ACCEPTABLE USE POLICY – FALCONPAY BUSINESS

Effective Date: 11th May, 2026

Last Updated: 11th May, 2026

1. INTRODUCTION

This Acceptable Use Policy ("Policy" or "AUP") governs the access to and use of the FalconPay Business platform, products, services, applications, APIs, websites, payment infrastructure, and all related services (collectively referred to as the "Services") provided by FalconPay Limited ("FalconPay", "we", "our", or "us"). This Policy establishes the standards and conditions under which FalconPay Services may be used. It is intended to preserve the security, integrity, reliability, and lawful operation of the FalconPay ecosystem while ensuring compliance with applicable laws, financial regulations, industry standards, and regulatory directives. By accessing, registering for, or using FalconPay Services, every user, merchant, business entity, partner, or representative agrees to comply with this Policy, the FalconPay Terms of Service, Privacy Policy, and all other applicable agreements or operational guidelines issued by FalconPay from time to time. FalconPay reserves the right to interpret and apply this Policy in a manner consistent with its legal, operational, regulatory, security, and risk management obligations.

2. PURPOSE OF THIS POLICY

The purpose of this Policy is to ensure that FalconPay Services are used responsibly, ethically, and lawfully. This Policy is specifically designed to prevent fraud, financial crimes, cyber-related misconduct, and abuse of payment infrastructure while protecting FalconPay, its users, financial institution partners, service providers, and the broader financial ecosystem. The Policy further seeks to ensure compliance with applicable anti-money laundering obligations, counter-terrorism financing regulations, sanctions requirements, consumer protection obligations, cybersecurity standards, and financial regulatory directives. It also establishes clear operational standards for acceptable use of FalconPay Services and provides a framework for identifying, monitoring, investigating, and addressing prohibited or suspicious activities.

3. USER OBLIGATIONS

Every user of FalconPay Services is required to use the platform in good faith and in accordance with all applicable laws and regulatory requirements. Users must ensure that all information submitted to FalconPay during onboarding, verification, compliance review, or continued use of the Services remains accurate, complete, current, and verifiable at all times. Users shall maintain adequate security over their accounts, passwords, login credentials, devices, authentication methods, API keys, and other security information associated with the use of FalconPay Services. Any unauthorized access, suspicious activity, attempted compromise, or security breach affecting a FalconPay account must be reported immediately to FalconPay. Users are prohibited from using FalconPay Services for unlawful, deceptive, harmful, misleading, or fraudulent purposes. Each user remains fully responsible for all activities conducted through their account, whether carried out directly or through an authorized representative, employee, agent, or third party acting on their behalf. Where requested by FalconPay, users shall promptly provide additional information, supporting documentation, transaction records, business information, licenses, approvals, or any other material reasonably required for compliance verification, risk assessment, investigations, audits, or regulatory reporting purposes.

3.1 Lawful Use

Users shall use FalconPay Services solely for lawful and authorized purposes and in compliance with all applicable local and international laws, regulations, guidelines, and industry standards.

3.2 Accurate Information

Users must provide complete, accurate, current, and verifiable information during onboarding, verification, and throughout the use of the Services, including but not limited to: • Business registration information; • Identification documents; • Tax information; • Beneficial ownership information; • Bank account details; • Contact information. Users shall promptly notify FalconPay of any changes to such information.

3.3 Account Security

Users are responsible for maintaining the confidentiality and security of their login credentials, passwords, API keys, tokens, devices, and authentication mechanisms. Users shall immediately notify FalconPay of: • Unauthorized access; • Suspicious account activity; • Security breaches; • Credential compromise. FalconPay shall not be liable for losses resulting from a user's failure to maintain proper account security.

3.4 Regulatory Compliance

Users shall comply with all applicable laws and regulations relating to: • Anti-money laundering ("AML"); • Counter-terrorism financing ("CTF"); • Know Your Customer ("KYC") requirements; • Consumer protection; • Data privacy and protection; • Tax obligations; • Financial reporting obligations; • Sanctions compliance.

