GFT PAY INC.

CARDHOLDER TERMS & CONDITIONS

Effective: April 1, 2026

1. Parties and Definitions

These Terms govern your use of the prepaid card, associated prepaid account, and related services (collectively, the “Card”).

The Card is issued by Florida Capital Bank, N.A., Member FDIC (“Bank”), pursuant to a license from Discover Network.

GFT Pay Inc. (“GFT,” “we,” “us,” or “Program Manager”) provides program management and customer support services on Bank’s behalf.

“You” and “Cardholder” mean the person who uses the Card. If you receive a Card from someone else, you become a Cardholder when you activate or use it.

“Applicable Law” means all applicable federal, state, and local laws, rules, and regulations, and applicable payment network rules.

2. Eligibility

If you are creating an account or registering with the Service, you represent that you are at least 18 years of age and have the legal capacity to enter into these Terms. If you received a Card from another person and are using it without registering an account, you represent that the adult who provided the Card to you has accepted these Terms and is responsible for your use of it. GFT does not knowingly collect personal information from individuals under 13 in connection with account registration; any such information inadvertently collected will be deleted promptly and handled in accordance with our Privacy Policy. Certain programs may have additional eligibility requirements disclosed at the point of purchase.

3. Activation, Registration, and Wallet Provisioning

• Digital wallet required. To use the Card, you must add it to a supported digital wallet (Apple Pay or Google Pay) on a compatible device.
• Information you provide. During activation/registration, you may be asked to provide your name, mobile phone number, and email address, along with device authentication. When you add value to your Card for the first time through the GFT app or website, we may also use this information to verify your identity before the transaction is completed, which may include sending a one-time code to your mobile phone number.
• SMS and RCS messaging. By providing your mobile phone number during registration, you consent to receive transactional messages such as card activation notifications, purchase receipts, and balance alerts. If you separately opt in, we may also send promotional messages such as special offers and reward notifications. Message frequency varies. Message and data rates may apply. Reply STOP or QUIT to cancel; you will receive a confirmation and no further messages will be sent. Reply HELP for assistance.
• Electronic Records Consent. Your use of the Card is subject to our Electronic Signatures Disclosure and Consent, which is provided to you separately and governs our right to deliver legally required communications electronically.
• Device and account security. You are responsible for maintaining the security and confidentiality of your device, wallet credentials, and any codes, passkeys, or biometric credentials used to access the device or Card.
• Biometric authentication. Access to your Card account number and details within the GFT app requires biometric verification (such as Face ID or fingerprint) or device passcode. Payments made through a linked digital wallet (Apple Pay or Google Pay) are also subject to that wallet’s biometric or passcode authentication requirements. A transaction completed following successful authentication through the GFT app or a linked digital wallet is deemed authorized by you, unless you had previously reported the linked device as lost or stolen in accordance with Section 12.
• One account per wallet. GFT limits active Card accounts to one per digital wallet account. We reserve the right to limit, suspend, or decline to activate additional accounts associated with the same digital wallet account or device.

If you do not provide information we request, or if information you provide cannot be verified as required, we may decline activation, suspend use, or limit features of the Card as permitted by Applicable Law.

4. Using Your Card

• Acceptance. The Card may be used wherever Discover is accepted, subject to any program restrictions described to you at purchase or in-app. Outside the United States, acceptance may also occur through the Diners Club network.
• Primary U.S. Use. The Card is intended primarily for use in the United States. You may use the Card internationally where permitted; however, we may monitor transactions and restrict or decline transactions that are inconsistent with this intended primary U.S. use or that raise fraud, sanctions, or compliance concerns.
• Merchant and category restrictions. Information about program-specific merchant or category restrictions will be disclosed at the point of purchase and may be available in-app. Transactions outside permitted uses may be declined.
• No cash access. The Card may not be used for ATM withdrawals, cash advances, or cash back, and cannot be redeemed for cash except where required by Applicable Law.
• Split tender. If your Card balance is insufficient to pay for a purchase, you may need to pay the remainder using another payment method. Not all merchants support split tender, in which case your transaction may be declined.
• No recurring billing unless allowed. Recurring or subscription payments may be declined unless we explicitly enable such transactions for your program.

We may decline any transaction that we believe is unauthorized, suspicious, unlawful, or presents risk to the Card, Bank, GFT, merchant, or the payment networks.

5. Loading Value and Limits

You may add value to the Card at the time of purchase or through other approved channels that we make available. Availability of reload, gifting, transfers, or other features may vary by program.

