Lotus Cards Policy

25 June, 2026

This policy applies to Polycard, Neufero X and any card product issued, distributed, or made available under the Lotus Cards program.

1. Card Program

Lotus Cards are provided by Lotus Information Technologies in cooperation with licensed issuing banks, regulated financial institutions, card networks, payment processors, and approved program partners.

Lotus Information Technologies is responsible for the customer-facing platform, account experience, support, and program operations where applicable. The issuance, processing, custody, settlement, and regulated financial services connected to the card may be performed by licensed or authorized third-party partners.

The card is not a bank deposit account unless expressly stated by the relevant issuer. Card availability, supported countries, currencies, limits, and features may vary depending on the issuer, regulatory requirements, compliance checks, and network rules.

2. Protection of Customer Funds

Non-Custodial Wallet Arrangements

Where a card product is linked to or funded through a non-custodial wallet, the underlying funds or digital assets are held exclusively by the customer in a self-custodied wallet. Lotus Information Technologies does not hold, control, access, or take custody of such funds at any time.

The customer is solely responsible for the custody, security, and management of their non-custodial wallet, including the safekeeping of private keys, seed phrases, and any associated access credentials. Loss of access to a non-custodial wallet — including loss of private keys or seed phrases — is irreversible. Lotus Information Technologies cannot recover, restore, or provide access to funds held in a non-custodial wallet under any circumstances.

By using a card product linked to a non-custodial wallet, the customer acknowledges and accepts that Lotus Information Technologies assumes no liability, responsibility, or obligation in respect of any funds, assets, or value held in or lost from such wallet, except to the extent that any loss is directly caused by a verified technical failure on the part of Lotus Information Technologies' own systems.

Safeguarding

Where required by applicable law or regulation, customer funds held in connection with Lotus Cards are safeguarded in accordance with the requirements of the relevant issuer and regulatory framework. This may include segregation of customer funds from the operational funds of Lotus Information Technologies or its partners.

UK customers: Where the card is issued or operated under a UK-regulated Electronic Money Institution (EMI) or Payment Institution (PI) licence, customer funds may be protected in accordance with the FCA's safeguarding rules under the Electronic Money Regulations 2011 or the Payment Services Regulations 2017. Safeguarded funds are not covered by the Financial Services Compensation Scheme (FSCS) unless expressly stated by the relevant issuer.

US customers: Where the card is issued by a US-licensed issuing bank, funds may be eligible for FDIC insurance up to applicable limits. Please refer to the relevant issuer's disclosures for confirmation of FDIC eligibility.

The specific safeguarding arrangements applicable to your card will be confirmed in the issuer's terms and conditions provided at account opening.

3. Customer Eligibility

Customers must provide accurate, complete, and up-to-date information. Lotus Information Technologies and its partners may require identity verification, business verification, source of funds checks, sanctions screening, fraud screening, or enhanced due diligence before activating, maintaining, or restoring card access.

We may refuse, delay, suspend, or cancel card services where verification is incomplete, inaccurate, expired, inconsistent, or where required by law, regulation, issuer policy, network rules, or our internal risk controls.

4. Compliance, AML, CTF, and Sanctions

Lotus Information Technologies operates risk and compliance controls designed to prevent fraud, money laundering, terrorist financing, sanctions evasion, misuse of financial services, and other prohibited activity.

We may monitor card activity, deposits, top-ups, withdrawals, refunds, merchant activity, customer behavior, IP/location signals, blockchain transactions, and other relevant information for compliance and security purposes.

We apply AML, CTF, fraud, and sanctions controls in line with applicable laws and partner requirements, including relevant U.S., U.K., European, and international compliance frameworks where applicable.

Customers must not use the card for illegal activity, sanctions evasion, money laundering, fraud, gambling where prohibited, unauthorized resale, high-risk activity, circumvention of limits, abuse of promotions, suspicious transaction routing, or any activity that violates applicable law, card network rules, issuer policy, or Lotus policies.

5. Right to Suspend, Freeze, or Close a Card

Lotus Information Technologies, the issuer, or any authorized program partner may suspend, freeze, restrict, or close a card at any time if:

• suspicious, fraudulent, abusive, or manipulative activity is detected;

• the customer breaches this policy or any applicable terms;

• required verification is not completed;

• activity appears inconsistent with the customer profile;

• funds, deposits, or transactions require review;

• the card is used in a prohibited country, sector, merchant category, or activity;

• required by law, regulation, court order, regulator request, issuer policy, partner instruction, or card network rules;

• we reasonably believe action is needed to protect customers, Lotus, the issuer, partners, or the financial system.

Where legally permitted, we may notify the customer of the restriction and request additional information. In some cases, we may be legally restricted from disclosing the reason for the action.

