TERMS AND CONDITIONS OF USE OF THE LETZPAY APPLICATION

This document contains the General Terms applicable to the use of the LetzPay Application, as well as the Specific Terms applicable to certain Services available through the Application.

In all cases, the User shall be subject to the General Terms, as well as to the Specific Terms corresponding to the Service used.

PART I – GENERAL TERMS

1. Introduction

1.1. These General Terms of Use (“General Terms”) establish the conditions for accessing and using the LetzPay mobile application, as well as the rights and obligations applicable to the relationship between the Company and the User in connection with the services, products and functionalities available through the Application.

1.2. The LetzPay Application is owned and operated by 360 Easy Payment Solutions S.R.L., a company incorporated and organised under Romanian law, hereinafter referred to as the “Company”. For the purposes of these General Terms, the name “LetzPay” refers to the mobile application and, where applicable, to the digital services provided by the Company through it. The Company’s full identification and contact details are: registered office: 2-4 Dante Alighieri Street, Apt. 2, District 1, Bucharest, postal code 012018, unique registration code 51076410, tax attribute RO, registered with the Trade Registry Office attached to the Bucharest Tribunal under no. J2024051275002, email address [office@letzpay.ro](mailto:office@letzpay.ro), telephone 0762 055 555.

1.3. Before creating a User Account and/or accessing the services for which acceptance of this document is required, the User shall be given the opportunity to review it. By expressing consent through the method made available in the Application, the User confirms that they have read, understood and accepted the General Terms, as well as the Specific Terms applicable to the Services they use.

1.4. If the User does not agree with the provisions of the General Terms, they will not be able to create or use the User Account or access the services for which acceptance thereof is a condition of use.

1.5. Certain products or services available in the Application may be subject to specific terms, rules or information (“Specific Terms”), which will be brought to the User’s attention before purchasing or using the respective service. The Specific Terms supplement these General Terms and shall be interpreted together with them. In the event of any inconsistency, the Specific Terms shall prevail exclusively with respect to the service for which they were established.

1.6. LetzPay reserves the right to amend or update this document whenever necessary, including as a result of legislative, technical or operational changes or the introduction, modification or removal of functionalities or services. The updated version will be published in the Application and/or on the official website and will indicate its effective date. In the case of changes that significantly affect Users’ rights or obligations, Users will be informed through the available means of communication, to the extent required by the nature of the change and applicable law.

1.7. As a general rule, amendments to this document will not affect transactions already completed before the new version enters into force, which shall remain subject to the terms applicable at the time they were carried out, except where applicable legal provisions provide otherwise.

1.8. The version of this document currently in force and its applicable effective date will be permanently available in the Application and/or on the official LetzPay website.

2. Definitions

2.1. For the purposes of these General Terms, the terms below shall have the following meanings:

LetzPay Application / Application – The mobile application made available to Users by 360 Easy Payment Solutions S.R.L., through which Users may access, select, purchase and/or pay for, as applicable, the available products and services, in accordance with these General Terms and, where applicable, the relevant Specific Terms.

User – The natural person who downloads, installs and uses the LetzPay Application on a compatible mobile device and who accepts these General Terms.

Consumer – A User who is a natural person acting for purposes outside their trade, business, production, craft or professional activity, within the meaning of applicable consumer protection legislation.

User Account – The account created in the Application by associating a telephone number with the authentication credentials required to access the available services and manage operations carried out through the Application.

Authentication – The process through which the access credentials associated with the User Account are verified for the purpose of accessing the Application and, where applicable, authorising operations carried out.

Security Credentials – The set of elements and mechanisms used for authentication and authorisation of operations, including, without limitation:

• verification codes;
• passwords;
• activation codes;
• biometric elements, insofar as these are managed through the functionalities of the User’s device;
• other security methods implemented in the Application.

Partner Provider / Partner – The legal entity, authority, economic operator or other entity with which the Company cooperates and which provides, issues, markets or otherwise makes available, as applicable, the product or service available through the Application. Depending on the Service accessed, the role and responsibilities of the Partner Provider may be detailed in the applicable Specific Terms.

Service – Any product, service, facility or functionality that may be accessed, contracted, purchased or used through the Application, including services provided by Partner Providers.

Specific Terms – The terms, conditions, rules and/or contractual information applicable to a particular Service available in the Application, which supplement these General Terms and prevail over them exclusively in the event and to the extent of an inconsistency relating to that Service.

Contract – The contractual relationship concluded by electronic means between the User and the Company and/or, where applicable, between the User and the Partner Provider, depending on the nature of the Service accessed and the information communicated to the User before completion of the Transaction.

Transaction – Any operation initiated by the User through the Application for the purpose of accessing, purchasing and/or paying for a Service available in the Application.

Authorised Instruction – The instruction transmitted by the User through the Application, after completing the applicable authentication and/or confirmation mechanism, whereby the User requests that a Transaction be carried out.

Card Transaction – A payment operation carried out using a bank card issued under the brand of an accepted international payment organisation and processed through the payment service provider involved in the Transaction.

SMS Transaction – A purchase operation carried out by sending a premium-rate SMS, subject to the conditions established by telecommunications operators and the Partner Provider, where this payment method is available for the selected Service.

Payment Service Provider / Payment Processor – An entity authorised under applicable law that provides, as applicable, the processing of payment operations carried out by the User. The use of this designation does not confer upon the Company the status of a payment service provider.

Travel Ticket – An electronic document purchased and made available to the User through the Application, under the conditions established by the competent transport operator, which grants the right to use the public transport services provided by partner operators.

Transaction Cost – The amount representing commissions, bank fees, SMS service costs or other operational costs applicable to the Transaction, as applicable, separate from the Transaction Price and communicated to the User before confirmation thereof.

Transaction Price – The consideration payable for the Service purchased by the User.

Transaction Value – The total amount payable by the User, consisting of the Transaction Price and, where applicable, the Transaction Cost.

Device – The mobile phone, tablet or other compatible device on which the LetzPay Application is installed and used.

Business Day – Any day on which banking institutions in Romania conduct business, excluding Saturdays, Sundays and public holidays.

3. Method of Operation

3.1. The LetzPay Application facilitates Users’ access to the Services available through the Application and, where applicable, interaction between Users and Partner Providers. The nature, characteristics, price and terms applicable to each Service are presented to the User in the Application and, where applicable, in the corresponding Specific Terms.

3.2. The Company ensures the administration and operation of the Application and, depending on the Service accessed, may facilitate access to the Service, receive and transmit information provided by the User, initiate the technical flow of the Transaction, transmit confirmations and perform other operations necessary for the functioning of the Service, within the limits of the role assumed for the respective Service.

3.3. The fact that a product or service is accessible through the Application does not, in itself, mean that the Company is the direct provider of that Service. The capacity in which the Company acts and the identity of the entity actually providing the Service will be determined according to the nature of the Service and will be communicated to the User before completion of the Transaction, where relevant.

3.4. In the case of payments made by bank card, payment operations are processed through authorised payment service providers or other entities legally entitled to provide the respective payment services, in accordance with applicable law.

3.5. 360 Easy Payment Solutions S.R.L. does not provide payment services in its own name under these General Terms and does not acquire the status of a payment institution merely by making payment functionalities available within the Application. In payment flows where funds are processed directly by the payment service provider, the Company does not hold the User’s funds.

3.6. Bank card data are processed exclusively through the infrastructure of the authorised payment processor, in accordance with the legal requirements and security standards applicable to that processor. The Company does not collect or store complete bank card details in its own systems insofar as the technical payment flow is configured in this manner.

3.7. For certain Services, the Company may act in a capacity different from that described in this section where the nature of the Service or the contractual relationship with the Partner Provider requires this. In such circumstances, the Company’s role, the identity of the other entities involved and the specific rules applicable to the Service will be presented to the User before conclusion of the Transaction and/or through the applicable Specific Terms.

3.8. The availability of a Service in the Application may depend on the Partner Provider, the locality or area in which the Service is available, the characteristics of the User or of the asset to which the Service relates, technical compatibility and other specific conditions communicated in the Application.

4. Subject Matter of the Contract

4.1. The purpose of these General Terms is to establish the rights and obligations between LetzPay and the User in connection with the use of the Application and access to the Services available through it.

4.2. Through the Application, Users may access, select, purchase and/or pay for, as applicable, the available Services provided by the Company and/or Partner Providers, depending on the nature of each Service, including, without limitation:

• travel tickets and public transport passes;
• parking services;
• other services and products available in the Application.

4.3. The inclusion of a Service in the list available in the Application does not, in itself, make the Company the direct provider of that Service. The Company’s role shall correspond to the legal and operational structure applicable to each Service and shall be communicated to the User before completion of the Transaction where the nature of the Service requires such information.

4.4. Certain Services may be subject to Specific Terms, Partner Provider rules, tariffs, eligibility requirements, technical, territorial or time-related conditions, or other additional information. These will be made available to the User before confirmation of the Transaction insofar as they apply to the respective Service.

4.5. The list of Services may be periodically modified by adding, removing or updating available functionalities and partners, without requiring an amendment to these General Terms, insofar as the new Service may be provided under the general rules set out herein and, where applicable, the corresponding Specific Terms.

4.6. The addition of a new Service does not require the User to purchase or use it and does not alter the legal relationships relating to Transactions already completed.

