TERMS OF SERVICE

1.ACCEPTANCE OF THESE TERMS#

By creating a User Account, affirmatively accepting these Terms through the Rovela App or another acceptance process we make available, accessing or using the Service, or initiating a transaction, you confirm, represent and warrant that: (i) you have had a reasonable opportunity to access and review these Terms and any disclosures presented to you; (ii) you have read and understood them and agree to be bound by them; (iii) you understand the nature and limitations of the Service; (iv) you acknowledge and agree to the involvement of Affiliates and Service Partners as described in these Terms; (v) all information and documents you provide are accurate, complete, current, genuine and lawfully provided; (vi) you have the legal capacity and authority to use the Service; and (vii) you will comply with these Terms and Applicable Law.

Your decision not to read or review all or part of these Terms does not, by itself, affect the validity of your acceptance where these Terms and relevant disclosures have been made reasonably available to you, subject to Applicable Law.

Certain features may also be subject to a fee schedule, feature-specific terms, transaction-specific disclosures or separate terms with an Affiliate or Service Partner. If feature-specific terms expressly conflict with these Terms, the feature-specific terms will apply to the relevant feature to the extent of that conflict. A separate agreement with an Affiliate or Service Partner applies only to the services and parties identified in that agreement.

2.DEFINITIONS#

“Add Funds” means a supported transaction through which funds are added to your Travel Balance using a funding method made available through the Service. An Add Funds transaction may remain pending until the applicable processing and settlement requirements have been completed.

“Affiliate” means an entity that directly or indirectly controls, is controlled by, or is under common control with the Company. “Control” means the power to direct the management or policies of an entity, whether through ownership, voting rights, contractual rights or otherwise.

“Applicable Law” means any law, regulation, regulatory requirement, binding governmental or court order, mandatory consumer protection rule, payment rule, sanctions requirement, data protection requirement or other legally binding requirement applicable to you, us, an Affiliate, a Service Partner, the Service or a transaction.

“Card Funding Transaction” means an Add Funds transaction made using a supported credit or debit card. It does not include a bank transfer or a Payment made to a Merchant using your Travel Balance.

“Funding Affiliate” means an Affiliate that supports one or more Add Funds functions through acquiring, banking, payment-processing or related financial arrangements, including transaction processing, reconciliation, settlement or onward transfer of funds, to the extent applicable to the relevant funding arrangement.

“Local Payment Partner” means a licensed, authorized or otherwise legally permitted financial or payment service provider that processes or facilitates supported local Payments through applicable payment infrastructure.

“Merchant” means a merchant or other supplier of goods or services to whom you make a Payment using the Service.

“Merchant of Record” or “MoR” means the entity designated as merchant of record under the applicable acquiring arrangement for a Card Funding Transaction. Acting as MoR for a Card Funding Transaction does not, solely by reason of that role, make that entity the Merchant or supplier of goods or services subsequently purchased using the Travel Balance.

“Partner Bank” means a bank through which funds underlying the Travel Balance are received, held, processed, transferred or settled under the applicable banking or financial arrangement.

“Rovela App” means the mobile application operated under the ROVELA brand through which you may access and use the Service.

“Service” means the ROVELA platform, customer interface and related services governed by these Terms, including features made available through the Rovela App, website or another supported interface.

“Service Partners” means independent third-party providers engaged in connection with the Service, including Partner Banks, acquirers, card networks, banks, payment processors, Local Payment Partners, authorized foreign exchange providers, identity verification providers, compliance providers, fraud-prevention providers and technology providers. For clarity, Service Partners do not include the Company or its Affiliates.

“Supported Currency” means a currency made available for one or more functions of the Service, including Add Funds, Travel Balance, currency conversion, Payments or return of funds. A currency may be supported for one function without necessarily being supported for another.

“Supported Market” means a country, territory or market in which we make a particular Service or feature available from time to time.

“Travel Balance” means the multi-currency travel spending balance displayed through ROVELA representing amounts recorded as available to you for eligible travel spending and other supported transactions, subject to pending transactions, holds, reversals and other adjustments under these Terms. The Travel Balance is distinct from the underlying customer funds held, processed or settled under the applicable financial arrangements.

“User”, “you” or “your” means the individual who accesses or uses the Service and agrees to these Terms.

“User Account” means your registration and access profile through which you access and use the Service. A User Account is not itself a bank account.

“VIFC” means the Vietnam International Financial Centre as established and operated under the applicable laws and regulatory framework of Vietnam.

