SNAIPAY Wallet Consumer Terms and Conditions



1.    Why you should read these terms and conditions

This Agreement sets out the Terms and Conditions for the SNAIPAY Consumer e-wallet and the related provision of services. It is a contract that is entered into between OKTOPAY LIMITED (“we”, “us”), an authorised electronic money distributor (the “EMD”) of Sureswipe E.M.I. PLC, the electronic money institution (the “EMI”) and you (the “User”) It applies to SNAIPAY Consumer e-wallet accounts in Italy.

The Agreement terms and conditions are valid and bound by both parties throughout the duration of the business service relation, from date of the Account opening until Account closure.

Please read this Agreement carefully before you start using our Services. The Agreement and the relevant documents tell you who we are, how we provide the services to you, how this Agreement can be changed or terminated, what to do if there is a problem and other important information.

If you do not accept these Terms and Conditions, you must refrain from opening a SNAIPAY Account or using the Services.

For any further assistance, please contact us at support@oktopay.eu

In addition to this agreement, you also need to read, understand and accept the following documents:

We will communicate with you in English language. We may also elect to use an alternative language to effectively communicate locally with you. Use of such alternative language for localization purposes should not be deemed as official for contractual purposes, unless otherwise provided in the applicable legislation. For contract purposes the official language is English nevertheless is also provided in Italian and where any discrepancy exists in the translated contracts the English version will supersede the other. By accepting this agreement, you agree that we may provide notices or other information to you from time to time to your registered email address or contact you using other contact details you have provided. Notices sent by email shall be deemed to have been received 24 hours after the time of remittance of email.


2.    Glossary

“Account” or “e-wallet” or “SNAIPAY Account” is the account you have opened with us in your name which you will be using in accordance with the terms and conditions of this Agreement.

“Agreement” are the terms and conditions included in this agreement, including all subsequent amendments and any additional documentation that accompanies it and to which you should adhere to.

“App” or “SNAIPAY App” is a mobile application software which allows you to access and manage your SNAIPAY Account.

“Available balance” the amount of e-money held in your SNAIPAY e-wallet.

“Business Day” means Monday to Friday from 9:00 – 17:00 Easter European Time – UTC+2, excluding bank and public holidays in Cyprus, and/ or in other jurisdictions where the Services are provided.

“Card” is a prepaid/debit Visa/MasterCard which is linked to your e-wallet and can be used to spend your available balance where MasterCard is accepted.

“Consumer” is a private individual or person who enters into this agreement acting for a purpose other than a trade, business or profession.

“Customer Due Diligence” is the process that we use to identify, verify our customers and monitor their Accounts according to our anti-money laundering obligations.

“EEA” or “European Economic Area” are the European Union (EU) member states as well as Iceland, Norway and Lichtenstein.

“E-money or Electronic Money” means electronically, including magnetically, monetary value stored in your SNAIPAY e-wallet, as represented by a claim on the issuer (EMI), which is issued upon receipt of funds for the purpose of making payment transactions and which is accepted by a natural or legal person other than us. The terms “e-money”, “money” and “funds” are used interchangeable in this Agreement.

“IBAN” is the International Bank Account Number, a standard international numbering system that identifies your Card or your Account.

“Gaming Account” is an existing and active account you have opened with SNAITECH.

“Location(s)” means the SNAIPAY physical points of distribution/sale in Italy, which commercially collaborate with SNAITECH and us, for the provision of the Services and specifically for allowing you to add money to your Gaming Account with the use of a QR Code issued through the gaming account.

SNAIPAY QR Code: means a dynamic QR code provided in each Location from the cashier which the User scans in order to proceed to the action/ functionality that User chose and will be  able  to execute the relevant functionality via SNAIPAY App.

“SNAITECH s.pa.” an Italian joint company incorporated and registered in Italy with registered office at Piazza della Repubblica 32, 20124 Milan, Italy with tax code and registration number with the Companies’ Registry of Milan 00754850154 and VAT no.01729640464 (“SNAITECH”)

“Services” are all products, services, features and functions offered by us that can be accessed by the User via the SNAIPAY App.

“Terms and conditions” see agreement.

“Third party” any other natural or legal person other than the parties under this agreement.

“Transaction” is an action by you which results to money entering or leaving your Account.

“User” is a natural person over 18 years old who keeps a Gaming Account which is using the Services.
“Website” means www.snaipay.it

“Writing” means in written form including email.


3.    Who we are?

OKTOPAY LIMITED (we /our/us) is an Electronic Money Distributor (EMD) in EEA Countries  that has been appointed by Sureswipe,a public limited liability company established in Cyprus, with registration number HE366500 and registered address at 18 Kyriakou Matsi, 1st Floor, Nicosia 1082, Cyprus and authorized as  an Electronic Money Institution (EMI) with authorization  number, under the supervision of the Central Bank of Cyprus.

For the avoidance of doubt, any reference to OKTOPAY shall mean OKTOPAY LIMITED, a company incorporated and registered under the laws of Cyprus, with registered address at 10 Mnasiadou and Strasikratous, ELMA HOUSE, Floor 2, 1065, Nicosia Cyprus.

