1.  About GaulBridge

GaulBridge Ltd. ("GaulBridge", "we", "us", "our") is incorporated in British Columbia, Canada (Company No. BC1533341), formerly known as Paynex Money Transfers Inc., with its registered address at 301 - 401 W Georgia Street, 5th Floor, Vancouver, British Columbia, V6B 1Z3, Canada.

GaulBridge Ltd. is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business (MSB Registration No. C100000971; registered activities: foreign exchange dealing, money transferring, dealing in virtual currency and payment service provider; registration valid to 31 March 2028) and is registered with the Bank of Canada as a payment service provider under the Retail Payment Activities Act (RPAA). Our anti-money laundering and anti-terrorist financing obligations arise under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its Regulations. You can verify our registrations on the FINTRAC MSB registry and the Bank of Canada PSP registry.

Registration with FINTRAC or the Bank of Canada is not a licence, approval, authorisation or endorsement of GaulBridge or its services by either body or by the Government of Canada.

2.  Scope of these Terms

2.1 What they cover

These Terms govern the agreement between GaulBridge and you ("you", "your", "Client") for all services we provide, including:

• International and domestic money transfers
• Foreign exchange (FX) services
• Multi-currency account management
• Pre-paid card issuance and management
• Batch payment processing
• Merchant card acquiring and global payments infrastructure, provided through regulated acquiring partners

These Terms apply to both personal and business clients.

2.2 Related documents

These Terms should be read together with the following, which form part of your agreement:

• Privacy Policy
• Cookie Policy
• Legal Disclaimer
• Whistleblowing Policy
• Acceptable Use Policy
• Fees & Pricing page

In the event of a conflict, these Terms take precedence unless expressly stated otherwise.

2.3 Changes to these Terms

We may update these Terms to reflect changes in law, regulation, or our services. We will give you at least 30 days' notice of any material change by email or via your account dashboard. Continuing to use our services after the effective date means you accept the updated Terms. If you do not accept the changes, you may close your account under Section 16.

3.  Eligibility and account opening

3.1 Who can open an account

To open a GaulBridge account you must:

• Be an individual aged 18 or over (personal clients), or a legally incorporated entity (business clients)
• Not be based or incorporated in a jurisdiction subject to Canadian, UN, EU, UK, or US sanctions, or in a jurisdiction listed as prohibited in our Acceptable Use Policy
• Not be a resident of, or an entity incorporated in, the United States or its territories (GaulBridge does not provide services to U.S. persons)
• Not appear on any applicable sanctions list
• Have the legal authority to enter into a binding agreement with GaulBridge
• Successfully complete our identity verification (KYC) and due diligence process

3.2 Business clients

If you open an account on behalf of a business, you confirm that:

• You have authority to bind the business to these Terms
• The business is lawfully incorporated and in good standing
• All information provided during onboarding is accurate and up to date
• You will notify us promptly of any changes to the business, its ownership, or beneficial owners

3.3 Verification

We are required by law to verify your identity and, for business clients, that of your beneficial owners and directors. You agree to provide all documentation we reasonably request. We may use third-party identity verification providers. We reserve the right to decline any application without providing a reason, subject to applicable law.

3.4 Ongoing due diligence

We may ask you to provide updated information or documentation at any time. Failure to respond within a reasonable timeframe may result in your account being restricted or closed.

3.5 Third parties and politically exposed persons

We will ask whether you are acting on behalf of, or at the instruction of, a third party, and we keep a record of that determination, including where it cannot be resolved. We also determine whether you, a beneficial owner or an authorised signatory is a politically exposed person (domestic or foreign) or the head of an international organisation, or a family member or close associate of one, and where required we apply enhanced measures, establish source of wealth and funds, and obtain senior-management approval before the relationship or transaction proceeds.

4.  Our services

4.1 Payment services

GaulBridge enables you to send and receive funds domestically and internationally. We execute payment instructions in accordance with these Terms, subject to applicable regulatory requirements, sanctions screening, and our internal controls.