3.ELIGIBILITY AND USER ACCOUNT#

You must be at least 18 years old, have the legal capacity to enter into these Terms and satisfy the eligibility requirements applicable to your use of the Service. Those requirements may relate to (i) your country or place of residence; (ii) nationality; (iii) travel or immigration status where relevant; (iv) identity verification; (v) Supported Markets; (vi) applicable regulatory requirements; and (vii) sanctions, compliance and risk requirements.

You may use the Service only for your own permitted personal travel and payment purposes. You must not open or operate a User Account on behalf of another person, business or undisclosed beneficiary.

You must provide and maintain accurate, complete and current information and promptly update any material change to information relevant to your use of the Service.

You must not create or use multiple User Accounts to circumvent eligibility requirements, verification, transaction limits or other restrictions or controls.

4.THE SERVICE#

Subject to eligibility and availability, the Service may enable you to (i) create and access a User Account; (ii) complete required verification; (iii) Add Funds using supported funding methods; (iv) view and use your Travel Balance in Supported Currencies; (v) obtain applicable foreign exchange quotations; (vi) initiate eligible Payments; (vii) view transaction information; (viii) request a return of funds where supported; and (ix) access other features made available from time to time.

Unless expressly stated otherwise, the Company is not a bank and does not itself perform a regulated financial activity that must, under Applicable Law, be performed by an appropriately licensed, authorized or otherwise legally permitted financial service provider. Such activities may be performed through the relevant Affiliate or Service Partner.

An Add Funds transaction and a subsequent Payment to a Merchant are separate transactions and may involve different Affiliates, Service Partners, processing times, settlement routes and financial arrangements.

Certain features may be provided under or in connection with VIFC, a regulatory sandbox, a special regulatory framework or another legally permitted arrangement. Where applicable, the relevant feature may be subject to additional eligibility requirements, regulatory conditions, transaction limits or other conditions disclosed in connection with that feature.

Unless expressly made available as a separate product, the Service does not provide credit, overdraft facilities, investment products or investment returns.

5.AFFILIATES AND SERVICE PARTNERS#

We may use one or more Affiliates to support particular functions of the Service, including funding, processing, settlement, technology, operations or other supporting activities. Each Affiliate is a separate legal entity and acts according to its applicable role and contractual arrangements.

A Funding Affiliate may support Add Funds activities through arrangements with acquirers, banks, card processors and other payment service providers and may, where applicable, act as MoR for a Card Funding Transaction.

We and our Affiliates may engage Service Partners to provide or support banking, acquiring, payment processing, foreign exchange, local payment, identity verification, compliance, fraud prevention, technology and other functions required for the Service.

Where you are required to enter into a separate agreement directly with an Affiliate or Service Partner, the identity of that entity and the relevant terms will be presented in connection with the applicable feature.

The use of an Affiliate or Service Partner does not, by itself, create a bank or other financial account in your individual name.

We may add, replace or change Affiliates, Service Partners or transaction routing where reasonably necessary for commercial, operational, legal, regulatory, security, technical or risk reasons.

Certain Affiliates and Service Partners operate independently and may make decisions outside our control, including whether to approve or decline a transaction, require additional checks, apply their own risk controls, determine processing time or continue providing a service.

To the fullest extent permitted by Applicable Law, we do not guarantee, and are not responsible for, the availability, solvency, systems, independent acts, omissions or decisions of an Affiliate or Service Partner to the extent the relevant matter is outside our reasonable control and is not a responsibility that Applicable Law places on us.

6.IDENTITY VERIFICATION, COMPLIANCE AND RISK CONTROLS#

We, our Affiliates and relevant Service Partners may request information or documentation including (i) your name, date of birth and nationality; (ii) proof of identity; (iii) contact and residence information; (iv) travel status where relevant; (v) photograph, selfie, identity matching, biometric or liveness verification where permitted; (vi) information regarding your funding source; (vii) the purpose of a transaction; (viii) source of funds or source of wealth; and (ix) other information reasonably required for compliance, security or risk purposes.

We, our Affiliates and relevant Service Partners may conduct customer due diligence, risk profiling, sanctions screening, PEP and watchlist screening, ongoing screening, fraud checks, transaction monitoring and other controls intended to detect or prevent fraud, money laundering, terrorist financing, sanctions violations or other unlawful activity.

