Spinwheel User Agreement
Last Updated: February 26, 2024
Spinwheel End User Agreement
This End User Agreement (“Agreement”) constitutes a legal contract between Spinwheel Solutions, Inc. (“Spinwheel,” “we,” or “us”) and you, the end user (“you” or “your”), of our products, websites, systems, and services (“Services” or “Spinwheel Services”). This Agreement governs your use of our Services, including your account establishment, product and service utilization, balance and account management, payment services, and the transmission of data and payment statuses to third parties on your behalf.
Both this Agreement, any posted terms and conditions or obligations on a public Spinwheel website, and the current Spinwheel Privacy Policy (“Privacy Policy”) (together, the “Spinwheel Terms”) govern how you use our products and services. Together, these documents set out both you and our rights, duties, and obligations. If you don’t agree to the terms set out in any of these documents, you cannot use Spinwheel or our Services, and by using or accessing any of our Services, you are agreeing to all of the provisions of the Spinwheel Terms.
- About Us
1.1. Spinwheel is a financial technology platform that helps customers better manage their financial decisions by giving them access to information and tools related to debt management, including re-financing, new financing, existing liabilities, and one-time or recurring payments. Our Services help customers manage one-time and recurring payments to loan or other debt providers as well as existing liabilities (e.g., bill payment). Spinwheel Services also include a comparison service that helps customers evaluate certain third party financial products and services.
- Spinwheel Services
2.1. You have accessed our Services through an Application or within any user interface designed for or allowing for the viewing, management, sharing, and modification of End User data (“Spinwheel Dashboard”). The products and services provided to you by the Application are governed by a separate agreement between you and the provider of the Application (“Application Terms“). We have no responsibility for the products and services provided to you by or through the Application and will not be liable to you for any harm, damage or loss arising from your use of the products and services provided by or through the Application.
2.2. Our Services allow you to obtain financial information from your online bank or payment account (“Payment Account“) (account information services), to connect to entities with which you have a credit account or debt (“Credit Accounts” and “Credit Data”), to check other credit or financial data (“Financial Data”), and to make online payments (payment initiation services). Not all of the Services may be available to you through the Application or the Spinwheel Dashboard, and not all services may be exposed by all Applications or the Spinwheel Dashboard.
2.3. The terms and conditions that apply to the Payment and Credit Accounts (together, “Accounts”) that you access through our Services (the “Account Terms“) will remain in effect and this Agreement does not change your Account Terms.
2.4. Applications or other third parties may charge you for products and services provided to you that make use of the Services provided by Spinwheel under this Agreement. Application providers and other third parties may pay us fees and other amounts in connection with the services we provide to them.
Account information services
2.5. Spinwheel’s account information services allow you to access and view information relating to your selected Payment Account, Credit Data, or Financial Data (collectively, “Account(s)”) within the Spinwheel app or other Spinwheel product or service.
2.6. To access the Spinwheel Dashboard, you need to create an account with Spinwheel. You also need to ensure that your information is accurate, complete and up-to-date. You must follow best practices to help secure your Spinwheel account and notify us if you learn of any unauthorized access to or use of your Spinwheel account.
2.7. With your explicit consent, we access and display information relating to your Account(s) (“Account Information“) within the Spinwheel dashboard and transmit such information to the Application through which you have accessed our Services. Such information may include: a. financial transaction history, for example, transaction amount, data, description and currency; b. financial account details, for example, account number, type, currency and balance; and c. financial account holder information, for example, name, address, phone number, and email address.
2.8. Before receiving Spinwheel’s Services, you will have instructed the Application through which you have accessed our Services to retrieve your Account Information using Spinwheel. Upon such an instruction, you will generally be redirected to us.
2.9. Please note, when accessing Spinwheel products or services via a third party site or Application, you may be required to authenticate yourself so that your account provider knows that you consent to the transaction or activity.
2.10. Once we have accessed your Account Information we may:
- share your Account Information with the Application through which you have accessed our Services;
- share your Account Information with third parties as directed by the Application through which you have accessed our Services provided, however, that you have explicitly consented to such sharing; or
- display your Account Information on the Spinwheel Dashboard.
2.11. You agree to us sharing the Account Information we have accessed from your Account Provider with the Application through which you have accessed our Services, and with third parties as directed by that Application provided that in both cases you have explicitly consented to such sharing. Such sharing allows the Application to provide you with products and services in accordance with the Application Terms. You acknowledge that we will only share Account Information when you ask us to, and that we never share Account Information without your approval or knowledge.
2.12. We do not check the accuracy of the Account Information retrieved from your Account Provider and we rely on your Account Provider to ensure that your Account Information is up to date and accurate.
2.13. We may standardize, categorize, merge, aggregate, and otherwise process your Account Information before displaying your Account Information on the Spinwheel dashboard, sharing it with the Application through which you have accessed our Services, or sharing it with third parties as directed by that Application with your explicit consent.
2.14. You may withdraw or vary your consent for Spinwheel to provide account information services at any time. For questions regarding consent or withdrawal of consent, please see our Privacy Policy.
Payment initiation services
2.15. Spinwheel’s payment initiation service allows you to make online payments from your Payment Account(s). Spinwheel can initiate the following types of online payments from your Payment Account(s): (i) single payments; (ii) standing orders; and (iii) variable recurring payments.
Single Payments
2.16. Before receiving our payment initiation service in respect of a single online payment order, you may have instructed the Application through which you have accessed our Services to make a single online payment using Spinwheel. You may also be asked to review and confirm your payment order details for the single online payment.
2.17. When you use Spinwheel’s payment initiation service for a consumer payment you may be asked to select the Payment Account from which you will fund the payment and you may be redirected to your Account Provider’s website or mobile application in order to authenticate yourself so that your Account Provider knows that you consent to the transaction.
2.18. If the payment order relates to a transaction that is to be executed by your Account Provider immediately, you will not be able to cancel the payment order once you have provided your confirmation and explicit consent in accordance with paragraph 2.20.
2.19. If the Application through which you accessed our Services supports refunds, any refunds made will be managed through that Application/Partner.
Standing Orders
2.20. You may be able to use Spinwheel’s payment initiation service to submit a standing order to your Account Provider. A standing order is an instruction to your Account Provider to make regular, recurring payments of the same amount to the same recipient over a specified or indefinite period of time.
2.21. If you use Spinwheel’s payment initiation service to submit a standing order you may, from time to time, be asked to confirm: (i) the amount of the periodic payment, (ii) the recipient of the payments, (iii) the payment start date, (iv) the interval of the payment (e.g. every week or every month) (v) the day on which the payment should be made (e.g. the day of the week or month) and (vi) the end date or that the payments will continue unless cancelled.
2.22. Once the standing order has been confirmed as received by your Account Provider, Spinwheel no longer has control over the execution of the standing order payments; this is the responsibility of your Account Provider.
2.23. In some instances, as with student loans, you will be able to view your standing order via your Account Provider’s online application (where supported). If you wish to change or cancel a standing order, you must do so directly with your Account Provider before the deadline provided by your Account Provider and before the next payment is due. If you miss the deadline for cancelling or amending your standing order, your Account Provider may not be able to stop the next payment in time.
2.24. For further information on how you can cancel and amend standing orders you should refer to your Account Provider terms and conditions.
- Eligibility and Availability
3.1. You can only use the Services if:
- (a) you are 18 or over;
- (b) a resident of the United States;
- (c) your Payment Account and Account Provider are located in the United States;
- (d) you provide us with accurate, complete, and up-to-date information, and do not misrepresent your identity or any other information about you;
- (e) you agree to this Agreement, to the Limited Power of Attorney set forth in Section 4, and to using our Services in accordance with this Agreement; and
- (f) you agree to comply with all laws and regulations applicable to your use of the Services.
3.2. The Services that are available and the manner in which the Services are delivered may vary depending on the type of device you are using, the type of Payment Account(s) you have, the Account Terms and the Application Terms.
- Limited Power of Attorney.
- Grant of Authority: You hereby appoint Spinwheel Solutions, Inc. (“Agent”), as your true and lawful attorney-in-fact and agent, with limited and specific authority as outlined below, to act in your name, place, and stead in any way which you could do if personally present, with respect to the following powers granted until such authority is revoked in writing.
- Specific Authorities Granted:
- Access and Retrieve Information: To access third-party financial institutions, websites, or services to retrieve your financial account information, including but not limited to account balances, transaction histories, and loan details.
- Initiate Transactions: To execute financial transactions on your behalf, including but not limited to payments to your loan service providers, based on explicit instructions you provide.
- Communications: To communicate on your behalf with financial institutions, loan service providers, and other third parties as necessary to perform the services you have requested.
- Authorization Management: To manage, add, or remove authorizations on your loan service provider accounts as necessary to facilitate the agreed-upon services.
- Limited Scope: This power of attorney is limited strictly to the activities necessary for Spinwheel to provide the services described in our agreement with you. It does not grant Spinwheel any further authority to act on your behalf or to access any information or perform any transactions beyond those necessary for the provision of said services.
- Duration: This power of attorney will remain in effect until you revoke it in writing or until it is automatically terminated upon the conclusion of your use of Spinwheel’s services, whichever occurs first.
- Revocation: You may revoke this authority at any time by providing written notice to Spinwheel, effective upon receipt by Spinwheel.
- Third-Party Reliance: Third parties may rely on this power of attorney until they receive notice of its revocation.
- Ratification: You ratify and confirm all that the Agent lawfully does or causes to be done under and by virtue of this power of attorney.
- Governing Law: This power of attorney shall be governed by the laws of the jurisdiction in which you reside.
- Acknowledgment: By using Spinwheel’s services, you acknowledge and agree that you have read, understood, and agree to the terms set forth in this Limited Power of Attorney.
- Incorrect or Unauthorized Payments
5.1. If you suspect that an incorrect or unauthorized payment has been made using Spinwheel’s payment initiation services you must contact us or one of our partners as soon as possible by emailing support@spinwheel.io
5.2. You may be entitled to a refund of the incorrect or unauthorized payment from your Account Provider provided that you notify them of the incorrect or unauthorized payment without delay and in any event no later than 13 months after the date of the relevant payment. You must contact your Account Provider in the manner set out in the applicable Account Terms.
5.3. You should be aware that your Account Provider may contact you directly (and not through Spinwheel or the Application through which you have accessed our Services) if there is an issue with a payment order submitted through Spinwheel for whatever reason (for example, if there are insufficient funds or an issue with your authorisation). You may need to resolve such matters directly with your Account Provider.
- Data
6.1. We use your information in line with our Privacy Policy which can be found on our website at https://legal.spinwheel.io/privacy/. If you are not comfortable with how we handle your information as explained in the Privacy Policy, you should not use our Service.
- Limitation of liability
7.1 YOU UNDERSTAND AND AGREE THAT IN NO EVENT WILL SPINWHEEL BE LIABLE TO YOU FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, LOSSES OR EXPENSES RESULTING FROM OR IN ANYWAY ARISING IN CONNECTION WITH YOUR ACCESS TO, USE, OR INABILITY TO USE, THE SERVICEES OR ANY LINKED SITE (IF APPLICABLE), EVEN IF SPINWHEEL HAS BEEN ADVISED OF THE POSSIBILITY OF THOSE DAMAGES.
7.2 SOME JURISDICTIONS EITHER DO NOT ALLOW OR PLACE RESTRICTIONS UPON THE LIMITATION OR EXCLUSION OF DAMAGES IN CERTAIN TYPES OF AGREEMENTS; FOR THESE JURISDICTIONS, THE AFOREMENTIONED LIMITATIONS ON LIABILITY SHALL BE TO THE MAXIMUM DEGREE PERMITTED BY APPLICABLE LAW. IF, NOTWITHSTANDING THE ABOVE, LIABILITY IS IMPOSED UPON SPINWHEEL, THEN YOU AGREE THAT SPINWHEEL’S TOTAL LIABILITY TO YOU FOR ANY OR AL OF YOUR LOSSES OR INJURIES FROM SPINWHEEL’S ACTS OR OMISSIONS, REGARDLESS OF THE NATURE OF THE LEGAL OR EQUITABLE CLAIM, SHALL NOT EXCEED THE AMOUNT PAID BY YOU TO SPINWHEEL FOR ACCESS TO AND USE OF SPINWHEEL’S SERVICES.
- Complaints
8.1. If you have a complaint about our Services, please email us at consumercomplaints@spinwheel.io so that Spinwheel can investigate the circumstances for you. We will aim to deal quickly and fairly with any complaints you have about our Services in accordance with our obligations under applicable law. Spinwheel may, however, direct you to: a. your Account Provider, if your complaint relates to the services provided under the Account Terms or involves an incorrect or unauthorized payment in accordance with paragraph 5 above; or b. the Application through which you accessed our Services, if your complaint relates to the products and/or services provided by the Application under the Application Terms.
8.3. Spinwheel is not responsible for any complaints or disputes about purchases made using our payment initiation services. You should settle these with the person from whom you bought the goods or services. We are not responsible for the quality, safety, legality or any other aspect of any goods or services purchased using our payment initiation services. Remember that once you have used our payment initiation service to make a purchase, Spinwheel cannot cancel or stop that payment transaction.
8.4. Spinwheel is also not responsible for any complaints or disputes about products and/or services provided by the Application through which you accessed our Services, other third parties, or your Account Provider. You should settle these with the Application, third party, or Account Provider directly.
- Electronic Notice
9.1. By providing Spinwheel with your email address, you are providing your affirmative consent to receive emails from Spinwheel and Spinwheel Partner(s) in order to receive security, privacy and administrative notices and other communications.
9.2 Affirmative Consent. When you use a product or service to which this Consent applies, you are providing your affirmative consent that we may provide you with any Notice in electronic format, and that we may discontinue sending paper Notices to you, unless and until you withdraw your consent as described below. If you would like to use the Services without consenting to receive notices electronically, please contact us at support@spinwheel.io.
9.3 Withdrawal of Consent to Electronic Notices. You may withdraw your consent to receive Notices electronically at any time by contacting us at support@spinwheel.io.Any withdrawal of your consent will be effective only after we have had a reasonable period of time to act upon your withdrawal. Any withdrawal of your consent to receive electronic communications will not affect the legal validity, enforceability, and binding effect of any Notice you received, electronic or otherwise, before the effective date of the withdrawal of your consent. Even if you choose to withdraw your consent to receive notices electronically, the Services will continue and the Services will remain available whether you again provide affirmative consent to receive emails or not.
9.4 By using the Services, you agree that communications regarding security, privacy and administrative issues relating to your use of the Services will be provided to you electronically through the Spinwheel Partner. You may have a legal right to receive certain notices in the event of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at support@spinwheel.io.
9.5 Text Messages. When you use the Services and provide us with a telephone number for a cellular phone or other wireless device, you consent to receive mobile text alerts using an automatic telephone dialing system. Consent to receiving SMS text Notifications includes autodialed and pre-recorded, non-marketing, service-related text messages from or on behalf of Spinwheel and Spinwheel Partner(s) at the phone number provided. Spinwheel will send you news and updates, including recommendations to help make the most of your Spinwheel account(s) and access select Spinwheel features. Message frequency varies.
9.6 We may ask for your telephone number for a cellular phone or other wireless device and to consent to receive messages for authentication, one time password or notification purposes only. By consenting, you consent to receive autodialed and pre-recorded text messages from or on behalf of Spinwheel at the number provided for only those stated purposes. Spinwheel will not send marketing or promotional messages via SMS. To stop receiving messages, you may reply STOP to any text message you receive from Spinwheel. After you text “STOP” to us, we will send you a text to confirm that you have been unsubscribed from text messages. Thereafter, you will no longer receive text messages from Spinwheel. Inability to receive text messages for the above purposes may impact your ability to use the Services and make the Services unusable for you.. If you are experiencing issues with the messaging program, you can reply with the keyword “HELP” for more assistance, or you can get help directly at support@spinwheel.io. Standard message and data rates apply to messages.
9.7 Push Notifications. By agreeing to this Agreement, you agree to receive push notifications from us. You can opt out of receiving push notifications through your device settings. Please note that opting out of push notifications may impact your use of the Services.
- Changes to this Agreement
10.1. The contract between you and Spinwheel which is set out in this Agreement and which governs your use of the Services will continue until cancelled in accordance with this paragraph 9.
10.2. Spinwheel has the right to change, modify or add to the terms and conditions governing the Services, or any part thereof. Such changes, modifications, additions or deletions aisle be effective immediately upon notice thereof, which may be given by any means including posting on this site or by other electronic or conventional means. You agree to review this page periodically to be aware of any such changes, modifications, additions or deletions to the terms and conditions stated herein. Your continued use of the Services after such notice has been given shall be deemed to constitute acceptance of the changes, modifications, additions or deletions.
10.3. If you do not agree with the proposed change(s) you must tell us using the Spinwheel contact details set out in paragraph 4.3. before that change takes effect and you will have the right to terminate this Agreement at any time before the proposed date of their entry into force. If you do not contact us in order to tell us that you do not accept the changes and request to terminate this Agreement you will be deemed to have accepted the change(s) to the Agreement.
- Termination
11.1. You have the right to cancel the contract between us, which is set out in this Agreement, at any time without notice by contacting Spinwheel using the Spinwheel contact details set out at paragraph 9.3.
11.2. We may cancel the contract with you, with immediate effect, by giving written notice: a. if you break this Agreement and fail to resolve the matter to Spinwheel’s satisfaction in a timely manner; or b. in the event of your death or incapacity.
11.3. We may cancel this Agreement with you for any reason by giving you at least 14 days written notice.
- Indemnification
12.1 You agree to protect and fully compensate Spinwheel and its affiliates from any and all third party claims, liability, damages, expenses and costs (including, but not limited to, reasonable attorney’s fees) caused by or arising from your use of the Services, your violation of this User Agreement or your infringement, or infringement by any other user of your account, of any intellectual property or other right of anyone.
- Legal Matters and Disputes
13.1 Except as otherwise required by applicable law, the User Agreement and the resolution of any disputes under Section 20 (“Dispute Resolution”) below, shall be governed by and construed in accordance with the laws of the State of California without regard to its conflict of laws principles.
13.2 This User Agreement, together with the Privacy Policy and any other agreements expressly incorporated by reference herein, constitute the entire and exclusive understanding and agreement between you and Spinwheel regarding your use of and access to the Services, and except as expressly permitted above may only be amended by a written agreement signed by authorized representatives of the parties. You may not assign or transfer this User Agreement or your rights hereunder, in whole or in part, by operation of law or otherwise, without our prior written consent. We may assign this User Agreement or any of our rights or obligations under this User Agreement at any time without notice.
13.3 The failure to require performance of any provision shall not affect our right to require performance at any time thereafter, nor shall a waiver of any breach or default of this User Agreement constitute a waiver of any subsequent breach or default or a waiver of the provision itself. Use of paragraph headers in this User Agreement is for convenience only and shall not have any impact on the interpretation of particular provisions. In the event that any part of this User Agreement is held to be invalid or unenforceable, the unenforceable part shall be given effect to the greatest extent possible, and the remaining parts will remain in full force and effect.
13.4 MOST CUSTOMER CONCERNS CAN BE RESOLVED QUICKLY AND TO THE CUSTOMER’S SATISFACTION BY CONTACTING SPINWHEEL’S CUSTOMER SUPPORT DEPARTMENT AT SUPPORT@SPINWHEEL.IO. IN THE UNLIKELY EVENT THAT SPINWHEEL’S CUSTOMER SUPPORT DEPARTMENT IS UNABLE TO RESOLVE A COMPLAINT YOU MAY HAVE TO YOUR SATISFACTION (OR IF SPINWHEEL HAS NOT BEEN ABLE TO RESOLVE A DISPUTE IT HAS WITH YOU AFTER ATTEMPTING TO DO SO INFORMALLY), WE EACH AGREE TO RESOLVE THOSE DISPUTES THROUGH BINDING ARBITRATION INSTEAD OF IN COURTS OF GENERAL JURISDICTION TO THE FULLEST EXTENT PERMITTED BY LAW. ARBITRATION IS MORE INFORMAL THAN A LAWSUIT IN COURT. ARBITRATION USES A NEUTRAL ARBITRATOR INSTEAD OF A JUDGE OR JURY, ALLOWS FOR MORE LIMITED DISCOVERY THAN IN COURT, AND IS SUBJECT TO VERY LIMITED REVIEW BY COURTS. ARBITRATORS CAN AWARD THE SAME DAMAGES AND RELIEF THAT A COURT CAN AWARD.
13.5 ANY ARBITRATION UNDER THIS AGREEMENT WILL TAKE PLACE ON AN INDIVIDUAL BASIS; CLASS ARBITRATIONS AND CLASS ACTIONS ARE NOT PERMITTED. IN ARBITRATION, THE PREVAILING PARTY WILL BE ENTITLED TO RECOVER ATTORNEYS’ FEES FROM THE OTHER PARTY.
13.6 Arbitration Agreement:
13.6.1 Any claim, dispute, or controversy, arising out of or relating to any aspect of the relationship between us, whether based in contract, tort, statute, fraud, misrepresentation or any other legal theory; claims that arose before this or any prior Agreement; claims that are currently the subject of purported class action litigation in which you are not a member of a certified class; and claims that may arise after the termination of this Agreement (“Claim”), no matter how described, pleaded or styled, shall be finally and exclusively resolved by binding individual arbitration conducted by the American Arbitration Association (“AAA”) under its Consumer Arbitration Rules in your state of residence at a location that is reasonably convenient for both parties.
13.6.2 A party who intends to seek arbitration must first send to the other, by certified mail, a written Notice of Dispute (“Notice”). The Notice to Spinwheel should be addressed to: Spinwheel, 490 43rd. St., Unit24 (“Notice Address”). The Notice must describe the nature and basis of the claim or dispute and set forth the specific relief you seek from Spinwheel (“Demand”). If Spinwheel and you do not reach an agreement to resolve the claim within 30 days after the Notice is received, you or Spinwheel may commence an arbitration proceeding. During arbitration, the amount of any settlement offer made by Spinwheel or you shall not be disclosed to the arbitrator until after the arbitrator determined the amount, if any, to which you or Spinwheel is entitled. You may obtain more information about arbitration from adr.org
13.6.3 After Spinwheel receives Notice at the Notice Address that you have commenced arbitration, it will promptly reimburse you for your payment of the filing fee. The arbitration will be governed by the Consumer Arbitration Rules (“Rules) of the American Arbitration Association (“AAA”), as modified by this Agreement, and will be administered by the AAA. The AAA Rules are available online at adr.org or by calling the AAA at 1-800-778-7879. All issues are for the arbitrator to decide, including the scope and enforceability of this arbitration provision as well as the Agreement’s other terms and conditions, and the arbitrator shall have exclusive authority to resolve any such dispute to the scope and enforceability of this arbitration provision or any other term of this Agreement including, but not limited to any claim that all or any part of this arbitration provision or Agreement is void or voidable.
13.6.4 The arbitrator may make rulings and resolve disputes as to the payment and reimbursement of fees and expenses at any time during the proceeding or in the final award, pursuant to applicable law and the AAA Rules.
13.6.5 Discovery and/or the exchange of non-privileged information relevant to the dispute will be governed by the AAA Rules.
13.7 ARBITRATION OF YOUR CLAIM IS MANDATORY AND BINDING. NEITHER YOU NOR SPINWHEEL WILL HAVE THE RIGHT TO LITIGATE THAT CLAIM THROUGH A COURT. IN ARBITRATION, NEITHER YOU NOR SPINWHEEL WILL HAVE THE RIGHT TO A TRIAL BY JUDGE OR JURY.
13.8 Spinwheel will pay the initial filing fee to commence the arbitration.
13.9 You and Spinwheel will have every remedy available in arbitration as you and Spinwheel would have from a court and will be entitled to reasonable discovery. All determinations as to the scope, interpretation, enforceability and validity of this User Agreement shall be made finally and exclusively by the arbitrator. The arbitrator’s award will be binding and final. Judgment on the arbitration award may be entered in any court having jurisdiction.
13.10 NO CLASS ACTION, OR OTHER REPRESENTATIVE ACTION, OR PRIVATE ATTORNEY GENERAL ACTION, OR JOINDER OR CONSOLIDATION OF ANY CLAIM WITH A CLAIM OF ANOTHER PERSON SHALL BE ALLOWABLE IN ARBITRATION.
13.11 This arbitration provision shall survive: (i) the termination of this User Agreement; (ii) the bankruptcy of any party; and (iii) any transfer, sale or assignment of your account, to any other person or entity. If any portion of this arbitration provision is deemed invalid or unenforceable, the remaining portions shall nevertheless remain in force. Any different agreement regarding arbitration must be agreed to in writing.
13.12 This arbitration agreement is made pursuant to a transaction involving interstate commerce, and shall be governed by the Federal Arbitration Act, 9 U.S.C. §§ 1-16.
13.13 IF YOU DO NOT AGREE TO THE TERMS OF THIS ARBITRATION AGREEMENT, DO NOT ACTIVATE OR USE THE SERVICES.