PapayMoni Terms and Conditions (User Agreement)

Version 2.0 Effective: 24 May 2026 Last Updated: 24 May 2026

Please read these Terms and Conditions ("Terms") carefully before using the PapayMoni mobile application or any of its services. By creating an account or using the platform, you agree to be bound by these Terms in their entirety. If you do not agree with any part of these Terms, you must immediately discontinue use of the platform and services.

IMPORTANT NOTICE — NATURE OF PLATFORM: PapayMoni is a technology platform operated by Barsmiko Enterprise Limited. PapayMoni is NOT a bank, is NOT a deposit-taking institution, is NOT an electronic money institution (EMI), and is NOT a licensed financial institution. All settlement, withdrawal, and deposit services are processed exclusively through regulated and licensed third-party financial service providers. Barsmiko Enterprise Limited does not directly hold, manage, or custody user funds.

1. Definitions

"Platform" / "PapayMoni": The mobile application and associated web services operated by Barsmiko Enterprise Limited, providing technology-facilitated payment initiation, transaction orchestration, platform balance management, and settlement coordination services.

"Barsmiko" / "We" / "Us" / "Company": Barsmiko Enterprise Limited, a technology company registered in the Federal Republic of Nigeria (RC No. available upon request) and in England and Wales (Company No. available upon request), with registered offices as listed on our Contact Us page. Full company registration details are available upon written request.

"User" / "You": Any individual, business, or organisation aged 18 years or over who registers for and uses the PapayMoni platform or any of its services.

"Services": All features and functionalities provided through the PapayMoni platform, including but not limited to platform balance management, payment initiation, transaction coordination, currency conversion (facilitated through regulated third-party providers), bill payments, airtime top-ups, peer-to-peer transfers, and account management tools.

"Platform Balance": The transaction ledger value represented within your PapayMoni account. Platform balances are not bank deposits, are not insured, and do not constitute a custodial banking relationship. See Section 4 for full details.

"Regulated Third-Party Provider": A licensed and regulated financial service provider, payment processor, or banking institution through which PapayMoni facilitates settlement, payment, or financial infrastructure services on behalf of users.

"KYC": Know Your Customer — the identity verification process mandated by applicable financial crime, anti-money laundering, and regulatory laws.

"AML": Anti-Money Laundering — regulatory obligations designed to detect and prevent the use of the platform for financial crime.

"EDD": Enhanced Due Diligence — heightened scrutiny applied to higher-risk accounts, transactions, or relationships as required by applicable law.

2. Parties, Eligibility & Minimum Age

By accessing or using PapayMoni, you represent, warrant, and confirm that:

Barsmiko Enterprise Limited reserves the right to request further evidence of eligibility at any time and to suspend or terminate accounts where eligibility cannot be confirmed.

3. Nature of Services — Technology Platform

Safe Harbour Declaration

Barsmiko Enterprise Limited operates PapayMoni exclusively as a technology platform. The Company facilitates:

Barsmiko Enterprise Limited is expressly and unequivocally NOT:

All fiat payment processing, card processing, settlement, and payout services are facilitated exclusively through regulated and licensed third-party providers. Barsmiko Enterprise Limited does not hold regulatory authorisation as a financial institution in any jurisdiction unless explicitly and separately stated in writing.

4. Platform Balances

Balances displayed within your PapayMoni account are transaction ledger balances representing platform-managed value coordination only. They are not bank account balances.

Platform balances:

5. Third-Party Providers

PapayMoni may engage regulated third-party providers for the facilitation of payment, settlement, verification, and infrastructure services. These include, but are not limited to:

You acknowledge that:

6. Fees and Charges

PapayMoni charges a platform service fee of up to 4% (four per cent) per applicable transaction, subject to the following maximum fee caps per individual transaction:

Applicable fees may vary depending on:

All applicable fees will be clearly disclosed to you before you confirm any transaction. By confirming a transaction, you consent to the stated fee deduction. Any changes to the platform fee structure will be communicated via in-app notification or email no less than 14 days before taking effect, except where urgency or regulatory obligation requires otherwise.

Third-party providers may levy separate charges independently of PapayMoni's platform service fee. These charges are outside the control of Barsmiko Enterprise Limited.

