Terms & Conditions

1.About ARIDANG and these Terms

ARIDANG OÜ ("ARIDANG", "we", "us", "our") is a company registered in Estonia. ARIDANG operates exclusively as an introducer and referral intermediary. We provide a branded platform and client-facing interface through our website at aridang.com and the online portal at online.aridang.ee, through which eligible businesses may apply to access corporate payment account services.

These Terms & Conditions ("Terms") govern your access to and use of the ARIDANG referral platform only. A separate agreement between you and Gemba Finance Ltd governs the payment account services. By registering or submitting an application through the ARIDANG platform, you confirm that you have read, understood, and agree to be bound by these Terms. If you do not agree, do not use our platform.

These Terms apply to corporate clients only. We do not offer services to individual consumers acting in a personal capacity.

ARIDANG reserves the right, at its sole and absolute discretion, to decline to introduce any applicant to Gemba Finance Ltd, or to discontinue making introductions at any time, without providing reasons and without liability to the applicant.

2.Eligibility and account opening

To open an account with ARIDANG, you must:

• Be a legally incorporated entity (company, partnership, or other business structure).
• Have at least one director or authorised signatory who is able to legally bind the entity.
• Successfully complete our know-your-business (KYB) and know-your-customer (KYC) onboarding process.
• Not be engaged in, or associated with, any activities listed in our Eligibility Policy.
• Not be subject to sanctions, asset freezes, or other regulatory restrictions that would prevent us from providing services.

We reserve the right to decline any application at our sole discretion, including where we are unable to complete satisfactory due diligence, without providing reasons.

Your account zone (UK, EU, or World) is determined by the residency of your company, all directors, and all Ultimate Beneficial Owners (UBOs). Misrepresenting residency or ownership information is a material breach of these Terms.

3.Your account

Upon successful onboarding, you will receive access to a corporate payment account with dedicated account number(s) and IBAN(s).

• You are responsible for maintaining the confidentiality of your login credentials and for all activity conducted under your account.
• You must notify us immediately at info@aridang.eu if you suspect unauthorised access to your account.
• You may grant access to team members with granular permission levels. You are responsible for all actions taken by authorised users on your account.
• An account with no transactions within 90 consecutive days may be classified as inactive. We reserve the right to apply an inactivity fee or request confirmation of continued use.

4.Payment services

Through a Gemba Finance Ltd account accessible via the ARIDANG platform, you may access the following payment rails and services (subject to your account zone and Gemba Finance Ltd's eligibility criteria and terms):

• UK Faster Payments (FPS) — domestic UK send and receive
• BACS — bulk UK direct debits and credits
• SEPA Credit Transfer and SEPA Instant — euro-area payments
• SWIFT / CHAPS / Target2 — international and high-value transfers
• Internal transfers — instant, between accounts on the Gemba Finance Ltd network
• Corporate card issuance and spend management (UK and EU zones)
• Multi-currency foreign exchange at published margins
• Bulk payment API — up to 3,000 transactions per minute

Payment execution timescales, transaction limits, currency availability, and service features are determined solely by Gemba Finance Ltd and the applicable payment scheme rules. ARIDANG has no control over and no liability for the execution, rejection, delay, reversal, or failure of any payment instruction.

All payment instructions submitted through the platform are directed to and processed by Gemba Finance Ltd. Such instructions are irrevocable once accepted by Gemba Finance Ltd, except where reversal is possible under applicable payment scheme rules. Any request to recall a payment must be made to Gemba Finance Ltd directly; ARIDANG cannot initiate, guarantee, or be held responsible for the outcome of any recall request.

Your funds are held and safeguarded by Gemba Finance Ltd in accordance with the FCA's safeguarding requirements for electronic money institutions. Under the Payment Services Regulations 2017, Gemba Finance Ltd is required to segregate all client funds in dedicated accounts at authorised credit institutions, separate from Gemba Finance Ltd's own funds. ARIDANG holds no client funds at any time. For full details of the FCA's safeguarding framework, see: fca.org.uk — Safeguarding requirements for EMIs.

