS is a trading name of SMARTFLOW PAYMENTS LIMITED, which is registered in England and Wales under company number 11070048, with its registered office at 11 Garden Court Tewin Road, Welwyn Garden City, Herts, England, AL7 1BH. It is an Electronic Money Institution authorised by the Financial Conduct Authority under Firm Reference Number 900873. Details of its authorisation and permissions are available on the Financial Services Register at register.fca.org.uk/s/firm?id=0010X00004ATBQbQAP and on the Companies House register at https://find-and-update.company-information.service.gov.uk/company/11070048. SENDS is authorised to issue electronic money and to provide payment services, including the following:● a) Services enabling cash placement on a payment account● b) Services enabling cash withdrawals from a payment account● c) Execution of payment transactions (not covered by a credit line)● d) Execution of payment transactions (covered by a credit line)● e) Issuing payment instruments or acquiring payment transactions● f) Money remittance● g) Issuing Electronic Money

Electronic money issued by SENDS is not covered by the Financial Services Compensation Scheme. Instead, we protect the funds we hold for you by safeguarding them in line with the Electronic Money Regulations 2011, and the effectiveness of our safeguarding arrangements is checked each year by an independent audit firm.

You can read more about how safeguarding works for payment and e-money customers at www.fca.org.uk/consumers/using-payment-service-providers.

3.1. SENDS grants you a licence to access and use the Website that is non-exclusive, non-transferable and revocable, and that must be exercised strictly in accordance with these Terms. Unless we agree otherwise, the licence is for your own use, whether personal or for the internal purposes of your business.

3.2. Access to the Website and its features is provided on a temporary basis. We may, at our discretion and without notice, change, suspend or withdraw all or part of it at any time, including limiting access to particular features or content, and we will not be liable to you for doing so.

3.3. Some features or services on the Website may require you to create login credentials and a password. You are responsible for keeping your account details, including your password, confidential, and for everything that happens under your account. You agree to tell SENDS immediately if you become aware of any unauthorised use of your account or password, or any other breach of security.

3.4. Access to some services may depend on you completing any registration or verification steps we consider necessary. You agree to give accurate, current and complete details when prompted, and to keep them up to date. Where you choose or are given a login, password or other security information, you must keep it confidential and must not share it with anyone. We may disable any login or password, whether you set it or we issued it, at any time, including where we reasonably believe you have not complied with these Terms. If you know or suspect that someone else has your login or password, you must tell us without delay using the support form on the Website.

3.5. We try to keep the Website available at all times, but because of how the internet works we cannot promise that it, or any service on it, will always be available or free from interruption. Access is provided on a temporary basis, and we may suspend, withdraw or change all or part of the Website without notice. We will not be liable if the Website is unavailable at any time or for any period.

3.6. Although we make reasonable efforts to keep the information on the Website accurate and current, we do not guarantee that it is complete, reliable or accurate. The content is provided for general information only and should not be relied on as the only basis for a decision without checking more accurate, complete or up-to-date sources. You are responsible for making sure that any information you give us through the Website is accurate, complete and current, and for correcting anything that is wrong or out of date without delay. Where the Website links to other sites or resources provided by third parties, those links are offered for information only and do not mean that we endorse those sites or their content, over which we have no control.

3.7. We aim to update the Website regularly and may change its content at any time. If we need to, we may suspend access to the Website or close it for an indefinite period. Any of the material on the Website, such as blog posts, insights, news or FAQs, may be out of date at any time, and we are under no obligation to update it.

3.8. You rely on the material on the Website at your own risk. You should obtain professional or specialist advice before doing, or deciding not to do, anything based on its content. We accept no liability for any reliance placed on the Website by you, by any other visitor, or by anyone who may be told about its contents.