Where required by Applicable Law or applicable payment arrangements, relevant originator, beneficiary or transaction information may also be collected, verified, retained or transmitted.

You must cooperate with verification and compliance reviews and provide information and documents reasonably requested from you.

To the fullest extent permitted by Applicable Law, we may delay, decline, block, restrict, review or, where appropriate, reverse a transaction where we reasonably consider this necessary for compliance, fraud prevention, sanctions, AML/CFT, security, operational integrity or risk-management purposes.

We may make reports or disclosures to competent authorities where legally required or permitted.

Where legally permitted, we are not required to disclose confidential monitoring criteria, regulatory reports, internal risk assessments or other information where disclosure is prohibited or could compromise our controls or an investigation.

7.ACCOUNT SECURITY AND AUTHENTICATED INSTRUCTIONS#

Your User Account is personal to you. You must not sell, assign, lend, share or permit another person to use it.

You are responsible for taking reasonable steps to protect (i) your device; (ii) passwords and PINs; (iii) OTPs and other authentication credentials; (iv) biometric credentials; (v) your registered email address and telephone number; and (vi) other information used to access or authenticate your User Account.

You must notify us promptly if your device or credentials are lost, stolen or compromised, if you suspect unauthorized access or if you identify an unauthorized or incorrect transaction.

To the fullest extent permitted by Applicable Law, we may reasonably rely on an instruction submitted through your User Account using the authentication method required by ROVELA unless (i) you notified us before the instruction was processed that your User Account or credentials had been compromised; or (ii) we knew, or reasonably should have known, that the instruction may be unauthorized.

You are responsible for reviewing all material transaction information before authenticating or confirming an instruction.

The use of valid authentication credentials may be taken into account when investigating a disputed transaction but will not, by itself, conclusively determine authorization where Applicable Law requires otherwise.

8.ADDING FUNDS#

You may Add Funds using the funding methods and Supported Currencies made available through the Service. Supported funding methods may include credit cards, debit cards, bank transfers and other methods made available from time to time.

Before you confirm an Add Funds transaction, the Service may display material transaction information including (i) the amount; (ii) funding currency; (iii) applicable Travel Balance currency; (iv) applicable fees; (v) currency conversion where applicable; and (vi) other material information relevant to the transaction.

You must own or be legally authorized to use the funding source.

By confirming an Add Funds transaction, you authorize us to transmit the relevant instruction and information to the applicable Funding Affiliate and Service Partners and authorize those entities to process the transaction under the applicable arrangements.

8.1 Funding Affiliate

A Funding Affiliate may support functions including (i) transaction processing; (ii) acquiring or banking connectivity; (iii) reconciliation; (iv) settlement; and (v) onward transfer of funds, in each case to the extent permitted under the applicable contractual, banking and legal arrangements.

The applicable funding route may vary depending on the funding method, Supported Currency, acquiring arrangement, banking arrangement, Service Partner and applicable operational or regulatory requirements.

8.2 Card Funding Transactions

When you confirm a Card Funding Transaction, you authorize the amount and currency displayed, together with any disclosed fees or charges, to be submitted through the applicable acquiring and card-processing arrangements.

Your card issuer may require additional authentication or verification and may independently approve or decline the transaction.

A card authorization or temporary hold does not constitute final settlement.

Where value has been made available in your Travel Balance before final settlement and the Card Funding Transaction is subsequently reversed, charged back or fails to settle, we may place a corresponding amount on hold or adjust your Travel Balance to reflect the confirmed transaction outcome.

Your card issuer or card network may independently apply fees, interest, currency conversion or other treatment under its own terms. To the fullest extent permitted by Applicable Law, we are not responsible for charges independently imposed by those providers outside our reasonable control.

8.3 Merchant of Record

For certain Card Funding Transactions, the Company or a Funding Affiliate may act as MoR where designated under the applicable acquiring arrangement.

Where applicable, the MoR’s name or an approved transaction descriptor may appear on your card statement.

MoR status applies only in relation to the applicable Card Funding Transaction and does not make the MoR the Merchant or supplier of goods or services subsequently purchased using your Travel Balance.

8.4 Bank Transfer Funding

Where bank transfer funding is available, you must use the beneficiary details, bank information, Supported Currency and payment reference provided for the applicable transfer.

Bank details or payment references provided to identify or reconcile a transfer do not, by themselves, establish a bank account in your name.

A bank transfer will be reflected in your Travel Balance only after the relevant funds have been received, identified and processed under the applicable banking and compliance arrangements.

