These Operator Terms apply to any Customer who holds the Operator role. They supplement the General Terms. Capitalised terms not defined here have the meanings given in the General Terms.
The Operator role is a sub-type of the Partner role. An Operator is a Partner whose specific function is to instruct Dintero on the distribution of funds to Payees on behalf of one or more Payers. The Operator does not accept payments from End Buyers, does not process acquiring transactions, and does not bear liability in connection with payment card schemes.
General Terms applicability for the Operator role:
Activated Channel Schedules:
Schedule SP — Split Payout is activated by default for all Operators. Schedules O, S, P, and R do not apply to the Operator role.
1.1 Definition. An Operator is a legal entity that has entered into these Operator Terms with Dintero and whose role is to instruct Dintero on the distribution of funds to Payees on behalf of one or more Payers. The Operator acts as an intermediary between the Payer and Dintero in the transfer flow.
The following terms have the meanings given below when used in these Operator Terms:
1.2 Nature of the arrangement. Dintero acts as a licensed intermediary under money remittance (PSD2 Annex I point 6). Funds paid by the Payer to Dintero are held by Dintero and disbursed to Payees on the Operator's instruction. The purpose of the arrangement is the transfer of amounts owed by the Payer to Payees. Dintero does not provide acquiring services or card payment acceptance to the Operator in its Operator role.
1.3 What all Operators have in common. Irrespective of the Operator's commercial model, all Operators share the following characteristics in their relationship with Dintero:
(a) the Operator does not accept payments from End Buyers in its own name;
(b) the Operator does not account for, or bear responsibility for, the sale of goods or services to End Buyers; and
(c) the Operator is not subject to Scheme Rules in its Operator role.
1.4 Nature of relationship. The Operator acts as an independent commercial intermediary. The only relationship between Dintero and the Operator is that of service provider, as set out in these Operator Terms. Nothing in these Operator Terms creates an employment, agency, partnership, joint venture, fiduciary, or any other relationship between Dintero and the Operator. Dintero has no relationship of any such kind with any Payer or Payee; Dintero's relationship to each of them is solely that of service provider, as described in the Terms. The Operator has no authority to make representations or commitments on Dintero's behalf.
1.5 Role isolation. Where the Operator simultaneously holds another role (such as Merchant or Partner), these Operator Terms govern only the rights and obligations arising from the Operator role. The terms governing any other role apply independently and remain unaffected by these Operator Terms unless expressly stated.
1.6 Regulatory basis. The Operator acknowledges that Dintero's provision of fund disbursement services to Payees is regulated activity under PSD2 and applicable national payment services law. The Operator shall not represent to Payees or third parties that it is itself a licensed payment institution or that it is performing regulated payment services. The Operator shall not use the Dintero Services to perform or facilitate any activity that would require the Operator itself to hold a payment institution licence or other financial services authorisation.
2.1 Instruction responsibility. The Operator is solely responsible for the accuracy and completeness of each Payout File submitted to Dintero. Dintero will execute payout instructions as submitted and bears no liability for errors in Payout Files provided by the Operator.
2.2 Format and submission. Payout Files must be submitted in the format and via the channel specified in Dintero's technical documentation. The Operator shall not submit Payout Files through any other mechanism.
2.3 No reversal of executed payouts. Dintero pays as instructed. Once a payout has been executed, Dintero will not reverse, claw back, or correct the payment. Where a payout was made in an incorrect amount or to an incorrect Payee as a result of an error in the Operator's Payout File, the Operator is solely responsible for resolving the discrepancy directly with the relevant Payee. Dintero has no obligation to assist in recovering funds already disbursed.
2.4 Correction of pending instructions. Where the Operator identifies an error in a Payout File that has been submitted but not yet executed, the Operator shall notify Dintero immediately. Dintero will use reasonable efforts to correct or cancel the instruction before execution, but cannot guarantee that a correction is possible once the instruction has entered processing.
2.5 Funds must be available. Dintero will only execute a payout instruction once the corresponding funds have been received from the Payer and cleared in Dintero's account. The Operator shall ensure that the Payer remits funds to Dintero in sufficient time to meet the intended payout schedule. Dintero is not obliged to advance funds or execute payouts where corresponding funds have not been received.
2.6 Geographic scope. The Operator may only instruct payouts to Payees located within the geographic areas covered by this Agreement. The Operator shall notify Dintero in writing before expanding its Payee population to a new country or jurisdiction. Geographic expansion is subject to Dintero's written approval and may be subject to additional requirements arising from applicable sanctions, anti-money laundering, or payment services law in the relevant jurisdiction.
2.7 Prohibited instructions. The Operator shall not submit Payout File instructions that:
(a) relate to transactions other than the transfers of amounts owed by Payers to Payees;
(b) are designed to transfer funds to recipients who have not been approved by Dintero;
(c) would result in a payment to the Operator's own accounts in a manner that conceals the nature of the transaction; or
(d) relate to any Absolutely Prohibited Activity or Restricted Activity as defined in Appendix 1 of the General Terms.
2.8 Record keeping. The Operator shall retain records of all Payout Files submitted to Dintero, including the underlying expense documentation that supports each transfer, for a minimum of five (5) years. Dintero may request access to these records in connection with a compliance review, audit, or regulatory enquiry.
3.1 Onboarding of Payees. Before Dintero can execute a payout to a Payee, Dintero must onboard that Payee and perform KYC, PEP, and sanctions screening. The Operator is responsible for submitting to Dintero all information required for onboarding each Payee, including full name, national identity number (personnummer or equivalent), country of residency, and bank account details. The Operator is responsible for the accuracy of the information it submits to Dintero.
