Terms of Service

1. Acceptance of Terms

These Terms of Service ("Terms") constitute a legally binding agreement between you ("User," "you," or "your") and TrustAm Technologies Ltd ("TrustAm," "we," "us," or "our"), a company incorporated under the laws of the Federal Republic of Nigeria (RC 1234567), with its registered office at Victoria Island, Lagos, Nigeria.

By downloading, installing, accessing, or using the TrustAm mobile application ("App"), website (www.trustamai.com), or any related services (collectively, the "Services"), you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy.

If you do not agree to these Terms, you must immediately cease using the Services. We reserve the right to refuse service to anyone for any reason at any time.

2. Description of Service

TrustAm provides the following services through its mobile application and website:

• AI-Powered Budgeting — Automated expense categorization and budget management powered by artificial intelligence, with categories localized for Nigerian financial life.
• Peer-to-Peer Payments — Instant money transfers between users, bank account transfers, bill payments, and airtime purchases, processed through our licensed payment service provider, Paystack.
• AI Financial Advisor — A conversational AI-powered financial advisor providing personalized budgeting guidance and savings tips in English, Pidgin English, Yoruba, Igbo, and Hausa.
• Open Banking Aggregation — Multi-bank account aggregation via Mono.co to provide a unified view of your financial life across Nigerian banks.
• Services Marketplace — A platform connecting service providers with customers across Nigeria in categories including beauty, events, home services, technology, and more.

TrustAm does not operate as a bank, deposit-taking institution, or microfinance bank. All payment services are provided through Central Bank of Nigeria (CBN)-licensed payment service providers, primarily Paystack (operated by Stripe Inc.).

3. Account Registration

To use certain features of the Services, you must create an account. When registering, you agree to:

• Provide accurate, current, and complete information during the registration process.
• Maintain and promptly update your account information to keep it accurate and complete.
• Maintain the security and confidentiality of your login credentials, PIN, and any biometric authentication methods.
• Accept responsibility for all activities that occur under your account.
• Notify TrustAm immediately of any unauthorized access to or use of your account.

You must be at least 18 years of age to create an account and use the Services. By registering, you represent and warrant that you are at least 18 years old and have the legal capacity to enter into binding agreements.

TrustAm reserves the right to suspend or terminate your account if any information provided is found to be inaccurate, misleading, or fraudulent.

4. Know Your Customer (KYC) Requirements

In compliance with Central Bank of Nigeria (CBN) regulations and the Money Laundering (Prohibition) Act 2022, TrustAm implements a tiered KYC verification system. Your transaction limits are determined by your verification level:

Tier 1 — Basic Verification

• Requirement: Phone number verification via OTP
• Daily transaction limit: ₦50,000
• Cumulative balance limit: ₦300,000

Tier 2 — Intermediate Verification

• Requirement: Bank Verification Number (BVN) verification
• Daily transaction limit: ₦200,000
• Cumulative balance limit: ₦1,000,000

Tier 3 — Full Verification

• Requirement: National Identification Number (NIN), government-issued photo ID, and address verification
• Daily transaction limit: ₦5,000,000
• Enhanced features and marketplace capabilities

You consent to TrustAm verifying your identity through third-party verification services including BVN lookups via Nigeria Inter-Bank Settlement System (NIBSS) and NIN verification via the National Identity Management Commission (NIMC). TrustAm may request additional documentation at any time to satisfy regulatory obligations or where we suspect fraudulent activity.

5. Payment Services

5.1 Payment Processing

All payment transactions on TrustAm are processed through Paystack, a CBN-licensed payment service provider. By initiating any payment or transfer, you authorize TrustAm and Paystack to process the transaction on your behalf. TrustAm does not hold, pool, or have custody of your funds at any time.

5.2 Transaction Authorization

Every payment transaction requires authentication through your transaction PIN and, where enabled, biometric verification (fingerprint or Face ID). You are solely responsible for all transactions authorized using your credentials. TrustAm shall not be liable for any unauthorized transactions resulting from your failure to safeguard your authentication credentials.

5.3 Transaction Limits

Transaction limits are governed by your KYC verification tier as outlined in Section 4. TrustAm reserves the right to impose additional limits on transactions that are flagged by our automated anti-money laundering (AML) monitoring systems.

5.4 Failed & Reversed Transactions

In the event of a failed transaction, TrustAm will initiate a reversal within the timeframes mandated by CBN guidelines. Refunds for bank transfers typically take 1–3 business days. TrustAm is not responsible for delays caused by recipient banks or payment infrastructure outages.

6. Marketplace Services

6.1 Platform Role

The TrustAm Marketplace connects service providers ("Providers") with users seeking services ("Clients"). TrustAm acts solely as an intermediary platform and is not a party to any service agreement between Providers and Clients. TrustAm does not employ, endorse, or guarantee any Provider listed on the platform.

