Terms and Conditions for ReflexPay Mobile App

1.1 General Access: ReflexPay is now officially available to the public and can be accessed by downloading the app from the App Store or Google Play Store.

1.2 Age Restriction: You must be 18 years or older to use ReflexPay. By using the app, you confirm that you meet this age requirement.

1.3 Geographic Availability: ReflexPay is currently available for users in Nigeria. Future availability in other regions will be announced as expansions are rolled out.

1.4 Bank Verification Number (BVN): Users are required to provide a valid BVN during registration. This ensures compliance with Nigerian financial regulations and enhances user account security.

1.5 KYC Verification: ReflexPay uses a trusted Know Your Customer (KYC) partner to verify user identities during the onboarding process. This step ensures regulatory compliance and enhances security for all users.

2.1 BVN Requirement: A valid BVN is mandatory to verify your identity, secure your account, and ensure compliance with financial regulations. Your BVN is used solely for this purpose and will not be shared with unauthorized third parties.

2.2 Account Protection: You are responsible for securing your account credentials and ensuring the security of your device. ReflexPay implements advanced security measures, but you must take precautions to protect your data.

2.3 KYC Process: As part of our onboarding process, you consent to undergo identity verification through our KYC partner. This process involves collecting and securely processing personal information to ensure compliance with Central Bank of Nigeria (CBN) anti-money laundering (AML) and other regulatory requirements.

2.4 Switching Partner for Transactions: ReflexPay uses a licensed switching company to facilitate secure and seamless money movement between accounts. This ensures that all transfers and payments are processed reliably and in compliance with Nigerian financial laws.

3.1 Wallet Balance Limit: To ensure compliance with financial regulations, wallet balances are capped at ₦300,000. You are responsible for ensuring that your balance does not exceed this limit, and you may be required to reduce it before conducting further transactions.

3.2 Transaction Limits: Transaction limits may apply depending on your account type and verification level. Visit our account limits page for more details. ReflexPay may impose daily or per-transaction limits for deposits, withdrawals, and transfers. These limits will be clearly communicated within the app and are subject to change.

3.3 Minimum Transaction Amount: All withdrawals must meet a minimum amount of ₦1,000 to ensure efficient processing. Transactions below this amount will not be processed.

4.1 App Functionality: ReflexPay offers features such as wallet funding, peer to peer transfers, and merchant payments. Users are expected to use these services responsibly and in compliance with Nigerian laws.

4.2 Updates and Maintenance: To access new features and ensure optimal app performance, users are required to download updates when prompted. ReflexPay reserves the right to disable access for outdated app versions.

4.3 Prohibited Activities: You agree not to use the app for illegal, fraudulent, or malicious purposes. Violations may result in immediate termination of your account and possible legal action, and or prosecution.

5.1 Data Collection: ReflexPay collects personal and transactional data to improve the platform and comply with financial regulations. All data is handled per ReflexPay's Privacy Policy, which is accessible within the app.

5.2 Security Measures: While ReflexPay employs industry-standard security protocols, no system is entirely immune to risks. Users must safeguard their personal information and passwords.

5.3 KYC Data Handling: Data collected during the KYC process will be securely stored and processed by our trusted partner. This ensures user privacy and compliance with regulatory standards.

5.4 Switching Company Transactions: ReflexPay relies on a licensed switching company to process payments and transfers securely. This partnership ensures that your financial data is handled with the utmost care and compliance with industry standards.

6.1 Biometric Authentication: ReflexPay supports biometric authentication (Face ID or fingerprint) for seamless and secure payment authorization.

6.2 Passcode Backup: If biometric authentication is unavailable, users can authorize payments using their device's passcode for added security.

7.1 Transaction Fees: Peer-to Peer (P2P) transactions are free on ReflexPay. ReflexPay charges transaction fees for withdrawals and merchant payments based on a sliding scale. These fees will be clearly displayed before you confirm any transaction.

7.2 Refund Policy: Refunds for failed transactions will be processed within a reasonable time frame. Please contact our support team for assistance.

When funds are transferred, the sender's name displayed on your transaction details may reflect ReflexPay's 'PayTag' rather than the sender's actual name. Full transaction records are accessible within the app for verification.

We reserve the right to reclaim, reassign, or modify any PayTag at our sole discretion, without liability to the user. PayTags are issued solely for use on our platform in accordance with our policies and do not constitute personal property or exclusive ownership.