Our services of distribution and redemption of electronic money are offered under the brand SNAIPAY, a brand owned by SNAITECH S.p.a. and lawfully licensed to us for the provision of the Services.

This Agreement will be available at you, at all times on the Website. These terms and conditions may also be sent to you or appear in places on the Website, SNAIPAY App or otherwise where relevant to your use of the Services. You can ask for a copy of these terms and conditions through the Website at any time or you can contact us at by email at support@oktopay.eu


4.    Who can use our services?

You can open an SNAIPAY Account if you are 18 years of age and over, resident of any country where the Services are available and have the full capacity to enter a contract. We may ask you at any time to show proof of your age.


5.    What is a SNAIPAY Account?

Your e-wallet is a payment account maintained under your name, that holds e-money. E-money is an electronic alternative to cash. We are offering only e-wallets in Euro currency.


With your e-wallet you can do the following:

  • Top-up your e-wallet Account with a deposit made in cash at a Location pursuant to the provisions of Sections 10 and 15 below (Reloads). A list of the Locations may be found in the APP.
  • Hold, send to and receive funds from other Users (P2P).
  • Withdraw funds from within your e-wallet in cash at a Location pursuant to the provisions of Sections 12 and 15 below (Returns). You may find the list of the Locations in the APP.
  • Perform and monitor deposits and withdrawals to and from your Gaming Account.
  • Receive verified winnings from your Gaming Account to your SNAIPAY Wallet Account.


We reserve the right to activate or deactivate any of the above or other features of your SNAIPAY e-wallet based on our agreement with SNAITECH.

You should never allow anyone to operate your SNAIPAY e-wallet on your behalf. All activities carried out in your account are deemed as activities carried out by you and you represent and warrant that you are the sole beneficiary of the account.

You may only open one SNAIPAY e-wallet. The opening of duplicate accounts for the same customer shall be refused.   Where duplicate Accounts are detected, they shall be closed or merged.

If we add new features or services, we may notify you in the email address you have given us when you opened the e-wallet. However, it is your responsibility to check regularly the Website where the updated features and services are displayed.

You can maintain balances in your SNAIPAY account; however you will not receive any interest on the electronic money in your Account. SNAIPAY e-wallet is an electronic money account and is not a bank account. Electronic money accounts are not allowed by the European Law to receive any paying interest. Electronic money is not a deposit or investment under the Cypriot Law and is therefore not protected by any deposit protection scheme or the investor compensation fund scheme that is provided for in Cyprus.

Every transaction executed, will appear in your transaction history.


Using the Card

If you use the Card services, you are implicitly accepting the terms governed by Paynovate SA (hereinafter “PNVT”),  who is the issuer of the Card . These terms can be found here.

PAYNOVATE SA (Company number: 0506.763.929) whose principal office is at Cantersteen, 47, Brussels registered in Belgium is a company authorised by the National Bank of Belgium under as an Electronic Money Institution in Belgium (“PNVT”) under the Act of 26 March 2018 regarding the legal status and supervision of credit institutions and electronic money institutions, access to the undertaking of payment service providers and to the activity of issuing electronic money, and access to payment systems (“PSD2-Act”) with license issued on 2019-03-26 , for the issuance of electronic money and provision of payment services. Details of  PNVT license can be found in the following  link: https://www.nbb.be/fr/supervision-financiere/controle-prudentiel/domaines-de-controle/etablissements-de-paiement-et


6.    Opening an e-wallet

When opening an SNAIPAY e-wallet through the SNAIPAY App, you are requesting us to open an Account for you under EMI’s authorization and approval.


When requesting us to open an Account for you, you will need to accept all required Terms and Conditions and provide us with the following information for opening a standard Account:

  • A valid and active email address which is legitimately assigned to you and validated via a one-time password (OTP)
  • Mobile phone number to which the User is the legitimate holder, and which is validated via a one-time password (OTP)
  • Identification data (full name, date of birth, id number)
  • A photo of your National ID or Passport
  • A selfie


You agree to comply with any further request from us for additional information for this purpose and that you will provide this information promptly.

You also agree that we may request or obtain, directly or through any Third Parties, the necessary documents or information to validate the information you provided to us.

Examples include commercial databases or other sources of information that we use to comply with its legal obligations for Customer Due Diligence purposes.

It is important to keep your details up to date and let us know immediately if any information you have given us has changed. This is necessary to avoid possible disruption to the provision of the Services. We cannot be responsible for any financial loss arising out of your failure to do so. We will ask you from time to time to confirm the accuracy of your information and in some cases ask you to provide additional supporting documents.

You may need to upgrade your Account to Premium Account in order to be able to use the full Services available in a personal Account and to increase your usage limits. This means that you will be required to provide us with further information:

  • A photo of your utility bill/Bank Statement up to 3 months old that confirms the permanent residence address
  • Answers to the Questionnaire A


For further upgrade to Platinum Account, we request additional documents and questionnaires to construct the economic profile and where necessary, identify the sources of origin of wealth.

If you want to know more information about how we use your personal data, please see our OKTO Privacy Policy.


7.    Protecting your account

You must take appropriate steps to protect your Account from being misused. You must take reasonable steps to secure your devices, items, IDs, passwords required to access your Account. You should PROTECT your security credentials by storing them safely. We advise that you change your password regularly and ensure that it is not reused in other online accounts.

