Financial Services Terms
Governing the HotelsMint Digital Wallet, e-money account, virtual cards, and payment services delivered via our FCA-authorised partner.
Introduction & Regulatory Status
1.1 Scope of Financial Services Terms
These Financial Services Terms govern all regulated financial features offered through the HotelsMint platform, including: the HotelsMint digital wallet and e-money account; virtual prepaid card issuance and usage; peer-to-peer (P2P) fund transfers; external bank account withdrawals; merchant checkout payments; and currency conversion services. These terms supplement the HotelsMint Terms & Conditions and Privacy Policy.
1.2 Regulatory Structure — Programme Manager Model
REGULATORY DISCLOSURE — PROGRAMME MANAGER STRUCTURE: Bankitt LTD (trading as "HotelsMint") operates as a Programme Manager. Financial services products — including the digital wallet, virtual prepaid cards, fund transfers, and payment processing — are delivered through an FCA-authorised Financial Services Partner holding the relevant regulatory permissions. THE E-MONEY IN YOUR WALLET IS ISSUED BY OUR FCA-AUTHORISED FINANCIAL SERVICES PARTNER, NOT BY BANKITT LTD DIRECTLY. Bankitt LTD designs, brands, distributes, and operates the customer-facing software experience. Any change in our Financial Services Partner will be communicated with at least 30 days' prior written notice pursuant to Payment Services Regulations 2017 (Regulation 46).
1.3 FCA Consumer Duty Compliance (PS22/9)
In compliance with the Financial Conduct Authority (FCA) Consumer Duty guidelines (PS22/9), we commit to acting in good faith, avoiding foreseeable harm, and supporting customer financial objectives. We provide transparent, clear, and non-misleading information regarding all wallet services and fees.
The HotelsMint Wallet & Safeguarding
2.1 Legal Nature of the Wallet
CRITICAL REGULATORY DISTINCTIONS — PLEASE READ CAREFULLY: 1. NOT A BANK DEPOSIT: Wallet funds represent electronic money (e-money) governed by the Electronic Money Regulations 2011 (EMR 2011), not traditional bank deposits. 2. FSCS PROTECTION EXCLUSION: Your Wallet funds are NOT covered by the Financial Services Compensation Scheme (FSCS). FSCS deposit protection applies strictly to regulated bank accounts, not e-money wallets. 3. STATUTORY SAFEGUARDING: Your funds are SAFEGUARDED under EMR 2011 and FCA Safeguarding Rules (PS25/12) in segregated accounts held by our Financial Services Partner at an FCA-authorised credit institution. Safeguarded funds cannot be accessed by creditors in insolvency. 4. NO INTEREST: The Wallet does not yield interest or investment returns. 5. NO CREDIT: The Wallet does not provide credit, overdrafts, or lending facilities.
2.2 Safeguarding Infrastructure
In compliance with EMR 2011 and FCA PS25/12 rules, customer funds are:
- Held in segregated safeguarding accounts at FCA-authorised credit institutions, separate from corporate operational funds.
- Reconciled daily through automated internal and external audits.
- Reported monthly to the FCA via formal Safeguarding Returns.
- Subject to annual independent safeguarding audits by certified external auditors.
- Legally protected to ensure priority distribution to e-money holders in the event of insolvency.
2.3 Eligible Jurisdictions
The HotelsMint Wallet is available to verified residents of eligible countries listed at www.hotelsmint.com/wallet-countries. It is your responsibility to ensure compliance with local financial regulations in your place of residence.
Eligibility & Identity Verification (KYC)
3.1 Baseline Eligibility
To open and maintain a HotelsMint Wallet account, you must:
- Be aged 18 or over.
- Reside in an eligible supported jurisdiction.
- Possess legal capacity to enter into binding financial contracts.
- Successfully pass Know Your Customer (KYC) identity verification checks under Money Laundering Regulations 2017 (MLR 2017).
- Not be subject to financial sanctions enforced by OFSI, EU, US OFAC, or UN bodies.
3.2 Verification Tiers & Account Limits
Wallet capabilities operate under progressive verification tiers:
- Tier 1 (Standard Verification): Requires legal name, date of birth, residential address, and email validation. Subject to standard annual transaction caps.
- Tier 2 (Full Verification): Requires government photo ID upload, proof of address (< 3 months old), and biometric liveness check. Unlocks higher transaction limits.
- Tier 3 (Enhanced Due Diligence): Applied to high-volume accounts, requiring source of wealth declarations and supporting bank statements.
Virtual Cards & Payment Operations
4.1 Virtual Card Issuance
Virtual prepaid payment cards are issued in partnership with our FCA-authorised partner under card scheme rules (Visa/Mastercard). Virtual cards are stored securely in-app. Card CVV security codes are displayed temporarily during checkout authorization and are never permanently saved.
4.2 Payment Execution & Currency Exchange
Transactions are executed instantly upon authorization. Where transactions involve currency exchange, exchange rates and applicable FX conversion markups are displayed prior to payment confirmation.
AML, Fraud Monitoring & Suspensions
5.1 Continuous Anti-Money Laundering Monitoring
Wallet accounts undergo continuous automated transaction monitoring under Proceeds of Crime Act 2002 (POCA) and Terrorism Act 2000. Suspicious activity is reported directly to the National Crime Agency (NCA).
5.2 Statutory Non-Disclosure Notice (Tipping Off)
STATUTORY LEGAL NOTICE: Pursuant to Section 333A of POCA 2002, disclosing that a Suspicious Activity Report (SAR) has been filed or that an investigation is underway constitutes a criminal offence. If an account is suspended or a transaction blocked without detailed explanation, HotelsMint is bound by statutory non-disclosure duties.
Complaints & Dispute Resolution
6.1 Financial Complaints Procedure
Financial complaints should be directed to info@hotelsmint.com. If your complaint is not resolved within 15 business days (or up to 35 business days in exceptional circumstances), you may refer the matter to the Financial Ombudsman Service (FOS):
- Website: www.financial-ombudsman.org.uk
- Free Phone: 0800 023 4567 or 0300 123 9123
- Address: Exchange Tower, London, E14 9SR
Bankitt LTD (trading as HotelsMint) acts as a Programme Manager. E-money accounts, virtual cards, and payment services are provided by our FCA-authorised Financial Services Partner. Funds are safeguarded under EMR 2011 and FCA PS25/12.