User Agreement

1. Acceptance of Terms

By creating an account or using KomKom's services, you agree to be bound by this User Agreement and all applicable laws and regulations. If you do not agree with any part of these terms, you may not use our services.

This agreement constitutes a legally binding contract between you ("User," "you," or "your") and KomKom, a subsidiary of Black Financial Consulting Group ("we," "us," or "our"). By accessing or using our platform, you acknowledge that you have read, understood, and agree to comply with these terms.

2. Description of Services

KomKom provides a digital payment platform that enables users to:

• Convert Nigerian Naira (NGN) to USD Coin (USDC), a stablecoin pegged to the US Dollar
• Convert USDC back to Nigerian Naira for local spending
• Store digital assets securely in an encrypted wallet
• Generate professional invoices for payment requests
• Create and share Request-to-Pay (R2P) payment links
• Accept payments through multiple channels including bank transfers, cards, and crypto networks

Our services are designed to help Nigerian users protect their savings from inflation by providing access to stable, USD-backed digital currency. All custody, liquidity, execution, settlement, and regulatory reporting are performed by our licensed partner, Yellow Card Financial.

3. Eligibility

To use KomKom services, you must:

• Be at least 18 years of age or the legal age of majority in your jurisdiction
• Be a resident of Nigeria or a country where our services are available
• Have the legal capacity to enter into binding contracts
• Provide accurate, current, and complete information during registration
• Successfully complete our Know Your Customer (KYC) verification process, which includes identity verification through QoreID (VerifyMe)
• Not be prohibited from using our services under applicable laws or regulations

We reserve the right to refuse service, terminate accounts, or cancel transactions at our sole discretion, especially in cases where we suspect fraudulent activity, violation of these terms, or non-compliance with regulatory requirements.

4. Account Registration and Security

4.1 Account Creation: To access our services, you must create an account by providing your legal name, email address, phone number, and other required information. You agree that all information provided is accurate, truthful, and complete.

4.2 KYC Verification: As part of our regulatory obligations, we require all users to complete identity verification through our KYC process. This includes providing government-issued identification, biometric verification, and Bank Verification Number (BVN) checks conducted by QoreID (VerifyMe). Failure to complete KYC verification may result in limited account functionality or account suspension.

4.3 Account Security: You are responsible for maintaining the confidentiality of your account credentials, including your password and two-factor authentication codes. You agree to:

• Use a strong, unique password that is not used for other services
• Enable two-factor authentication (2FA) for enhanced security
• Never share your login credentials with anyone
• Immediately notify us of any unauthorized access or security breaches
• Log out from your account after each session, especially on shared devices

You are solely responsible for all activities that occur under your account. KomKom will not be liable for any losses resulting from unauthorized use of your account, whether with or without your knowledge.

5. USDC Transactions and Conversions

5.1 On-Ramp (NGN to USDC): When you convert Nigerian Naira to USDC, the conversion is executed at the prevailing market rate at the time of the transaction. Exchange rates are subject to market fluctuations and may change without notice. All conversions are processed through our licensed partner, Yellow Card Financial.

5.2 Off-Ramp (USDC to NGN): When you convert USDC back to Nigerian Naira, the conversion is executed at the prevailing market rate. Converted funds will be deposited to your designated Nigerian bank account or mobile wallet. Processing times may vary depending on the receiving institution.

5.3 Transaction Finality: All transactions are final once confirmed on the blockchain or payment network. We do not support transaction reversals except in cases of verified fraud or system errors. You are responsible for ensuring the accuracy of all transaction details before confirming.

5.4 USDC Custody: Your USDC is held in custody by Yellow Card Financial under their VASP license. KomKom does not directly hold or control your digital assets. All custody arrangements comply with applicable regulatory requirements.

6. Fees and Charges

6.1 Transaction Fees: KomKom offers free conversions between NGN and USDC. However, certain services may incur fees, including but not limited to:

• Network fees for blockchain transactions (gas fees)
• Withdrawal fees for transferring funds to external wallets or bank accounts
• Premium features for business accounts (invoice generation, advanced analytics)
• Expedited transaction processing (where available)

6.2 Fee Disclosure: All applicable fees will be clearly displayed before you confirm a transaction. We reserve the right to modify our fee structure at any time, with advance notice provided to users.

6.3 Third-Party Fees: You may incur additional fees from third-party service providers, such as your bank or mobile network operator. These fees are beyond our control and are not included in our fee structure.

7. Prohibited Activities

You agree not to use KomKom services for any unlawful or prohibited activities, including but not limited to:

• Money laundering, terrorist financing, or other financial crimes
• Fraudulent transactions or misrepresentation of information
• Trading, exchanging, or facilitating the sale of illegal goods or services
• Operating gambling, betting, or lottery services without proper licensing
• Violating any applicable laws, regulations, or third-party rights
• Attempting to gain unauthorized access to our systems or user accounts
• Using our services to circumvent currency controls or sanctions
• Creating multiple accounts to evade transaction limits or verification requirements
• Manipulating market prices or engaging in market abuse

We reserve the right to monitor transactions for suspicious activity and report any suspected illegal activity to relevant authorities. Violation of these prohibitions may result in immediate account suspension, termination, and legal action.

8. Account Termination

8.1 Termination by User: You may close your account at any time by contacting our support team. Before closing your account, you must withdraw or convert all remaining balances. We are not responsible for any funds left in closed accounts.

8.2 Termination by KomKom: We reserve the right to suspend or terminate your account at any time, with or without notice, for any of the following reasons:

• Violation of this User Agreement or our policies
• Failure to complete KYC verification or provide requested documentation
• Suspected fraudulent, illegal, or suspicious activity
• Non-compliance with applicable laws or regulatory requirements
• Prolonged inactivity (accounts inactive for more than 12 months)
• Request by law enforcement or regulatory authorities

8.3 Effect of Termination: Upon termination, you will lose access to your account and all associated services. You remain responsible for any outstanding obligations, fees, or liabilities incurred before termination. We will make reasonable efforts to allow you to withdraw remaining balances, subject to applicable laws and regulations.

9. Limitation of Liability and Disclaimers

9.1 Service "As Is": KomKom services are provided "as is" and "as available" without warranties of any kind, either express or implied. We do not guarantee that our services will be uninterrupted, error-free, or completely secure.

9.2 Market Risks: You acknowledge that digital currencies and cryptocurrency markets are subject to significant volatility and risk. While USDC is designed to maintain a stable value pegged to the US Dollar, we do not guarantee its value or stability. You assume all risks associated with holding, trading, or converting digital assets.

9.3 Limitation of Liability: To the maximum extent permitted by law, KomKom, its affiliates, directors, employees, and partners shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, or business opportunities, arising from or related to your use of our services.

9.4 Maximum Liability: Our total liability to you for any claims arising from or related to these terms or our services shall not exceed the total fees paid by you to KomKom in the six months preceding the claim.

9.5 Third-Party Services: We are not responsible for the actions, products, or services of third-party providers, including but not limited to banks, mobile network operators, payment processors, or blockchain networks. Your use of third-party services is at your own risk.

10. Changes to This Agreement

We reserve the right to modify, amend, or update this User Agreement at any time. Material changes will be communicated to you via email, in-app notification, or through a prominent notice on our website at least 30 days before the changes take effect.

Your continued use of KomKom services after the effective date of any changes constitutes your acceptance of the revised terms. If you do not agree with the changes, you must stop using our services and close your account before the changes take effect.

We encourage you to review this User Agreement periodically to stay informed about any updates. The "Last Updated" date at the top of this document indicates when the most recent changes were made.