National Exchange Company Terms & Conditions

1. WHY THIS INFORMATION IS IMPORTANT

This is the Terms and Conditions, also known as User Agreement for NEX Pay mobile application (the “App”) and our services. It also sets out other important points that you need to know.

This User Agreement, along with the Privacy Policy, eCommunications Policy, and any other terms and conditions that apply to our services, form a legal agreement (the “Agreement”) between:

You, the user, and
us, NEXPAY

By signing up for the services and using the App, you are accepting and agreeing to be bound by the Agreement. Thus, when you are completing sign up you must click on the agree button in-order accept the terms and conditions and the privacy policy. If you do not agree to these documents then you will not be allowed to complete sign up, therefore we request you to read the documents carefully before accepting it. We provide our services to you through the App. We may provide information and/or our services in other ways too, like through web pages. Our Agreement applies whenever and however you access our services or other information. You can at any time, at no cost, stop using the App by deleting it or ending the Agreement (see Section 10).

2. ABOUT US

National Exchange Company commenced business in the year 2003 with the Ufficio Italiano dei Cambi license number 35830 (UIC = Department under Bank of Italy)

Ufficio Itliano dei cambi acted as the regulatory authority and was made a department of the Bank of Italy in 2008. Their previous web address was www.uic.it still, the web address will automatically direct you to the correct page under the Bank of Italy’s website www.bancaditalia.it. In 2011, the Banca D’Italia changed the legislation for Money Transfer Companies. Therefore, the category was changed from ‘Money Transfer Company’ to ‘Paying Institution’. Our subscription number as a paying Institution is 328302. Money Transfer Companies that couldn’t obtain the subscription as a paying institution are not allowed to provide and Money Transfer services legally since 2011.

Law Related: Iscritta nell’Albo degli Istituti di Pagamento di cui al DECRETO LEGISLATIVO 27 gennaio2010,

subscripton : n’. 11 con il numero 32830 Link : https://infostat.bancaditalia.it/giava-inquiry-public/flex/Giava/GIAVAFEInquiry.html Albo degli Istituti di pagamento pdf 76 kB

The best way to contact us is by phone, email (info@nationalexchange.it), or WhatsApp. Please see the “Support” section of the App or the “Contact Us” section of our website for more details.

3. DEFINITIONS

In this Agreement, we will refer to NEX PAY as “we” or “us” and we will refer to you, the user of the App and Services, as “you”.

“App ” means the NEX PAY mobile application through which money transfer services are provided.
“Remitter” means the individual or entity who transfers money through our app.
“Recipients” means the individual or entity who receives the money sent by the Remitter.
“Identity documents” means Official documents that verify a person’s identity, such as a passport, driver’s license, or national identity card.
“Password” means a confidential string of characters used to authenticate and grant access to your NEX PAY account..
“Activation code” means a unique set of characters (letters or numbers) used to activate or verify a user profile.
“Country List” means the country in which the Remitter can send money and the Recipient receives money.
“Bank List” means the list of supported banks that can receive funds through NEX PAY transfers.
“Payment Method” means the method used to transfer funds from the Remitter’s account to the Recipient’s account (e.g., bank transfer, mobile wallet, cash pickup).
“Today’s rate” means the current exchange rate applied to currency conversions for transfers made through the App.
“Payment Gateway ” means a secure technology platform that processes financial transactions, including payments made by credit cards, debit cards, or digital wallets.
“Transfer Instruction” refers to the set of details provided by the sender to initiate and complete a money transfer. This includes the recipient’s information, the amount to be transferred, and any specific instructions for the transaction.
“Track Transaction” is a feature that allows users to monitor the real-time status and progress of their transactions.
“Security Details” means the authentication credentials linked to your account, including passwords, biometric data, and other login information accepted by NEXPAY.
“Services” means the money transfer services through our app.
“Service Fee” means the fee charged for using NEXPAY services. Fees may vary based on factors such as the amount transferred and the destination country. The applicable fee will be displayed before confirming the transaction.
“Service Provider” means a third party, such as a local bank, mobile network operator, or financial institution in the destination country, that facilitates the delivery of funds to the Recipient (e.g., through cash pickup, mobile wallet, or direct deposit).
“Transfer” A transaction in which funds are moved from the Remitter’s account to the Recipient’s account through NEXPAY.
“Transfer History” means a record of the user’s past transactions available within the App.
“Transaction receipt” means a document issued as proof of a financial transaction, confirming that the transaction request has been received.

