General terms and conditions for the service “Satispay Consumer”

These general terms and conditions are not applicable and are not legally binding for individuals who have not reached the age of 18.

(Version 3.0| 07 July 2026)


These terms of use constitute an agreement ("Agreement") between you ("you", "your" and " User") and Satispay Europe SA ("we", "us", "our" and "Satispay"). Satispay is a Luxembourgish-registered company, with a registered office at 53, Boulevard Royal, L-2449 Luxembourg. Satispay is an electronic money institution authorised and regulated by the Commission de Surveillance du Secteur Financier ("CSSF") with register number W00000010.


Satispay Consumer service is exclusively reserved for natural persons acting for purposes which are outside their trade, business, craft or profession who are either resident or domiciled in one of the countries being part of the European Economic Area ("EEA") listed in the register of payment and electronic money institutions under PSD2 established by the European Banking Authority. In order to fully use our services you must be at least 18 years old, have legal capacity according to applicable laws and hold a bank account in the SEPA area.


If you need further information on us and/or on our Services (as defined below), you may refer to our "Help Center".

1. Services

Satispay will provide you with the following services ("Services"):

  • an electronic money ("E-money") account ("Account") where you may store funds and you can retrieve your transaction history;
  • a payment service that enables you to make payments, also on a recurring basis, ("Payment Service") to merchants that accept E-money issued by Satispay ("Merchants");
  • a peer-to-peer transfer service ("P2P Service") that enables you, also on a recurring basis, to send and to receive funds to and from other persons;
  • a payment service that enables you, also on a recurring basis, to make payments and/or transfer E-money to third parties such as public administrations, state entities or analogous bodies and/or juridical persons other than Merchants (the "Third Parties"), based on the specific function and instructions made available to you in the App (the "Third-Party Service")
  • a debit card (the “Card”), requested by you directly from the Satispay application (the “App*”). The Card is a personal payment instrument linked to your Account, and allows you to perform the supported transactions described below in paragraph 2.2.1;
    • Cards may be made available progressively and may not be available to all Users at the same time. Availability may also depend on the User’s country of residence, Satispay plan and the type of Card requested.
  • a service that enables you to use new features related to the above-mentioned services, based on the instructions we make available to you in the App (the "Related Services").


Certain additional services or features may be governed by dedicated terms, addenda or information documents. Where this is the case, those dedicated terms will supplement this Agreement and will prevail in case of conflict, unless otherwise stated. Satispay reserves the right not to offer all individual Services and features to all Users or in all eligible countries. The availability of certain specific Services and features may be subject to additional eligibility criteria determined by Satispay.

In order to access and use the Services you must have installed the App on a mobile device ("Device"). The App can be downloaded from the main app stores.

The Account is not a deposit account and funds held in the Account will not earn any interest. The Account is opened in the name of the User and not on any third party's behalf. You can allocate your E-money in various sections of your Account (such as money boxes) by following the relevant instructions in the App.

Funds we collect from your bank account in exchange for E-money are safeguarded in compliance with applicable European and national regulations and cannot be claimed by Satispay's creditors in case of its insolvency. For further information on how we ensure the safety of your funds, you may refer to our Help Center.

In order to activate the Services, you must install the App and provide the information and documents required to verify your identity. Additionally, Satispay may perform screenings and profile verifications. When we carry out these checks, your personal information may be disclosed to third parties (such as credit reference agencies and/or fraud prevention agencies) in compliance with our Privacy Policy, as per clause 15 below.

Upon successful completion of our internal checks, we will make the Services available to you.

In order to use the Services, you consent to the checks described in this Agreement being undertaken.

You may have only one Account under this Agreement.

We may not activate the Services or deny, suspend or limit access to the Services in the event that: (i) we are unable to obtain from you and verify the information and documents needed to perform the checks; (ii) we are not satisfied with the results of the checks in light of the obligations imposed on us by the law; (iii) providing the Services to you may expose Satispay or other companies of the Satispay Group to regulatory, financial, legal or reputational risk connected to suspected unauthorised, fraudulent, unlawful, abusive or non-compliant use of the Services. More details on suspension and restrictions are available in clause 7. We will not always provide specific details regarding any failed verification in order to protect our verification process and, more generally, the Services.

1.1. Transactions

You consent to Satispay executing transactions on your Account based on your instructions. This Agreement governs different types of transactions. For clarity:

a) a “Payment” is a transaction initiated by you via the App to: (i) pay Merchants for goods or services using the Payment Service; (ii) send E-money to a person using the P2P Service; (iii) pay and/or transfer E-money to Third Parties using the Third-Party Service;

b) a “Card Transaction” is a transaction performed using your Card. The types of supported Card Transactions are detailed in paragraph 2.2.1 of this Agreement.