6. Customer Requested Closure

A customer may request closure of their card at any time through the available support or account channels.

After a closure request, Lotus Information Technologies or its partners may disable new card activity and begin final settlement, subject to pending transactions, chargebacks, refunds, compliance review, network settlement timelines, and any legal or regulatory restrictions.

Where no hold, dispute, investigation, compliance restriction, or legal limitation applies, Lotus Information Technologies will use reasonable efforts to return the available card balance or complete final settlement within a maximum of 25 business days.

If funds are subject to investigation, dispute, chargeback, sanctions review, legal hold, regulatory request, or issuer restriction, settlement may be delayed until the matter is resolved.

7. Balance, Refunds, and Settlement

Available card balance may differ from displayed balance due to pending authorizations, reversals, refunds, FX adjustments, network settlement, fees charged by third parties, or compliance holds.

Refunds and settlements will be processed only to an approved destination, account, wallet, or payment method that satisfies our compliance and ownership checks.

Lotus Information Technologies may deduct or withhold amounts required to cover pending transactions, reversals, disputes, chargebacks, provider costs, network obligations, legal obligations, or confirmed losses caused by misuse or fraud.

8. Customer Responsibilities

Customers are responsible for keeping account credentials, card details, email access, devices, and authentication methods secure.

Customers must immediately notify support if they suspect unauthorized access, compromised credentials, incorrect card activity, or unauthorized transactions.

Customers must not share card data, authentication codes, one-time passwords, 3DS codes, or account access with any unauthorized person.

Card Data Security

The customer is solely responsible for the secure storage and handling of their card number, CVV, expiry date, PIN, and any other card credentials. Lotus Information Technologies shall not be liable for any loss, unauthorized transaction, or misuse arising from the customer's failure to keep card data secure, including but not limited to loss resulting from phishing, social engineering, device compromise, or voluntary disclosure to a third party.

Lotus Information Technologies is responsible only for the security of card data held within its own systems and infrastructure. In the event of a confirmed security breach originating from Lotus Information Technologies' own systems, customers will be notified in accordance with applicable data protection law and the relevant issuer's breach response procedures.

PCI DSS Compliance

The display, transmission, and storage of card data within the Lotus Cards platform is handled in accordance with the Payment Card Industry Data Security Standard (PCI DSS). Lotus Information Technologies maintains PCI DSS-compliant processes for the presentation of card credentials, including card number masking, secure display environments, and access controls designed to prevent unauthorized exposure of sensitive card data. Customers should be aware that PCI DSS compliance applies to Lotus Information Technologies' own systems and does not extend to the customer's own devices, networks, or third-party applications through which card data may be accessed or transmitted.

Card Closure

A customer may request closure of their card at any time by contacting support through the available account channels or by emailing [e-mail]. Closure requests will be processed subject to the terms set out in Section 6 (Customer Requested Closure) of this policy.

9. Changes to Card Services

Lotus Information Technologies may update card features, limits, availability, supported countries, settlement methods, compliance requirements, or this policy from time to time.

Material changes will be communicated where required. Continued use of the card after an update means the customer accepts the updated policy.

10. Complaints

If you are dissatisfied with any aspect of your card service, you have the right to make a formal complaint.

How to complain: Complaints may be submitted by contacting Lotus Information Technologies by email at [e-mail] or through the support channels available in your account.

Our process: We will acknowledge your complaint promptly and aim to provide a full response within 15 business days. In exceptional circumstances, we will notify you if more time is required, with a final response issued no later than 35 business days from receipt of your complaint.

UK customers: If you are not satisfied with our final response, or if you have not received a response within 8 weeks, you may refer your complaint to the Financial Ombudsman Service (FOS) free of charge. Details are available at www.financial-ombudsman.org.uk.

US customers: If you are not satisfied with our response, you may contact the Consumer Financial Protection Bureau (CFPB) at www.consumerfinance.gov or call 1-855-411-2372.

Complaints relating to regulated payment services in the UK are handled in accordance with the FCA's Dispute Resolution (DISP) rules.

11. Final Authority

Card services are subject to issuer approval, partner approval, applicable law, card network rules, compliance requirements, and operational availability. If there is any conflict between this policy and mandatory legal, issuer, partner, or network requirements, those requirements will prevail.

Governing Law and Jurisdiction

This policy is governed by and construed in accordance with the laws of England and Wales. Any dispute arising out of or in connection with this policy shall be subject to the exclusive jurisdiction of the courts of England and Wales, unless mandatory local law in the customer's country of residence requires otherwise.

Where Lotus Cards services are provided to customers in the United States, applicable U.S. federal and state laws — including the Electronic Fund Transfer Act (EFTA), Regulation E, and any applicable state money transmission laws — shall apply to the extent required by law, and shall prevail over this policy to the extent of any conflict.