4. PROHIBITED ACTIVITIES

Users shall not use FalconPay Services in any manner that violates applicable laws, infringes the rights of others, undermines platform integrity, exposes FalconPay to legal or regulatory risk, or threatens the security of the payment ecosystem. FalconPay strictly prohibits the use of its Services for fraudulent schemes, scams, impersonation, identity theft, embezzlement, money laundering, terrorism financing, tax evasion, cybercrime, bribery, corruption, forgery, financial deception, or any activity intended to unlawfully obtain funds, property, confidential information, or financial advantage. Users are prohibited from processing payments on behalf of undisclosed third parties or operating unauthorized payment aggregation services. The platform shall not be used for transaction laundering, unauthorized foreign exchange activities, unlicensed financial services, or the structuring of transactions intended to evade reporting obligations, transaction limits, compliance checks, or regulatory scrutiny. FalconPay Services must not be used in connection with businesses or activities involving illegal drugs, weapons, firearms, ammunition, counterfeit or pirated goods, stolen property, explicit adult content, unlawful gambling operations, Ponzi schemes, pyramid schemes, deceptive investment programs, shell financial services, or any unlawful or unregulated financial activity. The submission of false, misleading, forged, manipulated, or deceptive information to FalconPay is strictly prohibited. This includes fake business registration documents, falsified identification records, forged licenses, manipulated business information, inaccurate beneficial ownership details, and deceptive transaction records. Users are also prohibited from engaging in platform abuse or security violations. This includes unauthorized access to FalconPay systems, attempts to bypass security controls, reverse engineering of software or infrastructure, deployment of malicious code, denial-of-service attacks, automated abuse of the platform, exploitation of technical vulnerabilities, or any conduct capable of disrupting the proper functioning of FalconPay Services. Accounts created on FalconPay are personal or business-specific and may not be sold, leased, rented, transferred, or shared with unauthorized parties. Users may not create multiple accounts for deceptive purposes or permit unauthorized persons to access or operate their accounts. FalconPay additionally prohibits the use of its Services for activities that infringe intellectual property rights, deceive consumers, facilitate non-delivery scams, or otherwise expose customers or third parties to unfair, abusive, or misleading commercial practices. FalconPay reserves the right, at its sole discretion, to determine whether a business activity, use, transaction pattern, product offering, or operational practice constitutes a prohibited activity under this Policy.

5. HIGH-RISK ACTIVITIES

Certain business sectors, products, transaction categories, jurisdictions, or operational models may be classified by FalconPay as high-risk activities due to regulatory exposure, fraud risks, financial crime concerns, reputational considerations, or operational vulnerabilities. Businesses operating within high-risk categories may be subjected to enhanced due diligence measures, additional compliance requirements, transaction monitoring protocols, security reviews, licensing verification processes, or prior written approval requirements before access to FalconPay Services may be granted or continued. FalconPay reserves the unrestricted right to refuse, suspend, limit, or terminate support for any activity it reasonably considers or suspects to be fraudulent, excessively risky, unlawful, non-compliant, or inconsistent with its internal compliance framework or regulatory obligations.

6. MONITORING AND COMPLIANCE

FalconPay may monitor accounts, transactions, communications, usage patterns, devices, network activity, IP addresses, and other interactions with its platform for purposes including fraud prevention, cybersecurity protection, compliance verification, transaction monitoring, operational security, dispute resolution, regulatory reporting, and risk management. Users acknowledge and consent to such monitoring to the extent permitted under applicable law. FalconPay may delay, decline, review, reverse, or suspend transactions where necessary to conduct investigations, comply with legal obligations, respond to regulatory directives, prevent fraud, or mitigate financial or operational risks. FalconPay may also request additional documentation, conduct enhanced compliance reviews, verify the legitimacy of transactions, or report suspicious activities to law enforcement agencies, financial intelligence units, regulators, financial institutions, or other competent authorities where required or permitted by law.

