Terms of Business.

The following document ('The Document') provides information about XC Pay Limited ('XC Pay’, 'We', 'Our', 'Us' and 'The Company') and Our business practices for our stakeholders including, but not limited to online visitors and website users, registered users of Our services ['Clients'], professional partners and counter parties and regulatory bodies.

The Document contains the following sections which can be easily navigated to by using the links below:

​

1. Company Information:

  • Registered office and trading address

  • Company Intellectual Property Rights

2. Regulatory Disclosure:

  • Registered office and trading address

  • Company Intellectual Property Rights

  • Regulatory disclosure.

3. Privacy Policy:

  • How We collect information

  • What information we collect

  • Use of Cookies

  • Affiliate and third party data providers.

4. Terms of Use:

  • Market Report and call back request form submissions.

  • IB Client Introduction Form submissions.

  • Acceptance of Our Terms of Business

5. Safeguarding of Funds:

  • Overview.

  • Ebury’s Safeguarding Statement.

  • Currencycloud’s Safeguarding Statement.

6. Complaints:

  • How to make a complaint to XC Pay.

  • IB Client Introduction Form submissions.

  • Acceptance of Our Terms of Business

​

1. Company Information.

XC is a trade mark of XC Pay Limited. XC Pay Limited is a company registered in England and Wales (registered no. 17194728). Registered office: 6th Floor, 37 Lombard Street, London EC3V 9BQ.

Company Intellectual Property Rights

​

The name "XC Pay" and the "XC" Logos are trademarks of XC Pay Limited. All rights are reserved. Unauthorised use of these trade marks is prohibited.

The domain “xcpay.co.uk” ('Our site') and it’s hosted content remain the intellectual property of The Company.

​© 2026, XC Pay Limited. All Rights Reserved.

​

​

2. Regulatory Disclosure.

XC Pay Limited provides financial services, including deliverable and non-deliverable foreign exchange, risk management, global payments and over-the-counter (OTC) foreign exchange products through it's trading partner Ebury Partners UK Limited. Ebury Partners UK Limited is authorised and regulated by the Financial Conduct Authority as an Electronic Money Institution. Reference Number: 900797. Ebury Partners UK Limited is registered with the information Commissioner’s Office under the UK Data protection Act (registered no. Z209673X) in accordance with applicable law in the jurisdictions where services are provided. XC Pay Limited is a Programme Manager of Ebury Partners UK Limited - registered in England and Wales, registration number 7088713 Registered office: 3rd floor, 100 Victoria Street, Cardinal Place, London, SW1E 5J.

XC Pay Limited’s payment and e-money services are provided by The Currency Cloud Limited. Registered in England No. 06323311. Registered Office: Registered Office: 1 Sheldon Square, London, W2 6TT, United Kingdom. The Currency Cloud Limited is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 for the issuing of electronic money (FRN: 900199)

XC Pay Limited provides business finance services through its partnership with Spark Finance Ltd (Registered office - 18 John Stow House, London, England, EC3A 7JB. Registered Number 10128297) Spark Finance Ltd is a credit broker, not a lender. Any quotes provided are for information purposes only and subject to status and separate lender terms and conditions. Applicants must be aged 18 and over. Guarantees and indemnities may be required. Spark Finance may receive commission from lenders which may vary depending on the lender, product, or other permissible factors. The nature of any commission model will be confirmed to you before you proceed. Spark Finance Ltd is authorised and regulated by the Financial Conduct Authority in the UK (FRN 958123).

​

3. Privacy Policy.

​​

XC Pay Limited values its clients privacy and is committed to honouring the protection of client data.

We collect certain personal information about Our clients in order to conduct normal business activities. Our privacy policy outlines the manner in which We treat the information We collect or you provide Us about yourselves and your business.

​By visiting Our sites you are accepting and consenting to the practices described in this policy.

For the purpose of the General Data Protection Regulation (the “Regulation”):

​

Data Protection

You may contact Our Data Protection Officer directly with any enquiries relating to Data Protection at:

Data Protection Officer
XC Pay Limited
6th Floor,37 Lombard Street
London, EC3V 9BQ.
Telephone: +44 (0)207 177 0700
Email: dpo@xcpay.co.uk


You have the right to lodge a complaint with your Supervisory Authority. For the purpose of Our processing the lead Supervisory Authority is:

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Telephone: +44 (0) 303 123 1113
Email: casework@ico.org.uk
Website: https://ico.org.uk

​

How We collect your information.

We collect information you provide us in writing in paper and electronic form such as applications submitted by post and via Our website, email communication, verbal communication in person or during telephone conversations as well as information found in the public domain.

​​

What sort of information we collect from you.

​

We collect the names, addresses and contact information such as telephone and mobile phone numbers of authorised parties on your account. It may also be necessary to collect further information about directors, shareholders, trustees and beneficiaries as well as financial and credit information relating to your company or organisation. You must obtain appropriate consent before disclosing such information to Us.

​

Other information We collect about you.

​

We automatically collect technical information when you visit Our sites including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

​

Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our sites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service number.

Capture of Communications

Calls are recorded to ensure compliance, security and quality monitoring. Call recordings and electronic forms of communicationare kept for a period of 5 years to comply with FCA SYSC 10A - Obligations for the capture of communications.

​​

Why we collect information about you.

​

We collect information about you and/or your organisation which is necessary for Us to conduct our business activities and obligations properly. We only collect the information we need to best provide Our services.

​​

Sharing your information with third parties.

​

As part of our standard business activities we will share your information with relevant and necessary third party organisations including our trading partners and where required to do, financial authorities and law enforcement agencies. We will not share your details with any third party organisations for purposes other than the servicing of your account by Us.​

​​

4. Terms of Use

Market Report and Call Back Request web form submissions.

​

By accepting the the Terms and Conditions you consent to receiving contact from XC Pay Limited in the form of market and exchange rate news and updates by email and/or telephone.

​

IB Client Introduction Form.

​

By accepting the Terms and Conditions laid out within Our IB agreement, you declare that any personal or privileged information contained within the form is accurate and provided willingly by the named person or persons to which it refers. You will not otherwise record or keep copies of information provided by the named party intended for referral to XC Pay Limited without ensuring adequate data protection systems are in place, or the express permission of the named party or parties.

​

By providing the information of third parties you confirm that the person or persons named have consented to receive contact from a representative of XC Pay Limited to discuss the provision of financial products by XC Pay Limited and/or its trading partners.

Acceptance of Our Terms of Business

By submitting personal information and/or information about your company to Us you agree to Our Terms of Business. You consent to being contacted by XC Pay Limited and (where necessary) it's partners for the purpose of providing financial services.

​

5. Safeguarding of Funds

Overview

XC Pay will only provide you with named and client segregated currency accounts from an FCA Authorised and Regulated partnering institution and will not hold client funds on your behalf. Neither XC Pay nor any of our partners will have access to your funds for it’s own operational purposes.

XC Pay’s client accounts are provided by Ebury Partners UK Limited (Ebury) and The Currency Cloud Limited (Currencycloud). Further information about their authorisation can be found within our Regulatory Disclosure.

Ebury’s Safeguarding Statement

Summary

  • Ebury is licensed as an Electronic Money Institution by the Financial Conduct Authority in the UK

  • Ebury has a legal obligation to safeguard client account balances.

  • In the unlikely event that Ebury were to cease trading, any client funds held in client accounts subject to safeguarding are protected (ring-fenced) from Ebury's other creditors.

  • This gives you peace of mind knowing that your funds are protected.

Our safeguarding obligations can be satisfied in a number of ways. Currently, Ebury satisfies its safeguarding obligations by segregating client funds in designated safeguarding accounts with Tier 1 banks. Ebury selects and regularly reviews these institutions used to hold its client funds based on a number of factors including, but not limited to, reputational risk, agency ratings, service capabilities and local market presence.

Ebury Safeguarding Structure

Funds are reconciled immediately at the point of receipt and our safeguarding obligations are met at all times. Funds are ring fenced in our safeguarding vehicles within one business day.

Ebury performs daily safeguarding calculations for regulated entities as required under the relevant regulations such as the Electronic Money Regulations 2017 with further guidance provided in the FCA's Payment Services and Electronic Money - Our Approach document.

All safeguarding processes ensure that funds are appropriately protected in line with the client's agreed terms and conditions and the governing regulations.

Margins

Margin in the form of funds may be transferred to Ebury under title transfer collateral arrangements for the purpose of securing or otherwise covering the performance of financial obligations owed to Ebury. As such, ownership of these funds transfers to Ebury on receipt. If Ebury were to cease trading, the provider of this margin will generally be an unsecured creditor.