3.9. Nothing in these Terms excludes or limits our liability for death or personal injury caused by our negligence, or for anything else that cannot be excluded or limited under the law of England and Wales. So far as the law allows, we exclude all conditions, warranties, representations and other terms that might otherwise apply to the Website or its content, whether express or implied. We will not be liable to you, whether in contract, tort (including negligence), for breach of statutory duty or otherwise, even where the loss was foreseeable, for any loss or damage arising from your use of or inability to use the Website, or from your reliance on any content on it. This includes loss of profits, sales, business or revenue, business interruption, loss of expected savings, loss of business opportunity, goodwill or reputation, and any indirect or consequential loss or damage.

3.10. To the fullest extent the law allows, SENDS, including its directors, employees, agents and service providers, will not be liable for any direct, indirect, special or consequential loss, or any other loss of any kind, arising out of or connected with your use of, or inability to use, the Website. This includes loss caused by errors, omissions, interruptions, defects, delays in operation or transmission, computer viruses and line failures, as well as any other direct or indirect loss. Nothing in this clause 3.10 excludes or limits any liability that cannot be excluded or limited by law, and clause 1.9 takes priority for consumers.

3.11. If you are a business customer, you agree to indemnify SENDS, together with its service providers and their respective officers, directors, employees, contractors, agents, suppliers, successors and assigns, against any claim, liability, damage, judgment, award, loss, cost or expense (including reasonable legal fees) arising out of or relating to your breach of these Terms or your use of the Website, including any use of its content, services or products other than as these Terms permit, or your use of any information you obtain from the Website. If you are a consumer, you are responsible to us only for loss we suffer that is a foreseeable result of your breach of these Terms, and this clause does not require you to give any indemnity.

3.12. You may end your acceptance of these Terms at any time by stopping your use of the Website. We may suspend or end your access to the Website at any time and for any reason, including breach of these Terms, fraud or impersonation. Once your access ends, your right to use the Website stops immediately

4.1. To keep the Website and its services secure, reliable and working properly, SENDS applies certain restrictions on how they may be used. By using the Website, you agree not to use it or its services in any way that breaks any applicable law, rule or regulation, that encourages any unlawful activity, that infringes the rights of SENDS or anyone else, or that involves any of the conduct described in this section.

4.2. You must not access or use the Website or its services for any unlawful or unauthorised purpose. If you are using the Website from outside England and Wales, you agree to comply with the law of England and Wales and with all local laws that apply to online conduct and acceptable content.

4.3. You must not try to gain unauthorised access to the Website’s systems or to any account that is not yours, whether by hacking, password mining or any other method. You must not misuse the Website by knowingly introducing viruses, trojans, worms, logic bombs or other harmful or malicious material, and you must not attempt any denial-of-service or distributed denial-of-service attack. Doing so would be a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant authorities and will cooperate with them, including by disclosing your identity, to the extent the law requires.

4.4. You must not disrupt or interfere with the security of, or otherwise damage, the Website, or the systems, resources, accounts, passwords, servers or networks that are connected to or reachable through the Website or any linked website.

4.5. Using automated systems or software to extract data from the Website for commercial purposes, sometimes called screen scraping, is not allowed unless you have a written licence from SENDS that specifically permits it.

4.6. You must not upload, post or otherwise send any material that contains software viruses or any other code, file or program designed to interrupt, damage or limit the working of any software, hardware or telecommunications equipment.

4.7. You must not impersonate any person or organisation, including a member of SENDS staff, or misrepresent your connection with any person or organisation.

4.8. You must not create a false identity in order to mislead others, or to conceal your identity or your connection with any person or organisation dishonestly.

4.9. You must not use, copy, distribute or reproduce any content on the Website, including text, images, software or trademarks that are protected by copyright, without the express written permission of the owner of that content.

4.10. You must not take part in any activity that infringes the intellectual property rights of SENDS or anyone else, including patents, copyrights, trademarks, trade secrets or other proprietary rights.

4.11. SENDS may cooperate fully with any law enforcement authority or court that asks or orders us to reveal the identity of anyone who posts messages or makes available any material that we believe breaches these Terms.

4.12. If you break these restrictions, we may end your access to the Website and its services immediately, and you may face civil or criminal liability. SENDS may investigate any suspected breach and may involve and assist law enforcement authorities in taking action against those responsible.

