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General Terms of Use – Individual

What does everything in these Terms mean?

We have tried to keep our Terms as simple and straightforward as possible, because we at Lucy don’t like lots of complexity! However, there are some things that we are legally obliged to do and say. By signing up as a Lucy customer, you will automatically have agreed to these Terms, so please read them thoroughly.

In these General Terms of Use:

“Business Day” means a day other than a Saturday, Sunday or public holiday in Singapore

“Communications” means information provided relating to your Lucy Account or any Lucy Transaction, including: any agreements and policies you agree to) including updates to agreements or policies; disclosures and notices, including prospectuses and reports for transaction receipts or confirmations; Lucy Account statements and history; and payments authorisations and transaction receipts or confirmations; documents; and any other information related to your Lucy Account or the Lucy Services.

“Cookie Policy” means the cookie policy relating to the Website which can be found at here.

“Fees and Pricing Section” means the separate fees schedule outlining the fees we charge in relation to the Lucy Services which can be found here.

“Force Majeure Event” means an event which is beyond the reasonable control of an affected party including without limit any market disruption, acts or restraints of government(s) or public authorities, war, revolution, strikes or other industrial action, fire, flood, natural disaster, explosion, terrorist action, the suspension or limitation of trading by any execution venue, or any breakdown, failure, defective performance or malfunction of any telecommunications settlement or other equipment or systems.

“Information” means any confidential and/or personally identifiable information or other information, including but not limited to the following: name, email address, date of birth, tax identification number, billing/shipping address, phone number and financial information.

“Lucy” “we,” “us,” or “our” means Lucy Holdings Pte. Ltd., the details of which are set out in Clause 2.1.

“Lucy Account” means your relationship with us as described in these Terms.

“Lucy Account Profile” means your profile, accessible on the Lucy Home Screen where you can view, among other things, your details, your price plan and your verification limits.

“Lucy Card” means virtual or physical, Lucy-branded prepaid cards issued by Rapyd.

“Lucy Home Screen” has the meaning set out in Clause 5.1.

“Lucy Home Screen Transaction” has the meaning set out in Clause 9.1

“Lucy Services” means you being given access to the Lucy Home Screen via the Mobile App and the management of your Lucy Account.

“Lucy User” means a user of Lucy which is not you.

“Mobile” means your smartphone or other electronic device upon which you have downloaded the Lucy Mobile App.

“Mobile App” means the mobile application accessible through your Mobile where you can obtain access to your Lucy Home Screen.

“Mobile App Terms” means the terms and conditions governing your use of the Mobile App which can be found on the Mobile App.

“Mobile PIN” means your personal identification number which is entered onto the Lucy Mobile App to gain access to the Lucy Home Screen.

“Promo Code” means a code made available by Lucy through our marketing channels.

“Rapyd” means Rapyd Holdings Pte Limited, which is regulated as a major payment institution by the Monetary Authority of Singapore (MAS) for providing cross-border money transfers, and is currently exempted from holding a licence under the Payment Services Act (No. 2 of 2019) for merchant acquisition, domestic money transfer, e-money and account issuance services.

“Referral Code” means a code made available by Lucy, generated from within the Mobile App by a User.

“Privacy Policy” means our privacy policy which can be found on the Website.

“Supplement(s)” means an agreement between Lucy and you for the provision of separate services by Lucy or one of its partners to you, which will be set out on the

“User”, “you” or “your” means you being the individual that has agreed to these Terms to use the Lucy Services.

“Website” means our general website, the web address of which is

“Website Terms” means the terms and conditions regarding the use of our Website which can be found on our Website.

These terms as a framework agreement

1.1. These Terms constitute a framework agreement which sets out the terms of the use of the Lucy Home Screen and other Lucy Services. Before you can benefit from the Lucy Services you are required to:

  1. Read these Terms and tick the box confirming the accuracy of the information provided and your agreement with these Terms; and
  2. provide us with such documentation, photographs and information as may be reasonably requested to comply with regulatory obligations.

1.2. These Terms incorporate the Website Terms, the Cookie Policy, the Privacy Policy, the Mobile App Terms and any Supplements by this reference. By accepting these Terms, you are also deemed to have accepted the terms and conditions of Rapyd Holdings Pte which you can read here.

1.3. Once you have completed the above and you have passed our internal checks, we shall make the Lucy Home Screen available to you.

1.4. You confirm that you have provided the correct Information during the process of creating a Lucy Account. You undertake that, if your details change, you will notify us immediately. You shall bear any losses that occur due to the submission of invalid, incorrect or inaccurate Information.

Regulatory information

2.1. These Terms are between you and Lucy Holdings Pte. Ltd. (“Lucy”, “we”, “us” or “our”) a company incorporated in Singapore (U.E.N. 201939640R) and whose registered office is 11 Irving Place #09-01, Singapore 369551 .

2.2. Lucy Holdings Pte. Ltd. provides the Lucy Services only as a technology service provider and creator of the Mobile App. All issuance of electronic money, card and e-money account as well as payment transaction services are provided by Rapyd. We only act as a cross-border money services agent, and an e-money and card distributor of Rapyd. You can verify this information at the MAS website here.

2.3. These Terms are separate and independent from the terms and conditions by Rapyd which govern the use of your Lucy Card, e-money, account and payment transactions made via the Mobile App. You can read Rapyd’s Terms and Conditions here.

Commencement, term and your Lucy account

3.1. These Terms shall commence on the day that Lucy confirms to you via the Mobile App that your Lucy Account has been approved and shall continue until terminated in accordance with Clause 22 (Amendments to these Terms) and/or Clause 25 (Termination).

