14.

Electronic Instructions and Your Responsibilities

14.1

Security code

a)

Access to and use of password protected and/or secure areas or features of the services are restricted to authorised users only. You may not obtain or attempt to obtain unauthorised access to such parts of the services, or to any other protected information, through any means not

intentionally made available by us for your specific use.

b)

You will be required to select or designate a password, personal or logon identification number and other code and/or adopt certain access or security procedures (such items to be referred to as “security code”) for use in connection with access to the services or use of the facilities provided

through the services. You hereby agree to keep the security code confidential. You are to notify us immediately if you have knowledge that or have reason for suspecting that the confidentiality of the security code has been compromised or if there has been any unauthorised use of the security code.

c)

You agree to be bound by any access or use of the services (whether such access or use is authorised by you or not) which are referable to your security code. You agree and acknowledge that any use of or access to the services referable to your security code and any electronic instructions

shall be deemed to be, as the case may be:

(i)

use of or access to the services by you; or

(ii)

electronic instructions transmitted or validly issued by you. You therefore agree and acknowledge that any use of or access to the services and any information or data referable to your security code shall be deemed to be (a) use or access of the services by you; or (b) information or data

transmitted or validly issued by you and you agree to be bound by any access or use (whether such access or use are authorised by you or not) referable to your security code, and you agree that we shall be entitled (but not obliged) to act upon, rely on or hold you solely responsible and liable in

respect thereof as if the same were carried out or transmitted by you.

14.2

We are under no obligation to investigate the authenticity or authority of persons effecting the electronic instructions or to verify the accuracy and completeness of the electronic instructions. Accordingly, we may treat the electronic instructions as your authentic and duly authorised

instructions which are valid and binding on you notwithstanding any error, fraud, forgery, lack of clarity or misunderstanding in the terms of the electronic instructions.

14.3

Any risk of misunderstanding, error, loss, damage or expense resulting from the use of the services are entirely at your own risk and we shall not be liable therefor.

14.4

All electronic instructions will be deemed to be irrevocable and unconditional upon transmission through the services and we shall be entitled (but not obliged) to effect, perform or process such electronic instruction(s) without your further consent and without any further reference or notice to

you. Nevertheless, in certain circumstances you may request you to cancel or amend the electronic instructions which we shall endeavour to give effect to on a commercially reasonable effort basis. However, notwithstanding the foregoing, we are not obliged to give effect to any request to cancel or

amend any electronic instruction.

14.5

You acknowledge and agree that:

We may at any time at our sole discretion and without stating reasons, require that you identify yourself by alternative means; require any electronic instructions to be confirmed through alternative means (in writing given in person at a branch, etc.);

We may at any time decline to act on the electronic instructions at any time without prior notice or giving any reason, including to: (without incurring any responsibility for loss, liability or expense arising out of so declining to act refrain from acting promptly upon any electronic instructions)

(a)

verify the authenticity thereof

(b)

decline to act on the electronic instructions where they are ambiguous, incomplete or inconsistent with your other electronic instructions or instructions, information and/or data

(c)

decline to act where any electronic instructions would cause you to exceed your applicable transaction limits; or

(d)

decline to act on the electronic instructions where we did not receive authorisations from other banks or financial institutions in the form required by use; and

Electronic instructions may not be processed immediately, around the clock or in a timely manner and we shall not be liable for any loss, damage or expense arising from any delay in processing or executing any electronic instructions.

14.6

Notwithstanding any provision to the contrary in these terms and conditions, you acknowledge and agree that in the event that we discover or have been notified by the service providers that the funds to be or which have been sent under the services are to be or have been debited from any

other internet banking account or card account you may have other than your internet banking account and/or your card account maintained with us, we may at any time, at our sole discretion and without stating reasons or notice, reverse any or all electronic instructions which you have

transmitted or issued to, and which have been received by, us and/or impose an administration processing fee for such reversal and/or terminate these terms and conditions and your right to use the services.

14.7

You hereby agree to indemnify and render us, our directors, officers, employees, agents and assign free and harmless from and against any claim, cause of action, suit, liability, and loss or damage of whatever nature that may arise as a result of or in connection with the use of your account

and the transactions made with it in the following instances:

(a)

disruption, failure, or delay relating to or in connection with the use of your account due to circumstances beyond our control; fortuitous events such as, but not limited to, prolonged power outages, breakdown in computers and communication facilities, computer related errors, system errors,

system enhancements, system migration and integration, typhoons, floods, public disturbances and calamities, any action taken by a Government or public authority including imposing embargo, export or trade restriction or other restriction or prohibition caused by a “Epidemic” or “Pandemic”

outbreak, riots, strikes and work stoppages, delays by third-party vendors, any acts of Gods and unforeseen circumstances and other similar or related cases;

(b)

fraudulent or unauthorized utilization of your account due to unauthorized disclosure, or breach of its security or confidentiality with or without your participation; or

(c)

inaccurate, incomplete, or delayed information received by us due to disruption or failure of any communication facilities or electronic device used for your account.

