Payment Handling Policy

How payments, commission, refunds and chargebacks are handled across the EveryClinic Platform

Version 2.0 (Model B — payments marketplace) · Supersedes v1.0 · Draft — for solicitor review

Regulatory note — read first

This version reflects EveryClinic’s decision to take payment at the point of booking and settle clinics net of commission, using Stripe Connect. The structure is designed so that Stripe — an FCA-authorised e-money institution — collects, holds and settles the funds, and EveryClinic does not take possession or control of appointment funds beyond its own commission, so that EveryClinic itself does not require FCA authorisation as a payment institution. This position, and the specific Stripe Connect charge structure, must be confirmed with a solicitor and with Stripe before launch. Providing payment services without the necessary FCA authorisation or registration is a criminal offence.

1. Purpose and scope

1.1

This policy sets out how payments are handled across the EveryClinic Platform: (a) payment by Patients for appointments, taken at the point of booking and facilitated through the Platform via Stripe Connect; (b) EveryClinic’s Commission, collected as a Stripe application fee on each transaction; and (c) refunds, no-shows and chargebacks. It should be read alongside the Clinic Partner Agreement (clauses 6–9) and the Patient Terms and Conditions (clause 5).

1.2

Core principle (changed in this version). EveryClinic facilitates payment for appointments at the point of booking through Stripe Connect. Funds are collected, held and settled by Stripe as the authorised payment provider; EveryClinic instructs the settlement and receives only its Commission. EveryClinic does not operate as a payment institution in its own right and does not hold client money. This is a deliberate structural choice intended to keep EveryClinic outside the requirement for its own FCA authorisation — to be confirmed as set out in the regulatory note above.

2. Patient payments through the Platform (via Stripe Connect)

2.1

At the point of booking, the Patient pays the Clinic’s displayed price through the Platform’s integrated Stripe checkout. The price charged is the Clinic’s own list price; EveryClinic does not add any booking, service or convenience fee on top of it (see Patient Terms, clause 5, and Clinic Partner Agreement, clause 4).

2.2

Funds are collected and settled by Stripe. Under the Connect structure adopted, Stripe holds the funds from the point of booking, and settlement to the Clinic’s Connected Account is initiated 14 days after the appointment is completed, net of EveryClinic’s Commission (taken as an application fee). The Clinic is the recipient of the appointment fee; EveryClinic does not enter into possession or control of the appointment funds beyond its Commission — the funds are held by Stripe throughout the deferred-settlement period. The precise Stripe Connect charge type (direct or destination) remains to be confirmed with Stripe and the solicitor, and any change to it is subject to the change-control gate in section 9.

2.3

EveryClinic does not store raw card numbers or card security data. Card data is captured and processed by Stripe under its PCI-DSS Level 1 compliance; the Platform must not capture, transmit or store primary account numbers on its own systems.

2.4

The Clinic remains responsible for the accuracy of its displayed price and for the clinical service delivered. EveryClinic’s role in the payment is limited to operating the Platform through which the Stripe transaction is initiated.

3. Commission

3.1

EveryClinic’s Commission is calculated per Schedule 1 of the Clinic Partner Agreement and is charged on every Booking made through the Platform, collected automatically as a Stripe application fee at the point of the transaction rather than invoiced monthly in arrears. EveryClinic issues each Clinic a periodic statement showing gross amounts collected, Commission taken, and net amounts settled. Commission is variable and may change: EveryClinic gives Clinics at least 30 days’ written notice before any change takes effect, and rating-linked adjustments may apply under the EveryClinic Rating-Linked Commission Policy (see Clinic Partner Agreement, clause 6.5 and Schedule 1).

3.2

Because Commission is taken on an agency basis for facilitating the introduction and booking — not as consideration for the clinical service itself — VAT applies to EveryClinic’s Commission, not to the gross appointment price. This VAT position should be confirmed with EveryClinic’s accountant as the model firms up.

3.3

Failed settlements, negative balances and Commission adjustments arising from refunds or chargebacks are handled under sections 4 to 6 and under the Clinic Partner Agreement.

4. Refunds

4.1

Refund entitlement follows the Clinic’s own cancellation and refund policy, which is displayed to the Patient at the point of booking. EveryClinic does not adjudicate clinical refund disputes; entitlement is a matter between the Patient and the Clinic under that policy.

4.2

Where a refund is due before settlement to the Clinic (that is, before or within the 14-day post-appointment holding period), it is processed back through the Platform / Stripe to the Patient’s original payment method, because that is where the payment was taken. Where a refund becomes due after settlement to the Clinic, the Clinic issues the refund to the Patient directly. EveryClinic facilitates the mechanics of pre-settlement refunds; it does not decide the underlying entitlement.

4.3

Commission reverses with the refund. Where a Booking is refunded in full, EveryClinic’s Commission on that Booking is reversed (the application fee is refunded), so that no Commission is retained on an appointment that does not proceed. Where a Booking is partially refunded, Commission is adjusted proportionately or as set out in Schedule 1. These reversals apply to refunds processed through the Platform before settlement; where the Clinic issues a refund after settlement (more than 14 days after the appointment is completed), the Commission on that Booking is not reversed.

5. No-shows and late cancellation

5.1

Where the Clinic’s policy provides for a no-show or late-cancellation charge, that charge is applied to or retained from the collected payment in accordance with the policy disclosed to the Patient at booking. The treatment of Commission on a retained no-show charge is as set out in Schedule 1 of the Clinic Partner Agreement.

6. Chargebacks and payment disputes

6.1

Card-network chargebacks and payment disputes are handled through Stripe’s dispute process. EveryClinic will provide reasonable assistance and available booking records to support a response.

6.2

A chargeback or dispute that relates to the clinical service, the Clinic’s conduct, or a matter for which the Clinic is responsible is the Clinic’s financial responsibility. EveryClinic may recover from the Clinic the amount of any such chargeback, associated network or Stripe fees, and any resulting negative balance, as set out in the Clinic Partner Agreement.

6.3

EveryClinic bears only those chargebacks that arise directly from a failure of the Platform itself.

7. Currency, VAT and statements

7.1

All amounts are collected and settled in GBP. Patient-facing prices are shown in GBP as set by the Clinic; EveryClinic applies no currency conversion or payment surcharge to the Patient-facing price.

7.2

VAT on Commission is treated as set out in clause 3.2. Clinic statements are issued in a format that allows Clinics to account for VAT and reconcile gross, Commission and net amounts.

8. Fraud prevention

8.1

EveryClinic monitors for Platform-integrity fraud (for example, fake accounts or bookings created to manipulate Commission or reviews) as part of standard controls.

8.2

Card-network fraud screening and chargeback handling on the payment flow are performed by Stripe (including Stripe Radar) under its own terms, separate from EveryClinic’s Platform-integrity controls.

9. Client money, safeguarding and the regulatory perimeter

9.1

Because appointment funds are collected, held and settled by Stripe as an authorised provider, and not by EveryClinic, EveryClinic does not hold client money requiring safeguarding in its own right. EveryClinic’s own receipts are limited to its Commission.

9.2

Change-control gate. Any change that would cause EveryClinic itself to take possession or control of Patient funds — for example, routing appointment funds through an EveryClinic-controlled account before settling the Clinic, holding deposits, or issuing e-money — would be a material change to EveryClinic’s regulatory position and must not be implemented without: (a) legal advice on FCA authorisation, registration and safeguarding requirements; (b) confirmation of the revised Stripe Connect (or alternative) configuration; and (c) updated Patient Terms, Clinic Partner Agreement, Privacy Policy and this Policy.

9.3

A change to the Stripe Connect charge type or flow of funds (clause 2.2) is treated as a change within the scope of clause 9.2 and triggers a review of the regulatory position before it goes live.

10. Responsibility and review

10.1

This policy is owned by Lakhbir Dhillon (Founder and Data Protection Officer), who is responsible for the Stripe relationship, the settlement configuration, and for flagging any change described in section 9 before it is built.

10.2

This policy is reviewed at least annually, and immediately if the payment model, the Stripe Connect configuration, or the applicable regulation changes.