Legal Notes

For clients who started using the services after 2022-08-08, valid from 2022-08-08
For clients who started using the services before 2022-08-08, valid from 2022-10-08

1. General Information

These T&C govern the relations between the Company and the Client. They constitute a legally binding agreement which enters into force on the date the Client accepts these T&C and remain in force for an indefinite period of time unless terminated following the provisions set forth herein.

The Client accepts that the necessary pre-contractual and contractual documents shall be communicated via electronic communication channels. The Company stores these documents on the System and they are accessible to the Client as part of their remote Account access.

2. Key Definitions

• Account – an electronic record inside the System which allows to identify the Client, execute transactions and contains information on the Transactions performed.
• E-Money – electronically stored monetary value as represented by a claim on the Company which is issued on receipt of funds for the purpose of making Transactions.
• Services – opening and operating Accounts, execution of payment transactions, issuing of Payment Instruments, issuance and redemption of E-Money, and related services.

3. Services Provided

The Company provides the following services:

• Opening and operating of Account(s)
• Execution of payment transactions
• Issuing of Payment Instruments and acquiring of payment transactions
• Issuance and redemption of E-Money
• Additional services such as currency conversion

4. Fees and Charges

The Company provides Services for the fees agreed by the Parties and published in Fees and Charges provided on the Company's Website or individually to the Client. The Client gives consent to deduct respective amounts of Fees and Charges due at any time without notice from the Balance of the Account.

5. Security

The Client is solely responsible for safely keeping Security Credentials. If at any time the Client becomes aware or suspects that Security Credentials have been lost, stolen, misappropriated, used without authorisation or otherwise compromised, the Client shall notify the Company without undue delay.

6. Termination

The Client may terminate these T&C by a 30 days prior written notice (if the Client is a Consumer) or by a 6-months prior written notice (if the Client is not a Consumer). The Company may terminate with 60 days notice (Consumer) or 30 days notice (non-Consumer).

7. Complaints and Disputes

Any complaint shall be presented in English or Lithuanian. The Company investigates complaints no later than within 15 Business Days from receipt. Where the Client is a consumer and not satisfied with the Company's answer, they have the right to submit a request to the Bank of Lithuania.

8. Governing Law

These T&C shall be governed by the laws of the Republic of Lithuania without recourse to the conflict of laws rules regardless of the venue or jurisdiction in which a dispute arises.

Please download the full document for complete terms and conditions.

For clients who started using the services after 2025-04-01, valid from 2025-04-01
For clients who started using the services before 2025-04-01, valid from 2025-06-01

1. General Information

These T&C govern the relations between the Company and the Client. They constitute a legally binding agreement which enters into force on the date the Client accepts these T&C and remain in force for an indefinite period of time unless terminated following the provisions set forth herein.

The Client accepts that the necessary pre-contractual and contractual documents shall be communicated via electronic communication channels. The Company stores these documents on the System and they are accessible to the Client as part of their remote Account access.

In the case that the Client that is a Consumer accepts these T&C remotely, they will benefit from a cooling-off period of 14 calendar days to cancel without penalty and without needing to give any reason.

2. Key Definitions

• Account – an electronic record inside the System that allows to identify the Client, execute transactions and contains information on the Transactions performed.
• E-Money – electronically stored monetary value as represented by a claim on the Company which is issued on receipt of funds for the purpose of making Transactions.
• Services – opening and operating Accounts, execution of payment transactions, issuing of Payment Instruments, issuance and redemption of E-Money, and related services.
• Sanctioned Person – people or entities subject to Red Notice by Interpol, Most Wanted by Europol, or international financial sanctions by UN Security Council or EU.

3. Services Provided

The Company provides the following services:

• Opening and operating of Account(s)
• Execution of payment transactions
• Issuing of Payment Instruments and acquiring of payment transactions
• Issuance and redemption of E-Money
• Additional services such as currency conversion

4. Onboarding and KYC

The Company shall accept the Client and provide Services only to those Clients whose identity has been duly established. The Company may request information about the Client's country of residence for tax purposes, taxpayer identification number, source of funds, and business activity.

