User Agreement

1. Eligibility

• You must be at least 18 years of age to use Airkobo. Our Services are not available to persons under 18 and by accepting this Agreement you confirm you meet this requirement.
• You must be a resident of, or legally present in, the Federal Republic of Nigeria, or be a Nigerian citizen using the Services for Nigeria-based bill payments.
• You must have the legal capacity to enter into a binding contract under Nigerian law.
• Your account must not have been previously suspended or terminated by us for a breach of this Agreement or any applicable law.

2. Account registration and identity verification

To access the full functionality of Airkobo, including your dedicated NGN wallet, you must complete our identity verification (KYC) process. This is required by the Central Bank of Nigeria (CBN) KYC Directives, the Money Laundering (Prevention and Prohibition) Act 2022 and related regulations.

• You agree to provide accurate, current and complete information during registration and KYC, including your full legal name, date of birth, BVN and a valid government-issued identity document.
• You agree to update your account information promptly if it changes. Providing false, incomplete or misleading information is a breach of this Agreement and may constitute a criminal offence under Nigerian law.
• Your account is personal to you. You must not share your login credentials, PIN or biometric data with any third party. You are solely responsible for all activity that occurs under your account.
• You must notify us immediately at support@airkobo.com if you suspect any unauthorised access to or use of your account.
• We reserve the right to refuse, suspend or terminate any account at our discretion where we have reason to believe the account is being used fraudulently, in breach of this Agreement or in violation of any applicable law.

3. Your Airkobo wallet

• Upon successful KYC verification, you may be issued a dedicated Nigerian Naira (NGN) virtual account number through our licensed payment-partner bank. Funds credited to that account number are reflected in your Airkobo wallet balance.
• Your wallet balance is held by our licensed partner institution and is not a deposit at Airkobo Technology Ltd. Airkobo is not a bank and does not hold a CBN banking licence. Your funds are safeguarded in accordance with applicable CBN regulations for payment service providers.
• You are solely responsible for ensuring that beneficiary details you enter (meter numbers, decoder numbers, phone numbers, account numbers) are correct. We cannot reverse a successfully delivered service based on incorrect beneficiary details provided by you.
• We may impose transaction limits, daily spending caps or wallet balance limits in compliance with CBN tier-based KYC requirements. These limits will be communicated to you in the app.
• Wallet balances do not earn interest. We are not responsible for losses arising from the insolvency of a partner institution, except to the extent required by law.

4. Payments and transactions

• Every payment instruction you give, whether by text, voice or direct tap, constitutes an authorisation for us to debit your wallet or process a card payment on your behalf for the amount and beneficiary you confirm.
• All payment instructions are final once you confirm them. You must review all details carefully before confirming.
• If a transaction fails after your wallet is debited, we will reverse the amount to your wallet within the timeframe prescribed by CBN dispute-resolution guidelines, typically within 5 business days.
• For biller-side failures (where your payment reaches the biller but the service is not delivered), we will raise a dispute with the relevant biller on your behalf and credit your wallet once a resolution is received. We are not liable for delays caused by the biller.
• We maintain records of all your transactions in accordance with CBN record-keeping requirements (minimum 7 years) and will make these available to you on request.

5. The AI assistant

• The Airkobo AI assistant interprets natural-language instructions and converts them into payment actions. It always presents the interpreted action to you for confirmation before any money moves.
• You remain solely responsible for reviewing and confirming every payment instruction before authorising it. Confirming a transaction you did not intend because you did not read the confirmation screen does not entitle you to a refund.
• We do not guarantee that the AI assistant will correctly interpret every instruction. If you are unsure, use the manual payment flow. The AI is a convenience tool, not a substitute for your own due diligence.
• Interaction data with the AI assistant (text and voice inputs) is processed by Airkobo to fulfil your request and improve the Service. It is handled in accordance with our Privacy Policy.

6. Fees and charges

• Airkobo charges a small flat service fee on selected bill categories. Where a direct-payment processing fee applies (for non-wallet payments), it is capped and disclosed to you before you confirm.
• All fees are displayed in full before you confirm any transaction. You will never be charged a fee that was not disclosed at the point of confirmation.
• Fees are subject to change. We will provide at least 14 days' advance notice of any increase in fees through in-app notification or email.
• Service fees are non-refundable once a transaction has been successfully processed.

7. Your personal data and NDPA rights

By creating an account, you acknowledge that Airkobo Technology Ltd processes your personal data as Data Controller in accordance with our Privacy Policy and the Nigeria Data Protection Act 2023 (NDPA).

• Consent to KYC processing: you give explicit consent to the processing of your BVN and identity-document data for identity verification, fraud prevention and compliance with CBN and AML obligations. This consent is required to access the wallet feature; you may withdraw it by closing your account, subject to our statutory data-retention obligations.
• Consent to transaction processing: each payment instruction you confirm constitutes consent to processing the associated personal and financial data to fulfil that transaction.
• Consent to communications: you consent to receiving transactional notifications, payment confirmations, security alerts and renewal reminders. You can manage marketing communication preferences in Settings at any time.
• Your NDPA rights: you have the right to access, correct, delete, port, restrict processing of, and object to the processing of your personal data. Full details of how to exercise these rights are set out in our Privacy Policy (Section 13 and Section 14).
• Complaint to the NDPC: if you believe your data rights have been violated, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.

8. Prohibited uses

You agree not to use the Services:

• For any unlawful purpose or in violation of any applicable Nigerian or international law, including the Cybercrimes (Prohibition, Prevention, etc.) Act 2015, the Money Laundering (Prevention and Prohibition) Act 2022, the Economic and Financial Crimes Commission (Establishment) Act, the Terrorism (Prevention and Prohibition) Act and CBN regulations.
• To launder money, finance terrorism or conduct any other financial crime, including structuring transactions to evade reporting thresholds.
• To process payments on behalf of third parties without their explicit knowledge and consent.
• To attempt to gain unauthorised access to any system, network or data, or to reverse-engineer, decompile or tamper with any part of the Services.
• To provide false, misleading or fraudulent information at any stage, including during KYC.
• To create multiple accounts for the purpose of circumventing transaction limits, suspensions or any other control.
• To engage in any activity that disrupts, degrades or impairs the Services for other users.

Breach of this section may result in immediate account suspension, termination and/or reporting to the relevant law-enforcement or regulatory authority (including the EFCC, NFIU, and CBN).

9. Intellectual property

All content, trademarks, logos, software, AI models and other intellectual property forming part of the Services are owned by or licensed to Airkobo Technology Ltd. No part of the Services may be copied, reproduced, distributed or used for commercial purposes without our express written consent. Your account grants you a limited, non-exclusive, non-transferable, revocable licence to access and use the Services for your own personal, non-commercial bill payment purposes.

10. Service availability and changes

We strive to maintain continuous service availability but do not guarantee uninterrupted access. The Services may be interrupted for scheduled maintenance, regulatory compliance updates or factors outside our control (including network outages, biller downtimes and acts of God). We will endeavour to provide advance notice of planned downtime where possible.

We reserve the right to modify, suspend or discontinue any feature of the Services at any time. Where a change materially affects your use of the Services, we will provide at least 30 days' notice, except where a shorter timeframe is required by law or regulatory direction.

11. Suspension and termination

• By you: you may close your account at any time through the in-app settings or by contacting support@airkobo.com. Any positive wallet balance will be refunded to a Nigerian bank account you specify, subject to identity verification, within 10 business days.
• By us: we may suspend or terminate your account immediately and without notice if we have reasonable grounds to believe you have breached this Agreement, engaged in fraudulent activity, or if we are required to do so by a regulator or law-enforcement agency.
• Upon termination, your right to access the Services ceases immediately. Provisions of this Agreement that by their nature should survive termination (including Sections 8, 9, 12, 13 and 14) will continue to apply.

12. Limitation of liability

To the maximum extent permitted by Nigerian law:

• Airkobo's total liability to you for any claim arising out of or in connection with the Services, whether in contract, tort or otherwise, shall not exceed the total fees paid by you to Airkobo in the three months immediately preceding the event giving rise to the claim.
• We are not liable for: indirect, consequential, incidental or punitive losses; loss of profit, revenue or data; losses arising from biller failures, network outages or acts of third parties; or losses arising from your failure to comply with this Agreement.
• Nothing in this Agreement limits our liability for death or personal injury caused by our negligence, fraud, or any liability that cannot be excluded by Nigerian law.
• We are not liable for losses arising from your failure to keep your login credentials, PIN or biometric data secure, or from your use of the Services in breach of this Agreement.

13. Indemnification

You agree to indemnify, defend and hold harmless Airkobo Technology Ltd, its directors, officers, employees and agents from and against any claims, damages, losses, liabilities, costs and expenses (including reasonable legal fees) arising out of or relating to: (a) your use of the Services; (b) your breach of this Agreement; (c) your violation of any applicable law; or (d) any false or misleading information you provide to us.

14. Governing law

This Agreement is governed by and shall be construed in accordance with the Laws of the Federal Republic of Nigeria, including but not limited to the Companies and Allied Matters Act (CAMA) 2020, the CBN Act, the Cybercrimes Act 2015, the NDPA 2023 and all relevant CBN regulations and guidelines.

15. Dispute resolution

We encourage you to contact our support team first to resolve any dispute informally:

• Email: support@airkobo.com
• Phone: +234 800 000 0000

If we cannot resolve the matter informally within 30 days, either party may refer the dispute to arbitration under the Arbitration and Conciliation Act (Cap A18, LFN 2004) as amended, with a sole arbitrator appointed by agreement of the parties or, failing agreement, by the Chartered Institute of Arbitrators (Nigeria Branch). The seat of arbitration shall be Lagos, Nigeria. The language of arbitration shall be English.

Nothing in this clause prevents either party from seeking urgent injunctive or other interim relief from a court of competent jurisdiction in Nigeria.

16. Amendments

We may revise this Agreement at any time. Where a change is material, we will give you at least 30 days' advance notice via in-app notification or email. Your continued use of the Services after the effective date of the revised Agreement constitutes your acceptance of the changes. If you do not accept the revised Agreement, you must stop using the Services and close your account before the effective date.

17. Entire agreement and severability

This Agreement, together with our Privacy Policy, Terms of Service and Cookie Policy, constitutes the entire agreement between you and Airkobo with respect to the Services and supersedes all prior agreements, representations and understandings. If any provision of this Agreement is found to be unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect.

18. Contact us

For any questions about this Agreement:

• Support: support@airkobo.com
• Phone: +234 800 000 0000
• Data Protection Officer: dpo@airkobo.com
• Address: AIRKOBO TECHNOLOGY LTD, Lagos, Nigeria
• Registration: RC No. 9626141, Corporate Affairs Commission (Nigeria)