4.7. The availability of a Service may vary depending on the locality, Partner Provider, User category, characteristics of the relevant asset or service, time period, technical configuration of the Application or other specific conditions communicated during the usage flow.

4.8. Depending on the version of the Application and the Services available, LetzPay may make additional functionalities available to Users, such as:

• submitting requests to the support service;
• configuring authentication methods;
• managing notifications;
• updating contact details;
• saving favourite Transactions;
• logging out and managing the User Account.

4.9. These functionalities may be supplemented, modified, suspended or removed depending on the technical and operational development of the Application, while respecting Users’ rights and without affecting Transactions already completed.

5. Transaction Costs

5.1. Where the use of certain Services involves fees or commissions, these will be displayed in the Application before confirmation of the Transaction and will form an integral part of the information provided to the User.

5.2. Before confirmation of the Transaction, the User will be shown, as applicable:

• the Transaction Price;
• the Transaction Cost;
• any other applicable fees or additional costs;
• the total amount payable for the respective Transaction.

5.3. The User confirms the Transaction only after reviewing the information concerning the applicable price and costs and after having the opportunity to verify the total Transaction Value.

5.4. Following confirmation of the Transaction, the Company will not charge the User any additional fees or costs that were not previously communicated and accepted, except where such fees or costs result from a separate operation subsequently requested by the User and accepted under the terms communicated for that operation.

5.5. Where the price or certain costs associated with the Service are determined by the Partner Provider or another third party involved in providing the Service, they will be presented to the User in the form available in the Application before confirmation of the Transaction.

5.6. In the case of Transactions involving a payment obligation, the element through which the User definitively confirms the Transaction will clearly and unequivocally indicate that the action gives rise to an obligation to pay.

6. Security of Access to the Application

6.1. LetzPay applies appropriate technical and organisational measures, according to the nature and risks associated with the services provided, in order to protect User Accounts and prevent unauthorised access to or fraudulent use of the Application.

6.2. The User is required to keep their Security Credentials confidential and to take reasonable measures to protect the Device on which they use the Application against unauthorised access.

6.3. The User shall not disclose the Security Credentials to other persons or allow unauthorised persons to use their Account. The User is responsible for configuring and protecting the authentication methods available on their own Device.

6.4. In the event of loss or theft of the Device, disclosure or compromise of Security Credentials, or identification of access or a Transaction that the User does not recognise, the User must notify LetzPay without delay through the official contact channels and follow the instructions provided for securing the Account.

6.5. LetzPay may temporarily suspend or restrict access to the User Account or certain functionalities of the Application where there are reasonable grounds to suspect fraudulent use, unauthorised access or any other security risk that may affect the User, the Company or its contractual partners.

6.6. To the extent possible and provided that doing so would not compromise security measures, fraud prevention or compliance with a legal obligation, the Company will inform the User of the suspension or restriction of access and of the measures necessary to restore it.

6.7. Access may be restored after the reasons giving rise to the suspension have ceased to exist or after completion of the security checks considered necessary by the Company.

6.8. The Company may periodically implement or modify the authentication and security mechanisms used in the Application, including in response to new security risks, technological changes or applicable legal requirements.

7. Carrying Out Transactions

7.1. Access to the Application

7.1.1. The LetzPay Application may be downloaded and installed from official application stores (Google Play for Android devices and the App Store for iOS devices) and is available only for operating system versions compatible with the technical requirements of the Application.

7.1.2. The User is encouraged to use the latest available version of the Application. Where an update is necessary to ensure security, compatibility or the operation of certain Services, the Company may make continued use of the Application or the relevant functionalities conditional upon installation of the updated version.

7.2. Authorisation of Transactions

7.2.1. Each Transaction initiated through the Application must be confirmed by the User using the authentication or confirmation method available in the Application.

7.2.2. Before confirmation of the Transaction, the User is presented with the essential information available concerning the selected Service, the data entered, the Transaction Price, the Transaction Cost, where applicable, and the total amount payable. The User is required to verify this information before submitting the Authorised Instruction.

7.2.3. Submission of an Authorised Instruction constitutes the User’s express consent to the initiation and execution of the Transaction under the conditions presented in the Application.

7.2.4. Following submission of an Authorised Instruction, the possibility of cancelling, modifying or revoking the Transaction depends on the stage of its processing, the nature of the Service, the Partner Provider’s rules, the rules applicable to the payment operation and, where applicable, the Specific Terms and applicable law.

7.2.5. Confirmation of the Transaction by the User does not, in itself, constitute confirmation that the payment has been authorised by the payment service provider, nor that the purchased Service has been issued, activated or provided; these matters are confirmed separately depending on the nature of the Transaction.

7.3. Payment Methods

7.3.1. Depending on the selected Service, the Application allows payments to be made using one or more of the following methods:

• direct use of a bank card without saving it in the Application;
• enrolment of a bank card for subsequent quick payments;
• payment by SMS, where this option is available;
• other payment methods that may be made available in the Application and communicated to the User before initiation of the Transaction.

7.3.2. Enrolment of a bank card is intended to simplify future Transactions and does not involve debiting the bank account at the time the card is enrolled, except for any technical verification operations carried out by the payment service provider, where applicable and communicated to the User.

7.3.3. Card validation is carried out through the security mechanisms made available by the issuing institution and the payment service provider involved.

7.3.4. In the case of payment by SMS, the Transaction is subject to the technical, tariff and eligibility conditions applicable to the electronic communications operator and the respective Service.

7.4. Payment Processing

7.4.1. Bank card Transactions are processed through the payment service providers involved in the Transaction flow. The Company does not provide payment services in its own name merely by making this functionality available in the Application.

7.4.2. LetzPay does not collect or store the complete bank card details used by Users.

7.4.3. Only information strictly necessary for the operation of the service is retained in the Application database, which may include, as applicable, the last four digits of the card, its expiry date and/or technical identifiers communicated by the payment service provider, without storing complete card details.

7.5. Transaction Confirmation

7.5.1. Completion of the payment operation is conditional upon its authorisation by the issuing bank, the payment service provider or the telecommunications operator, as applicable.

7.5.2. Following confirmation of the payment, the Application will display the corresponding status of the Transaction and, where applicable, the payment confirmation message.

7.5.3. Payment confirmation does not in all cases constitute issuance, activation or provision of the Service. The Service becomes available under the conditions and at the time established for the respective Service and, where applicable, by the Partner Provider.

7.5.4. The User shall not consider the Transaction completed from the perspective of the purchased Service until the corresponding confirmation for that Service has been received or displayed in the Application, where such confirmation is required.

7.6. Purchase of Travel Tickets

7.6.1. Through the Application, the User may purchase electronic travel tickets and passes made available by partner transport operators.

7.6.2. The Travel Ticket is generated electronically and becomes available in the User Account following successful completion of the purchase process, under the conditions established by the applicable transport operator.

7.6.3. It may be presented to inspection personnel directly from the Application, subject to the conditions established by the transport operator.

7.6.4. Where the transport operator permits only display of the QR code, the QR code shall be used exclusively to verify the validity of the Travel Ticket and not for validation on the means of transport.

7.6.5. Before using the transport service, the User is required to verify the existence and validity of the Travel Ticket in the Application and to comply with the conditions of use, activation or validation established by the transport operator.

7.7. Transfer of Travel Tickets

7.7.1. Purchased Travel Tickets are associated with the User Account and, where applicable, the Device used, in accordance with the rules of the relevant transport operator.

7.7.2. Their transfer to another Device is possible only if the transport operator permits such an operation and exclusively under the conditions established by that operator.

7.7.3. The Company cannot guarantee the transfer of a Travel Ticket where such an operation is not permitted by the transport operator’s rules or systems.

7.8. Issuance of Proof of Payment

7.8.1. Proof of payment is issued on the basis of the information contained in the User’s profile and/or provided during the Transaction at the time it is carried out.

7.8.2. Subsequent changes to identification details do not automatically affect documents already issued.

7.8.3. The User is responsible for the accuracy of the information entered in their Account and/or provided for the issuance of documents relating to the Transaction.

7.8.4. The nature of the document issued, the issuing entity and the information contained therein may differ depending on the Service purchased and the roles of the Company and the Partner Provider in the respective Transaction.

8. Cancellation of Transactions and Refunds

8.1. Refusal to Carry Out a Transaction

8.1.1. LetzPay may refuse, suspend or interrupt the initiation or processing of a Transaction where there are objective grounds, including, without limitation:

• failure to authorise the payment;
• invalidation of the Transaction by the payment service provider, telecommunications operator or Partner Provider, as applicable;
• the entry of incomplete or incorrect data;
• suspected fraudulent use of the Application;
• use of an unauthorised payment instrument;
• breach of these General Terms or the applicable Specific Terms;
• technical or operational reasons preventing the safe execution of the Transaction;
• unavailability of the Service or inability of the Partner Provider to provide it.

8.1.2. Refusal or inability to process a Transaction does not constitute provision of the Service. To the extent that payment has already been authorised or made, the relevant amounts will be handled in accordance with section 8.4, the rules of the payment service provider, the rules of the Partner Provider and applicable law.

