Privacy & Policies

Terms of Service

Welcome to Spozik ("Spozik", "we", "us", or "our"). These Terms of Service ("Terms") govern your access to and use of the Spozik website, mobile application, and the services, features and content we make available to you (collectively, the "Service"). Please read these Terms carefully before using the Service.

By creating an account, downloading the application, or otherwise accessing the Service, you agree to be bound by these Terms, our Privacy Policy, and all other policies referenced herein. If you do not agree, you may not use the Service.

1. Eligibility

You must be at least 13 years of age to use the Service. If you are between 13 and the age of majority in your jurisdiction, you may only use the Service under the supervision of a parent or legal guardian who agrees to these Terms. You represent that you have full power and authority to enter into these Terms and that you are not barred from using the Service under applicable law.

2. Your Account

• You must provide accurate, current and complete information when creating an account.
• You are responsible for safeguarding your password and any credentials used to access your account.
• You are responsible for all activity that occurs under your account, whether or not authorized by you.
• You agree to notify us immediately of any unauthorized use of your account.
• We may suspend or terminate your account if we reasonably believe it has been compromised or misused.

3. Use of the Service

You agree to use the Service only for lawful purposes and in accordance with these Terms. You will not use the Service to send money to parties engaged in prohibited activities, to defraud any person or entity, or to violate any applicable law, rule, or regulation.

4. Fees and Taxes

We may charge fees for certain aspects of the Service, which will be disclosed to you before you incur them. You are responsible for any taxes, fees or other obligations that may apply to your use of the Service. For personal peer-to-peer payments within the same jurisdiction, standard fees are generally waived; business and certain instant-transfer features may be subject to fees described in the app.

5. Intellectual Property

The Service and all content, software, features, and designs made available through it are owned by Spozik or its licensors and are protected by copyright, trademark, trade dress, patent, and other intellectual property laws. You may not copy, modify, distribute, sell, or lease any part of the Service without our prior written consent.

6. Disclaimer of Warranties

The Service is provided on an "as is" and "as available" basis, without warranties of any kind, whether express or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, and non-infringement. We do not warrant that the Service will be uninterrupted, secure, or error-free.

7. Limitation of Liability

To the fullest extent permitted by law, Spozik, its affiliates, officers, directors, employees, and agents shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses, resulting from your use of the Service.

8. Indemnification

You agree to indemnify, defend, and hold harmless Spozik and its affiliates from and against any claims, liabilities, damages, losses, and expenses (including reasonable attorneys' fees) arising out of or in any way connected with your access to or use of the Service, your violation of these Terms, or your violation of any rights of another person or entity.

9. Changes to These Terms

We may modify these Terms at any time. When we do, we will post the revised Terms and update the "Last updated" date. Your continued use of the Service after the effective date of any changes constitutes acceptance of the revised Terms.

10. Termination

We may terminate or suspend your access to the Service at our discretion, without prior notice, for conduct that we believe violates these Terms or is harmful to other users, third parties, or us. You may close your account at any time by contacting support, subject to settlement of outstanding balances.

11. Governing Law

These Terms are governed by the laws of the jurisdiction in which Spozik is established, without regard to conflict of law principles. Any disputes arising out of these Terms shall be resolved in the competent courts of that jurisdiction, subject to the dispute resolution provisions described below.

12. Dispute Resolution

Before filing a claim, you agree to contact our support team and attempt to resolve the dispute informally for 30 days. If the dispute is not resolved, you agree that any claims shall be resolved by binding arbitration in accordance with the rules of the applicable arbitration association, unless otherwise required by law. You may opt out of arbitration within 30 days of first agreeing to these Terms by contacting us.

Privacy Policy

This Privacy Policy describes how Spozik collects, uses, shares, and protects information about you when you use the Service, including the Android mobile application. It applies to information we collect when you register, make or receive payments, add payment methods, grant in-app permissions, contact support, or otherwise interact with the Service.

Information We Collect

• Account Information: name, email address, phone number, date of birth, and profile picture you provide.
• Financial Information: linked bank accounts (institution name and last four digits only — your bank login credentials are handled by our bank-linking provider, never by us), card details (stored in encrypted form with tokenized numbers), and transaction history.
• Device & Usage Information: IP address, device identifiers, operating system, browser type, and information about how you interact with the Service.
• Log Information: details of your use of the Service, including timestamps, feature usage, and crash reports.
• Communications: information you provide when you contact support or participate in surveys and promotions.
• Device Contacts (with your permission): names and phone numbers from your device's address book. These are read only when you open the app's People, Send, or Request screens, and only after you grant the Contacts permission. The phone numbers are then transmitted over an encrypted connection to Spozik's own servers and compared against the phone numbers of accounts that already use Spozik, so the app can show you which of your contacts can receive money from you. Your contact list is used for this matching only: it is not stored on our servers after the comparison, is not sold, is not shared with advertisers or any third party, and is not used for advertising or marketing.

