TERMS AND CONDITIONS

Terms & Conditions – Venner Platform

Version: 1.1

Governing Law: Cyprus

Effective Date: 03.02.2026

These Terms and Conditions (“Agreement”) set out the terms on which ARTICUNO HOLDINGS LIMITED, Amathountos 22, OSM House, Agios Tychonas, 4532 Limassol, Cyprus (“Articuno”, “we”, “us”, “our”), provides access to the mobile application (the “App”) to you (“you”, “User”).

Articuno is a technical service provider of the technology platform (“Venner”), a Software as a Service, that enables your Maritime Employer to deliver salary and other Wage Payments to you electronically and allows you to access your e-money Wallet through the mobile application.

Articuno does not process, execute, or transmit Wage Payments. All payroll disbursements and credits to your Wallet are carried out solely by your Maritime Employer and the Issuer (a licensed Electronic Money Institution) or its authorised payment processors. Articuno’s role is limited to providing the user interface and technical capabilities through which you access the Wallet and related services offered by third-party regulated providers.

This Agreement governs your use of the mobile application (the “App”), which provides a technology interface only. Articuno does not provide regulated payment or e-money services. All such regulated services are provided exclusively by the Issuer and governed by the Issuer’s separate terms and conditions.

1. Overview

  • 1.1 This Agreement applies to your use of the App as a technology service.

  • 1.2 Articuno provides the digital platform and user interface only.

  • 1.3 Regulated Payment Services, including e-money issuance, operation of the wallet, card services, account freezing/unfreezing, transfers, and safeguarding of funds, are not provided by Articuno.

  • 1.4 These regulated services are provided exclusively by the licensed Electronic Money Institution (the “Issuer”), whose terms you must accept separately and can be found here: [link]

1.5 Articuno acts solely as the technology provider and does not hold, safeguard, or process customer funds, nor does it make any regulated decisions (including KYC/AML, transaction monitoring, or payment execution).

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2. Definitions

For the purposes of this Agreement:

  • App– The technology interface and software application provided by Articuno, enabling Users to access services offered by third-party regulated providers. Articuno does not provide Regulated Payment Services or operate the Wallet.

  • Wallet – The electronic money account issued, and operated by the Issuer (a licensed Electronic Money Institution). The Wallet is accessible through the App but is not provided or operated by Articuno.

  • Regulated Payment Services – Regulated services provided exclusively by the Issuer, according to its terms and conditions, that may include issuance of e-money, redemption, execution of payment transactions, card services, and any other regulated activities. Articuno does not provide Regulated Payment Services.

  • Issuer –. Bnext Electronic Issuer, E.D.E., S.L. is an electronic money institution that operates under the supervision of the Bank of Spain in accordance with the provisions of Law 21/2011, of 26 July, on electronic money (\”Electronic Money Law\”), with registered office at Calle López de Hoyos 135, 1ºC, 28002, Madrid, NIF B88463534 and registered in the Bank of Spain register under number 6717. The Issuer is responsible for issuing e-money, safeguarding user funds, conducting KYC/AML checks, executing payments, freezing/unfreezing accounts, and performing all regulated functions.

  • Maritime Employer – The entity authorised to credit salary or other payments to the User’s Wallet, under instructions and rules defined by the Issuer.

  • Supported Jurisdictions – Countries or territories permitted for Wallet usage as defined by the Issuer and displayed in the App.

  • Compliance Obligations – Regulatory requirements applicable to the Issuer and its authorised processors, including AML, CTF, sanctions screening, fraud prevention, and KYC/EDD obligations. Articuno is not responsible for Compliance Obligations as far as payments are concerned.

  • Business Day – Any day banks are open for business in Cyprus, unless the Issuer specifies otherwise.

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3. Eligibility

3.1 To access the App, you must:

  1. be at least 18 years old and have legal capacity

  2. agree to and comply with this Terms and Conditions

  3. be linked to and/or authorised by an approved Maritime Employer (where applicable)

  4. use the Wallet only in accordance with the Issuer’s terms and conditions

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4. Data Protection

For the purpose of these terms and conditions, the Issuer acts as Controller of Personal Data processed in connection with the Wallet and Regulated Payment Services. In particular, the Issuer processes your personal data to create and manage your App account, operate core App features such as authentication, device trust, notifications, and customer support, and to enable and display payment, card, and remittance data received from the regulated payment service provider. Your data is also used to ensure security, fraud detection, and misuse prevention, to communicate updates, service messages, and mandatory notices, and to improve the app through troubleshooting and analytics (using aggregated or anonymized data). In addition, your data is processed to provide regulated payment services through the Issuer and to comply with legal and regulatory obligations, including anti money laundering, counter terrorist financing, sanctions screening, and financial reporting, according to the Issuer’s Privacy Policy.

Articuno Holdings Limited (“Articuno”) provides the App as a technical interface and acts solely as Processor on behalf of the Issuer, does not make regulated decisions or use your data for its own purposes, and shall process Personal Data only in accordance with Issuer’s documented instructions, this Agreement, and Applicable Data Protection Law (including Regulation (EU) 2016/679 – “GDPR”).

The Issuer will process your personal data for purposes related to the registration and use of the App and the Wallet, in connection with the provision of Regulated Payment Services to the You. The legal basis is the contractual relationship with You, as well as legitimate interests to ensure security, fraud prevention, and service improvement, and and the personal data processed are:

  • Identification data: name, passport, email, mobile number, user ID.

  • Device data: device identifier, IP address, security tokens.

  • Authentication data: login credentials (hashed), trusted device status, session tokens.

  • Financial data: transaction history, balances, card details, remittances. These originate from the regulated payment provider.

  • Communication data: support queries, documents uploaded, notifications.

This information will only be kept for as long as the intended purpose lasts, which means for as long as You remain a user of the App. Once this purpose has been fulfilled, the data will be kept, duly blocked, only for as long as claims or liabilities may arise in relation to it and until the limitation periods for such claims or liabilities have expired, after which it will be completely deleted.

Your data may be shared with authorized service providers with different purposes, such as enabling payment services, with KYC/AML verification partners, technology infrastructure vendors such as cloud hosting, analytics, and messaging systems strictly for App operation, other group companies and with professional services such as auditors, legal advisors or authorities when legally required, under the corresponding data protection agreements that ensure compliance and confidentiality. In case transfers outside the EEA, appropriate safeguards such as Standard Contractual Clauses are applied.

You may exercise your data protection rights (access, rectification, erasure, objection, restriction of processing, and portability, as well as not to be subject to automated decisions, where applicable) through the email address [email protected], and contact the Issuer’s Data Protection Officer at [email protected]. You may also file a complaint to the relevant Data Protection Control Authority.

Your information will be processed and stored with due confidentiality, applying the security measures established in the applicable regulations to prevent its alteration, loss, unauthorized processing, or access, in accordance with the state of technology and the nature of the data. You may find further information on how the Issuer processes your personal data in the Issuer’s Privacy Policy that can be found here: [link]

5. Use of the App

  • 5.1 You are granted a personal, non-exclusive, non-transferable right to use the Venner Platform for lawful and authorised purposes only.

  • 5.2 You must keep your security credentials (passwords, PINs, biometrics) confidential at all times.

  • 5.3 You must notify us immediately if you suspect unauthorised access or security breach.

  • 5.4 All intellectual property in the Venner Platform remains owned by Articuno or our licensors.

Use of the Wallet and Regulated Payment Services is governed exclusively by the Issuer’s terms and not by this Agreement.

5.5 You must provide accurate, complete and up to date information while using the App.

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6. Salary Disbursement Consent

By accepting these Terms and Conditions, you expressly confirm and agree that:

  • 6.1 You consent to select Venner as your salary payment method.

  • 6.2 If you already have an assigned salary account you consent to change your existing salary or wage payment method to payment via Venner, including any designated payment or banking partners such as Bnext.

  • 6.3 You agree to register, maintain, and use an active account with Venner and Issuer, where required, for the purpose of receiving your salary payments through this method.

  • 6.4 You authorise your Maritime Employer to remit your salary payments through Venner and Bnext in accordance with the Maritime Employer’s payroll procedures and applicable laws.

