MilleWallet – Terms of Service

Last updated:  November 2025
Contact email: contact@millewallet.com

These Terms of Service (the “Terms”) govern your access to and use of the MilleWallet website, applications and related services (collectively, the “Service” or “MilleWallet”). By creating an account, accessing or using MilleWallet, you agree to be bound by these Terms.

⚠ Legal Disclaimer: This document is a general template and may not cover all legal requirements in your country. It must be reviewed and adapted by a qualified lawyer licensed in the relevant jurisdiction(s) before production use.

1. Scope of the Service

MilleWallet provides a digital wallet interface and tools to:

• Store and view a virtual balance associated with your user account.
• Initiate or request deposits and withdrawals via supported payment methods (for example, SEPA transfers, card payments or other PSP integrations, where available).
• Manage internal transfers and payments within the MilleWallet ecosystem, where enabled.
• Track transactions, fees and account activity.

MilleWallet does not:

• Provide bank accounts, credit lines, loans or overdrafts.
• Issue payment cards or IBANs in its own name.
• Provide investment, tax, legal or financial advice.

2. Eligibility and Registration

You may use MilleWallet only if:

• You are at least the legal age of majority in your country or region (typically 18+).
• You have full legal capacity to enter into a binding contract.
• You are not located in, or a resident or citizen of, any country subject to comprehensive sanctions or where the Service is prohibited by law.
• You are not on any sanctions, terrorism or watch list maintained by applicable authorities.

You agree to provide accurate, complete and up-to-date information during registration and to update such information as necessary. We may require additional identity verification (KYC) or documentation before enabling specific features, limits or withdrawals.

3. User Accounts & Security

You are responsible for maintaining the confidentiality of your login credentials and for all activities performed under your account. You agree to:

• Use strong, unique passwords and keep them secure.
• Enable multi-factor authentication (MFA) if available.
• Notify us immediately at contact@millewallet.com of any suspected unauthorized access or security incident.

We may require you to change your password, re-verify your identity, or temporarily restrict access to protect you, MilleWallet or third parties.

4. Deposits, Withdrawals & Manual Top-Ups

4.1 Deposits

You may add funds (“Deposits”) to your MilleWallet account using supported payment methods and/or manual bank transfers, where available. Deposits may be processed by third-party payment service providers (“PSPs”).

Deposits are credited to your MilleWallet balance once confirmed by the PSP or our banking partners. Processing times, cut-off times and fees may vary.

4.2 Manual bank transfers

When using manual SEPA or other bank transfers:

• You must use the exact reference and details provided by MilleWallet.
• Transfers must originate from a bank account held in your own name, unless explicitly authorized by us.
• Mismatched names, wrong references, or transfers from third-party accounts may result in delays, rejection, return of funds (minus fees) or additional compliance checks.

4.3 Withdrawals

You may request withdrawals of available funds to supported payout methods (e.g., SEPA transfer to a bank account in your name), subject to:

• Completion of required KYC/AML checks.
• Compliance with applicable sanctions, fraud and risk controls.
• Payment of any applicable fees.
• Internal and PSP risk scoring or manual review.

Withdrawals to bank accounts in the name of a third party (other than you) may be rejected or require additional documentation and are generally discouraged.

4.4 Irreversible payments

Once a payment or transfer has been executed correctly according to the details you provided, it may not be possible to reverse it. You are solely responsible for verifying all payment details before confirming a transaction.

5. Fees, Pricing & Currency

MilleWallet may charge fees for:

• Deposits and withdrawals (including SEPA or manual transfers).
• Currency exchange, where applicable.
• Internal transfers, premium features or additional services.

Fees will be clearly communicated in the app or on our website and may be updated from time to time. By using the Service after such updates, you accept the revised fees.

Fees and charges may be deducted directly from your MilleWallet balance or from received amounts.

6. Fraud, Abuse, Chargebacks & Prohibited Use

6.1 Zero-tolerance policy for fraud

MilleWallet applies a strict zero-tolerance policy towards fraud, abuse and illegal activity. Any suspected or confirmed fraudulent behavior may result in:

• Immediate suspension or closure of your account.
• Immediate freezing or retention of balances and incoming funds.
• Reporting to PSPs, banks and competent authorities.
• Legal action to recover losses, fees, penalties and damages.