4.2 Foreign exchange

We offer spot foreign exchange at the rate displayed when you confirm your transaction. Exchange rates fluctuate and the quoted rate is only valid for the period stated at the point of transaction. GaulBridge earns revenue through the FX spread in addition to any disclosed fees.

4.3 Multi-currency accounts

Your GaulBridge account may hold balances in multiple currencies. Funds held are safeguarded in segregated accounts with regulated financial institutions in accordance with the RPAA and are not invested. Interest is not paid on account balances unless separately agreed in writing.

4.4 Pre-paid cards

Where a pre-paid card is issued under GaulBridge's card programme with its regulated card partner, additional card-specific terms, limits and fees will be provided at the time of card issuance. Cards are subject to spending limits, jurisdictional restrictions, and the terms of the card programme.

4.5 Batch payments

Business clients may submit batch payments for processing. Batch files must meet our specified format requirements. We are not responsible for errors arising from incorrect data you submit. Cut-off times apply to batch submissions and are communicated in your account portal.

4.6 Third-party services

Some services, including card programmes and merchant acquiring, are delivered in whole or in part by regulated third-party partners. Their terms and conditions will also apply to those specific services, and we will make them available before you use the relevant service.

5.  Fees and charges

5.1 Our fees

Our fees are set out in your account portal, confirmed in writing at onboarding, and described on our Fees & Pricing page at gaulbridge.com/fees-and-pricing. Our FX margin is typically 0.5%–2% over the mid-market rate, depending on volume and corridor. Fees may include:

• Transfer fees (fixed or percentage-based, depending on corridor and amount)
• FX spread (the difference between the mid-market rate and the rate applied to your transaction)
• Card fees (issuance, maintenance, or transaction fees where applicable)
• Account management fees (where separately agreed)
• Fees for additional or bespoke services, agreed in writing

5.2 No hidden fees

We will always show you the total cost of a transaction — the exchange rate, our FX margin and any transfer fee — before you confirm it. Correspondent or receiving-bank charges outside our control may apply and are flagged where known (see 5.3). If the fee structure changes, we will give you at least 30 days' notice.

5.3 Third-party costs

Some payments may attract correspondent banking charges or local receiving bank charges outside our control. Where we are aware of such charges, we will disclose them. Where unknown in advance, we will note that third-party charges may apply.

5.4 Deduction of fees

We may deduct fees directly from your GaulBridge account balance or from the transaction amount. The exact method will be shown at the point of transaction confirmation.

6.  Payment execution and timelines

6.1 How we process payments

When you submit a payment instruction, we process it subject to:

• Successful completion of required sanctions and compliance screening
• Sufficient available funds in your account
• Our cut-off times for same-day processing
• Applicable regulatory requirements

6.2 Execution timeframes

We aim to process payments as follows:

• Domestic Canadian payments (CAD): same business day or next business day
• International SWIFT transfers: typically 1–3 business days depending on the destination
• Interac e-Transfers: typically within minutes during business hours
• FX conversions: executed at the time you confirm the transaction

These are target timeframes. Some payments may take longer due to correspondent banking requirements, public holidays, regulatory holds, or factors outside our control. We will notify you of any delays where we are aware of them.

6.3 Cut-off times

Payment instructions received after our published cut-off time on a business day will be processed on the next business day. Cut-off times are displayed in your account portal and may vary by payment type and currency corridor.

6.4 Irrevocability

Once a payment instruction has been submitted and confirmed, it cannot be cancelled or amended unless we have not yet processed it. If you need to recall a payment already processed, we will make reasonable efforts to assist but cannot guarantee recovery. Third-party charges may apply to recall requests.

6.5 Failed or rejected payments

If a payment is rejected by a receiving bank or returned for any reason, we will return the funds to your GaulBridge account after deducting any charges incurred, and will notify you of the rejection and the reason where provided.