8.2. Conditions Regarding Use of the Application

8.2.1. Proper operation of the Application requires:

• an active internet connection;
• use of a compatible Device;
• maintenance of a sufficient battery charge level;
• installation of a compatible version and, where required under section 7.1, the updated version of the Application.

8.2.2. LetzPay cannot be held liable, insofar as the cause is not attributable to it, for inability to use the Services resulting from the absence of an internet connection, improper functioning of the Device or other causes beyond its reasonable control.

8.3. Request for Cancellation or Verification of a Transaction

8.3.1. Where the User considers that a Transaction has been processed incorrectly, or wishes to request its cancellation or verification, the User may submit a written request to LetzPay using the email address specified in section 1.2.

8.3.2. The possibility of cancelling or modifying a Transaction depends on the stage of processing, the nature of the Service, the Partner Provider’s rules, the payment method used and applicable legal provisions. Submission of a cancellation request does not guarantee that a Transaction already processed or a Service already provided can be stopped.

8.3.3. The request must contain at least the following information:

• the User’s first and last name;
• the telephone number associated with the Account;
• the date and time of the Transaction;
• the Transaction identifier;
• the Transaction Value;
• the name of the Partner Provider;
• a description of the situation and the reason for the request.

8.3.4. If the request relates exclusively to performance of the Service by the Partner Provider, LetzPay may forward the request to that Provider or inform the User of the appropriate method for resolving the matter, without affecting the obligations assumed directly by the Company towards the User.

8.4. Refunds

8.4.1. Where, according to the nature of the Service, the Specific Terms, the Partner Provider’s rules or applicable legal provisions, the User is entitled to a refund, the refund will be initiated through the mechanism corresponding to the payment method used and processed under the conditions applicable to the respective Transaction.

8.4.2. LetzPay does not hold the funds relating to Transactions and does not directly carry out refund operations where the funds are managed and the refund is processed by the payment service provider or another entity involved in the Transaction.

8.4.3. The actual period within which the amount becomes available to the User may depend on the payment service provider, the institution issuing the payment instrument or the payment method used.

8.4.4. The provisions of this article do not limit any rights the User may have directly against their payment service provider in the event of an unauthorised or incorrectly executed payment operation or in other circumstances governed by payment services legislation.

8.5. Consumer Rights Regarding Cancellation and Withdrawal

8.5.1. The right of withdrawal, the conditions for exercising that right and any applicable exceptions shall be determined according to the nature of the Service purchased and the legislation applicable to that Service.

8.5.2. In the case of Services for which the law grants the Consumer a right of withdrawal, information regarding the existence of that right, the applicable period and the method for exercising it, as well as any applicable conditions or exceptions, will be communicated before completion of the Transaction and, where applicable, through the Specific Terms.

8.5.3. No provision of these General Terms concerning the final nature of a Transaction, the inability to cancel it or the Partner Provider’s rules shall be interpreted as restricting any mandatory right granted to the Consumer under applicable law.

9. Processing of Personal Data

9.1. General Provisions

9.1.1. 360 Easy Payment Solutions S.R.L. processes Users’ personal data in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (“GDPR”), as well as applicable national legislation.

9.1.2. The Company acts as controller in relation to processing operations for which it determines the purposes and means of processing personal data.

9.1.3. For certain Services or operations, Partner Providers or other third parties involved may act, depending on the circumstances, as independent controllers, joint controllers with the Company or processors acting on its behalf. The applicable roles and relevant information concerning processing will be presented to the User through the Privacy Policy and, where applicable, through the notices or Specific Terms relating to the respective Service.

9.2. Purposes of Data Processing

9.2.1. Personal data are processed exclusively for specified, explicit and legitimate purposes, which may include, as applicable:

• creating and managing the User Account;
• providing the Services available through the Application;
• initiating, processing and confirming Transactions;
• managing requests concerning cancellation or refund of Transactions;
• preventing and investigating fraud and ensuring the security of the Application and IT systems;
• sending operational communications regarding the Account, Transactions and Services used;
• performing contractual obligations and managing relationships with Partner Providers;
• complying with legal obligations applicable to the Company;
• handling requests, complaints and potential disputes;
• establishing, exercising or defending legal claims;
• analysing operation, improving the Services and developing Application functionalities, under the conditions permitted by applicable law;
• sending commercial communications under the conditions set out in section 9.9.

9.2.2. The data will not subsequently be processed in a manner incompatible with the purposes for which they were collected, subject to applicable legal provisions.

9.3. Categories of Data Processed

9.3.1. Depending on the Services used and the information necessary to provide them, the Company may process, as applicable, the following categories of data:

• first and last name;
• telephone number;
• email address;
• User Account identifier;
• data provided by the User in connection with the requested Service;
• the last four digits of the bank card and its expiry date and/or other technical identifiers communicated by the payment service provider, insofar as such data are available to the Company;
• history of Transactions carried out through the Application;
• date and time of Transactions;
• Transaction Values;
• information necessary for handling requests and complaints;
• technical data regarding the Device, the Application and its use, insofar as such data are actually collected and necessary for security, operation or the other purposes communicated to the User;
• other data required by applicable law or necessary to provide the selected Service.

9.3.2. LetzPay does not collect or store complete bank card details used to make payments insofar as the technical payment flow is configured so that such data are processed exclusively by the payment service provider.

9.4. Legal Basis for Processing

9.4.1. Depending on the specific purpose, personal data are processed on the basis of one or more of the following legal grounds:

1. a) performance of the contract concluded with the User or taking the necessary steps, at the User’s request, before entering into the contract;
2. b) compliance with legal obligations to which the Company is subject;
3. c) the legitimate interests pursued by the Company or, where applicable, a third party, subject to the rights and freedoms of data subjects, including for:

• fraud prevention;
• security of the Application and IT infrastructure;
• administration and protection of the Services;
• establishment, exercise or defence of legal claims;

1. d) the User’s consent, where required under applicable law.

9.4.2. Acceptance of these General Terms does not, in itself, constitute consent to all personal data processing operations. Where processing requires consent, such consent will be requested separately and in accordance with the law.

9.5. User Consent

9.5.1. Where processing is based on consent, such consent will be requested freely, specifically, on an informed basis and unambiguously.

9.5.2. The User may withdraw consent at any time, without such withdrawal affecting the lawfulness of processing carried out before withdrawal.

9.5.3. Consent may be withdrawn through the functionalities available in the Application or by submitting a request through the Company’s official contact channels specified in section 1.2.

9.5.4. Withdrawal of consent does not affect processing carried out on another applicable legal basis.

9.6. Recipients of Data

9.6.1. Personal data may be disclosed, insofar as necessary for the purposes for which they are processed, to the following categories of recipients:

• Partner Providers involved in providing the requested Service;
• payment service providers and payment processors;
• IT, hosting, maintenance and technical support service providers;
• IT security service providers;
• communications and notification service providers, as applicable;
• consultants, auditors and other professional service providers, insofar as necessary;
• competent public authorities and institutions where disclosure is required or permitted by law;
• courts and other bodies authorised by law.

9.6.2. The role of each recipient from a data protection perspective is determined according to the legal relationship and the processing operations carried out. Providers processing data on behalf of the Company will be subject to the contractual and legal obligations applicable to processors.

9.7. Retention Period

9.7.1. Personal data are retained only for the period necessary to fulfil the purposes for which they were collected and in compliance with the retention periods prescribed by applicable law.

9.7.2. The specific retention period may vary depending on the category of data, the nature of the Service and the purpose of processing, including statutory retention periods, limitation periods and the need to resolve complaints or disputes.

9.7.3. After the purpose has ceased to apply and the period for which retention is necessary or required by law has expired, the data will, as applicable, be:

• deleted; or
• irreversibly anonymised.

Data for which there continues to be an obligation or legal basis for retention will be retained only for the period and purposes justifying such retention.

9.8. Rights of Data Subjects

9.8.1. Subject to the conditions and limitations provided by the GDPR, Users have, as applicable:

• the right to information;
• the right of access to data;
• the right to rectification;
• the right to erasure (“right to be forgotten”), subject to the conditions prescribed by law;
• the right to restriction of processing;
• the right to data portability;
• the right to object;
• the right to withdraw consent where processing is based on consent;
• the right not to be subject to a decision based solely on automated processing, including profiling, in the cases provided by law;
• the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP).

9.8.2. Requests concerning the exercise of rights will be handled within the time limits and under the conditions provided by applicable law.

9.8.3. Requests may be sent to [dpo@letzpay.ro](mailto:dpo@letzpay.ro), as well as through the other methods indicated in the Privacy Policy.

9.9. Commercial Communications

9.9.1. LetzPay may send Users commercial communications regarding, as applicable:

• new Services;
• promotional campaigns and discounts;
• personalised offers;
• products and Services offered by the Company or its partners.

Such communications will be sent only under the conditions permitted by the legislation applicable to commercial communications and data protection.

9.9.2. Where the User’s prior consent is required, it will be requested separately and will not constitute a condition for accessing Services that do not require such communications.

9.9.3. The User may at any time request that commercial communications cease through a simple mechanism made available in the communication or through the means indicated by the Company and, where required by law, free of charge.

9.9.4. Strictly operational or transactional communications concerning the Account, security, Transactions or Services used do not, in themselves, constitute promotional commercial communications and may be sent where necessary for performance of the contract, compliance with a legal obligation or on another applicable legal basis.