Any Payment and Card Transaction are jointly or individually referred to as “Transaction(s)”. Your consent also extends to the use of any Related Services.

1.2. P2P Service

If you have authorised us to access your contact list, you can initiate or request a Payment in favour of or from a person listed among your contacts by using their personalised username (Satistag) or their mobile phone number, even if they do not have an active Satispay account at the time of the initiation. Persons without an active Satispay account can only claim and/or send E-money by activating the account within the timeframe displayed in your App. If the deadline is not met, the Payment will be cancelled and the funds will be made available in your Account.

Satispay’s decision on whether or not to activate your contact’s account is made following the provisions set out under clause 1.

1.3. App

1.3.1. App Use

Subject to clause 17 of the Agreement, we grant you a non-exclusive, non-transferable, royalty-free licence to use the App subject to this Agreement and the rules or policies of the platform you downloaded the App from. This licence also governs any software upgrades or updates that we provide unless we issue a new licence at the time of the upgrade or update.

You understand that the App hasn’t been created just for your needs but has been developed for general use.

When you download and use the App, Satispay has access to some Device information, such as Internet Protocol address, Device name, operating system version and geolocalisation data. When you use the App, it connects via your Internet connection.


You agree not to:

  • translate, adapt, vary, modify, violate, circumvent, reverse-engineer, decompile, disassemble, create derivative works or otherwise interfere with any element of the App, or assist another person in doing so;
  • distribute, publish or otherwise transfer the App to any third party;
  • use the App in any unlawful manner, for any unlawful purpose, in any manner inconsistent with this Agreement, or act fraudulently or maliciously (e.g. by hacking into or inserting malicious code or harmful data into the App or any connected operating system);
  • attempt to install or use the App on any jailbroken/rooted device. Jailbroken devices refer to any devices where software restrictions imposed by iOS, Apple's mobile operating system, are removed. Rooted devices refer to any device where privileged control (known as root access) is attained over various Android, Google’s mobile operating system, versions;
  • collect or harvest any information or data from the App or our systems or attempt to decipher any transmissions to or from the servers running any service;
  • upload any content that is or may be considered violent, threatening, liable to incite racial hatred, in breach of confidence or privacy, discriminatory, defamatory, abusive, unlawful, pornographic, obscene, indecent, profane or that may cause annoyance or inconvenience.


We may suspend, restrict or terminate your use of the Services, including the use of the App, if you use it for unlawful, fraudulent or abusive purposes, if you engage in offensive, threatening, abusive or unlawful conduct towards Satispay, other companies of the Satispay Group, our employees and/or representatives, or if you commit a material or persistent breach of this Agreement.

If you leave Satispay, we suggest that, for privacy/security purposes, you remove the App from all your Devices.


From time to time we may update or modify the App:

  • to reflect changes in relevant laws and regulatory requirements;
  • to offer new services; and/or
  • to implement minor technical adjustments and improvements.


We'll let you know when upgrades are available for the App. Some of these upgrades may be compulsory if you continue using the App; some older versions of the App may become obsolete or cease to be supported over time.

We assume that you've obtained permission to download or install the App from the owners of any Devices you use but don't own. Either or both of you may be charged by your service provider for Internet access on the Devices.

By using the App, you're allowing us to collect and use technical information about the Devices and related software, hardware and peripherals. This allows us to improve our products and to provide our services to you.

If we don't insist that you perform your obligations under this Agreement, it doesn't mean you don't have to. Similarly, if we don't enforce our rights under this Agreement, or we delay in doing so, it doesn't mean we've given up those rights.

1.3.2. App availability

There are times when we may need to carry out planned maintenance on the App. When we do this, all or some of the features on your App might be unavailable for a period of time, so we ensure we give you advance notice before we do this.

In the event of unplanned maintenance (for example, a technical fault or system error) we will make every effort to restore your service as quickly as possible.

We are not held liable for any consequence arising from the App being unavailable as a result of any technical issue that’s beyond our control. This includes the unavailability of connectivity and technical issues with your Device.

1.3.3. App analytics

To help us keep the App working properly and improve your experience, we collect and analyse certain information about how the App is used. This may include app events, such as screens viewed, approximate time spent on screens, time taken to complete certain processes, interaction with app features, connectivity type, technical Device information and, where relevant and permitted, location data. We use this information to identify and fix issues, monitor App performance and usage, and make improvements. Further details may be found in our Privacy Policy.

1.4. Loading funds to your Account

1.4.1. Loading through your bank account

Your Account may be linked to one or more of your bank accounts according to the relevant instructions made available to you in the App. You may load funds into the Account via the App by using a SEPA Direct Debit transfer (the “Top-Up”).

To do that, you must provide all the information requested to generate a proper direct debit mandate (“Mandate”); otherwise, we are unable to load funds into the Account.