3.2. You may be required to provide supplemental information to us or to Rapyd to be able to use all of the functionality available.

3.3. We may stop your access to the Lucy Home Screen and/or the Lucy Card on reasonable grounds relating to:

  1. the security of the Lucy Home Screen;
  2. the suspected unauthorised and/or fraudulent use of the Lucy Home Screen.

If we do stop your access in such instances, we will inform you via the Mobile App and direct you to our customer services team.

The Lucy dashboard

4.1. The Lucy Home Screen is our portal where you can, among other things:

  1. perform top-ups via stored value or debit card, instant bank transfers including recurring transfers (once accepting all charges as displayed on the Lucy Home Screen);
  2. review and accept or decline transfers;
  3. verify your identity;
  4. view your transaction history;
  5. view the balance and currency of the electronic money you hold in your e-money account;
  6. enable or disable your Physical Lucy Card, change the PIN on your Physical Lucy Card and access other security features; and
  7. enter the details of your bank account and your card(s)

4.2. You may access the Lucy Home Screen via the Mobile App.

Verification of identity

5.1. You agree to cooperate with all requests made by us or Rapyd in connection with your Lucy Account, to identify or authenticate your identity or validate your funding sources or Lucy Transactions. This may include, but not limited to, asking you for further information that will allow Lucy or Rapyd to reasonably identify you, including requiring you to take steps to confirm ownership of your phone number or payment instruments or verifying your Information against third party databases or through other sources.

5.2. We or Rapyd reserve the right to close, suspend, or limit access to your electronic money account and/or the Lucy Services in the event we or Rapyd are unable to obtain, verify such Information or you do not comply with our requests under these Terms.

5.3. We may confidentially verify the information you provide us with or obtain information on you ourselves or through third parties from secure databases. Some of the searches which we or a third party may perform, such as a credit check, may leave a soft footprint on your credit history. This will not affect your credit rating. By entering into these Terms, you confirm that you consent to us or a third party on our behalf carrying out such verifications.

5.4. You must ensure the information on your Lucy Account is always accurate and up to date. If at any time we believe that your information is outdated or inaccurate, we may contact you and request further information or request that you go through the verification process again. Your Lucy Transaction Limit will be adjusted accordingly while we verify your identity. We shall not be liable for any losses arising out of your failure to maintain up to date information.


6.1. Lucy provides virtual receipts for successful transactions, which are accessible on the Lucy Home Screen. In addition to virtual receipts, merchants should provide you with receipts when you purchase with a Lucy Card. Lucy or Rapyd will not and are under no obligation to provide you with a physical receipt or other written confirmation in connection with any Lucy Transaction.

Fund Transfers

7.1. You are able to perform a fund transfer by logging onto the Lucy Home Screen and following the on-screen instructions. You will need to enter the details of your intended beneficiary (“Counterparty”) in order to request for a transfer. It is your responsibility to make sure that the Counterparty’s details are entered correctly. Any error may result in the transfer being unsuccessful or delayed. Neither we nor Rapyd shall be liable for any losses you incur from entering incorrect Counterparty details.

7.2. You will be informed, prior to confirming your request to enter into the transfer, of:

  1. the Counterparty’s name and other details;
  2. the amount and currency of electronic money you wish to send to the Counterparty; and
  3. the fees for the transfer (if any).

7.3. In order to submit the request to enter into the transfer, you will need to confirm the details which have been entered by hitting the button titled “Send” on the relevant part of the Lucy Home Screen.

7.6. Once your funds have been sent, you will be able to view the completed transfer on the Lucy Transaction History part of the Lucy Home Screen.

7.7. If the currency of the Counterparty (in accordance with the information provided by you on the Lucy Home Screen) is different to the currency of the electronic money you are using to enter into the bank transfer, then as part of the transfer you will be informed of the exchange rate for the currency exchange prior to confirming the bank transfer.

Exchange rates

8.1. The “Exchange Rate” means the:

  1. “Standard Exchange Rate”; or
  2. “Non-Standard Exchange Rate”

depending on the value of the e-money redemption permitted by Rapyd for the purchase of other currencies, as carried out by you in the given month, further details of which are set out in the Fees and Pricing Section.

8.2. Generally, for major currencies during FX market hours the Standard Exchange Rate will be the interbank rate. However, in certain circumstances, it is not possible for the Standard Exchange Rate to be the interbank rate including when the FX market is closed on weekends or on public holidays or when your Exchange Rate involves illiquid currencies. It may also not be possible for the Standard Exchange Rate to be the interbank rate due to other external factors such as volatile market conditions, a system failure of Rapyd or Lucy or any other external factors. In such instances, the Standard Exchange Rate will be different from the interbank rate. Please see the Fees and Pricing Section for more details.

8.3. We will inform you of the exact Exchange Rate for each transaction prior to your entry into the same. It is your responsibility to ensure that you are happy with the Exchange Rate offered to you, prior to entering into each Lucy Transaction.

Your balance and negative balances

9.1. You acknowledge that balances and available funds reported on the Lucy Home Screen are only approximate real time balances rather than the settled balances in your electronic money account displayed in the Mobile App. A real time balance may not take into account pending debits and credits. Lucy will provide you with information on pending debits and credits as soon as it has that information.


10.1. You must ensure that you take all reasonable steps to:

  1. ensure that your Mobile and your Mobile PIN is kept safe and secure;
  2. ensure that access to the Lucy Home Screen is kept safe and secure; and
  3. ensure your Lucy Card PIN and other unique numbers (including CVC, expiry and card number) are kept safe and secure.

