Brighty App – General Terms and Conditions

These Terms and Conditions (the “T&Cs” or “Terms”), together with any documents incorporated by reference, constitute a legally binding agreement (the “Agreement”) between you (the “User”) and Brighty Digital UAB, registered at Konstitucijos pr. 21, Vilnius 09306, Lithuania (“we”, “us”, “our”, or “Brighty App”) (collectively, the Parties to this Agreement). Please read this document carefully to understand how your account and our services work. If you do not agree to these Terms, you should not access or use our services.

1. Who We Are

Different Brighty App companies: Various entities under the Brighty App brand may provide different services to you, and each may have its own terms. For example, one company may handle cryptocurrency services, while another handles fiat payment services, and you may be subject to different terms depending on the service.

Cryptocurrency services: These are provided by Brighty Digital UAB (incorporated in Lithuania at Konstitucijos pr. 21, Vilnius 09306, reg. no. 306099818). Brighty Digital UAB is registered with the Lithuanian Register of Legal Entities for the provision of cryptocurrency services. It holds authorisation for cryptocurrency exchange and crypto wallet/custodian services issued by the Financial Crime Investigation Service of Lithuania (FNTT) (authorization can be verified on the official register). Please note these cryptocurrency services are overseen by the Lithuanian Financial Crime Investigation Service but are not regulated by the Bank of Lithuania.

Fiat currency payment services: Brighty App does not directly provide any fiat-related banking or payment services. Instead, all fiat functionalities offered within the Brighty Application — including SEPA/SWIFT transfers, IBAN accounts, fiat deposits, and outgoing fiat payments — are made available through partnerships with licensed and regulated third-party Banking-as-a-Service (BaaS) providers. Brighty App acts solely as a technical facilitator, offering users access to these third-party services through the Brighty App interface. We do not act as a bank or a financial institution and do not hold or manage fiat funds.

Terminology: For the avoidance of doubt, Razz Finanzz AG and Brighty Digital UAB are collectively referred to in these Terms as the “Brighty App Companies.”

2. Our Services

Brighty App provides a mobile application (the “Brighty Application”), available on Google Play and the App Store, as well as access through our website. Through the Brighty Application, you can create an account to buy, sell, and manage supported fiat currencies and cryptocurrencies, participate in our earning programs, and apply for or manage virtual and physical payment cards (loading funds onto them as needed).

3. Acceptance of the Terms and Amendments

You are responsible for reading these Terms and determining if you accept them. If you do not agree with these T&Cs, you may not use any of the services offered by Brighty App. By clicking the box “I accept these Terms and Conditions” (or by otherwise indicating your acceptance), you unconditionally agree to be bound by these Terms and any future changes to them.

These T&Cs constitute a legally binding agreement between you and Brighty App and govern your use of our services as they are available via our website (https://brighty.app) and our mobile application. Please read them carefully.

Use of our Application, website, and/or services is limited to individuals who are at least 18 years old and who are legally permitted to form binding contracts under applicable law.

4. Your Account

To use the Brighty Application, you must register with a valid email address and active phone number, set up an account password, and complete our identity verification process.

When signing up, you agree to provide true, current, and complete information about yourself as prompted during registration and in any applicable forms.

If we have reasonable doubt that any information you provided is inaccurate, untruthful, or outdated, we reserve the right to demand that you correct or update it. We may also suspend or terminate your account and refuse any current or future use of our services if you fail to provide accurate information.

You must keep all of the information you provide up to date. You agree to notify Brighty App immediately if any of your registration information changes.

By registering an account, you agree to share personal information required for identity verification. This information will be used to detect and prevent money laundering, terrorist financing, fraud, and other financial crimes on the Brighty App. We will collect, use, and share this information in accordance with our Privacy Notice.

You also agree that we may retain records of your personal information for the lifetime of your account plus five years after account closure, in compliance with industry data retention standards.