Deposit Guarantee Scheme

Because Ebury operates as an Electronic Money Institution we do not fall under any relevant banking deposit guarantee scheme, such as the Financial Services Compensation Scheme (FSCS).

Currencycloud’s Safeguarding Statement

Summary

As an Electronic Money Institution (EMI), we receive, collect and store funds for our clients, as well as facilitating FX conversions and processing outbound payments. Any funds held on a client's behalf, for the provision of a conversion or payment service, are subject to safeguarding - ensuring that your funds are always protected and can be issued back should Currencycloud go into administration or liquidation. Unlike holding money in a standard bank account, all of our clients’ funds are protected, regardless of the value.

How we safeguard your funds

We separate clients’ funds from our company funds and place them in safeguarding accounts held with reputable UK and EU banks. If Currencycloud was to become insolvent, the funds held in our safeguarding accounts would form an asset pool from which claims of the e-money holders (our clients) would be paid above those of other creditors. The bank(s) or authorized credit institutions have no rights over funds in Currencycloud’s safeguarding accounts. Currencycloud has no rights over our clients’ accounts (other than where specified in our Terms and Conditions).

When funds are credited to your account, electronic money (e-money) is issued in exchange by an authorised Electronic Money Institution with whom we partner, namely Currencycloud. In accordance with applicable regulatory requirements, Currencycloud safeguards your funds. This means that the monetary value behind your account balance is held at a reputable financial institution and is protected in the event of insolvency of either Currencycloud or ourselves. Currencycloud ceases safeguarding your funds once the money has been successfully transferred from your account to the intended beneficiary’s account.

Currencycloud Terms of Use

Payment and e-money services are provided by The Currency Cloud Limited. Registered in England No. 06323311. Registered Office: Registered Office: 1 Sheldon Square, London, W2 6TT, United Kingdom. The Currency Cloud Limited is authorized by the Financial Conduct Authority under the Electronic Money Regulations 2011 for the issuing of electronic money (FRN: 900199)

To view The Currency Cloud’s terms of use please visit https://www.currencycloud.com/legal/terms/.

6. Complaints

​​

How to make a complaint to XC Pay

  1. If you feel that an issue about our service or conduct has not been resolved please contact us directly either by post to by email complaints@xcpay.co.uk or by post to XC Pay, 6th Floor, 37 Lombard Street, London EC3V 9BQ or outlining your complaint.

  2. Please provide as much detail as possible about the nature of your complaint including the names of the person(s) you have been dealing with and the date(s) when the transaction(s) or communication(s) took place.

  3. We will aim to provide a first response (acknowledgement) within 1 business day of receipt of your email or 7 business days by post.

  4. If we are able to resolve your complaint within 3 business days we will do so and provide you with a Summary Resolution Communication.

  5. If we require more information about your complaint to complete our investigations we will notify you.

  6. Once we have received all required information about your complaint we will aim to provide you with a formal written Final Response letter within 15 business days, however this may be extended to 8 weeks in cases where the investigation is reliant on gathering communications from third parties.

Once you have received our response:

  1. You may accept our Final Response and any measures we offer to resolve your complaint,

  2. Reject our Final Response and refer your complaint to the Financial Ombudsman Service (FOS).

  3. If at any time you are unhappy with our handling of your complaint, or if we are unable to provide a Final Response within 8 weeks of receiving it, you may also refer your matter to the Financial Ombudsman Service (FOS).

Details of how to make a complaint to the Financial Ombudsman Service can be found at https://www.financial-ombudsman.org.uk/consumers/log-ombudsman-connect/how-to-complain

We are your first port of call for any queries or concerns, including complaints. We will handle these complaints in line with our complaints process. We work with Currencycloud, who ultimately provides you with regulated payments and e-money services. Currencycloud has certain obligations as a regulated financial services institution, including around complaints. We keep them informed of the complaints we receive from you regarding the regulated payments and e-money services they ultimately provide to you. They oversee how we handle complaints to ensure we do this to the standard required under the regulations. However, if for any reason your complaint regarding your payments and e-money services has not been acknowledged or dealt with by us, or if you have concerns about the way it has been handled, Currencycloud’s complaints information can be found here.