Terms of service

1. Who you are contracting with

Vaultly is operated by [PayLab Technologies Limited], a company registered in Nigeria with number [RC NUMBER], registered office [ADDRESS] ("we", "us", "Vaultly"). In these terms "you" means the person who holds a Vaultly account.

We are [licensed/authorised] by the Central Bank of Nigeria as a [LICENCE TYPE], licence number [NUMBER]. You can verify this on the CBN register.

2. Where these terms apply

Vaultly is offered to residents of Nigeria only. These terms are governed by the laws of the Federal Republic of Nigeria, and the courts of [Lagos State] have jurisdiction over any dispute. Nothing here removes any right you have under Nigerian consumer protection law.

3. Who can open an account

To open a Vaultly account you must be at least 18, resident in Nigeria, able to enter a binding agreement, and able to complete identity verification. We may decline an application, and we will tell you why unless the law prevents us.

4. Your money and how it is protected

Money in your Vaultly wallet is electronic money, not a bank deposit. We hold customer funds separately from our own, in a designated account with [PARTNER BANK], a bank licensed by the Central Bank of Nigeria. We do not lend your balance out.

This means that if Vaultly were to fail, customer funds are held separately from our business assets and are intended to be returned to customers. [Confirm NDIC pass-through position before publishing.] Your wallet balance does not earn interest unless you place it in a SafeLock, which has its own terms.

5. What Vaultly does

• ✓Wallet. A naira balance you can add to, spend from and withdraw.
• ✓Transfers. Send to any Nigerian bank account, to another Vaultly user, or by request.
• ✓Bill payments. Airtime, data, electricity, cable television, betting top-ups and examination fees. We pass your payment to the biller; we are not the biller and cannot fix a fault in their service, though we will help you chase it.
• ✓Savings Vaults. Goal-based savings you can add to when you like or on a schedule.
• ✓SafeLock. Savings locked until a date you choose. The interest rate, the maturity date and any early-exit charge are shown before you commit, and those figures govern that SafeLock.
• ✓Loans. Short-term credit, subject to section 7.
• ✓Cards. Virtual cards, and physical cards where available, which you can freeze or cancel yourself.

Vaultly does not offer foreign currency accounts, international transfers or investment products. If that changes we will publish separate terms first.

6. Fees

Every fee is shown to you before you confirm a transaction. There are no fees you will discover afterwards.

If we introduce a new fee, or increase one, we will give you at least 60 days notice in the app and by email. You may close your account free of charge at any point before the change takes effect, and we will return your balance.

7. Loans

Before you accept a loan we will show you, on one screen: the amount you receive, the interest, the processing fee, the total you must repay, the annual percentage rate, and the date the full amount is due. You cannot accept a loan without confirming you have read that total.

• ✓We check that a loan is affordable for you, not only that you are eligible. We may decline on that basis.
• ✓You may cancel within 3 business days of disbursement by repaying the principal plus interest accrued to that day, and nothing else.
• ✓You may repay early, in part or in full, at any time. Early repayment reduces what you owe immediately.
• ✓If you pay late, a fee of 0.1% of the amount borrowed applies per day, capped at 10% of the amount borrowed in total. It cannot grow beyond that cap under any circumstances.
• ✓We never request access to your contacts, your photo gallery or your call logs, and we do not make access to them a condition of borrowing.
• ✓If you fall behind we contact you and only you. We do not contact your family, employer, referees or anyone in your address book about your debt.
• ✓If you are struggling to repay, tell us. We will discuss a repayment arrangement before taking any recovery action, and we will not charge you for asking.
• ✓We report repayment history to licensed credit bureaux, which affects your credit record. We will tell you before we report a default.

8. If a transaction goes wrong

Tell us as soon as you notice. You can raise a dispute from the transaction itself, and you will get a case reference you can track.

• ✓Payments you did not authorise. If someone takes money from your account without your authority, we will refund it, unless we can show you acted fraudulently or with gross negligence. We will refund first and investigate afterwards where the facts allow.
• ✓Payments that did not arrive. If a transfer you authorised does not reach the recipient, we will trace it and either complete it or refund you.
• ✓Wrong details. If you give us an account number that turns out to be wrong, the payment may not be recoverable. We will make real efforts to get it back, tell you what we find, and give you the information you need to pursue it yourself.
• ✓Duplicate charges. If you are charged twice for the same thing, we refund the duplicate.

You must tell us within 13 months of the transaction date. Sooner is better, because recovery gets harder with time.

9. If you need to complain

We would rather hear it. Email complaints@vaultly.app or raise it in the app under Help and Support.

• ✓We acknowledge every complaint within 1 business day and give you a reference number.
• ✓We aim to resolve it within 14 days. If it is complex we will tell you why and keep you updated at least every 7 days.
• ✓You will always get a written outcome explaining the decision and the reason for it.
• ✓If you are unhappy with our answer, or we have not resolved it within 30 days, you can escalate to the Consumer Protection Department of the Central Bank of Nigeria at cpd@cbn.gov.ng, and to the Federal Competition and Consumer Protection Commission.

Our full complaints procedure is published on this site and we do not close a case without recording an outcome and telling you what it is.

10. If you need extra support

Some people need more help than others, for reasons that can be permanent or temporary: a health condition, a bereavement, a difficult financial period, low confidence with technology, or something else entirely. Tell us and we will adjust how we deal with you. That may mean more time, a different channel, plainer explanations, or pausing collections activity while you get advice. Asking costs you nothing and does not affect your account standing.

11. Keeping your account safe

• ✓Keep your passcode private and your device secure. Do not share your PIN or one-time codes with anyone, including anyone claiming to be from Vaultly. We will never ask for them.
• ✓Tell us immediately at security@vaultly.app if you think someone has your credentials or your device is lost.
• ✓Keep your phone number, email and address up to date, so we can reach you.
• ✓We may ask you to verify your identity again, for example before raising your limits.

12. When we can suspend or close an account

We may suspend or close your account if we reasonably suspect fraud or money laundering, if you break these terms, or if the law requires it.

Where we close your account for any other reason, we will give you at least 60 days notice. We will tell you the reason unless the law prevents us. In every case we return your balance to a verified account of yours, less anything you owe us, and less any amount we are legally required to hold.

13. What you must not do

Do not use Vaultly for anything illegal, including fraud and money laundering. Do not use someone else's account without their authority, interfere with our security, or try to access accounts or systems that are not yours. Doing any of this may end your account and may be reported to the authorities.

14. Our responsibility to you, and its limits

We are responsible for providing the service with reasonable care and skill, and for the specific commitments in sections 6, 7, 8 and 9.

We are not responsible for losses we could not reasonably have foreseen, for the acts of a biller or bank we pass your instruction to, or for events outside our reasonable control such as a national network failure.

Nothing in these terms limits our liability for fraud, for death or personal injury caused by our negligence, or for anything else that cannot be limited under Nigerian law. In particular, nothing here removes your right to a refund for an unauthorised payment under section 8.

15. Your information

How we collect, use and protect your personal information is set out in our Privacy Policy, which forms part of this agreement.

16. Closing your account

You can close your account at any time in Settings, or by emailing us. Withdraw your balance first, or tell us where to send it. Closing an account does not cancel a loan you still owe.

17. Changes to these terms

We may update these terms. For any change that affects your rights or costs, we will give you at least 30 days notice in the app and by email, and 60 days for a change to fees. If you do not accept a change you may close your account free of charge before it takes effect.

18. Contact

General questions: support@vaultly.app. Complaints: complaints@vaultly.app. Security: security@vaultly.app. Legal: legal@vaultly.app. Written correspondence: [ADDRESS].