  • 6.5 You acknowledge that this selection or change is voluntary, is made in accordance with your rights as a seafarer, and does not amend, replace, or override your employment contract, collective bargaining agreement, or any mandatory wage protections.

  • 6.6 You understand and agree that you may withdraw this consent at any time by notifying your Maritime Employer (including, where applicable, OSM Thome) in accordance with the employer’s payroll change process, and that such withdrawal will apply prospectively only.

  • 6.7 You acknowledge that Venner and Bnext do not control, initiate, or guarantee salary payments, and that responsibility for payroll execution, timing, amounts, deductions, and statutory obligations remains solely with your Maritime Employer.

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7. Fees and Limits

  • 7.1 Fees and limits applicable to the Wallet and Regulated Payment Services are defined by the Issuer.

  • 7.2 Fees may change in accordance with the Issuer’s terms.

  • 7.3 Limits depend on your KYC/EDD status and the Issuer’s risk rules.

  • 7.4 Articuno does not charge fees for Wallet or Regulated Payment Services.

Any fees relating to e-money issuance, transfers, withdrawals, card use, foreign exchange, or other regulated Payment Services are set, applied, and collected solely by the Issuer or its authorized processors.

7.5 Articuno may receive compensation from the Issuer or other technical service providers in connection with the operation of the Venner Platform or for enabling Wallet and Regulated Payment Services through the App. Such compensation is commercial in nature and does not affect or increase the fees charged to you.

7.6 Articuno may charge fees for optional, non-regulated features made available through the Venner Platform, such as premium app features, additional support services, or value-added functionality. Where applicable, any such fees will be clearly disclosed to you in advance before you elect to activate or use such optional features.

7.6 If Articuno introduces paid optional features in the future, you will be shown:

  1. the fee amount;

  2. the billing method (for example, deduction from your linked payment method or in-App purchase); and

  3. the date the fee becomes payable.

You will not be charged unless you actively confirm your acceptance of any fees.

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8. Customer Support & Complaints

  • 8.1 You can contact Venner Support via the App or by email at [email protected]. Articuno operates this first-line support channel and will receive queries and complaints relating to the App.

  • 8.2 Articuno will handle and resolve queries that relate to the App and technology layer (for example, access, login, technical errors, user interface issues).

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9. Suspension and Termination

  • 9.1 Articuno may suspend access to the App where required for security, misuse, or breach of this Agreement.

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10. Liability

  • 10.1 Nothing limits liability where unlawful to restrict.

  • 10.2 Articuno is not responsible for:

  • Maritime Employer payroll errors

  • decisions or actions taken by the Issuer relating to Wallet or Regulated Payment Services

  • third-party outages affecting Issuer services

  • indirect or consequential losses

  • losses caused by your negligence or breach

10.3 You indemnify Articuno for misuse of the App. Liability relating to Wallet or Regulated Payment Services is governed solely by the Issuer’s terms.

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11. Right of Set-Off

11.1 Articuno has no access to Wallet balances and cannot deduct or apply set-off.

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12. Amendments

  • 12.1 Articuno may update this Agreement (relating to the App) with a 60 days notice, unless changes are required sooner for legal or security reasons.

  • 12.2 Changes to Venner or Regulated Payment Services terms are made by the Issuer.

  • 12.3 Continued use of the App constitutes acceptance of updated terms.

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13. Dispute Resolution & Governing Law

  • 13.1 In relation to this Agreement (the App and technology platform), the parties shall first attempt to resolve disputes amicably through Venner Support.

  • 13.2 This Agreement is governed by the laws of Cyprus, and the courts of Cyprus shall have exclusive jurisdiction in relation to any dispute arising from use of the App or the Venner Platform.

  • 13.3 Disputes, complaints or claims relating to the Wallet or Regulated Payment Services (including transactions, card use, refunds, freezes, AML/KYC decisions, or safeguarding) are governed solely by the Issuer’s terms and conditions and shall be handled and resolved by the Issuer under its governing law and regulatory complaints framework.

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14. Contact Details

ARTICUNO HOLDINGS LIMITED

Amathountos, 22 OSM House

Agios Tychonas, 4532 Limassol, Cyprus

Email: [email protected]