End User License Agreement (EULA)

Introduction

This End User License Agreement ("EULA") is a legally binding contract between you ("User," "you," or "your") and T Crew Limited ("FreeMoney," "we," "us," or "our"), a company duly incorporated under the laws of the Federal Republic of Nigeria, with its registered office in Lagos, Nigeria. This EULA governs your access to and use of the FreeMoney mobile application ("App"), which is distributed via the Apple App Store and Google Play Store, and operates in accordance with Nigerian law, including the Cybercrimes (Prohibition, Prevention, etc.) Act 2015, the Nigeria Data Protection Act 2023, and the Companies and Allied Matters Act (CAMA).

By downloading, installing, accessing, or using the App, you agree to be bound by the terms of this EULA. If you do not agree to these terms, do not use the App.

1. Parties and Definitions

1.1 Parties

• Licensor: T Crew Limited, a company registered under CAMA, with its principal place of business in Nigeria.
• Licensee: The individual or entity who downloads, installs, or uses the freemoney App.

1.2 Definitions

• App: The FreeMoney mobile application, including all updates, upgrades, and related services, available on iOS and Android platforms.
• User Content: Any data, information, text, images, or other content uploaded, submitted, or transmitted by the User through the App.
• Personal Data: Any information relating to an identified or identifiable individual, as defined under the Nigeria Data Protection Act 2023.
• Objectionable Content: Content that violates this EULA, Apple App Store Guidelines, Google Play policies, or applicable law, including but not limited to hate speech, harassment, explicit material, or illegal activities.
• Zero-Tolerance Policy: The strict prohibition and enforcement regime against objectionable content and abusive behaviour as detailed in Section 7.

2. Grant of License and Scope of Use

2.1 License Grant

Subject to your compliance with this EULA, FreeMoney grants you a limited, non-exclusive, non-transferable, revocable license to download, install, and use the App on a compatible iOS or Android device solely for your personal, non-commercial use in accordance with this EULA and all applicable laws.

2.2 License Restrictions

You may not:

• Copy, modify, adapt, translate, reverse engineer, decompile, disassemble, or create derivative works of the App, except as expressly permitted by law.
• Rent, lease, lend, sell, sublicense, distribute, or otherwise transfer the App or any portion thereof to any third party.
• Use the App for any unlawful, fraudulent, or abusive purpose.
• Circumvent, disable, or otherwise interfere with security-related features of the App.
• Use the App in any manner that could damage, disable, overburden, or impair the App or interfere with any other party's use of the App.

2.3 Updates and Upgrades

freemoney may, from time to time, provide updates, upgrades, patches, or new versions of the App. Such updates may be installed automatically or require your action. By using the App, you consent to receive such updates. Continued use of the App after updates constitutes acceptance of the updated EULA where applicable.

3. App Store and Google Play Store Compliance

3.1 Apple App Store Requirements

The App is distributed via the Apple App Store and must comply with all Apple App Store Review Guidelines and policies, including but not limited to:

• Compliance with Apple's App Store Review Guidelines.
• Adhering to Apple's Human Interface Guidelines and design standards.
• Compliance with Apple's privacy requirements, including App Tracking Transparency.
• Providing a valid, accessible privacy policy linked from the App's App Store listing and within the App itself.
• Implementing robust moderation and reporting mechanisms for user-generated content (UGC).
• Compliance with Apple's requirements for apps with in-app purchases and subscriptions.

3.2 Google Play Store Requirements

The App is distributed via the Google Play Store and must comply with all Google Play Developer Program Policies, including but not limited to:

• Targeting the required Android API level (currently API 35 or higher).
• Adhering to Google Play's content, privacy, and user data policies.
• Providing a valid, accessible privacy policy linked from the App's Play Store listing and within the App itself.
• Implementing robust moderation and reporting mechanisms for user-generated content (UGC).

3.3 Third-Party Terms

Your use of the App is also subject to Apple's Licensed Application End User License Agreement, the Google Play Terms of Service, and any applicable third-party terms. In the event of a conflict between this EULA and Apple's or Google's terms, the respective platform's terms will prevail to the extent required.