‍“Customer support” means the assistance provided by NEXPAY to help users resolve issues related to the App or its services.

4. USING THE SERVICES

4.1. NEX PAY provides money transfer services from Italy to worldwide.

4.2. To use NEX PAY money transfer services:

4.2.1. First, you must download the “NEX PAY” App from the Apple App Store or Google Play Store and install it on your mobile device.
4.2.2. Upon installation, you are required to complete the registration process by following the instructions provided within the App.

4.3. Profile creation

4.3.1. To use our Services, you must create a “NEX PAY” profile (your “Profile”). Your Profile allows us to record certain information about you.

4.3.2. Provide us complete, accurate, and truthful information as requested by us from time to time (including information about you and any information or documents we may reasonably require). The information you provide will be used by us to determine your eligibility to use our services.

4.3.3. You must not create a Profile or make a Transaction for someone else or using another person’s identity. If you impersonate someone else and try to use another person’s account to send money you may be legally charged, thus legal action may be taken against you.

4.3.4. It is very important that the information you provide us is accurate, and in particular, is updated when there is a change in legal documentation or address.

4.3.5. If any of your information (such as your mailing or email address) changes, you must update your Profile and inform us right away. You are responsible for making sure all the information you provide is always accurate, complete, and up to date when using our Services.

4.3.6. You must make every effort to keep your security details safe and prevent unauthorized access to the services by changing your password regularly and ensuring that it is not reused for other online services. We will not be liable if someone signs in with your username and password without your permission, unless we can see that there is clear signs of hacking.

4.3.7. Do not share your security details with anyone, including us, and let us know immediately if anyone asks you for your Security Details. We will also send you security alerts via email if we see that your profile is being used for the first time in a new device other than your regular device. It is your responsibility to check such security alerts and report to us immediately if you see something suspicious.

4.4. Eligibility to use our services

4.4.1. You must be at least eighteen (18) years old to access or use our services as a Sender, aka Remitter.

4.4.2. As a Remitter, you must be based and resident in Italy to use the services provided by us under the terms of this Agreement.

4.4.3. If you are a resident of another country but work in Italy, you are also eligible to use our services.

4.4.4. You may not use our services if you are resident or work outside of Italy.

4.4.5. You may only register and open 1 (one) Profile, and we may place limits on the number of email addresses and payment instruments that can be associated with your Profile.

4.4.6. Individuals who are subject to legal restrictions or prohibitions under Italian law are not permitted to use our services.

4.5. Once your registration is completed, you will be able to send international money transfers from Italy to Recipients in eligible destination countries.

4.6. We may release updates to the NEX PAY App from time to time via the Apple App Store or Google Play. Depending on the nature of the update, you may be required to install the latest version to continue using our services. We will also send you in app notifications to inform you regarding the updates.

4.7. All data collected is clearly mentioned in our privacy policy which you will find inside the app, in the website and when you are completing sign up. The major data we collect are personal information of the remitter such as name, surname, date of birth, phone number, valid document (such as carta di identita, patente, permesso soggiorno, passaporto).

4.8. All data collected is processed through our various systems in order to check if the individual is a PEP or has any legal convictions against him. We also collect the data in order to determine if you are eligible to send remittance as a resident or non-resident. The collected data is archived and stored in our main database due to legal and compliance regulations.

5. SENDING MONEY

5.1. To send money via our Services, you must use a permitted funding instrument. Card Funded Payments: Debit or credit card. We accept only debit and credit cards from Mastercard and VISA at the moment

5.2. The card must be valid, unexpired, and registered in your name.

5.3. Cards must be in good standing and legally owned by you.

5.4. Debit or Credit cards must be issued by an Italian banking authority. Therefore, cards issued by any other banking authority outside of Italy will not be accepted.

5.5. To make a payment with a card, you must provide information about your Transfer, including the full name and address of the recipient, the recipient’s account details, and the amount to be transferred. Correctly provide the unique identifier for the recipient’s account (e.g., the account number, mobile number). All of these details must be filled up when creating a recipient, aka beneficiary. Depending on what payment delivery method you choose, the information required for the recipient will change.

