To be fair, they do have one on their website. And it’s not hard to find (took me some 10 seconds) if you’re used to this practice of fintechs putting it (sometimes exclusively) on their terms and conditions. Whether a company with head office in Berlin but registered in Latvia seems particularly trustworthy, is of course a different matter.
…in this case anyhow, they seem to operate only as a service platform of sorts: “services provided to you under this Agreement which are regulated as e-money and/or payments services are exclusively provided by the E-Money Provider (and never by Iban Wallet)”.
Other services are provided by so-called “collaborating providers”, whose “Terms and Conditions (…) as well as their respective Policies will be in force” once “receive(s) registration confirmation from Iban in the form of an email sent by the Iban team”.
Neither of these providers can I readily find or determine from the T&C or anywhere on their website. So it remains questionable if and how they (and their T&C) are disclosed during the signup process.