Acceptable Use Policy

Purpose

This Acceptable Use Policy ("AUP") describes the activities, conduct, and content that are not permitted on Technest Limited's websites, applications, and services, including Swappr and Pouch (the "Services"). It supplements our Terms of Use and forms part of the agreement between you and Technest. By using the Services you agree to comply with this AUP. If we believe you have breached this AUP, we may suspend or close your account, refuse or reverse Transactions, and report you to regulators or law-enforcement authorities, as described in section 6 of our Terms of Use and section 5 of this AUP.

Prohibited transactions and business activities

You must not use the Services in connection with any transaction, business, or activity that is illegal under Nigerian law, the law of the destination country of a payment, or any other applicable law. Without limiting the scope of that obligation, you must not use the Services in connection with the following categories of transaction or business activity:

Illegal activity of any kind. Any transaction, business, or activity that is unlawful, that promotes or facilitates unlawful activity, or that violates the rights of third parties.

Money laundering and terrorism financing. Any transaction designed or reasonably suspected of being designed to launder the proceeds of criminal activity, to finance terrorism, to evade sanctions, or to obscure the origin, ownership, control, or destination of funds.

Sanctioned persons and jurisdictions. Any transaction with or for the benefit of a person, entity, vessel, or jurisdiction that is the subject of comprehensive sanctions or other sanctions that prohibit our involvement. This includes any transaction that would breach sanctions administered by the United Nations Security Council, the Government of the Federal Republic of Nigeria, the United States (including OFAC), the United Kingdom (HMT/OFSI), the European Union, or any other applicable sanctions authority.

Fraud and deception. Any transaction that is fraudulent or that involves false, misleading, or deceptive representations or practices, including business email compromise schemes, romance scams, advance-fee fraud, investment fraud, pyramid or Ponzi schemes, and fake invoicing.

Narcotics and controlled substances. The manufacture, distribution, sale, or purchase of narcotic drugs, controlled substances, or related precursors and paraphernalia, except where the activity is conducted by a duly licensed pharmacy or healthcare provider in line with applicable law.

Weapons. The manufacture, distribution, or sale of firearms, ammunition, explosives, military equipment, or weapons of any kind that are prohibited or restricted under applicable law, or that are sold without the licences required under applicable law.

Human trafficking and exploitation. Any activity involving human trafficking, forced labour, child labour, sexual exploitation, or the trade in human organs.

Child sexual abuse material. Any activity involving the production, distribution, or possession of child sexual abuse material or any other content that sexually exploits or endangers minors.

Adult content and services of prohibited categories. Adult content that is unlawful under applicable law, that depicts non-consensual acts, that depicts minors, or that is otherwise prohibited. Unlicensed gambling and betting. The operation of, or any payment in connection with, gambling, betting, lotteries, sweepstakes, contests, or fantasy-sports activities that are not properly licensed in the jurisdictions in which they operate.

Pyramid, Ponzi, and similar schemes. Multi-level marketing schemes that are unlawful, or that depend on the recruitment of additional participants rather than the sale of legitimate goods or services; Ponzi schemes; high-yield investment programmes; and other "get-rich-quick" arrangements that the law treats as unlawful.

Unauthorised collective investment, virtual asset, and securities activity. The offering or operation of investment products, collective investment schemes, securities, or virtual-asset services (including issuance, exchange, custody, and broker-dealer activity for cryptocurrencies and similar digital assets) without the licences, registrations, or approvals required by Nigerian law or by the law of any other applicable jurisdiction. Unauthorised financial services. The operation of an unlicensed bank, money-transfer business, payment-service provider, foreign-exchange dealer, lender, or insurer, or other regulated financial activity that requires a licence which the user does not hold.

Counterfeit and infringing goods. The manufacture, distribution, or sale of counterfeit goods, goods that infringe intellectual property rights, or goods sold in breach of import or export controls.

Bribery, corruption, and tax evasion. Any transaction connected to bribery, corruption, kickbacks, facilitation payments, or tax evasion.

Sale of personal data. The sale, transfer, or disclosure of personal data in breach of applicable data-protection law.