15.

Suspension, cancellation, termination, nonrenewal.

Your account and/or the Wallet, Services or any part thereof may be cancelled by us at any time without prior notice to you. After cancellation, account and/or the Wallet, Services or any part thereof may be reinstated in such manner and on these terms and conditions as we may at our absolute

discretion determine.

15.1

Discretion: Without giving any reason or prior notice and without prejudice to the other provisions in these terms and conditions, we have absolute discretion to:

(a)

refuse approval of any proposed transaction even if the BBG wallet linked to the Wallet has sufficient balance;

(b)

terminate or cancel your right to use your account, Wallet and Services; (c) increase or decrease the transaction limit; (d) refuse reissuance, renewal, or replacement of Wallet; or

(e) introduce, amend, vary, restrict, terminate, or suspend the benefits, related services, facilities, and privileges in respect of or in connection with your account, Wallet.

15.2

Termination by us notwithstanding anything, we may close and revoke any one or all your account, Wallet and Services, with or without notice to you, if:

a)

You do not follow our instructions in connection with your Wallet account or Services or you do not comply with any applicable law;

b)

We believe you have (i) offered, promised or given any bribe; or (ii) agreed to receive or accepted any bribe;

c)

In our opinion, any Wallet account is not operated in a proper or regular manner;

d)

In our opinion, a business relationship with you is no longer appropriate;

e)

You have breached, any term in these terms and conditions, or any other agreement whether relating to the borrowing of funds or the granting of advances or credit or otherwise;

f)

You have given us untrue, inaccurate, incomplete or misleading information;

g)

You do not pay on time any amount due tous;

h)

You pass away or become incapacitated;

i)

You become insolvent or bankrupt or subject to judicial proceedings;

j)

Your assets are in jeopardy or subject to enforcement of a judgment by any party;

k)

Any legal proceeding (civil or legal) or action (including garnishee order, writ of seizure and sale, injunction) is commenced or levied against you, or you have been convicted of a crime, or you or any security provider has acted inappropriately;

l)

Anything happens which, in our opinion, may have a material or adverse effect on your financial condition, assets or compliance with the terms of these terms and conditions;

m)

Any other event of default occurs under any other agreements or arrangements between us;

n)

Any of the events or proceedings under this clause occurs in relation to any third party who has agreed to provide or is providing security;

o)

It would constitute a breach of our agreement with any other party;

p)

It is necessary for us to do so in order for us to meet any obligation, either in Singapore or elsewhere in the world, in connection with the prevention of fraud, money laundering, terrorist activity, bribery, corruption or tax evasion, or the enforcement of economic or trade sanctions; or

q)

It is unlawful for us to continue to provide wallet account or any service or allow the use of the card.

15.3

You may, at any time, suspend, cancel, terminate or reactivate Wallet in accordance with these terms and conditions by following the required steps specified at http://www.website.com.sg/. You acknowledge that such actions may be charged a fixed amount for such changes.

15.4

Upon cancellation or termination of your account, Wallet or any part thereof:

a)

All rights and benefits granted to you shall immediately be terminated and shall revert to us;

b)

You cannot and must not use your wallet;

c)

We may at our absolute discretion, decide not to act on any confirmation or request received by you after the effective date of termination;

d)

We may at our absolute discretion, decide not to act on any confirmation or request received by us between the date of notice given to you and the effective date of termination (if there is a lapse of time between the two dates).

16.

Intellectual Property Rights

16.1

The BBG services and all intellectual property relating to them and contained in them (including but not limited to copyrights, patents, database rights, trademarks and service marks) are owned by BBG Global Pte. Ltd..

16.2

The BBG services may be used only for the purposes permitted by these terms and conditions or described on this website. You are authorized solely to view and to retain a copy of the pages of the BBG website for your own personal use. You may not duplicate, publish, modify, create

derivative works from, participate in the transfer or sale of, post on the internet, or in any way distribute or exploit the BBG website, the BBG services or any portion thereof for any public or commercial use without our express written permission. You may not:

(a)

use any robot, spider, scraper or other automated device to access the BBG website or the BBG services; and/or

(b)

remove or alter any copyright, trademark or other proprietary notice or legend displayed on the BBG website (or printed pages of the website). The name BBG and other names and indicia of ownership of our products and/or services referred to on the BBG website are our exclusive marks or

the exclusive marks of other third parties. Other product, service and company names appearing on the website may be trademarks of their respective owners.