6.2 Provider Obligations

Providers who register on the TrustAm Marketplace agree to: provide accurate descriptions of their services and pricing; deliver services as described and within agreed timeframes; maintain appropriate qualifications, licenses, and insurance for their trade; comply with all applicable Nigerian laws and regulations; and respond to booking requests within 24 hours.

6.3 Client Obligations

Clients agree to: provide accurate information when booking services; pay for services as agreed; treat Providers with respect and professionalism; leave honest and fair reviews; and report any issues through TrustAm's dispute resolution process.

7. Escrow & Payment Protection

For marketplace transactions, TrustAm provides an escrow payment protection service to safeguard both Providers and Clients:

• When a Client books a service, payment is held in escrow by our payment processor until the service is confirmed as complete.
• Funds are released to the Provider within 24–48 hours after the Client confirms satisfactory completion of the service, or automatically after 72 hours if no dispute is raised.
• In the event of a dispute, funds remain in escrow until the dispute is resolved through TrustAm's dispute resolution process.
• Refunds for cancelled bookings are processed according to the Provider's cancellation policy as displayed on their service listing.

Escrow services are provided through Paystack's payment infrastructure. TrustAm does not hold funds directly.

8. Fees

TrustAm's fee structure is as follows:

8.1 Peer-to-Peer Payments

Peer-to-peer transfers between TrustAm users are free of charge. Bank transfers may incur standard payment processor fees as displayed at the time of the transaction.

8.2 Marketplace Transactions

TrustAm charges a 5% service fee on completed marketplace transactions. This fee is deducted from the Provider's payout. The service fee covers platform maintenance, payment processing, escrow protection, and customer support.

8.3 Other Fees

Bill payments (airtime, data, electricity, etc.) may incur third-party processing fees as displayed at the point of transaction. TrustAm will always display the total cost, including any applicable fees, before you confirm a transaction. We reserve the right to modify our fee structure with 30 days' advance notice to users.

9. User Conduct

You agree not to use the Services for any unlawful purpose or in any way that could damage, disable, overburden, or impair the Services. Specifically, you shall not:

• Use the Services for money laundering, terrorism financing, fraud, or any activity that violates the Money Laundering (Prohibition) Act 2022 or the Terrorism (Prevention and Prohibition) Act 2022.
• Provide false, misleading, or fraudulent information during registration, KYC verification, or in marketplace listings.
• Attempt to circumvent transaction limits, KYC requirements, or security measures.
• Use the Services to harass, threaten, or defame other users or Providers.
• Scrape, crawl, or use automated tools to access the Services without written authorization.
• Reverse engineer, decompile, or disassemble any part of the Services.
• Use the platform to facilitate transactions for prohibited goods or services, including but not limited to narcotics, weapons, counterfeit goods, or stolen property.
• Create multiple accounts or share your account credentials with third parties.
• Manipulate ratings, reviews, or marketplace rankings through artificial means.

Violation of these conduct rules may result in immediate account suspension or termination, forfeiture of pending marketplace payouts, and reporting to relevant law enforcement authorities.

10. Intellectual Property

The Services, including but not limited to the App, website, software, algorithms, designs, text, graphics, logos, icons, images, audio clips, and the "TrustAm" name and logo, are the exclusive property of TrustAm Technologies Ltd and are protected by Nigerian and international copyright, trademark, and intellectual property laws.

You are granted a limited, non-exclusive, non-transferable, revocable license to use the Services for personal, non-commercial purposes in accordance with these Terms. This license does not include the right to: modify, copy, distribute, or create derivative works; use the Services for commercial purposes without written authorization; or sublicense or transfer your rights to any third party.

Content you upload to the marketplace (including service descriptions, images, and portfolio items) remains your property. However, you grant TrustAm a non-exclusive, worldwide, royalty-free license to use, display, reproduce, and distribute such content for the purpose of operating and promoting the Services.

11. Privacy

Your privacy is important to us. Our collection, use, storage, and sharing of your personal data is governed by our Privacy Policy, which is incorporated into these Terms by reference. By using the Services, you consent to the data practices described in the Privacy Policy. Our Privacy Policy has been prepared in compliance with the Nigeria Data Protection Act 2023 (NDPA) and regulations issued by the Nigeria Data Protection Commission (NDPC).

12. Limitation of Liability

To the maximum extent permitted by the laws of the Federal Republic of Nigeria:

• Services provided "as is": The Services are provided on an "as is" and "as available" basis. TrustAm makes no warranties, express or implied, regarding the reliability, availability, accuracy, or fitness for a particular purpose of the Services.
• No liability for third-party services: TrustAm shall not be liable for any loss, damage, or inconvenience arising from the actions, omissions, or failures of third-party service providers, including but not limited to Paystack, Mono.co, banks, telecommunications operators, or marketplace Providers.
• No liability for marketplace services: TrustAm is not responsible for the quality, safety, legality, or timeliness of services provided by marketplace Providers. Your engagement with Providers is at your own risk.
• Cap on liability: In no event shall TrustAm's total liability to you for all claims arising out of or relating to these Terms or the Services exceed the total fees paid by you to TrustAm in the twelve (12) months preceding the claim, or ₦50,000, whichever is greater.
• Exclusion of consequential damages: TrustAm shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including loss of profits, data, business opportunities, or goodwill, even if advised of the possibility of such damages.

