1. Introduction and Scope

1.1. These Terms. These Terms and Conditions (the "Terms") constitute a legal agreement between you ("you" or the "User") and Kestrl Invest Limited ("Kestrl", "we", "us", or "our") governing your access to and use of the Kestrl mobile application (the "App") and the associated technology services (collectively, the "Services").

1.2. Acceptance. By downloading, accessing, or using the App, you confirm that you have read, understood, and agreed to be bound by these Terms. If you do not agree to these Terms, you must immediately cease use of the App and uninstall it.

1.3. Important: Distinction of Services. It is critical that you understand the separation of roles between Kestrl and our regulated partners:

• Kestrl (The App Provider): We provide the technology interface, budgeting tools, informational ethical screening data, and act as an agent for Open Banking services. We do not hold, store, or safeguard your funds.

• AF Payments (The E-Money Issuer): The electronic money account and debit card accessible via the App (the "E-Money Account") are issued and managed by AF Payments Limited ("AF Payments").

Separate Agreement: Your use of the E-Money Account and Card is governed exclusively by the AF Payments Terms and Conditions. By opening an E-Money Account, you enter into a direct contractual relationship with AF Payments.

2. Information About Us

2.1. Corporate Details. Kestrl Invest Limited is a company registered in England and Wales. Our registered office is at Salisbury House, 29 Finsbury Circus, London, EC2M 5SQ.

2.2. Regulatory Status.

• Kestrl: We are a technology provider. For the provision of Open Banking services (Account Information and Payment Initiation), we act as a registered agent of TrueLayer Limited.

• TrueLayer: TrueLayer Limited is authorised and regulated by the Financial Conduct Authority ("FCA") under the Payment Services Regulations 2017 (FRN: 927200).

• AF Payments: AF Payments Limited is authorised by the FCA under the Electronic Money Regulations 2011 (FRN: 900440) for the issuing of electronic money.

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3. How we’ll contact you

The only ways we will contact you are through email, SMS, in-app notifications and through mail to your registered address. We will typically communicate with you through the Kestrl app and most of the time in English.

This is how we will provide any Account information or notify you about fraud or suspected fraud related to your Account. Please ensure you regularly check your Kestrl app for messages from us.

We will give you at least two months’ notice before any changes to this Agreement or fees take effect.

To help us keep your Account safe, download the latest operating software for your mobile device and the latest version of the Kestrl app as soon as they are available.

We will never call you and ask you to move money.

You can contact Kestrl through any of the following;

• Through the in-app chat function. 

• Through our help & FAQs page https://support.kestrl.io/en/

• Or send a letter to Kestrl, Salisbury House, 29 Finsbury Circus, London EC2M 5SQ

In-app chat is our preferred and our fastest means of communication.

4. The Kestrl Services

Subject to your compliance with these Terms, Kestrl grants you a limited, non-exclusive, non-transferable, revocable licence to use the App for the following purposes:

4.1. Visual Interface. The App provides a visual dashboard allowing you to view the balance, transaction history, and status of your E-Money Account held with AF Payments.

4.2. Open Banking Integration. Through our partnership with TrueLayer, the App allows you to:

• Account Information Services (AIS): Connect and view balances and transaction data from your external bank accounts.

• Payment Initiation Services (PIS): Initiate transfer instructions (e.g., "Easy Bank Transfer") from your external bank accounts to load funds into your E-Money Account.

4.3. Insights and Analytics. We provide proprietary analytics, including budgeting categorisation, carbon footprint estimation, and informational ethical spending scores. These insights are for informational purposes only and do not constitute financial, investment, or tax advice.

5. User Eligibility and Security

5.1. Eligibility. To use the App, you must be at least 18 years of age and a resident of the United Kingdom.

5.2. Security Credentials. You are responsible for maintaining the confidentiality of your App login credentials, including your PIN, password, and biometric keys. You must not share your device or credentials with any third party.

5.3. Breach of Security. If you suspect that your App access has been compromised, or if your device is lost or stolen, you must notify us immediately via the in-app chat.

5.4. Card Controls. The App may provide functionality to "freeze" or "unfreeze" your AF Payments debit card. You acknowledge that Kestrl transmits this instruction to AF Payments on your behalf. We are not liable for any delay or failure in executing this instruction caused by network failures, third-party system outages, or AF Payments’ operational constraints.

6. Open Banking Provisions

6.1. Authority. By connecting an external bank account, you explicitly authorise Kestrl (acting as agent for TrueLayer) to access, retrieve, and process your financial data from that external account for the purpose of providing the Services.

