Effective from: September 2026
These Terms of Service ("Terms") govern your access to and use of the https://carteza.com/ website (the "Site") and all related services, platforms, APIs, and technical orchestration infrastructure provided by Cardway Technologies OÜ, a private limited company incorporated in Estonia with registry code 17593866 , registered address Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152 , Estonia ("Cardway Tech", "we", "our", or "us").
"Agreement" - these Terms of Service together with any applicable Order Form, Service Schedule, or addendum incorporated herein by reference.
"API" - the application programming interface provided by Cardway Tech enabling programmatic access to the Platform.
"Confidential Information" - any non-public information disclosed by one party to the other in connection with the Services.
"Licensed PSP" - a third-party payment service provider duly licensed under applicable law (including PSD2 or equivalent) that processes payment transactions on behalf of Users via integration with the Platform.
"Orchestration Layer" - Cardway Tech's routing and integration infrastructure that connects Users to one or more Licensed PSPs, enabling intelligent transaction routing, fallback logic, and payment method aggregation, without Cardway Tech itself processing, settling, or holding funds.
"Payment Facilitator" - a User that onboards Sub-Merchants to the Platform pursuant to a separate Payment Facilitator Agreement with Cardway Tech.
"Platform" - the proprietary software, APIs, routing engine, and related infrastructure operated by Cardway Tech and made available to Users under these Terms.
"Services" - the technical orchestration, gateway integration, and related support services described in Section 1.
"Sub-Merchant" - a third-party merchant onboarded by a Payment Facilitator via the Platform.
"User" - a legal entity or registered self-employed professional that has accepted these Terms and uses the Services.
"Working Day" - any day other than a Saturday, Sunday, or public holiday in Estonia.
Cardway Technologies OÜ is not a licensed payment institution or electronic money institution and does not provide regulated payment services. All payment processing is performed by duly licensed third-party providers. Cardway Tech acts solely as a technical facilitator and assumes no responsibility for the movement or custody of funds.
The primary business activity is the development, provision, and maintenance of IT solutions for payment gateway integration, transaction routing, and related technical support.
These Terms have been drafted in accordance with Estonian law, EU regulations, and best practices for IT service providers operating as technical facilitators in the payment sector.
Users located outside the European Economic Area acknowledge that Cardway Tech is incorporated and regulated under Estonian and EU law. Users operating in jurisdictions outside the EEA are solely responsible for ensuring compliance with applicable local laws, licensing requirements, and regulatory restrictions. Cardway Tech makes no representation that the Services are appropriate or available for use in any specific jurisdiction outside the EEA. In particular, Users operating in the United Kingdom, Switzerland, Australia, or any APAC jurisdiction shall additionally comply with applicable local payment services regulations and sanctions regimes applicable in those jurisdictions.
These Terms apply exclusively to Users who meet the eligibility criteria set out in Section 2. Visitors who do not qualify may browse the Site but may not register or use the Services. By accessing the Services, the User confirms satisfaction of the eligibility requirements and that the individual accepting these Terms has full authority to legally bind the relevant entity.
Only legal entities or registered self-employed professionals with full legal capacity may use the services.
Users must not be located in, or operate from, any jurisdiction subject to restrictive measures or sanctions imposed by the European Union, the United Nations Security Council, the U.S. Office of Foreign Assets Control (OFAC), the UK Office of Financial Sanctions Implementation (OFSI), the Swiss State Secretariat for Economic Affairs (SECO), or any other applicable national or international sanctions regime (collectively, "Applicable Sanctions"). Cardway Tech maintains an internal restricted jurisdiction list, updated from time to time and available upon written request. Users are responsible for monitoring their ongoing compliance with Applicable Sanctions. Cardway Tech reserves the right to immediately suspend Services to any User where a sanctions concern arises, without prior notice. Individuals acting on behalf of a User represent and warrant that they have the authority to bind the entity to these Terms.
Cardway Tech reserves the right to refuse, suspend, or terminate access at its sole discretion, including for compliance, risk, or regulatory reasons.