A debit or transfer confirmation from your sending bank does not, by itself, establish that the funds have been received or are available in your Travel Balance.

Bank transfers may be delayed or rejected because of bank operating hours, cut-off times, intermediary banks, incorrect or incomplete information, unsupported currencies, compliance checks or other circumstances outside our reasonable control.

Fees imposed independently by your sending bank, intermediary bank or another financial institution may affect the amount received or returned.

8.5 Funding Limits and Adjustments

Add Funds transactions may be subject to minimum or maximum amounts, transaction-frequency limits, cumulative limits or other restrictions based on factors including your verification status, funding method, Supported Currency, jurisdiction, Service Partner requirements, compliance requirements and risk controls.

You must not structure or split Add Funds transactions to circumvent applicable limits or controls.

An Add Funds transaction may remain pending, be declined, fail to settle, be cancelled, reversed or charged back because of an issuer or bank decision, compliance review, processing error, duplicate transaction, dispute, recall or another valid transaction event.

Where an Add Funds transaction is reversed, charged back or otherwise fails after value has been reflected in your Travel Balance, we may place a corresponding amount on hold or adjust your Travel Balance.

9.TRAVEL BALANCE AND UNDERLYING CUSTOMER FUNDS#

Your Travel Balance represents amounts recorded through ROVELA as available to you for eligible travel spending and other supported transactions.

Amounts that are pending, reserved for authorized transactions or otherwise restricted are not available for new spending.

The Travel Balance is distinct from the underlying customer funds and does not itself constitute a bank account or establish that underlying funds are held in an individual bank account in your name.

We may maintain records of credits, debits, fees, pending transactions, holds, reversals and adjustments reflected in your Travel Balance and coordinate reconciliation with relevant Affiliates and Service Partners.

Funds underlying the Travel Balance may be received, held, processed, transferred or settled through a Partner Bank and, where relevant, other authorized financial service providers.

The entities and financial arrangements involved may vary depending on the funding method, Supported Currency, Supported Market and applicable regulatory framework.

Where the identity of a Partner Bank or the nature of a particular financial arrangement must be disclosed to you, the relevant information will be made available through the Service or applicable disclosure.

The legal treatment and protection of underlying customer funds are determined by the applicable banking or financial arrangement and Applicable Law. We do not represent that safeguarding, segregation, deposit insurance or another specific protection applies unless that protection is expressly disclosed.

Access to underlying customer funds may be affected by circumstances involving a Partner Bank or another financial service provider, including operational disruption, regulatory action, insolvency or other events outside our reasonable control.

To the fullest extent permitted by Applicable Law, we are not responsible for such independent circumstances to the extent they are outside our reasonable control, but we may provide reasonable assistance using available records and communications relating to your Travel Balance and transactions.

The Service does not provide an overdraft or credit facility.

Unless expressly provided under a separate product or arrangement, the Travel Balance does not earn interest or investment returns.

10.SUPPORTED CURRENCIES, FOREIGN EXCHANGE AND FEES#

The Supported Currencies and functions available to you will be displayed through the Service.

Currency conversion may be required when you Add Funds, convert between Supported Currencies, make a Payment, receive a refund or return funds.

Where currency conversion is required, it may be performed through a Partner Bank or another appropriately authorized financial service provider. ROVELA may facilitate presentation of the applicable exchange rate and transmission of the relevant conversion instruction.

Before you authorize a currency conversion, the Service may display (i) the source currency; (ii) destination or payment currency; (iii) amount to be debited; (iv) amount to be credited or paid; (v) applicable exchange rate; (vi) fees or charges; and (vii) other material transaction information.

By confirming the transaction, you accept the exchange rate and converted amount presented for that transaction.

Exchange rates may change until a transaction is confirmed. If a quote expires or materially changes before execution, you may be required to review and confirm updated transaction information.

We do not guarantee an interbank, central-bank, mid-market, wholesale or best available exchange rate.

Exchange rates may differ between the time funds are added, converted, spent, refunded, reversed or returned. Accordingly, an amount received following a refund, reversal or return may differ from the amount originally funded or spent.

We may charge fees for certain Services. By confirming a transaction, you authorize deduction of fees or charges disclosed for that transaction.

Banks, card issuers, intermediary banks and other providers may independently impose fees, interest, taxes, currency conversion or other charges under their own arrangements. Those amounts may be outside our reasonable control.