9.10. Transfers of Data Outside the European Economic Area

9.10.1. Where personal data are transferred to a country outside the European Economic Area or to an international organisation, the transfer will be carried out only in compliance with the requirements of Chapter V of the GDPR.

9.10.2. Insofar as such transfers take place, information regarding the transfer, its legal basis and the applicable safeguards will be presented in the Privacy Policy or in the relevant notice provided to the data subject.

9.11. Data Protection Policies

9.11.1. Additional and detailed information concerning the manner in which the Company processes personal data is available in:

• the Privacy Policy;
• data protection notices applicable to certain Services or operations;
• the Cookie Policy, insofar as applicable to the website and/or technologies used;
• other notices made available to the User through the Application or website.

9.11.2. These documents are intended to inform the User about the processing of personal data and shall be interpreted together with these General Terms, without acceptance of the General Terms constituting consent to processing operations that require such consent.

10. Rights and Obligations of the User

10.1. User Rights

10.1.1. The User has the right:

• to use the LetzPay Application in accordance with these General Terms and, where applicable, the relevant Specific Terms;
• to benefit from the Services available through the Application, subject to the conditions applicable to each Service;
• to receive clear and complete information regarding the Services, prices, costs and conditions of use;
• to consult, insofar as the functionalities of the Application allow, information concerning Transactions carried out through their Account;
• to request technical assistance through the official communication channels made available by LetzPay;
• to submit notices and complaints regarding the use of the Application and Transactions carried out through it;
• to exercise their rights regarding the protection of personal data in accordance with applicable law;
• to benefit from all other rights granted to them by applicable mandatory legal provisions.

10.2. User Obligations

10.2.1. The User undertakes:

• to provide accurate, complete and up-to-date information and to verify its accuracy before confirming a Transaction;
• to use the Application exclusively for lawful purposes and in accordance with these General Terms and, where applicable, the relevant Specific Terms;
• to maintain the confidentiality of the Security Credentials;
• not to allow unauthorised persons to access their Account;
• to take reasonable measures to protect the Device and the Account against unauthorised access;
• to notify LetzPay without delay in the situations referred to in section 6.4, including in the event of loss or theft of the Device, compromise of the Security Credentials or identification of a Transaction that the User does not recognise;
• to use the Application without adversely affecting its operation, system security or the rights of other Users or third parties;
• to comply with the technical and security instructions communicated through the Application, as well as the rules applicable to the Service used.

10.2.2. The User shall be liable for the consequences of using the Account or Security Credentials in breach of the obligations set out in these General Terms, insofar as the act or omission is attributable to the User and within the limits provided by law.

10.2.3. The mere fact that a Transaction was initiated through the User’s Account does not remove the User’s rights in the case of an unauthorised operation and may not be interpreted as establishing the User’s liability where such liability is excluded or limited by applicable law.

10.2.4. Where a situation concerns an unauthorised or incorrectly executed payment operation, the User’s rights and obligations vis-à-vis their payment service provider shall be those provided by the applicable payment services legislation.

11. Rights and Obligations of LetzPay

11.1. LetzPay’s Rights

11.1.1. LetzPay has the right:

• to administer, maintain and develop the Application;
• to modify, supplement or update the available functionalities;
• to add, update, suspend or remove Services and Partner Providers depending on their availability and the technical, commercial or operational development of the Application;
• to implement additional security measures;
• to temporarily suspend access to the Application or certain functionalities for maintenance, updates or remediation of technical incidents;
• to suspend or restrict the User’s access in the event of a breach of these General Terms or the applicable Specific Terms, or where there are reasonable suspicions of fraud, abusive use or a security risk;
• to request additional information or verification from the User where necessary for Account security, fraud prevention, handling a request or providing a Service;
• to refuse or interrupt a Transaction in the cases provided by these General Terms, the Specific Terms or applicable law.

11.1.2. Exercise of the Company’s right to modify, suspend or remove a Service or functionality will not affect rights already acquired by the User in connection with Transactions completed previously, insofar as the nature of the Service and applicable law permit.

11.1.3. Where a change significantly affects use of the Application or an ongoing Service, the Company will inform the User through the available means where the nature of the change and applicable law require such notification.

11.2. LetzPay’s Obligations

11.2.1. LetzPay undertakes:

• to use all reasonable efforts to ensure the operation of the Application and the functionalities under its control;
• to implement appropriate technical and organisational measures to protect data and system security;
• to provide the User with the necessary information regarding the Services and Transactions, insofar as such information falls within the scope of the obligations assumed by the Company;
• to correctly process and transmit the data and instructions received from the User, within the limits of the Company’s role in the relevant Service;
• to respond to User requests within the periods provided by law and, where no specific statutory period applies, within a reasonable period taking into account the nature and complexity of the request;
• to inform the User, insofar as possible, of incidents preventing the processing of a Transaction or access to a Service where such information is relevant to the User;
• to comply with the obligations laid down by applicable law and these General Terms.

11.2.2. The Company’s obligations are limited to the activities and Services it directly undertakes. The mere availability of a Service in the Application does not result in the Company assuming obligations that, according to the nature of the Service, the contract or applicable law, are incumbent upon the Partner Provider or another entity involved.

11.2.3. The Company does not guarantee the permanent availability of all Services or Partner Providers, as availability may depend on technical, operational or contractual factors or on the availability of the third parties involved.

12. Limitation of Liability

12.1. LetzPay uses all reasonable efforts to ensure the continuous and secure operation of the Application; however, it does not guarantee uninterrupted or error-free operation and cannot guarantee the permanent availability of systems and services administered by third parties.

12.2. To the extent that the relevant circumstance is not attributable to the Company and is beyond its reasonable control, LetzPay shall not be liable for the unavailability, delay or temporary inability to use the Application or a Service caused by:

• interruptions or malfunctions of electronic communications services;
• temporary unavailability or malfunction of banking systems or payment service providers;
• unavailability of the systems or Services of Partner Providers;
• loss or interruption of the User’s internet connection;
• malfunction, incompatibility or improper operation of the Device used;
• the installation or presence of malicious software, applications or components on the User’s Device;
• maintenance, updates or technical interventions carried out by third parties involved;
• technical, operational or legislative changes affecting the operation of a Service and which are outside the Company’s control;
• force majeure events, fortuitous events or other grounds for exemption recognised by law.

12.3. LetzPay shall not be liable, insofar as the consequence results from an act or omission attributable to the User, for damage resulting from:

• improper use of the Application;
• providing or confirming incorrect, incomplete or outdated information;
• failure to comply with security instructions or obligations laid down in these General Terms;
• allowing unauthorised access to the Account or compromise of the Security Credentials as a result of failure by the User to comply with their obligations;
• failure to comply with the conditions or rules applicable to the Service used where these were communicated to the User.

12.4. In the case of Services provided directly by a Partner Provider, that Provider shall be responsible for the quality, characteristics, performance and conformity of the Service in accordance with the applicable legal relationship. The Company does not assume the obligations of the Partner Provider merely because the Service is accessible through the Application.

12.5. Section 12.4 does not exclude the Company’s liability for obligations it has directly assumed towards the User, including, where applicable, in connection with the operation of the Application, the processing and transmission of data or instructions under its control and communications it is required to make.

12.6. The Company shall not be liable for damage that could reasonably have been avoided through the User’s compliance with the verification, security and information obligations set out in these General Terms, insofar as the damage results from failure to comply with such obligations.

12.7. Nothing in this article excludes or limits the Company’s liability in cases where such exclusion or limitation is prohibited by law, nor does it affect mandatory rights granted to Consumers.

13. Suspension and Termination of Use of the Application

13.1. LetzPay may temporarily suspend or restrict the User’s access to the Account, the Application or certain functionalities where there are objective grounds, including in the following situations:

• breach of these General Terms or, where applicable, the relevant Specific Terms;
• fraudulent, abusive or improper use of the Application;
• reasonable suspicion that the security of the Account has been compromised or that it is being used without authorisation;
• the need to prevent or investigate fraud or a security incident;
• the existence of an obligation imposed by a competent authority or applicable law;
• maintenance, updating or remediation of technical incidents;
• the existence of a situation that may affect the security, integrity or operation of the Application, the Company, Partner Providers or other Users.

13.2. To the extent possible and provided that notification would not compromise a security measure, the prevention or investigation of fraud or compliance with a legal obligation, the Company will inform the User of the suspension or restriction of access and, where applicable, of the measures necessary to restore it.

13.3. Suspension or restriction of access will be maintained only for as long as the grounds giving rise to the measure continue to exist or for as long as necessary to carry out the relevant checks or comply with applicable obligations.

13.4. In the event of serious or repeated breaches of these General Terms, fraudulent or unlawful use of the Application, or where continuation of the contractual relationship is no longer possible for legal, technical or security reasons, the Company may terminate the User’s access and close the Account, in compliance with applicable law.

13.5. The User may request closure of the Account at any time through the functionalities available in the Application or by submitting a request to customer support.

13.6. Closing the Account does not cancel Transactions already completed, does not affect rights and obligations arising before closure and does not prevent the handling of complaints, refunds or other operations in progress.

13.7. Closing the Account does not automatically result in deletion of all personal data associated with it. Data will be deleted, anonymised or retained, as applicable, in accordance with Article 9, the Privacy Policy and applicable data protection law.