• Purchase information. When you purchase or add value to the Card, you may be asked to provide your billing address or ZIP code, which we may rely on for state law compliance purposes including unclaimed property reporting.
• Per-Card daily activity limit. For most programs, no more than $2,000 in total activity may be associated with a single Card in a single day. “Total activity” includes adding funds, purchases, refunds/credits, transfers (if available), and other debits and credits.
• Maximum balance. We may limit the maximum value that may be held on a Card at any time.
• Aggregate limits. We may also apply limits across multiple Cards or accounts linked to you (for example, daily purchase or limits on adding funds across all Cards), and we may change any limits at any time as permitted by Applicable Law.
• Additional verification for higher limits. If you request limits above those permitted without additional verification, we may require you to provide additional information and complete identity verification (including as required by Bank policies, payment network rules, or Applicable Law) before we allow higher limits or additional functionality.
• No cash loads. Cash or currency deposits are not permitted unless we expressly state otherwise.

Additional limits on Card usage may be implemented at any time to comply with Applicable Law, payment network rules, or Bank policies, including controls to mitigate fraud and financial crime.

6. Fees

Fees may apply depending on the Card program and how you use the Card. Any fees that apply to you will be disclosed at purchase or in-app before you complete the relevant transaction, as required by Applicable Law.

• Foreign transaction fees may apply for transactions outside the United States.
• We do not charge interest on any Card balance.
• We do not charge dormancy, inactivity, or maintenance fees unless disclosed to you as required by Applicable Law.

7. Authorizations, Preauthorizations, and Holds

When you use the Card, some merchants (and payment networks) may request authorization for a transaction amount and may place a hold on your available balance.

• How holds work. A hold reduces your available balance by the authorized amount until the merchant completes (settles) the transaction or releases the hold.
• Estimated amounts. Some merchants may authorize an amount greater than your purchase amount (for example, restaurants, hotels, car rentals, fuel dispensers, or other merchants with tips or incidental charges). For international transactions, the amount converted to U.S. dollars at settlement may also differ from the amount at authorization due to exchange rate movement. See Section 8 for details.
• Timing. Release times vary by merchant and network rules and may take several days. We do not control how quickly a merchant releases a hold.
• Activation holds on new accounts. For accounts that have not previously had a customer-funded load, we may impose a short hold before loaded funds are available to spend. The duration of any such hold will be disclosed to you at the time of the transaction. This hold applies only to customer-funded loads and does not apply to value loaded by a merchant or program sponsor on your behalf.
• Partial approvals. Some merchants may support partial approvals. If not, a transaction may be declined if the full amount is not available.

You are responsible for ensuring sufficient available balance for authorizations and holds.

8. Foreign Transactions and Currency Conversion

If you use the Card for a transaction in a currency other than U.S. dollars, the transaction amount will be converted to U.S. dollars by the payment network at a rate determined at the time of settlement, which may differ from the rate at the time of authorization. Additional fees may apply, and the final converted amount may differ from estimates shown at the time of purchase. Because exchange rates can shift between authorization and settlement, we may apply an internal buffer when evaluating whether to approve or decline an international transaction — meaning we may decline a transaction even if your available balance equals or exceeds the authorization amount, if we determine it may be insufficient to cover the final settled amount. This is not a fee; it is a risk management control applied at our discretion.

9. Receipts, Balance Information, and Transaction History

• Receipts. Merchants may provide receipts for Card purchases. Keep your receipts.
• Balance. You may check your balance and transaction history through features we make available in-app or via other disclosed channels.
• Review. Review your transaction history regularly and report issues promptly.

10. Error Resolution and Unauthorized Transactions (Regulation E)

This section applies only if and to the extent your Card program is subject to the Electronic Fund Transfer Act and Regulation E (“Regulation E”). Reg E applies to Cards that are reloadable by the consumer. Cards that are not reloadable by the consumer and were not provided as payroll or government benefits are not subject to Reg E.

If Regulation E applies, you may have certain rights regarding error resolution and unauthorized transactions. To report an error or unauthorized transaction, contact us at support@gftpay.com or call (877) GFT-PAY1 / (877) 438-7291 as soon as possible. Provide: (i) your name and contact information; (ii) information sufficient to identify the Card; (iii) a description of the error; and (iv) the date and amount of the transaction you believe is in error.