In order to ensure the safety of your Account and of the Services provided to you, you agree to do the following:

  • Try to conceal your password in order to make it hard for others to understand.
  • Try to avoid using as a password information that can be known to a number of people, like your birthday, ID number, telephone number, or a sequence of letters and number that can easily be guessed.
  • Try not to allow any prying eyes from seeing you entering your login details
  • Refrain from using any functionality, either device or software specific, that allows you to store (“remember”) your login details as they may be compromised
  • Ensure that you do not remain logged in your Account after you have finished accessing the Services.
  • Do not allow other people to use your Account or Card.
  • Do not share your security credentials with anyone else

In some cases, we may ask you to authenticate an instruction related to your Account.

This is necessary to ensure that it’s you giving us the instruction. This could include your email and password in order to successfully log into your Account to provide us with your instruction.

If your security credentials are stolen, lost, used without authorization or compromised, you should immediately contact support@oktopay.eu and change your password without delay.

We do not accept responsibility for any interference or damage to your own computer system which arises in connection with your accessing of this website or any other website. You must take your own precautions to ensure that you are not exposed to the risk of viruses or other form of interference which may damage your own computer system.


8.     How is your Account balance protected?


When money is received from you for the services, Sureswipe E.M.I PLC will issue the equivalent value of e-money and place it in your e-wallet. The equivalent money received from you are deposited into a pooled safeguarding client account with a bank in the European Union, separated from the EMIs own money. This means that, in case of insolvency, your e-money will not be used against payment of the company’s liabilities. Your money is safe and protected in accordance with the Electronic Money Regulations which are designed to ensure the safety of funds held in electronic money accounts like your Pay3000 Account. Unlike banks, there is no lending out customer money and your account has no interest bearing. Instead of protecting your money in a deposit guarantee scheme which does not apply to our services, your money is safeguarded by Sureswipe E.M.I.
Safeguarding means that, by law, your money is kept in accounts that are completely separate from corporate accounts that are used for running a business. These funds are called ‘safeguarded funds’.  This means that, in case of insolvency, your e-money will not be used against payment of EMI’s liabilities. It should be noted that segregated account(s) will be established, maintained, and operated according to the applicable rules and regulations. The banking institution(s) will receive instructions regarding the transfer and the movement (s) of the money.

9.    How to get information about your SNAIPAY e-wallet?

You can view your SNAIPAY Account statement by logging into your Account. All your transactions) will appear in the transaction history section of your SNAIPAY e-wallet. You can access the transaction history when you log in to your Account and select the transactions tab/button.

The Account information is available for 5 years after you close your Account with us.

We highly recommend that you do not disable notifications from us but, if you choose to do so, you will have to check your payments regularly on the SNAIPAY App.

The transaction history report will be available only if there has been an activity on your Account We may charge you a fee for providing you with additional information in a different way.

You need to check your SNAIPAY e-wallet regularly and let us know immediately if you see a transaction that was not authorized by you or a payment that you think it might be made incorrectly. You can do this no later than 13 months from the date of the transaction otherwise, you are not entitled to any correction of errors or refund of funds.

With this you acknowledge and agree to review your transactions through your SNAIPAY Account, and the relevant transaction history section and you understand and accept that no period statements will be sent to you either physical or by e-mail

The Available Balance in your Account should always be positive or zero. If your e-wallet goes negative as a result of a reversal of a transaction, deduction of fees or any other action, we will ask you to repay the negative balance within seven (7) Business Days. In case you fail to do so, we will close your Account and terminate this Agreement.


10.            Adding money to your SNAIPAY Account (Reload)

All funds in your Account are “electronic money” as recognized in the European Economic Area as a form of money suitable for online use.

To get Electronic Money in your Account you must sign-in in the SNAIPAY App and use the “add money” function. Each time you want to add money in your account (top up), you may select the funding source of your preference. You can deposit cash at a Location pursuant to the provisions of Sections 15 below (Reloads). You may find the list of the designated Locations in the APP.

When you add money to your Account the equivalent amount of e-money will be issued in Euro. The e-money will be stored in your Account, and you can use them for the available transactions. For now, the electronic money can be issued only in Euro.

We may limit the adding of money in your Account, either by requirement of the anti-money laundering laws and regulations, or at our reasonable discretion (for example, without limitation, to limit fraud or credit risk). In no event will such limits exceed the maximum allowable limits set by the applicable legislation including mainly the anti-money laundering legislation.

  1. Adding money to your Gaming Account

You can use your SNAIPAY e-wallet to add money to your Gaming Account. In order to add money to your Gaming Account, you must have sufficient balance in your SNAIPAY e-wallet (either via the means mentioned under Section 10 of these Terms and Conditions) or you can add money to your Gaming Account as a result of Section 15 below.


  1. Withdraw money from your SNAIPAY Account (Returns)

To withdraw Electronic Money from your Account you must sign-in in the SNAIPAY App and use the “Prelievo” function. Each time you want to withdraw money from your Account after choosing the “Prelievo” function, you may select the destination means of your preference i.e. you can withdraw money from your SNAIPAY e-wallet by receiving it to your bank cards or bank account. If you wish to perform a cash withdrawal you need to visit a Location pursuant to the provisions of Section 15 below (Returns).

