1. TERMS & CONDITIONS (EMI-COMPLIANT)
1.1 Introduction
These Terms and Conditions (“Terms”) govern your use of CLiP Ability services, operated by CLiP Ability Ltd.
CLiP Ability provides inclusive financial technology services designed for individuals with intellectual and developmental disabilities (I/DD), neurodiverse individuals, and their caregivers.
By using our services, you agree to these Terms.
1.2 Regulatory Status
CLiP Ability Ltd. acts as a programme manager and technology provider.
Financial services are provided by a regulated Electronic Money Institution:
[Wallester AS or applicable issuer], authorised and regulated as an Electronic Money Institution.
The Issuer provides:
Electronic money accounts (IBANs)
Payment services
Card issuance (Visa/Mastercard)
CLiP Ability does not hold customer funds.
1.3 Nature of Funds
Your balance represents electronic money (e-money)
E-money is not a bank deposit
No interest is paid
Safeguarding
Funds are:
Held in segregated accounts
Protected under EU e-money regulations (EMD2)
Deposit Guarantee
Funds are not covered by a Deposit Guarantee Scheme
1.4 Eligibility
Users must:
Be 18+, OR have a registered caregiver/guardian
Complete identity verification (KYC)
Provide accurate information
1.5 Services Provided
CLiP Ability provides access to:
Digital wallet with IBAN
Virtual and physical prepaid cards
Payment and transfer services
Accessibility-enabled financial tools
Caregiver/guardian controls
1.6 Account Responsibilities
Users must:
Keep login details secure
Notify us of unauthorised use
Maintain accurate account data
Caregivers are responsible for managed accounts.
1.7 Fees
Indicative pricing:
Physical card: €2/month
IBAN: €0.98/month
Virtual card: €0.98/month
Account maintenance: €2/month
Additional fees may apply:
FX beyond €500/month
ATM withdrawals
Replacement cards
All fees are disclosed transparently before purchase.
1.8 Payment Services (PSD2)
Services include:
Execution of payments
Issuing payment instruments
Money remittance
Strong Customer Authentication (SCA)
Transactions may require:
Two-factor authentication
Biometrics
3D Secure
1.9 Transaction Execution
SEPA: same-day or next business day
Card payments: real-time authorisation
Limits may apply based on:
KYC level
Risk assessment
1.10 Permitted Use
You may not:
Use services for illegal activity
Engage in fraud or money laundering
Misrepresent identity
1.11 Suspension & Termination
Accounts may be suspended or closed if:
Required by law
Fraud or misuse is suspected
Terms are breached
Remaining funds will be returned (subject to checks).
1.12 Liability
Under PSD2:
User liability is limited (typically €50)
Except in cases of fraud or gross negligence
CLiP Ability is not liable for:
Indirect losses
Third-party outages
1.13 Accessibility Commitment
CLiP Ability provides:
Inclusive UX design
Assisted financial access
Caregiver tools
Spending controls
1.14 Governing Law
These Terms are governed by:
Laws of Ireland
Applicable EU financial regulations
1.15 Contact
support@clipability.com
2. PRIVACY POLICY (GDPR)
2.1 Overview
We process personal data in accordance with GDPR.
2.2 Data Collected
Identity data
Contact information
Financial data
Device data
Accessibility preferences
Caregiver relationships
2.3 Purpose
Data is used to:
Provide services
Perform KYC/AML
Prevent fraud
Improve accessibility
2.4 Legal Basis
Contract
Legal obligation
Legitimate interest
Consent
2.5 Data Sharing
Data may be shared with:
Issuer (e.g. Wallester)
Payment networks
KYC providers
Regulators
2.6 Retention
Data is retained:
During account lifecycle
5–7 years post-closure
2.7 User Rights
Users may:
Access data
Correct data
Request deletion
Restrict processing
Port data
2.8 Security
We implement:
Encryption
Secure authentication
Fraud monitoring
2.9 Contact
privacy@clipability.com
3. REFUND POLICY
3.1 General
CLiP Ability operates a prepaid service model.
3.2 Eligible Refunds
Duplicate charges
Failed transactions
Unauthorised transactions
3.3 Non-Refundable
Used subscription fees
Completed FX conversions
ATM fees
3.4 Disputes
Submit within 30 days.
Resolution: 5–15 business days.
3.5 Processing Times
Card refunds: 3–10 days
Wallet refunds: 1–3 days
4. DELIVERY TERMS
4.1 Digital
Wallet: instant
Virtual card: immediate
4.2 Physical Card
Ireland: 3–7 days
EU: 5–10 days
4.3 Activation
Cards must be activated via app.
4.4 Risk Transfer
Risk passes upon delivery.
5. FULL TRANSACTION FLOW (PSD2 + UX COMPLIANT)
Step 1: Add to Basket
User selects:
Card type
IBAN account
Plan
Pricing clearly displayed.
Step 2: Review
User sees:
Full cost breakdown
Recurring vs one-off fees
Step 3: Checkout
User enters:
Personal details
Accessibility settings
Caregiver info
Step 4: KYC Verification
ID upload
Biometric check
Address verification
Step 5: Payment
User pays via:
Card / bank
Includes:
SCA / 3D Secure
Step 6: Confirmation
User receives:
Confirmation screen
Email
Step 7: Account Creation
IBAN issued
Wallet activated
Virtual card generated
Step 8: Delivery
Physical card shipped
Step 9: Activation
PIN setup
Card activation
Step 10: Usage
User can:
Spend
Transfer
Manage accessibility controls
6. COMPLAINTS & REGULATORY ESCALATION
6.1 Complaints
support@clipability.com
Response: within 15 business days
6.2 Escalation
Users may escalate to:
Issuer complaints process
Financial Services and Pensions Ombudsman (Ireland)