1. Indemnification

By using our service, the User agrees to protect SevPay from any legal or financial harm resulting from the use of any of our services across all our platforms. The User shall be responsible for any loss resulting from providing inaccurate information.

2. Dispute Resolution

All disputes arising from the use of any of SevPay’s services shall be resolved solely by arbitration. The seat of arbitration, cost and panel of arbitrators shall be mutually agreed upon and all decisions made by the arbitrators shall be deemed final and binding.

3. Entire Agreement and Modifications

This agreement is the complete legal document outlining the use of the SevPay services by the User and it overrides all prior agreements. Any alterations to this agreement shall be made in writing and the User shall be duly notified before using SevPay’s services.

4. Parties

SevPay may involve various parties in delivering its services to the User. This could include:

• Subsidiary and affiliate companies that SevPay owns or controls.
• Partner companies that assist SevPay in providing the service, such as banks, telephone service providers, or other financial institutions. These partners may help with payment processing, identity verification, or handle customer support inquiries.

By using SevPay, the User acknowledges that these other parties may be involved in the facilitation of the User’s transactions. The User also consents to SevPay assigning its roles to any of the parties mentioned above to aid the fulfillment of its obligations.

5. Governing Laws

The legal terms depend on the location of the User upon using any of SevPay’s services.

• Nigeria: All relevant Nigerian federal and state laws, rules and regulations.
• Outside Nigeria: All relevant Nigerian federal and state laws, rules and regulations.

1. Introduction

We understand the importance of protecting the User’s personal information and our privacy policy is geared at minimizing data breaches. This privacy policy explains how SevPay collects, uses, discloses, and safeguards the User’s data. By using any of our platforms, the User hereby agrees to the terms of this privacy policy. SevPay reserves the right to make changes to this policy. The User will be notified of all changes made to this policy and SevPay shall keep updated the "Last Updated" date across all its service platforms. The User is encouraged to periodically review this policy agreement to keep abreast of the policies and any new updates.

2. What Information We Collect

• Personal Data: This includes things like name, email address, and any other information the User voluntarily provides while using our services.
• Public Data: SevPay allows the User to share information on its platforms. Any data the User discloses in these public areas can be accessed by anyone who uses SevPay’s platforms.
• Device Data: SevPay collects information about the User’s device to help optimize service usability and delivery. This includes but is not limited to the User’s device's model, operating system, phone number, country, and location. The User may also choose to share additional information such as their contacts.
• Financial Data (Limited): SevPay collects some data related to the User’s payment methods, such as payment receipts and choice of payment methods (e.g., debit card, bank transfer). SevPay does not store the User’s card details or other sensitive financial information. These sensitive pieces of information are collected and stored by the independent payment partners used by SevPay. For more information on how these data are collected and stored, the User is advised to review the privacy and data protection policies of the payment partners used by SevPay.
• Push Notifications: SevPay may request permission to send the User push notifications. These notifications might include information about the User’s transactions, account updates, or promotional offers. The User has the discretion to disable push notifications and stop receiving push notifications.

3. Use of User’s Data

SevPay may share the User’s data under these circumstances:

• Legal Requirements: Personal data may be disclosed if it is required by law to disclose such information, especially in cases where the rights and safety of others are at risk. This includes sharing data to prevent fraudulent activities.
• Service Providers: SevPay uses third-party service providers for various tasks (e.g., data analysis and customer support). These providers may have access to the User’s data purely for functionality purposes.
• Marketing (with User’s consent): SevPay may share the User’s data with third parties after obtaining consent. The data shared must be used strictly for marketing purposes only.
• Public Interactions on Various Platforms: Any information the User shares publicly on any of SevPay’s platforms will be visible to other users that interact with SevPay’s platforms.
• Business Transactions: SevPay may transfer the User’s data in connection with a business transaction, such as a merger or acquisition.
• Third-Party Websites: SevPay isn't responsible for the privacy practices of the other websites the User visits through any of the links on the various SevPay platforms. The User has the responsibility of reviewing the privacy policy of any third-party website before providing any personal information.
• Security: SevPay uses security measures to protect data; however, we cannot guarantee complete security as no online data transmission is completely risk-free.