11.PAYMENTS#

You may use your Travel Balance to initiate eligible Payments to supported Merchants through payment methods made available through the Service, including supported Merchant QR codes or other supported payment identifiers.

Before confirming a Payment, you must review the Merchant or recipient information, transaction amount, payment currency, Travel Balance currency, applicable currency conversion, fees and other material transaction information.

By confirming a Payment using the required authentication method, you authorize (i) the specific transaction amount; (ii) disclosed fees or charges; (iii) any currency conversion presented to you; (iv) the corresponding amount to be reserved or debited from your Travel Balance; and (v) the relevant Payment instruction and information to be transmitted and processed through the applicable Affiliates and Service Partners.

Supported local Payments may be processed or facilitated by a Local Payment Partner through the applicable local payment infrastructure.

Once a Payment instruction has been confirmed and accepted for processing, cancellation may not be possible.

To the fullest extent permitted by Applicable Law, we are not required to cancel, reverse or compensate you for a correctly authenticated Payment solely because you (i) changed your mind; (ii) selected the wrong Merchant; (iii) used an incorrect payment code or payment identifier; (iv) confirmed an incorrect amount; or (v) misunderstood the underlying purchase.

You must not authorize a Payment where the QR code or payment identifier appears altered, the displayed Merchant or recipient does not match the intended Merchant, or the transaction information is otherwise incorrect.

We do not guarantee that (i) every Merchant is supported; (ii) every QR code or payment identifier is compatible with the Service; (iii) every supported Merchant will remain available; (iv) every Payment will be approved; or (v) local payment infrastructure will always be available.

12.TRANSACTION STATUS, ERRORS AND UNAUTHORIZED TRANSACTIONS#

A transaction may be displayed as pending, completed, failed, rejected, cancelled, reversed or another status supported by ROVELA.

The corresponding amount may be reserved and unavailable for other transactions.

A completed status means that the relevant transaction confirmation has been received through the applicable processing arrangement. A completed transaction may subsequently be subject to a valid refund, reversal, chargeback or correction.

If a Payment fails after the corresponding amount has been reserved or debited, we may restore, release or adjust the relevant amount once the final transaction outcome has been confirmed.

If a transaction status is unclear or a Merchant indicates that a Payment has not been received, you should check the transaction status through ROVELA or contact us before attempting the Payment again.

To the fullest extent permitted by Applicable Law, we are not responsible for a duplicate Payment resulting from your re-initiating a transaction despite a pending or unclear transaction status where the Service made that status reasonably available to you.

We may correct identifiable technical, processing, settlement or recording errors to reflect the confirmed transaction outcome.

You must notify us promptly if you believe a transaction was unauthorized or incorrectly executed.

To the fullest extent permitted by Applicable Law, authentication records, device information, transaction logs, security records, timestamps and other electronic records may be taken into account when investigating or determining the status or authorization of a transaction.

13.MERCHANT TRANSACTIONS AND REFUNDS#

Your purchase of goods or services is a transaction between you and the Merchant.

Unless expressly stated otherwise, we do not sell, supply, deliver, endorse or warrant the goods or services provided by a Merchant.

The Merchant is responsible for matters relating to the underlying goods or services, including price, availability, quality, quantity, delivery, suitability, cancellation, warranty and refund arrangements.

Payment confirmation through ROVELA confirms the relevant payment status only and does not constitute our endorsement, recommendation or guarantee of the Merchant or its goods or services.

A dispute with a Merchant does not, by itself, reverse or invalidate a correctly processed Payment.

A Merchant refund, local Payment reversal, Card Funding Transaction chargeback and bank-transfer recall are separate processes and may be subject to different rules, parties and processing times.

A refund relating to a purchase does not automatically reverse the Add Funds transaction used to fund your Travel Balance, and a dispute relating to an Add Funds transaction does not automatically reverse a completed Merchant Payment.

Where a refund or reversal is received and confirmed, the applicable amount may be credited to your Travel Balance or returned through another supported method depending on the transaction type and applicable financial arrangement.

Where the relevant transaction involved currency conversion, the amount credited or returned may differ from the original amount because of exchange-rate movements, applicable fees or the conversion method used for the refund or return.

14.RETURN OF FUNDS AND REMAINING TRAVEL BALANCE#

Where supported and permitted under the applicable financial arrangement and Applicable Law, you may request the return of unused amounts available in your Travel Balance.

Available return methods may include (i) return to the original funding source; (ii) transfer to a verified bank account; or (iii) another supported return method made available through ROVELA.

