FLEX Merchant Terms of Use

Effective Date: 18th July, 2025

These Merchant Terms of Use ("Terms") govern your access to, and use of the FLEX Merchant App ("App") provided by ReflexPay Limited ("FLEX", "we", "our", or "us"). By registering as a merchant or using the App to receive payments, you agree to be bound by these Terms.

1. Eligibility and Verification

1.1. You may register as a merchant on FLEX if you meet the following conditions:

• Sole Proprietor: Must provide a valid BVN and NIN. CAC registration is optional.
• Registered Business: Must provide CAC registration documents, BVN, and authorized representative information.

Important: Merchant verification is required before any funds can be withdrawn from the wallet. Unverified merchants may receive payments but cannot initiate withdrawals.

• 1.1.1. General Access: FLEX Merchant App is now officially available to the public and can be accessed by downloading the app from the App Store or Google Play Store.
• 1.1.2. Age Restriction: You must be 18 years or older to use FLEX Merchant App. By using the app, you confirm that you meet this age requirement.
• 1.1.3. Geographic Availability: Our Know Your Customer (KYC) requirements limit merchant account registration to merchants who own a registered business in Nigeria and possess a Bank Verification Number issued by The Central Bank of Nigeria.
• 1.1.4. Bank Verification Number (BVN): Users are required to provide a valid BVN during registration. This ensures compliance with Central Bank of Nigeria (CBN) financial regulation and enhances user account security.
• 1.1.5. National Identification Number (NIN): We may require submission of a valid National Identification Number (NIN) as part of the KYC process.
• 1.1.6. KYC Verification: FLEX uses trusted CBN approved KYC partners to verify user identity during the onboarding and registration process. This ensures CBN compliance and enhances security for all users. As part of FLEX's identity verification process, we may utilize Smile ID to validate biometric data (e.g., facial recognition). FLEX does not store your biometric likeness on its servers. All biometric processing is handled by Smile ID and governed by their Privacy Policy.

2. Merchant Account and PayTag

• 2.1. Upon registration, you will be assigned a unique PayTag and QR Code that customers can use to make payments to your business.
• 2.2. You are responsible for managing your PayTag and must not impersonate any brand, public figure, or use deceptive identifiers.
• 2.3. PayTags may be reassigned or suspended if deemed misleading, inactive, or in violation of our terms.

3. KYC and Identity Verification

• 3.1. All merchants are required to complete identity verification through our approved KYC partners. Smile ID Privacy Policy
• 3.2. FLEX reserves the right to request additional documents at any time to maintain regulatory compliance.
• 3.3. Submission of false or fraudulent documents will result in immediate suspension and possible legal action.

4. Receiving Payments

4.1. You may accept payments via:

• FLEX PayTag
• QR Code
• USSD Short code (if enabled)
• Payment Request (via the app)

5. Payments and Transactions

FLEX uses licensed payments companies 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.

Customers must authorize each transaction; FLEX is not responsible for disputes arising from non-fulfillment of services.

6. Fees and Settlements

• Standard merchant transaction fee: 1% capped at ₦500 per transaction.
• Payouts to your linked bank account may follow standard settlement windows (e.g. T+1).
• Instant settlement (optional): May incur additional processing fees.
• FLEX reserves the right to hold or delay payouts for risk monitoring, dispute resolution, or compliance checks.

7. Wallet and Withdrawal Policies

• 7.1. There is no wallet balance limit for merchants. However, withdrawal of funds is only available to merchants who have completed the necessary KYC verification.
• 7.2. Minimum withdrawal: ₦5,000. Withdrawal attempts below this threshold will not be processed.

8. Withdrawal Authorization

• 8.1. To ensure the security of your account and prevent unauthorized access, FLEX requires strong authentication for all transactions. You must authorize each transaction using at least one of the following secure methods:
• Biometric verification (such as fingerprint or facial recognition)
• Personal Identification Number (PIN)
• Pattern lock
• If biometric authentication is unavailable, users can authorize payments using their device's passcode for added security.
• 8.2. By using FLEX, you agree to keep your chosen authentication method confidential and to immediately report any suspected unauthorized access or security breach.

9. Refunds, Disputes & Chargebacks

• You are responsible for resolving service or delivery-related disputes with customers.
• In cases of formal dispute, FLEX may freeze the transaction amount until resolution is achieved.
• Customers may request refunds within the app. Excessive refund claims may trigger a merchant review.

10. Prohibited Activities

10.1. You agree not to use FLEX to:

• Sell illegal, counterfeit, or prohibited goods/services
• Engage in fraud, identity theft, or money laundering
• Circumvent payment or settlement systems
• Mislead customers or misrepresent your identity or business

FLEX may suspend or terminate merchant access without notice if these activities are suspected.

11. Updates and Maintenance

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

12. Marketing and Promotions

• FLEX may provide you with promotional tools, QR codes, and shareable links.
• Merchants are encouraged to promote FLEX-powered payments via social media or in-store materials.
• You may not offer cash incentives to customers without prior approval from FLEX.

13. Data Protection and Privacy

13.1. FLEX is committed to protecting your privacy and ensuring the security of your personal information in compliance with applicable data protection laws, including the Nigeria Data Protection Act (NDPA) and relevant global standards. We collect, use, store, and share your personal data only for legitimate purposes related to the operation of our services, including:

• Verifying your identity and conducting Know Your Customer (KYC) checks
• Facilitating transactions and managing your wallet
• Communicating with you about your account, services, or updates
• Detecting and preventing fraud or unauthorized activity
• Complying with legal and regulatory obligations

Your data may be shared with trusted third-party service providers (e.g., payment processors, verification partners) under strict confidentiality and data protection agreements. We do not sell or rent your personal information to any third parties.

By using FLEX, you consent to the use of your business name, PayTag, and logo in promotional materials unless you opt out in writing, and our collection and use of your data as outlined in our Privacy Policy.

13.2. Data Security: We implement robust security measures—including encryption, firewalls, and secure authentication protocols—to protect your information from unauthorized access, loss, or misuse. For more information, please review our full Privacy Policy.

13.3. KYC Data Handling: Data collected during the KYC process will be securely stored and processed by our trusted KYC partners – Dojah Inc. and Smile ID. Please review their policies: Dojah and Smile ID.

13.4. Switching Company Transactions: FLEX relies on licensed switching companies and/or banks to process payments and transfers securely. FLEX utilizes SarePay to facilitate secure payments and transaction processing. Their Privacy Policy applies to all related services.

13.5. Biometric & Likeness Rights: You grant FLEX and its verification partners the limited right to process your likeness (face image) for the sole purpose of identity verification. No biometric data is stored on FLEX servers.

14. Sender Information Display

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

15. Termination and Account Closure

• 15.1. You may close your merchant account by submitting a written request and clearing all pending settlements.
• 15.2. FLEX may terminate your account at any time for breach of terms, compliance issues, or fraud.
• 15.3. Upon termination, all pending funds (minus fees or liabilities) will be settled within 30 business days.

16. Governing Law and Dispute Resolution

These Terms are governed by the laws of the Federal Republic of Nigeria. Any dispute will be resolved through arbitration in Lagos, Nigeria, in accordance with applicable laws.

17. Contact Information

For inquiries or support, please reach out to: techsupport@yourflexpay.com

By using FLEX, you confirm that you have read, understood, and agreed to these Terms and Conditions. If you do not agree, please discontinue use immediately.