App Permissions

The Android app declares the permissions below and requests each one only at the moment you use the feature that needs it — never on launch before you have done anything. Declaring a permission is not the same as collecting data: no data is read at all until you grant the relevant permission and reach that feature. Each permission is used strictly for the feature that requires it:

• Contacts: to find your friends already on Spozik so you can send and request money by name. Read only on the People, Send, and Request screens.
• Camera: to capture profile photos or scan QR payment codes, and only when a screen you opened asks for it.
• Microphone: to record voice messages or content you choose to attach, and only when a screen you opened asks for it.
• Location (approximate and precise): to show nearby people/activity and enable proximity features when you opt in, and only when a screen you opened requests it.
• Photos and videos: to attach a picture you choose. The app uses the Android system Photo Picker, so it receives access to the single item you select and cannot see, browse, or index your photo library. Spozik does not declare READ_MEDIA_IMAGES, READ_MEDIA_VIDEO, READ_MEDIA_VISUAL_USER_SELECTED, MANAGE_EXTERNAL_STORAGE, or READ_EXTERNAL_STORAGE/WRITE_EXTERNAL_STORAGE.
• Notifications: to send you transaction alerts and account updates.

You can revoke any of these permissions at any time in your device settings. Revoking a permission only disables the feature that relies on it; it does not affect the rest of the Service.

How We Use Your Information

• To operate, maintain, and improve the Service.
• To process and settle your payment transactions.
• To verify your identity and prevent fraud, money laundering, and other prohibited activities.
• To communicate with you about your account, transactions, and service updates.
• To personalize your experience and deliver relevant in-app content.
• To comply with legal and regulatory obligations.

How We Share Your Information

We do not sell your personal information. Device contacts you choose to share are sent only to Spozik's own servers, over an encrypted connection, to match them against existing Spozik accounts; they are not shared with advertisers, analytics providers, or any other third party. Otherwise, we may share information with service providers who process data on our behalf (such as payment processors, identity verification providers, and cloud hosting), with financial institutions to facilitate transactions, with law enforcement or regulators where required by law, and with your consent or at your direction.

Data Security

We use administrative, technical, and physical safeguards to protect your information, including encryption in transit and at rest, tokenization of card data, and access controls. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

Data Retention

We retain your information for as long as your account is active and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. Transaction records may be retained longer where required by law. Contact phone numbers sent for matching are processed in memory for the comparison and are not retained on our servers once that comparison completes.

Your Choices

You may update your profile information at any time from your account settings. You may request access to, correction of, or deletion of your personal information by contacting us. You can stop the app from reading your contacts at any time by revoking the Contacts permission in your device settings — the app will then no longer read or transmit your address book, and the people/contact features will fall back to searching within Spozik only. You may also withdraw consent to certain data uses where applicable, subject to legal requirements.

Children's Privacy

The Service is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.

Contact

If you have questions about this Privacy Policy or your data, contact our Privacy Office at privacy@spozik.com.

Data Safety

This section is the plain-language mirror of our Google Play Data safety declaration. It exists so you — and Google Play's policy reviewers — can check the app against the declared answers without guessing. Every answer below is also stated in the Privacy Policy.

Data we collect

Data we do not collect at all

• No photo or video library access. The app uses the Android system Photo Picker, so it can only read the single item you select. It does not declare READ_MEDIA_IMAGES, READ_MEDIA_VIDEO, READ_MEDIA_VISUAL_USER_SELECTED, MANAGE_EXTERNAL_STORAGE, or legacy READ_EXTERNAL_STORAGE/WRITE_EXTERNAL_STORAGE.
• No health or fitness information.
• No web browsing history, or files and documents from your device beyond the single attachment you choose.
• No SMS, call history, or email contents.
• No advertising or marketing identifiers, and we do not use your data for ads.

Is your data sold or shared for advertising?

No. We do not sell your personal information and we do not share it for cross-app behavioural advertising. Data is shared only with the service providers listed in the Privacy Policy — payment processors, our bank-linking provider, our card programme partner, hosting and identity verification — purely to deliver the Service you asked for, and where we say so above.