16.3

Wallet and related Services, including services and products are our sole properties and/or its licensors and are subject to our existing policies, rules, and regulations. Wallet and related

Services are protected by copyright, trade secret and other intellectual property laws. We and/or our licensors own the title, copyright and other worldwide intellectual property rights in all services relating to Wallet and related Services. Using the wallet and related Services do not grant you any

rights to our trademarks or service marks.

16.4

For the purpose of these terms and conditions, intellectual property rights shall mean all patent rights, copyright rights, moral rights, rights of publicity, trademark, trade dress and service mark rights, goodwill, trade secret rights and other intellectual property rights as may now exist or

hereafter come into existence, and all applications and registrations, renewals and extensions thereof, under the laws of Singapore and any country, territory or other jurisdiction.

16.5

You may choose to, or we may invite you to submit comments or ideas about Wallet and related Services, including but without limitation about how to improve any service or product. By submitting any idea, you agree that your disclosure is gratuitous, unsolicited and without restriction and

shall not place us under any fiduciary or other obligations, and that we shall be free to use the idea without any additional compensation to you, and/or to disclose the idea on a nonconfidential basis or otherwise to anyone.

17.

Notices.

17.1

All notices and documents required to be given by us to you shall be sent by any one of following methods:

a)

Ordinary or registered post to your last known address according to our record;

b)

Electronic mail to your last known electronic mail address according to our record;

c)

Posting notice or communication on the wallet website;

d)

Notices placed with or in any of the wallet written communications to you;

e)

Phone call to your last known phone number according to our records;

f)

Notices placed through any media; or

g)

Any manner of notification as we may at our absolute discretion determine.

17.2

Unless otherwise expressly provided in writing, our notices and communications to you are effective:

a)

If sent by post to an address within your country, the following business day after posting;

b)

If sent by post to an address outside of your country, 5 business days after posting;

c)

If sent by fax, electronic mail or SMS, at the time of transmission;

d)

If sent by hand, at the time of delivery or when left at the address;

e)

If posted on our website, on the date of display or posting;

f)

If advertised in the newspaper, on the date of advertisement; and

g)

If broadcast via radio or television, on the date of broadcast.

18.

Promotional ofers, advertisements, and surveys.

You hereby consent that your Personal data will be collected, used and disclosed by us in accordance with the Personal Data Protection Act 2012, for the provision of all services. We may also send you marketing mailers by post or email or via SMS text, telephone or fax. You hereby consent that we

may disclose your Personal data to our business partners and third- party service providers for these purposes. Where there are joint account holders, you confirm that they have consented to our collection, use and disclosure of their Personal data. In this context, you agree that:

18.1

We may inform you about promotional offers through mail, email, fax, SMS, telephone, or any other means of communication. You agree that we and our affiliates, and third parties selected by any of them can offer specially selected products and services to you through any means of

communication provided above. For this purpose, you agree that we may transfer and disclose customer information to our affiliates and third parties selected by any of them.

18.2

Third parties’ services and links to other websites. You may be offered services, products and promotions provided by third parties and not by us. If you decide to use these services, you shall be responsible for reviewing and understanding the terms and conditions associated with these

services. You agree that we are not responsible for the performance of these services.

18.3

Our website may contain links to third parties’ websites as a convenience to you. The inclusion of any website link does not imply an approval, endorsement, or recommendation by us. You agree that you access any such website at your own risk, and that the site is not governed by the terms

and conditions contained in these terms and conditions. We expressly disclaim any liability for these websites.

18.4

If you wish to be excluded from the recipient lists for our promotional

offers, advertisements or surveys, or find any incorrect entry in the information held by us or in the information provided by us to third service providers, you have to immediately notify us by calling our customer service by dialling +65 8034 0928.

19.

Consent to broadcast and sending of push messages.

You agree and consent to the sending by us and our affiliates of broadcast and push messages as well as notices and announcements to you via SMS/email blast. However, should you opt not to receive these messages, you may make a request to that effect by following the optout instructions

regularly sent by us to you.

20.

Compliance

20.1

You shall comply with all laws and regulations related to the use of stored value facilities and the current anti-money laundering/counterterrorism financing legislation of your residence country or otherwise in the country or territory in which you are present while using the Wallet or Services.

20.2

You shall comply with all laws and regulations related to the use of services and the current anti-money laundering/ counterterrorism financing legislation required. For further information on anti-money laundering/counter terrorism financing

legislation: https://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial- sanctions

21.

