PagoPay Terms of Service
Effective Date: November 18, 2025
Last Updated: March 2026
1. Introduction
These Terms of Service (“Terms”) govern your access to and use of the PagoPay platform, mobile applications, and related services (collectively, the “Platform”).
By accessing or using the Platform, you agree to be bound by these Terms. If you do not agree with these Terms, you must not use the Platform.
2. Operator of the Platform
PagoPay Payment Services is operated by 9538-8310 Québec Inc., a company incorporated in Québec, Canada and registered as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
Certain operational services may be conducted by 1001529768 Ontario Inc., acting as a registered MSB agent on behalf of the principal MSB.
PagoPay provides financial technology services including:
• digital wallet services
• payment transfers and balance transfers
• cryptocurrency conversion services
• prepaid card funding and spending services
PagoPay is a financial technology platform and not a bank.
Funds held within the Platform are not deposits and are not insured by the Canada Deposit Insurance Corporation (CDIC).
3. Eligibility
To use the Platform, users must:
• be at least 18 years old
• complete required identity verification procedures
• comply with applicable laws and regulations
• not be subject to applicable sanctions restrictions.
PagoPay reserves the right to refuse, restrict, or terminate accounts that do not meet eligibility requirements.
4. Identity Verification
PagoPay is required to verify the identity of users in accordance with anti-money laundering and financial crime regulations.
Users may be required to submit:
• government-issued identification
• proof of residential address
• biometric verification such as live selfie verification.
PagoPay may request additional documentation or information to comply with regulatory obligations.
5. Services Offered
The Platform may provide access to the following services:
• digital wallet services
• cryptocurrency on-ramping and off-ramping
• peer-to-peer transfers
• foreign exchange conversion services
• prepaid card funding and spending
Availability of services may vary depending on regulatory requirements and geographic restrictions.
6. Fees
Certain services may involve fees, including but not limited to:
• card issuance fees
• monthly card or account subscription fees
• cryptocurrency conversion spreads or fees
• foreign exchange conversion fees.
Applicable fees will be disclosed within the Platform prior to completing transactions.
7. Card Subscription and Renewal Fees
Certain prepaid card products offered through the Platform may require a recurring subscription or maintenance fee.
By activating and using a PagoPay card, the cardholder authorizes PagoPay and its issuing partners to charge applicable card subscription or renewal fees.
Where applicable, card subscription fees may be automatically deducted from the cardholder’s available balance at the time of renewal.
If sufficient funds are not available at the time of renewal, card functionality may be suspended until the applicable subscription fee is paid.
8. Account Responsibilities
Users are responsible for maintaining the confidentiality of their account credentials.
Users must:
• protect login information and authentication credentials
• immediately report unauthorized access or suspicious activity
• ensure all information provided to PagoPay is accurate and current.
PagoPay is not responsible for losses resulting from unauthorized access caused by failure to safeguard account credentials.
9. Transaction Responsibility
Users are responsible for ensuring the accuracy of all transaction details submitted through the Platform.
This includes verifying:
• recipient wallet addresses
• recipient account information
• transaction amounts
• selected blockchain networks where applicable.
Cryptocurrency transactions are generally irreversible once submitted to the blockchain network.
PagoPay cannot cancel, reverse, or recover transactions once confirmed on the blockchain.
PagoPay is not responsible for losses resulting from transactions sent to incorrect wallet addresses, incorrect recipients, or incorrect network selections.
10. Blockchain Network Risk
Cryptocurrency transactions are processed through decentralized blockchain networks that are not controlled by PagoPay.
Transaction processing times, network fees, and confirmation speeds are determined by the underlying blockchain networks.
Users acknowledge that:
• blockchain networks may experience congestion or delays
• transaction fees may fluctuate
• confirmation times may vary depending on network activity.
PagoPay is not responsible for delays, increased transaction fees, or failed transactions resulting from blockchain network conditions outside its control.
11. Prohibited Activities
Users may not use the Platform to:
• engage in illegal or fraudulent activities
• conduct transactions involving sanctioned individuals or jurisdictions
• attempt to bypass identity verification procedures
• process transactions on behalf of third parties without authorization
• violate applicable financial regulations.
PagoPay reserves the right to restrict or terminate accounts involved in prohibited activities.
12. Regulatory Compliance and Anti-Money Laundering
PagoPay operates in accordance with applicable anti-money laundering and counter-terrorist financing regulations.