5.Fees and charges

Our fees are set out in the Full Price List. By using our services, you agree to pay all applicable fees. Key points:

• Fees are denominated in GBP. Your applicable zone (UK, EU, or World) determines which fee schedule applies.
• We reserve the right to update our fee schedule with 30 days' written notice. Continued use of the service after the effective date constitutes acceptance of the new fees.
• A High Value Fee may apply when your weekly transaction volume exceeds £100,000, calculated from Monday each week.
• An additional compliance surcharge (1%, minimum £500 or £250 per compliance hour) may apply to High-Risk Transfers (HRT) as defined in our pricing documentation.
• Fees are charged by direct debit from your account balance. You must maintain sufficient funds to cover applicable fees.
• In the event of account termination due to a breach of these Terms, a termination fee of £1,000 applies and funds may be held at 5% per month (minimum £500) during the holding period.

6.Acceptable use

You agree to use ARIDANG's services only for lawful business purposes and in accordance with these Terms. Specifically, you agree to:

• Provide accurate, complete, and up-to-date information at all times, including promptly notifying us of any changes to your company structure, directors, UBOs, or business activities.
• Use the account solely for the business activities disclosed during onboarding.
• Maintain adequate records and provide supporting documentation for transactions within 3 business days of our request.
• Not allow any third party to use the account on your behalf without our prior written consent.
• Comply with all applicable laws, including anti-money laundering, sanctions, and tax reporting obligations in your jurisdiction.

7.Prohibited activities

You must not use ARIDANG's services in connection with any of the following:

• Unlicensed financial services, including unlicensed money transmission, exchange, or lending.
• Activities involving proceeds of crime, money laundering, or terrorist financing.
• Cryptocurrency exchanges, mining operations, ICOs, NFT platforms, or related businesses (unless expressly approved in writing).
• Online gambling, gaming, or betting platforms without appropriate licensing.
• Adult content, escort services, or dating platforms.
• Weapons, firearms, ammunition, or military equipment trading.
• Pharmaceutical sales without regulatory approval.
• Shell companies with no apparent business substance or economic purpose.
• Any business involving individuals or entities subject to sanctions.
• Any other activity that we reasonably consider to present unacceptable legal, regulatory, or reputational risk.

A full eligibility matrix is available in our Eligibility Policy.

8.Compliance obligations

We are subject to anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. As our client, you acknowledge and agree that:

• We may request additional documentation at any time in connection with your account or any transaction, including source of funds evidence, contracts, or invoices.
• Failure to provide requested documentation within 3 business days may result in the suspension of your account and a late documentation fee of £5 per day from the 4th day.
• We may file suspicious activity reports (SARs) with relevant financial intelligence authorities without notifying you, where required by law.
• We conduct periodic reviews of your account and may request updated KYB/KYC information.
• Transactions to or from high-risk countries or counterparties may be subject to enhanced due diligence and/or the HRT compliance surcharge.

9.Limitation of liability — ARIDANG as introducer

9.1 — Scope of ARIDANG's liability

ARIDANG's sole obligation under these Terms is to introduce eligible applicants to Gemba Finance Ltd and to maintain the platform through which that introduction is made. ARIDANG is not a payment service provider and is not a party to any payment account agreement between you and Gemba Finance Ltd. Accordingly, ARIDANG's liability is strictly limited to its role as an introducer.

9.2 — Aggregate liability cap

To the maximum extent permitted by applicable law, ARIDANG's total aggregate liability to you — whether in contract, tort (including negligence), breach of statutory duty, or otherwise — arising out of or in connection with these Terms or the ARIDANG platform shall not exceed £500 (five hundred pounds sterling), or the total referral or platform fees actually paid by you to ARIDANG (not to Gemba Finance Ltd) in the 12 months preceding the event giving rise to the claim, whichever is lower.

9.3 — Exclusion of consequential loss

To the maximum extent permitted by applicable law, ARIDANG shall not be liable — whether in contract, tort, or otherwise — for any:

• loss of profit, loss of revenue, or loss of anticipated savings;
• loss of business, goodwill, contracts, or commercial opportunities;
• loss or corruption of data or information;
• indirect, consequential, incidental, special, or punitive damages of any kind;
• reputational harm or regulatory penalties arising from your use of the payment services.