• Timing. Tell us as soon as you can, but no later than 60 days after you learn of the issue or after the issue appears in your transaction history.
• Our investigation. We will investigate your claim, which may include requesting additional information. We may ask you to provide your claim in writing.
• Provisional credit. If required by Regulation E, we may provide provisional credit while we complete our investigation.
• Investigation timeframe. We will complete our investigation and report results within timeframes required by Regulation E and payment network rules. If we need more time, we may extend the investigation as permitted by Regulation E.
• Dispute outcomes. Our obligation is to investigate your claim and notify you of the outcome within required timeframes, not to automatically credit your account. We may deny a dispute where our records show that the transaction was authenticated via biometric or passcode verification on a device not reported as lost or stolen prior to the transaction, or where transaction data or other available evidence corroborates that the transaction was consistent with authorized use. We will notify you of any denial and the basis for it as required by Applicable Law.

11. Non-Regulation E Disputes; Network Deadlines

For any claim, complaint, or dispute not governed by Regulation E, you agree to notify us as soon as possible and in any event within 60 days after the transaction or event first appears in your transaction history or you otherwise become aware of it. Failure to provide timely notice may impair our ability to investigate and may result in denial of the claim to the extent permitted by Applicable Law and payment network rules. To notify us, contact us at support@gftpay.com or call (877) GFT-PAY1 / (877) 438-7291.

You acknowledge that payment network rules impose strict deadlines for disputes and chargebacks. Even if you notify us within the timeframe above, we may be unable to pursue recovery if network deadlines have passed. We are not responsible for missed network recovery opportunities caused by delayed notice or incomplete information from you.

12. Lost, Stolen, or Compromised Cards, Devices, and Credentials

If you believe your Card, device, or wallet credentials are lost, stolen, compromised, or used without permission, contact us immediately at support@gftpay.com or call (877) GFT-PAY1 / (877) 438-7291.

• Your responsibility. You are responsible for all transactions unless and until you report the issue and Applicable Law provides otherwise.
• Timely reporting. You must report a lost or stolen device promptly. Transactions authenticated on a lost or stolen device after the loss event but before you notify us are your responsibility, and failure to report promptly constitutes a waiver of dispute rights for such transactions to the fullest extent permitted by Applicable Law.
• Replacement. Replacement availability depends on the program and whether we can verify your identity and Card ownership. If a replacement is available, we may issue a replacement Card and transfer any remaining eligible balance, subject to Applicable Law and payment network rules.

13. Fraud, Compliance, and Restrictions

We and Bank monitor transactions and activity for fraud prevention, sanctions compliance, anti-money laundering, and other compliance purposes. We may request information or take action as permitted by Applicable Law, including declining transactions, placing holds, limiting features, suspending access, or closing the Card.

We may share information with Bank, payment networks, service providers, and government authorities as required or permitted by Applicable Law and as described in our privacy disclosures.

14. Business Use, Resale, and Prohibited Activities

The Card is intended for personal, consumer use unless we expressly agree otherwise. You may not:

• resell Cards or use Cards for commercial distribution without our written permission;
• use the Card for unlawful, fraudulent, or abusive purposes;
• use the Card in a way that attempts to circumvent limits, controls, or compliance processes;
• use the Card to purchase other prepaid cards, gift cards, or stored value products without our prior written permission; or
• use the Card for transactions that are prohibited by the payment networks or Applicable Law.

We may suspend or terminate the Card for prohibited activity and may retain or limit access to balances to the extent permitted by Applicable Law and payment network rules to mitigate fraud, chargebacks, or other losses.

15. Promotional Value

From time to time, we or a merchant sponsor may offer promotional value, bonus value, or other incentives. Promotional value may be subject to additional terms (including expiration) that will be disclosed at the time the promotion is offered. Unless otherwise required by Applicable Law, promotional value is generally not redeemable for cash.

16. Expiration and Unclaimed Property (Escheatment)

Your Card may have an expiration date shown in the wallet or associated materials. If an expiration date applies, the Card may expire, but any underlying funds may remain available as required by Applicable Law.

Unused funds may be subject to state unclaimed property laws. If funds are remitted to a state as unclaimed property, your rights to recover those funds are governed by Applicable Law and the state’s unclaimed property process.

17. Privacy

Our privacy practices are described in our Privacy Policy, which is made available through our product and website. By using the Card, you acknowledge that we may collect, use, and share information as described in that Privacy Policy and as required or permitted by Applicable Law.

18. Changes to These Terms

We may change these Terms from time to time as permitted by Applicable Law, including for operational, legal, regulatory, or security reasons. We will provide notice of material changes as required by Applicable Law, which may be delivered electronically through the mobile application, website, or email. Continued use of the Card after the effective date of a change constitutes acceptance.