5. Anti-Money Laundering and Know-Your-Client

In accordance with applicable anti-money laundering (AML) and counter-terrorist-financing (CFT) laws, you authorize us (or our agents) to make any inquiries or obtain any information necessary to verify your identity, address, source of funds, and other required details. We may retain evidence of your identity in our records from time to time.

You will need to provide valid government-issued proof of identity (such as a passport or ID card) and may be asked to provide proof of address (issued within the last six months), as well as any other documents or information required by our AML policy.

Your identity may be validated by any Brighty App Company. If we cannot verify your identity or the authenticity of your documents, we will refuse to open or may close your Brighty App account.

If you appear on any government or international sanctions list, we will refuse your application for a Brighty App account.

6. Dormancy and Account Closure Policy

Risk-Based Dormancy

Brighty App reserves the right to terminate a user’s account for risk management reasons or due to policy changes. If we do terminate your account on a risk-based approach, we will notify you and give you 14 days to withdraw any remaining funds.

If you do not withdraw your funds within 14 days, we will allow an additional 2-month grace period for withdrawal.

If you still have not withdrawn your funds by the end of the 2-month grace period, we may classify your account as dormant.

Dormant accounts (under this risk-based category) will incur a monthly fee of €5 (or its equivalent in another currency) for each month the account remains dormant.

You can avoid this fee by either withdrawing all funds during the specified withdrawal periods or by contacting Brighty App’s Customer Support for assistance to keep your account active.

Inactivity-Based Dormancy

If you do not log into your Brighty App account for a continuous period of 6 months, your account will be classified as dormant due to inactivity.

Dormant accounts due to inactivity will also incur a monthly fee of €5 (or currency equivalent).

To reactivate your account and avoid further fees, you must either log in and perform at least one transaction, or contact Brighty App’s Customer Support to request reactivation.

Dormancy Due to AML/CFT/Fraud Investigations

If an internal investigation (related to anti-money laundering, counter-financing of terrorism, fraud, or similar issues) is initiated for your account, we may require you to submit additional documentation for compliance.

If you fail to provide the requested documentation within 2 weeks of our request, we reserve the right to begin automatic withdrawals of €500 per month from your account balance.

If your account balance is less than €500, we may withdraw the remaining balance in full.

This measure applies if you have: (a) failed to verify your identity when requested, or (b) failed to provide necessary documentation for compliance purposes.

7. Travel Rule Compliance

To comply with the Travel Rule requirements— Brighty App may be legally required to collect, verify, retain, and transmit specific information regarding certain virtual asset transfers.

Scope of Application

This clause applies to any user of the Brighty App (whether individual or business) who initiates or receives a virtual asset transfer above applicable regulatory thresholds or to/from a regulated Virtual Asset Service Provider (VASP).

Data Collection and Transmission

When engaging in qualifying transfers, Brighty App may be required to collect and securely transmit including but not limited:

Sender (Originator):

• Full legal name

  • Account or wallet identifier
  • Address and/or national ID number or customer reference (as required)

  Recipient (Beneficiary):

  • Full legal name
  • Wallet address or account reference
  • VASP or institution identifier (if applicable)

Such data may be shared with other regulated financial institutions or VASPs involved in processing or receiving the transaction, strictly for compliance with applicable Travel Rule requirements.

User Responsibilities

You must provide accurate and complete beneficiary and transaction information when prompted by the Brighty App.

You are responsible for ensuring that your counterparties (recipients or senders) also provide the required information if relevant.

If required information is not provided or cannot be verified, Brighty App may delay, reject, or block the transaction in order to comply with legal obligations.

Privacy and Data Protection

All data processed under this clause will be handled in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

Please refer to our Privacy Policy for full details on how we protect and use your personal data.

Regulatory Cooperation

Brighty App may also disclose Travel Rule-related data to relevant regulatory, supervisory, or law enforcement authorities when legally required to do so.

8. Security

Account security: You are responsible for keeping your Brighty App account secure. You alone are responsible for all transactions initiated using your account.

Reporting unauthorized use: You must immediately notify us (via support@brighty.app) if you suspect or become aware of any unauthorized use of your account credentials. Upon such notice, we will suspend and/or freeze your account and launch an investigation. This helps minimize any potential damage and protect your data and assets.

Unauthorized transactions: Any unauthorized use of your account may result in financial losses. Brighty App will not be liable for any loss or damage arising from unauthorized use of your account, whether by you or by a third party. It is your responsibility to take precautions to protect your account and personal information.

Safety precautions: We recommend that you follow these practices to help safeguard your account:

• Use a strong, unique password for your Brighty App account.
  • Keep your phone secure (e.g. use a PIN, pattern, or biometric lock).
  • Keep your account password confidential and do not share it.
  • Close the Brighty Application or log out of the website when you are not using it.

9. Eligibility

You must meet the following criteria to create and maintain a Brighty App account:

You must be at least 18 years of age and reside in a country where the Brighty App application is available.

You must successfully complete our identity verification and any required checks (such as anti-money laundering/KYC procedures described above in “Anti-Money Laundering and Know-Your-Client”).

10. Cryptocurrencies and Earning Program

Any cryptocurrency purchases or sales that you make through the Brighty Application will be subject to additional terms found at Brighty App Cryptocurrency Terms and Conditions.

The Terms and Conditions for Brighty App’s Earning Program (including Brighty Earning Vaults) are available at Brighty App Earning Vault Terms and Conditions.

We may offer rewards or promotional programs from time to time. These programs will have separate terms, which will be provided to you when the promotions are available.

11. Termination of Brighty App Account

You may close your Brighty App account at any time by manually closing it in the app or by sending a written request to support@brighty.app. You must send the request from the email address registered with your account.

Your account closure request must include the following information:

• A clear declaration requesting the closure of your Brighty App Account (you may specify a date or state “as soon as possible”).
  • Your full legal name (given name and family name).
  • The IBAN(s) of your Brighty App account from which funds will be withdrawn.
  • If you have any funds remaining, you must provide the IBAN of another bank account (within the SEPA zone, i.e. Eurozone) for us to transfer the remaining balance.

IMPORTANT: Please ensure all provided information is complete and accurate. Missing or incorrect information (especially an incorrect IBAN) may delay processing of your request. Brighty App cannot be held liable for any damages or delays resulting from incorrect information you provide.

After we receive your request, we will confirm in writing that we have initiated the account closure process. The process can take up to 14 days (and potentially longer due to legal or regulatory reasons).

Our termination rights: Brighty App may also terminate, change, suspend, or discontinue access to your account at any time by sending you notice (which may take effect immediately or on a specified date).

We may restrict, suspend, or terminate your account without notice if we believe, in our sole discretion, that you are in breach of these Terms or any other applicable terms, or if we suspect you are involved in fraudulent activity, money laundering, terrorism financing, or other illegal activities.

We may also suspend your account at any time for security reasons or if we suspect unauthorized or illicit use of your account.

We will attempt to give you advance notice of any suspension if possible; otherwise, we will notify you as soon as reasonably practicable.

Effect on cryptocurrency services: If your Brighty App account is terminated or suspended, your access to Brighty App’s cryptocurrency services will also be terminated or suspended (as applicable).

12. Refund Fee in Case of Termination

If Brighty App restricts, suspends, or terminates your account due to a breach of these Terms, other applicable terms, or applicable law (including suspected fraud, money laundering, terrorism financing, or other illegal conduct), we reserve the right to charge a Refund Processing Fee of 20% on any amount refunded to you. This fee will be deducted prior to executing any refund and is intended to cover our administrative, legal, and operational costs incurred during the investigation and termination process.

13. Data Protection and Privacy

Brighty collects and processes your personal data in accordance with applicable data protection laws and regulations.

For full details on how we handle your personal data, please refer to our official Privacy Policy.