3.4 Apple-Specific Acknowledgements

You acknowledge and agree that:

• This EULA is concluded between you and T Crew Limited only, and not with Apple Inc. ("Apple"). T Crew Limited, not Apple, is solely responsible for the App and its content.
• Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the App.
• In the event of any failure of the App to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the App (if any) to you. To the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the App.
• Apple is not responsible for addressing any claims by you or any third party relating to the App or your possession and/or use of the App, including but not limited to: (i) product liability claims; (ii) any claim that the App fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection, privacy, or similar legislation.
• In the event of any third-party claim that the App or your possession and use of the App infringes that third party's intellectual property rights, T Crew Limited, not Apple, will be solely responsible for the investigation, defense, settlement, and discharge of any such intellectual property infringement claim.
• Apple and Apple's subsidiaries are third-party beneficiaries of this EULA, and upon your acceptance of this EULA, Apple will have the right (and will be deemed to have accepted the right) to enforce this EULA against you as a third-party beneficiary thereof.

4. Intellectual Property Rights and Ownership

4.1 Ownership

The App, including all software, code, graphics, user interfaces, logos, trademarks, and content (excluding User Content), is the exclusive property of freemoney or its licensors and is protected by Nigerian and international intellectual property laws.

4.2 Reservation of Rights

Except for the limited license granted herein, all rights, title, and interest in and to the App are reserved by freemoney. No rights are granted to you except as expressly set forth in this EULA.

4.3 User Content

By submitting User Content through the App, you grant freemoney a non-exclusive, worldwide, royalty-free license to use, reproduce, modify, adapt, publish, and display such content solely for the purpose of operating and improving the App. You represent and warrant that you have all necessary rights to grant this license and that your User Content does not infringe any third-party rights.

5. User Obligations and Acceptable Use Policy

5.1 User Obligations

You agree to:

• Provide accurate, current, and complete information during registration and use of the App.
• Maintain the confidentiality of your account credentials and notify freemoney immediately of any unauthorized use.
• Use the App only for lawful purposes and in accordance with this EULA and all applicable laws and regulations.

5.2 Acceptable Use

You must not:

• Upload, post, transmit, or otherwise make available any Objectionable Content.
• Engage in any activity that constitutes harassment, abuse, stalking, or threats against others.
• Use the App to promote or facilitate illegal activities, including but not limited to money laundering, fraud, or terrorism financing.
• Attempt to gain unauthorized access to any part of the App, other user accounts, or freemoney's systems or networks.
• Use the App to distribute unsolicited or unauthorized advertising, spam, or promotional materials.

6. User-Generated Content (UGC) Moderation and Takedown Procedures

6.1 UGC Moderation

If the App allows users to submit content (e.g., comments, posts, images), freemoney will implement robust, effective, and ongoing moderation measures, including:

• Requiring users to accept this EULA and the Acceptable Use Policy before creating or uploading UGC.
• Defining and prohibiting Objectionable Content in the App's terms and policies.
• Providing in-app mechanisms for users to report and block objectionable content and abusive users.

6.2 Takedown Procedures

FreeMoney reserves the right to review, remove, or disable access to any User Content that violates this EULA, Apple App Store Guidelines, Google Play policies, or applicable law, at its sole discretion and without prior notice. Users may appeal content removals or account actions as described in Section 7.

7. Zero-Tolerance Policy for Objectionable Content and Abusive Behaviour

7.1 Policy Statement

freemoney maintains a zero-tolerance policy for objectionable content and abusive behaviour. This includes, but is not limited to:

• Sexual content, pornography, or sexually explicit material.
• Hate speech, incitement to violence, or discrimination based on race, religion, gender, or other protected characteristics.
• Harassment, bullying, threats, or intimidation.
• Depictions or encouragement of violence, self-harm, or illegal activities.
• Child endangerment, exploitation, or abuse.
• Distribution of malware, phishing, or other malicious activities.

7.2 Enforcement and Consequences

Violations of this policy will result in immediate and severe consequences, which may include:

• Removal of offending content without notice.
• Temporary or permanent suspension or termination of user accounts.
• Reporting of illegal activities to law enforcement authorities.
• Forfeiture of any virtual assets or balances associated with the account.
• Legal action where applicable.

7.3 Appeals Process

Users whose content or accounts have been actioned under this policy may submit an appeal through the in-app support or designated contact channels. Appeals will be reviewed by freemoney's moderation team, and decisions are final unless otherwise required by law.

8. Data Protection and Privacy Compliance

8.1 Nigeria Data Protection Act 2023 (NDPA) Compliance

freemoney is committed to protecting your privacy and processing your Personal Data in accordance with the Nigeria Data Protection Act 2023 ("NDPA"). Key principles include:

• Processing Personal Data lawfully, fairly, and transparently.
• Collecting data for specified, explicit, and legitimate purposes.
• Limiting data collection to what is necessary.
• Retaining data only as long as necessary.
• Implementing appropriate security measures to protect data.

8.2 Lawful Basis for Processing

Personal Data is processed only where:

• You have given explicit consent.
• Processing is necessary for the performance of a contract.
• Processing is required to comply with legal obligations.
• Processing is necessary to protect vital interests or for legitimate interests pursued by freemoney.

8.3 Data Subject Rights

You have the right to:

• Access your Personal Data.
• Request correction or deletion of inaccurate or outdated data.
• Restrict or object to processing.
• Withdraw consent at any time.
• Request data portability.
• Lodge complaints with the Nigeria Data Protection Commission (NDPC).

8.4 Data Security and Breach Notification

freemoney implements technical and organizational measures to ensure the security, integrity, and confidentiality of Personal Data. In the event of a data breach likely to result in high risk to your rights and freedoms, freemoney will notify the NDPC within 72 hours and affected users without undue delay.

8.5 Privacy Policy

A comprehensive Privacy Policy, compliant with NDPA, Apple App Store, and Google Play requirements, is accessible via the App's App Store and Play Store listings and within the App. The Privacy Policy details data collection, use, sharing, retention, and your rights.

9. Cybersecurity and Cybercrimes Act 2015 Compliance

9.1 Prohibited Conduct

You must not:

• Access, intercept, or modify any computer system, network, or data without authorization.
• Engage in identity theft, impersonation, or fraud.
• Distribute or possess child pornography or related illegal material.
• Engage in cyberstalking, bullying, or harassment.
• Use the App for any purpose related to terrorism, money laundering, or other criminal activity.

9.2 Corporate Liability

freemoney, as a corporate entity, is subject to the Cybercrimes Act and may be held liable for offenses committed through the App. freemoney will cooperate with law enforcement and regulatory authorities as required by law.

9.3 Recordkeeping and Audit

freemoney will retain relevant traffic data, subscriber information, and transaction records for at least two years, as required by law, and will provide such information to law enforcement upon lawful request, subject to privacy safeguards.

10. Limitation of Liability and Warranties

10.1 Disclaimer of Warranties

THE APP IS PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. FREEMONEY DOES NOT WARRANT THAT THE APP WILL BE ERROR-FREE, UNINTERRUPTED, SECURE, OR FREE FROM VIRUSES OR OTHER HARMFUL COMPONENTS. TO THE MAXIMUM EXTENT PERMITTED BY LAW, FREEMONEY DISCLAIMS ALL WARRANTIES, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

10.2 Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY NIGERIAN LAW, FREEMONEY SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES ARISING FROM YOUR USE OF OR INABILITY TO USE THE APP, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, DATA, OR GOODWILL, EVEN IF FREEMONEY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL FREEMONEY'S TOTAL LIABILITY TO YOU EXCEED THE AMOUNT PAID BY YOU (IF ANY) FOR USE OF THE APP IN THE TWELVE MONTHS PRECEDING THE CLAIM.

10.3 Statutory Rights

Nothing in this EULA excludes or limits liability that cannot be excluded or limited under applicable law, including liability for death or personal injury caused by negligence, fraud, or willful misconduct.

11. Termination, Suspension, and Account Enforcement

11.1 Termination by User

You may terminate this EULA at any time by uninstalling the App and ceasing all use.