Can you request deletion?

Yes. Email privacy@spozik.com from the address on your account and we will verify your identity and action the request. Contact phone numbers sent for matching are held in memory for the comparison only and are already discarded once it finishes.

Consumer Agreement

This Consumer Agreement ("Agreement") is between you and Spozik and governs your use of the Spozik money-transfer services, including sending, requesting, and receiving funds through the Service.

1. Your Balance

Funds you add to your Spozik balance are held in pooled accounts at our banking partners. Your balance is not a bank deposit and is not eligible for federal deposit insurance unless otherwise indicated. Funds in your balance are available for peer-to-peer payments and withdrawals according to your available balance.

2. Sending and Receiving

• Payments: When you send a payment, funds are debited from your balance or linked payment method and credited to the recipient's balance. Payments sent from a bank-linked account may take several business days to settle.
• Requests: A payment request is not a payment. A request merely invites the counterparty to authorize a transfer; funds move only when the counterparty confirms.
• Receiving: Money you receive is added to your available balance. You can keep it there, send it to someone else, or withdraw it to your linked bank account.

3. Authorization and Reversals

By confirming a payment, you authorize Spozik to debit the specified amount. Peer-to-peer payments are generally final once processed; we cannot reverse a payment without the recipient's consent, except where required by law or our fraud policies.

4. Disclosures and Errors

You are responsible for reviewing your transaction history. If you believe an error has occurred, you must notify us promptly (generally within 60 days) so we can investigate. We will correct verified errors by refunding the affected amount to your balance.

Cardholder Agreement

This Cardholder Agreement applies when you order a Spozik Card (the "Card") and use it to make purchases. The Card is a physical card manufactured, shipped, and issued in partnership with our licensed card program provider and its issuing bank, not by Spozik itself.

How to Get Your Card

1. Open Create card in the app (and on the web at /create-card).
2. Choose a design — limited colorways, animals, or a country flag — or build a Custom card with two colors of your choice plus an optional flag.
3. Enter the name to print on the card and confirm your shipping address. The name is sanitized to letters, numbers, and spaces before it is sent to our card provider.
4. Submit your request. It is reviewed, then created for you. Our provider's partner bank prints and mails the card to your saved address.
5. Track it any time under Your card orders. Once the card ships, the carrier and tracking number appear next to the order. When delivery is confirmed, the card is activated.

Card Issuance and Use

The Card is not a credit card. Card transactions are debited from the available balance in your account at the time of the transaction. You must maintain a sufficient available balance to complete any purchase.

Authorized Users

You are the only person authorized to use your Card. You may not allow anyone else to use your Card, and you are responsible for all transactions initiated with it.

Lost or Stolen Cards

Report a lost, stolen, or compromised Card immediately through the app. We will freeze the Card and work with our provider on a replacement. Your liability for unauthorized use is limited if you notify us promptly and have not acted negligently.

Fees

There are no monthly fees for using the Card. Fees may apply to certain optional features — such as instant transfers, ATM withdrawals through partner networks, or replacement cards — and will be disclosed before you incur them.

Foreign Transactions

Transactions in a currency other than your account currency may be subject to a foreign transaction fee and exchange-rate adjustments, which will be reflected in your transaction details.

Cancellation

You may cancel your Card order at any time before it is shipped from the app or by contacting support. Spozik or the issuer may also suspend or terminate the Card at their discretion for suspected fraud, violations of this Agreement, or legal requirements.

Design Artwork

Design artwork shown in the card studio is illustrative. Flag artwork is sourced from our country list (with image links provided by flagcdn.com) for identification purposes on your card face; it does not imply any affiliation with, or endorsement by, the country depicted.

Banking Services

Spozik partners with regulated financial institutions to provide the underlying payment infrastructure for the Service. Spozik itself is not a bank. Certain features, such as account top-up, instant deposits, and withdrawals, are facilitated through our banking partners.

Direct Deposit and Top-Up

You may add funds to your Spozik balance from a linked bank account or other funding source. Standard transfers typically settle within one to three business days. Instant transfer features, where available, incur a fee that is disclosed before you confirm the transfer.

Linking Your Bank Account (Plaid)

You can link a bank account by choosing your bank in the Plaid Link flow. Plaid handles your bank login securely, and Spozik never sees or stores your bank login credentials — we only keep a masked reference (bank name and last four digits). If instant linking is not available for your bank or country, you may add a bank manually using the last four digits only.