7. ENFORCEMENT

Where FalconPay reasonably believes that a user has violated this Policy, applicable law, regulatory requirements, or has engaged in conduct capable of exposing FalconPay or its partners to financial, legal, operational, reputational, or security risks, FalconPay may take enforcement action without prior notice. Such enforcement actions may include the restriction of account functionality, temporary suspension of Services, permanent account termination, transaction reversals, freezing or withholding of funds, refusal to process payments, imposition of rolling reserves, withdrawal of API access, enhanced account monitoring, or referral of the matter to law enforcement or regulatory authorities and may institute legal action against defaulting Users. FalconPay reserves the right to cooperate fully with governmental agencies, regulators, financial institutions, courts, and law enforcement authorities in relation to investigations, subpoenas, compliance reviews, or enforcement proceedings.

8. USER LIABILITY AND INDEMNITY

Users remain solely responsible for all activities conducted through their FalconPay accounts and for ensuring that their use of the Services complies fully with this Policy and all applicable laws. Users agree to indemnify, defend, and hold harmless FalconPay, its affiliates, officers, directors, employees, agents, contractors, licensors, service providers, and partners against all claims, liabilities, damages, losses, penalties, fines, costs, expenses, legal fees, or regulatory actions arising out of or connected with the user's breach of this Policy, unlawful conduct, negligence, fraudulent activity, misuse of FalconPay Services, or violation of third-party rights.

9. LIMITATION OF LIABILITY

To the maximum extent permitted by applicable law, FalconPay shall not be liable for any direct, indirect, incidental, consequential, punitive, special, or exemplary damages arising from or relating to the enforcement of this Policy, including account restrictions, transaction delays, suspension of Services, freezing of funds, compliance investigations, or refusal to process transactions. FalconPay shall further not be liable for losses resulting from unauthorized account access caused by user negligence, third-party actions, cybersecurity incidents beyond FalconPay's reasonable control, force majeure events, regulatory actions, or interruptions in third-party infrastructure or financial systems. All enforcement and compliance decisions taken by FalconPay pursuant to this Policy shall be deemed final except where otherwise required by applicable law.

10. REPORTING VIOLATIONS

Users who become aware of suspicious activity, fraud, unauthorized access, violations of this Policy, or misuse of FalconPay Services are encouraged to promptly notify FalconPay using the contact information provided below. FalconPay may investigate all reports received and take such actions as it deems appropriate in the circumstances.

11. POLICY UPDATES

FalconPay reserves the right to amend, revise, modify, or replace this Policy at any time in response to changes in our guidelines/policies, applicable laws, regulatory obligations, operational requirements, industry standards, technological developments, or risk management considerations. Updated versions of this Policy shall become effective immediately upon publication on FalconPay's website or upon notification to users through appropriate communication channels. Continued use of FalconPay Services following such updates constitutes acceptance of the revised Policy.

12. PRE-ACTION NOTICE

As a condition precedent to the commencement of any legal action, suit, claim, arbitration, or regulatory proceeding against FalconPay Limited, the user shall first issue a written Pre-Action Notice to FalconPay. Such notice shall clearly state: • the nature and particulars of the claim; • the reliefs sought; • the factual and legal basis of the claim; • all supporting documents or relevant evidence; and • the proposed means of resolving the dispute. The Pre-Action Notice shall be served on FalconPay at its registered address or designated legal/contact email address and FalconPay shall be entitled to a period of three (3) months from the date of receipt of the notice within which to review, investigate, respond to, and where applicable, attempt amicable resolution of the dispute before any legal proceedings may be commenced. No action shall be instituted against FalconPay unless the provisions of this clause have been fully complied with. Failure to comply with this clause shall constitute a material breach of the agreement between FalconPay and the user and may render any instituted action premature and incompetent to the extent permitted by applicable law.

13. GOVERNING LAW AND JURISDICTION

This Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any dispute, claim, or controversy arising out of or relating to this Policy, the use of FalconPay Services, or any enforcement action taken pursuant to this Policy shall be subject to the exclusive jurisdiction of the competent courts in Nigeria.

14. CONTACT INFORMATION

FalconPay Limited Email: support@falconpay.ng FalconPay Business Website