13.8. Following closure of the Account, the User may lose access to information and functionalities available exclusively through the Account. Before closing the Account, the User is encouraged to retain any documents or information they may need subsequently, insofar as the Application allows them to be downloaded or stored.

14. Complaints and Support

14.1. The User may submit notices, complaints or requests for information regarding use of the Application, the User Account, Transactions carried out or Services accessed through it, using the official communication channels indicated in the Application or on the LetzPay website.

14.2. For the purpose of resolving the request, the User shall provide the information necessary to identify the matter complained of, such as, where applicable, Account identification details, the Transaction identifier, its date and value, the relevant Service or Partner Provider and a description of the situation.

14.3. LetzPay will review each request and communicate a response within the period provided by applicable law and, where no specific statutory period applies, within a reasonable period having regard to the nature and complexity of the request.

14.4. Where the complaint concerns a matter falling within the responsibility of a Partner Provider, payment service provider or another entity involved in providing the Service, LetzPay may, as applicable, forward the request to the competent entity or inform the User of the appropriate method for resolving it.

14.5. Forwarding a complaint to a Partner Provider or another entity does not remove LetzPay’s obligation to resolve those aspects of the complaint concerning obligations directly assumed by the Company.

14.6. Where resolution of a complaint requires information or verification from a Partner Provider or another third party involved, LetzPay may request additional information from the User and take the reasonable steps necessary to clarify the matter.

14.7. The provisions of this article do not limit the User’s right to refer the matter to authorities, alternative dispute resolution bodies or competent courts in accordance with applicable law.

15. Intellectual Property

15.1. All intellectual property rights in the LetzPay Application, including, without limitation, software, source code and object code, design, structure, interfaces, graphic elements, databases, documentation, texts, trademarks, trade names and available content, belong to the Company, Partner Providers or other right holders and are used in accordance with applicable law and, where applicable, under licences or other rights of use.

15.2. By accepting these General Terms, the User is granted a limited, non-exclusive, non-transferable and revocable right to use the Application exclusively for the purpose of accessing the available functionalities and Services, in accordance with these General Terms.

15.3. Reproduction, copying, distribution, publication, modification, adaptation, translation, transmission, commercialisation, exploitation or any other use, in whole or in part, of protected elements of the Application is prohibited without the prior written consent of the relevant right holder, except where expressly permitted by law.

15.4. To the extent permitted by law, the User is prohibited from:

• decompiling, reverse engineering, disassembling or carrying out other operations intended to obtain the source code of the Application;
• removing, modifying or concealing trademarks, copyright notices or other elements identifying the right holders;
• using the Application or its content for the development, training or exploitation of competing products or services insofar as such use infringes the rights of the Company or third parties;
• using automated means to extract, collect or systematically reuse substantial parts of the content or databases of the Application, except where permitted by law.

15.5. Names, trademarks, logos and other distinctive elements belonging to Partner Providers or other third parties are used in the Application solely for the purpose of identifying the relevant Services or entities and remain the property of their respective owners. Their presence in the Application does not grant the User any right to use them.

15.6. Nothing in these General Terms shall be interpreted as transferring to the User any intellectual property right in the Application or its content beyond the limited right of use provided in section 15.2.

15.7. The restrictions set out in this article apply only insofar as they do not limit rights or uses expressly permitted by mandatory legal provisions.

16. Amendment of This Document

16.1. LetzPay may amend or update this document whenever necessary, including for:

• compliance with legislative changes or requirements of competent authorities;
• implementation of new functionalities;
• improvement or modification of the Services;
• adaptation to technical, operational or security changes;
• clarification or updating of contractual provisions.

16.2. The updated version of this document will be published in the Application and/or on the official website and will indicate the date from which it becomes applicable.

16.3. Where amendments significantly affect Users’ rights or obligations, Users will be informed before the amendments enter into force through the Application and/or other available means of communication, insofar as the nature of the amendment and applicable law require such notification.

16.4. Where the nature of an amendment requires obtaining renewed consent from the User, continued access to the relevant Services may be made conditional upon the User’s express acceptance of the updated version of this document through the mechanism made available in the Application.

16.5. In all other cases, use of the Application after the effective date of the updated version shall be governed by the version of this document applicable at that time, after the User has been informed in accordance with this article.

16.6. As a general rule, amendments will not affect Transactions completed before the effective date of the new version, which will remain subject to the terms applicable at the time they were carried out, except where applicable legal provisions or the nature of the Service require otherwise.

16.7. Previous versions of this document applicable to completed Transactions will be retained by the Company for the period necessary to evidence contractual relationships and comply with applicable legal obligations.

17. Applicable Law and Dispute Resolution

17.1. These General Terms, as well as the legal relationships between the Company and the User regarding access to and use of the Application, are governed by Romanian law, without prejudice to mandatory legal provisions that may apply to the Consumer under European Union law or other applicable mandatory rules.

17.2. Any disagreement, complaint or dispute arising from the interpretation or performance of these General Terms shall first be sought to be resolved amicably in accordance with Article 14, using the Company’s contact details specified in section 1.2.

17.3. Where an amicable resolution is not possible, disputes shall fall within the jurisdiction of the competent courts of Romania, in accordance with the law.

17.4. In the case of a User who qualifies as a Consumer, these General Terms do not limit the User’s right to bring proceedings before the court having jurisdiction under the applicable rules on jurisdiction in consumer contracts.

17.5. The Consumer may, in accordance with the law, make use of alternative dispute resolution (“ADR”) procedures made available by competent entities for resolving disputes between consumers and traders. Information regarding ADR mechanisms is available through the Romanian National Authority for Consumer Protection.

17.6. Recourse to an alternative dispute resolution procedure does not remove the Consumer’s right to refer the matter to the competent courts in accordance with the law.

17.7. Where a specialised alternative dispute resolution body has jurisdiction in respect of a particular Service, the relevant information will be communicated to the User in the Specific Terms or in the information relating to that Service.

18. Final Provisions

18.1. If one or more provisions of these General Terms are declared null, invalid or unenforceable, the remaining provisions shall remain valid and continue to have effect insofar as the purpose and overall structure of the contractual relationship allow them to be maintained.

18.2. To the extent permitted by law, a null, invalid or unenforceable provision shall be interpreted or replaced with a valid provision that reflects as closely as possible the legal and economic purpose originally intended.

18.3. Failure or delay by LetzPay in exercising a right under these General Terms shall not constitute a waiver of that right and shall not prevent its subsequent exercise.

18.4. These General Terms constitute the entire agreement between LetzPay and the User regarding access to and use of the Application and the relationships governed by this document and supersede any previous understandings or communications relating to the same subject matter, without prejudice to the Specific Terms, pre-contractual information and other documents which, according to the nature of the Service, supplement the relationship between the parties.

18.5. In the event of any inconsistency between these General Terms and the Specific Terms applicable to a particular Service, the Specific Terms shall prevail exclusively with respect to that Service.

18.6. Article and section headings are used solely for ease of reference and do not affect the interpretation of these General Terms.

18.7. This document enters into force on the date indicated in the relevant version and remains applicable until amended or replaced by an updated version.

18.8. The applicable version of this document and its effective date shall be visibly indicated at the end thereof.

PART II – SPECIFIC TERMS FOR LOCAL PUBLIC TRANSPORT SERVICES

1. Scope

1.1. These Specific Terms govern the access, purchase, payment and use, through the LetzPay Application, of Travel Tickets and passes relating to local public transport services provided by the Transport Operators available in the Application.

1.2. These Specific Terms supplement Part I – General Terms and shall be interpreted together with them. In the event of any inconsistency, the provisions of this Part II shall prevail exclusively with respect to Local Public Transport Services.

1.3. The Transport Operator, the available Travel Tickets and the specific conditions applicable to them will be identified and presented to the User in the Application before confirmation of the Transaction.

1.4. The public transport service is provided by the competent Transport Operator under the conditions established by that Operator and by the regulations applicable to the relevant transport service. Through the Application, the Company facilitates the User’s access to available Travel Tickets and, depending on the applicable technical and contractual configuration, the operations necessary for their purchase, payment, provision and verification.

1.5. The types of Travel Tickets, fares, zones or transport lines for which they are valid, validity periods, the time from which validity begins, activation or validation conditions and any eligibility requirements are established by the competent Transport Operator and are presented to the User in the Application insofar as they apply to the selected Travel Ticket.

1.6. Changes by the Transport Operator to the fare offer, fares, validity periods, zones, lines or conditions of activation, validation or use do not require an amendment to these Specific Terms, as those elements shall apply in the form communicated to the User in the Application for the relevant Transaction.

1.7. Use of a Travel Ticket purchased through the Application is subject to the rules established by the Transport Operator and the regulations applicable to the relevant public transport service, including with respect to activation, validation, period of validity and presentation of the Travel Ticket during inspection.

1.8. Confirmation of payment does not, in itself, in all cases mean that the validity of the Travel Ticket has begun. The time from which the Travel Ticket becomes valid is the time established for the relevant ticket and displayed in the Application, which may coincide, as applicable, with the time of purchase, the time of Activation or another time established by the Transport Operator.

2. Specific Definitions

2.1. Terms defined in the General Terms retain the same meaning in these Specific Terms, except where this article expressly provides a specific meaning for Local Public Transport Services.