7. Identity Verification, KYC & AML

In compliance with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and Know Your Customer (KYC) regulations in Nigeria, the United Kingdom, and other applicable jurisdictions, Barsmiko Enterprise Limited reserves the right to:

You agree to co-operate fully and promptly with all KYC, AML, and compliance verification requests. Failure to provide requested documentation within a reasonable timeframe may result in account restriction, suspension, or termination and the withholding of pending transactions pending compliance resolution.

Barsmiko Enterprise Limited may, and in certain circumstances is legally required to, report suspicious activity to relevant regulatory and law enforcement authorities (including but not limited to the Central Bank of Nigeria (CBN), the UK National Crime Agency (NCA), and applicable financial intelligence units) without prior notification to the user. This is a legal obligation and does not constitute a breach of confidentiality.

8. Acceptable Use

You may not use PapayMoni for any unlawful, fraudulent, or harmful purpose. Prohibited uses include but are not limited to:

Barsmiko Enterprise Limited reserves the right to immediately suspend or permanently terminate accounts where violations are suspected or confirmed, to freeze associated platform balances pending investigation, and to pursue recovery of any losses caused to the Company or third parties arising from prohibited use.

9. Supported Currencies & Funding Your Balance

PapayMoni supports platform balance transactions in multiple currencies as made available from time to time within the application. Currency availability is subject to jurisdictional restrictions and regulatory requirements.

Available funding methods include:

You must ensure that funds are sent in the correct currency to the matching balance account. PapayMoni accepts no liability for losses, delays, or reversal complications arising from incorrect currency routing by the user.

Account number generation and certain funding methods may be subject to jurisdictional availability, KYC completion tier, and applicable regulatory approvals. PapayMoni reserves the right to modify, restrict, or discontinue any funding method at any time with reasonable notice.

10. Withdrawals, Settlement & Compliance Holds

Withdrawal requests are processed through regulated third-party payment providers. Settlement timelines may vary depending on:

Barsmiko Enterprise Limited expressly and contractually reserves the right to delay, restrict, suspend, or withhold withdrawal processing where:

Barsmiko Enterprise Limited will use reasonable endeavours to notify you of any compliance hold where legally and operationally permitted to do so. The Company shall not be liable for any losses, costs, or damages arising from lawfully imposed compliance holds.

11. Cryptocurrency Services

Where cryptocurrency-related funding or conversion options are made available within the platform, such services are facilitated exclusively through regulated or licensed third-party cryptocurrency service providers operating in compliance with applicable law.

Cryptocurrency Risk Disclosure: Barsmiko Enterprise Limited does not directly custody cryptocurrency assets. Cryptocurrency values are highly volatile and can decrease significantly or become worthless. Past performance is not indicative of future performance. Cryptocurrency services may not be available in all jurisdictions and may be subject to separate terms from the applicable third-party provider. Any investment or transaction in cryptocurrency is undertaken entirely at your own risk.

Users in jurisdictions where cryptocurrency activity is restricted, prohibited, or unlicensed must not access cryptocurrency-related features. PapayMoni accepts no liability for regulatory action, financial losses, or penalties arising from a user's access to or use of cryptocurrency features from a restricted or prohibited jurisdiction.

12. Security and Data Privacy

PapayMoni implements industry-standard encryption (SSL/TLS and AES-256), multi-factor authentication options, and continuous system monitoring to protect your data and platform access.

You are responsible for:

Any action taken via your credentials is deemed to have been authorised by you unless you have promptly reported a security incident to our support team. Barsmiko Enterprise Limited reserves the right to suspend an account immediately where a security incident is reported or detected.

All personal data is collected and processed in accordance with our Privacy Policy, which forms an integral and binding part of these Terms. Our Privacy Policy sets out our obligations under the Nigeria Data Protection Regulation 2023 (NDPR), the UK General Data Protection Regulation (UK GDPR), and other applicable data protection legislation.

13. Limitation of Liability & Indemnification

13.1 Limitation of Liability

To the fullest extent permitted by applicable law, Barsmiko Enterprise Limited shall not be liable for any:

Where Barsmiko Enterprise Limited's liability cannot be entirely excluded under applicable law — including the Consumer Rights Act 2015 in the United Kingdom or equivalent consumer protection legislation — that liability is limited to the total amount of platform service fees actually paid by you to Barsmiko Enterprise Limited in the 12 months immediately preceding the event giving rise to the claim.

Nothing in these Terms excludes or limits liability for death or personal injury caused by Barsmiko Enterprise Limited's negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot be excluded or limited by applicable law.

13.2 Indemnification

You agree to indemnify, defend, and hold harmless Barsmiko Enterprise Limited, its directors, officers, employees, agents, and third-party service providers from and against all claims, proceedings, losses, damages, liabilities, costs, and expenses (including reasonable legal fees) arising from or in connection with:

14. Intellectual Property

All intellectual property rights in the PapayMoni platform, including its software, design, trademarks, trade names, logos, and content, are owned by or licensed to Barsmiko Enterprise Limited. You are granted a limited, non-exclusive, non-transferable, revocable licence to use the platform solely for its intended purpose as described in these Terms.

You must not:

By submitting feedback, suggestions, or ideas to Barsmiko Enterprise Limited, you grant the Company a perpetual, irrevocable, worldwide, royalty-free licence to use, reproduce, and incorporate such input for the purposes of improving and developing the platform.

15. Communication Preferences

Essential communications: PapayMoni will send you transactional and service-related communications (including transaction confirmations, security alerts, verification requests, and account notices) that are necessary for the operation and security of your account. These communications are not optional while your account remains active.

Marketing communications: PapayMoni will only send you promotional or marketing communications where you have expressly opted in to receive them. Opt-in consent to marketing is separate from, and not a condition of, accepting these Terms or using the platform.

You may withdraw your consent to receive marketing communications at any time by:

Withdrawal of marketing consent does not affect the lawfulness of any communications sent on the basis of earlier consent, and does not affect receipt of essential service communications.

16. Account Dormancy

An account is considered dormant where there has been no user-initiated transaction or login activity for a continuous period of 12 months or more.

Upon an account becoming dormant, Barsmiko Enterprise Limited may:

Unclaimed platform balances associated with dormant accounts will be handled in accordance with applicable Nigerian and United Kingdom regulatory requirements governing unclaimed balances. Barsmiko Enterprise Limited will use reasonable endeavours to notify you via registered email before any dormancy action is taken.

17. Refund Policy

17.1 Eligible Refunds

A refund request may be considered where:

17.2 Non-Refundable Situations

Refunds will not be issued where:

17.3 Processing Timelines

Barsmiko Enterprise Limited will use reasonable endeavours to process confirmed eligible refunds within 14 business days of verification and approval. Processing timelines may be extended due to third-party provider timelines, banking network schedules, or compliance review requirements. You will be notified of any material delay.

To initiate a refund request, contact papaymoni-support@barsmiko-inc.net with your transaction ID, registered account details, and a clear description of the issue.

18. Modifications & Version Control

Barsmiko Enterprise Limited may revise these Terms from time to time to reflect changes in law, regulation, platform features, or operational practice. All amendments will be assigned a new version number and effective date, as recorded in the Version History section (Section 24) of this document.

Material changes will be communicated to you via in-app notification or email no less than 14 days before taking effect, except where an urgent change is required by regulatory obligation, court order, or to address an immediate security or compliance risk.

Your continued use of the platform after the effective date of any revised Terms constitutes your acceptance of the updated Terms. If you do not accept the revised Terms, you must cease using the platform and contact us to initiate account closure.

19. Force Majeure

Barsmiko Enterprise Limited shall not be in breach of these Terms, nor liable for any delay or failure in performance, where such delay or failure results from events, circumstances, or causes beyond its reasonable control, including but not limited to: acts of God, natural disaster, war, civil unrest, government action, regulatory direction, sanctions enforcement, financial system failures, cyberattacks, pandemics, epidemic events, strikes, internet or telecommunications outages, or third-party infrastructure failures.

In such circumstances, Barsmiko Enterprise Limited will use reasonable endeavours to minimise disruption to users and to restore normal service as soon as reasonably practicable, and will communicate the nature and expected duration of any force majeure event where possible.