Once you have accepted the Mandate, funds will be transferable from your bank account to your Account based on the instructions made available to you in the App.

Top-Up operations are pre-notified via the App, and performed in the shortest technical time cycle available. With reference to the first Top-Up transaction carried out upon your registration or after your request to change the associated bank account, sometimes we may need to perform additional checks to confirm the availability of funds in your bank account.

Should the Top-Up process fail (“Failed Top-Up”) as a result of you having insufficient funds in your bank account, if your direct debit is cancelled or if you have any other issue with your bank account, we may limit and/or suspend your access to the Services until you resolve any issues with your bank account and we are able to successfully perform the Top-Up.

If the E-money in your Account is insufficient to cover your Transactions due to a Failed Top-Up or for any other reason, including where you complete a Transaction above your available balance and the related Top-Up fails, this will result in negative available funds in your Account (“Negative Availability”). Any Negative Availability represents an amount that you owe us. In this situation, you authorise us to initiate a direct debit transaction from your bank account to recover the due amount. Should the recovery process fail, we may contact you to find alternative ways to resolve the issue, without prejudice to our right to take any necessary actions or measures to collect the amount due, also by setting off any amount owed to Satispay for any reason. Please note that in such a case, you will not be able to close your Account until the Negative Availability has been resolved.

1.4.2. Other ways of funding the Account

You may also load funds into the Account through other instruments (such as a SEPA credit transfer from your bank account to Satispay) that we make available to you via the App pursuant to specific agreements, documents or instructions provided to you via the App.

1.5. Payments approval

1.5.1. Single payments

In case a Payment is to be approved (i) by a Merchant, it has the opportunity to refuse such Payment, if the amount or the payer doesn’t match the underlying purchase; (ii) by you, you may refuse such Payment for any reason.

Once a Payment is approved, it cannot be revoked.

1.5.2. Recurring and automatic payments

You may grant your consent to execute recurring or automatic Payments (i) related to the P2P Service or a Third-Party Service pursuant to the instructions you are provided with via the App; and/or (ii) in compliance with the terms agreed with a Merchant. In such circumstances, the Payment is considered approved when you (i) set the recurring P2P Service or Third-Party Service on the App or (ii) authorise a Merchant to automatically debit your balance according to the frequency of your purchases and subscriptions.

You have the right to withdraw, at any time, with immediate effect, your consent for future recurring Payments, it being understood that no refund will be made or due for any approved Payments which have already been performed in compliance with the instructions you provided via the App, or the terms agreed between you and the Merchant.

This paragraph applies to recurring or automatic Payments made through the App and does not apply to recurring Card Transactions, which are authorised and managed under the arrangements you agree with the relevant merchant and the applicable Card payment network rules.

1.6. Payment execution

All Payments are executed in Euro currency. For Card Transactions in other currencies, please refer to paragraph 2.3. If you are the payer, in case of (i) single payments, we execute the Payment by transferring the payment amount to the payee when the Payment is confirmed in the App; (ii) recurring or automatic payments, we transfer the amount to the relevant Merchant on the dates you agreed with the Merchant and/or to the relevant User or Third-Party on the date you specified in the App.

Where made available by Satispay, if the available balance in your Account is not sufficient to execute a Payment, we may initiate an instant Top-Up from your linked bank account under your Mandate to cover the amount needed to execute the Payment on the basis of the relevant instructions made available to you in the App or in our Help Center. Where the Payment requires your confirmation in the App, the missing amount and any applicable fee will be shown to you before you confirm the Payment. For automatic Payments that do not require further confirmation after you have authorised the relevant Merchant, Satispay may initiate the relevant Top-Up without asking for your confirmation at the time of each Payment, where this functionality is available and in accordance with the information made available to you in the App or in our Help Center.

If the relevant Top-Up fails, this will result in Negative Availability and the provisions under paragraph 1.4.1. shall apply.

If you are the payee of a peer-to-peer Payment, we credit the amount of the Payment to your Account when the App confirms the payment receipt. Except for the provisions set out under paragraph 1.2, we may reverse peer-to-peer Payments at any time within ten days of the Payment where the payer's funds are unauthorised, for example, as a consequence of a Failed Top-Up.

2. Card

2.1. Card Issuance, Ownership and Renewal

2.1.1. Request and Issuance

You may request the issuance of a Card directly from the App. Issuance is conditional upon successful activation of your Account as provided under clause 1 above and may also depend on your active Satispay plan, the type of Card requested, your country of residence, any applicable eligibility criteria, and the availability of the Card service from time to time.

The availability, material, cost, delivery method and replacement conditions of each Card will be shown to you in the App before you request the Card. Where a Card is linked to, included in or affected by a Satispay subscription plan, the plan terms will also apply.