10.2. The requirement in Clause 10.1 includes, but is not limited to, for the avoidance of doubt: you:

  1. closing the Mobile App every time you are not using it;
  2. keeping the Mobile you use to gain access to the Lucy Home Screen safe and secure and locked with a secure password or other security mechanism;
  3. not writing down or telling anyone your Mobile PIN;
  4. changing your Mobile PIN regularly;
  5. if you receive any SMSs or emails, questionnaires, surveys, or other links that require you to provide your Mobile PIN, not providing your information and contacting our customer services team via the support function on the Lucy Home Screen;
  6. ensuring that the Mobile and e-mail account(s) you use to communicate with us are secure and only accessed by you, as the Mobile and e-mail address may be used to reset your Mobile PIN or to send information relating to the security of the Lucy Home Screen;
  7. if at any time you think that your Mobile PIN has been lost, stolen or any other person knows your Mobile PIN or anyone has access to your e-mail account or Mobile you use to communicate with us, informing customer services immediately via the chat function on the Lucy Home Screen;
  8. updating the Mobile App to the latest version available for your device as it may contain security updates;
  9. keeping your Lucy Card safe and secure;
  10. not writing down or telling anyone your Lucy Card PIN or details of the Lucy Card; and
  11. disabling your Lucy Card via the Lucy Home Screen or otherwise reporting to us, at any time if you think the security of the Lucy Card is at risk, for example, if it is lost or stolen.

10.3. All transactions are processed by automated methods, and anyone who obtains access credentials to the Lucy Home Screen or access to a Lucy Card could use it to enter into transactions without your permission. If you notice misuse, theft or unauthorised use of your Mobile, Lucy Card, Mobile PIN or Card PIN or any other activity that makes you suspicious, you must contact the customer services team and if possible enable the appropriate security features on the Mobile App. If you suspect identity theft or theft of electronic money, we suggest that you contact your local police as well.

Restrictions on the use of the Lucy services

11.1. It is not permitted to:

  1. use the Lucy Services for any illegal purposes, including, but not limited to fraud and money laundering, unlawful sexually oriented materials or services, counterfeit products, unlawful gambling activities, fraud, money laundering, the funding of terrorist organisations, the unlawful purchase or sale of tobacco, firearms, prescription drugs, other controlled substances or other products prohibited by law. Lucy or Rapyd will report any suspicious activity and cooperate with any relevant law enforcement agency or regulator;
  2. use the Lucy Services to abuse, exploit or circumvent the usage restrictions imposed by a merchant on the services it provides, or to obtain goods or services without paying the amount due partially or in full;
  3. breach these Terms or any other agreement or policy that you have agreed with Lucy or with Rapyd;
  4. create more than one Lucy Account without our prior written consent;
  5. use the Lucy Services to violate any law, statute, ordinance, or regulation;
  6. use the Lucy Services for any illegal purposes including the purchase or sale, or the facilitation of the purchase or sale of, illegal goods or services;
  7. use the Lucy Services to conduct activities pertaining to adult entertainment/pornography, auction houses, charities, chemicals and allied products, dating and escort services, binary options, legal services, political or religious organisations, video game arcades or establishments and business claiming to trade in prime bank guarantees, debentures, letters of credit or medium term notes;
  8. infringe Lucy’s or any third party’s copyright, patent, trademark, trade secret or other intellectual property rights, or rights of publicity or privacy;
  9. act in a manner that is defamatory, libellous, threatening or harassing when using the Lucy Services;
  10. provide us with false, inaccurate or misleading information;
  11. use the Lucy Services to engage in debt-collection activities;
  12. instruct us to send or receive what we reasonably believe to be potentially fraudulent funds on your behalf;
  13. attempt to intentionally or knowingly receive or attempt to receive funds from both Lucy and a merchant for the same transaction;
  14. control a Lucy Account that is linked to another Lucy Account that has engaged in any of these Restricted Activities;
  15. conduct your business or use the Lucy Services in a manner that is likely to result in or may result in complaints, disputes, reversals, chargebacks, fees, fines, penalties or other liability to Lucy, other Users, third parties or you;
  16. use your Lucy Account or the Lucy Services in a manner that Lucy, Rapyd, Visa, MasterCard, American Express, Discover or any other electronic funds transfer network reasonably believes to be an abuse of the card system or a violation of card association or network rules;
  17. allow your any e-money account issued to you by Rapyd to have a negative balance;
  18. provide yourself with a cash advance from a credit card in your name (or help others to do so);
  19. take any action that imposes an unreasonable or disproportionately large load on our infrastructure; facilitate any viruses, Trojan horses, worms or other computer programming routines that may damage, detrimentally interfere with, surreptitiously intercept or expropriate any system, data or information; use an anonymising proxy; use any robot, spider, other automatic device, or manual process to monitor or copy our Website without our prior written permission; or interfere or attempt to interfere with the Lucy Services;
  20. take any action that may cause us to lose any of the services from our Internet service providers, payment processors, or other suppliers;
  21. use the Lucy Services to test credit card behaviours;
  22. circumvent any Lucy policy or determinations about your account usage including, but not limited to, attempting to create a new or additional Lucy Account when the current Lucy Account has been restricted, suspended or otherwise limited; using Information that is not your own (e.g. name, address, email address, etc.); or using someone else’s electronic money account;
  23. harass our employees, agents, or other Users;
  24. refuse to cooperate in an investigation or provide confirmation of your identity or any Information you provide to us;
  25. use the Lucy Services in a manner that we believe may be a violation of any applicable electronic payment network rules, card association or network rules, or applicable law;
  26. use the Lucy Services to trade FX for speculative purposes or for FX arbitrage;
  27. refuse or fail to provide further information about your activities that we may reasonably request;
  28. use the Lucy Services in a manner that leads us to receive a disproportionate number of claims or chargebacks;
  29. have a credit score provided by a third party provider of Lucy’s choosing which indicates a higher level of risk associated with your use of the Services; and/or
  30. reveal your Mobile PIN or Card PIN to anyone or use anyone else’s Mobile App or Lucy Card.