20. Severability

If any provision of these Terms is found by a court of competent jurisdiction to be invalid, unlawful, void, or unenforceable, that provision shall be deemed severed from the remainder of these Terms. The remaining provisions shall continue in full force and effect. The parties agree to replace any severed provision with a valid provision that achieves, as closely as possible, the original intent of the severed provision.

21. Governing Law

These Terms are governed and construed as follows, depending on your jurisdiction of residence:

(a) Nigerian Users

These Terms are governed by the laws of the Federal Republic of Nigeria. Subject to Section 22, disputes shall be subject to the jurisdiction of Nigerian courts or arbitration in Nigeria.

(b) United Kingdom Users

These Terms are governed by the laws of England and Wales. Nothing in these Terms removes, restricts, or limits your statutory rights as a consumer under the Consumer Rights Act 2015 (UK), the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, the Unfair Terms in Consumer Contracts Regulations 1999, or any other applicable UK consumer protection legislation. UK users who are consumers retain the right to bring proceedings before the courts of England and Wales, regardless of any other provision in these Terms.

(c) All Other Jurisdictions

These Terms are governed by the laws of England and Wales, without prejudice to any mandatory consumer protection or statutory provisions applicable in your local jurisdiction that cannot lawfully be excluded or overridden by contract.

22. Dispute Resolution

22.1 Internal Resolution (All Users)

In the event of any dispute, complaint, or claim arising from your use of PapayMoni, you should first contact our support team at papaymoni-support@barsmiko-inc.net with full details of your complaint. We will acknowledge receipt within 5 business days and endeavour to resolve the matter within 30 days.

22.2 Nigerian Arbitration

For Nigerian users, where internal resolution is unsuccessful, disputes may be referred to binding confidential arbitration conducted in Lagos, Nigeria, in accordance with the Arbitration and Conciliation Act 2023 (Nigeria). The language of arbitration shall be English.

22.3 United Kingdom Users

UK users who are consumers are not required to submit to arbitration and retain the right to pursue claims before the courts of England and Wales or through any applicable independent dispute resolution (ADR) scheme available under UK law.

22.4 Regulatory Complaints

Nothing in these Terms prevents you from lodging a complaint directly with a relevant regulatory authority, including:

23. Contact Information

For questions, support, compliance enquiries, or to exercise any rights under these Terms, please contact us using the following details:

24. Version History

Version Effective Date Summary of Changes
1.0 May 2025 Initial publication. Covered user obligations, BVN verification, fees (unspecified cap), limitation of liability (brief), arbitration in Nigeria only, and Nigerian governing law only. Contained non-compliant implied marketing consent clause and unenforceable arbitration clause for UK consumers.
2.0 24 May 2026 Full compliance rewrite. Key changes include:
  • Added Safe Harbour Declaration — explicit technology platform positioning (not a bank / not an EMI)
  • Added Platform Balance disclaimer (not deposits, not FSCS/NDIC protected)
  • Added dual governing law — Nigeria and England & Wales
  • Added UK Consumer Rights Act 2015 carve-out; corrected arbitration clause (UK consumers excluded from mandatory arbitration)
  • Added explicit fee cap: 4% / EUR 100 / USD 100 / GBP 100 maximum
  • Added detailed KYC, AML, and EDD section
  • Expanded Acceptable Use Policy (12 prohibited categories)
  • Added Withdrawal Compliance Hold rights (contractual basis for fund holds)
  • Added Cryptocurrency Services disclaimer and jurisdictional restriction
  • Corrected Communications Preferences to GDPR/PECR-compliant opt-in model
  • Added Force Majeure clause
  • Added Severability clause
  • Added Indemnification clause
  • Added Account Dormancy policy
  • Added Refund Policy (17.1 eligible, 17.2 non-refundable, 17.3 timelines)
  • Added Version Control framework
  • Removed: misleading "digital asset management" and "digital exchange" terminology from Definitions
  • Removed: specific Bybit reference from key definitions
  • Corrected: "bank-grade encryption" replaced with "industry-standard encryption (SSL/TLS and AES-256)"
  • Corrected: "100% uptime" representation removed