Other high-risk activities. Any other activity that is unlawful, that we reasonably consider to expose us, you, or a third party to material legal, regulatory, reputational, or financial risk, or that our banking, payment, or other regulated partners prohibit. ## Prohibited user conduct

In addition to the prohibited transactions and business activities listed above, you must not, and you must not allow any other person to:

Misrepresent your identity or your business. Provide false, misleading, or incomplete information during onboarding, during enhanced due diligence, in connection with a Transaction, or in any other interaction with us. Use another person's identity or financial credentials. Use a stolen, expired, or otherwise compromised payment instrument.

Circumvent KYC, screening, or risk controls. Take steps designed to avoid or weaken our identity-verification, sanctions-screening, transaction-monitoring, or other risk controls. This includes structuring transactions to fall below reporting or verification thresholds, opening or operating multiple accounts to evade limits, and using third-party "money mules" to move funds.

Share or sell accounts. Sell, rent, lease, or otherwise transfer your account, or allow any other person to access your account using your credentials. Operate an account on behalf of an undisclosed third party.

Abuse the Services. Use the Services in a way that places an unreasonable load on our systems, that is designed to disrupt or impair the Services, or that interferes with the Services' availability, integrity, or security for other users.

Attack our systems. Probe, scan, or test the vulnerability of any of our systems or networks without our prior written consent. Attempt to bypass authentication, authorisation, rate-limiting, or other security measures. Introduce viruses, worms, malware, ransomware, or other harmful code. Engage in denial-of-service or distributed-denial-of-service activity.

Scrape or harvest data. Use any automated means (including bots, scrapers, crawlers, or harvesting tools) to access, collect, or extract content or data from the Services, except where we have expressly authorised the use of an API for that purpose.

Reverse engineer. Reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code, algorithms, or non-public technical details of the Services, except to the extent that applicable law expressly permits these activities and only after notifying us.

Misuse our APIs. Where we make APIs available, use them in breach of the applicable developer documentation, rate limits, scopes, or terms; share API keys or credentials; or use APIs to provide a service that competes with the Services.

Engage in harassing or abusive behaviour. Harass, threaten, defame, or abuse our employees, agents, partners, or other users in any communication with or about Technest.

Misuse our brand. Use Technest's name, logos, trademarks, or other intellectual property in a way that is likely to cause confusion, that suggests an endorsement or association that does not exist, or that is otherwise unauthorised.

Reporting violations

If you become aware of a breach of this AUP — whether by you, by another user, or by a third party using the Services — please report it to us at hi@the-technest.com. We treat reports confidentially to the extent permitted by law.

Where you suspect that an account has been used to commit fraud against you or against another person, please contact us immediately. We will investigate and take appropriate action, which may include freezing the account, reversing or recalling Transactions where possible, and notifying competent authorities.

Consequences of breach

If we reasonably believe that you have breached this AUP, we may take any of the following actions, separately or in combination:

• refuse, delay, suspend, or reverse a Transaction;
• restrict the features available to your account;
• suspend or close your account, with or without notice;
• retain funds in your account for the period reasonably necessary to investigate and to comply with applicable law;
• recover from you any losses, costs, or expenses we incur as a result of the breach;
• report you to regulators, law-enforcement authorities, our banking and payment partners, fraud-prevention databases, or other appropriate third parties;
• pursue any other remedy available to us at law or under the Agreement.

The actions we take in response to a suspected breach are determined by the seriousness of the breach, the risk involved, and our legal and regulatory obligations.

Cooperation with law enforcement and regulators

We cooperate fully with law-enforcement authorities, regulators, and other competent authorities. We may disclose information about your account, your Transactions, and your use of the Services to these authorities where we are required to do so by law, where we are responding to a lawful request, where we believe disclosure is necessary to prevent or address fraud, money laundering, terrorism financing, or other criminal activity, or where disclosure is otherwise permitted by applicable law.

Nothing in this AUP limits our right or obligation to comply with the law.

Changes to this policy

We may update this AUP from time to time to reflect changes in our risk posture, in the Services, in the requirements of our banking and payment partners, or in applicable law. When we make material changes, we will notify you through the Services or by other reasonable means before the changes take effect. The "lastReviewed" and "effective" dates at the top of this document indicate when it was last updated.

Contact us

Technest Limited 8 Providence Street, Lekki Phase 1 Lagos State, Nigeria Email: hi@the-technest.com