5.1. SENDS owns all the intellectual property rights and materials on the Website, including the text, content, graphics, logos, icons, images, audio clips, design, layout, structure, downloadable files, data compilations and software. These are protected by copyright, trademark, patent, trade secret and other intellectual property laws, and all rights are reserved.

5.2. Subject to these Terms, we grant you a limited, non-exclusive licence to access the Website and use it for your own purposes. You may view, print and download limited parts of the content for your own personal or internal business use, provided you keep all proprietary and copyright notices in place. You may not modify, distribute or create derivative works from the content without our express written consent. This licence does not give you any rights that are not set out here, and in particular it does not allow you to:● resell or otherwise make commercial use of the Website or its contents,● collect and use any product listings, descriptions or prices,● make any derivative use of the Website or its contents,● download or copy account information for the benefit of another business,● use data mining, robots or similar tools to gather or extract data.

5.3. The trademarks, logos and service marks shown on the Website belong to SENDS or its licensors. You may not use, reproduce, download or distribute them in any way, including as meta tags on other pages, without the prior written consent of SENDS or the relevant third-party owner.

5.4. All content on the Website, including the text, graphics, logos, button icons, images, audio clips, downloadable files and software, belongs to SENDS or its content suppliers and is protected by international copyright law. The compilation of all the content on the Website is owned exclusively by SENDS.

5.5. Any unauthorised use immediately ends the permission or licence that SENDS has granted. SENDS actively protects its intellectual property rights and may take legal action against any infringement, including seeking an injunction or damages.

5.6. SENDS respects the intellectual property of others and asks users of the Website to do the same. If you believe that your work has been copied and placed on the Website in a way that infringes your copyright, please send us the relevant details using the support form on the Website, and we will take appropriate steps to deal with it, including removing the material in question.

6.1. SENDS is committed to the highest standards of conduct and integrity across everything we do, in line with the Financial Conduct Authority’s Consumer Duty. Because we provide services to individuals as well as businesses, we place our customers’ interests at the heart of our business and seek to meet the standards of conduct expected under the FCA’s Principle 12. In practice this means:● Acting in good faith: we deal with our customers honestly and fairly and in their best interests, making our decisions with integrity and openness.● Avoiding foreseeable harm: we take active steps to identify and reduce anything in our services or practices that could cause harm to our customers, and we keep our services under review to maintain a high standard of protection.● Supporting good outcomes: we aim to help our customers meet their financial goals by providing services that work well for them and support the outcomes they are looking for.

6.2. SENDS follows the cross-cutting rules set out under Principle 12 by the FCA, applying the principles of acting in good faith, avoiding foreseeable harm and helping customers achieve their financial objectives. This runs through the way we design and deliver our products and services, so that they are suitable, offer fair value and are backed by clear communication and proper support.

6.3. Our services are available to both individuals and businesses. Where we provide services to retail customers, we apply the Consumer Duty in full, and we give particular attention to customers in vulnerable circumstances to make sure they receive the support they need.

7.1. SENDS is committed to giving all our customers a high standard of service and support. We know that there may be occasions when our service falls short of what you expect, and when that happens we will deal with your complaint promptly, fairly and effectively.

7.2. If you have a concern or wish to make a complaint, please contact our support team at [email protected].

7.3. To help us investigate quickly and effectively, please give us as much detail as you can, including the nature of your complaint, any relevant dates, transactions and impact, the outcome you are looking for, and your contact details. Complete information helps us deal with your complaint more efficiently.

7.4. We will record your complaint and assign a member of the SENDS team to handle it. Our people are suitably experienced and will do their best to put things right, and they will either have the authority to resolve your complaint or have access to someone who does.

7.5. The way we handle complaints of our clients in relation to regulated services under the Agreement, including our response times, is set out in the Agreement and in our Complaints Procedure published at sends.co/complaints. If you are a client of SENDS and you are not satisfied with how we have dealt with your complaint, you have the right to take the matter further. Where you are an eligible complainant, you may be able to refer your complaint to the Financial Ombudsman Service.