5.6. Select your Payment Method, which at this moment is only debit or credit card issued by Visa or Mastercard.

5.7. When you click “Send” on the confirmation page, you authorize us to debit your card and initiate the Transfer. We will receive your Payment Instruction and will start to execute the transfer immediately. You will not be able to cancel or change it once payment has been confirmed and transactions has been issued. In some cases, if payment is not completed properly and the payment fails due to incorrect card information, insufficient funds, non-Italian card etc. then you will see a transaction with an incomplete status in your transfer history. This transaction can no longer be edited or cancelled therefore you can click on the retry option which you will see inside that transaction. This will then redirect you to a new transaction with the same recipient details but rates may change according of there is a change in FX rates.

5.8. You must make sure all the details of your recipient are accurate before submission. If you enter the wrong details, you will send the transfer to the wrong account and lose your money, we may not be able to get it back.

5.9. We reserve the right to reject any transaction request further information from you if we detect suspicious, unauthorized, or incomplete information.

5.10. Each money transfer you initiate constitutes a separate agreement under these Terms and Conditions.

5.11. We will provide you with a pdf receipt via the app and email, once your payment has gone through successfully enabling you to identify the Transfer, along with details of the amount of the Transfer in the currency used in the Transfer, any Service Fees we may charge, amount the Recipient will receive, and the date on which the transfer Instruction was received.

5.12. You may track the progress of your transaction at any time using the “Track Transaction” feature available in the App.

5.13. If you have made a transfer for cash pick-up and the cash is not picked up by the Recipient within 30 days of when it was first made available, we may keep the amount frozen for a further 6 months. If neither the remitter or beneficiary makes a claim for the amount then the amount will be donated to charity.

6. OUR RIGHT TO REFUSE, DELAY, OR SUSPEND A PAYMENT INSTRUCTION OR THE SERVICES

Limits

6.1. We may apply limits to the amount you can send to Recipients.

6.2. We may apply limits to your Transfers either on a per-Transfer basis or on an aggregate basis, and either in respect of one set of registration details or one Payment Method or on related sets of registration details or Payment Methods. We might also limit the value of currency exchange you can carry out at any one time or over some time.

6.3. TRANSFER LIMIT THRESHOLD TABLE

LIMIT APPLICABLE TO NON-RESIDENT SENDER
SENDER’S NATIONALITY	PERIOD	AMOUNT	DOCUMENT
ALL	30 DAYS	999 €	DLGS N. 231/07
ALL	365 DAYS	3,000 €	POLICY AML

LIMIT APPLICABLE TO RESIDENT SENDER
SENDER’S NATIONALITY	PERIOD	AMOUNT	DOCUMENT
ALL	1 DAY	999 €	DLGS N. 231/07
ALL	7 DAY	999 €	DLGS N. 231/07
ALL	30 DAY	5,000 €	POLICY AML
ALL	90 DAY	5,000 €	POLICY AML
ALL	365 DAY	16,000 €	POLICY AML

LIMIT REGARDING THE BENEFICIARY
BENEFICIARY NATIONALITY	PERIOD	AMOUNT	DOCUMENT
NO BLACK LIST	1 DAY	999€	DLGS N. 231/07
NO BLACK LIST	7 DAY	999€	DLGS N. 231/07
NO BLACK LIST	30 DAY	4,000€	POLICY AML
NO BLACK LIST	365 DAY	16,000€	POLICY AML

LIMIT CONCERNING THE BENEFICIARY
BENEFICIARY NATIONALITY	PERIOD	AMOUNT	DOCUMENT
BLACK LIST	1 DAY	999 €	DLGS N. 231/07
BLACK LIST	7 DAY	999 €	DLGS N. 231/07
BLACK LIST	30 DAY	2,500 €	POLICY AML
BLACK LIST	365 DAY	9,000 €	POLICY AML

Blacklisted Countries According to NEX PAY:

The countries mentioned below are black listed by our compliance team due to various AML regulations. Therefore, if you wish to send money to the countries mentioned below, you must go to an agent and sign an AVR form. You will not be allowed to send money to the countries listed below via the app NEX PAY.

-Algeria

-Angola

-Bulgaria

-Burkina Faso

-Camerun

-Corea del Nord

-Costa d’Avorio

-Croazia

-Fiji

-Guam

-Isole Cayman

-Repubblica Democratica del Congo

-Haiti

-Isole Vergini

-Iran

-Laos

-Libano

-Kenia

-Mali

-Monaco

-Mozambico

-Namibia

-Nepal

-Nigeria

-Myanmar

-Palau

-Panama

-Russia

-Samoa

-Siria

-Sud Sudan

-Sudafrica

-Tanzania

-Trinidad e Tobago

-Yemen

-Vanuatu

-Venezuela

-Vietnam

Delays

6.4. We may delay or suspend a service, including (but not limited to):

To verify your identity.
To respond to any security alerts that we receive concerning your use of the services.
Due to system outages or technical difficulties of banks and other corresponding companies we work with.
Otherwise, to comply with applicable law.