6.6 Information accompanying transfers

Every electronic funds transfer we send must carry the originator's name, address and account or reference number and the beneficiary's name and account or reference number, as required by the PCMLTFA Regulations. You must give us this information when you instruct a payment. Transfers we receive without the required originator or beneficiary information may be held, returned or rejected while we take reasonable measures to obtain it.

7.  Your responsibilities

7.1 Accuracy of instructions

You are solely responsible for the accuracy of all payment instructions you submit, including recipient account details, IBANs, SWIFT/BIC codes, and amounts. GaulBridge executes instructions as provided and is not liable for losses arising from incorrect instructions.

7.2 Account security

You must keep your account credentials secure and not share them with any unauthorised person. You must notify us immediately at support@gaulbridge.com if you suspect your account has been compromised, accessed without authorisation, or if your credentials have been lost or stolen.

7.3 Lawful use

You agree to use GaulBridge's services only for lawful purposes and in compliance with all applicable laws, including anti-money laundering, sanctions, and tax laws. You must not use our services to process proceeds of crime, evade sanctions, or facilitate fraud or financial crime.

7.4 Keeping us informed

You must promptly notify us of any material changes to your circumstances, including changes to your business structure, ownership, beneficial owners, registered address, or the nature of your activities.

7.5 Business clients — authorised users

If you are a business client, you are responsible for ensuring all individuals who access your account are authorised to do so and are aware of these Terms. You are liable for all actions taken by authorised users on your account.

8.  Compliance, AML and sanctions

8.1 Our obligations

GaulBridge is subject to anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance obligations under Canadian law, including the PCMLTFA and RPAA, and international standards. We maintain the compliance programme the PCMLTFA Regulations require: an appointed Compliance Officer with the authority and resources to implement it, written and current policies and procedures, a documented business-based risk assessment of our products, services, delivery channels, clients and geographies, ongoing training for our staff, and an independent review of the programme's effectiveness at least every two years, documented with findings and a follow-up action plan. Our Compliance Officer can be contacted at compliance@gaulbridge.com.

8.2 Screening

We screen all clients, beneficial owners, counterparties and transactions at onboarding, on every transaction, on a periodic basis and whenever a list is updated, against Canadian sanctions and terrorist-listing instruments — the Special Economic Measures Act (SEMA), the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), regulations made under the United Nations Act, the Freezing Assets of Corrupt Foreign Officials Act and the Criminal Code list of terrorist entities — and against the lists maintained by OFAC, the UN Security Council, the EU and the UK. Where a match is confirmed we freeze the property, refuse the transaction and make the disclosures the law requires. We may delay, block, or refuse any transaction that fails our screening processes.

8.3 Reporting obligations

We are required by law to report to FINTRAC: suspicious transactions and attempted transactions (STR), as soon as practicable once we have reasonable grounds to suspect; large cash transactions of CAD 10,000 or more (LCTR); international electronic funds transfers of CAD 10,000 or more, including two or more transfers made by or for the same person within 24 hours that together total CAD 10,000 or more (EFTR); large virtual currency transactions (LVCTR); and terrorist property (TPR). Transactions involving jurisdictions or entities subject to a Ministerial Directive under Part 1.1 of the PCMLTFA are subject to the enhanced measures and reporting those Directives require. We may be prohibited by law from disclosing that a report has been made.

8.4 Account restrictions

We may restrict, suspend, or close your account without notice if required by law or regulation, or if we suspect your account is being used in connection with financial crime, fraud, or sanctions violations. Where legally permitted, we will notify you.

9.  Digital asset services

GaulBridge does not currently offer digital asset services. Where GaulBridge has entered into a separate written agreement with a client for such services, that agreement governs. Nothing on our website or in our communications is a recommendation to buy, sell, hold or use any digital asset.

10.  Errors, disputes and complaints

10.1 Reporting errors

If you believe an error has occurred — including an unauthorised transaction, incorrect amount, or failed payment — notify us as soon as possible and in any event within 13 months of the transaction date by contacting:

Please include your account details, the transaction reference, the date, the amount, and a description of the issue.

10.2 How we handle complaints

We take every complaint seriously. Here is how the process works:

• Acknowledgement: we will acknowledge your complaint within 5 business days of receipt
• Investigation: we will investigate promptly and fairly, keeping you informed of progress
• Resolution: we aim to provide a full response within 30 business days. In complex cases this may extend to 90 calendar days, and we will let you know if that applies
• Outcome: we will provide a clear written response explaining our findings and any action we will take

10.3 Escalation

If you are not satisfied with our final response, or if we have not resolved your complaint within 90 calendar days, you may:

• Ask for your complaint to be escalated to our Compliance Officer at complaints@gaulbridge.com
• If you are a consumer in British Columbia, contact Consumer Protection BC under the Business Practices and Consumer Protection Act (www.consumerprotectionbc.ca), or the consumer-protection authority in your province or territory
• For complaints about how we handle your personal information, contact the Office of the Privacy Commissioner of Canada (www.priv.gc.ca)
• Clients outside Canada may also have rights before their local consumer-protection authority

FINTRAC supervises our compliance with the PCMLTFA and the Bank of Canada supervises our compliance with the RPAA. You may raise regulatory concerns with either body, but neither resolves individual client complaints.

10.4 Our liability for errors

Where we are responsible for an error in processing a payment, we will — at your election — either re-execute the payment correctly or refund the amount of the incorrect transaction together with any charges directly caused by the error. Our liability is limited as set out in Section 12.

11.  Account statements and records

Transaction records and account statements are available in your GaulBridge account portal. You should review your statements regularly and notify us promptly of any discrepancies. We retain records in accordance with the PCMLTFA and its Regulations: transaction records for at least five years from the date of the transaction, and client identification, account and ongoing-monitoring records for at least five years from the day the account is closed or the business relationship ends.

12.  Limitation of liability

12.1 What we are responsible for

GaulBridge is responsible for executing your payment instructions correctly and for maintaining appropriate security standards. If we fall short, we will work promptly to put things right.

12.2 What we are not responsible for

To the fullest extent permitted by applicable law, GaulBridge is not liable for:

• Losses arising from incorrect payment instructions provided by you
• Delays or failures caused by third-party banks, correspondent institutions, or payment networks
• Losses from events outside our reasonable control, including systems outages at third-party providers, force majeure events, or regulatory actions
• Losses arising from your failure to keep your account credentials secure
• Indirect, consequential, or economic losses, including loss of profit, loss of business, or reputational damage

12.3 Cap on liability

Where we are found liable, our total aggregate liability in respect of any claim or series of related claims shall not exceed the greater of: (a) the total fees paid by you to GaulBridge in the 12 months preceding the claim, or (b) CAD 10,000 — except in cases of fraud, wilful misconduct, or where liability cannot be limited by applicable law. For consumer clients, nothing in this Section limits any right under the Business Practices and Consumer Protection Act (British Columbia) or any end-user protection under the RPAA that cannot be excluded or limited by agreement.

12.4 Indemnity

You agree to indemnify and hold GaulBridge harmless from any claims, losses, costs, or liabilities arising from your breach of these Terms, your misuse of our services, or any unlawful instructions or conduct on your part.

13.  Data protection and privacy

GaulBridge processes your personal data in accordance with applicable data protection laws, including PIPEDA (Canada), the GDPR (EU), and the UK GDPR, as applicable. Our Privacy Policy explains how we collect, use, share, and protect your data, and sets out your rights. You can read it at gaulbridge.com/privacy-policy.

By using our services, you agree to the collection and use of your data as described in our Privacy Policy. We process personal data only where we have a lawful basis to do so, including to perform this contract, comply with legal obligations, and pursue our legitimate interests.

14.  Intellectual property

All content, software, technology, trademarks, and materials on the GaulBridge platform and website are owned by or licensed to GaulBridge. You may not copy, reproduce, distribute, or create derivative works from any part of our platform without our prior written consent. Your right to use our services is a limited, non-exclusive, non-transferable licence that may be revoked if you breach these Terms.

15.  Confidentiality

Each party agrees to keep confidential any non-public information received from the other in connection with these Terms, and not to disclose it to any third party without prior written consent, except as required by law or regulation, or as necessary to perform the services. This obligation survives termination of these Terms.

16.  Suspension and termination

16.1 Closing your account

You may close your account at any time by contacting us at support@gaulbridge.com. We will process any pending transactions and return any remaining balance, less outstanding fees, within a reasonable timeframe.

16.2 Our right to suspend or close

We may suspend or close your account with immediate effect and without prior notice if:

• We are required to do so by law, regulation, court order, or regulatory direction
• We reasonably suspect your account is being used for fraud, money laundering, terrorist financing, sanctions evasion, or other financial crime
• You provide false or misleading information at any point
• You fail to complete required KYC or due diligence requests within a reasonable timeframe
• You breach these Terms in a material way

Where legally permitted, we will give you notice of the closure and the reason. For closures not caused by the above, we will provide 60 days' notice.

16.3 Effect of termination

On termination, pending payment instructions not yet processed may be cancelled. We will return any remaining funds after deducting outstanding fees and amounts owed to us. Sections 8, 12, 13, 14, 15, and 19 of these Terms survive termination.

17.  Communications

We will communicate with you primarily by email to the address registered on your account, or through notifications in your account portal. It is your responsibility to keep your contact details up to date. Notices sent to your registered email address are deemed received on the day they are sent.

For support: support@gaulbridge.com. For complaints: complaints@gaulbridge.com. For compliance or regulatory enquiries, contact our Compliance Officer: compliance@gaulbridge.com.

18.  Force majeure

GaulBridge will not be liable for any failure or delay in performing its obligations where that failure or delay is caused by circumstances beyond our reasonable control, including acts of God, war, pandemic, government action, regulatory change, industrial disputes, or failure of third-party infrastructure. We will take reasonable steps to resume performance as soon as practicable.

19.  Governing law and jurisdiction

These Terms are governed by and construed in accordance with the laws of the Province of British Columbia and the federal laws of Canada applicable therein.

Any dispute arising from these Terms or your use of our services that cannot be resolved through our complaints process (Section 10) shall be referred to the courts of British Columbia, Canada, which shall have non-exclusive jurisdiction. Clients in other jurisdictions may also have rights under local mandatory law, and nothing in these Terms limits such rights.

20.  General

20.1 Entire agreement

These Terms, together with the related documents in Section 2.2, constitute the entire agreement between you and GaulBridge regarding our services and supersede all prior representations, agreements, or understandings.

20.2 Severability

If any provision of these Terms is found to be unlawful or unenforceable, it will be modified to the minimum extent necessary or severed. The remaining provisions continue in full force and effect.

20.3 No waiver

A failure by GaulBridge to enforce any provision of these Terms does not constitute a waiver of that provision or of our right to enforce it in the future.

20.4 Assignment

You may not assign or transfer your rights or obligations under these Terms without our prior written consent. GaulBridge may assign these Terms to a successor entity in connection with a merger, acquisition, or sale of substantially all of its assets, provided your rights are not materially diminished.

20.5 Third-party rights

These Terms are between GaulBridge and you only. Nothing in these Terms confers any rights on any third party.

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Contact us

If you have any questions about these Terms or our services, please get in touch:

• General support: support@gaulbridge.com
• Complaints: complaints@gaulbridge.com
• Compliance Officer: compliance@gaulbridge.com
• Post: GaulBridge Ltd., 301 - 401 W Georgia St, 5th Floor, Vancouver, BC, V6B 1Z3, Canada
• Website: www.gaulbridge.com

We aim to respond to all enquiries within 2 business days.