11.2. You must ensure that you only enter into transactions relating to the sale or supply of goods and services in compliance with all applicable laws and regulations. The fact that a person or entity accepts payments is not an indication of the legality of the supply or provision of the goods and services.

11.3. Rapyd reserves the right to refuse to perform a transaction directly or indirectly associated with any Restricted Country.

11.4. If Lucy, in its sole discretion, believes that you may have breached the provision of this Clause, we may take action to protect ourselves, other Users and third parties. The action we may take includes but is not limited to:

  1. closing, suspending, or limiting your access to your electronic money account or any or all of the Lucy Services.
  2. contacting other Users who have transacted with you; contacting your bank or credit card issuer; and/or warning other Users, law enforcement, or impacted third parties of your actions;
  3. updating inaccurate Information you have provided to us;
  4. taking legal action against you;
  5. terminating these Terms or access to the Website;
  6. fully or partially reversing a transaction; and/or
  7. blocking your access to your Lucy Home Screen temporarily or permanently.

11.5. Where possible, Lucy will provide you with the relevant information regarding the actions imposed, but we may be unable to do so in accordance with the appropriate law including avoiding disclosing protected third party information or interfering in the course of an investigation.

Suspending your use of the Lucy services

12.1. We reserve the right to change, suspend or discontinue any aspect of the Lucy Services at any time, including hours of operation or availability of the Lucy Services or any Lucy Services feature, without notice and without liability.

Our right to set-off

13.1. On the happening of any event which entitles us to be compensated by you (including, but not limited to, any technical errors on our behalf or on behalf of our third-party providers), we shall be entitled to recover any sum due to us by retaining part or all of any sum that you have lodged with us under any Lucy Transaction or otherwise. You shall have no similar right of set-off. For the avoidance of doubt, this includes if one of the currency balances in your Lucy Electronic Money Account shows that you owe us an amount of funds for any reason or has a negative balance, Lucy may set-off the amount you owe us by using funds you maintain or by deducting amounts you owe us from money you receive into your electronic money account, or money you attempt to withdraw or send from your Lucy electronic money account, or in a different electronic money account which you control and by deducting funds from any withdrawals you attempt to make.

13.2. On the happening of any event which entitles us to be compensated by you, if for whatever reason we are unable to exercise our right of set-off pursuant to Clause 13.1, we may initiate a payment transaction for the amount we are due to be compensated by you from one of your Stored Cards or User Bank Accounts.

13.3. If the amount owed to us is in a currency which is different to the money or Electronic Money you hold with us, we shall convert the amount you hold with us to the currency of the amount you owe us by applying our Exchange Rates. We do not need to notify you of this conversion occurring.

Our liability with respect to fund transfers, ATM withdrawals and card transactions

14.1. If you believe that a fund transfer, ATM withdrawal and/or a transaction with your Lucy Card has been incorrectly executed or was not authorised by you, you must inform us as soon as possible via the support function on the Lucy Home Screen. Failure to notify us immediately on becoming aware or within 120 days  of the date of the unauthorised or incorrectly executed activity or transaction will result in you losing your entitlement to have the matter corrected.

14.2. Where it is established that a fund transfer, ATM withdrawal and/or a card transaction was not authorised by you, or was incorrectly initiated or executed (provided we can prove such incorrect transaction has taken place) and you have notified us in a timely manner within 120 days of the date of the unauthorised activity or transaction, unless Clause 14.3 applies, we shall refund to you the full amount debited without authorisation.

14.3. You will be liable for:

  1. all losses incurred in respect of a fund transfer, ATM withdrawal and card transaction made by Rapyd which was not authorised by you, if you have acted fraudulently, or have intentionally or with gross negligence failed to comply with the obligations set out in Clause 10 (Security) or you have not notified us on time in accordance with Clause 14.1; and
  2. where Clause 14.3(1) does not apply, up to SGD60 of any losses incurred in respect of such activity or transaction which were not authorised by you, where you have otherwise failed to comply with your obligations under Clause 10 (Security).

General liability

15.1. Except where you have acted fraudulently, you will not be liable for any losses incurred in respect of a fund transfer, ATM withdrawal or a card transaction which was not authorised by you which occurs after you have notified us, without undue delay, on becoming aware of the loss, theft, misappropriation or unauthorised use of the Lucy Card or the Mobile PIN or Card PIN which relates to those losses.

15.2. Neither we nor Rapyd shall be liable for non-execution or defective execution in relation to a fund transfer Rapyd has made in accordance with a unique identifier given to us by you which proves to be incorrect. However, we shall make reasonable efforts to recover funds involved in that transaction and may charge you for doing so, including passing on to you charges made by intermediary banks and/or the payee’s bank for their assistance in the tracing process.

15.3. Neither we nor Rapyd are liable to you for the correct execution of a fund transfer, an ATM withdrawal or a card transaction, if we can prove to you (and where relevant, to any payee’s payment services provider) that the payee’s payment services provider received the payment within the appropriate time period. We will however, upon your request, make efforts to trace any non-executed or defectively executed payment transactions or any bank transfers which were correctly executed to an account which is deemed fraudulent and notify you of any outcome involving our search.

15.4. Please note that any restriction on your liability in relation to an unauthorised or incorrectly executed payment transaction does not apply to losses arising from and/or in relation to the e-money services provided by Rapyd via the Mobile App or foreign currency exchanges.

15.5. Neither we nor Rapyd shall be liable to you for any:

  1. loss or damage which you may incur as a result of losses or costs caused by abnormal and unforeseeable circumstances outside our reasonable control, which would have been unavoidable despite all efforts to the contrary, which might for example include delays or failures caused by problems with another system or network, mechanical breakdown or data-processing failures;
  2. consequential or indirect loss (such as loss of profits or opportunity) you may incur as a result of us failing to perform our duties under a transaction; or
  3. losses as a result of us taking action (or not taking action) as necessary to meet our legal obligations.

15.6. You are responsible for all liabilities, financial or otherwise, incurred by Lucy, Rapyd, a Lucy User, or a third party caused by or arising out of your breach of these Terms, your use of the Lucy Services, and any use of your Lucy Account. You agree to reimburse Lucy, Rapyd, a Lucy User, or a third party for any and all such liability, to the extent not prohibited by applicable law.

15.7. You remain liable under these Terms in respect of all charges and other amounts incurred through the use of your Lucy Account at any time, irrespective of termination, suspension or closure.

15.8. You alone are responsible for understanding and complying with any and all laws, rules and regulations of your specific jurisdiction that may be applicable to you in connection with your use of the Lucy Services, including but not limited to, those related to export or import activity, taxes or foreign currency transactions. You are liable to the state and other subjects for fulfilment of all tax obligations independently. Lucy shall not be responsible for the execution of tax obligations, or calculation and transfer of taxes applied to you.

15.9. You agree to defend, reimburse or compensate us (known in legal terms to “indemnify”) and hold Lucy, our third party providers, Rapyd, our employees or agents who are authorised to act on our behalf harmless from any claim or demand (including legal fees) made or incurred by any third party due to or arising out of your breach of these Terms, breach of any law and/or use of the Lucy Services.

15.10. Nothing in these Terms shall operate to exclude liability for death or personal injury or for fraud or fraudulent misrepresentation or for any liability cannot be excluded or amended under Singapore law.

15.11. In no event shall Lucy be liable for loss of profits or any special, incidental or consequential damages arising out of these Terms or otherwise in connection with the Lucy Services, howsoever arising.

15.12. We are not liable for any loss you incur resulting from your use of the Lucy Card which shall be subject to the Lucy Cardholder Terms (as applicable).

15.13. To the extent permitted by applicable law, Lucy is not liable, and you agree not to hold it responsible, for any damages or losses (including, but not limited to, loss of money, goodwill, or reputation, profits, or other intangible losses or any special, indirect, or consequential damages) resulting directly or indirectly from:

  1. your inability to use the Lucy Services for whatever reason;
  2. delays or disruptions in the Lucy Services;
  3. viruses or other malicious software obtained by accessing the Website or any associated site or service;
  4. glitches, bugs, errors, or inaccuracies of any kind in the Lucy Services;
  5. the content, actions, or inactions of third parties;
  6. a suspension or other action taken with respect to your Lucy Account;
  7. your need to modify practices, content, or behaviour, or your loss of or inability to do business, as a result of changes to these Terms or Lucy’s policies; and/or
  8. illegal actions and operations of third persons performed using counterfeited and/or illegal documents or illegally received data.

Closing your account

16.1. Your Lucy Account will be closed at the end of the term of this agreement in accordance with Clause 3.1 or upon termination of these Terms in accordance with Clause 22 (Amendments to these Terms) and Clause 25 (Termination). You accept that after your Lucy Account has been closed, Rapyd will store personal data about you and your past transactions for a period of six years.

16.2. If your electronic money account holds a balance at the time of its closure, we or Rapyd may ask you to withdraw your funds within a reasonable period of time, during which your account will be accessible for the purpose of withdrawing the remaining balance only. After the expiry of this period you will not be able to access your account but you may withdraw any remaining funds for a period of six years from the date of closure of your Lucy Account by contacting customer service and requesting that the funds be sent to you by returning the funds by either a card refund or bank transfer. When your Lucy Account is closed, any pending instructions will be cancelled.

16.3. You may not close your Lucy Account to evade an investigation. If you attempt to close your Lucy Account while Lucy is conducting an investigation, it may freeze the account to protect all parties to the Lucy Services, its affiliates, or a third party against any liability. You will remain liable for any obligations related to your Lucy Account even after it is closed.


Notice and communications

17.1. You agree and consent to electronic receipt of all Communications that we provide in connection with the Lucy Services. We will provide Communications to you by making them available on the Lucy Home Screen or by emailing them to you at the primary email address listed in your Lucy Account Profile.

17.2. It is your responsibility to ensure that you log onto the Lucy Home Screen regularly and regularly review the Lucy Home Screen, the Website and your primary email address and open and review communications that we deliver to you through those means. You are obligated to review your notices and Lucy Transaction History, and to promptly report any questions, apparent errors, or unauthorised Lucy Transactions. Failure to contact us in a timely manner may result in loss of funds or important rights.

17.3. We may contact you from time to time to notify you of changes or information regarding your Lucy Account. It is your responsibility to ensure you regularly check the Lucy Home Screen and that your contact information stored on your profile in the Lucy Home Screen is up to date. You may contact us in accordance with these Terms via the chat function on the Lucy Home Screen.



18.1. The processing of your data is governed by these Terms, any applicable Supplements as well as our Privacy Policy.

18.2. Lucy reserves the right to transmit the Information or personal data about you as well as activity in your Account to law enforcement institutions, state authorities and financial institutions, if such is necessary to comply with relevant legislation, and in order to identify whether these Terms and relevant legislation have not been violated.

18.3. When you use the Lucy Services we may collect precise location data about a transaction. If you permit the Mobile App to access location services through the permission system used by your mobile operating system, we may also collect the precise location of your device when the app is running the foreground or background. We may also derive your approximate location from your IP address. You may opt out of providing location data through the Mobile App, unless you opt out of providing location data, you consent to the collection, use, sharing and onward transfer of location data, as further set forth in the Privacy Policy.

18.4. By providing Lucy with a telephone number (including a mobile telephone number), you agree to receive autodialed and pre-recorded message calls at that number. The ways in which you provide us a telephone number include, but are not limited to, providing a telephone number at Lucy Account opening, adding a telephone number to your profile on your Lucy Home Screen at a later time, providing it to one of our employees, or by contacting us from that phone number. If a telephone number provided to us is a mobile telephone number, you consent to receive SMS or text messages at that number, for service-related matters. We will not share your phone number with non-affiliated third parties for their purposes without your consent and we will never market, advertise, or solicit you using autodialing or pre-recorded messages, but we may share your phone numbers with our affiliates or with other service providers, such as billing or collections companies, who may contact you using autodialed or pre-recorded message calls or text messages.

18.5. You understand and agree that Lucy may, without further notice or warning and in our discretion, monitor or record the telephone conversations you or anyone acting on your behalf has with Lucy or its agents for quality control and training purposes or for its own protection. You acknowledge and understand that, while your communications with Lucy may be overheard, monitored, or recorded without further notice or warning, not all telephone lines or calls may be recorded by Lucy, and Lucy does not guarantee that recordings of any particular telephone calls will be retained or retrievable.

18.6. You agree that we can use your Information in connection with your Lucy Account, to enable us to review, develop and improve our products and services. This may involve providing your Information to our partners, affiliates, agents, distributors and suppliers to process Lucy Transactions and for their statistical research and analytical purposes. We may also disclose your Information as required by law, regulation or any competent authority or agency to investigate possible fraudulent, unlawful or unauthorised activity.

18.7. You understand and agree that we may collect information about how you and other Lucy Users interact with the Lucy Services. We may access the address book on your device and store names and contact information to facilitate social interactions through the Lucy Services and for other purposes. We may access the photo gallery on your device to obtain images for identity verification purposes. We collect transaction details related to your use of the Lucy Services, including the type of service requested, date and time the service was provided, amount charged and other related transaction details. We may collect information about your mobile device, including for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information and mobile network information. You agree that we may use the information that we collect to facilitate interactions with the Lucy Services, including sharing certain non-sensitive information about you with other Lucy Users.


Intellectual property

19.1. The Lucy Home Screen and the Website and all intellectual property rights contained therein, including but not limited to any content, are owned or licenced by us. Intellectual property rights means rights such as: copyright, trademarks, domain names, design rights, database rights, patents and all other intellectual property rights of any kind whether or not they are registered or unregistered (anywhere in the world). Lucy’s intellectual property includes “,” “Lucy”, and all logos related to the Lucy Services. In addition, all page headers, custom graphics, button icons, and scripts are service marks, trademarks, and/or trade dress of Lucy. You may not copy, imitate, or use them without our prior written consent.

19.2. We reserve all of our rights in any intellectual property in connection with these Terms. This means, for example, that we remain owners of them and free to use them as we see fit.

19.3. Nothing in these Terms grants you any legal rights in the Lucy Home Screen and/or the Website, other than as necessary to enable you to access the Lucy Home Screen. You agree not to adjust or try to circumvent or delete any notices contained on the Lucy Home Screen (including any intellectual property notices) and in particular in any digital rights or other security embedded or contained within the Lucy Home Screen.


Requesting information

20.1. You may request, at any time during the extent of these Terms, a copy of these Terms.


Customer support and complaints

21.1. We take all complaints seriously. Any complaints about us or the services we provide should be using the support function on the Lucy Home Screen. You should clearly indicate that you are wishing to make a complaint to us. This helps us to distinguish a complaint from a mere query. Our complaints procedure (available on our Website) sets out the process for submitting and resolving any complaints. You may request a copy of our complaints procedure at any time by contacting customer services via the chat function on the Lucy Home Screen.

21.2. A final response to your complaint, or a letter explaining why the final response has not been completed, will be sent to you within 14 Business Days of your complaint having been made. Should this not be possible due to unforeseen circumstances or lack of information, we will contact you.

21.3. If after having received our final response you are still unhappy or not satisfied, you may, if your complaint falls within the jurisdiction of the Consumer Association of Singapore, be able to take your complaint to the Consumer Association of Singapore (CASE) details of which are available here. You can also call the CASE on 6100-0315 or write to: Consumer Association of Singapore, 170 Ghim Moh Road #05-01 Ulu Pandan Community Building Singapore 279621.


Amendments to these terms

22.1. These Terms may be amended unilaterally by us, by providing you with two months’ notice. These changes will be deemed to have been accepted by you where you do not, before the proposed date of the entry into force of the changes, notify us to the contrary. If you do notify us to the contrary, your notification will be deemed to be a notice that you wish to close your Lucy Account and terminate these Terms on the date upon which the changes are to take effect.

22.2. Where an amendment to the Terms is required by law or relates to the addition of a new service, extra functionality to the existing Service, a reduction in the cost of the Services or any other change which neither reduces your rights nor increases your responsibilities, the amendment may be made without prior notice to you and shall be effective immediately.