1. Definitions

• Money Laundering (ML): This is a financial transaction that aims at concealing the origin, identity, and destination of money obtained illegally by converting it to a cleaner source in order to avoid detection from law enforcement agencies.
• Terrorism Financing: This involves funding terrorist activities either directly or indirectly by giving money to terrorists or terrorist organizations irrespective of whether the funds used are obtained legally or otherwise.
• Financial Intelligence Unit (FIU): These are government agencies that collect and analyze information about financial transactions. They use this information to identify and investigate potential money laundering and terrorism financing.
• Politically Exposed Persons (PEPs): These are people who hold high-level government positions or have close connections to those who do. Because of their positions, they may be at a higher risk of being involved in bribery or corruption. Financial institutions need to be especially careful when doing business with PEPs.
• Enterprise Risk Management (ERM): This is the process a company uses to identify, assess, and manage risks that could affect its ability to achieve its goals. Money laundering and terrorism financing are both risks that financial institutions need to consider as part of their ERM plan.
• Client: In the context of SevPay, this refers to anyone who uses their services, including individuals and businesses. SevPay needs to assess the risk that each client poses, especially the risk of being involved in financial crimes.

2. Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CFT)

1. Why This Policy Exists

Money laundering and terrorism financing are serious crimes that can destabilize economies and financial systems. Money laundering involves criminals disguising the source of their illegally obtained money. Terrorism financing involves raising money to support terrorist activities. These crimes can harm people and businesses, and they can erode trust in financial institutions.

SevPay has a responsibility to help fight these crimes. By following a strong AML/CFT policy, SevPay can help to prevent its services from being used by criminals. This helps to protect SevPay's reputation and keeps the financial system safe for everyone.

2. Benefits of the Policy

• Protects SevPay's reputation and financial stability: By following AML/CFT rules, SevPay helps to avoid being involved in financial crimes. This protects SevPay's reputation and keeps the company financially stable. If SevPay were to be caught facilitating money laundering or terrorism financing, it could face serious consequences, including fines, reputational damage, and even criminal charges. This could damage SevPay's ability to operate and could lead to financial losses.
• Promotes a safe and secure financial environment: AML/CFT policies help to deter criminals from using the financial system. This creates a safer and more secure environment for everyone who uses financial services, including SevPay's customers. When criminals are able to launder money or finance terrorism through the financial system, it undermines the integrity of the system and makes it more difficult for legitimate businesses and individuals to operate. By following AML/CFT rules, SevPay helps to make the financial system safer for everyone.

3. Key Requirements

Know Your Customer (KYC)

SevPay needs to verify the identity of their customers before allowing them to use their services. This helps to ensure that criminals cannot hide behind fake accounts to launder money or finance terrorism. KYC procedures typically involve collecting basic information about the customer, such as their name, address, date of birth, and government-issued ID number. SevPay may also need to verify this information by checking it against public databases or documents. In some cases, SevPay may also need to collect additional information about the customer, such as their source of income or the reason for using their services.

Monitor Transactions

SevPay needs to monitor all transactions that take place on their platform for suspicious activity. This could include transactions that are unusually large or complex, transactions that involve high-risk countries or customers, or transactions that are inconsistent with the customer's normal activity. SevPay may use a variety of tools and technologies to monitor transactions, such as transaction monitoring software and sanctions screening lists.

Report Suspicious Activity

If SevPay detects any suspicious activity, they are required to report it to the authorities. This helps to ensure that potential money laundering or terrorism financing can be investigated and stopped. The specific requirements for reporting suspicious activity may vary depending on the jurisdiction in which SevPay operates.

Train Employees

SevPay’s employees are trained on how to identify and report suspicious activity. This is essential for ensuring that SevPay's AML/CFT program is effective. Employee training covers topics such as the risks of money laundering and terrorism financing, signs of suspicious activity, and how to report suspicious activity.

Compliance Officer

A qualified compliance officer will oversee the AML/CFT program. The compliance officer is responsible for developing and implementing SevPay's AML/CFT policies and procedures, as well as for monitoring and reporting on compliance. The compliance officer should have a strong understanding of AML/CFT regulations and should be able to keep up with changes in the law.