14. Remedies

If you breach these Terms in any manner, Brighty App may, in our sole discretion, take one or more of the following actions:

• Contact and/or warn third parties about your actions (including other users, your bank or card issuer, law enforcement, or regulatory authorities).
• Refuse to complete any pending transactions involving your account.
• Fully or partially reverse any transaction or exchange in your account.
• Initiate legal action against you.

15. Your Responsibilities

You are responsible for all charges and other amounts incurred through your use of the Brighty Application at any time, including any amounts that remain outstanding after you stop using the Brighty Application or after your account is suspended or canceled.

You are responsible for complying with all laws, rules, and regulations in your jurisdiction that apply to your use of the Brighty Application. This includes import/export controls, tax obligations, and foreign currency transaction rules. We are not responsible for calculating, collecting, or remitting any taxes you owe as a result of your use of the Brighty App.

16. Intellectual Property

Brighty App owns (or is licensed to use) all intellectual property rights in the Brighty Application and its content, logos, and related materials. You may not copy, imitate, or use any Brighty App intellectual property without our prior written consent.

These Terms do not grant you any intellectual property rights in the Brighty Application, other than the limited right to use the Brighty Application in accordance with these Terms.

17. Customer Support

If you need assistance or have feedback or complaints, please contact our Customer Support at support@brighty.app. We aim to resolve all inquiries within 5-7 business days.

18. Liability and Indemnification

Limitation of liability: In no event will any Brighty App company (including Razz Finanzz AG or Brighty Digital UAB), nor our directors, employees, or agents, be liable to you or any third party for any direct, indirect, incidental, special, or punitive damages. This includes, without limitation, any loss of profit, revenue, data, or other economic loss, arising from your use of the Brighty Application or our website, even if we have been advised of the possibility of such damages.

Aggregate liability cap: In any case, our total liability to you under these Terms (whether in contract, tort, or otherwise) will not exceed the total amount we have received from you through your use of the Brighty Application.

Force majeure: We will not be liable for any loss or damage caused by events beyond our reasonable control, including acts of God, labor disputes, electrical or telecommunications failures, computer or software failures, natural disasters (earthquakes, storms, etc.), government orders or restrictions, acts of terrorism or war, or changes in monetary conditions.

Third-party disputes: To the fullest extent permitted by law, you release us from any responsibility or liability arising out of or related to disputes between you and any third party (such as merchants, banks, or other users).

Indemnification: You agree to indemnify, defend, and hold harmless Brighty App (and our directors, employees, agents, and affiliates) from and against any and all claims, damages, losses, or expenses (including reasonable legal fees) arising from or related to:

• Your use of the Brighty Application;

  • Your obligations or actions under these Terms;
  • Any breach or violation of these Terms by you;
  • Any inaccurate, misleading, or false information or representation you provide to us;
  • Your violation of any third party’s rights (e.g. privacy, publicity, or intellectual property rights);
  • Your violation of any applicable laws or regulations; or
  • Any negligent, unlawful, or willfully misconduct by you.

  We reserve the right to control the defense of any such claim at your expense.

19. No Investment Advice

Brighty App does not provide investment advice. We may provide general information about currencies and cryptocurrency prices, but such information should not be construed as investment advice. You should consult your own financial or investment advisor to determine what may be best for your individual needs.

20. Governing Law and Dispute Resolution

These T&Cs are governed by the laws of England. You agree that any dispute arising out of or in connection with these Terms will be subject to the exclusive jurisdiction of the English courts.

21. Miscellaneous

Third-party rights: These Terms do not create any rights for any third party. Only you (the holder of the Brighty App account) have rights under these Terms, and you may not transfer or assign your rights to anyone else.

Waiver: If we do not enforce any right or provision of these Terms at any time, this will not waive our right to enforce it at a later date. We may also transfer or assign our rights and obligations under these Terms at any time, without your consent.

Severability: If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, that provision will be deemed severed from these Terms and will not affect the validity or enforceability of the remaining provisions, which will continue in full force.