A return of funds is not an unrestricted cash-out, money-transfer or remittance service.

Available return methods may vary depending on the original funding method, Supported Currency, Supported Market, Partner Bank, Funding Affiliate, Service Partners and applicable compliance or regulatory requirements.

We and the relevant Affiliates or Service Partners may verify your identity, entitlement to the funds and the destination of the return before processing a return.

Where required under the applicable funding, banking or compliance arrangement, funds may be returned to the original funding source. If the original funding source is no longer available, an alternative verified return method may be used only where supported and legally permitted.

A return may be delayed, restricted or placed on hold where reasonably necessary to address (i) pending transactions; (ii) chargebacks; (iii) refunds or reversals; (iv) compliance or fraud reviews; (v) legal or regulatory restrictions; or (vi) another outstanding transaction obligation.

Closing your User Account or discontinuation of the Service does not, by itself, extinguish your entitlement to amounts properly available for return.

Any remaining amount will remain subject to pending transactions, valid adjustments, compliance requirements, applicable financial arrangements and Applicable Law.

15.REVERSALS, CHARGEBACKS, SET-OFF AND AMOUNTS YOU OWE#

An Add Funds transaction or Payment may be reversed, recalled, charged back, duplicated, incorrectly recorded or fail to settle.

Where such an event occurs, we may place a corresponding amount on hold or adjust your Travel Balance to reflect the confirmed transaction outcome.

If a valid chargeback, reversal, correction, fee or other adjustment results in an insufficient or negative Travel Balance or otherwise creates an amount owed by you to us, you remain responsible for that amount.

To the fullest extent permitted by Applicable Law, we may (i) deduct an amount owed from your available Travel Balance; (ii) set it off against amounts subsequently credited or payable to you through the Service; (iii) reserve amounts reasonably connected with a pending chargeback, reversal or dispute; (iv) restrict further transactions or access to affected features; (v) require repayment; and (vi) take reasonable lawful steps to recover any outstanding amount.

These Terms do not, by themselves, authorize us to initiate a new debit from an external card or bank account without the authorization required for that debit.

You must not knowingly retain duplicate value arising from a refund, reversal, chargeback or other recovery relating to the same transaction and must not use multiple recovery mechanisms to recover the same transaction more than once.

16.LIMITS, PROHIBITED USE, SUSPENSION AND TERMINATION#

The Service may be subject to limits on Add Funds, Travel Balance amounts, individual or aggregate Payments, returns of funds, transaction frequency, Supported Currencies, Supported Markets, Merchant categories or other transaction parameters.

Limits may depend on (i) verification status; (ii) funding method; (iii) Supported Currency; (iv) jurisdiction; (v) transaction history; (vi) Service Partner requirements; (vii) compliance requirements; and (viii) fraud-prevention, security or risk controls.

You must not use the Service to (i) engage in unlawful, fraudulent, deceptive or unauthorized activity; (ii) use a funding source you do not own or are not authorized to use; (iii) impersonate another person; (iv) provide false, forged or misleading information; (v) conceal the source, ownership, beneficiary or purpose of funds; (vi) evade KYC, AML/CFT, sanctions, transaction-monitoring or risk controls; (vii) structure or split transactions to circumvent limits or controls; (viii) facilitate unsupported cash withdrawals, person-to-person transfers, commercial collections or other unsupported transaction types; (ix) misuse refunds, reversals, chargebacks, promotions or other Service features; (x) falsify proof of payment; (xi) exploit pricing, foreign-exchange, Travel Balance or technical errors; or (xii) interfere with, disrupt, damage, reverse engineer, bypass security controls or gain unauthorized access to the Service or related systems.

To the fullest extent permitted by Applicable Law, we may immediately and, where appropriate, without prior notice delay, decline, block, restrict or suspend a transaction, feature or User Account where reasonably necessary because (i) required information is incomplete; (ii) additional verification is required; (iii) a limit has been exceeded; (iv) fraud, unauthorized activity or misuse is suspected; (v) an Affiliate or Service Partner rejects or cannot process the transaction; (vi) a chargeback or dispute is under review; (vii) there is a technical, operational or security issue; (viii) you breach these Terms; (ix) a competent authority requires action; or (x) continued use could expose us, an Affiliate or Service Partner to material legal, regulatory, compliance, financial, reputational, fraud, sanctions or security risk.

We may close your User Account where reasonably necessary because of (i) a material or repeated breach of these Terms; (ii) fraud or unlawful activity; (iii) material compliance, security or risk concerns; (iv) legal or regulatory requirements; (v) discontinuation of the relevant programme or Service; or (vi) circumstances that make continued provision of the Service unlawful, impracticable or commercially unreasonable.

Suspension, restriction or closure does not affect accrued rights or obligations, pending transactions, valid adjustments, chargebacks, reversals, returns of funds or outstanding amounts.

17.SERVICE AVAILABILITY AND DISCLAIMERS#

The Service may depend on compatible devices, software, internet connectivity, telecommunications services, banking systems, payment networks, Affiliates and Service Partners.

You are responsible for maintaining (i) a compatible device; (ii) a current supported version of the Rovela App where applicable; (iii) suitable internet or mobile connectivity; (iv) any roaming or carrier charges; and (v) an alternative means of payment while travelling.

Except for obligations that cannot lawfully be excluded, we do not represent or warrant that (i) the Service will always be uninterrupted, timely, secure or error-free; (ii) every Add Funds transaction or Payment will be approved, completed or processed within a particular time; (iii) every Merchant, QR code, payment identifier, funding method, Supported Currency or payment channel will remain available; (iv) any exchange rate will remain available for a particular period; (v) information or services provided by an independent Service Partner will always be accurate, complete or available; or (vi) the Service will meet all of your travel or payment needs.

ROVELA is a payment service and is not a travel agency, transport provider, accommodation provider, insurer or emergency service.

You should not rely on ROVELA as your sole means of paying for accommodation, transportation, medical care, food or other urgent or time-sensitive expenses.

18.EXCLUSION AND LIMITATION OF LIABILITY#

To the fullest extent permitted by Applicable Law, we are not liable for loss arising from or relating to (i) inaccurate, incomplete or incorrect information or instructions provided by you; (ii) your failure to protect your User Account, device or authentication credentials; (iii) your fraud, misconduct or unlawful activity; (iv) transaction details that you authenticated or confirmed incorrectly; (v) an altered, incorrect, fraudulent or compromised QR code or payment identifier outside our reasonable control; (vi) goods, services, conduct or omissions of a Merchant; (vii) an issuer, card network, acquirer, bank, Affiliate or Service Partner declining, delaying, reversing or failing to process a transaction where the relevant matter is outside our reasonable control; (viii) telecommunications, internet, mobile or device failures; (ix) market movements, exchange-rate differences or charges independently imposed by another provider; (x) regulatory, sanctions, legal or governmental action; (xi) cyber incidents or security events outside our reasonable control; or (xii) force majeure or other circumstances beyond our reasonable control.

To the fullest extent permitted by Applicable Law, we are not liable for indirect, incidental, punitive, exemplary, special or consequential losses, including loss of profit, revenue, business opportunity, goodwill, anticipated savings, data, travel opportunity or enjoyment.

To the fullest extent permitted by Applicable Law, we are also not liable for (i) missed transport; (ii) missed bookings or reservations; (iii) additional accommodation or transportation costs; (iv) immigration or travel consequences; (v) loss arising from a Merchant refusing or being unable to accept a Payment; (vi) medical, travel or emergency costs arising from your reliance on ROVELA as your sole means of payment; or (vii) other travel-related consequential losses.

Our total aggregate liability to you arising out of or in connection with the service, these Terms or any transaction will not exceed the greater of the total fees paid directly by you to us during the 12 months immediately preceding the event giving rise to the claim.

For purposes of this limitation, returning or restoring amounts that properly form part of your Travel Balance is not treated as damages merely because those amounts are returned or restored.

Nothing in these Terms excludes or limits liability to the extent that such liability cannot lawfully be excluded or limited.

19.INDEMNITY#

To the fullest extent permitted by Applicable Law, you will indemnify us against direct, reasonable and documented losses, liabilities, costs and third-party claims arising from (i) your fraud or intentional unlawful conduct; (ii) your knowing misuse of the Service; (iii) your use of a funding source without authorization; (iv) your intentional provision of false, forged or misleading information; (v) your deliberate circumvention of sanctions, AML/CFT, KYC or other risk controls; or (vi) your material intentional breach of these Terms.

This Section does not require you to indemnify us for losses caused by our own fraud or wilful misconduct.

20.RECORDS, COMMUNICATIONS AND PRIVACY#

You should review your transaction history and notify us promptly if you identify an error, unauthorized transaction or other discrepancy.

To the fullest extent permitted by Applicable Law, electronic records, authentication data, transaction logs, system logs and communications may be relied upon as evidence of activity conducted through your User Account.

We may provide transaction confirmations, Service notices, regulatory disclosures and changes to these Terms through the Rovela App, your registered email address or another contact channel associated with your User Account.

You are responsible for keeping your contact information current.

Our Privacy Notice, available at https://rovelapay.com/privacy, explains how personal data is processed in connection with the Service.

Personal data may be shared with Affiliates and Service Partners and processed across borders where necessary to operate, secure and support the Service, process transactions, conduct verification and compliance activities, prevent fraud or satisfy legal requirements.

Acceptance of these Terms does not, by itself, constitute consent to every form of personal data processing. Where separate consent is required under Applicable Law, it may be requested separately.

21.CHANGES AND GENERAL TERMS#

We may amend the Service or these Terms to reflect (i) changes in Applicable Law or regulatory requirements; (ii) changes to Service features, Affiliates or Service Partners; (iii) security, technology or risk requirements; (iv) changes to operational, banking, payment or financial arrangements; or (v) legitimate commercial needs.

If you do not agree to a material change, you may stop using the Service and request closure of your User Account and return of remaining amounts in accordance with Section 14. Changes will not retrospectively alter the terms of a transaction already authorized unless required by Applicable Law.

You may not assign or transfer your User Account or your rights or obligations under these Terms without our prior written consent.

We may assign or transfer our rights or obligations as part of a lawful corporate reorganisation, merger, acquisition, financing, sale or transfer of all or part of the relevant business, subject to Applicable Law.

If any provision of these Terms is invalid, illegal or unenforceable, it will apply to the maximum extent permitted by law or be modified or severed only to the minimum extent necessary. The remaining provisions will continue in effect. A delay or failure by us to exercise a right does not waive that right.

These Terms, together with any applicable feature-specific terms, fee schedule and other terms expressly incorporated into them, constitute the agreement governing your use of the Service.

Provisions that by their nature are intended to survive suspension, closure or termination will survive, including provisions concerning pending transactions, remaining funds, reversals, chargebacks, outstanding amounts, records, intellectual property, liability, indemnity and dispute resolution.

22.GOVERNING LAW AND DISPUTE RESOLUTION#

These Terms are governed by the laws of Vietnam, including the special legal framework applicable to the Vietnam International Financial Centre (“VIFC”).

If a dispute arises out of or in connection with these Terms or the Service, the parties shall first attempt in good faith to resolve it within 30 days after written notice of the dispute is received.

If the dispute is not resolved within that period, it shall, subject to any mandatory rights available under Applicable Law, be finally resolved by arbitration administered by the VIFC International Arbitration Centre (“VIFCA”) in accordance with the VIFCA Arbitration Rules in force when the arbitration is commenced.

The Tribunal shall consist of three arbitrators. The seat of arbitration shall be Ho Chi Minh City, Vietnam, and the language of arbitration shall be English. The arbitral award shall be final and binding on the parties.

Nothing in this Section prevents a party from seeking urgent interim or conservatory relief from a court of competent jurisdiction or limits any dispute-resolution right that cannot lawfully be excluded under Applicable Law.

23.INTELLECTUAL PROPERTY#

ROVELA, the Rovela App, software, interfaces, designs, content, trademarks, logos, technology and related intellectual property belong to us or the relevant rights holder.

Subject to your compliance with these Terms, we grant you a limited, personal, revocable, non-exclusive and non-transferable right to use the Service solely for its intended personal purpose.

Except where expressly permitted by Applicable Law, you must not reproduce, distribute, sell, sublicense, modify, scrape, commercially exploit, reverse engineer, decompile, bypass security controls, remove proprietary notices or otherwise misuse any part of the Service or related intellectual property.

24.CONTACT INFORMATION#

Service provider and primary contracting entity:

CÔNG TY TNHH MTV ROVELA PAY (ROVELA PAY COMPANY LIMITED)

Enterprise Registration Number: [●]

Customer Support: [email protected] or through the Rovela App

Website: www.rovelapay.com

Privacy-related requests may be submitted using the contact information specified in the Rovela Privacy Policy or through the support channel above. Where a separate Affiliate or Service Partner is responsible for a particular financial service or transaction, Rovela may direct you to the applicable provider without limiting any right you have to contact that provider directly.