Prohibited Business Categories. Users may not use the Services in connection with the following activities ("Prohibited Activities"):
(i) unlicensed money transmission, currency exchange, or financial services;
(ii) unregulated cryptocurrency exchanges, DeFi protocols, or unregistered token offerings;
(iii) adult content or sexually explicit material;
(iv) sale of controlled substances, narcotics, or prescription drugs without valid authorisation;
(v) weapons, firearms, ammunition, or military/surveillance equipment;
(vi) pyramid schemes, Ponzi schemes, or fraudulent investment programmes;
(vii) any activity promoting, facilitating, or constituting human trafficking or exploitation;
(viii) unlicensed lending, consumer credit, or investment services;
(ix) any activity requiring a licence under MiFID II or AIFMD that the User does not hold;
(x) any activity illegal under the laws of Estonia, the EU, or the User's jurisdiction of operation.
Cardway Tech may update this list at any time by publishing a revised version on the Site or notifying the User in writing. Continued use of the Services following such notification constitutes acceptance of the revised list.
Payment Facilitator Obligations. Users acting as Payment Facilitators must:
(i) enter into a separate Payment Facilitator Agreement with Cardway Tech prior to onboarding any Sub-Merchants;
(ii) perform and document KYB/KYC due diligence on each Sub-Merchant prior to enabling access to the Platform;
(iii) ensure Sub-Merchants comply with these Terms, the Prohibited Activities list, and all applicable laws;
(iv) take full and exclusive responsibility for all actions, transactions, and compliance obligations of their Sub-Merchants;
(v) immediately notify Cardway Tech of any Sub-Merchant suspected of engaging in Prohibited Activities or showing elevated chargeback or fraud indicators;
(vi) ensure Sub-Merchants do not have direct access to the Platform or API without Cardway Tech's prior written consent.
Cardway Tech and the Licensed PSP shall have no direct relationship with Sub-Merchants and shall bear no liability for Sub-Merchant activities. The Payment Facilitator indemnifies Cardway Tech and the Licensed PSP against any claims arising from Sub-Merchant conduct.
Access to certain services requires registration and the creation of a client account. Users must provide accurate, up-to-date, and complete information and promptly update any changes.
Users are responsible for maintaining the confidentiality and security of their authentication credentials and for all activities conducted under their account.
Users must immediately notify Cardway Tech of any unauthorized access, use, or security breach.
Onboarding and KYB Verification. As part of the registration process and on an ongoing basis, Cardway Tech may require Users to provide the following documentation:
(i) certificate of incorporation and constitutional documents;
(ii) proof of registered address;
(iii) ownership structure and UBO declaration (ultimate beneficial owners holding 25% or more);
(iv) identification documents of directors and UBOs (passport or national ID);
(v) description of business activity, source of funds, and anticipated transaction volumes;
(vi) any other documentation reasonably required by Cardway Tech or its Licensed PSP for compliance purposes.
Cardway Tech reserves the right to refuse, suspend, or terminate a User's access to the Services at its sole discretion. Where suspension or termination is not caused by fraud, sanctions breach, material AML concern, regulatory order, or material breach of these Terms, Cardway Tech shall provide no less than five (5) Working Days prior written notice. In urgent cases involving any of the foregoing, Cardway Tech may act immediately and without prior notice, and shall notify the User as soon as practicable thereafter. The User may submit a written objection to [email protected] within ten (10) Working Days of receiving notice of suspension or termination. Cardway Tech shall provide a written response within fifteen (15) Working Days.
Cardway Tech processes personal and business data in accordance with Regulation (EU) 2016/679 (GDPR), Directive 2002/58/EC (ePrivacy Directive), and applicable Estonian law.
Data is collected and processed for legitimate business purposes, including account management, compliance, fraud prevention, and service improvement.
The Privacy Policy, which forms an integral part of these Terms, details:
Use of cookies and similar tracking technologies is governed exclusively by Cardway Tech's Cookie Policy, available at https://carteza.com/cookie-policy . Cookie consent is obtained separately through the consent management tool on the Site and is not a condition of accepting these Terms. Acceptance of these Terms does not constitute consent to the use of non-essential cookies.
Where Cardway Tech processes personal data on behalf of a User in connection with the Services (including transaction-related personal data of the User's customers or Sub-Merchants), Cardway Tech acts as a data processor within the meaning of Article 28 GDPR. In such cases, a Data Processing Agreement ("DPA") shall be entered into between the parties prior to commencement of such processing.
