Loyalty scheme
We advised our client on preparing its new loyalty scheme for deployment in the Polish market. Loyalty scheme allows users to accrue points for card spend, in-app challenges and the use of selected Revolut services, and to redeem those points for benefits offered within the application.
Our engagement covered the full regulatory, contractual and operational set-up. We tested and refined the end-to-end customer flow, confirmed the programme’s alignment with Polish consumer-protection, advertising and payment-services rules, and drafted the internal governance framework, including risk and compliance controls.
We drafted the full corpus of documentation: internal governance policy, detailed product specification, risk-control matrix, merchant-acquiring addendum, marketing disclaimers and the terms and conditions for end-users. Our team also produced and negotiated all client-facing documentation (programme terms, marketing disclosures, privacy wording). All work and deliverables were provided in English, with Polish versions prepared where required for local implementation. We provided comprehensive legal support in a technically and legally complex FinTech matter, ensuring the project met all applicable regulatory standards across financial services.
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We advised our client on the implementation of a commitment decision issued by the Polish Office of Competition and Consumer Protection (UOKiK), which addressed certain practices related to informing clients about changes in payment service agreements. Specifically, the decision highlighted issues such as the improper form of notifying customers about fee changes and the lack of appropriate modification clauses in contracts.
We acted for our client throughout the implementation of a strategic partnership with, Poland’s leading mobile payments platform for urban mobility. The project enables Polish Revolut users to reserve parking spaces and purchase public-transport tickets directly in the client’s payment application.