6.2 Examples of prohibited and fraudulent behavior

The following activities are strictly prohibited (non-exhaustive list):

• Using stolen, cloned or unauthorized payment instruments (cards, bank accounts, wallets, etc.).
• Attempting or performing unauthorized withdrawals or transfers from accounts that are not yours.
• Money laundering, financing of terrorism or handling proceeds of crime.
• Fake identity, forged documents, or using another person’s identity without authorization.
• Chargeback abuse (for example: depositing, spending or withdrawing funds, then initiating unjustified chargebacks or disputes with your bank or card issuer).
• Account farming, multiple accounts to bypass limits, bans or risk controls.
• Phishing, social engineering, or attempting to access other users’ accounts.
• Any attempt to bypass or manipulate our security, risk or compliance systems.
• Using MilleWallet in relation to scams, pyramid schemes, Ponzi schemes or illegal gambling.
• Using MilleWallet to receive or distribute funds on behalf of third parties without clear legal and economic justification (“money mule” activity).

6.3 Chargebacks and disputes

If you initiate a chargeback or payment dispute for a transaction that was properly authorized and executed:

• We may immediately freeze your account and associated balances.
• We may share relevant information and documentation with the PSP, bank or card network to contest the chargeback.
• We may charge you administrative fees and pass on any chargeback fees or penalties imposed by PSPs.
• We may permanently ban your account and refuse future registration.

6.4 Fraud flags and risk scoring

MilleWallet uses internal and third-party tools for fraud detection, including risk scoring, velocity checks, device fingerprinting and pattern analysis. You acknowledge and agree that:

• Your transactions may be delayed, reviewed or blocked for risk or compliance reasons.
• We may request additional documents or proofs (e.g., bank statements, invoices, ID, proof of address) before accepting or releasing funds.
• We may, at our discretion, reject transactions or close accounts where fraud risk or non-compliance is suspected.

7. Account Suspension, Blocking & Termination

7.1 Our right to suspend or block your account

We may, at any time and without prior notice, suspend, limit or block your account (including login, deposits, withdrawals and transfers) in whole or in part, if:

• We detect or suspect fraud, abuse, chargeback risk or security incidents.
• We detect or suspect money laundering, terrorist financing, sanctions issues or other illegal activity.
• You fail to provide requested KYC/AML documents or information, or such information appears inaccurate or inconsistent.
• We receive instructions or legal orders from PSPs, banks or competent authorities.
• You breach these Terms, our Privacy Policy, AML policy or applicable law.

7.2 Permanent ban & blacklist

In serious or repeated cases (for example fraud, chargeback abuse, identity theft, or serious AML concerns), we may:

• Permanently terminate your account (“Banned Account”).
• Add your details (such as name, date of birth, email, phone, device identifiers) to an internal blacklist to prevent future registration.
• Share relevant information with PSPs, banks and, where legally permitted, other partners to protect the ecosystem.

If your account is banned, you may lose access to some or all services and features permanently.

7.3 Termination by you

You may request closure of your account at any time by contacting us at contact@millewallet.com. Account closure is subject to:

• Completion of pending transactions and investigations.
• Settlement of any outstanding fees, negative balances or disputes.
• Compliance with record-keeping and legal obligations.

8. Funds Holds, Freezes, Offsetting & Negative Balances

8.1 Funds holds & investigation periods

MilleWallet may temporarily hold or freeze all or part of your balance for risk, fraud or compliance reasons, including but not limited to:

• Chargebacks, disputes or refunds linked to your account.
• Unusual or high-risk transactions (e.g., large manual deposits, cross-border transfers, third-party payments).
• Ongoing AML or fraud investigations by MilleWallet, PSPs, banks or authorities.

Such holds may remain in place for the time reasonably necessary to complete the investigation, obtain information from third parties, or comply with legal obligations. In some cases, this may extend up to several months (for example, up to 180 days or more, where required by PSPs or law).

8.2 Seizure or confiscation of funds in case of fraud

Where there is clear evidence that funds on your account are the proceeds of fraud, crime or violation of these Terms or applicable laws, we may:

• Confiscate or permanently withhold such funds, in whole or in part, to cover:
  • Chargebacks, refunds and related penalties.
  • Losses suffered by MilleWallet or third parties.
  • Investigation and administrative costs.
• Return funds to the rightful owner or originating institution where legally required or appropriate.

8.3 Offsetting and negative balances

If your account shows a negative balance (for example, due to chargebacks, fees, refunds, or corrections), you agree that:

• We may offset any positive balance in your account (present or future) against the negative balance.
• We may collect amounts owed by debiting linked payment methods or initiating collection procedures.
• You remain liable for any outstanding amounts even after account closure.

9. AML, KYC & Sanctions Compliance

MilleWallet is committed to complying with applicable anti-money laundering (“AML”), counter-terrorism financing (“CFT”) and sanctions regulations. Our AML Program includes, among other things:

• Customer identification and verification (“KYC”).
• Risk-based monitoring of accounts and transactions.
• Screening against sanctions and watch lists.
• Reporting of suspicious activities to competent authorities, where required.

You agree to:

• Provide accurate and truthful information and documents when requested.
• Promptly update your information in case of changes.
• Cooperate with any compliance review or investigation.