The Client shall periodically (at least once a year) update their information and provide supporting documents related to KYC processes in order to comply with Applicable Law.

5. Fees and Charges

The Company provides Services for the fees agreed by the Parties and published in Fees and Charges on the Company's Website or individually to the Client. The Client gives consent to deduct respective amounts of Fees and Charges from the Balance of the Account at any time without notice.

6. Security

The Client is solely responsible for safely keeping Security Credentials. If at any time the Client becomes aware or suspects that Security Credentials have been lost, stolen, misappropriated, used without authorisation or otherwise compromised, the Client shall notify the Company without undue delay.

7. Restrictions on Services

The Company may block the Account, Payment Instruments or restrict Services if: the Client engages in prohibited activities, there are security concerns, Security Credentials are incorrectly used multiple times, the Account is seized, or required by Applicable Law.

8. Termination

The Client may terminate these T&C by a 30 days prior written notice (if the Client is a Consumer) or by a 6-months prior written notice (if the Client is not a Consumer). The Company may terminate with 60 days notice (Consumer) or 30 days notice (non-Consumer).

9. Complaints and Disputes

Any complaint shall be presented in English or Lithuanian. The Company investigates complaints no later than within 15 Business Days from receipt. Where the Client is a consumer and not satisfied with the Company's answer, they have the right to submit a request to the Bank of Lithuania.

10. Governing Law

These T&C shall be governed by the laws of the Republic of Lithuania without recourse to the conflict of laws rules regardless of the venue or jurisdiction in which a dispute arises.

Please download the full document for complete terms and conditions.

1. Introduction

BEBAWA (company code 305483424), having its registered office at Mėsinių str. 5, Vilnius, Republic of Lithuania, provides services based on the electronic money license No. 70 issued by the Bank of Lithuania on 09 June 2020.

BEBAWA cares about the privacy of your personal data protection and therefore seeks to ensure a fair and transparent processing of personal data. This Privacy Policy determines the key aspects relating to terms under which the Company collects, uses, discloses and protects your personal data.

2. Data Controller

BEBAWA acts as a data controller in respect of your personal data. We adhere to the General Data Protection Regulation (EU) 2016/679 (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other applicable legal acts.

3. Personal Data We Collect

The personal data we collect includes:

• Basic personal data: first, last, middle names
• Identification information: personal identity number, date of birth, nationality, copy of ID document
• Contact details: phone number, email, correspondence address, residence address
• Transaction data: IBAN number, beneficiary details, date, time, amount, currency, purpose of payment
• Activity details: device information, IP address, login data, browsing information

4. Purposes of Processing

We process your personal data for:

• Conclusion and performance of contracts
• Client identification and verification
• Compliance with anti-money laundering (AML) obligations
• Ensuring compliance with international sanctions
• Handling complaints and enquiries
• Direct marketing (with your consent)

5. Data Retention

We keep your personal data for as long as needed for the purposes for which it was collected. Personal data collected for AML compliance is stored for up to 8 years. Customer support inquiries are kept for 1 year after resolution.

6. Your Rights

You have the following rights regarding your personal data:

• Right to be informed
• Right to access your data
• Right to rectification
• Right to data portability
• Right to be forgotten
• Right to restrict processing
• Right to object to processing
• Right to file a complaint with a supervisory authority
• Right to withdraw consent

7. Contact Information

For questions regarding the protection of your personal data, please contact our Data Protection Officer at dataprotection@bebawa.com or send a letter to Bebawa UAB, Mėsinių str. 5, Vilnius, Lithuania.

Please download the full document for the complete Privacy Policy.

1. Introduction

UAB "BEBAWA" is an electronic money institution licensed by the Bank of Lithuania, incorporated and existing in the Republic of Lithuania, company code 305483424, having its registered office at Mėsinių st. 5, LT-01133 Vilnius.

This Cookie Policy explains what cookies are and what type of cookies we use when you visit our website www.bebawa.com, the information we collect using cookies and how that information is used.