6.5. We will attempt to maintain up-to-date information regarding the availability of service providers by means of information on our website or our App.

Refusing a transfer instruction or suspending the Services

6.6. We may refuse or suspend your money transfer request if we believe that:

It would put you over any applicable limits.
It would break this Agreement.
It is unauthorized (e.g., someone else is trying to use the Services without your permission).
It is fraudulent (including where we suspect that you may be a victim of a scam).
You may be acting illegally.
We are required to do so by law.

6.7. We will generally inform you before or immediately after refusing a Payment Instruction or suspending your use of the Services, and provide our reasons for doing so. However, we will not provide reasons or any information if doing so is against the law or compromises our security measures. Our customer service team is active 24/7 enabling you to contact us regarding any issue or clarification needed.

7. REFUNDS

7.1. You can request a refund for a transfer within three (3) months of when it was made if:

A transfer instruction was made without your permission.
If we didn’t send the transfer on time, to the correct Recipient, or for the correct amount, as shown in your confirmed transfer instruction.

7.2. We may refuse your refund request if we find that:

7.2.1. You acted fraudulently.
7.2.2. You didn’t take reasonable care to protect your security details, either intentionally or through gross negligence.
7.2.3. The transfer happened before you told us someone else was using your login details.
7.2.4. The recipient has already received the money in their account.
7.2.5. The transfer instruction you gave us included incorrect information, such as the wrong account details.

7.3. If you want to request a refund, please do so as soon as possible—no later than three (3) months after the Transfer date. Send your request by email using the contact details in the support section. Include:

Your ID number, full name, address, and phone number
The transfer number
The amount sent
The reason for your refund request is with proper evidence.

7.4. If the transfer was sent based on the details you provided, and those details were wrong, we are not responsible for the error. We’ll try to recover the funds, but we may charge a reasonable fee for doing so.

7.5. If your refund is approved, we’ll return the money to the most recent Payment Method you used, in the same currency as the original Transfer, within 15 days. We may ask for more details to complete the refund.

8. YOUR RESPONSIBILITY

8.1. This section explains when you may need to pay NEXPAY or its partners for any losses they experience because of your actions.

8.2. When You Are Responsible:

8.2.1. Your use of the Services (whether correct or not)
8.2.2. You breaking this Agreement or any company policies
8.2.3. Disputes or legal actions caused by something you did or failed to do
8.2.4. Your carelessness or your violation (or possible violation) of any laws or regulations.

8.3. You must cover all related costs, even if the problem was accidental or unintentional.

9. OUR RESPONSIBILITY

9.1. We will provide our services with reasonable care and skill. However, you acknowledge that our services may not be fully available in some regions, countries, or jurisdictions.

9.2. Where we have materially breached this Agreement, causing a loss to you, we will refund you the Transfer and any Service Fee charged. Any claim for compensation made by you must be supported by any relevant documentation.

9.3. We are not responsible for any damage or loss because of any failure to perform the Services due to abnormal and unforeseen circumstances outside our reasonable control, which may, for example include delays or failures caused by problems with another system or network (including those of our Service Providers), mechanical breakdown or data-processing failures. Natural disasters or unpredictable situations such as pandemics, wars, political situations may cause disturbances in our service, therefore we ask that you be patient in these situations however we will not be responsible for not delivering our service properly in such situations.

9.4. Once money is made available to the recipient (either in their account or for pickup), we are no longer responsible for it.

9.5. You will be responsible in the case of cyber-attacks or hacking on your phone. Therefore, we will not be responsible for any incidents that may occur in NEX PAY, if your phone is hacked or suffers from a cyber attack

10. CHANGES TO THE AGREEMENT

10.1. We may update this Agreement for any of the following reasons:

10.1.1. To comply with changes in laws or regulations.
10.1.2. To improve the Agreement or make it easier to understand.
10.1.3. To reflect changes in the costs of providing our services.
10.1.4. To adjust how we operate our business, especially if industry changes affect how we deliver services.
10.1.5. To address potential security risks.
10.1.6. Because we are adding or changing services.
10.1.7. To respond to other changes that affect us, where it is fair to pass those changes on to you.

10.2. We can’t anticipate everything that might happen while you are registered for our Services. This means we may also need to make other changes. If we do, when we tell you about the change, we’ll explain how it will affect you.

10.3. Some changes may be necessary due to unforeseen events. If this happens, we will explain the change and how it affects you when we notify you at least two (2) months before the change takes effect.

10.4. If you do not agree with a change, you may reject it and end the Agreement. If you do not object, we will assume you accept the change.

10.5. We will inform you of any upcoming changes by sending an email to the address you provided.

11. ENDING THE AGREEMENT

11.1. This Agreement will remain effective until either you or we choose to terminate it.

11.2. You may terminate this agreement at any time, free of charge, by contacting us in writing via email or the Contact Us section.

11.3. We may terminate this agreement and your access to the Services at any time by providing two (2) months’ prior notice.

11.4. We may also terminate this agreement and your access to the services immediately, without prior notice, if:

11.4.1. We reasonably believe the Services are being used fraudulently or illegally;
11.4.2. We are required to do so by law, regulation, court order, or instruction from an ombudsman.
11.4.3. You fail to provide required information, or we reasonably believe the information you have provided is false or misleading;
11.4.4. You have seriously or repeatedly breached this agreement and have not resolved the issue within a reasonable time after we have asked you to do so.
11.5. If we terminate the agreement immediately, we will inform you as soon as possible through your contacts (email or phone number), provided we are legally allowed to do so.

11.6. Upon termination of this Agreement:

11.6.1. We will stop processing any new transaction instructions.
11.6.2. Any transaction already submitted and still pending will continue to be processed;
11.6.3. Your obligation to pay any outstanding amounts to us will continue after the Agreement ends.
11.7. If we are unable to refund a transaction and you do not provide alternative instructions within one (1) year of termination, you will forfeit your right to a refund.

11.8. You will lose access to your remitter profile and the profile and its data will become inactive. We will keep your profile and its data for 10 years maximum and then delete it if you profile is still inactive. Before deleting your inactive profile, we will send you a notification via email in order to inform you about your account termination.

12. HOW YOUR MONEY IS PROTECTED

12.1. In the event of our insolvency, you will be prioritized over other creditors and will be paid from the proceeds of the funds in these dedicated client money accounts, according to applicable law. Therefore, your money is protected at all times and we are responsible for paying out the money in the unforeseen circumstance of insolvency.

13. COMPLAINTS

13.1. If you have a complaint about your use of the Services, please reach out to our Customer Service Team. We will promptly acknowledge your complaint. Our customer service team operates 24/7 therefore we believe we can resolve your complaint or issue almost immediately.

13.2. We will do our best to resolve your complaint as quickly as possible and will send you a response via email within a maximum of 15 days of receiving your complaint. If, due to exceptional circumstances beyond our control, we require additional time to respond, we will send you a holding reply within 15 days to inform you when you can expect our final response.

13.3. Except for complaints about Digital Content Services, if you do not receive our final response on time, or you are unhappy with our final response, you may 1.1. may, free of charge, refer your complaint to National Exchange Company SRL, located in Via Ferruccio 30, 00185, Roma, Italy. ‍

13.4. If there are any disputes or problems with the service provided by NEX PAY we request you to contact customer service immediately and we will try to solve your issue almost instantly. If we are unable to provide a solution immediately then we will definitely come to a solution or conclusion with in a maximum of 10 days.

14. FEES AND EXCHANGE RATES

14.1. You are required to pay any applicable Service Fees. Information about our Service Fees and live exchange rates can be found in the App. We provide transparent fees and exchange rates which can be viewed real time in the app. This will also be viewable right before you confirm your payment with your card details. Service Fees are due when you submit your Transfer instructions and are non-refundable. Before you confirm your Transfer Instruction, we will inform you of the exact amount you need to pay in the App.

14.2. Our exchange rate is determined by us for each relevant currency pair and service, and it typically changes 2-3 times daily. Rates are due to change at any time due to the various fluctuations in the FX market.

14.3. When you make transfers in a currency different from that of your payment method (for example, if you pay in euros to receive an equivalent amount in another currency), we will apply our standard exchange rate. This rate may change at any time and will be displayed in the app at the time of conversion.

14.4. Others might impose taxes, fees, or charges on you, e.g. for use of a particular Payment Method to fund a Transfer. However, we do have these extra costs such as hidden charges in order to benefit the client as much as possible.