Satispay reserves the right to set limits on the number of active Cards a User may hold or on the frequency of new Card requests. The Card is a personal payment instrument linked to your Account and allows you to perform the supported transactions described below.

2.1.2. Card type

Satispay offers two types of Cards:
a) Virtual Card: upon your request, a virtual Card will be provisioned to you and made available within the App for online payments and for addition to supported digital wallets (e.g., Apple Pay, Google Pay).
b) Physical Card: where the service is available, you may request the issuance of a physical Card, which will be shipped to the address you confirm during the request process. Upon receipt of the physical Card, you must activate it in the App. The physical Card is required to perform cash withdrawals at Automated Teller Machines (ATMs) and deposits at ATMs that support that functionality.

2.1.3. Ownership and transferability

The Physical Card remains the property of Satispay. All Cards are strictly personal and non-transferable, and may only be used by you as the holder of the Account to which they are linked.

2.1.4. Expiry and renewal

The Card is valid until the last day of the month indicated on the Card itself (“Expiry Date”). Around the Expiry Date, Satispay may renew or replace your Card, or allow you to request a new Card, in accordance with the conditions applicable to the relevant Card at that time. We may ask you to confirm or update certain information, such as your delivery address, before issuing or shipping a replacement Physical Card.

Satispay reserves the right not to renew or replace a Card where your Account is suspended, restricted or subject to termination, where you do not meet the applicable requirements, where there is unresolved Negative Availability, suspected fraudulent or unlawful use, or a material breach of your obligations under this Agreement. An expired Card can no longer be used. If your Card is renewed or replaced, you may need to update your Card details with merchants, digital wallets or other third parties with whom you have stored or registered the Card. We will notify you in accordance with the communication methods set out in this Agreement.

2.2. Card Transactions

2.2.1. Supported transactions

You can use your Card for the following types of Card Transactions, subject to any limits or restrictions applicable to the Card and/or the relevant type of Card Transaction:
a) Point of Sale (POS) and Online Payments: making payments for goods and services, both in-store and online, at merchants within Card’s payment network;
b) Cash withdrawals at ATMs that accept the Card’s payment network (only available with Physical Cards);
c) Digital Wallet Payments: adding your Card to supported mobile payment platforms (e.g., Apple Pay, Google Pay) to make contactless payments in-store, or to pay within apps and websites, subject to the terms and conditions of such supported mobile payment platforms.

We may make additional Card-related functionalities available from time to time, such as cash deposit services, if and when supported by Satispay and/or its partners and subject to the applicable eligibility criteria, limits, restrictions, channels, third-party arrangements and instructions provided in the App and/or on our Website.

2.2.2. Card Transaction authorisation

A Card Transaction is considered authorised when you perform one of the following actions:
a) for in-store transactions: tapping the Card or Device on a contactless reader, inserting the Card and entering your PIN, or signing a receipt. Small-value transactions may, in certain circumstances, be completed without entry of a PIN;
b) for online transactions: providing your Card details (number, expiry date, CVV) and completing any required Strong Customer Authentication (SCA) steps, such as those under the 3D Secure protocol;
c) for ATM transactions (including cash withdrawal and deposits): inserting your physical Card and entering your PIN.

Once authorised, you cannot stop or revoke a Card Transaction. This does not affect your rights to dispute a Transaction or claim a refund for an unauthorised Transaction, as described in clause 8 below.

2.2.3. Funding Card Transactions

For every Card Transaction you authorise, you consent to Satispay using the corresponding amount of funds from your Account. You must ensure you have a sufficient available balance in your Account to cover the full value of your Card Transactions. Where made available by Satispay for the relevant type of Card Transaction, paragraph 1.6 shall apply. Satispay reserves the right to decline Card Transactions where the funds in your Account are insufficient, where the relevant Top-Up cannot be initiated or is not sufficient for the relevant Card Transaction, or where the Card is no longer valid.

2.2.4. Foreign currency Transactions

If you make a Card Transaction in a currency other than Euro, the transaction amount will be converted to Euro. The currency conversion will be performed by the Card’s payment network using its exchange rate applicable on the day they process the transaction.

Satispay does not add its own mark-up to the exchange rate applied by the Card’s payment network. However, Satispay may charge a separate foreign exchange service fee, depending on your Satispay subscription plan and monthly foreign currency card spend. The applicable fee, thresholds and any plan-based conditions are set out in our pricing information and/or in the relevant Help Center page.

Information on the total currency conversion charges, expressed as a percentage mark-up over the latest available Euro foreign exchange reference rates issued by the European Central Bank, will be made available in our Help Center, together with further information on how currency conversion works.

Exchange rates fluctuate and the rate applied to your Card Transaction may differ from the rate available at the time you make the Card Transaction. The final Euro amount charged to your Account may therefore differ from any estimate shown before or at the time of the Card Transaction.