9.4 — Exclusion of liability for payment services

ARIDANG expressly excludes all liability in connection with the payment account services provided by Gemba Finance Ltd, including but not limited to:

• the rejection, delay, failure, reversal, or incorrect execution of any payment instruction;
• the freezing, restriction, suspension, or closure of your account by Gemba Finance Ltd;
• any compliance hold, suspicious activity report, or regulatory action taken by Gemba Finance Ltd;
• the unavailability or interruption of any payment rail, currency, or service feature;
• any foreign exchange loss, conversion error, or FX rate applied by Gemba Finance Ltd;
• the acts, omissions, errors, insolvency, or regulatory status of Gemba Finance Ltd;
• loss of funds held by Gemba Finance Ltd, whether due to fraud, insolvency, or otherwise;
• any failure by Gemba Finance Ltd to comply with its regulatory obligations;
• the accuracy, completeness, or currency of any information provided by Gemba Finance Ltd.

Your sole recourse in respect of any of the above matters is against Gemba Finance Ltd directly, under the terms of your agreement with Gemba Finance Ltd. ARIDANG is not able to assist in or be liable for resolving any dispute between you and Gemba Finance Ltd.

9.5 — No warranty

ARIDANG makes no representation or warranty, express or implied, regarding: (a) the outcome of any application submitted to Gemba Finance Ltd; (b) the continued availability of Gemba Finance Ltd's services; (c) the suitability of Gemba Finance Ltd's products for your business needs; or (d) the accuracy of any information about Gemba Finance Ltd's fees, service levels, or capabilities published on the ARIDANG platform. Such information is provided for indicative purposes only and may not reflect Gemba Finance Ltd's current terms.

9.6 — Indemnity

You agree to indemnify, defend, and hold harmless ARIDANG OÜ and its directors, officers, employees, agents, and affiliates (each an "Indemnified Party") from and against any and all claims, proceedings, demands, losses, damages, liabilities, costs, and expenses (including reasonable legal fees) arising out of or in connection with:

• your breach of any provision of these Terms;
• your use of the ARIDANG platform or the payment services;
• any misrepresentation made by you during the application or onboarding process;
• any claim brought by Gemba Finance Ltd, a regulatory authority, or any third party in connection with your payment account or your business activities;
• your violation of any applicable law, regulation, or third-party rights.

This indemnity shall survive termination or expiry of your account and these Terms.

9.7 — Force majeure

ARIDANG shall not be liable for any failure or delay in performing its obligations under these Terms to the extent that such failure or delay is caused by circumstances beyond its reasonable control, including acts of God, acts of government or regulatory authority, pandemics, cyberattacks, third-party service failures (including those of Gemba Finance Ltd, payment networks, or technology providers), telecommunications failures, or other events of force majeure.

10.Suspension and termination

By you: You may close your account at any time by providing written notice to info@aridang.eu. Any outstanding fees will be deducted from your balance before funds are returned. Please allow up to 10 business days for closure processing.

By us: We may suspend or terminate your account immediately and without prior notice if:

• We have reasonable grounds to suspect fraud, money laundering, or other criminal activity.
• You breach any material provision of these Terms.
• We are required to do so by law, regulation, or instruction from a competent authority.
• You provide false or misleading information during onboarding or at any subsequent point.
• Your account poses an unacceptable risk to us or our payment network partners.

Where we terminate your account due to a breach, a termination fee of £1,000 applies. Any funds remaining in your account after settlement of all fees will be returned to a nominated bank account. Funds held during a post-termination review period are subject to a holding charge of 5% per month (minimum £500).

11.Changes to these Terms

We may amend these Terms from time to time. We will provide at least 30 days' notice of material changes via email or a notice in your online banking portal. Your continued use of the services after the effective date of the changes constitutes your acceptance of the amended Terms.

If you do not agree to the revised Terms, you must stop using the services and close your account before the effective date.

12.Governing law and disputes

These Terms are governed by the laws of the Republic of Estonia, without regard to conflict of law principles. The courts of Estonia shall have exclusive jurisdiction over any disputes arising out of or in connection with these Terms, except where mandatory consumer protection laws in your jurisdiction provide otherwise.

Before commencing formal proceedings, we encourage you to contact us at info@aridang.eu to resolve any dispute informally. We will acknowledge your complaint within 5 business days and aim to resolve it within 15 business days.

Payment service-related complaints may also be referred to the Financial Ombudsman Service (UK) where Gemba Finance Ltd is the relevant regulated entity.

13.Contact