We are only offering e-wallets in euro and do not offer currency conversion for now.

In certain situations, a Return of funds may be delayed to comply with the anti-money laundering and other legal obligations. We may also delay a Return to protect you, other users and itself from loss or if it needs to confirm that you are the one who has authorized the Return.

  1. Receiving verified winnings of your Gaming Account to your SNAIPAY Account

You can choose to receive verified winnings from your Gaming Account by transferring it directly to your SNAIPAY e-wallet Account. The verified winnings will be added to your Available Balance in your Account, and they can be used for any Transaction available in the SNAIPAY App.

We may impose a limit on transferring returns from your Gaming Account into your SNAIPAY Account in order to comply with our anti money laundering obligations.


14.Sending money from your SNAIPAY Account

Once you submit a payment order, we consider that you have given consent and authorized us to execute the transaction.

You can send money to other SNAIPAY Users instantly in the section “Invia e Richiedi”, choose a recipient from your phone contacts, and follow the instructions to complete the transfer. The other person will receive the payment immediately. You have the option to send money in Euro.

We may impose a limit on sending money from your Account, either by requirement of the anti-money laundering laws and regulations, or at our reasonable discretion (for example, without limitation, to limit fraud or credit risk). In no event will such limits exceed the maximum allowable limits set by the applicable legislation including mainly the anti-money laundering legislation.

  1. Reload and Return monitoring

You may use your SNAIPAY e-wallet to monitor your reload and return transactions towards and from your e-wallet Account.

In order to top up your e-wallet Account with cash (Reload), you need to visit a Location. In the Location, you need to request to the cashier the operation and amount you want to perform, after the Location has made the necessary identity verification,  then scan the available dynamic QR code using your SNAIPAY e-wallet and you will confirm the functionality and the amount to Reload and send to your e-wallet account, which you will pay to the Location. From within your SNAIPAY e-wallet, you will type the amount you wish to send to your e-wallet account, which you will pay to the Location. The transaction, upon its completion, will be registered in the SNAIPAY App and you will be notified of its completion.

Reversely, in order to withdraw money from your e-wallet Account in cash (Return), you need to visit a Location. Using your SNAIPAY App, you need to request to the cashier the operation and amount you want to perform, after the Location has made the necessary identity verification, then scan the available dynamic QR code using your SNAIPAY e-wallet and you will confirm the functionality and the amount to Return and send back from your e-wallet account, which you will receive from the cashier at the Location. The transaction, upon its completion, will be registered in you SNAIPAY App and you will be notified of its completion.


16.Exchange rates

There is no offer for a currency conversion at this time. No exchange rates apply.


There are fees applicable for the use of the SNAIPAY  App and the related Services may be accessed here

Service Fixed cost Cost in %
Value Added Services – Top-Up –       € –      %
Value Added Services – Deposit slips 1.00 € –      %
Extra-EU card withdrawal from ATMs 1.99 € 1,75%
Card withdrawal from ATMs 1.50 € 0,30%
Extra-EU payment with Card –      % –      %
Payment with Card –      % –      %
Payment with Card Declined –      % –      %
ATM declined transaction –      % –      %
Direct Repayment on Card – Out of Scope SEPA –      % –      %
Direct Repayment on Card –      % –      %
Wallet Top-Up via Bank Transfer 1.50 € –      %
Withdrawal From Wallet To Checking Account 1.50 € –      %
Withdrawal From Wallet To Card 1.50 € –      %
Wallet Top-Up With Card 1.50 € –      %
Cash Withdrawal 1.50 € –      %
Cash Top-up 1.50 € –      %
Virtual Card Annual Fee 4.00 €/year –      %
Physical Card Annual Fee 6.00 €/year –      %
Iban Issue –       € –      %


18.Authorization and execution of your transaction with your Card

You can authorise a Transaction with your Card by:

  • making payments by entering the details of your Card to a merchant (card number, expiry date and CVV number).
  • Allow a merchant to swipe the magnetic strip of the Card and the corresponding sales slip being signed
  • Make a “contactless transaction” by touching your OKTO Card at a terminal (no PIN is required for contactless transactions up to a certain amount).
  • Insert your OKTO Card into the electronic card reader for transactions that require your PIN
  • Provide your OKTO Card number and other details consenting to the initiation of payment orders for debiting your Account when entering into an agreement with a service

If you take these actions, we will consider as you are giving us  consent execute a Transaction or withdraw cash   through your Card unless you notify us that the money was stolen from your account. For charges relating to the use of the card please see our Foglio Informativo and the Fees under Section 17.

You cannot make any payments or use your Card after it has expired. The expiry date is printed on the card. You will not be able to use your Card the day following the expiry date. However, you will still be able to receive and send funds from and to the SNAIPAY Account associated with the card.

You can contact support@oktopay.eu to request a renewal of your  card provided you do that 14 days before the expiry date printed on your Card. We may send you a renewed card for an expired Card even if you have not requested one. A replacement Card is subject to a fee.