3. Limits

We may impose limits on the amounts and volumes of Transactions that you are permitted to make using the Services. These limits are set in accordance with regulatory requirements and our internal risk policies. You can view all applicable limits at any time within the App.

4. Fees

Holding the Account and using the Payment Service and the P2P Service are free of charge. Other services may be subject to fees. These include, but are not limited to, using the Third-Party Service, certain Related Services (including the instant top-up), certain Top-Up functionalities and certain uses of the Card (such as foreign currency transactions or cash withdrawals at ATMs). Any fees or charges applicable to you for using the Third-Party Service and/or the Related Services will be shown to you on the App and/or through the Third Parties’ platform at the time of each relevant payment, before your approval of the Payment. The specific amounts and details of all applicable fees are outlined here.

5. Security obligations

You are responsible for keeping your mobile Device, your Account, and all your security details safe. You must take all reasonable steps to avoid the loss, theft, or misuse of your mobile Device, Account, Card and related security details. Do not disclose your security details to anyone or allow anyone else to use your Account, except where you are required to enter them in the App or in another secure authentication flow provided by Satispay. For further information on how to maintain the security of your Account, you may refer to the dedicated section of our Help Center.

In order to access the App, you are required to create security details such as a PIN code. You must not disclose this PIN code to anyone. Satispay will never ask you to disclose your App PIN and/or your Card PIN to anyone, including anyone claiming to act on behalf of Satispay, whether by phone, email, message or through any other channel. You are responsible for ensuring that no one else can access the App without your authorisation. You are responsible for keeping your physical Cards, as well as the security details of all your Cards (such as your PIN, card number, expiry date, and CVV), safe at all times. You must take all reasonable steps to prevent unauthorised use, including by using the security features made available in the App to manage how your Card can be used, such as enabling or disabling certain types of Card Transactions.

If you suspect that your Account, Card, or security details have been compromised, lost, stolen or used without your authorisation, you must notify us promptly by contacting us at the addresses and channels set out in clause 6.1 below, or using any dedicated emergency channel made available by Satispay for this purpose.

If your Card is affected, you must also take all reasonable steps available to you to prevent unauthorised use, including, where possible, freezing your Card from the Card Details section in the App. Freezing your Card is a temporary measure designed to prevent the Card from being used for Card Transactions until it is unfrozen. If you cannot access the App, you may use the dedicated card emergency channels made available by Satispay, including the 24/7 phone line indicated on the Card and/or on our website, to freeze or block the Card or request a re-issue.

Failure to notify us promptly and to take reasonable steps to prevent unauthorised use may be treated as gross negligence and affect your ability to claim any losses for unauthorised Transactions.

6. Communication

6.1. How you may contact us

Please

  • Use the "Contact Us" function in the App;
  • Send us an email at support@satispay.com or a letter via post at Satispay Customer Services, 53, Boulevard Royal, L-2449 Luxembourg.

For urgent Card-related matters, including loss, theft or suspected unauthorised use, you should use the App or the dedicated emergency channels indicated on our App, Help Center and/or on our website. To freeze or block your Card by phone, you can call the dedicated 24/7 emergency line. For assistance in Italian, call +39 800 826 533. For assistance in English, call +352 27 647 687.

6.2. How we may contact you

We may contact you using the App. However, if necessary, we may contact you by email, via push notifications, social media or by phone call, using the details you provided in the App.

If those details change, you must inform us as soon as possible.

6.3. Language

This Agreement is written in English. Any communications related to this Agreement will be in English and any translation into other languages is considered a mere courtesy translation.

Where this Agreement, other terms and conditions or any notice or other document relating to this Agreement is provided in a language other than the English language, then the English language shall prevail if there is a conflict, provided that the language at the place of the User’s residence or domicile may also be applied if mandatory applicable User-related provisions are concerned.

6.4. Copy of Agreement

You can contact us to request a copy of this Agreement, which will be sent to you by email free of charge.

7. Suspension, blocking and restrictions

We may suspend, block or restrict your use of the Services, your Account, your Card and/or specific payment or transaction functionalities where we have objectively justified reasons to do so. Depending on the circumstances, the measure may apply to all or only part of the Services, for example by restricting certain Transactions, suspending access to the Account, blocking or suspending use of the Card, or requiring replacement of the Card.

