1.1 General Access: Flex is now officially available to the public and can be accessed by downloading the app from the App Store or Google Play Store.

1.2 Age Restriction: You must be 18 years or older to use Flex. By using the app, you confirm that you meet this age requirement.

1.3 Geographic Availability: FLEX is available for users across the globe. However, our Know Your Customer (KYC) requirements limit account registration to users who possess a Bank Verification Number issued by The Central Bank of Nigeria. Regional KYC availability will be announced as global expansion is rolled out.

1.4 Bank Verification Number (BVN): Users are required to provide a valid BVN during registration. This ensures compliance with Nigerian financial regulations and enhances user account security.

1.5 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

2.1 BVN Requirement: A valid BVN is mandatory to verify your identity, secure your account, and ensure compliance with financial regulations. Your BVN is used solely for this purpose and will not be shared with unauthorized third parties.

2.2 NIN Requirement: Your NIN may be used to fulfill regulatory KYC obligations. It is not stored locally and is handled through secure transmission to our KYC verification partners in compliance with the Nigeria Data Protection Act (NDPA).

2.3 Account Protection: You are responsible for securing your account credentials and ensuring the security of your device. FLEX implements advanced security measures, but you must take precautions to protect your data.

• 2.3.1 KYC Process: As part of our onboarding process, you consent to undergo identity verification through our KYC partner. This process involves collecting and securely processing personal information to ensure compliance with Central Bank of Nigeria (CBN) anti-money laundering (AML) and other regulatory requirements. Our partners, including Smile ID and Dojah, are responsible for securely processing identity documents and biometrics. FLEX does not store this data. See their individual privacy policies for additional details. These partners act as sub-processors under legally binding Data Protection Agreements (DPAs) in compliance with Nigerian and global data protection regulations.

2.4 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.

3.1 Wallet Balance Limit: To ensure compliance with financial regulations and maintain operational integrity, FLEX imposes wallet balance limits based on user verification tiers. These limits are as follows:

• 3.1.1. Tier 1 - SILVER (Basic Level - Phone Number + BVN Only)This tier is suitable for users with minimal verification. Transaction functionality may be limited. Maximum Wallet Balance: ₦300,000.00
• 3.1.2. Tier 2 - GOLD (Intermediate Level - National Identification Number [NIN] and Selfie/Face Match)This tier provides access to increased transaction limits and additional services upon successful verification. Maximum Wallet Balance: ₦500,000.00
• 3.1.3. Tier 3 - PLATINUM (Address Verification, and Selfie/Face Match)This tier allows for the highest wallet limit and access to all FLEX features and financial tools. Maximum Wallet Balance is not applicable for PLATINUM users
• 3.1.4. Custom Tier - DIAMOND RESERVE which requires minimum PLATINUM status, is a discretionary status granted to select users by FLEX. This tier may offer increased wallet limits, exclusive features, and personalized support. Entry is invitation-only and governed by internal FLEX evaluation criteria.” FLEX reserves the right to adjust wallet or transaction limits at its discretion, based on ongoing compliance reviews, transaction behavior, or risk monitoring.

Note: It is your responsibility to ensure your wallet balance does not exceed the applicable limit for your tier. FLEX may restrict incoming funds or require you to reduce your balance before permitting further transactions if your wallet exceeds its tiered limit.

3.2 Transaction Limits: : Transaction limits may apply depending on your KYC level (SILVER, GOLD, OR PLATINUM).

• SILVER: Daily Transaction Limit: ₦50,000.00
• GOLD: Daily Transaction Limit: ₦200,000.00
• PLATINUM: Daily Transaction Limit: ₦5,000,000.00

Visit our account limits page for more details. FLEX may impose daily or per-transaction limits for deposits, withdrawals, and transfers. These limits will be clearly communicated within the app and are subject to change.

3.3 Minimum Withdrawal Amount: All withdrawals must meet a minimum amount of ₦1,000 to ensure efficient processing. Transactions below this amount will not be processed.

• 3.3.1 Daily Withdrawal Limit is capped at ₦500,000.00 for all users.

4.1 App Functionality: Flex offers features such as wallet funding, peer to peer transfers, and merchant payments.

• 4.1.2 Users can also withdraw funds from their FLEX wallet, subject to applicable daily withdrawal limits and minimum balance requirements.

• 4.1.3 Withdrawals may be made to verified Nigerian bank accounts only.

• 4.1.4 Transaction failures will be resolved in accordance with our Refund Policy.

• 4.1.5 Withdrawal attempts below the minimum threshold or during pending review periods will not be processed.

• 4.1.6 For withdrawal issues, users must contact support within 24 hours of the failed withdrawal transaction to trigger a formal resolution process, which may take up to 72 hours.

4.2 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.

4.3 Prohibited Activities: You agree not to use the app for illegal, fraudulent, or malicious purposes. Violations may result in immediate termination of your account and possible legal action, and or prosecution.

5.1 Privacy & Data Collection: 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. You have the right to access, correct, or request deletion of your personal data, subject to legal and operational requirements. By using FLEX, you consent to our collection and use of your data as outlined in our Privacy Policy.

5.2 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.

5.3 KYC Data Handling: Data collected during the KYC process will be securely stored and processed by our trusted KYC partners - Dojah Inc. Privacy Policy. and Smile ID Privacy Policy. This ensures user privacy and compliance with regulatory standards.

5.4. Switching Company Transactions: FLEX relies on licensed switching companies and/or banks to process payments and transfers securely. These partnerships ensure that your financial data is handled with the utmost care and compliance with industry standards. FLEX utilizes SarePay to facilitate secure payments and transaction processing. Their data policies apply to all related services. Please review SarePay's Privacy Policy. for more details

5.5. 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. Your likeness is processed in accordance with the policies of our biometric KYC partners.

6.1 Biometric Authentication: 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.

6.2. By using FLEX, you agree to keep your chosen authentication method confidential and to immediately report any suspected unauthorized access or security breach.

7.1 Transaction Fees:

• Peer-to Peer (P2P) transactions are free on FLEX.
• All withdrawals will be subject to a flat fee of ₦53.75
• Fees for all merchant payments will be based on a sliding scale. See here for more information

All fees will be clearly displayed before you confirm any transaction.

7.2 Refund Policy:

• In the case of failed withdrawals or unresolved outbound transfers, users must notify the FLEX Support Team via the app or email within 24 hours. Once validated, the transaction will be investigated and resolved within 3-5 business days.
• If the issue is due to third-party banking systems, resolution timelines may vary, and users will be kept updated throughout the process.

10.1 Program Overview: The Referral Points Program (“the Program”) is a discretionary promotional scheme provided by ReflexPay Limited (“FLEX”) to incentivize user growth and engagement. By participating, users agree to the terms outlined herein, in addition to the general Terms and Conditions.

10.2 Eligibility: Participation is open exclusively to Flex users who have completed full account verification, including but not limited to Know Your Customer (KYC) requirements such as BVN validation, phone number verification, and device authentication.

10.3 Earning Referral Points: Users (“Referrers”) may earn points when a referred user (“Referee”) registers on the FLEX platform using the Referrer's referral code and completes account registration and verification.

• 10.3.1 The allocation of points will be determined in accordance with the applicable Referral Points schedule at the time of the referral.
• 10.3.2 Referees may earn monetary rewards at the discretion of ReflexPay Limited.

10.4 Reward Redemption Conditions:

• 10.4.1 Redemption is available exclusively in the form of cash credited to the user's Flex wallet.
• 10.4.2 Points shall only be awarded upon successful top up of a minimum of N500 (Five Hundred Naira) by the referee.
• 10.4.3 Points shall only be redeemable upon accumulation of a minimum of 5,000 points.
• 10.4.4 FLEX reserves the right to impose additional redemption conditions, including but not limited to withdrawal limits and compliance reviews.
• 10.4.5 Any attempt to manipulate, abuse, or fraudulently participate in the Program, including but not limited to self-referrals or circumvention of system rules, may result in disqualification, forfeiture of accrued points, or permanent account suspension.

10.5 Non-Transferability & Non-Exchangeability: Points awarded under the Program are personal to the user, non-transferable, non-assignable, and possess no monetary value until such time as they are validly redeemed in accordance with these terms.

• 10.5.1 Points awarded under the Program are personal to the user, non-transferable, non-assignable, and possess no monetary value until such time as they are validly redeemed in accordance with these terms.

10.6 Attribution Model:

• 10.6.1 Points will be credited based on a last-click attribution model, meaning the Referrer whose PayTag was used at the time of registration will exclusively receive credit. FLEX shall not be liable to adjudicate disputes between users arising from referral claims

10.7 Program Limitations and Abuse Control:

• 10.7.1 FLEX reserves the right to monitor all activity relating to the Program. Any attempt to manipulate, abuse, or fraudulently participate in the Program, including but not limited to self-referrals, creation of fake accounts, or circumvention of system rules, may result in disqualification, forfeiture of accrued points, or permanent account suspension.

10.8 Point Validity:

• 10.8.1 Points accumulated shall not expire unless FLEX provides prior written notice through platform communication channels. FLEX reserves the right to introduce an expiry policy subject to regulatory compliance.
• 10.8.2 Points awarded to accounts that do not complete any transaction shall be forfeited upon closure of such accounts.

10.9 Amendments and Termination:

• 10.9.1 FLEX retains absolute discretion to modify, suspend, or terminate the Referral Points Program, including its structure, mechanics, and rewards, at any time without prior notice.
• 10.9.2 In the event of voluntary account closure, all unredeemed referral points and rewards will be permanently forfeited. Redemption must be completed before closure.

13.1 Governing Law: These Terms and Conditions are governed by the laws of The Federal Republic of Nigeria.

13.2 Dispute Resolution: Disputes arising from the use of Flex will be resolved through mediation or arbitration in accordance with Nigerian law.

14.1 Termination by Flex: Flex reserves the right to suspend or terminate your account if these Terms and Conditions are violated.

14.2 Termination by User: Users may close their accounts at any time. However, any liabilities incurred during account usage remain enforceable.

For inquiries or support, please reach out to:

• Email: techsupport@yourflexpay.com