If you’re an unregulated platform moving funds using Grid’s money transmitter licenses, Grid (operating as Lightspark Payments, LLC) is the licensed money transmitter on your transactions. Your end users contract directly with Lightspark for these services, so you must present Lightspark’s End User Terms to each end user and capture their consent before they transact.
Exposing the End User Terms and collecting consent is a launch precondition. Provide Lightspark with evidence of your consent flow and receive approval before making Grid available to your end users.
Include the End User Terms in your terms
Copy Lightspark’s End User Terms and append your own terms of service to them, so each end user accepts a single combined document:
Present the combined terms in your onboarding or consent flow, and require each end user to affirmatively accept them (for example, an unchecked checkbox or an “I Agree” button) before they can use Grid.
Provide evidence of your consent flow
Send Lightspark evidence that your end users are shown the End User Terms and consent to them. Provide both:
- A screenshot of the consent screen showing how the End User Terms are presented and accepted.
- How you track consent — the record you keep each time an end user accepts, such as the end user identifier, the timestamp of acceptance, and the version of the terms accepted.