We may take these measures where this is necessary or appropriate for one or more of the following reasons:
a) to protect the security of your Account, your Card, your security details, the Services, or other Satispay users;
b) where we suspect unauthorised, fraudulent, unlawful or abusive use of the Services, your Account, your Card or any Transaction, including where your Account, Card or Transactions appear to be involved in fraud, scams or other unauthorised or unlawful activity, whether initiated by you or by a third party;
c) where this is required for us to comply with applicable legal or regulatory obligations, including AML/CTF, sanctions, restrictive measures, court orders or instructions from competent authorities;
d) where there is a confirmed or potential match with sanctions, restrictive measures or other financial crime screening lists, pending verification;
e) where you do not provide, within the requested timeframe, information or documents that we reasonably need to comply with our legal or regulatory obligations, verify your identity, check your eligibility to use the Services, or assess your risk profile;
f) pending completion of checks, enhanced due diligence or other controls following a change in your information, risk profile or transaction activity;
g) where your transaction activity or patterns indicate a risk of unauthorised, fraudulent, unlawful, abusive or non-compliant use of the Services, or trigger checks required under applicable legal or regulatory obligations;
h) where you no longer meet, or we have reasonable doubts that you continue to meet, the eligibility requirements to use the Services;
i) where you materially breach your obligations under this Agreement; or
j) where you use the Services in an abusive, threatening, offensive or unlawful way, including towards other users, Satispay, other companies of the Satispay Group, or our employees, agents or representatives.

We will inform you of the decision to suspend, block or restrict your use of the Services, along with the reasons for it, where we are permitted to do so. Where possible, we will notify you before applying the measure and, in any event, immediately afterwards, unless doing so would compromise reasonable security measures, breach applicable law or regulation, or affect the performance of financial crime, sanctions, fraud prevention or other compliance controls.

Where we cannot provide specific reasons, we will still provide you, where permitted, with information on the type of restriction applied, the Services or Transactions affected, the expected timing for review or resolution, and any action you may take to help us complete our checks or remove the restriction.

We will lift the suspension, block or restriction of one or more Services, unblock the Card or issue a replacement Card and, where appropriate, issue new security details free of charge as soon as the reasons for blocking and/or suspension cease to exist.

8. Disputed Transactions, Liability and Refunds

8.1. Reporting unauthorised or incorrectly executed Transactions

We assume that all Transactions are authorised by you unless you notify us otherwise.

If you believe you did not authorise a particular Transaction or that a Transaction was incorrectly executed (for example, because the paid amount is incorrect), you must contact us without undue delay and in any event within 13 months from the date of the Transaction. This 13-month period does not extend any shorter deadlines that may apply to chargeback requests for Card Transactions under the rules of the Card’s payment network.

8.2. Liability

If you notify us of an unauthorised Transaction, we will refund the full amount to you without undue delay, and, in any event, within the timeframe required by applicable law, unless we have reasonable grounds to suspect fraudulent conduct by you and notify the competent authority where required. Your liability for losses resulting from an unauthorised Transaction that takes place before you notify us is limited to a maximum of €50. You will not be liable for this amount if:

  • You were not able to detect the loss, theft, or misappropriation of your Account, Card or related security details before the Transaction was made;
  • You acted with reasonable care in safeguarding your Account, Card, payment instrument and security details and notified us promptly after becoming aware of the issue; or
  • The loss was caused by the actions or lack of action of Satispay, our employees or representatives; or
  • The law otherwise provides that you are not liable.

You are liable for all losses resulting from an unauthorised Transaction if you:
* have acted fraudulently; or * have, intentionally or with gross negligence, failed to: (i) comply with your security obligations as set out in clause 5; or (ii) notify us in accordance with clause 8.1.

Except where you have acted fraudulently, you are not liable for any losses incurred in respect of an unauthorised Transaction that takes place after you have notified us.

8.3. Disputes with merchants, Refunds and Chargebacks

Satispay is not a party to any purchase you make from a Merchant or, for Card Transactions, from a merchant accepting the Card’s payment network. We are not responsible for the safety, legality, quality or any other aspect of the goods and services purchased using the Services. Any complaints or disputes should first be raised directly with the seller or service provider.

If the relevant Merchant agrees to provide you with a refund for any reason (e.g., if you return faulty goods), the Merchant is responsible for initiating that refund. We will credit the funds to your Account only after we have received them.

Chargebacks (for Card Transactions only): In addition to the above, if you are unable to resolve a dispute with a merchant regarding a Card Transaction, you may ask us to assess whether a chargeback request may be available and, where eligible, to submit or support it under the rules of the Card’s payment network. To initiate this process, you must contact us as soon as possible and provide all relevant information and evidence. Satispay will act as your intermediary with the Card’s payment network, but the final decision on any chargeback rests solely with the Card’s payment network under its applicable rules.

8.4. Investigation

We will acknowledge receipt of your report without undue delay and proceed with the investigation in accordance with applicable law. We will let you know the outcome of our investigation as soon as possible. If, after refunding you, we determine that the Transaction was authorised by you or that you acted fraudulently or with gross negligence, we may reverse the refund and you may be liable for the losses we suffer in connection with the Transaction. For Card Transaction disputes, where your claim is not upheld, this may include any fees charged to Satispay by the Card’s payment network in relation to the dispute. We will give you reasonable notice before reversing any refund, unless we are prevented from doing so by applicable law or security reasons.