Withdrawals

You may withdraw your available balance to a linked bank account at any time. Withdrawals are subject to your bank's processing times and any applicable limits. Withdrawal fees, if any, will be disclosed before you confirm.

Transfers to Bank or Card

You may withdraw your available balance to a linked bank account or onto your Spozik Card. Bank transfers settle within the time shown before you confirm; transfers to your card are instant and add funds to a Spozik Card balance you can spend wherever cards are accepted. Where a payment partner is connected, bank settlements may be made directly by the partner to your bank.

Withdrawal Fees

A fee is charged on certain withdrawals and is always disclosed before you confirm. Fees are a small percentage of the transferred amount and vary by destination (bank or card) under the current fee schedule.

Country Availability

Instant bank linking is available only in countries supported by our bank-linking provider. Where it is not available, we tell you in the app and let you add a bank manually or cash out to your Spozik Card instead.

FDIC Insurance

Depending on the program structure, funds held in your balance may be held in an FDIC-insured account at our partner banks. In a demo environment, no actual funds or insurance apply. This disclosure is provided for educational purposes.

Account Holds and Freezes

We may place a hold on your balance or a transaction where required by law, to comply with regulatory requirements, or where we reasonably suspect fraud or prohibited activity. We will notify you when we place a hold where permitted by law.

Acceptable Use Policy

This Acceptable Use Policy describes activities that are prohibited when using the Service. You may not use the Service, directly or indirectly, for or in connection with:

• Fraudulent activity, including phishing, scams, impersonation, or deceptive financial practices.
• Money laundering, terrorist financing, or any activity prohibited by sanctions, anti-money-laundering, or counter-terrorism laws.
• Purchasing or selling controlled substances, prescription drugs, firearms, ammunition, or other regulated goods in violation of law.
• Gambling, betting, lotteries, or other transactions where funds are staked on uncertain events, unless expressly permitted by law and our policies.
• Pornography, escort services, or content of an explicitly sexual nature.
• Child exploitation or any activity involving harm to minors.
• High-risk investments, including pump-and-dump schemes or unregistered securities offerings.
• Any activity that violates the rights of others or applicable law.
• Attempting to gain unauthorized access to the Service, our systems, or other users' accounts.
• Uploading malicious code, viruses, or any content designed to disrupt the Service.

We may monitor transactions for compliance with this policy and may freeze, reverse, or reject transactions and suspend accounts that we believe violate it.

License Agreement

Subject to your compliance with these Terms and the Acceptable Use Policy, Spozik grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Service for your personal, non-commercial purposes. This license is subject to the following restrictions:

• You may not copy, modify, translate, or create derivative works of the Service or its software.
• You may not reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code of the Service.
• You may not remove, alter, or obscure any copyright, trademark, or other proprietary notices.
• You may not rent, lease, lend, sell, sublicense, or otherwise commercially exploit the Service.
• You may not use the Service to develop a competing product or service.

We may update, modify, or discontinue any feature of the Service at any time. The license granted herein automatically terminates upon any breach of these Terms.

Licenses & Open Source

The Service incorporates open-source software components. The use of these components is subject to their respective open-source licenses. We gratefully acknowledge the following categories of open-source software used by Spozik:

• Express.js — MIT License. A minimal and flexible Node.js web application framework.
• Mongoose — MIT License. An elegant MongoDB object modeling tool for Node.js.
• jsonwebtoken — MIT License. An implementation of JSON Web Tokens for Node.js.
• bcryptjs — MIT License. A library to hash and compare passwords.
• dotenv — BSD-2-Clause. Loads environment variables from a .env file.
• jsQR — Apache-2.0. A pure JavaScript QR code reading library.
• QRCode — MIT License. A QR code generation library.
• Plaid (Link + Node SDK) — MIT License. Bank account linking, powered by Plaid to connect users to their bank accounts.

Full copies of each license are available on request. Nothing in these Terms restricts, impairs, or is intended to override rights you may have under any applicable open-source license.

Cookie Policy

Spozik uses cookies and similar technologies to keep you signed in, remember your preferences, and understand how the Service is used. This policy explains what cookies are, how we use them, and how you can control them.

What Are Cookies?

Cookies are small text files stored on your device when you visit a website or use an application. They are widely used to make services work efficiently and to provide reporting information.

How We Use Cookies

• Essential cookies: Required for the Service to function, such as keeping you authenticated during a session.
• Preference cookies: Remember settings such as your preferred currency or theme.
• Analytics cookies: Help us understand usage patterns so we can improve the Service.
• Security cookies: Help detect and prevent fraudulent or abusive activity.