Fees and Promotions

23.1. The fees we charge for the Lucy Services are set out in the separate Fees and Pricing Section to these Terms. We will provide you with notice of any changes to the Fees and Pricing Section in accordance with these Terms. It is your responsibility to stay informed and review these changes once we have provided you notice of a change to our fees.

23.2. The fees we charge for any other transactional fees are clearly shown on the Lucy Home Screen prior to you completing an action and accepted by you or a User.

23.3. We shall deduct the fees that you owe us from the balance in your Lucy electronic money account. If there is not enough electronic money in your account to pay your fees, then we shall take our fee from the Stored Card you supplied when signing up for the Lucy Services or other Stored Card belonging to you which has been provided to us. We reserve the right to suspend your access to your Lucy Services if we are not paid any monies owing to use by you on time.

23.4. Fees for the delivery of replacement Physical Lucy Cards shall be charged at the time the request for Physical Lucy Card is made. If your Lucy Electronic Money Account balance is insufficient to cover the fees for the delivery of the replacement Physical Lucy Card, then we may refuse to issue the replacement Physical Lucy Card. If your Physical Lucy Card has been lost, stolen or misappropriated we will only charge you for the costs associated with replacing your Physical Lucy Card and sending it to your applicable jurisdiction.

23.5. ATM Withdrawal fees will be charged at the time the ATM Withdrawal is performed. If your Lucy Electronic Money Account balance is insufficient to cover the ATM Withdrawal fees, Rapyd may refuse to execute the ATM Withdrawal. Please be aware that some ATM providers charge additional fees for the use of their ATMs and some merchants add a surcharge for accepting certain types of cards. You may also be subject to the merchant’s terms and conditions of business when you use the Lucy Card and it is your responsibility to review and agree these before proceeding with a card tΩransaction.

23.6 From time to time, we may provide Promo Codes and Referral Codes as an incentive for members of the public to become a User, the terms and amounts of which are decided by us at our own discretion. Although there may be multiple Promo Codes or Referral Codes issued by us through different channels in circulation at a single point in time, a User is only entitled to enter and claim the amount granted by a single Promo Code or Referral Code.

23.7 A User can generate a Referral Code from within the Mobile App and send to other members of the Public who are not already Lucy Users. The User who generated the Referral Code is entitled to receive any incentive amount that may be determined by us from time to time and stated within the Mobile App, for any person who becomes a Lucy User and enters the sending User’s Referral Code.

No warranty

24.1. The Lucy Services are provided on an “as is”, “as available” basis and without any representation or warranty, whether express, implied or statutory. Lucy, and the officers, directors, agents, joint ventures, employees and suppliers of Lucy, make no representation or warranty of any kind whatsoever for the services or the content, materials, information and functions made accessible by the Lucy Services used on or accessed through the Lucy Services, or for any breach of security associated with the transmission of sensitive information through the Lucy Services.

24.2. Lucy does not warrant that the Lucy Services will be uninterrupted or error free. Lucy shall not be responsible for any service interruptions, including, but not limited to, system failures or other interruptions that may affect the receipt, processing, acceptance, completion or settlement of Lucy Transactions or the Lucy Services.

24.3. Lucy does not have any control over the products or services that are paid for using the Lucy Services.

24.4. Lucy is not responsible for the quality, performance, or any consequential results of the products and/or services purchased using the Lucy Services.



25.1. Lucy, in its sole discretion, may terminate these Terms at any time, by giving you two months’ notice. The termination of these Terms will not affect any of our rights or your obligations arising under these Terms.

25.2. You may terminate these terms at any time by providing us with one month’s notice, such notice to be provided using the support function on the Lucy Home Screen.

25.3. Without prejudice to any rights that have accrued under these Terms, or any party’s other rights or remedies, either party may at any time terminate these Terms with immediate effect by giving written notice to the other party if:

  1. the other party commits a material breach of any term of these Terms and (if such breach is remediable) fails to remedy that breach within a period of 30 days after being notified in writing to do so;
  2. the other party repeatedly breaches any of the terms of these Terms in such a manner as to reasonably justify the opinion that its conduct is inconsistent with it having the intention or ability to give effect to the terms of these Terms;
  3. the other party is subject to a bankruptcy, insolvency, winding up or other similar event; and/or
  4. the result of laws, payment scheme rules, regulatory authority rules or guidance or any change in or any introduction thereof (or change in the interpretation or application thereof) means that it is unlawful or contrary to any such law, rules, order or regulations for either of the parties to perform or give effect to any of its obligations hereunder and such obligation cannot be readily severed from these Terms.

25.4. Without prejudice to any rights that have accrued under these Terms or any of the party’s rights or remedies, we may at any time terminate these Terms with immediate effect by giving written notice to you if:

  1. we are unable to verify your information in the manner set out in these Terms;
  2. you die;
  3. we have reason to believe that your use of the Lucy Services: damages, corrupts, degrades, destroys and/or otherwise adversely affects the Lucy Services, or any other software, firmware, hardware, data, systems or networks accessed or used by you;
  4. there is a significant fluctuation (either positive or negative) in the aggregate number of Lucy transactions you enter into;
  5. you have acted or omitted to act in any way which we reasonably determine to diminish Lucy’s (or Rapyd’s) business operations and/or reputation and/or goodwill and/or which we reasonably determine or suspect to give rise to any offence or any increased risk or liability to us; and/or
  6. we are unable to provide the Lucy Services to you through the inability of any third party to provide us with any good and/or service that we require to provide the Lucy Services to you.