Nothing in these Terms shall exclude or limit our liability for death or personal injury caused by our negligence, fraud, or any other liability that cannot be excluded or limited under Nigerian law.

13. Dispute Resolution

13.1 Marketplace Disputes

Disputes between Providers and Clients regarding marketplace transactions should first be reported through the TrustAm in-app dispute resolution system within 72 hours of service completion. TrustAm will review the dispute and make a determination within 7 business days. TrustAm's determination regarding escrow fund release is final with respect to the platform.

13.2 Disputes with TrustAm

Any dispute, controversy, or claim arising out of or in connection with these Terms shall be resolved as follows:

• Negotiation: The parties shall first attempt to resolve the dispute through good-faith negotiation within 30 days of written notice of the dispute.
• Mediation: If negotiation fails, the parties shall submit the dispute to mediation under the rules of the Lagos Court of Arbitration (LCA).
• Arbitration: If mediation fails, the dispute shall be finally resolved by arbitration under the Arbitration and Mediation Act 2023, administered by the Lagos Court of Arbitration. The arbitration shall be conducted in English in Lagos, Nigeria. The decision of the arbitrator(s) shall be final and binding.

Nothing in this section shall prevent either party from seeking injunctive or other equitable relief from a court of competent jurisdiction where necessary to protect its rights.

14. Governing Law

These Terms shall be governed by, and construed in accordance with, the laws of the Federal Republic of Nigeria, without regard to its conflict of law provisions. Any legal proceedings arising out of these Terms that are not subject to the arbitration clause in Section 13 shall be brought exclusively in the courts of Lagos State, Nigeria.

15. Anti-Money Laundering & Counter-Terrorism Financing

TrustAm is committed to preventing its platform from being used for money laundering, terrorism financing, or other financial crimes. In compliance with Nigerian AML/CFT regulations, TrustAm:

• Conducts real-time transaction monitoring using automated systems to detect suspicious patterns.
• Screens users against Politically Exposed Persons (PEP) lists, OFAC sanctions lists, EU sanctions lists, and UN Security Council consolidated lists.
• Files Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) with the Nigerian Financial Intelligence Unit (NFIU) as required by law.
• Reserves the right to freeze, suspend, or close accounts and withhold funds where suspicious activity is detected, pending investigation.
• Cooperates with law enforcement agencies and regulatory bodies in investigations related to financial crimes.

You agree to cooperate with TrustAm in fulfilling its AML/CFT obligations, including providing additional identity documentation when requested.

16. Account Suspension & Termination

TrustAm may suspend or terminate your account and access to the Services, with or without prior notice, for reasons including but not limited to:

• Violation of these Terms or any applicable laws and regulations.
• Suspected fraudulent, abusive, or illegal activity.
• Failure to complete required KYC verification within the timeframe specified.
• Extended period of inactivity (12 months or more).
• At the request of law enforcement or regulatory authorities.

You may terminate your account at any time by contacting [email protected]. Upon termination, any pending marketplace transactions will be completed or refunded in accordance with the applicable escrow terms. Any remaining balance will be transferred to your linked bank account within 30 business days.

17. Changes to Terms

TrustAm reserves the right to modify these Terms at any time. When we make material changes, we will:

• Notify you via in-app notification and email at least 30 days before the changes take effect.
• Update the "Last updated" date at the top of this page.
• Provide a summary of the key changes.

Your continued use of the Services after the effective date of the revised Terms constitutes your acceptance of the changes. If you do not agree to the revised Terms, you must stop using the Services and close your account.

18. Indemnification

You agree to indemnify, defend, and hold harmless TrustAm Technologies Ltd, its officers, directors, employees, agents, and affiliates from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or in connection with: your use of the Services; your violation of these Terms; your violation of any applicable law or regulation; your marketplace activities as either a Provider or Client; or any content you submit, post, or transmit through the Services.

19. Force Majeure

TrustAm shall not be liable for any failure or delay in performing its obligations under these Terms where such failure or delay results from events beyond our reasonable control, including but not limited to: natural disasters, pandemic or epidemic, war or civil unrest, government actions or regulations, power outages, telecommunications failures, internet service disruptions, bank or payment processor outages, strikes or labour disputes, and cyberattacks or security breaches despite reasonable security measures.

20. Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, or if modification is not possible, it shall be severed from these Terms. The remaining provisions shall continue in full force and effect.

21. Entire Agreement

These Terms, together with the Privacy Policy, constitute the entire agreement between you and TrustAm regarding your use of the Services and supersede all prior agreements, negotiations, representations, and proposals, whether written or oral, relating to the subject matter herein.

22. Contact Information

If you have any questions, concerns, or complaints about these Terms or the Services, please contact us: