Terms & Conditions

1.1 About These Terms

These Terms and Conditions ("Terms") are a legally binding agreement between you ("User", "you" or "your") and BorderFlo Technologies Limited, a company incorporated in the Federal Republic of Nigeria with RC number 7879022, whose registered address is 82B Younis Bashorun Street, Victoria Island, Lagos, Nigeria ("BorderFlo", "we", "us" or "our").

By registering for, accessing or using the BorderFlo mobile application, website or any related service (together, the "Platform"), you confirm that you have read, understood and agree to be bound by these Terms. If you do not agree, you must not use the Platform.

These Terms must be read together with our Privacy Policy, our KYC & AML Statement and our Schedule of Fees, each of which forms part of the agreement between you and BorderFlo.

1.2 Eligibility

To use the Platform, you must at all times:

• be a natural person aged 18 years or older;
• be resident in Nigeria, with a valid Nigerian mobile number and Bank Verification Number (BVN);
• not be legally prohibited from entering into a contract under Nigerian law;
• not be a person, or resident of a country, subject to sanctions imposed by the United Nations Security Council, the Government of Nigeria, the United States Office of Foreign Assets Control, or any other sanctions authority applicable to BorderFlo or its partners; and
• use the Platform for lawful, personal purposes only.

We may verify your eligibility at any time and may suspend or close your Account if we reasonably determine that you do not meet these conditions.

1.3 Amendments

We may amend these Terms from time to time. For a material change, including a change to fees, we will notify you through the Platform or by email at least fourteen (14) calendar days before it takes effect. If you continue to use the Platform after that date, you accept the revised Terms. If you do not accept them, you may close your Account under section 14 before the effective date at no cost.

In these Terms, the following words have the meanings below.

3.1 Registration

To open an Account you must:

• provide your Nigerian mobile number and email address;
• create a password and a transaction PIN;
• provide your BVN, which is verified through our Identity Verification Provider against NIBSS records;
• complete a liveness check, in which our Identity Verification Provider compares a live image of your face with the photograph on your BVN record; and
• provide any further information or documents we reasonably request under our KYC & AML Statement.

Completing registration does not entitle you to an Account. We may decline an application where Applicable Law or our risk assessment requires it.

3.2 Accuracy of Information

You confirm that all information you give us is true, accurate, current and complete, and you will update it promptly if it changes. We are not liable for loss caused by information you failed to keep accurate.

3.3 Account Security

You must keep your password, PIN, device passcode, and biometric login private and must never share them. BorderFlo will never ask for your PIN or password by phone, SMS, email or social media.

Tell us immediately at security@borderflo.com or through in-app support if you suspect unauthorised access to your Account or a Transaction you did not authorise. Once you notify us, we will block further activity on your Account as soon as reasonably possible.

You are responsible for Transactions authorised with your credentials before you notify us, unless the loss was caused by our error, a failure of our or our Payment Partner's systems, or fraud you could not reasonably have prevented. You are not responsible for Transactions made after you notify us, unless you acted fraudulently.

3.4 Account Limits

Your Account is subject to limits on maximum Balance, daily send value and single Transaction value, set in line with CBN requirements and our Payment Partner's risk policy. Your current limits are shown in the app. We may change them where Applicable Law or a risk review requires, and will tell you where the law permits.

4.1 Nature of the Service

BorderFlo is a technology company. It provides the Platform through which you give payment instructions. BorderFlo is not a bank, does not hold a banking, payment or money transfer licence, and does not hold your money.

Your funds are held, and every Transaction is executed, by our Payment Partner, a financial institution licensed by the CBN as a Payment Solution Service Provider (PSSP). When you fund your Wallet or authorise a Transaction, you instruct our Payment Partner, through BorderFlo, to hold or move your funds. BorderFlo does not operate an agent network, and no person is authorised to collect cash or accept payment instructions on BorderFlo's behalf.

4.2 Domestic Transactions

Domestic Transactions are processed through NIP and usually settle in real time. Before you confirm, we show you an estimated processing time; it is an estimate, because settlement depends on the receiving institution.

Once you authorise a Domestic Transaction it cannot be cancelled. If you send money to the wrong account, we will help you request a recall from the receiving institution, but a reversal depends on that institution and cannot be guaranteed.

4.3 Education Payments

Education Payments are made to Institutional Payees on our verified payee directory. For each Education Payment:

• you must enter reference numbers, application IDs and payee details exactly as issued by the institution;
• payments to payees or reference formats not on our directory are held for manual review before release;
• the FX Rate, Service Fee and amount the payee will receive are shown before you confirm, and the FX Rate is held for the Rate Lock Period; and
• we are not liable for funds misdirected because you entered incorrect details, but we will help you request a return from the payee.

We provide no assurance that an institution will accept or credit a payment within any deadline it sets. Please pay well before any deadline.

4.4 Cross-Border Transactions

Cross-Border Transactions let you send Naira from your Balance to a beneficiary in an African Corridor, who receives local currency by bank account, mobile money wallet, or another channel listed for that corridor. For each Cross-Border Transaction:

• you must select a purpose from the options on the Platform;
• before you confirm, we show the FX Rate (including our margin), the Service Fee, any known third-party charges and the exact amount the beneficiary will receive;
• the FX Rate is held for the Rate Lock Period; if you do not confirm in time, a new rate applies;
• once authorised with your PIN, the Transaction cannot be cancelled;
• delivery times are estimates and may be affected by cut-off times, public holidays, outages or compliance checks in either country; and
• you must ensure the Transaction is lawful in the destination country.

If a Cross-Border Transaction cannot be delivered, the full amount debited, including the Service Fee, is returned to your Balance within five (5) business days of the failure being confirmed.

4.5 Proof of Payment

After a successful Cross-Border Transaction or Education Payment, you can download a Proof of Payment Certificate from the Platform. It records the Transaction details. We cannot guarantee that any particular institution or authority will accept it.

4.6 Rate Alerts

You can set an alert for when an FX Rate reaches a level you choose. Alerts are for convenience only and are not financial advice. We make no prediction about future exchange rates and are not liable for decisions you make based on an alert.

5.1 Disclosure

Every Service Fee, the FX Rate and any statutory levy that applies to a Transaction are shown before you confirm it. You will not be charged any BorderFlo fee that was not shown at the point you authorised the Transaction.

5.2 Basis of Fees

Service Fees may be a flat amount, a percentage of the Transaction value, or both, depending on the Transaction type and destination. The current Schedule of Fees is published on the Platform. Fee changes follow the notice period in section 1.3.

5.3 Taxes and Statutory Levies

Transactions may attract taxes and levies imposed by law, including the Electronic Money Transfer Levy on qualifying transfers and Value Added Tax on our Service Fees. These are charged or collected as the law requires and shown before you confirm. Service Fees shown on the Platform include VAT.

5.4 Third-Party Charges

A bank, mobile money operator or other delivery network in the destination country may deduct its own charges. Where we know of these charges, we show them before you confirm. We do not control them, but if a charge we did not disclose reduces the amount received, contact support and we will investigate with our Payment Partner.

6.1 Who Holds Your Money

All money you add to your Wallet is held by our Payment Partner in designated accounts with licensed Nigerian banks, for your benefit and separately from BorderFlo's own money. BorderFlo never receives, holds or controls your funds. Your Wallet shows your Balance as recorded by our Payment Partner.

6.2 Funding Your Wallet

You can fund your Wallet by bank transfer to the account details shown in the Platform, or by any other method the Platform supports from time to time. Funds are available once our Payment Partner confirms receipt.

6.3 Withdrawals

You can withdraw your available Balance at any time to a Nigerian bank account in your own name, subject to your Account limits. Withdrawals are processed through NIP and are credited within the receiving bank's processing time.

6.4 No Interest

No interest or other return is paid on your Balance.

6.5 Dormancy

If there is no Transaction on your Account for twelve (12) consecutive months, we will notify you and may classify the Account as dormant. You can reactivate it by logging in and completing any verification we require. Your Balance remains your property at all times, and any unclaimed balance will be handled in line with CBN rules on dormant accounts and unclaimed balances.

You must not use the Platform, directly or indirectly, to:

• launder money, finance terrorism or the proliferation of weapons, or commit any offence under the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022 or other Applicable Law;
• pay for goods, services or assets prohibited in Nigeria or the destination country;
• send money on behalf of another person, act as an agent or money transfer business for others, or operate an informal value transfer scheme;
• split payments to avoid limits, monitoring or reporting thresholds;
• give false, misleading or fraudulent information to BorderFlo, our partners or any beneficiary;
• interfere with, circumvent or disable any security feature of the Platform;
• access another person's Account, or any BorderFlo system or data, without authorisation; or
• transmit malware, spam or unlawful content.

We may suspend or close your Account, or refuse a Transaction, if we reasonably suspect prohibited use. Where the law requires, suspicious activity will be reported to the NFIU and other competent authorities.

8.1 Screening and Monitoring

BorderFlo and our Payment Partner screen customers, beneficiaries and Transactions against sanctions lists and monitor Transaction patterns for signs of financial crime. You agree to provide any additional information or documents we request for a compliance review within the time stated in the request.

8.2 Reporting

Suspicious Transaction Reports and other mandatory reports are filed with the NFIU by our Payment Partner as the licensed institution, with BorderFlo's support, as required by law. These reports may be made without notice to you, and making them is not a breach of any duty of confidentiality.

8.3 Holds

We or our Payment Partner may place a temporary hold on a Transaction or your Account for a compliance review, identity verification, fraud prevention or a lawful directive. We will try to resolve any hold promptly and will keep you informed as far as the law allows.

All intellectual property in the Platform, including software, designs, trademarks, logos and content, belongs to BorderFlo or its licensors. We grant you a limited, personal, non-exclusive, non-transferable licence to use the Platform as these Terms permit. You must not copy, modify, decompile, reverse-engineer or create derivative works from the Platform without our written consent.

The Platform relies on licensed and specialist partners, including our Payment Partner (holding funds and executing Transactions), our Identity Verification Provider (identity verification), NIBSS (domestic payments) and banks or mobile money operators in destination countries (delivery of funds). Each partner operates under its own terms and regulatory obligations. We choose our partners carefully and remain responsible to you under these Terms for the service we provide, but we do not control third parties' systems.

11.1 Refund of Principal

If money is lost, misdirected or debited in error because of a mistake by BorderFlo, a failure of the Platform, or a failure of our Payment Partner or another partner we engaged, we will ensure the affected amount and any Service Fee charged on it are refunded to your Balance. This obligation is not limited by section 11.3.

11.2 Exclusions

To the extent permitted by Applicable Law, BorderFlo is not liable for:

• indirect or consequential loss, including loss of profit, revenue, business, data or goodwill;
• loss caused by events beyond our reasonable control, including force majeure, nationwide network outages and acts of government;
• loss caused by your breach of these Terms, inaccurate information you provided, or your failure to keep your credentials secure (subject to section 3.3); or
• a delay or refusal by an institution or beneficiary outside our partner network.

11.3 Cap

Apart from refunds under section 11.1 and liability that cannot legally be limited, our total liability to you for all claims in any twelve-month period is limited to the greater of the Service Fees you paid in that period and ₦100,000.

11.4 Your Statutory Rights

Nothing in these Terms limits any right you have under the Federal Competition and Consumer Protection Act 2018, the CBN Consumer Protection Regulations 2019, or any other law that cannot be excluded by contract.

You agree to compensate BorderFlo for reasonable losses, costs and legal fees it suffers as a direct result of your fraud, your unlawful use of the Platform, or your deliberate or negligent breach of these Terms.

13.1 Our Complaints Process

Contact us through in-app support or at support@borderflo.com. We acknowledge complaints within two (2) business days and aim to resolve them within fourteen (14) business days. Complaints about failed or unauthorised Transactions are handled within the timelines set by CBN rules, where shorter.

13.2 Escalation to Regulators

If you are not satisfied with our response, you may escalate to the CBN Consumer Protection Department through its complaint channels or to the Federal Competition and Consumer Protection Commission. This does not affect any other right you have.

13.3 Governing Law and Jurisdiction

These Terms are governed by the laws of the Federal Republic of Nigeria. Any dispute not resolved under sections 13.1 and 13.2 will be submitted to the courts of Lagos State, Nigeria, without limiting your right to approach any regulator or tribunal with jurisdiction.

14.1 Closure by You

You can close your Account at any time through the Platform. Before closing, make sure no Transactions are pending and withdraw your Balance to a Nigerian bank account in your name. We process closure requests within five (5) business days, subject to any outstanding compliance checks.

14.2 Closure or Suspension by Us

We may suspend or close your Account if:

• you breach these Terms, our KYC & AML Statement or our Privacy Policy;
• a regulator, court or law enforcement authority lawfully directs us to;
• we reasonably suspect money laundering, fraud or other unlawful use;
• your Account has been dormant for twenty-four (24) consecutive months after notice under section 6.5; or
• we stop operating the Platform or a relevant feature, in which case we will give you at least thirty (30) days' notice where possible.

Where we close your Account, your remaining Balance will be returned to a Nigerian bank account in your name once required compliance checks are complete, normally within thirty (30) business days, unless the law requires the funds to be held.

15.1 Entire Agreement

These Terms, the Privacy Policy, the KYC & AML Statement and the Schedule of Fees are the entire agreement between you and BorderFlo on their subject matter.

15.2 Severability

If a court finds any provision invalid, it will be modified to the minimum extent needed to make it enforceable, or removed, and the rest of these Terms will continue in effect.

15.3 No Waiver

If we do not enforce a provision on one occasion, we may still enforce it later.

15.4 Assignment

You may not transfer your rights or obligations under these Terms without our written consent. We may transfer ours to a successor in a merger, acquisition or restructuring, provided the successor takes on all our obligations to you and we give you notice.

15.5 Contact Information