3.2 Dintero performs KYC independently. Dintero is solely responsible for performing KYC controls on Payees. The Operator does not perform KYC on Payees and shall not represent to any party that it has done so. Dintero's KYC process is conducted in the background; Payees are not required to interact with Dintero as part of onboarding.
3.3 Payee notification. Before Dintero commences onboarding of any Payee, the Operator shall inform that Payee of the following:
(a) that Dintero will act as the fund distributor for the transfer arrangement and will execute payouts on the Operator's instruction;
(b) that Dintero will perform KYC, PEP, and sanctions screening on the Payee as part of onboarding and on an ongoing basis; and
(c) how Dintero processes the Payee's personal data in connection with that role, by directing the Payee to Dintero's privacy notice or by providing an equivalent summary.
The Operator shall ensure that this notification is given in a manner that meets the requirements of applicable data protection law, including the GDPR transparency obligations under Articles 13 and 14.
3.4 KYC updates. Where a Payee's data changes, the Operator shall submit updated information to Dintero as soon as it becomes aware of the change. Payees may also notify Dintero directly of changes to their bank account, name, or country of residency; Dintero will verify and update the Payee's record accordingly. The Operator shall not instruct payouts to bank account details that differ from those registered with Dintero for the relevant Payee.
3.5 Payee support. The Operator is responsible for handling all queries, complaints, and disputes raised by Payees in connection with the transfer arrangement, including queries about payout amounts, timing, and entitlement. Dintero provides support to the Operator only; Dintero does not provide direct support to Payees. The Operator shall not direct Payees to contact Dintero for support relating to the transfer arrangement.
3.6 Changes to the Payee population. The Operator shall notify Dintero of any material change to the size or geographic composition of its Payee population, including the addition of Payees in a new country or jurisdiction. Such changes may affect Dintero's sanctions and anti-money laundering exposure and may require additional compliance measures before payouts to new Payees can be processed.
3.7 Payee liability allocation. Dintero's obligation is limited to executing payouts to Payees in accordance with the Payout File instructions provided by the Operator. Dintero is not responsible for:
(a) any dispute between the Operator, the Payer, and a Payee regarding the amount owed by the Payer to the Payee;
(b) any failure by the Payer to remit sufficient funds to cover the payouts instructed by the Operator; or
(c) any claim by a Payee arising from an incorrect payout amount or a failed payout where the error originated in the Operator's Payout File.
4.1 The fees applicable to the Operator role are set out in the applicable price list agreed between Dintero and the Operator. Fees may include a per-payout transaction fee, a monthly service fee, or both, as specified in the price list.
4.2 Dintero may increase fees payable by the Operator by giving at least three (3) months' prior written notice. Changes in fees imposed by third parties (such as payment scheme owners) take effect as notified by those parties. Where Dintero increases fees, the Operator may terminate this Agreement as of the date on which the new fees take effect, provided that written notice of termination is given within one (1) month of receiving Dintero's notice of the increase.
4.3 Dintero may deduct applicable fees from funds held prior to disbursement, or invoice the Operator separately, as set out in the applicable price list.
5.1 Term and termination are governed by GT 9, which applies in full to the Operator role. References in GT 9.3 to "Sellers" and "End Buyers" do not apply to the Operator, which has neither; the corresponding grounds apply where the relevant conduct is carried out by the Operator, a Payer, or a Payee in connection with the transfer arrangement. This section sets out additional termination obligations specific to the Operator.
5.2 Termination of Payer arrangements. The Operator shall not terminate this Agreement with Dintero while any Payer arrangement that relies on the Dintero Services remains active. Before giving notice of termination to Dintero, the Operator shall:
(a) terminate or transfer to another operator all active Payer arrangements; and
(b) ensure that no outstanding Payout Files remain pending execution.
Where the Operator has terminated all Payer arrangements and there are no pending Payout Files, the Operator may give notice of termination to Dintero in accordance with GT 9.2.
5.3 Dintero-initiated termination. Where Dintero terminates this Agreement pursuant to GT 9, Dintero will use reasonable efforts to provide the Operator with sufficient notice to wind down active Payer arrangements in an orderly manner, unless immediate termination is required under GT 9.3.
5.4 Surviving obligations. Upon termination of this Agreement, the Operator's obligations under section 2.8 (record keeping) and section 3.5 (Payee support for pre-termination payouts) survive for a period of five (5) years.
6.1 Independent controllers. With respect to Personal Data processed in connection with the transfer arrangement, Dintero and the Operator each act as independent controllers within the meaning of GT 12.1. The data processor limb of GT 12.1 — under which Dintero acts as the Customer's Article 28 processor for payment transaction data submitted by the Customer — does not apply to the Operator role. Dintero processes Payee and Payer Personal Data for its own purposes of performing KYC and its other regulatory obligations, and of executing payouts as a regulated money remittance service, and determines the purposes and means of that processing. Each Party is solely responsible for its own processing, including its lawful basis, security, breach notification, and responses to data subject requests. Dintero's processing is described in its privacy notice.
6.2 Flow-down to the Operator–Payer contract. The Operator shall ensure that its contract with each Payer:
(a) allocates, as between the Operator and the Payer, the data protection roles and responsibilities for Personal Data relating to the Payer and the Payees;
(b) establishes a valid legal basis for the Payer and the Operator to share that Personal Data with Dintero for the purposes set out in section 6.1;
(c) secures the Payer's agreement that Dintero acts as an independent controller for KYC and payout execution, and that Dintero performs KYC and ongoing monitoring of the Payer in accordance with applicable law, including laws on the prevention of money laundering and terrorist financing; and
(d) provides for Payees to be informed accordingly and directed to Dintero's privacy notice (see also section 3.3).
The Operator shall, on Dintero's request, provide evidence that its contracts with Payers meet these requirements.