Managing Cookies

Most browsers let you control cookies through their settings. You may block or delete cookies, but doing so may prevent parts of the Service from working correctly, including signing in.

Accessibility Statement

Spozik is committed to ensuring the Service is accessible to people with disabilities. We strive to conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, and we continuously work to improve the accessibility of our products.

Our Efforts

• Clear color contrast and legible type throughout the interface.
• Keyboard navigation support for all major features.
• Descriptive labels and instructions for form fields.
• Responsive layouts that adapt to assistive technologies and screen sizes.
• Text alternatives for meaningful icons and images.

Feedback

If you encounter an accessibility barrier, please contact us at accessibility@spozik.com. We will review your feedback and work to address the issue.

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information.

Your Rights

• Right to know: You may request details about the categories and specific pieces of personal information we collect, use, and disclose.
• Right to delete: You may request deletion of the personal information we hold about you, subject to certain exceptions.
• Right to correct: You may request correction of inaccurate personal information.
• Right to opt out of sale/sharing: We do not sell or share personal information. You may still exercise the right to opt out at any time.
• Right to non-discrimination: We will not discriminate against you for exercising any of your privacy rights.

How to Exercise Your Rights

You may submit a request by emailing privacy@spozik.com. We will verify your identity before responding, generally within 45 days. You may also designate an authorized agent to submit requests on your behalf.

We collect the categories of personal information described in our Privacy Policy, including identifiers (name, email, phone), financial information, and commercial information (transaction history). We do not sell personal information.

EU & UK Data Rights

If you are located in the European Economic Area (EEA) or the United Kingdom, the General Data Protection Regulation (GDPR) and related legislation provide you with specific rights regarding your personal data.

Legal Bases for Processing

• Contract: Processing necessary to provide the Service you have requested.
• Legal obligation: Processing required to comply with financial and anti-fraud regulations.
• Legitimate interests: Processing to improve the Service and prevent abuse, balanced against your interests and rights.
• Consent: Processing for optional purposes, such as marketing, where you have given consent and may withdraw it at any time.

Your Rights

• Right of access to your personal data.
• Right to rectification of inaccurate data.
• Right to erasure ("right to be forgotten").
• Right to restrict processing.
• Right to data portability.
• Right to object to processing based on legitimate interests.
• Right to lodge a complaint with your supervisory authority.

International Transfers

Your personal data may be transferred to and processed in countries outside the EEA or UK. Where such transfers occur, we rely on appropriate safeguards, including standard contractual clauses, to protect your data.

Contact

To exercise your rights, contact us at privacy@spozik.com. We will respond within one month of receiving a verified request.

Feedback & Complaints

We value your feedback and take complaints seriously. If you have a complaint about the Service, a transaction, or our policies, we want to resolve it quickly and fairly.

How to Submit a Complaint

You may submit a complaint by contacting support through the app, by email at support@spozik.com, or by mail to our registered address. Please include your account email, a description of the issue, and any relevant transaction details.

Our Process

1. We acknowledge receipt of your complaint within 5 business days.
2. We investigate, which may take up to 15 business days depending on complexity.
3. We respond with our findings and any corrective action taken.
4. If you remain unsatisfied, you may escalate to our senior complaints team.

Regulatory Escalation

If we cannot resolve your complaint to your satisfaction, you may be entitled to refer the matter to the appropriate financial ombudsman or regulator in your jurisdiction.

Compliance & Regulations

Spozik is committed to operating in compliance with all applicable laws and regulations governing money transmission, consumer protection, anti-money laundering (AML), and counter-terrorism financing (CTF).

Identity Verification

We are required to verify the identity of our customers. When you register or reach certain transaction thresholds, we may ask for your full name, date of birth, government-issued identification, and proof of address. We may refuse service where identity cannot be adequately verified.

Transaction Monitoring

We monitor transactions for suspicious activity and may file reports with the appropriate financial intelligence units where required by law. We may also block or freeze transactions that appear unusual, without notice where disclosing such action could prejudice an investigation.

Sanctions

We screen customers and transactions against sanctions lists maintained by the applicable authorities. We do not provide services to individuals or entities on such lists, and transactions involving sanctioned parties are prohibited.

Licensing

Money transmission activities are licensed and regulated in many jurisdictions. Spozik operates under applicable money transmitter licenses and may disclose its license numbers to you on request.

Contacting Regulators

Customers may contact the appropriate financial regulator in their jurisdiction to learn more about their rights or to file a complaint about a licensed money transmitter.