Users may not use the Site or services for any unlawful, fraudulent, or unauthorized purpose, including but not limited to:
(i) Circumventing or violating applicable laws or regulations;
(ii) Interfering with the operation or security of the platform;
(iii) Reverse engineering, decompiling, or tampering with any component;
(iv) Processing payments for third parties not subject to prior onboarding and due diligence;
(v) Transfer, sublicense, resell, or share access to the Platform, API credentials, or the User's account with any third party without the prior written consent of Cardway Tech, except as expressly permitted under a separate reseller, white-label, or Payment Facilitator agreement executed with Cardway Tech.
For the avoidance of doubt, Section 5(iv) above shall not apply to Sub-Merchants onboarded by a User acting as a Payment Facilitator pursuant to a duly executed Payment Facilitator Agreement with Cardway Tech. Sub-Merchants must be fully onboarded, verified, and approved in compliance with Cardway Tech's onboarding requirements and applicable KYB/AML standards prior to processing any transactions through the Platform.
Cardway Tech may investigate, suspend, or block any activity deemed suspicious or non-compliant.
Fees and pricing applicable to the Services are set forth in individual Service Agreements, Order Forms, or as published on the Site. Cardway Tech reserves the right to amend fees at any time, provided that Cardway Tech shall give the User no less than fourteen (14) days prior written notice of any fee increase. Continued use of the Services after the effective date of such change constitutes the User's acceptance of the revised fees. All fees are exclusive of applicable taxes, levies, and duties unless otherwise stated in the applicable Service Agreement. Users are responsible for timely payment of all charges.
Refunds. Cardway Tech, acting solely as a technical orchestration layer, does not hold, process, or control client funds and is not itself party to the payment transaction between the User's customer and the Licensed PSP. Accordingly, Cardway Tech does not itself issue refunds.
Refund requests relating to payment transactions processed through the Platform must be submitted directly to the Licensed PSP responsible for the transaction, in accordance with that Licensed PSP's terms and conditions. Cardway Tech will use reasonable endeavours to forward documented refund requests to the relevant Licensed PSP within five (5) Working Days of receipt. Processing timelines, eligibility criteria, and final refund decisions are governed solely by the Licensed PSP's policies. Cardway Tech accepts no liability for any delay, refusal, or partial processing of a refund request by a Licensed PSP.
Technical Errors. In the event of a documented technical error solely attributable to Cardway Tech's Orchestration Layer causing an incorrect transaction, Cardway Tech shall promptly notify the relevant Licensed PSP and co-operate fully in resolving the error.
No refunds are provided for fraudulent chargebacks, third-party services, or violations of these Terms or applicable law.
Chargebacks. The User acknowledges that chargeback management, dispute resolution, and all related fund flows are handled exclusively by the Licensed PSP and applicable payment scheme rules, over which Cardway Tech has no control. In the event that the Licensed PSP or Cardway Tech notifies the User of chargeback activity exceeding acceptable thresholds, Cardway Tech reserves the right, acting in consultation with the Licensed PSP, to: (i) require the User to implement enhanced fraud prevention measures; (ii) request the Licensed PSP to impose a rolling reserve on future settlements; or (iii) suspend or terminate the User's access to the Platform. For Users acting as Payment Facilitators, such measures may apply to individual Sub-Merchant accounts.
Cardway Tech, as a non-regulated technical service provider, is not itself a reporting entity directly subject to the AML/CTF obligations imposed on credit institutions and payment service providers under Directive (EU) 2015/849 (4AMLD) as amended by Directive (EU) 2018/843 (5AMLD) and Regulation (EU) 2024/1624 (Anti-Money Laundering Regulation, AMLR), which replaces the existing directives and will apply directly from 10 July 2027. Statutory AML/CTF compliance obligations applicable to payment transactions processed through the Platform are fulfilled by the Licensed PSPs with which Users contract for payment services.
Notwithstanding the foregoing, Cardway Tech voluntarily maintains an internal, risk-based compliance programme designed to prevent the Platform from being used to facilitate financial crime, including money laundering, terrorist financing, fraud, or sanctions violations. This programme includes User and Sub-Merchant onboarding controls, transaction pattern monitoring at the platform level, and co-operation with Licensed PSP compliance requirements. Details are set out in Cardway Tech's AML and Security Policy, available at https://carteza.com/aml.
Use of the platform is conditional upon full cooperation with AML/CTF requirements, including Know Your Customer (KYC) procedures, identification of beneficial owners, and verification of business activity.
Services may be restricted or terminated if:
Required information is incomplete, inaccurate, or unverifiable;
Transactions are suspected to be illicit or non-transparent;
Users or counterparties are subject to sanctions or regulatory restrictions.