6.2. Liability for PIS. When you use the App to initiate a payment (PIS):

• You are responsible for ensuring the accuracy of the payment amount and recipient details.

• Once authorised by you, a payment instruction is irrevocable.

• Kestrl’s liability is limited to the accurate transmission of the instruction to your account servicing payment provider (your bank). We are not liable for delays or rejections by your bank or AF Payments provided we have submitted the instruction to the relevant interface promptly.

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7. The Alif Programme (Beta Testing)

7.1. Nature of the Programme. If you are selected for the "Alif" early adopter programme, you acknowledge that you are using a beta version of the Services which may contain bugs, errors, or feature limitations.

7.2. Feedback. You agree to provide reasonable feedback regarding your experience. Kestrl shall own all right, title, and interest in any feedback, suggestions, or ideas you provide.

7.3. Incentives. Kestrl may, at its sole discretion, offer perks or early access to features for Alif members. These benefits are provided strictly for the duration of your active participation in the programme and may be withdrawn or amended at any time without notice.

8. Rewards and Ethical Screening

8.1. Promotional Rewards. Kestrl may offer discretionary cashback, discounts, or rewards based on your App usage. These rewards:

• Are promotional incentives and do not constitute interest, yield, or a return on savings;

• Are subject to specific eligibility criteria displayed in the App; and

• May be withheld or revoked if we reasonably suspect abuse, fraud, or breach of these Terms.

8.2. Shariah Screening. Data regarding the Shariah compliance of your spending or investments is sourced from third-party advisors (including Amanah Advisors). Kestrl does not warrant the accuracy or completeness of this data. It is provided for informational purposes only and you should rely on your own judgment or seek independent advice.

9. Fees and Charges

9.1. App Fees. Access to the standard features of the App is currently provided free of charge. Kestrl reserves the right to introduce subscription fees for premium features in the future, subject to providing you with reasonable prior notice.

9.2. Third-Party Fees. You acknowledge that your use of the E-Money Account is subject to fees charged by AF Payments (including, but not limited to, foreign exchange fees, ATM withdrawal fees, and card replacement fees). Kestrl has no control over, and is not liable for, fees charged by AF Payments or your external bank.

10. Suspension and Termination

10.1. Termination by You. You may terminate these Terms at any time by deleting the App from your device.

10.2. Termination by Us. We may suspend or terminate your access to the App immediately and without notice if:

• You breach any provision of these Terms;

• AF Payments restricts, suspends, or closes your E-Money Account;

• We are required to do so by law, regulation, or a court order; or

• Your use of the App poses a security risk to our systems or reputation.

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11. Limitation of Liability

11.1. Scope. Nothing in these Terms excludes or limits our liability for death or personal injury arising from our negligence, or for fraud or fraudulent misrepresentation.

11.2. Service Provision. The App is provided on an "as is" and "as available" basis. To the maximum extent permitted by law, Kestrl disclaims all implied warranties of satisfactory quality, fitness for a particular purpose, or non-infringement.

11.3. Exclusion of Liability. Kestrl shall not be liable to you for any loss or damage arising from:

• The E-Money Account: Any act, omission, insolvency, or default of AF Payments, including the failure to safeguard funds or execute transactions.

• Third Parties: The actions or failures of TrueLayer, external banks, or merchants.

• Force Majeure: Events beyond our reasonable control, including telecommunications failures, government actions, or pandemics.

• Indirect Loss: Any loss of profit, loss of business, or indirect, consequential, or special loss.

11.4. Liability Cap. Subject to clause 11.1, our total aggregate liability to you under or in connection with these Terms shall be limited to the amount of fees paid by you in the preceding 12 months, or £100, whichever is greater..

12. Data Protection

12.1. Roles.

• Kestrl: We act as the Data Controller for your profile information, app usage data, and marketing preferences.

• AF Payments: AF Payments acts as a separate Data Controller for your financial transaction data, KYC information, and E-Money Account operation.

12.2. Privacy Policy. Our collection and use of your personal data is governed by the Kestrl Privacy Policy, available in the App and on our website.

13. General Provisions

13.1. Amendments. We may update these Terms from time to time. We will notify you of material changes via the App or email. Your continued use of the App following such notice constitutes acceptance of the updated Terms.

13.2. Severability. If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

13.3. Governing Law. These Terms and any dispute or claim arising out of or in connection with them shall be governed by and construed in accordance with the laws of England and Wales. The courts of England and Wales shall have exclusive jurisdiction.

14. Contact Information

For support regarding the App, please contact us via the in-app chat or through our support page: https://support.kestrl.io/en/.