Limitation of liability.

a)

The Services are provided on an “as is” and “as available” basis. We do not warrant

(i)

the accuracy, adequacy or completeness of the services, and expressly disclaim any liability for errors, delays or omissions in the Website, or for any action taken in reliance on the Website;

(ii)

that the services will be provided uninterrupted or free from errors, or that any identified defect will be corrected, nor that the services and the Website are free from any computer virus or other malicious, destructive or corrupting code, agent, program or macros. No warranty of any kind,

implied, express or statutory, including but not limited to the warranties of noninfringement of third party rights, title, merchantability, satisfactory quality or fitness for a particular purpose, is given in conjunction with the services. In particular, you should be aware that where services are initiated or

accessed via SMS, your mobile network operator’s confirmation that any SMS you sent has been sent to us or our service provider does not guarantee that we have executed, or even received, the electronic instructions contained within such SMS.

b)

We may, from time to time and without giving any reason or prior notice, upgrade, modify, suspend or discontinue the provision of or remove, whether in whole or in part, the services or any information, functionalities, services or products provided therein, and shall not be liable if any such

upgrade, modification, suspension or removal prevents you from accessing the services or associated information, functionalities, services or products.

c)

Risks and expenses relating to the use of the internet and other telecommunication systems: we do not warrant the security of any information transmitted by you or to you through the services and you accept the risk that any information transmitted or received through the services may be

accessed by unauthorised third parties. Transactions over the internet as well as messages sent via SMS may be subject to interruption, transmission blackout, delayed transmission due to internet traffic or incorrect data transmission due to the public nature of the internet and the SMS system. You

shall be responsible for obtaining and using the necessary services, software and/or device, hardware and/or equipment necessary to obtain access to the services at your own risk and expense (including all costs levied by your mobile network operator).

d)

Exclusion of liability: we shall in no event be liable to you or any other person for any loss, damages or expenses whatsoever or howsoever caused and regardless of the form of action (including tort or strict liability) arising directly or indirectly in connection with any access, use or inability to

use the services, or reliance on any materials, even if we or our agents or employees may have been advised of, or otherwise might have anticipated, the possibility of the same. We shall not at any time be liable for indirect or consequential losses, damages or expenses, even if foreseeable, within

our contemplation or if we may have been advised of, or otherwise might have anticipated, the possibility of the same.

e)

Information available through the services: information displayed at the services or sent to you in connection with the services, may be from a variety of sources. All data and/or information contained in the services or sent to you in connection with the services is provided for informational

purposes only. We make no representations as to the accuracy, timeliness, adequacy or commercial value of all such information and/or data. You should not act on data or information obtained through the services or sent to you in connection with the services, without first independently verifying

its contents.

f)

Refund. We will refund to you any benefit which we receive as a result of any breach of our agreement with you (this means that, for example, where a money transfer has failed, in such circumstances we will refund to you the transaction amount and the service fee). We do not, in any event,

accept responsibility for: (i) any failure to perform your instructions as a result of circumstances which could reasonably be considered to be outside our control; (ii) malfunctions in communications facilities which cannot reasonably be considered to be under our control and that may affect the

accuracy or timeliness of messages you send to us; (iii) any losses or delays in transmission of messages arising out of the use of any internet service provider or caused by any browser or other software which is not under our control; and (iv) errors on the website or with the service caused by

incomplete or incorrect information provided to us by you or a third party.

g)

In no event shall we be liable for damages whether caused by negligence on the part of our employees, suppliers or agents or otherwise, beyond the sum of SGD 500. In no event shall we or our agents be liable for any indirect, special, incidental, consequential, exemplary or punitive damages,

or the like.

21. Non-waiver of rights.

No failure or delay on the part of us in exercising any right or power given here shall operate as a waiver of that right or power, and nor shall any partial or single exercise of any such rights or powers preclude any of the other rights or powers provided here. Moreover, no waiver by us or any of its

rights or powers under this wallet agreement shall be deemed to have been made unless expressed in writing and signed by its duly authorized representative.

23.

Other means of communication.

You undertake to notify us of any additional means of communicating with you aside from those disclosed in your wallet application. Pursuant to such undertaking, you authorize us at its discretion but without any obligation to do so, to secure information from third parties such as but not limited to

utility companies, insurers, and financial intermediaries, and to receive information on how and where you can be contacted.

24.

Assignment of waiver.

You agree that we, without notice to you, may assign, discount, or otherwise transfer part of all of its rights or obligations here or under any wallet transaction. In the event of such assignment, you irrevocably agree not to assert against the assignee setoff rights of any obligation that may be owed

by us to you. You may not assign your rights and obligations under these terms and conditions without our prior consent.

25.

Your complaints.

Any complaint regarding your Wallet and Services or their use, or both, shall be communicated to the wallet hotline or contact us or other means in accordance with these terms and conditions. If we deem necessary, we will conduct an investigation of the complaint for its prompt resolution and

communicate its findings to you. You agree to fully cooperate with any such investigation by providing the necessary or required data, information, and

documents. You must resolve any complaint against any Merchant or other party directly with them. You cannot setoff against us any claim you have against them. If there is a dispute with any Merchant in respect of a payment, a refund for the transaction will be made to you only after the

Merchant has refunded the payment to us.

26.

No deposit insurance coverage.

Funds stored on the BBG Mobile Wallet and stored value Card provided in conjunction with the Mobile Wallet are not insured deposits under the Deposit Insurance and Policy Owners’ Protection Schemes Act (Chapter 77B of the Singapore Statutes) and are ineligible for protection by the Deposit

Insurance Scheme.

27.

Disclosure.

We shall keep all your files and records in strictest confidence in accordance with the provisions of your residence country’s legislation and its privacy policy.

28.

Severability clause.

28.1 If any provision of the terms and conditions is found by an arbitrator or court of competent jurisdiction to be invalid, the parties nevertheless agree that the arbitrator or court should endeavour to give appropriately valid effect to the intention of the terms and conditions as reflected in the

provision, and the other provisions of the terms and conditions shall remain in full force and effect.

29.

Dispute resolution.

29.1

BBG and you shall attempt to resolve any controversy or claim arising out of or relating to the creation, performance, termination and/or breach of these terms and conditions in the first instance through good faith negotiation or mediation between the parties. Any claims or disputes arising

from or related to these terms and conditions shall be resolved through binding arbitration via the Singapore international arbitration center located in Singapore and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. Notwithstanding the

foregoing, and solely with respect to breaches or threatened breaches of these terms and conditions, either party to these terms and conditions may seek a temporary restraining order and injunction to protect its legal rights or interests, without the need to post bond in any court having jurisdiction.

30.

Miscellaneous

30.1

Governing Law. These terms and conditions and any and all amendments thereto shall be governed by and construed in accordance with the substantive laws of Singapore, without reference to its conflicts of law provisions.

30.2

Act in good faith. We may act in any instruction we believe in good faith has been given by you according to the operating mandate.

30.3

Dispute resolution. Any dispute arising from or relating to BBG services shall be resolved by final and binding arbitration. The arbitrator shall also decide what is subject to arbitration. The arbitration will be administered by Singapore International Arbitration Centre under (“SIAC”) in

accordance with the arbitration rules of the SIAC (“SIAC rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause.

30.4

Indemnity. You agree to indemnify us and all our affiliates, subsidiaries, servants, employees, nominees, directors and agents for any loss and embarrassment suffered by us (other than such loss and embarrassment arising from us or our employees’ and agents’ willful misconduct or

negligence) in connection with:

a)

Any wallet account, Services or transaction;

b)

Acting on or carrying out or delaying or refusing to act on any instruction you give us;

c)

and enquiries we make in connection with you, or a security provider;

d)

The provision of any service to you and the performance of our functions;

e)

Any service provided by any third party;

f)

Any default or the preservation or enforcement of our rights under the terms of these terms and conditions or any other applicable terms and conditions in connection with any wallet or related services or as a result of your noncompliance with any of these terms;

g)

Any action by us or any party against you relating to any Wallet, wallet account or Services;

h)

Any involvement by us in any proceeding of whatever nature for the protection of or in connection with the Wallet, wallet account or Services;

i)

Our compliance with any existing or future law or regulation or official directive in respect of any of these terms;

j)

Taxes payable by us in connection with your wallet account; and

k)

Any increased cost in our funding if there is a change in law or circumstances.

30.5

Waiver. Any failure or delay by us in exercising or enforcing any right we have under the terms of these terms and conditions does not operate as a waiver of and does not prejudice or affect our right subsequently to act strictly in accordance with our rights.

30.6

Illegality. We may close and revoke any Wallet, wallet account or Services with or without notice to you if, because of any change to any applicable law, regulation,

regulatory requirement or judicial decision, or in our opinion, maintaining or performing any obligation under the terms in these terms and conditions becomes illegal, or we are otherwise prohibited from doing so. If this happens, you must pay us all liabilities on demand.

30.7

General construction and interpretation. In our opinion: when we determine a matter in our opinion, the determination is made at our absolute discretion. When we act or refuse

to act: on any matter including any instruction or transaction, we do not need to provide any reason for our act or refusal unless required by the law. Timing: if we receive any instruction on a non business day or after the specified clearance or cutoff times, we may treat the instruction as received on

the following business day.

30.8

Amendments. We reserve the right to amend these terms and conditions at any time and for whatever reason it may deem proper, and any such amendment shall be binding upon notice to you by publication or other means of communication, electronic or otherwise. This is unless you object

to those amendments by manifesting the intention to terminate your membership in writing within five (5) days from notice of the amendment. Your failure to notify us about this intention to terminate your membership as provided, and your continued use of your Wallet and Services, or both, shall

be taken as your conclusive acceptance of the amendments.

30.9

Any external links to third-party websites on the website are provided as a convenience to you. These sites are not controlled by us in any way and we are not responsible for the accuracy, completeness, legality or any other aspect of these other sites including any content provided on them.

You access such websites at your own risk.

30.10

Subcontracting and delegation: we reserve the right to use any service providers, subcontractors and/or agents on such terms as we think appropriate.

30.11

Force majeure: we shall not be liable for any non performance, error, interruption or delay in the performance of its obligations or in the services’ operation, or for any inaccuracy, unreliability or unsuitability of the materials or any of the services’ contents if this is due, in whole or in part, directly

or indirectly to an event or failure which is beyond its reasonable control (which includes without limitation acts of god, natural disasters, acts of any government or authority, power failures, and the acts or a party for whom we is not responsible for).

30.12

We take security very seriously at BBG, and we work hard, using state-of-the-art security measures, to make sure that your information remains secure. The BBG service is a safe and convenient way to send money to friends and family and to other people that you trust. However, we do

advise you to consider very carefully before sending money to anyone that you do not know well. In particular, you should be very cautious of deals or offers that seem too good to be true they may be scams. If you are aware of anyone or any entity that is using the service inappropriately, please

email us cs@bbggames.com. Similarly, if you receive any emails, purporting to be from us, which you suspect may be “phishing” (fake) emails, please forward them to us by send an email to cs@bbggames.com.

30.13

Contact information

Any questions, notices, and requests for refunds or further information should be directed to us by contacting our customer service at +65 8034 0928 OR WRITE TO:

BBG Global Pte. Ltd.,

68 Circular Road, #02-01, Singapore 049422

or call the Customer Service by dialling +65 8034 0928 or by send an email to cs@bbggames.com

ADDITIONAL TERMS FOR USER PROTECTION PURSUANT TO EPAYMENTS USER PROTECTION GUIDELINES ISSUED BY MONETARY AUTHORITY OF SINGAPORE

31.

Account Holder to provide contact information and monitor notifications

31.1

The Account Holder of a Protected Account shall be required to provide us with contact details as required by us in order to send the Account Holder transaction notifications. Where the Protected Account is a joint account, the Account Holders should jointly give instructions to us on whether

we should send transaction notifications to any or all the Account Holders. The duties of the Account Holders in this Section will apply to all the Account Holders that the Regulated Entity has been instructed to send transaction notifications to.

31.2

The Account Holder shall be required at a minimum to provide the following contact information which must be complete and accurate, to us:

(a)

where the Account Holder has opted to receive transaction notifications by SMS, his Singapore mobile phone number; or

(b)

where the Account Holder has opted to receive notification by email, his email address.

31.3

It is the Account Holder’s responsibility to enable transaction notification alerts on any device used to receive transaction notifications from us and to monitor the transaction

notifications sent to the contact address. We may assume that the Account Holder will monitor such transaction notifications without further reminders or repeat notifications.

32.

Transaction Notifications

32.1

We will provide Transaction Notifications that fulfil the following criteria to you that we have been instructed to send, in respect of all transactions (of any amount) made to or from your account (“Notifiable Transaction”).

(a)

the Transaction Notification will be sent to your contact address. If you have provided more than one contact address to us, the Transaction Notification will be sent to every contact address selected by you to receive such notifications.

(b)

the Transaction Notification will be sent on a real time basis for each transaction or on a batched basis at least once every 24 hours to consolidate every notifiable transaction made in the past 24 hours. We may but are not obligated to send both real time notifications and daily batched

notifications to you.

(c)

the Transaction Notification will be conveyed to the Account Holder by way of SMS or email. An in-app notification will be accompanied by an SMS or email notification that meets the deadline in sub-paragraph (b) above.

(d)

the Transaction Notification will contain the following information, but we may omit any confidential information provided that the information provided to you still allows you to identify the transaction as being an authorized transaction or Unauthorized Transaction:

(i)

information that allows you to identify the Protected Account such as the Protected Account number;

(ii)

information that allows you to identify the Recipient whether by name or by other credentials such as the Recipient’s account number;

(iii)

information that allows us to later identify you, the Protected Account, and the recipient account such as each account number or name;

(iv)

transaction amount;

(v)

transaction time and date;

(vi)

transaction type;

(vii)

if the transaction is for goods and services provided by a business, the trading name of the merchant and where possible, the merchant’s reference number for the transaction.

33.

Account user to protect access codes and access to protected account

33.1

You should not do any of the following:

(a)

voluntarily disclose any Access Code to any third party;

(b)

disclose the Access Code in a recognizable way on any Wallet, Authentication Device, or any container for the Wallet; or

(c)

keep a record of any Access Code in a way that allows any third party to easily misuse the Access Code.

33.2

If you keep a record of any Access Code, you should make reasonable efforts to secure the record, including:

a)

keeping the record in a secure electronic or physical location accessible or known only to the Account User; and

b)

keeping the record in a place where the record is unlikely to be found by a third party.

33.3

You shall at the minimum do the following where a device is used to access the Protected Account:

a)

update the device’s browser to the latest version available;

b)

patch the device’s operating systems with regular security updates provided by the operating system provider;

c)

install and maintain the latest anti-virus software on the device, where applicable; and

d)

use strong passwords, such as a mixture of letters, numbers and symbols.

33.4

You should inform all other Account Users, if any, of the security instructions or advice provided by us. An Account User should follow security instructions or advice provided by us to you.

34.

Report and provide information of Unauthorized Transactions

34.1

You should report any Unauthorized Transactions to us as soon as practicable after receipt of any Transaction Notification alert for any Unauthorized Transaction.

34.2

Where you are not able to report the Unauthorized Transaction to us as soon as you receive any Transaction Notification alert for any Unauthorized Transaction, you should if we so request, provide us with reasons for the delayed report. This includes the time periods or circumstances where

it would not be reasonable to expect us to monitor Transaction Notifications. The report should be made in any of the following ways:

a)

by reporting the Unauthorized Transaction in the communications channel as set out in this agreement; or

b)

by reporting the Unauthorized Transaction to us in any other way and where we acknowledge receipt of such a report.

34.3

You should within a reasonable time provide us with any of the following information as requested by us:

a)

the Protected Account affected;

b)

your identification information;

c)

the type of Authentication Device, Access Code and device used to perform the payment transaction;

d)

the name or identity of any Account User for the account;

e)

whether an account, Authentication Device, or Access Code was lost, stolen or misused and if so:

(i)

the date and time of the loss or misuse,

(ii)

the date and time that the loss or misuse, was reported to us, and

(iii)

the date, time and method that the loss or misuse, was reported to the police;

f)

where any Access Code is applicable to the account,

(i)

how you or any Account User recorded the Access Code, and

(ii)

whether you or any Account User had disclosed the Access Code to anyone; and G any other information about the Unauthorized Transaction that is known to you.

34.4

You should make a police report if we request such a report to be made to facilitate the claims investigation process.

35.

Recipient credential information

35.1

Where transactions are made by way of internet banking, any mobile phone application or device arranged for by us for payment transactions, including a payment kiosk, we will provide an onscreen opportunity for any Account User of a Wallet to confirm the payment transaction and

recipient credentials before we execute any authorised payment transaction. The onscreen opportunity will contain the following information:

(a)

information that allows the Account User to identify the Protected Account to be debited;

(b)

the intended transaction amount;

(c)

credentials of the intended recipient that is sufficient for the Account User to identify the recipient, which at the minimum should be the recipient’s phone number, identification number, account number or name as registered for the purpose of receiving such payments; and

(d)

a warning to ask the Account User to check the information before executing the payment transaction.

36.

Reporting channel

36.1

We will provide Account Holders of Protected Accounts with a reporting channel for the purposes of reporting unauthorised or erroneous transactions.

36.2

The reporting channel should have all the following characteristics.

(a)

The reporting channel may be a manned phone line, phone number to receive text messages, online portal to receive text messages, or a monitored email address.

(b)

Any person who makes a report through the reporting channel will receive a written acknowledgement of his report through SMS or email.

(c)

We will not charge a fee to any person who makes a report through the reporting channel for the report or any service to facilitate the report.

(d)

The reporting channel shall be available at any time every calendar day, unless it is a manned phone line, in which case that reporting channel shall be available during business hours every business day.

37.

Claim Investigation

37.1

We will while acting reasonably at our sole discretion assess any claim made by you in relation to any Unauthorized Transaction (“Relevant Claim”) for the purposes of assessing your liability. Where we have assessed that the relevant claim does not fall within Unauthorized Transaction, we

will resolve such a claim in a fair and reasonable manner. We will communicate the claim resolution process and assessment to you in a timely and transparent manner.

37.2.

We may require that you furnish a police report in respect of Unauthorized Transaction claim, before we begin the claims resolution process. Upon enquiry by you, we will provide you with relevant information that we have of all the Unauthorized Transactions which were initiated or executed

from a Protected Account, including transaction dates, transaction timestamps and parties to the transaction.

37.3.

We will complete an investigation of any relevant claim within twenty-one (21) business days for straightforward cases or forty-five (45) business days for complex cases. Complex cases may include cases where any party to the Unauthorized Transaction is resident overseas or where we

have not received sufficient information from the Account Holder to complete the investigation. We will within these periods give each Account Holder that we have been instructed to send Transaction Notifications to in accordance with manner set out in these terms, a written or oral report of the

investigation outcome and its assessment of your liability. We will seek acknowledgement (which need not be an agreement) from that Account Holder of the investigation report.

37.4.

Where you do not agree with our assessment of liability, or where we have assessed that the claim falls outside of Unauthorized Transaction, the parties may proceed to commence other forms of dispute resolution including mediation such as FIDReC,

37.5.

We will credit your Protected Account with the total loss arising from any Unauthorized Transaction as soon as we have completed our investigation and assessed that you are not liable for any loss arising from the Unauthorized Transaction. We will disclose this arrangement to you at the

time you report the Unauthorized Transaction to us and inform you of the timeline for completing our investigation.

38.

Liability for losses arising from Unauthorized Transactions

38.1

You are fully liable for actual loss arising from an Unauthorized Transaction where any Account User’s recklessness was the primary cause of the loss. Recklessness would include the situation where any Account User deliberately did not comply with requirements under these terms. You are

required to provide us with information we may reasonably require to assist us to determine whether or not any Account User was reckless.

38.2

For the avoidance of doubt, where any Account User knew of and consented to a transaction (“Authorised Transaction”), such a transaction is not an Unauthorised Transaction, notwithstanding that the Account Holder may not have consented to the transaction. This would also include the

situation where any Account User acts fraudulently to defraud any Account Holder or us. In such a case, the Account Holder shall be solely liable for entire loss.

38.3.

You are not liable for any loss arising from an Unauthorized Transaction if the loss arises from, solely on account of, any action or omission by us and does not arise from any failure by any Account User to comply with any duty in this agreement.

38.4.

Any action or omission by us includes the following:

(a)

fraud or negligence by us, our employee, our agent or any outsourcing service provider contracted by us to provide our services through the Protected Account;

(b)

non-compliance by us or our employee with any requirement imposed by a regulatory authority on us in respect of our provision of any financial service;

(c)

non-compliance by us with any duty set out in this agreement.

38.5.

You are not liable for any loss arising from an Unauthorized Transaction that does not exceed $1,000, if the loss arises from any action or omission by any third party not referred to in paragraph 37.4 above and does not arise from any failure by any Account User to comply with any duty

under this agreement.

38.6 Where the Protected Account is a joint account, the liability for losses set out in this section applies jointly to each Account Holder in a joint account.

39.

Specific duties in relation to Erroneous Transactions

39.1

Where you inform us in accordance with this section that you or an Account User has initiated a payment transaction from a Protected Account such that money has been placed with or transferred to the wrong recipient (“Erroneous Transaction”), we will inform the wrongful recipient’s FI of

the Erroneous Transaction promptly as much as practicable, to the FI of the wrong recipient and shall make reasonable efforts to recover the sum sent in error.

39.2

For the purposes of paragraph above, reasonable efforts mean the following:

(a)

where we are the FI of Account Holder:

(i)

within two business days of receiving the necessary information from you under this section, we shall inform the recipient FI of the erroneous transaction;

(ii)

within seven business days of informing the recipient FI, we shall ask the recipient FI for the recipient’s response and provide you with any new relevant information to allow you to assess if you should make a police report about the erroneous transaction.

(b)

where we are the FI of the wrong recipient:

(i)

within two business days of receiving the necessary information about any Erroneous Transaction, we will:

I.

Inform the recipient of the erroneous transaction and all necessary information that would allow the recipient to determine if the transaction was indeed erroneous;

II.

Ask the recipient for instructions on whether to send the sum sent in error back to you; and

III.

Inform the recipient that his retention or use of sums transferred to him erroneously where he has had notice of the erroneous transaction is an offence under the penal code.

(ii)

within five business days of receiving the necessary information about any erroneous transaction, we will:

I.

Ask the recipient for instructions whether to send the sum sent in error back to the Account Holder; and

II.

Inform the other FI about the recipient’s response, including nil responses.

39.3

For the purposes of assisting the FIs to recover sums sent in error, you should provide us with any of the following information as requested by us:

(a)

all such information that we may request as set out in section 33.3);

(b)

the recipient’s unique identifier, including account number, identification number, name or other credentials entered by the Account User; and

(c)

the date, time, amount, and purpose of the erroneous transaction insofar as such information is known to you.