19. Suspension and Cancellation

We or Bank may suspend, limit, or terminate your Card or access to your Card balance as permitted by Applicable Law and payment network rules, including if we suspect fraud, unauthorized activity, misuse, or legal or compliance risk, or if required by a regulator or payment network.

If your Card is cancelled, we will provide access to any remaining balance as required by Applicable Law and subject to verification, security, fraud prevention, setoff, chargebacks, or other adjustments permitted by Applicable Law and payment network rules.

20. Setoff; Chargebacks; Reversals; Adjustments (Recoupment)

To the fullest extent permitted by Applicable Law and payment network rules, you authorize Bank and/or GFT to:

(a) reverse, correct, or adjust your Card balance for transactions that are reversed, cancelled, declined, disputed, returned, or processed in error (including duplicate postings), and for fees or network adjustments that apply to your Card program; and

(b) deduct from your Card balance any amounts you owe in connection with your use of the Card, including amounts resulting from unauthorized use attributable to your acts or omissions, returns of merchandise where a merchant does not properly process the return, chargebacks, fraud recoveries, or other losses allocable to your Card under these Terms.

If an adjustment causes a negative balance, we may suspend your Card and require you to repay the negative balance before you may continue using the Card, to the extent permitted by Applicable Law. We are not responsible for losses caused by merchants’ failure to properly process reversals or refunds, except to the extent required by Applicable Law.

21. Disclaimers and Limitation of Liability

You acknowledge that you are not relying on any statement not expressly set forth in these Terms. We do not guarantee that the Card will be available at all times, will work at every merchant, terminal, or transaction type, or will be authorized for any particular transaction. Merchant acceptance, network availability, and wallet functionality may vary.

To the fullest extent permitted by Applicable Law, the Card and related services are provided “as is” and “as available,” without warranties of any kind, express or implied, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

We are not responsible for the quality, safety, legality, or any other aspect of goods or services purchased with the Card. Any disputes regarding a purchase should be addressed directly with the merchant, subject to your rights under these Terms.

To the fullest extent permitted by Applicable Law, neither Bank nor GFT will be liable for indirect, incidental, special, consequential, exemplary, or punitive damages, or for lost profits or revenues. To the fullest extent permitted by Applicable Law, the maximum aggregate liability of Bank and GFT related to the Card will not exceed the remaining available balance on the Card at the time of the event giving rise to the claim.

Some jurisdictions do not allow certain limitations; in those jurisdictions, liability is limited to the greatest extent permitted by Applicable Law.

22. Dispute Resolution and Arbitration Agreement

PLEASE READ THIS SECTION CAREFULLY. It affects your legal rights. It provides that most disputes must be resolved by binding individual arbitration, not in court, and includes a class action waiver.

22.1 Mandatory Informal Dispute Resolution (Required Before Arbitration)

Before either party may start arbitration, the party initiating the Dispute must send the other party a written “Notice of Dispute” by email to support@gftpay.com. If the party initiating the Dispute is unable to access email for whatever reason, it may initiate a Notice of Dispute by calling (877) GFT-PAY1 / (877) 438-7291. The Notice of Dispute must include all of the following:

(a) Cardholder’s full name and contact information (email and phone);

(b) information sufficient to identify the Card (including the last 4 digits of the Card or other wallet/Card identifier we request);

(c) the specific transaction(s) or event(s) at issue (date(s), amount(s), merchant name(s), and any relevant reference numbers);

(d) a detailed description of the Dispute and the factual basis for the claim;

(e) the specific relief requested and how the requested amount was calculated;

(f) copies of all supporting documents the Cardholder has in their possession; and

(g) a statement that the sender is the Cardholder (or the Cardholder’s authorized representative) and that the Notice is accurate to the best of their knowledge.

The parties will attempt in good faith to resolve the Dispute informally for sixty (60) days after receipt of a complete Notice of Dispute (the “Informal Resolution Period”), which period may be extended by mutual agreement. Completion of this process is a condition precedent to arbitration. If a Notice of Dispute is incomplete, we may request additional information; the Informal Resolution Period does not begin until we receive a complete Notice of Dispute.

Tolling. To the fullest extent permitted by Applicable Law, any applicable limitations periods are tolled during the Informal Resolution Period.

22.2 Binding Arbitration

If a dispute is not resolved informally, any dispute or claim arising out of or relating to the Card or these Terms (a “Dispute”) will be resolved by binding individual arbitration administered by the American Arbitration Association (“AAA”) under its Consumer Arbitration Rules, as modified by these Terms, and governed by the Federal Arbitration Act.

