Merchant of Record Statement

1. What "Merchant of Record" means

For certain transactions processed through the Nordgate platform, Nordgate acts as the Merchant of Record. This means that Nordgate is the legal seller of record for payment and transaction purposes.

When Nordgate acts as Merchant of Record, Nordgate may be responsible for:

• processing the Buyer's payment;
• making available supported payment methods;
• issuing receipts, payment confirmations, or invoices to the Buyer where applicable;
• handling payment-related refunds, claims, disputes, and chargebacks;
• managing fraud, payment risk, transaction monitoring, sanctions, AML, and compliance controls;
• calculating, collecting, reporting, or remitting applicable indirect taxes where required by law;
• settling funds to approved Vendors, Submerchants, or commercial partners according to their agreement with Nordgate.

In simple terms, the Buyer may purchase a product or service provided by an approved third-party Vendor, but the payment transaction may be legally processed by Nordgate as Merchant of Record.

2. Who provides the product or service

Products and services sold through Nordgate may be provided by approved third-party vendors, software companies, digital service providers, platforms, creators, or other commercial partners ("Vendors" or "Submerchants").

The Vendor remains responsible for the underlying product or service, including:

• product functionality;
• product delivery;
• access to software, accounts, licences, or approved digital services;
• technical support;
• service performance;
• product documentation;
• product-specific warranties or commitments;
• compliance with product-specific laws and regulations.

Nordgate is responsible for payment-related matters where Nordgate acts as Merchant of Record. Product-specific support may require involvement from the Vendor.

3. How this may appear to buyers

When Nordgate acts as Merchant of Record, the Buyer may see Nordgate during checkout, on the receipt or invoice, or on the Buyer's bank, card, wallet, or payment account statement.

The statement descriptor may appear as:

• NORDGATE FINANCIAL
• NORDGATE
• a related Nordgate descriptor, where supported by the applicable payment method.

The exact descriptor may vary depending on the payment method, bank, card issuer, wallet provider, payment processor, region, currency, or transaction type.

4. Payment methods

Nordgate may make available different payment methods depending on the Buyer's country, currency, product type, Vendor eligibility, compliance review, and payment partner availability.

Supported payment methods may include, where available and approved:

• credit and debit cards;
• bank transfers;
• digital wallets;
• local payment methods;
• alternative payment methods;
• Skrill / Paysafe-supported payment methods, where available and approved for public use and branding;
• other payment methods made available through Nordgate or its payment partners.

Not all payment methods are available for all Buyers, Vendors, countries, currencies, or products. Nordgate may add, remove, suspend, or restrict payment methods for legal, compliance, risk, commercial, technical, or payment partner reasons.

5. Payment partners and infrastructure

Nordgate may work with regulated payment providers, acquiring banks, card schemes, digital wallets, local payment method providers, fraud prevention providers, tax providers, identity verification providers, compliance providers, and other financial or technology partners.

These partners help Nordgate provide payment processing, fraud prevention, tax calculation, compliance screening, transaction monitoring, refunds, chargebacks, and settlement services.

Unless expressly stated at checkout or in a specific payment flow, references to "payment providers" and "payment partners" are intended to be general and may include current or future providers used by Nordgate.

If a specific payment provider is shown during checkout, that provider's own terms, availability rules, payment flow, verification requirements, or payment method rules may also apply.

6. Receipts and invoices

Where Nordgate acts as Merchant of Record, Nordgate is responsible for issuing the Buyer's receipt, invoice, tax receipt, or payment confirmation where applicable.

A receipt or invoice may include:

• EMPYRA LTD, trading as Nordgate, as Merchant of Record;
• Buyer details;
• Vendor or product provider name;
• product or service description;
• transaction amount;
• currency;
• applicable taxes;
• payment method;
• order number, transaction ID, or invoice number;
• transaction date.

Buyers may request a copy of their receipt or invoice by contacting support@nordgate.financial.

7. Refunds

Where Nordgate acts as Merchant of Record, Buyers should submit payment-related refund requests to Nordgate.

Refund requests may relate to:

• duplicate charges;
• incorrect charges;
• failed or incomplete payment issues;
• non-delivery claims;
• payment confirmation issues;
• refund eligibility under applicable law;
• Vendor-approved refunds;
• other payment-related matters.

Refund eligibility depends on the product type, delivery status, usage, Vendor input, applicable law, Nordgate's Refund Policy, and payment method rules. Unless a different period is shown at checkout, stated in the Vendor's product terms, or required by applicable law, refund requests should generally be submitted within 14 calendar days from the date of purchase.

Refund requests should be submitted to support@nordgate.financial. Nordgate's Refund Policy is available at https://www.nordgate.financial/refund-policy.

8. Claims, disputes, and chargebacks

Where Nordgate acts as Merchant of Record, Nordgate is responsible for handling payment-related claims, disputes, and chargebacks.

Buyers should contact Nordgate before initiating an external chargeback or payment dispute with their bank, card issuer, wallet provider, or payment provider.

Nordgate may request information from the Buyer and the Vendor to investigate a claim or dispute. This may include proof of purchase, order details, delivery evidence, usage records, support correspondence, refund history, or other relevant information.

Nordgate may contest disputes or chargebacks where Nordgate believes the transaction was valid, authorized, delivered, non-refundable, fraudulent, abusive, or otherwise not eligible for reversal.

9. Taxes

Where required by applicable law or where Nordgate acts as Merchant of Record, Nordgate may calculate, collect, report, or remit applicable indirect taxes, including VAT, GST, sales tax, or similar taxes, in connection with transactions processed through Nordgate.

Nordgate may perform these tax-related activities directly or through third-party tax, accounting, payment, or compliance service providers.

The tax treatment of a transaction may depend on several factors, including:

• the Buyer's location;
• the Vendor's location;
• Nordgate's role in the transaction;
• the product or service type;
• whether the Buyer is a consumer or a business;
• the transaction amount;
• applicable tax registration thresholds;
• tax exemptions, reverse charge rules, or special digital services rules, where applicable;
• the requirements of payment providers, tax authorities, or applicable law.

Where required, Nordgate may issue receipts, payment confirmations, tax receipts, or tax invoices in its own name as Merchant of Record. The Vendor may also have separate tax, invoicing, accounting, or reporting obligations in relation to its commercial relationship with Nordgate.

Any payout or settlement from Nordgate to a Vendor is separate from the Buyer-facing transaction and may be subject to separate tax, invoicing, accounting, withholding, or reporting treatment depending on the Vendor's jurisdiction, tax status, product type, and agreement with Nordgate.

10. Subscriptions and recurring payments

Nordgate does not currently support subscriptions or recurring payments as a standard service.

If an approved Vendor is permitted to offer subscriptions or recurring payments through Nordgate in the future, the checkout or applicable product terms should display the subscription price, billing interval, renewal terms, trial terms if applicable, cancellation method, refund rules, applicable taxes, and payment method before the Buyer completes the purchase.

In such approved cases, Buyers may cancel subscriptions through the Vendor account dashboard where available or by contacting support@nordgate.financial. Cancellation stops future billing but does not automatically guarantee a refund for past charges unless required by law or approved under Nordgate's Refund Policy.

11. Buyer support

For payment-related support, Buyers should contact Nordgate at support@nordgate.financial.

Payment-related support may include:

• receipts and invoices;
• duplicate charges;
• failed payments;
• refund requests;
• chargebacks and disputes;
• payment method issues;
• transaction status;
• statement descriptor questions.

For product-specific support, the Vendor may be responsible. Product-specific support may include software access, account login, licence activation, product functionality, technical support, fulfilment, product defects, or service performance.

Where applicable, the Vendor's support contact may be shown at checkout, on the Vendor website, in receipt emails, or in product-specific communications. Nordgate may coordinate with the Vendor to resolve Buyer issues where necessary.

12. Vendor and submerchant onboarding

Vendors may only use Nordgate after approval by Nordgate. Vendor onboarding, partnership, or business enquiries may be sent to onboarding@nordgate.financial.

Nordgate may conduct due diligence before approving a Vendor, including:

• company verification;
• director and representative verification;
• beneficial ownership checks;
• website review;
• product and service review;
• sanctions screening;
• PEP and adverse media screening;
• AML and fraud risk assessment;
• payment risk review;
• review of refund, cancellation, and customer support processes;
• review of expected transaction volume and target markets.

Nordgate may reject, suspend, or terminate a Vendor where the Vendor, product, website, transaction activity, or business model creates legal, regulatory, payment, fraud, AML, sanctions, consumer protection, or reputational risk.

13. Prohibited and restricted activities

Nordgate does not support illegal, misleading, deceptive, high-risk, prohibited, or unsupported business activities. Vendors must comply with Nordgate's Acceptable Use Policy.

The Acceptable Use Policy may prohibit or restrict categories such as:

• illegal goods or services;
• fraud or scams;
• money laundering or sanctions evasion;
• unlicensed financial services;
• crypto, virtual currency, and digital asset activities unless expressly approved;
• unauthorized gambling;
• adult content or services;
• illegal drugs or controlled substances;
• weapons or dangerous goods;
• counterfeit goods;
• intellectual property infringement;
• deceptive subscription billing;
• unauthorized third-party payment processing;
• other restricted or high-risk activities.

Nordgate's Acceptable Use Policy is available at https://www.nordgate.financial/acceptable-use-policy.

14. Compliance and monitoring

Nordgate may monitor transactions, refunds, disputes, chargebacks, websites, vendors, buyer activity, and other risk indicators.

Nordgate may take action where required for legal, compliance, payment, fraud, sanctions, AML, tax, consumer protection, or risk reasons. Such action may include:

• requesting additional information;
• delaying or rejecting a transaction;
• refunding a transaction;
• suspending a payment method;
• applying transaction limits;
• delaying settlement;
• applying reserves;
• suspending or terminating a Vendor;
• reporting suspicious activity where required or permitted by law.

Nordgate may also share information with payment providers, banks, card schemes, regulators, law enforcement, tax authorities, or other competent authorities where required or permitted by law.

15. Relationship to other Nordgate policies

This Merchant of Record Statement should be read together with:

• Nordgate Terms of Service: https://www.nordgate.financial/terms-of-service;
• Nordgate Refund Policy: https://www.nordgate.financial/refund-policy;
• Nordgate Privacy Policy: https://www.nordgate.financial/privacy-policy;
• Nordgate Acceptable Use Policy: https://www.nordgate.financial/acceptable-use-policy;
• Vendor or Submerchant Agreement, where applicable;
• any checkout terms or product-specific terms shown at the time of purchase.

If there is a conflict between this Statement and mandatory consumer protection law, mandatory consumer protection law will apply.

16. Checkout notice

Nordgate may display the following or similar notice during checkout:

17. Contact

For Merchant of Record questions, payment support, refunds, receipts, disputes, or chargebacks, contact:

Company

EMPYRA LTD, trading as Nordgate

Company Number

14984613 (England and Wales)

Support Email

support@nordgate.financial

General Email

info@nordgate.financial

Website

https://www.nordgate.financial

Registered office

27 Old Gloucester Street, London, WC1N 3AX, United Kingdom

For vendor onboarding, partnership, or business enquiries, contact onboarding@nordgate.financial.