PagoPay may monitor transactions and account activity to ensure compliance with applicable laws.
Users acknowledge that PagoPay may:
• conduct transaction monitoring
• request additional identity verification
• delay or block transactions
• restrict or suspend accounts.
PagoPay may report certain transactions or account activity to regulatory authorities as required by law.
13. Source of Funds Verification
PagoPay may request documentation regarding the source of funds associated with transactions conducted through the Platform.
Failure to provide requested information may result in transaction delays, account restrictions, or account termination.
14. Sanctions and Geographic Restrictions
PagoPay services may not be available in certain jurisdictions due to regulatory requirements or international sanctions.
Users may not access or use the Platform if they are located in, resident in, or conducting transactions from jurisdictions subject to comprehensive sanctions.
These sanctions may include those administered by:
• the Government of Canada
• the United States Office of Foreign Assets Control (OFAC)
• the United Nations Security Council
• other applicable governmental authorities.
Examples of sanctioned jurisdictions may include:
• North Korea
• Iran
• Syria
• Cuba
• Crimea Region of Ukraine
• Donetsk Region of Ukraine
• Luhansk Region of Ukraine.
PagoPay reserves the right to restrict services in any jurisdiction where providing services would violate applicable laws or regulations.
15. Third-Party Crypto Payments
Individual users may receive cryptocurrency transfers from external blockchain wallets, including transfers originating from third parties.
Business Accounts may also receive cryptocurrency payments from customers or other counterparties as part of legitimate commercial activity.
However, transfers made to PagoPay for the purpose of funding corporate wallets or corporate prepaid card programs must originate from the verified Business Account associated with the onboarded corporate entity.
PagoPay does not accept direct third-party transfers intended to fund corporate card programs from individuals or entities that have not been verified through the Business Account.
All incoming transactions remain subject to compliance review and monitoring.
16. Third-Party Services
Certain services provided through the Platform may rely on third-party service providers including payment processors, card issuing institutions, and cryptocurrency liquidity providers.
PagoPay is not responsible for delays, outages, or service disruptions caused by third-party providers.
17. Card Program and Issuer Disclaimer
Prepaid card services offered through the Platform are issued and managed by licensed third-party issuing institutions.
These issuing institutions are responsible for the custody of card balances and administration of card program funds.
PagoPay does not hold or control card program funds.
If a card program is suspended or terminated by the issuing institution or card network, PagoPay will use reasonable efforts to notify users and facilitate communication with the issuing institution.
Users may be required to contact the issuing institution directly to recover funds held by the issuer.
18. Program Changes
PagoPay may modify, suspend, replace, or discontinue certain services or programs where required by regulatory requirements, banking partners, card issuers, or service providers.
PagoPay will use reasonable efforts to notify users of material changes where practicable.
19. Inactive or Dormant Accounts
Accounts that remain inactive for twelve (12) consecutive months may be classified as dormant.
PagoPay may apply a monthly inactivity maintenance fee to dormant accounts where permitted by applicable regulations.
Users may avoid inactivity fees by logging into their account or conducting a transaction.
20. Disclaimers and Limitation of Liability
PagoPay disclaims liability for:
• losses resulting from cryptocurrency price volatility
• unauthorized account access caused by user negligence
• service interruptions caused by third-party infrastructure providers.
To the maximum extent permitted by law, PagoPay shall not be liable for indirect or consequential damages arising from the use of the Platform.
21. Force Majeure
PagoPay shall not be liable for delays or failure to perform obligations due to events beyond its control, including natural disasters, government actions, banking disruptions, blockchain network outages, or telecommunications failures.
22. Modifications to Terms
PagoPay may update these Terms from time to time.
Updated versions will be published on the Platform with a revised effective date.
Continued use of the Platform constitutes acceptance of the revised Terms.
23. Privacy Policy
The collection and use of personal information is governed by the PagoPay Privacy Policy, which forms part of these Terms.
24. Entire Agreement
These Terms of Service, together with the Privacy Policy and any policies referenced herein, constitute the entire agreement between the user and PagoPay regarding use of the Platform.
If any provision of these Terms is determined to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.
25. Governing Law
These Terms are governed by the laws of the Province of Québec and the applicable laws of Canada.
26. Contact Information
For questions regarding these Terms or PagoPay services:
support@mypagopay.com
compliance@mypagopay.com