2.2. For the purposes of these Specific Terms, the terms below have the following meanings:

Transport Operator – the local public transport operator or any other competent entity that provides the Public Transport Service and/or establishes or administers the fare offer and the conditions for issuing, activating, validating and using Travel Tickets available through the Application.

Local Public Transport Service / Transport Service – the public passenger transport service provided by the Transport Operator, for the use of which the User may purchase one or more Travel Tickets through the Application.

Travel Ticket – the document, entitlement or electronic record evidencing the User’s right to benefit from the Transport Service under the conditions established by the Transport Operator. The Travel Ticket may take the form of a single journey, a ticket valid for a specified period, a pass or any other fare product available in the Application.

Pass – a Travel Ticket granting the right to use the Transport Service for a specified period and/or under the conditions established by the Transport Operator, including, where applicable, for certain lines, zones, categories of transport or categories of Users.

Fare Offer – all Travel Tickets available for a particular Transport Operator, together with their fares, validity periods, zones, lines, categories and other associated conditions.

Activation – the operation whereby a previously purchased Travel Ticket is placed in a usable state where, under the Transport Operator’s rules, its validity does not begin automatically at the time of purchase.

Validation – the operation or technical condition through which the use or validity of a Travel Ticket is confirmed where required under the Transport Operator’s rules. Validation may be carried out through the Application, equipment belonging to the Transport Operator or another method communicated to the User.

Validity Period – the period during which the Travel Ticket may be validly used, calculated according to the conditions established for the relevant Travel Ticket. The Validity Period may begin, as applicable, at the time of purchase, Activation, Validation or another time indicated in the Application.

Active Ticket – a Travel Ticket whose Validity Period has begun and which may be used for the Transport Service subject to compliance with the conditions applicable to it.

Expired Ticket – a Travel Ticket whose Validity Period has ended and which no longer grants the right to use the Transport Service.

Inspection – the activity carried out by the Transport Operator’s personnel or other competent persons, in accordance with applicable legislation and rules, to verify the existence and validity of the Travel Ticket.

Inspection Element – a QR code, unique code, graphical representation, information displayed in the Application or any other technical element made available for verifying the existence and/or validity of the Travel Ticket.

2.3. The name, characteristics and specific conditions of each Travel Ticket are those established by the Transport Operator and presented in the Application before the Transaction is carried out.

3. Role of LetzPay and the Transport Operator

3.1. The Transport Service is provided by the Transport Operator, which establishes, within the limits of its powers and applicable law, the Fare Offer, types of Travel Tickets, fares, conditions of use, Validity Periods, zones, lines, categories of Users and other rules applicable to public transport.

3.2. Through the LetzPay Application, the Company makes available the digital infrastructure necessary to access Travel Tickets and facilitates, depending on the technical and contractual configuration applicable to each Transport Operator:

• selection of the Travel Ticket;
• execution and processing of the Transaction;
• transmission of the necessary information to the Transport Operator and/or the entities involved in payment processing;
• recording of the Transaction;
• making the Travel Ticket and/or related confirmations available to the User;
• displaying information concerning the validity of the Travel Ticket;
• making Inspection Elements available where used for the relevant Travel Ticket.

3.3. Making a Travel Ticket available through the Application does not confer upon the Company the status of public transport operator and does not result in the Company assuming obligations that, under the law, local regulations or the applicable legal relationship, are incumbent upon the Transport Operator.

3.4. The Transport Operator is responsible, in accordance with applicable law and rules, for the actual provision of the Transport Service, including the organisation and operation of transport, routes, timetables, vehicles, travel conditions and the other elements relating to the actual provision of the public transport service.

3.5. The Company is responsible for obligations directly assumed in relation to the operation of the Application and technical operations under its control, including the correct processing and transmission of the User’s data and instructions, within the limits of its role in the relevant Service.

3.6. Depending on the contractual and technical mechanism applicable to the Transport Operator, amounts paid by the User may be processed and settled through a payment service provider, banking institution or another lawful collection and settlement flow established between the Company, the Transport Operator and the entities involved.

3.7. The User is not required to know the internal settlement mechanism between the Company, the Transport Operator and the entities involved in payment processing. For the User, the relevant information is the Transaction status and Travel Ticket status displayed in the Application.

3.8. Information concerning the Fare Offer and the specific conditions of Travel Tickets is provided and/or configured on the basis of information communicated by the Transport Operator. The Company may update this information in the Application following instructions, changes or updates communicated by the Transport Operator.

3.9. Verification of Travel Tickets and performance of Inspection activities fall within the responsibility of the Transport Operator and/or persons competent under applicable legislation and rules. The Company may provide the technical tools necessary to carry out Inspections without thereby acquiring powers to establish violations or impose penalties.

3.10. Measures regarding the cancellation, deactivation, suspension or withdrawal of a Travel Ticket may be applied where provided by the Transport Operator’s rules, the technical configuration of the Service or applicable law.

4. Available Travel Tickets

4.1. Through the Application, Users may be offered different types of Travel Tickets from the Transport Operator’s Fare Offer, including, where applicable, tickets for one or more journeys, time-based tickets, passes and other fare products available for the relevant Transport Service.

4.2. The types of Travel Tickets available may differ depending on the Transport Operator, locality, zone, line or transport network, validity period, User category and other criteria established by the Transport Operator.

4.3. For each available Travel Ticket, the Application will display, where applicable and insofar as the information is relevant:

• the name or type of Travel Ticket;
• the Transport Operator;
• the fare;
• the duration or Validity Period;
• the time from which validity begins;
• the zone, lines, network or category of transport for which it may be used;
• the Activation and/or Validation conditions;
• the category of Users for whom it is intended;
• other essential conditions of use communicated by the Transport Operator.

4.4. The User is required to verify the information relating to the selected Travel Ticket before confirming the Transaction and to ensure that it corresponds to the journey they intend to make.

4.5. The availability of a particular Travel Ticket in the Application may be modified, suspended or discontinued as a result of changes to the Fare Offer, the Transport Operator’s rules, applicable law or the technical or operational conditions of the Service.

4.6. In the case of Travel Tickets intended for specified categories of Users or provided under special fare conditions, including discounted or free travel, their purchase and use may be conditional upon fulfilment of eligibility criteria established by the Transport Operator or applicable law.

4.7. Where proof of eligibility is required for a particular Travel Ticket, the User is responsible for providing accurate information and holding the supporting documents required by the applicable rules.

4.8. The Transport Operator and/or competent entity may verify compliance with eligibility requirements and, in the cases provided by the applicable rules, may order that a Travel Ticket granted or used without the necessary conditions being met is not activated, or is deactivated, suspended or cancelled.

4.9. Changes to the Fare Offer by the Transport Operator will generally not affect Travel Tickets purchased previously and still within their Validity Period, except where the rules applicable to the relevant ticket or legal provisions provide otherwise.

5. Purchase and Payment of the Travel Ticket

5.1. In order to purchase a Travel Ticket, the User shall select in the Application the Transport Operator and the desired Travel Ticket and shall provide or confirm, as applicable, the information necessary to carry out the Transaction.

5.2. Before confirming the Transaction, the User will be presented with the essential information relating to the selected Travel Ticket, including the fare, any applicable additional costs and the total Transaction Value, in accordance with the General Terms.

5.3. Before confirming the Transaction, the User is required to verify the accuracy of the selected Travel Ticket and, where applicable, the Transport Operator, zone, line, period, User category and other relevant elements displayed in the Application.

5.4. By confirming the Transaction, the User authorises the initiation of the operations necessary for the purchase and payment of the Travel Ticket, subject to the conditions applicable to the selected payment method.

5.5. Payment may be made using the methods available in the Application for the relevant Transport Operator and Travel Ticket, including by bank card or other payment methods that may be implemented in the Application.

5.6. In the case of card payment, depending on the available functionalities, the User may use the card details entered for the relevant Transaction or a card previously enrolled in accordance with the General Terms and the conditions of the payment service provider involved.

5.7. The Transaction may be refused or may remain incomplete, including where the payment instrument is invalid, there are insufficient funds, the operation is refused by the issuing institution or payment service provider, restrictions apply to the payment instrument, or security or fraud-prevention measures are triggered.

5.8. Where the Transaction is not approved or successfully completed, the Travel Ticket shall not be considered purchased merely on the basis that the payment operation was initiated.

5.9. Following successful confirmation of the Transaction, the Application will display its status and, where applicable, make available to the User the Travel Ticket, purchase confirmation and/or the document relating to the Transaction.

5.10. Confirmation of payment and purchase of the Travel Ticket do not in all cases mean that the Travel Ticket is already active or may be used immediately. The User must check in the Application the status of the Travel Ticket and the time from which its Validity Period begins.

5.11. Where, under the Transport Operator’s rules, the Travel Ticket requires Activation or Validation after purchase, merely making the payment does not replace the performance of the relevant operation.

5.12. Where payment is approved but the Travel Ticket is not displayed, cannot be accessed or is displayed with an incorrect status in the Application, the User shall not consider themselves to hold a valid Travel Ticket until the appropriate confirmation thereof has been provided and may use the support mechanisms provided for in Article 11.

