Compliance & Regulatory Disclosure

INSPIREME PAY COMPLIANCE & REGULATORY DISCLOSURE This document sets out who we are, who we work with, and the compliance programme behind the platform. 1. Who we are, and who we are not InspireMe Pay is a Nigerian technology company that provides collection, tracking, reconciliation and reporting software to organizations. We are not a bank, not a deposit-taking institution, not an e-money issuer and not a licensed lender. We do not accept deposits and we do not hold customer deposits. Any wallet balance shown in the app is an operational balance used to make payments on the platform, not a bank deposit, and it is not insured by the Nigeria Deposit Insurance Corporation (NDIC). 2. Our licensed partners Payment processing, dedicated virtual accounts, bank-transfer inflows and settlement payouts are provided through licensed partners: - Flutterwave, a payment processor licensed by the Central Bank of Nigeria - Safe Haven MFB, a microfinance bank licensed by the Central Bank of Nigeria Funds are processed, held and settled by these partners under their own licences, terms and regulatory obligations. The provider handling a given transaction is identified in your dashboard and on the transaction or settlement record. 3. Anti-money laundering and counter-terrorist financing We maintain an AML/CFT programme that includes: - Customer due diligence: identifying and verifying every organization and its owners or authorized signatories before collections are enabled, using CAC registration, valid ID, address proof, NIN, BVN and bank account details as applicable - Screening: checks against available sanctions, watchlist and adverse-media sources at onboarding and on an ongoing basis - Transaction monitoring: threshold and pattern-based monitoring, including review before settlement of unusual activity - Reporting: reporting to the Nigerian Financial Intelligence Unit (NFIU) as required by law, including Currency Transaction Reports for large cash transactions, currently above N5,000,000 for individuals and N10,000,000 for corporate bodies, and Suspicious Transaction Reports for suspicious activity at any amount. We do not disclose the filing of a report to the person concerned - Records: we retain customer identification and transaction records for at least five years after the transaction or after the end of the relationship, and produce them to regulators on request - Governance: a designated compliance officer, staff training, and periodic review of our risk assessment 4. Consumer protection - Fees and charges are disclosed before a payment is made and shown on receipts - Settlement requests, transaction statuses and balances are visible in your dashboard - Complaints are acknowledged within 24 hours, and failed or disputed electronic transactions are targeted for resolution within 72 hours, as set out in our Refund & Dispute Resolution Policy - If our handling is not satisfactory, a complaint can be escalated to the Consumer Protection Department of the Central Bank of Nigeria or to the FCCPC 5. Data protection We process personal data in line with the Nigeria Data Protection Act (NDPA) 2023: on a lawful basis, for the purposes we state, for no longer than we need it, and with technical and organizational safeguards. Our Privacy Policy explains the details, including how to exercise your rights of access, correction, deletion, restriction, portability and objection, and how to reach our Data Protection Officer through our support channels. Where our technology and hosting providers operate outside Nigeria, data may be transferred outside Nigeria with contractual safeguards and in line with NDPA cross-border transfer requirements. Organizations using InspireMe Pay are the data controllers for their staff, customer, parent and student records, and we process that data on their instructions. 6. Loans, payroll and statutory deductions Where loan, payroll or deduction features are enabled, they run on the organization's instructions and through licensed partners, and the organization remains responsible for statutory obligations to PENCOM, the Federal Inland Revenue Service, state tax authorities and other bodies. InspireMe Pay provides computation and record-keeping tools and does not provide financial, tax or investment advice. 7. Security Access is protected by one-time-code verification, role-based permissions and device checks. Sensitive data is protected in transit and at rest. Payment webhooks are signature-verified, wallet movements use atomic conditional updates, and key account and money-movement actions are logged for audit. Contact us through in-app support or the contact form on our website, including for compliance or data protection queries.