A PayTag may be subject to reassignment, modification, or revocation if it is deemed:

• Inactive for an extended period, as defined by our usage policies.
• Misleading, deceptive, or inappropriate, including but not limited to offensive, harmful, or otherwise objectionable content.
• Impersonating a public figure, brand, or entity in a manner that could cause confusion or violate rights.
• Violating our guidelines or posing a risk to the integrity and security of our platform.

We reserve the right to take appropriate action, including renaming, reclaiming, or revoking a PayTag, to ensure compliance with our policies and to maintain a safe and trustworthy user experience.

Upon account creation, the Customer's account will be placed in a "Pending for Review" status. During this period, which may take up to 24 hours, withdrawals will not be permitted. The review process is conducted to ensure compliance with our policies and security measures. Once the review is successfully completed, the Customer will be notified, and standard account functionalities, including withdrawals, will be enabled.

11.1 Program Overview: The Referral Points Program (“the Program”) is a discretionary promotional scheme provided by ReflexPay Technologies Limited (“ReflexPay”) to incentivize user growth and engagement. By participating, users agree to the terms outlined herein, in addition to the general Terms and Conditions.

11.2 Eligibility: Participation is open exclusively to ReflexPay users who have completed full account verification, including but not limited to Know Your Customer (KYC) requirements such as BVN validation, phone number verification, and device authentication.

11.3 Earning Referral Points: Users (“Referrers”) may earn points when a referred user (“Referee”) registers on the ReflexPay platform using the Referrer's PayTag and:

• Completes account registration and verification
• Successfully tops up their ReflexPay wallet with a minimum of ₦500
• Completes at least one qualifying transaction

The allocation of points will be determined in accordance with the applicable Referral Points schedule at the time of the referral.

11.4 Reward Redemption Conditions:

• Redemption is available exclusively in the form of cash credited to the user's ReflexPay wallet.
• Points shall only be redeemable upon accumulation of a minimum of 5,000 points.
• ReflexPay reserves the right to impose additional redemption conditions, including but not limited to withdrawal limits and compliance reviews.

11.5 Non-Transferability & Non-Exchangeability: Points awarded under the Program are personal to the user, non-transferable, non-assignable, and possess no monetary value until such time as they are validly redeemed in accordance with these terms.

11.6 Attribution Model: Points will be credited based on a last-click attribution model, meaning the Referrer whose PayTag was used at the time of registration will exclusively receive credit. ReflexPay shall not be liable to adjudicate disputes between users arising from referral claims.

11.7 Program Limitations and Abuse Control: ReflexPay reserves the right to monitor all activity relating to the Program. Any attempt to manipulate, abuse, or fraudulently participate in the Program, including but not limited to self-referrals, creation of fake accounts, or circumvention of system rules, may result in disqualification, forfeiture of accrued points, or permanent account suspension.

11.8 Point Validity: Points accumulated shall not expire unless ReflexPay provides prior written notice through platform communication channels. ReflexPay reserves the right to introduce an expiry policy subject to regulatory compliance.

11.9 Amendments and Termination: ReflexPay retains absolute discretion to modify, suspend, or terminate the Referral Points Program, including its structure, mechanics, and rewards, at any time without prior notice.

To maintain an active ReflexPay wallet, a minimum balance of ₦250 is required at all times. This amount will be reserved and not available for transactions. The available balance displayed in your wallet reflects the funds you can use, excluding the required minimum balance.

If a user initiates a request to withdraw their full wallet balance, including the ₦250 minimum, it will be treated as a request to close the account. Upon completion of the withdrawal, the wallet will be deactivated, and any future use will require re-registration.

ReflexPay reserves the right to adjust the minimum balance requirement with prior notice to users, in accordance with applicable regulations and business needs.

13.1 Governing Law: These Terms and Conditions are governed by the laws of The Federal Republic of Nigeria.

13.2 Dispute Resolution: Disputes arising from the use of ReflexPay will be resolved through mediation or arbitration in accordance with Nigerian law.

14.1 Termination by ReflexPay: ReflexPay reserves the right to suspend or terminate your account if these Terms and Conditions are violated.

14.2 Termination by User: Users may close their accounts at any time. However, any liabilities incurred during account usage remain enforceable.

For inquiries or support, please reach out to:

• Email: techsupport@getreflexpay.com