For further information regarding the use of your OKTO Card please visit the following link: Card Consumer Terms and Conditions

We charge fees for our Services as stated in the Foglio Informativo set out on the Website and pursuant to the provisions of Section 17. We are not responsible to determine any applicable taxes relating to your Τransaction, nor we are responsible to collect report and remit any taxes arising from any Τransaction. You agree that it is your sole responsibility to determine the applicable taxes relating to a Τransaction and further to collect, report and remit tax balances arising from any transaction to the relevant tax authority. Sureswipe may deduct the fees from your SNAIPAY Account balance or deduct the transaction related fees from the amounts transferred before those funds are credited to your SNAI Account.If a transaction or payment requires you to pay a fee, we will disclose that fee to you at the time of the payment instruction.

All fees become due and payable upon the use of the Services by you. We have the right to receive all due and payable amounts towards you by directly debiting and subsequently reducing the balance of your Account without any specific notification. With the acceptance of this Agreement, you explicitly and unconditionally mandate us for the receipt and/or compensate these amounts with the equivalent debiting of your OKTO Account. Any amount that has become due and payable and has not been paid off due to insufficient balance, shall be withheld in priority against any other debit, once and to the extent the Available Balance is sufficient or compensated, if applicable.

You can find the details of the transactions and our fees charged in your transaction history in the SNAIPAY App. We will not process your transaction until we have received the fees from you. You cannot deduct any amounts from our fees.

We may make a charge for additional services we provide outside these Terms and Conditions. We will notify you if there are fees applicable when you ask for the specific service.

We are not responsible for the fees associated with a bank or another payment service provider to process payments from you to us. Any fees charged by third parties will be deducted by Sureswipe before crediting the remaining balance to you.

19.Cancelling a payment

You may not cancel or revoke a payment instruction that has already been received by us, nor can you withdraw your consent to execute a transaction.

After adding money to your Gaming Account with the use of a QR Code issued via your Gaming  Account, we have no control over the products or services that are purchased through your Gaming Account, as we only act as independent intermediaries. The lack of control denotes that we cannot confirm the legality and do not assume the responsibility and potential liability stemming from the legality of the products or services that are purchased with / through the use of your Gaming Account. Any issue regarding the above shall be directed towards SNAITECH.

20.How long will the payment take?

Payments between SNAIPAY Users are made instantly and the money are available at the time of transfer.

If you give your payment instruction after the cut-off time (5.00 pm Easter European Time – UTC+2) the payment will be executed the next Business Day.

  • If a payment was sent to the wrong account, wasn’t sent at all or was delayed

We try to process your payments correctly and timely, but sometimes things go wrong, and a payment might be delayed or not received by the person you wanted to pay.

If a person has not received the money you have sent him, we will not be responsible if we have processed the payment correctly, but you gave us the wrong details.

If the payment was not received or delayed, let us know by sending us an email to support@oktopay.eu no later than 13 months after the amount was taken from your Account.

If the money was not received into the account, and the reason was our mistake, then we will refund the payment back into your Account If possible, we will restore your Account to the state in which it would have been if the transaction did not take place.


22.Refusal of execution of a payment

We may refuse to make any type of payment in the following cases:

  • You do not have enough money in your Available
  • You do not provide us with all mandatory information requested in a payment instruction.
  • The Transaction exceed the applicable limits as defined herein We have a reason to believe that the activity is in breach of these Terms and Conditions.
  • If we have a legal or regulatory obligation that prevents us from making the payment or if we are required to perform further
  • If a third party prevents us from making the payment (for example Mastercard or Visa does not allow a payment or a withdrawal).
  • If your Account has specific
  • If your account is blocked for any other
  • If specific restrictions on adding money to your Gaming Account or on withdrawing money from your Gaming Account have been imposed by SNAITECH.
  • If we receive instructions from SNAITECH, based on our agreement, for not executing the Transaction.


We may refuse the execution of any transaction for any reason without limitation. Provided it is not prohibited by any applicable law, we will be required to provide information as to the reason it took action, what caused it to take action, and any remedial action you may take to resolve the refusal issue if possible. Sureswipe shall communicate the refusal according to the methods agreed with the User, with the utmost promptness and, at the latest, within the deadlines set for the execution of the payment transaction.


You agree that we may also suspend the execution of a Transaction, which based on available information at the time, can be reasonably deemed as above acceptable risk levels, and you will be notified for such action. Should the thread of excess risk be eliminated, Sureswipe will lift the suspension allowing the execution of the transaction.

23.Refunds to your account

If a person has not received the money you have sent, and this is not due to our mistake, we and Sureswipe will try to refund the money back to your Account, but this is not always possible. In the case of a refund of a payment, you agree to bear the fees charged for the processing of the initial payment.

We will not refund the payment if:

  1. The personalized security credentials, are lost, stolen or misappropriated. For unauthorized payments where we believe you should have been aware of the loss, theft or unauthorized use, you will be liable for the first 50 EUR. We will not hold you liable for the first 50 EUR if the unauthorized payment was caused either by us or a third party carrying out activities on our behalf. Your liability for the first 50 EUR also does not apply to any unauthorized transactions made after you have notified us that your SNAIPAY e-wallet may have been
  2. if we believe you have acted fraudulently,
  3. if you do not quickly notify us for the loss, stealing or unauthorized use of your security credentials or access to your Account,
  4. if the payment transaction was unauthorized but you have acted with intent or gross negligence
  5. if you don’t let us know about the unauthorized or incorrectly completed transaction within thirteen (13) months from the date of the payment transaction.