2. What Are Cookies?

Cookies and other similar technologies are small text files generated by a website and saved by your browser when you visit various websites on the internet. We may also use other similar technologies such as web beacons, tags, scripts, pixels, and local storage.

With the help of cookies, we may understand how you are interacting with our website, determine your preferences and improve your online experience.

3. Types of Cookies We Use

We use 4 varieties of cookies on our website:

• Essential Cookies – Ensure the basic functions of the website (security, identity verification, network management). These cannot be disabled. Legal basis: legitimate interest (Article 6(1)(f) GDPR).
• Marketing Cookies – Track the effectiveness of advertisements and display more relevant ads based on the user's interests. Legal basis: user's consent (Article 6(1)(a) GDPR).
• Functional Cookies – Remember user preferences to provide a personalized experience. Legal basis: user's consent (Article 6(1)(a) GDPR).
• Analytics Cookies – Help to understand how visitors interact with the website, identify errors, and improve analytical data. Legal basis: user's consent (Article 6(1)(a) GDPR).

4. How to Control and Delete Cookies

You can change your cookie preferences at any time and decide which cookies you consent to. You can also withdraw your consent to the use of cookies (except for strictly necessary cookies) at any time by updating your preferences in the website's cookie management section and by deleting cookies in your browser settings.

If you delete cookies, all settings controlled by these cookies will be deleted and will need to be re-created when you later visit our website. The website may not function properly without strictly necessary cookies.

5. Your Rights

As a data subject, you have the following rights:

• To be informed about the processing of your personal data
• To access your personal data being processed
• To request the rectification of inaccurate personal data
• To request the erasure of personal data ("right to be forgotten")
• To object to the processing of your personal data
• To restrict the processing of your personal data

6. Contact

You may contact us by sending a letter to our office at Mėsinių st. 5, LT-01133 Vilnius, Lithuania. Alternatively, you can contact our Data Protection Officer (DPO) by sending an email to dataprotection@bebawa.com.

If you are a customer or a potential customer of e-money and payment services provided by Bebawa UAB ("we" or "us"), this Complaints Policy applies to you.

1. How to make a complaint?

If you are not satisfied with our services, you may contact our customer service and we will do our best to solve your issue as soon as possible.

You can also file a formal complaint to us, free of charge:

• by submitting it directly to our employees;
• by sending it to Bebawa's registered office address at Mėsinių St. 5, Vilnius, Lithuania, by regular or registered mail;
• via our website www.bebawa.com; or
• by email at info@bebawa.com.

Your complaint should be filed not later than within 3 months of learning about potential violation of your rights or legitimate interests. Please file your complaint in English or Lithuanian language and specify:

• your name, surname;
• your contact details: residence address, e-mail and phone number;
• description of dispute matter;
• date of violation of your rights;
• your claim to us;
• any other information related to your complaint.

Please attach supporting documents to your complaint, if any, which could help us solve your issue more efficiently. If you file a complaint through your representative, representative's power of attorney or other document stating their right to act on your behalf should be submitted together with the complaint. Please note that we generally do not accept anonymous complaints.

Unless you specify otherwise, by providing your email address in your complaint to us, you agree that we may provide information and further communication to you by this email.

2. When will you get our reply?

Within 3 business days, we will send you the confirmation that your complaint is received, together with the reference number of your complaint. We will keep you informed about the progress of handling your complaint.

We will aim to provide you with our reply as soon as possible, but not later than within 15 business days from the date of receipt of your complaint.

In exceptional cases, when due to reasons beyond our control the reply cannot be submitted to you within 15 business days, we will send a preliminary reply to you indicating the reasons for delay in replying and the term by which you will receive our final reply. In any case, the maximum term for the submission of a reply will not exceed 35 business days from receipt of the complaint.

We will send you our reply to the email address specified in your complaint, in Lithuanian or English language. If you do not provide us with your email address or specifically request so, we will send you our reply to your residence address specified in your complaint.

3. What if our reply is not satisfactory?

If you use our services for personal, family or household purposes, you will have the right as a consumer to refer your complaint to the Bank of Lithuania, free of charge. The competence of the Bank of Lithuania is to settle disputes between financial services providers on one side and consumers on the other side.