Failure to comply may result in account suspension, restrictions, closure and/or reporting to authorities.

10. Third-Party Providers & Bank Transfers

Payments, deposits, withdrawals and some services may be provided or facilitated by third-party PSPs, banks or other financial institutions. By using MilleWallet, you also agree to be bound by the terms and conditions and privacy policies of those third parties, as applicable.

MilleWallet is not responsible for:

• Delays, errors or failures caused by banks, PSPs or payment networks.
• Bank fees, exchange fees or intermediary charges imposed by your bank or other institutions.
• IBANs or account numbers provided by PSPs under their own regulatory licenses.

11. Closed Wallet Nature & Limitations

MilleWallet operates as a closed-wallet system (or limited network) where:

• Transfers may be limited to certain users, merchants, regions or use cases defined by MilleWallet.
• The Service may not constitute an electronic money institution or payment institution under some regulations.
• Features and limits may vary depending on your profile, country and verification level.

We may change limits (such as maximum balances, deposits, withdrawals, daily or monthly volume) at any time for risk, compliance or operational reasons.

12. Intellectual Property

All intellectual property rights in MilleWallet, including logos, trademarks, designs, software, text, graphics and interfaces, are owned by MilleWallet or its licensors. You are granted a limited, non-exclusive, non-transferable, revocable license to access and use the Service for personal or permitted business use, subject to these Terms.

You may not:

• Copy, modify, distribute or create derivative works based on the Service.
• Reverse engineer, decompile or attempt to extract the source code, except where permitted by law.
• Use our trademarks or branding without prior written permission.

13. Disclaimers & Limitation of Liability

13.1 No guarantee of uninterrupted service

The Service is provided on an “as is” and “as available” basis. We do not guarantee that the Service will be uninterrupted, secure or error-free.

13.2 No financial or investment advice

Nothing within the Service constitutes financial, investment, tax or legal advice. You are solely responsible for your financial decisions and for complying with any applicable tax obligations.

13.3 Limitation of liability

To the maximum extent permitted by law, MilleWallet and its directors, employees, and agents shall not be liable for:

• Any indirect, incidental, special, consequential or punitive damages.
• Any loss of profits, revenue, data, business or goodwill.
• Any loss or damage arising from:
  • Incorrect payment details you provided.
  • Third-party failures (banks, PSPs, payment networks).
  • Fraud or unauthorized activity caused by your failure to secure your credentials, devices or accounts.
  • Compliance actions, such as holds, freezes or account bans, performed in good faith.

Where liability cannot be excluded, it shall be limited to the lesser of (i) the total fees paid by you to MilleWallet in the previous 12 months, or (ii) a reasonable amount as defined under applicable law.

14. Indemnification

You agree to indemnify, defend and hold harmless MilleWallet, its affiliates, directors, employees and agents from and against any claims, liabilities, damages, losses, costs and expenses (including reasonable legal fees) arising out of or related to:

• Your use or misuse of the Service.
• Your breach of these Terms or any applicable law.
• Any fraud, chargeback, dispute or illegal activity linked to your account.
• Any third-party claim resulting from your actions or omissions.

15. Data Protection & Privacy

Our processing of your personal data is governed by our Privacy Policy, which explains in detail how we collect, use, share and protect your data, including in the context of AML, fraud detection and payments processing.

By using the Service, you acknowledge that we may share your data with PSPs, banks, risk and fraud providers, and competent authorities where necessary for:

• Providing the Service and executing transactions.
• Performing AML, KYC and fraud checks.
• Meeting legal and regulatory obligations.

16. Electronic Communications & Notifications

You agree that we may communicate with you electronically (for example via email, in-app messages or notifications) for all purposes related to the Service, including:

• Account information and security alerts.
• Policy updates and changes to these Terms.
• Compliance requests and investigations.

17. Changes to the Service or the Terms

We may modify the Service or these Terms from time to time. Where required by law, we will notify you in advance by email or via the Service. Continued use of the Service after the effective date of changes constitutes your acceptance of the updated Terms.

If you do not agree to the updated Terms, you must stop using the Service and request closure of your account.

18. Governing Law & Disputes

Unless otherwise required by mandatory law, these Terms and any dispute or claim arising out of or in connection with them shall be governed by and construed in accordance with the laws of the jurisdiction where MilleWallet is legally established.

Any dispute shall be submitted to the competent courts of that jurisdiction, without prejudice to any mandatory consumer protection rules granting you rights in your country of residence.

19. Miscellaneous

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

Our failure to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision.

You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations to an affiliate or in connection with a merger, acquisition or sale of assets.

If you have any questions regarding these Terms, please contact us at contact@millewallet.com.