14.5. Your Payment Method may give you chargeback rights. You agree that you will not request a chargeback for reasons for which we are not responsible, such as a dispute with your Recipient. We may charge you for our costs associated with your chargebacks.

15. INTELLECTUAL PROPERTY

15.1. The App, its Services, and all related content—including copyrights, patents, database rights, trademarks, and service marks—are owned by us, our affiliates, or third parties. All rights, titles, and interests in the National Exchange Company website and the Services remain our property or the property of other third parties.

15.2. The App and its Services may only be used for the purposes allowed by this Agreement or as described on our website. You are authorized only to view and retain copies of the pages from the App for your 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 National Exchange Company website, the NEXPAY App, Services, or any part of them for public or commercial purposes without our express written permission.

15.3. You may not: (i) use any robot, spider, scraper, or other automated device to access the App or the Services; or (ii) remove or alter any copyright, trademark, or other proprietary notice displayed on the National Exchange Company website or printed pages from the site. The names “National Exchange Company S.R.L.” and “NEXPAY,” along with other names and trademarks associated with National Exchange Company’s products or services mentioned on the National Exchange Company website, are our exclusive marks or the exclusive marks of other third parties. Other products, services, and company names appearing on the website may be trademarks of their respective owners, and you should not use, copy, or reproduce them in any manner.

16. ELECTRONIC COMMUNICATIONS

16.1. You agree that this Agreement is entered into electronically, and that the following types of information (“Communications”) may be provided by electronic means:

16.1.1. This Agreement, along with any amendments, modifications, or supplements made to it, shall be included.
16.1.2. You can view your transfer history through our services
16.1.3. Any initial, periodic, or other disclosures or notices provided concerning the Services, including, without limitation, those required by law.
16.1.4. Any customer service communications, including communications to claims of error or unauthorized use of the Services; and
16.1.5. All other communications related to the Services or us.

16.2. The Services do not permit Communications to be delivered in paper format or through non-electronic means. If you choose to withdraw your consent to receive Communications electronically, your use of the Services will be terminated. To withdraw your consent, please contact us via email.

16.3. Agreement Copy: You can review this Agreement at any time through the App or on our website. We will send you a copy of these terms via email when you first register for the Services. Additionally, you can request a copy of these terms (including any modifications) to be emailed to you at any time.

16.4. Transfer History: You can also download the Transfer History from the App for your records at any time. All pdf receipts for each transfer will be available in the app at all times. If you need all transfer history records for a particular period of time then you can contact us through customer support and we will send it to you via email.

16.5. Security: If we need to contact you regarding suspected fraud or security threats, we will reach out by calling or texting your mobile number.

16.6. App: In case of a conflict between information on the App and our website, please prioritize the information on the App.

17. GENERAL

17.1. Governing Law: This Agreement is governed by Italian law.

17.3. No Rights for Third Parties: Only you and we possess rights under this Agreement.

17.4. Language: We will typically communicate with you in the language used in your contract with us. However, you are welcome to reach out to us in any of the following languages: English, Italian, Bengali, or Sinhala. We may update you on this from time to time, using the contact details provided above (see the About Us section). In case of discrepancies between translated versions and the original English version of these Terms, the English version shall prevail.

17.5. Waiver: If you breach the Agreement and we choose not to enforce our rights, or if we delay in doing so, it does not prevent us from enforcing those or any other rights in the future.

17.6. Transfer of rights: You cannot transfer any rights or obligations under this agreement. We can transfer or assign this Agreement and our rights under it at any time without your consent.

17.7. Entire Agreement: This Agreement constitutes the complete understanding between you and us, superseding any prior agreements, discussions, or understandings regarding the subject matter of this Agreement, the use of the App, and/or our Services.

17.8. The user has the right to edit their personal data once submitted when creating their profile. Due to compliance and legal security we do not allow customers to edit their existing personal data directly from the app, once the profile has been checked and approved. However, there is an option in the app which allows users to ask for an update to their personal details. If this option is selected by the user then the user will be redirected to a customer service operator who will ask for proof for any changes to the user’s personal data. If the user can provide valid proof then we will approve the changes.

17.9. Our Data protection officer, Mr. Alessio Proetti is in charge of conserving all client’s data and handling data according to current GDPR rules and regulations. All data is stored securely in our main data base which is located in Milan. All data stored is available for life time, however any data related to inactive users is kept for a maximum of 10 years.