9. Refusal and Decline

In certain circumstances, we may refuse to execute a Payment or decline a Card Transaction that you have authorised. These circumstances include:

  • if we have reasonable concerns about the security of your Account or Card, or we suspect the Services are being used in a fraudulent, unlawful, abusive or unauthorised manner;
  • if there are insufficient funds in your Account to cover the Transaction and any associated fees, unless an instant Top-Up is available for the relevant Transaction and can be successfully initiated by Satispay;
  • if we have reasonable grounds to believe you are acting in breach of the Agreement; or
  • if we are required to do so by law, court order, instruction from a competent authority, or applicable Card payment network rules.


Unless it would be unlawful for us to do so, where we refuse to execute a Payment or decline a Card Transaction, we will notify you as soon as reasonably practicable that it has been refused and the reasons for the refusal, together, where relevant, with the procedure for correcting any factual errors that led to the refusal or decline.

10. Cooling off

You have a period of 14 days to exercise your statutory right of withdrawal from this Agreement without penalty and without giving any reason. This period begins from the acceptance of this Agreement and after you have received the terms of the Agreement via email. It is understood that any Transaction carried out during the 14-day period is not affected by that withdrawal.

11. Termination

11.1. How you may terminate the Agreement

You may terminate the Agreement at any time by contacting us. You can do this through the App, by email at support@satispay.com, or via post at Satispay Customer Services, 53, Boulevard Royal, L-2449 Luxembourg.

11.2. Why we may terminate the Agreement

We may terminate this Agreement with immediate effect if:

  • you do not provide us with all of the information we need to open or operate your Account or use the Services; or
  • you were not entitled to open the Account or use the Services; or
  • you breach an important part of the Agreement, or repeatedly breach the Agreement and fail to resolve the matter within 10 days; or
  • you use the Services or the services provided by another company of the Satispay Group in a manner that we believe is fraudulent or unlawful; or
  • you perform any fraudulent or unlawful Transaction; or
  • you fail to resolve any Negative Availability related to your Account; or
  • continuing to provide the Service to you may expose Satispay or other companies of the Satispay Group to regulatory, financial or legal risk, including where this results from suspected unauthorised, fraudulent, unlawful, abusive or non-compliant use of the Services; or
  • we receive notice of your death, in which case we may close or restrict access to the Account and process any remaining E-money in accordance with applicable succession procedures and legal requirements; or
  • we need to do so to comply with the law or court order.


We may terminate the Agreement without any reason by giving you a 60-day notice.

We will not always provide specific details regarding any termination in order to protect our internal processes and, more generally, the Services.

If the Agreement terminates, we will disable your access to the Services, and we will deactivate your Card. Any unused amount in the Account will be automatically redeemed in accordance with clause 13, unless we are not permitted to do so to comply with the law.

12. Duration

This Agreement is a framework contract of indefinite duration for the purposes of the Luxembourg law of 10 November 2009 on payment services, as amended.

13. Redemption and expiry

You may redeem all or part of the E-money held in the Account at any time by following the instructions made available to you in the App. We will redeem your funds to your bank account. It is not possible to redeem your funds to a bank account that is not under your name.

14. Amendments to the Agreement

If we need to make any amendments to this Agreement, we will notify the amendments 60 days prior to their effectiveness, except where the amendments are required under the law or they do not cause prejudice to your rights and obligations, in which case they will be immediately effective. This allows you to consider the amendments which require prior notice; in case you disagree with any of the amendments, you will have the right to terminate the Agreement as per clause 11 - Termination.

Copies of the most up-to-date version of the Agreement are made available in the App and on our website at all times.

15. Data Protection

Satispay is a data controller of your personal data and manages and protects your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”) and any other applicable data protection laws (jointly, the “Applicable Data Protection Laws”).

It is the sole responsibility of Merchants to ensure any personal data shared with them at the time of making a Payment is managed and protected in accordance with the Applicable Data Protection Laws. Satispay will collect and process personal data relating to you in compliance with our Privacy Policy.

Satispay is subject to secrecy obligations. Satispay will therefore not disclose any personal data collected except if authorised or required by law (or court order) or explicitly authorised by this section and/or provided for by our Privacy Policy.

When entering into a business relationship with Satispay, you authorise and instruct Satispay to disclose and transfer any data relating to you or your business relationship with us (including but not limited to first name, surname, address, date and place of birth, nationality, contact details, financial situation, any Transactions made), to its outsourcing service providers located in Germany, Luxembourg, Italy, Ireland, the United Kingdom and the United States of America as well as to third parties whose involvement is necessary or useful for Satispay to provide our Services (e.g. the Card’s payment network and our designated card issuer processor) located inside and outside of the European Union or for you to benefit from services provided by third parties, including other companies of the Satispay Group, when you agreed to the relevant terms. These transfers of data will be done in accordance with data processing agreements executed by Satispay and such outsourcing service providers or third parties and in accordance with our Privacy Policy. Satispay will ensure that such outsourcing service providers and third parties are subject to secrecy obligations or contractual confidentiality duties. The services that are outsourced by Satispay, mainly to other companies of the Satispay Group, include platform hosting, IT operations and security, data storage, internal audit operations, AML/KYC screening, accounting and controlling, customer care tasks, payroll and HR as well as certain legal and marketing activities. You agree with such outsourcing by accepting the Agreement.

You agree to inform Satispay as soon as possible of any change in personal data collected and to supply Satispay upon request with any additional information it deems useful to the maintenance of a business relationship and/or that is required by applicable laws or regulations.

16. Complaints

If you are not satisfied with the Services, tell us first by contacting us (see contact details in clause 6.1) so we can try to resolve your issues. We will promptly send you a complaint acknowledgement and a copy of our complaints procedure.

A copy of our complaints procedure can be requested at any time and can also be found here. You agree to cooperate with us and provide the necessary information to enable us to investigate and resolve the complaint as quickly as possible.

If, after following the procedure and steps set out in this clause 16, you are not fully satisfied with how we have handled your complaint, you may contact the competent supervisory authority as detailed below.

You can contact the CSSF by filling in the online complaint form where all relevant documents can be attached or by sending the completed complaint form (PDF):

  • either by mail (simple mailing, no registered letter required) to the following address: Commission de Surveillance du Secteur Financier, Département Juridique CC 283, route d’Arlon, L-2991 Luxembourg.
  • or by email to the following address: reclamation@cssf.lu.

17. Intellectual Property Rights

All content included in our App (including all user-facing material, and all underlying material such as code, software and databases) and the copyright and other intellectual property rights in that content, unless specifically labeled otherwise, belong to or have been licensed by us. All content is protected by applicable intellectual property laws and treaties.

By Intellectual Property Rights we mean all vested, contingent and future intellectual property rights including but not limited to copyright, trademarks, service marks, design rights (whether registered or unregistered), patents, know-how, trade secrets, inventions, set-up, database rights and any applications for the protection or registration of these rights and all renewals and extensions thereof existing in any part of the world whether now known or in the future created which Satispay or other Satispay Group companies may be entitled to.

18. Third parties' content

We may provide links to other content such as websites, web apps and downloadable apps. Unless expressly stated, this content is not under our control. We neither assume or accept responsibility or liability for such third-party content. The provision of a link by us is for reference only and does not imply any endorsement of the linked content or of those in control of it.

19. Force Majeure

We are not liable for any breach of the Agreement where the breach is due to abnormal and unforeseeable circumstances beyond our control, the consequences of which would have been unavoidable despite all efforts to the contrary.

We cannot be held liable where the breach is due to our legal obligations.

20. Severance

If any term or provision in the Agreement shall be held to be illegal or unenforceable, in whole or in part, under any enactment or rule of law, such term or provision or part shall to that extent be deemed not to form part of the Agreement, but the validity and enforceability of the remainder of the Agreement shall not be affected.

21. Assignment

We may assign the receivables as well as the rights and/or obligations arising out of this Agreement to another company at any time by giving you prompt notice of this. If we do this, your rights will not be affected.

22. Governing law and jurisdiction

This Agreement and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation are governed by and construed in accordance with the laws of the Grand Duchy of Luxembourg, provided that the law at the place of the User’s residence or domicile may also be applied if mandatory applicable or more consumer-protective provisions are concerned.

Each party irrevocably agrees that the courts of the User’s residence or domicile shall have jurisdiction over any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with this Agreement or its subject matter or formation.

We are at your disposal for any additional information. Contact us.

Should you have any questions regarding our service for accepting payments please email us at business@satispay.com

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Payment services are provided by Satispay Europe S.A., registered under no. W00000010 in the Register of Electronic Money Institutions at the Commission de Surveillance du Secteur Financier and under no. B229149 in the Luxembourg Business Register. Registered office: 53, Boulevard Royal, L-2449 Luxembourg.
Corporate welfare services are provided by SatisWelfare S.p.A., tax code and registration number in the Milan Business Register no. 12408640964. Registered office: Piazza Fidia 1, 20159 Milan.
Investment services are provided by Satispay Invest S.A. registered under No. P00000555 in the Register of Investment Firms at the Commission de Surveillance du Secteur Financier and under no. B285448 in the Luxembourg Business Register. Registered office: 53, Boulevard Royal, L-2449 Luxembourg.