Your complaint should be submitted to the Bank of Lithuania in Lithuanian or English language within 1-year term of your initial application to us. If you miss the 1-year term to address the complaint to the Bank of Lithuania, you will lose the right to apply to the Bank of Lithuania about the same dispute, i.e. any matter having the same parties and factual background, irrespective of the fact that you might have repeatedly addressed us.

You can submit your complaint in three ways:

• through the electronic financial services dispute resolution system "Electronic Government Gateway";
• by filling in the application form and sending it to the Legal and Licensing Department of the Bank of Lithuania, Totorių St. 4, 01121 Vilnius, Lithuania, or via e-mail prieziura@lb.lt;
• by submitting a free-form application and sending it to the Legal and Licensing Department of the Bank of Lithuania, Totorių St. 4, 01121 Vilnius, Lithuania or via e-mail prieziura@lb.lt.

Further information can be found on the website of the Bank of Lithuania: https://www.lb.lt/lt/daugiau-apie-gincus-su-finansiniu-paslaugu-teikeju.

Consumers using our services in other EU/EEA Member States may also submit complaints via FIN-NET network.

Please note that even if you are not a consumer and the out-of-court dispute settlement procedure specified above does not apply to you, you have a right to reach out with your claim to the court or, if you believe to have well-founded suspicions that we have breached certain provisions of legal acts regulating the financial market, you can submit a notification to the Bank of Lithuania, in Lithuanian or English language, by filling in the application form as specified in the website of the Bank of Lithuania and sending it in writing or by electronic means at: Totorių St. 4, 01121 Vilnius, Lithuania or via e-mail prieziura@lb.lt.

Best practices against fraud

In recent years a phenomenon of fraud has emerged across the world. While we follow the most secure techniques for protecting our customers, criminals are always seeking new tricks for stealing money or information. Please be careful and follow these guidelines.

Internet Bank Fraud

Fraudsters are known to call, saying that there is an attempt to commit fraud on your account or saying that a computer virus has been found on your device. Then the criminals request customers to move their money to a "safe account". Of course, the "safe account" is controlled by the criminals.

If anyone requests you to transfer money to another account or to provide your credentials, please say NO. No one at Bebawa will ever ask you to do that.

Invoicing fraud

We have also received reports about fraudsters pretending to be from suppliers to an organization and tricking them into changing bank account details for standing orders or scheduled payments.

Before making any changes to standing orders, please verify the request with your supplier. If you receive a suspicious call, contact the supplier directly using a contact number that you obtained independently. Do NOT use the number given on the suspicious email or letter.

Fake Senior Management

Fraudsters may impersonate senior managers, CEO, or other executives of an organization, or even external persons such as lawyers or accountants. Usually, they send an email or call with urgent requests for money transfers or sensitive financial information. Always verify requests through official company channels before transferring funds. Be wary of unsolicited requests, especially those creating a sense of urgency.

Phishing and Spear Phishing

Phishing is a type of fraud where criminals try to gain access to sensitive information, such as bank account details, credit card numbers, or passwords. Most phishing emails appear to come from well-known organizations and ask for personal or financial information.

Be careful when you receive an email that asks for sensitive information. Before providing the information requested, try to verify the email is genuine by calling the sender using a contact number that you obtained independently. Check the sender's email address. If suspicious, the email address may differ from the genuine email address.

E-mail Attachments

Criminals are known to spread malware by sending emails with attachments. These attachments might be disguised as PDF, Word, or other common file types containing hidden malicious code.

• DO NOT open attachments from unknown senders
• Verify the identity of the sender for unexpected attachments
• Note that e-mails can be "spoofed" to hide the sender's identity
• Report any suspicious emails to your information security unit

General Tips

• Never share your passwords or security credentials with anyone
• Use strong, unique passwords for different accounts
• Enable two-factor authentication where available
• Keep your devices and software up to date
• Regularly monitor your account statements for suspicious activity
• Contact Bebawa immediately if you suspect fraudulent activity on your account