5.13. Any documents or confirmations relating to the Transaction will be issued and made available in the form corresponding to the configuration applicable to the Service and the roles of the entities involved.

6. Issuance, Activation and Validity of the Travel Ticket

6.1. The Travel Ticket is made available to the User in the Application after successful completion of the Transaction and fulfilment of the technical and operational conditions applicable to the relevant Travel Ticket.

6.2. Depending on the rules and configuration established by the Transport Operator, the Validity Period of the Travel Ticket may begin:

• automatically, at the time of purchase;
• at the time of Activation by the User;
• at the time of Validation;
• on a later date or at a later time established for the relevant Travel Ticket.

6.3. The manner in which validity begins and, where applicable, the requirement for Activation or Validation will be indicated in the Application for the relevant Travel Ticket.

6.4. Where the Travel Ticket requires Activation, the User is responsible for carrying out the Activation under the conditions and at the time prescribed by the Transport Operator before using the Travel Ticket for the relevant journey.

6.5. The mere purchase or payment of a Travel Ticket requiring Activation or Validation does not grant the right to use the Transport Service before the required operation has been performed and the Validity Period has begun.

6.6. For active Travel Tickets, the Application may display information regarding their status and Validity Period, including, where applicable, the date and time at which validity begins and ends, the remaining time and the relevant Inspection Elements.

6.7. The Validity Period is determined according to the parameters established by the Transport Operator for the relevant Travel Ticket. Upon expiry, the Travel Ticket no longer grants the right to use the Transport Service.

6.8. Before using the Transport Service and, where applicable, during the journey, the User is required to verify in the Application that the Travel Ticket is displayed as valid and that the information relating to it corresponds to the Transport Service being used.

6.9. Where the Travel Ticket does not appear in the Application, is displayed as inactive, expired, suspended or invalid, or cannot be presented in the form necessary for Inspection, the User shall not consider themselves to hold a valid Travel Ticket solely on the basis of the existence of a payment confirmation.

6.10. Activation, Validation and calculation of the Validity Period are carried out in accordance with the technical configuration applicable to the Travel Ticket and the information provided by the Transport Operator. The Company cannot individually modify, at the User’s request, the duration or starting time of the validity of a Travel Ticket, except where such an operation is permitted by the Transport Operator’s rules and is available in the Application.

6.11. In the event of inconsistencies between the validity information displayed to the User and the configuration communicated by the Transport Operator, the matter will be verified in accordance with the support and complaint procedures provided in these Specific Terms.

7. Use and Verification of the Travel Ticket

7.1. The Travel Ticket may be used only during its Validity Period and under the conditions applicable to it, including with respect to the Transport Operator, zone, lines, transport category and, where applicable, the category of User for whom it was issued.

7.2. While using the Transport Service, the User is required to be able to present the Travel Ticket in the form available in the Application and to allow it to be verified by authorised personnel.

7.3. Depending on the system used by the Transport Operator, verification of the validity of the Travel Ticket may be carried out by:

• scanning the QR code or another Inspection Element displayed in the Application;
• checking information concerning the type and status of the Travel Ticket;
• checking the Validity Period or remaining time;
• using equipment or inspection systems belonging to the Transport Operator;
• any other verification mechanism communicated to the User and available for the relevant Travel Ticket.

7.4. Where the Travel Ticket is intended for a particular person or a category of Users benefiting from special fare conditions, Inspection personnel may request, subject to the conditions established by the Transport Operator and applicable law, presentation of the documents necessary to verify identity and/or eligibility.

7.5. The User shall not modify, reproduce, falsify, transmit to another person or improperly use the Travel Ticket or its Inspection Elements. Use of a screenshot, static reproduction or copy of the Inspection Element shall not replace display of the Travel Ticket in the Application where the inspection mechanism requires the use of a dynamic or real-time updated element.

7.6. The User is responsible for maintaining the Device in a condition that allows the Travel Ticket to be accessed and displayed for as long as it must be presented for Inspection, including, where necessary, ensuring the proper operation of the Device and access to the Application’s functionalities.

7.7. Failure to present or verify the Travel Ticket at the time of Inspection may have the consequences provided by the Transport Operator’s rules and applicable law. The Company does not establish infringements and does not determine or impose penalties relating to use of the Transport Service.

7.8. Where, before or during the journey, the User finds that the Travel Ticket cannot be displayed or verified due to a technical issue with the Application, the User may use the support mechanisms provided in Article 11. The existence of such a report does not, in itself, replace the obligation to hold a valid Travel Ticket, subject to the rights granted to the User under applicable law.

7.9. The validity of the Travel Ticket is determined by the information recorded in the systems used for its issuance and verification and by the Transport Operator’s rules applicable to that Travel Ticket.

7.10. The Company may provide the Transport Operator with the technical tools necessary for verifying Travel Tickets, including inspection applications, interfaces or other IT components, without thereby altering the allocation of responsibilities set out in Article 3.

8. Association with the Account and Transfer to Another Device

8.1. Travel Tickets purchased through the Application are associated with the User Account and, where applicable, the Device from which they were purchased or activated, depending on the technical configuration applicable to the relevant Transport Service.

8.2. Accessing Travel Tickets from another Device may be subject to technical, security or authentication conditions and may require transfer of the Account or reactivation of access on the new Device.

8.3. Where transfer of the Account to another Device is permitted, this may involve deactivating access from the previously used Device and activating access on the new Device.

8.4. Simultaneous use of the same Account or the same Travel Ticket on multiple Devices may be restricted or prohibited depending on the technical configuration, the type of Travel Ticket and the Transport Operator’s rules.

8.5. The User shall not transfer, lend or make available to another person the Account, Travel Ticket or Inspection Elements where the Travel Ticket is personal, non-transferable or subject to individual conditions of use.

8.6. Transfer of the Account or change of Device does not, in itself, alter the Validity Period of the Travel Ticket and does not cause it to restart, be extended or suspended, unless the rules applicable to the relevant Travel Ticket expressly provide otherwise.

8.7. The User is responsible for carrying out the transfer or re-authentication in a timely manner and for verifying, before using the Transport Service, that the Travel Tickets are available and can be properly presented on the new Device.

8.8. In the event of loss, theft, replacement or unavailability of the Device, the User may use the access recovery and/or support mechanisms available in the Application. The possibility of recovering or transferring a Travel Ticket depends on its characteristics and the applicable rules.

8.9. The Company may temporarily restrict transfer of the Account, access to Travel Tickets from another Device or certain related operations where the measure is necessary for Account security, fraud prevention, protection of the LetzPay System or verification of unusual use.

9. User Obligations

9.1. The User is required to use the Application and Travel Tickets in accordance with the General Terms, these Specific Terms, the information displayed in the Application and the applicable rules established by the Transport Operator.

9.2. Before confirming the Transaction, the User is responsible for verifying that the selected Travel Ticket corresponds to the Transport Service they intend to use, including, where applicable, with respect to the Transport Operator, zone, line, duration, validity period and User category.

9.3. The User is required to pay in full the amounts displayed for the confirmed Transaction and to use a valid payment method that they are authorised to use.

9.4. Where the Travel Ticket requires Activation and/or Validation, the User is responsible for performing the required operation under the conditions and at the time prescribed for the relevant Travel Ticket.

9.5. The User shall not begin or continue using the Transport Service relying exclusively on the initiation of payment, the apparent debiting of an amount or the existence of a payment confirmation where the Travel Ticket is not displayed in the Application as valid under the applicable conditions.

9.6. For as long as the Travel Ticket must be capable of verification, the User is required to keep it accessible in the Application and allow Inspection to be carried out in accordance with the Transport Operator’s rules.

9.7. In the case of personal Travel Tickets or Travel Tickets granted under special fare conditions, the User is required to satisfy the eligibility requirements throughout the relevant period and, where necessary, present the supporting documents requested by authorised personnel.

9.8. The User shall not dispose of, reproduce, falsify, modify, improperly reuse, transmit or make available to another person a Travel Ticket or Inspection Element outside the circumstances in which such operations are expressly permitted.

9.9. The User is required to keep the Account access details and the Device used secure and to notify the Company through the available channels where they become aware of or suspect unauthorised access to the Account or fraudulent use thereof.

9.10. The User is responsible for complying with the travel, conduct and Transport Service usage rules established by the Transport Operator and applicable regulations. Purchasing a Travel Ticket through the Application does not remove the obligation to comply with such rules.

9.11. Where an error concerning the Travel Ticket, its status, payment or operation of the Application is identified, the User shall use the available support mechanisms and provide the information reasonably necessary to identify and verify the Transaction.

9.12. The User shall be responsible for the consequences of providing incorrect, incomplete or inappropriate information or incorrectly selecting a Travel Ticket, insofar as the error is attributable to the User and subject to the rights granted to them under applicable law.

10. Cancellation, Correction and Refunds

10.1. The possibility of cancelling, modifying or correcting a Travel Ticket after confirmation of the Transaction depends on the type and status of the Travel Ticket, the Transport Operator’s rules, the technical configuration of the Service and applicable legal provisions.

10.2. The Company cannot unilaterally modify, cancel, reactivate, extend or replace a Travel Ticket where such an operation is not permitted by the Transport Operator’s rules or by the systems used to issue and administer the relevant Travel Ticket.