25.5. Other actions we may take. If you have breached the terms of these Terms (including a breach of your obligation to pay us any amount owing), we are otherwise entitled to terminate these Terms, or we may: suspend your use of the Lucy Services (in whole or in part) in which case we will not treat any order for a transaction that you may wish to make as being received by us; report any transaction or any other relevant information about you and your use of the Lucy Services to the relevant regulatory authority, law enforcement agency and/or government department; and/or if appropriate, seek damages from you.

25.6. Termination of these Terms requires the closing of your electronic money account and the termination of all Lucy Cards in accordance with Rapyd’s terms and conditions. Lucy will deal with your remaining balance in accordance with these Terms and Rapyd’s terms and conditions governing your use of the e-money account and card (as applicable).

25.7. Any terms which by their nature should survive, will survive the termination of these Terms.


26.1. In order to use other functions of the Lucy Services, you may be requested to accept other terms and conditions, either with Lucy, Rapyd or with a third party.

26.2. To be eligible to use the Lucy Services, you must:

  1. pass our regulatory due diligence checks;
  2. not be in breach of these Terms; and
  3. not have had any previous Lucy Account closed by us.

26.3. These Terms shall be governed by the laws of Singapore and any claim or dispute arising out of or in relation to these Terms shall be subject to the non-exclusive jurisdiction of the courts of Singapore.

26.4 We may report any unlawful activity (or suspected unlawful activity) by you or another person to the police or other appropriate authorities, and cooperate with them in any investigation. We may also require your reasonable cooperation in alternative dispute resolution procedures as a means of disputing or issuing any claims in relation to these Terms.

26.5. Save for Rapyd, these Terms do not intend to confer any benefit on any third party and no third party shall have the right to enforce these Terms.

26.6. It is your responsibility to determine what, if any, taxes apply to the payments you make or receive, and it is your responsibility to collect, report and remit the correct tax to the appropriate tax authority. We are not responsible for determining whether taxes apply to your Lucy Transactions, or for collecting, reporting or remitting any taxes arising from any Lucy Transactions. In certain circumstances, the laws of the country in which you carry out a Lucy transaction may permit Lucy to collect from you stamp duty or other tax up to the maximum amount specified by applicable laws.

It is your responsibility to comply with any and all applicable tax laws in connection with your use of the Lucy Services, including without limitation, the reporting and payment of any taxes arising in connection with transactions made through the Lucy Services.

26.7. If we fail to enforce any of our rights under the Terms, or applicable laws, it shall not be deemed to constitute a waiver of such right.

26.8. You may not transfer or assign or sell any rights or obligations you have under these Terms or otherwise grant any third party a legal or equitable interest over your electronic money account without Rapyd’s prior written consent. Lucy reserves the right to transfer or assign these Terms or any right or obligation under these Terms at any time.

26.9. We may comply with any subpoena, levy, or other legal process which we believe to be valid. We may notify you of such a process electronically, by phone, or in writing.

26.10. Lucy or Rapyd has the right to change any of its third-party service providers with or without notice.

26.11. Lucy reserves the right, but shall have no responsibility, to edit, modify, refuse to post or remove any provider content, in whole or in part, that in its sole and absolute discretion is objectionable, erroneous, illegal, fraudulent or otherwise in violation of these Terms.

26.12. Unless stated otherwise in these Terms, if any provision of these Terms is held to be invalid or unenforceable, such provision shall be struck and the remaining provisions shall be enforced.

26.13. We do not provide advice and contract on an execution only basis. We may provide information to you from time to time, for example via the Lucy Home Screen or the Website, but we will not and do not provide advice to you either upon the merits of a proposed transaction or upon any other matter. Foreign currency exchange rates are subject to fluctuations outside our control. Past movements or trends in the movement of foreign currency exchange rates should not be taken as an indicator of future movements in such exchange rates.

26.14. Clause, Schedule and paragraph headings shall not affect the interpretation of these Terms.

26.15. A person includes a natural person, corporate or unincorporated body (whether or not having separate legal personality).

26.16. The Schedules form part of these Terms and shall have effect as if set out in full in the body of this agreement. Any reference to this agreement includes the Schedules.

26.17. A reference to a company shall include any company, corporation or other body corporate, wherever and however incorporated or established.

26.18. Unless the context otherwise requires, words in the singular shall include the plural and in the plural shall include the singular.

26.19. Unless the context otherwise requires, a reference to one gender shall include a reference to the other genders.

26.20. These Terms shall be binding on, and ensure to the benefit of, the parties to these Terms and their respective personal representatives, successors and permitted assigns, and references to any party shall include that party’s personal representatives, successors and permitted assigns.

26.21. A reference to a statute or statutory provision is a reference to it as amended, extended or re-enacted from time to time.

26.22. A reference to writing or written includes email and the support function on the Lucy Home Screen.

26.23. Any obligation on a party not to do something includes an obligation not to allow that thing to be done.

26.24. These Terms shall be concluded and interpreted in the English language. If these Terms are translated into another language, it is for reference purposes only. All communications between the parties shall be in the English language.

26.25. A reference to these Terms or to any other agreement or document referred to in these Terms is a reference to these Terms or such other agreement or document as varied or novated (in each case, other than in breach of the provisions of these Terms) from time to time. References to Clauses and Schedules are to the Clauses and Schedules of these Terms and references to paragraphs are to paragraphs of the relevant Schedule.

26.26. Any words following the terms including, include, in particular, for example or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase or term preceding those terms.

26.27. Supplements to these Terms are an integral part of these Terms, under which you and Lucy agree on usage of specific services as defined in the Supplements.

26.28. In the event of any conflict between these Terms and the terms and conditions by Rapyd which governs your use of any e-money account, card, e-money usage and money transfers, the latter terms and conditions by Rapyd prevail.