7.6. SENDS is particularly committed to supporting victims of fraud. We communicate clearly and with empathy, give special attention to customers in vulnerable circumstances, and prioritise their complaints. We aim to reduce the impact of fraud through fraud alerts, responsive support, and helping our customers understand how to protect themselves against scams. For more information, please visit sends.co/protect-yourself-from-fraud

8.1. SENDS is committed to protecting the confidentiality and privacy of the information you entrust to us. We recognise how important it is to keep your personal data private, and we work to keep your information secure whenever you use our services.

8.2. We maintain strict confidentiality standards and controls to prevent unauthorised access to, or disclosure, alteration or destruction of, the information under our control, including your personal and financial information.

8.3. We handle personal data in line with UK data protection law, including the UK GDPR and the Data Protection Act 2018, and, where it applies to our processing, the EU General Data Protection Regulation, so that your information is handled lawfully, fairly and securely.

8.4. Our approach to handling data is based on:● Lawfulness, fairness and transparency: we collect, process and use your data ethically and within the law, and we are open about how we do so.● Purpose limitation: we collect data for specific purposes connected with providing our services.● Data minimisation: we collect only the data we need to provide our services.● Accuracy: we keep data accurate and up to date so far as we can.● Storage limitation: we keep data only for as long as it is needed for its purpose.● Integrity and confidentiality: we apply strong security measures to protect your data at every stage.

8.5. We review and update our practices and policies as needed so that we continue to meet our legal obligations and protect your information. Our full Privacy Policy published at sends.co/privacy-policy and Cookies Policy are published separately at sends.co/cookie-policy and explain in more detail how we handle your personal data.

9.1. These Terms, and any dispute or claim arising out of or in connection with them or their subject matter or formation, including non-contractual disputes or claims, are governed by and interpreted in accordance with the law of England and Wales. By accessing and using the Website, you agree that the law of England and Wales applies to any matter or dispute relating to or arising out of these Terms, and to any dispute of any kind between you and SENDS, without regard to conflict of law rules.

9.2. You agree that any legal action or proceeding relating to or arising out of your use of the Website, these Terms or our services will be brought only in the competent courts of England and Wales. If you are a consumer, you may also bring proceedings in the courts of the part of the United Kingdom in which you live, and you benefit from any mandatory consumer protection of the law that applies where you live. Nothing in this clause affects those rights.

9.3. We believe most disputes can be settled amicably. Before starting any formal dispute resolution, we ask you to contact us so that we can try to find an amicable solution. This does not affect your right to bring a claim against us in the competent courts of England and Wales, as set out above.

10.1. The headings in these Terms are for convenience only and do not affect how they are interpreted.

10.2. In these Terms, unless stated otherwise, the singular includes the plural, any gender includes every gender, and a reference to a person includes a company, a partnership or any other body or entity, and the other way around.

10.3. Where we use the words "includes" or "including" or similar words, they mean without limitation and do not restrict the meaning of the words around them.

10.4. We will not be liable for any delay or failure to perform an obligation under these Terms if it is caused by circumstances beyond our reasonable control.

10.5. Nothing in these Terms is intended to give any person who is not a party to them any right under the Contracts (Rights of Third Parties) Act 1999 to enforce any of their terms.

10.6. Each provision of these Terms, or part of a provision, is severable. If any provision is or becomes illegal, invalid or unenforceable in any jurisdiction, that will not affect the legality, validity or enforceability of the remaining provisions. The affected provision will apply with the minimum change needed to make it legal, valid and enforceable.

10.7. If we fail or delay in enforcing any provision of these Terms, that will not be a waiver of that provision or of any other provision.

10.8. You may not assign or transfer any of your rights or obligations under these Terms.

10.9. These Terms are the whole agreement and understanding between you and us about their subject matter and your use of the Website. They do not affect, replace or override the Agreement or any Partner Terms, which govern the relevant services and prevail over these Terms in the event of any conflict about those services.

Email address: [email protected]

Registered office: 11 Garden Court Tewin Road, Welwyn Garden City, Herts, England, AL7 1BH