10.3. In the event of an error attributable to the User regarding selection of the Travel Ticket, Transport Operator, zone, period, User category or other information confirmed before carrying out the Transaction, the possibility of correction, cancellation or refund will be determined in accordance with the rules applicable to the relevant Travel Ticket.

10.4. Travel Tickets that have been activated, validated or used, or whose Validity Period has begun or ended, may be cancelled or refunded only where such a possibility is provided by the Transport Operator’s rules or applicable legal provisions.

10.5. Where the User identifies a discrepancy between the confirmed Transaction and the Travel Ticket made available in the Application, or where payment has been completed but the Travel Ticket has not been issued or cannot be used due to a technical error, the User may submit a request through the available support channels.

10.6. Depending on the nature of the situation, the request will be reviewed by the Company, the Transport Operator and/or the entity involved in processing the payment. The Company may provide the Transport Operator with the information necessary to resolve the request insofar as permitted by applicable law.

10.7. Requests regarding the conditions of use of the Travel Ticket, eligibility, cancellation, deactivation or reimbursement of its price shall be resolved in accordance with the Transport Operator’s rules. Where resolution falls within the responsibility of the Transport Operator, the Company may forward the User’s request to the Transport Operator or direct the User to the appropriate resolution channel.

10.8. Where verification establishes that the User is entitled to a full or partial refund, the refund will be initiated and processed in accordance with the mechanism applicable to the Transaction and the payment method used.

10.9. The period within which the refunded amount becomes effectively available to the User may depend on the payment service provider, the institution issuing the payment instrument and the other entities involved in processing the operation.

10.10. A request for cancellation, correction or refund does not, in itself, suspend or extend the Validity Period of the Travel Ticket and does not grant the right to use the Transport Service in the absence of a valid Travel Ticket.

10.11. The provisions of this article are supplemented by the provisions of the General Terms regarding cancellation of Transactions and refunds and do not limit the mandatory rights granted to the User under applicable law.

11. Complaints and Support

11.1. The User may submit reports, complaints or requests for assistance regarding the purchase, payment, issuance, Activation, Validation, display or use of Travel Tickets through the official communication channels indicated in the Application or on the LetzPay website.

11.2. In order to identify and resolve the request, the User shall provide the information reasonably necessary to verify the reported situation, such as, where applicable:

• the information necessary to identify the Account;
• the Transport Operator;
• the type of Travel Ticket;
• the date and time of the Transaction;
• the Transaction identifier;
• the amount paid;
• a description of the reported situation;
• any other information or documents necessary for verification.

11.3. The Company will review those aspects of the request concerning the operation of the Application, the User Account, recording of the Transaction and the other obligations directly assumed by the Company.

11.4. Where resolution of the request depends on the Transport Operator, payment service provider or another entity involved in providing the Service, the Company may forward the request and necessary information to the competent entity or inform the User of the appropriate method for resolving it.

11.5. In particular, matters concerning the organisation and provision of the Transport Service, Fare Offer, conditions for using Travel Tickets, eligibility for certain fare categories, Inspection and any measures or penalties imposed in connection with travel shall be handled by the Transport Operator and/or competent authority in accordance with applicable rules and legislation.

11.6. Where a complaint simultaneously concerns matters falling within the Company’s responsibility and matters falling within the responsibility of the Transport Operator or another entity, each entity shall handle the part falling within its respective role.

11.7. The Company may request additional information or documents from the User and may carry out checks together with the Transport Operator, payment service provider or other entities involved where necessary to clarify the situation.

11.8. The Company will respond to requests within the period provided by applicable law and, in the absence of a specific statutory period, within a reasonable period having regard to the nature and complexity of the matter and any checks required from the Transport Operator or other entities involved.

11.9. Submission of a complaint through the Company does not limit the User’s right to contact the Transport Operator, payment service provider, competent authorities, alternative dispute resolution bodies or competent courts directly, in accordance with the law.

12. Liability

12.1. The Company shall be liable, in accordance with the law and the General Terms, for damage caused to the User as a result of the non-performance or improper performance of obligations directly assumed by the Company in connection with the operation of the Application and technical operations under its control.

12.2. The Company does not provide the Transport Service and shall not be liable for matters relating to its organisation and performance by the Transport Operator, including, without limitation:

• routes, lines, stops and operating schedules;
• delays, cancellations, interruptions or changes to services;
• actual transport conditions;
• the Transport Operator’s vehicles and personnel;
• travel rules;
• determination of the Fare Offer and eligibility conditions;
• Inspection activities and measures or penalties imposed by authorised personnel.

12.3. The Transport Operator is responsible for the accuracy, legality and currency of the information it establishes or communicates in connection with the Fare Offer, Travel Tickets and conditions for using the Transport Service. The Company will use reasonable efforts to correctly display in the Application the information received.

12.4. The Company shall not be liable for discrepancies caused exclusively by incomplete, incorrect, outdated or delayed information provided by the Transport Operator, insofar as the Company has properly processed and displayed the information received.

12.5. The Company cannot guarantee uninterrupted operation of the Application and all components of the Service where they depend on third-party infrastructure or services, including banking institutions, payment service providers, electronic communications providers, internet services, cloud infrastructure or the Transport Operator’s IT systems.

12.6. The Company shall not be liable for inability to carry out, complete or verify a Transaction where this is caused exclusively by:

• refusal or unavailability of the payment service provider or issuing institution;
• absence or interruption of the communications connection;
• unavailability of the Transport Operator’s systems;
• malfunctions of the User’s Device;
• use of an unsupported or outdated version of the Application or operating system where an update was necessary and had been reasonably made available to the User;
• other causes not attributable to the Company.

12.7. The Company shall not be liable for the consequences of the User incorrectly selecting a Travel Ticket or failing to comply with obligations regarding Activation, Validation, eligibility or presentation of the Travel Ticket for Inspection, insofar as the relevant information was properly displayed in the Application.

12.8. The Company shall not be liable for penalties imposed on the User by the Transport Operator or competent authorities, except where the penalty results directly from an error attributable to the Company and the existence of such error is established in accordance with the applicable procedures.

12.9. In the event of a technical error attributable to the Company affecting the issuance, display, Activation or verification of the Travel Ticket, the Company’s liability will be determined by reference to the proven direct damage and applicable legal provisions, without affecting the User’s mandatory rights.

12.10. Nothing in this article shall be interpreted as excluding or limiting the Company’s liability where such exclusion or limitation is prohibited by law.

13. Changes to the Fare Offer and the Transport Operator’s Rules

13.1. The Transport Operator may, within the limits of its powers and in compliance with applicable law, modify the Fare Offer and the rules relating to the Transport Service, including the types of Travel Tickets, fares, validity periods, zones, lines, Activation or Validation conditions and eligibility criteria.

13.2. The changes referred to in section 13.1 will be reflected in the Application on the basis of information communicated or made available by the Transport Operator and will apply to Transactions carried out after the date on which such changes are implemented.

13.3. Before confirming a new Transaction, the User will be presented with the information applicable to the selected Travel Ticket at that time. The User is required to verify this information before making the purchase.

13.4. A change to the Fare Offer or the specific rules of a Transport Operator does not, in itself, constitute an amendment to these Specific Terms and does not require their republication or renewed acceptance, insofar as the general rights and obligations governed by this document are not amended.

13.5. Travel Tickets purchased before a change remain subject to the conditions applicable to them at the time of purchase, insofar as the Transport Operator or applicable law does not mandatorily provide for a different regime.

13.6. Where a change to the Transport Operator’s rules affects Travel Tickets already purchased and unused or still within their validity period, the effects of the change shall be those established by the Transport Operator and applicable law, and the relevant information will be communicated to the User through the available means where such notification is required.

13.7. The Company may adapt the technical and functional elements of the Application necessary to implement changes communicated by the Transport Operator, in compliance with the General Terms and without affecting the User’s mandatory rights.

13.8. Amendments to these Specific Terms will be made in accordance with the rules governing amendments to the applicable Terms set out in the General Terms.

14. Final Provisions

14.1. These Specific Terms are supplemented by the General Terms of Use of the LetzPay Application, which apply to all matters not expressly governed by this document.

14.2. In the event of any inconsistency between these Specific Terms and the General Terms, these Specific Terms shall prevail exclusively with respect to Local Public Transport Services.

14.3. Use of the Transport Service and Travel Tickets is, in all cases, subject to applicable mandatory laws and regulations, as well as the rules established by the Transport Operator within the limits of its powers.

14.4. The information specific to the Travel Ticket displayed in the Application before confirmation of the Transaction, including information concerning the type of ticket, fare, validity, zone or transport lines and Activation or Validation conditions, supplements these Specific Terms for the relevant Transaction.

14.5. If any provision of these Specific Terms becomes invalid, unlawful or unenforceable, this shall not affect the validity and enforceability of the remaining provisions, to the extent permitted by law.

14.6. Failure or delay by the Company in exercising a right under these Specific Terms shall not constitute a waiver of that right.

14.7. By accepting this document, the User confirms that they had the opportunity to review the provisions of this Part II before using the Transport Service and that they accept them together with the provisions of Part I – General Terms.

14.8. These Specific Terms do not alter the legal relationships between the Transport Operator and the competent authorities and do not transfer to the Company obligations which, under applicable laws or regulations, are incumbent upon the Transport Operator.