• Small claims. Either party may bring an individual action in small claims court if it qualifies, so long as it remains in small claims court.
• No class actions. Disputes must be brought in an individual capacity only. The arbitrator may not consolidate claims or preside over any class, collective, or representative proceeding.
• Arbitration location and format. The arbitration will be conducted by telephone, video, or in-person in the county where you reside, unless the parties agree otherwise, or as otherwise required by AAA rules.

22.3 Additional Procedures for Mass Filings

If twenty-five (25) or more similar Disputes are asserted against Bank and/or GFT by the same or coordinated counsel, or are otherwise coordinated, within a 180-day period (a “Mass Filing”), the parties agree to the following procedures to promote efficient resolution and reduce costs. These procedures are essential to the arbitration agreement.

(a) Staged process; bellwethers.

Stage 1: Counsel for the claimants and counsel for Bank/GFT will each select up to ten (10) Disputes (for a total of up to twenty (20)) to proceed first in individual arbitrations (the “Stage 1 Cases”). Stage 1 Cases will be filed and proceed individually.

Stage 2: After final resolution of the Stage 1 Cases (including any settlement or award), the parties will participate in a good faith mediation to attempt to resolve the remaining Disputes.

Stage 3: If Disputes remain after mediation, the parties will meet and confer in good faith on a staged process for additional Disputes to proceed in batches, including the number of cases per batch, sequencing, and whether additional mediation is appropriate.

(b) Filing and fees for non-bellwether claims. Except for the Stage 1 Cases (and any later cases the parties agree to proceed in a later stage), the remaining Disputes in a Mass Filing will not be filed, and arbitration fees will not be assessed or collected for those Disputes until they are selected to proceed pursuant to the staged process.

(c) Tolling. To the fullest extent permitted by Applicable Law, any applicable limitations periods for Disputes subject to a Mass Filing are tolled from the date a complete Notice of Dispute is received under Section 22.1 until the Dispute is selected to proceed in arbitration, settled, withdrawn, or otherwise resolved.

(d) Administrator / severability mechanics. If the arbitration administrator (including AAA) declines to administer a Mass Filing consistent with this Section 22.3, the parties will meet and confer to select an alternative administrator that will do so. If the parties cannot agree, either party may request that a court of competent jurisdiction appoint an administrator that will apply these procedures. If a court determines that these Mass Filing procedures are unenforceable for a particular Dispute, then that Dispute may proceed only in a court of competent jurisdiction (and not in arbitration) to the extent required by Applicable Law.

22.4 Class Action Waiver and Jury Trial Waiver

To the fullest extent permitted by Applicable Law, you and we waive the right to a jury trial and agree that any proceeding (in arbitration or in court) will be conducted only on an individual basis and not as a class, collective, consolidated, private attorney general, or representative action. If any portion of this class action waiver is found unenforceable with respect to a particular Dispute, then that Dispute will proceed in a court of competent jurisdiction (subject to the governing law provisions of Section 23) and not in arbitration, but this waiver will remain in full force and effect for all other Disputes to the maximum extent permitted by Applicable Law.

22.5 Opt-Out

You may opt out of this arbitration agreement by sending an email to support@gftpay.com within 30 days of first accepting these Terms. Your email must include your name, information sufficient to identify your Card, and a clear statement that you want to opt out of arbitration. Opting out will not affect any other provisions of these Terms.

23. Governing Law

These Terms are governed by federal law and, to the extent not preempted, the laws of the State of Florida, without regard to conflict-of-laws principles. Certain fees, expiration rules, or other features described in these Terms may not apply in some states. Where applicable law conflicts with these Terms, the provisions of applicable law will control.

24. Assignment, Severability, and No Third-Party Beneficiaries

Assignment. We may assign these Terms or our rights and obligations in connection with the Card without notice to you, as permitted by Applicable Law. You may not assign these Terms without our prior written consent.

Severability. If any provision of these Terms is found unenforceable, the remaining provisions will remain in effect. Provisions that by their nature should survive will survive termination (including dispute resolution, limitations of liability, and compliance-related provisions).

No Third-Party Beneficiaries. Except as required by Applicable Law or payment network rules, these Terms are for the benefit of the Cardholder, Bank, and GFT only and do not create any third-party beneficiary rights in any other person.

25. Contact and Notices

For customer service and notices under these Terms, contact: