1. Introduction & Scope
This Payment Policy (the “Policy”) governs all payments processed by GREMBIS LIMITED Corporation and made via the GREMBIS Widget Integration (the “Widget”). It forms an integral part of the Terms of Use, Public Offer, AML/KYC Policy, Privacy Policy, Risk Disclosure and Dispute Resolution Policy. By initiating a payment, the User acknowledges and accepts this Policy.
2. Definitions
“Cryptocurrency, Virtual Currency, Virtual Asset” means a cryptographically secured digital expression of value or contractual rights that uses distributed ledger technology and can be transmitted, stored and displayed electronically. For the purposes of this Policy, the terms ‘Virtual Asset’, ‘Cryptocurrency’ and ‘Virtual Currency’ are used interchangeably.
“User” means any individual or legal entity who uses the Widget or Wallet services of GREMBIS and has agreed to the applicable Terms of Use and this Policy.
“Offer” means the quotation of price and amount of digital assets available for purchase or the offer to credit purchased digital assets to the User’s Wallet or the offer to transfer digital assets from the Wallet to an external address.
“Wallet” means the digital wallet provided within the GREMBIS platform. Digital Wallet means software or service that provides access to one or more blockchain addresses, enabling the User to view balances, initiate transactions, and interact with distributed ledger technology.”
“Expiry” means the lapse of the 15-minute validity of an Offer.
“Payment Method” means any supported card or account used for payment.
“Technical Failure” means any error in processing due to system or network malfunction.
“Administrative Fee” means a fee applied by GREMBIS for processing refunds or reversals.
“Open Banking Transaction” means a transaction initiated directly from a User’s bank account via open banking rails.
3. Processing Partners
Fiat payment processing, refunds, and chargebacks are carried out exclusively by licensed third-party Payment Service Providers (PSPs) engaged by GREMBIS.
The specific PSP applicable to a transaction will depend on the Payment Method chosen by the User. GREMBIS shall make available information about the relevant PSP to the User at or before the moment of payment. GREMBIS bears responsibility only for the digital asset leg of the transaction, whereas fiat processing, refunds, and chargebacks are governed by the terms of the applicable PSP.
4. General Payment Principles
All payments are processed in EUR. If the User’s Payment Method is denominated in another currency, conversion is executed by the issuing bank. GREMBIS discloses all applicable fees to the User before completion of a transaction.
All fiat payments (card, bank transfer, open banking) are processed in EUR by GREMBIS’s authorized Payment Service Providers (the “PSPs”). GREMBIS does not provide fiat payment services directly. If the User’s Payment Method is denominated in another currency, conversion is executed by the issuing bank in accordance with its rules.
5. Payment Flow
Offer Display. The Widget displays the Offer, including the EUR amount, applicable fees, and quantity of digital assets.
Validity. Offers remain valid for fifteen (15) minutes. Upon expiry, transactions are cancelled and funds refunded.
After successful payment, the User must confirm acceptance to receive digital assets in the Wallet. If unconfirmed, funds are refunded. GREMBIS may auto-accept Offer after Expiry.
To transfer assets from the Wallet, the User must accept Offer. If the User does not act within fifteen (15) minutes, Offer may be auto-accepted. If insufficient assets are available, the transaction is cancelled and refunded.
6. Processing Timelines
Digital assets shall be credited to the User’s Wallet within one (1) hour after successful payment and confirmation of Offer. Transfers under Offer shall be executed promptly after confirmation or auto-acceptance.
Travel Rule Requirements for Virtual Currency Transfers
For transfers of virtual currency equivalent to CAD $1,000 or more, Canadian law requires GREMBIS to collect and include:
- Your full name, address, and account/reference number
- The beneficiary's full name, address, and wallet address
What You Need to Provide:
When requesting a transfer of CAD $1,000 or more in virtual currency, you must provide:
- Complete beneficiary information (full name and address of the person/entity receiving the funds)
- Purpose of the transfer
- Source of funds (if requested)
Transfers to Self-Hosted Wallets: If you are transferring to your own self-hosted (non-custodial) wallet, you must confirm that you are the beneficial owner of the destination wallet address.
Important: Failure to provide complete and accurate information may result in:
- Delay or suspension of your transfer
- Cancellation of the transaction
- Account restrictions
7. Refund Triggers
Refunds may occur if:
(i) an Offer expires;
(ii) the User refuses Offer;
(iii) a Technical Failure occurs; or
(iv) insufficient Wallet funds prevent execution.
For the detailed refund procedure, eligibility criteria, and terms, please refer to the GREMBIS Refund Policy or Partner's Refund Policies.
Market Volatility & Refund Amount: The User acknowledges and agrees that the value of digital assets is highly volatile.
All refunds are processed in EUR for the exact amount of the original transaction.
Under no circumstances will the refund amount be adjusted based on the current market value of the digital assets that were the subject of the cancelled or failed transaction.
Refunds of fiat payments, including chargebacks, are governed by the terms and conditions of the relevant PSP.
GREMBIS is responsible solely for ensuring that, once fiat refunds are confirmed by the PSP, the corresponding digital asset transaction is cancelled or reversed as appropriate.
8. Fees and Charges
GREMBIS may apply transaction fees, disclosed before execution. Refunds may incur an Administrative Fee. Bank and network charges are borne by the User. Blockchain fees are non-refundable.
9. Fraud and Risk Controls
GREMBIS may suspend or freeze transactions in cases of suspected fraud, chargeback risk, or regulatory alerts. Users may be required to submit additional verification.
10. AML/KYC Compliance
All transactions are subject to GREMBIS’s AML/KYC Policy and Canadian anti-money laundering legislation. GREMBIS may withhold, suspend or cancel transactions pending compliance checks, including:
- - Customer identity verification
- - Source of funds verification
- - Sanctions screening
- - Risk assessment
- - Enhanced due diligence (where required)
As a Money Services Business registered with FINTRAC, GREMBIS is legally required to report certain transactions to Canadian authorities:
Large Virtual Currency Transactions: When you receive virtual currency equivalent to CAD $10,000 or more in a single transaction, or multiple transactions totaling CAD $10,000 or more within 24 hours, we are required to report this to FINTRAC within 5 business days.
Suspicious Transactions: If we have reasonable grounds to suspect a transaction is related to money laundering or terrorist financing, we must report it to FINTRAC as soon as practicable.
What This Means for You
- These reports are submitted by GREMBIS directly to FINTRAC and are not sent to you
- We cannot inform you whether we have submitted, or intend to submit, such reports
- Asking about these reports or attempting to obtain information about them may result in denial of service
- Submitting these reports is a legal obligation and does not mean you have done anything wrong.
11. Excluded Territories
GREMBIS shall not process transactions for Users located in, or transferring funds to/from restricted territories due to:
- Canadian sanctions laws
- Ministerial Directives issued under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act
- International sanctions and embargoes
- High-risk jurisdictions identified by FINTRAC.
For the most current list of restricted jurisdictions, please contact us at aml@grembispay.com
The User undertakes not to:
- Provide accurate information about your location and residence
- Not use VPNs, proxies, or other technical means to circumvent geo-blocking measures
- Not transfer digital assets to addresses in prohibited jurisdictions
- Inform GREMBIS immediately if your residence status changes.
If GREMBIS determines that you:
- Are located in a restricted territory
- Have provided false location information
- Are attempting to circumvent restrictions
We will:
- Immediately suspend or terminate your account
- Freeze pending transactions
- Report the activity to FINTRAC (if required)
- May be unable to return your funds if prohibited by law.
All transactions are screened against:
- Canadian sanctions lists
- United Nations sanctions lists
- International terrorism lists
- Politically Exposed Persons (PEP) databases
This screening may cause delays in transaction processing.
12. Technical Failures
In the event of a Technical Failure, GREMBIS shall take reasonable measures to restore functionality and inform affected Users. GREMBIS shall not be liable for delays beyond its control.
13. User Obligations
The User shall provide truthful information, use the Widget in compliance with law, and refrain from abusive or fraudulent activity.
14. GREMBIS Rights
GREMBIS reserves the right to suspend, cancel or withhold payments; require additional information; impose limits; or terminate access for breach, fraud, AML issues or legal restrictions.
15. Liability Allocation
GREMBIS’s liability is limited to direct damages not exceeding fees paid in the prior twelve (12) months
No liability shall arise for indirect or consequential losses. Liability exclusions do not apply to fraud or wilful misconduct.
GREMBIS shall not be liable for delays, errors, or disputes arising from the fiat payment process, including refunds and chargebacks, which are subject to the applicable PSP’s terms and regulatory obligations.
GREMBIS’s liability is limited to the provision of digital asset services under this Policy.
16. No Right of Cancellation for Digital Assets
The User, being a consumer in the European Union, expressly agrees that the supply of digital assets (cryptocurrencies) begins immediately after the successful execution of the transaction (Offer). By confirming the transaction, the User explicitly consents to the immediate performance and acknowledges that he/she will thereby lose the right to withdraw from the contract under Article 16(m) of Directive 2011/83/EU.
17. Force Majeure
GREMBIS shall not be liable for failures due to events beyond its reasonable control, including natural disasters, war, government action, or telecom failures.
18. Governing Law & Dispute Resolution
This Policy is governed by Canadian law. Disputes shall be resolved under GREMBIS’s Dispute Resolution Policy.
19. Final Provisions
This Policy may be amended. The latest version on the GREMBIS website shall prevail. Invalid provisions shall not affect the enforceability of the remainder
20. Contact
Email: aml@grembispay.com
Phone: +1 450 322-0118