For more information, please read our Refund Policy.



24.Changing your PIN

If you forget your PIN of your SNAIPAY Card or your SNAIPAY Account, you may retrieve this on the SNAIPAY App.


25.Cancelling your Card

In case your account is closed, it is your responsibility to destroy the card associated.

If you want to cancel your card or report it as lost or stolen, you must immediately contact us by email at support@oktopay.eu. Replacement cards will be sent to the most recent address you have registered with us. Replacement cards are subject to a Card Replacement Fee.

If you have found the card that you have reported as lost or stolen, you need to destroy it.


26.Closing your SNAIPAY Account

You can close your Account at any time and for any reason on the SNAIPAY App.

Go to setting, select ‘Account’ and then ‘Close Account’. You will be informed through the App or via e-mail that your request is received. After this point, you will not be able to log in to the App. You accept that your Account will remain under clearance result. Please ensure that any available balances on your e-wallet are withdrawn prior the closure request of your Account.

You acknowledge and accept that closing your SNAIPAY Account does not lead automatically to the closing of your Gaming Account. The closing of your Gaming Account is governed by the separate agreement you have concluded with SNAITECH. Notwithstanding the above, if you close your Gaming Account, we will automatically close your SNAIPAY Account and terminate this Agreement.


You must not close your SNAIPAY e-wallet to avoid an investigation. If you attempt to do that, we may hold your money until the investigation is fully completed in order to protect its interests and meet its legal obligations.

In case you close your account, you agree the following:

  1. You will not be able to avail yourself with the Services
  2. You forfeit any non-monetary benefits such as bonuses, coupons and/or vouchers (if applicable).
  3. Any pending transactions will be cancelled
  4. This Agreement shall be terminated, except to the extent and for so long as we require to deal with the closure of your Account and to comply with applicable laws and regulations.
  5. We have the right to hold the balance in your Account for a period of 180 calendar days from the day you close your Account, in order to protect itself and any third party against any potential claims of reversals, fines, penalties and other liabilities that stem from the use of your Account while it was active. After this time, you will be able to withdraw any undisputed funds.
  6. After your Account is closed you will remain liable for any outstanding obligations related to your Account prior to



27.Terminating or suspending our Services at our own discretion

We may terminate or suspend our Services under this Agreement at any time by closing or blocking your Account at our own discretion in exceptional circumstances including:

  • If we have a good reason to believe that you might be acting
  • If we believe that you have provided us with false or misleading information
  • If this is required to meet our legal obligations.
  • If you did not provide us with the information, we need to meet our legal obligations or if you have provided us with incorrect
  • If we are unable to verify your identity or other information we have
  • If you have acted in breach of these Terms and Conditions in a serious way or in a way that we are entitled to close your
  • If we have a reason to believe that you use the SNAIPAY App in a way that might be harmful to our
  • If we have a good reason to believe that, if we continue to offer you our services this may harm our
  • If we must do so to meet instructions from governmental authorities within their legal
  • You do not use your Account for two years and we are unable to communicate with you during this
  • We suspect that your Account has been accessed without your authorization or if we are concerned about the security of your
  • If we have reasonable grounds to believe you are carrying out a prohibited or illegal activity
  • If you stop being a holder of a Gaming Account for any reason.


We will let you know when we block your Αccount including the reasons for this if the law allows us to do so. We will unblock your Αccount as soon as the reasons for the Αccount blocking do not exist.



We undertake that we shall not at any time, disclose to any person any of your confidential information, except in the following circumstances:

  • to our employees, officers, representatives, or advisers who need to know such information for the purposes of exercising our rights or carrying out our obligations under or in connection with this Agreement. We shall ensure that our employees, officers, representatives, or advisers to whom we disclose your confidential information comply with this clause; and
  • as may be required by law, a court of competent jurisdiction or any governmental or regulatory


29.General information

For a contract to be legally enforceable, there needs to be an offer, acceptance. This Agreement constitutes our offer to make the Services available to you and you agreeing to this Agreement constitutes your acceptance of this offer.

If we do not insist immediately that you do anything you are required to do under this Agreement, or if we delay in taking steps against you in respect of your breach of this Agreement, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.

We shall have no liability to you under this Agreement or any contract if we are prevented from or delayed in performing our obligations under this Agreement, or from carrying on our business, by acts, events, omissions or accidents beyond our reasonable control, including, without limitation, strikes, lockouts or other industrial disputes (whether involving us or any other party), failure of a utility service or transport or telecommunications network, act of God, war, riot, civil commotion, malicious damage, compliance with any law or governmental order, rule, regulation or direction, accident, breakdown of plant or machinery, fire, flood, storm or our default of subcontractors, provided that you are notified of such an event and its expected duration.

Each of the subclauses, clauses and paragraphs of this Agreement operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining subclauses, clauses and paragraphs will remain in full force and effect.

Nothing in this Agreement is intended to or shall operate to create a partnership or joint venture between you and us or authorize either party to act as agent for the other, and neither party shall have the authority to act in the name or on behalf of or otherwise to bind the other in any way (including, but not limited to, the making of any representation or warranty, the assumption of any obligation or liability and the exercise of any right or power).

We may transfer our rights and obligations under this Agreement to another organization without your consent. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under this Agreement.

You may only transfer your rights or your obligations under this Agreement to another person if we agree to this in writing.

This contract is between you and us. No other person shall have any rights to enforce any of its terms.

This Agreement and all matters arising from it and any dispute arising between the parties in connection with the Agreement shall be governed and construed in accordance with the laws of the Republic of Cyprus. Any legal proceedings resulting or connected with the Agreement shall be submitted for settlement before the competent courts as follows: (i) in case of legal proceedings brought by us against the Consumer, the courts of the Member State in which you are domiciled; (ii) in case of legal proceedings brought by you against us, either before the courts of the Member State in which we are domiciled, or before the courts of the Member State in which you are domiciled. However, this shall not prevent us from bringing any action in the courts of any other jurisdiction for injunctive or similar relief.


30.Making a complaint

If you are not happy with the provision of our services, please contact us at support@oktopay.eu or submit the online form and a client service representative will issue a ticket in reference to the dispute matter. We take seriously the complaints of our customers. If we receive a complaint from you, we will try to solve it within 15 business days. If the problem cannot be solved within 15 business days, we will send you a reply stating the reasons of the delay including the date of by which we will give you the final answer. In any case, the final reply will not exceed the 35 business days.

If you are not satisfied with our final reply, you may refer to the following Alternative Dispute Resolution Bodies:

  • Financial Ombudsman of the Republic of Cyprus:
  • Address: 13 Lord Byron Avenue, 1096 Nicosia Phone: +357 22848900

Facsimile (Fax): +357 22660584, +357 22660118

Website: www.financialombudsman.gov.cy Emails:

Financial Ombudsman: fin.ombudsman@financialombudsman.gov.cy Complaints: complaints@financialombudsman.gov.cy


·        Central Bank of Cyprus:

Address: 80 Kennedy Avenue, 1076

Nicosia Phone: +357 22714100

Facsimile (Fax): +357 22714959 Website: www.centralbank.cy


·        Cyprus Consumer Center for Alternative Dispute Resolution:

Address: 16 Kyriakou Matsi, Eagle House, 8th Floor, Agioi Omologites, 1082 Nicosia Phone: +357 22519741

Facsimile (Fax): +357 22318214 Email: secretariat@adrcyprus.com Website: www.adrcyprus.com

If you wish you may refer to Additional Alternative Dispute Resolution Bodies that exist in Italy. You may find an alternative dispute resolution body in Italy by visiting https://ec.europa.eu/consumers/odr/main/?event=main.adr.show2&lng=EN

31.Restrictions on using the Services

The Services must not be used, directly or indirectly, for the following restricted activities:


  • Breach this Agreement Privacy Policy or any other
  • Violate any law, regulation, directive, statute or contract in relation to the Services received, including without limitation, anti-money laundering laws and regulations, consumer and personal data protection, the Electronic Money Institution Law and its directives.
  • Use tools and mechanisms to conceal your online identity and location (use of proxy and other anonymizing technic.)
  • Cause and maintain an Account with a negative balance.
  • Engage in activities (in accordance with information in our possession) that may present Sureswipe with increased risk or fraud or credit exposure or that lead us handling a disproportionate number of claims settled in favor of the claimant.
  • Use the Services in a manner that results in complaints, disputes, claims, reversals, fees, fines, penalties and other liability to us, another User or a third party.
  • Use the Services for illegal
  • Infringe our, or any third party’s copyright, patent, trademark, trade secret or other intellectual property rights, or rights of publicity or
  • Provide false, inaccurate or misleading
  • Send or receive what we reasonably believe to be potentially fraudulent or unauthorized
  • Refuse to cooperate in an investigation or provide confirmation of your identity or any information you provide to
  • Control an Account that is linked to another account that has engaged in any of these restricted
  • Use the Services in a manner that MasterCard, or any other electronic funds transfer network reasonably believes to be an abuse of the card system or a violation of card association or network
  • Use of the Services in a way that we reasonably believe that might harm our ability to provide our Services,
  • To control or use a SNAIPAY Account that’s not
  • Give security credentials to any other person.
  • Allow anyone else to access or use your Account
  • To abuse, exploit or get around any usage restrictions set by a service provider your SNAIPAY Card is registered
  • Harass and/or threaten our employees, agents, or other


In case you use the Services for the above restricted services and/or in a manner that results in complaints, disputes, claims, reversals, fees, fines, penalties and other liability to us, the EMI, another User or a Third Party, you may be liable for the above restricted activities and their outcome. In such case, you agree to reimburse us, the EMI, another User or a Third Party for any and all such liability, and for us  to settle any amounts owed as a result of the liability from your available balance. Should your balance be insufficient to cover the amount, you agree that the EMI  may use any amount proceeds from a transaction, and in the event that such amount does not cover the liability, allow the holder of the claim to recover the amount through other legal means available.

In case of disputed amounts resulting from a claim or reversal, we  will block the use of enough funds in your Account to cover the full amount of the dispute. The block will not affect the use of your Account if you have a residual balance in excess of the blocked disputed amount. The block is restricted to the disputed balance amount. Should the dispute be resolved on your favor, we  will restore the full access to your Account and remove the block from the formerly disputed amount. To the contrary, if the dispute is resolved in favor of the opposing party, the blocked amount will remove the required amount from your Account in settlement of the dispute resolution decision.


32. Changing these terms and conditions

We may change or update these terms and conditions from time to time for the following reasons:

  • To make it easier for you to understand,
  • If we change the way we are doing business with you or a major change in our operations,
  • To comply with changes in regulations,
  • To reflect changes in the costs associated with the way we do business with you
  • When we are offering new products or


We reserve the right to amend these Terms and Conditions unilaterally. You may access the applicable Terms and Conditions on our Website. It is recommended that you visit the Terms and Conditions page on our Website frequently in order to be informed accordingly.

The notification of the amendments of the Terms and Conditions is concluded by posting the amended Terms and Conditions on our Website or by emailing you to the email address associated with your Account.

Any amendment to the Terms and Conditions shall apply and is valid after the lapse of two (2) months from its notification, unless such modification is made in compliance to the provisions of the applicable legislation, any court ruling or administrative decisions or when it is connected to the provision of new services or new features of existing services or when the amendment, at our discretion, does not increase your obligations and does not restrict your rights.

In any event and within the aforementioned deadline of two (2) months, if you do not accept such amendment, you must close your Account and terminate this Agreement without any charge, otherwise you are deemed to have accepted the amended Terms and Conditions without reservation. In such an event, the relevant provisions herein regarding the results of the termination apply.


33.        Limitation of liability

In the event that we are deemed to have breached the Agreement leading to loss and causing direct damage to you, our liability will be limited to the following:

  • In no event shall we, our associates, affiliates and other related persons who act on our behalf, and/or the persons we enter into contracts with, be liable for any of the following types of loss or damage in relation to this Agreement or otherwise:
  • any loss or damage whatsoever that is not directly related to our breach of this Agreement; or
  • any loss of revenue, profits, business, goodwill, contracts, or savings even if we were informed of the possibility of such occurrence; or
  • any loss or corruption of data.

Nothing in this Agreement limits or excludes our liability for death or personal injury caused by our negligence or for any damage or liability incurred by you as a result of fraud or fraudulent misrepresentation by us or to the extent that the liability may not be excluded or limited by applicable law.

We expressly disclaim, to the maximum extent permitted by law, all conditions and warranties, of any kind express, implied or statutory, regarding the Services offered or the software provided, including warranties or conditions of fitness for a particular purpose, lack of viruses, accuracy, satisfactory quality and non-infringement. We neither represent nor warrant that the provision of the Services to you will be without delay, interruption, compromise to your security systems, or error free (neither that all errors will be rectified) and we do not accept any responsibility for any delay or failure in delivering the Services under this Agreement. We and/or our third-party provider may undertake to perform maintenance and/or repair work on our systems that may restrict your access to your Account and/or the Services.


34.        Intellectual property rights

We, the system vendor and/or our licensors, grant you a limited, non-exclusive, non-transferable license for the use of any software application(s) you access through or have downloaded to your personal computer, mobile device, or platform, including an Application Programming Interface (API) or a Developer’s toolkit where applicable, but this is for your personal use only. You may not:

  • Transfer, lease or rent, sell or distribute these rights to any person or
  • Alter, reproduce, adapt, distribute, display, publish, reverse engineer, translate, disassemble, decompile or otherwise attempt to create any source code which is derived from our material.

With this you acknowledge that all rights related to our material, belong exclusively to us or to a third-party provider depending on the contractual arrangements between us and the third-party provider.

The brand(s), website(s) URL(s), logos relating to the name, products and services described/used in/on electronic and hard copy material are either copyrighted, or are registered trademarks, or are our trademarks or trademarks of a third-party provider and/or our licensors. In addition, all page headers, custom graphics, button icons, and scripts are copyrighted service marks, trademarks belonging to us. Copying, modification, alteration of any kind, amendment or use of any kind is strictly prohibited.

Specifically, we and/or our licensors are the owners of all rights, interests and titles of logos, tradenames, registered and unregistered trademarks, custom designs, proprietary software core code, patentable applications, trade secrets, registered and unregistered copyrights, any and all other intellectual property, proprietary rights or other rights related to intangible property which are used, or developed in connection with any of the Services and you agree not to claim ownership of or interest in any such intellectual property right.

You acknowledge that you have not obtained any rights expressed or implied other than the rights granted to you under the terms of this Agreement, and that no title of ownership has been transferred to you under this Agreement.

You shall not undertake any action with the intent to ascertain and/or obtain for any reason or purpose our and/or our licensors’ systems source code, processes or data. You have not been granted the right and shall not sell, resell, lease or sublet, sublicense, lend or otherwise transfer the services or components thereof.


35.        Contact us

All queries should be directed towards OKTOPAY, which operates and handles the Customer Service. Customer Service means the customer support that can be accessed online by sending an email at support@oktopay.eu.  



Updated on: 26.09.2023

Download the app
Login to your account