Further details are available in Cardway Tech’s AML and Security Policy.
Availability Target. Cardway Tech shall use commercially reasonable endeavours to ensure that the Platform is available with a monthly uptime of no less than 99.5%, excluding Scheduled Maintenance and Force Majeure Events. Uptime of the Licensed PSP's own processing infrastructure is outside Cardway Tech's control and is not included in this target.
Scheduled Maintenance. Cardway Tech will provide Users with no less than forty-eight (48) hours prior written notice of Scheduled Maintenance. Emergency maintenance may be carried out without prior notice; Cardway Tech will notify Users as soon as practicable thereafter.
Incident Notification. In the event of an unplanned outage affecting the Platform, Cardway Tech shall notify Users via email or status page within four (4) hours of incident identification and shall provide updates at regular intervals until resolution.
Disclaimer. The Platform is provided on an "as available" basis. Cardway Tech does not warrant that the Platform will be error-free or uninterrupted. Service unavailability caused by factors outside Cardway Tech's reasonable control - including Licensed PSP outages, payment scheme downtime, third-party infrastructure failures, or Force Majeure Events - shall not constitute a breach of these Terms.
Orchestration Failover. Where the Platform supports multi-PSP routing, Cardway Tech shall use reasonable endeavours to route transactions to an available Licensed PSP in the event of a primary Licensed PSP outage, subject to the configuration agreed in the applicable Service Agreement.
Maintenance, upgrades, or force majeure events may result in temporary service interruptions. Cardway Tech will provide advance notice where possible.
Force Majeure. Neither party shall be liable for any failure or delay in performance to the extent caused by a Force Majeure Event. "Force Majeure Event" means any circumstance beyond the reasonable control of the affected party, including acts of God, natural disasters, war, terrorism, civil unrest, governmental actions, strikes, pandemic, or failure of third-party infrastructure (including internet service providers, cloud hosting providers, and Licensed PSPs). The affected party shall: (i) notify the other party in writing within five (5) Working Days of becoming aware of the event; and (ii) use reasonable endeavours to mitigate its effects. If a Force Majeure Event continues for more than sixty (60) consecutive days, either party may terminate the Agreement on ten (10) Working Days written notice without liability.
These Terms and any non-contractual obligations arising out of or in connection with them are governed by and construed in accordance with the laws of Estonia, without regard to conflict of law provisions. Any dispute shall be subject to the exclusive jurisdiction of the courts of Harju County, Estonia, unless the parties agree in writing to resolve the dispute through binding arbitration under the ICC Rules of Arbitration. Users located outside the European Union are advised to seek local legal counsel regarding the enforceability of this jurisdiction clause in their respective jurisdictions.
Cardway Tech shall comply with lawful requests from regulatory authorities, courts, payment schemes, or law enforcement agencies, including orders to disclose User data or restrict access to the Services. Where permitted by applicable law, Cardway Tech shall notify the affected User of any such request promptly. Notwithstanding the foregoing, Cardway Tech shall not be required to disclose information the disclosure of which is prohibited by law.10.
To the maximum extent permitted by law, Cardway Tech disclaims liability for:
Indirect, incidental, or consequential damages;
Loss of business, data, profits, or revenue;
Claims arising from service unavailability or third-party failures.
Cardway Tech's total aggregate liability to the User under or in connection with these Terms in any twelve (12) month period shall not exceed the greater of the total fees actually paid by the User to Cardway Tech for the affected Services during the twelve (12) months immediately preceding the event giving rise to the claim. This cap applies to all claims in aggregate, regardless of the form of action (contract, tort, negligence, or otherwise). For the avoidance of doubt, Cardway Tech shall bear no liability whatsoever for any loss arising from the acts, omissions, insolvency, or regulatory action affecting any Licensed PSP.
Indemnification. The User shall defend, indemnify, and hold harmless Cardway Tech and its officers, directors, employees, and agents from and against any third-party claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or relating to:
(i) the User's breach of these Terms or any applicable law or regulation;
(ii) the User's use of the Services for Prohibited Activities (Section 2(c));
(iii) any claim by a Sub-Merchant, end-customer, or third party arising from the User's or Payment Facilitator's business operations;
(iv) any misrepresentation made by the User during onboarding or otherwise.
Cardway Tech shall: (a) promptly notify the User of any claim; (b) give the User reasonable control of the defence; and (c) provide reasonable co-operation at the User's expense.
All content, code, trademarks, and other intellectual property on the Site or provided as part of the services are owned by Cardway Tech or its licensors.
Users are granted a limited, non-exclusive, non-transferable license to use the platform solely as intended under these Terms.
Feedback. If the User provides Cardway Tech with any suggestions, ideas, enhancement requests, feature proposals, or other feedback relating to the Platform or Services ("Feedback"), such Feedback shall be the exclusive property of Cardway Tech. The User hereby irrevocably assigns to Cardway Tech all rights, title, and interest in and to such Feedback. Cardway Tech may use Feedback for any purpose without restriction, attribution, or compensation to the User.
Each party ("Receiving Party") shall keep strictly confidential all Confidential Information received from the other party ("Disclosing Party") and shall not disclose it to any third party without the prior written consent of the Disclosing Party.
The Receiving Party may disclose Confidential Information only to its employees, officers, professional advisers, or contractors who need to know such information for the performance of these Terms, provided they are bound by obligations of confidentiality no less protective than those set out herein.
The obligations in this Section 12 shall not apply to information that: (i) is or becomes publicly available other than through breach of these Terms; (ii) was already known to the Receiving Party prior to disclosure; (iii) is independently developed by the Receiving Party without reference to the Confidential Information; or (iv) is required to be disclosed by law, court order, or regulatory authority, provided the Receiving Party gives prompt written notice to the Disclosing Party where legally permissible.
These confidentiality obligations shall survive termination or expiry of these Terms for a period of three (3) years.
13. Termination
Termination for Convenience. Either party may terminate these Terms upon thirty (30) days prior written notice to the other party, without cause.
Termination for Cause. Either party may terminate these Terms immediately upon written notice if: (i) the other party commits a material breach and fails to remedy it within fifteen (15) Working Days of receiving written notice; (ii) the other party becomes insolvent or enters insolvency proceedings; or (iii) the other party ceases to carry on business.
Immediate Termination by Cardway Tech. Cardway Tech may terminate immediately, without notice, if: (i) the User engages in Prohibited Activities (Section 2(d)); (ii) the User provides materially false or misleading information; (iii) termination is required by a regulatory authority, Licensed PSP, or court order; or (iv) continued provision of Services would expose Cardway Tech or its Licensed PSP partners to regulatory, legal, or reputational risk.
Effect of Termination. Upon termination: (i) all licences granted under these Terms shall immediately cease; (ii) the User shall cease all use of the Platform and API; (iii) Cardway Tech shall, upon written request within thirty (30) days of termination, provide the User with an export of non-transactional account data in a standard machine-readable format; (iv) transactional data shall be retained in accordance with applicable legal requirements and Cardway Tech's Privacy Policy. Sections 4, 10, 12, and this Section 13 shall survive termination of these Terms.
Cardway Tech may engage sub-processors and third-party service providers in connection with the delivery of the Services, including cloud infrastructure providers, cybersecurity vendors, Licensed PSPs and other technical or professional service providers necessary for the operation of the Platform.
Cardway Tech shall ensure that Subcontractors engaged in processing personal data are bound by data protection obligations at least equivalent to those in these Terms and Cardway Tech's DPA.
Licensed PSPs. The User acknowledges that payment transactions facilitated through the Platform are processed by Licensed PSPs which are independent third parties. Cardway Tech does not warrant the performance, solvency, or regulatory compliance of any Licensed PSP. The User's relationship with any Licensed PSP in respect of payment processing is governed by the Licensed PSP's own terms and conditions. Cardway Tech's role is limited to technical orchestration and routing between the User and the Licensed PSP.
Cardway Tech may amend these Terms at any time. Updates become effective upon publication on the Site. Continued use of the Site or services after changes constitutes acceptance of the revised Terms.
These Terms are published in English. In the event of any discrepancy between translations, the English version shall prevail.
Severability. If any provision of these Terms is held invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, or if modification is not possible, severed from these Terms. The validity, legality, and enforceability of the remaining provisions shall not be affected.
Cardway Technologies OÜ
Registry Code: 17593866
Registered Address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152
Website: https://carteza.com
For legal or compliance queries, please contact:
Legal & Compliance Department
Email: [email protected]
Notice
These Terms have been drafted in accordance with the laws of Estonia, the regulations of the European Union, and best practices applicable to technical service providers and payment orchestrators operating in the payment sector.