11.2 Termination or Suspension by freemoney

freemoney may suspend or terminate your access to the App, with or without notice, if you breach this EULA, violate applicable law, or engage in prohibited conduct. Upon termination, your license to use the App will immediately cease, and you must uninstall the App.

11.3 Consequences of Termination

Upon termination:

• Your right to use the App ceases immediately.
• freemoney may delete or deactivate your account and any associated data, subject to legal and regulatory retention requirements.
• Any provisions of this EULA that by their nature should survive termination (e.g., intellectual property, limitation of liability, dispute resolution) shall remain in effect.

11.4 Enforcement Mechanisms

freemoney reserves the right to:

• Issue warnings, suspend, or permanently ban accounts for violations.
• Remove or block access to content or features.
• Report violations to law enforcement or regulatory authorities.
• Withhold or forfeit virtual assets or balances associated with terminated accounts.

12. Dispute Resolution, Governing Law, and Jurisdiction

12.1 Governing Law

This EULA shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, without regard to conflict of law principles.

12.2 Dispute Resolution

In the event of any dispute, controversy, or claim arising out of or relating to this EULA or the App:

• Parties shall first attempt to resolve the dispute amicably through good-faith negotiations.
• If unresolved, disputes may be referred to mediation or arbitration in accordance with the Arbitration and Mediation Act 2023 of Nigeria, unless otherwise required by law.
• Nothing in this section shall prevent either party from seeking interim or injunctive relief from a court of competent jurisdiction.

12.3 Jurisdiction

Subject to the dispute resolution provisions above, you agree to submit to the exclusive jurisdiction of the courts of Nigeria for the resolution of any disputes arising under this EULA.

13. Compliance with Companies and Allied Matters Act (CAMA)

13.1 Corporate Status

T Crew Limited is duly incorporated and operates in accordance with the Companies and Allied Matters Act (CAMA) of Nigeria.

13.2 Corporate Governance

freemoney maintains proper corporate governance, recordkeeping, and compliance with all statutory obligations, including annual returns, financial reporting, and regulatory filings as required by CAMA.

14. Children and Minors — Age Restrictions and Parental Consent

14.1 Age Restrictions

The App is not intended for use by children under the age of 18. By using the App, you represent that you are at least 18 years old or have obtained verifiable parental or legal guardian consent as required by law.

14.2 Parental Consent

Where the App collects or processes Personal Data of children (persons under 18), freemoney will obtain verifiable parental or legal guardian consent and implement appropriate mechanisms to verify age and consent.

14.3 Parental Controls

Parents and guardians are encouraged to monitor their children's use of the App and to use available parental control features to restrict access where appropriate.

15. Payment, Fees, Refunds, and In-App Purchases

15.1 Payments and Fees

Certain features or services within the App may require payment of fees or charges. Payments are processed via the respective platform's payment system:

• iOS Users: Payments are processed via Apple's In-App Purchase system and are subject to Apple's payment terms and refund policies.
• Android Users: Payments are processed via Google Play's payment system and are subject to Google Play's payment terms and refund policies.

15.2 In-App Purchases

In-app purchases are subject to Apple App Store and Google Play policies, as applicable, and Nigerian law. You are responsible for any charges incurred through your account. For iOS users, in-app purchases are processed exclusively through Apple's In-App Purchase mechanism.

15.3 Refunds

Refunds for in-app purchases are governed by the respective platform's refund policies:

• iOS Users: Refund requests must be submitted to Apple through their standard refund process at reportaproblem.apple.com.
• Android Users: Refund requests are governed by Google Play's refund policies.

FreeMoney may, at its discretion, issue refunds in accordance with its own policies and applicable law. Users seeking refunds should contact customer support through the App or the respective app store.

16. Financial Services and Regulatory Considerations

16.1 Regulatory Compliance

If the App offers financial services, payments, or wallet features, freemoney will comply with all applicable regulations, including those of the Central Bank of Nigeria (CBN), the Nigeria Deposit Insurance Corporation (NDIC), and other relevant authorities.

16.2 Know Your Customer (KYC) and Anti-Money Laundering (AML)

Users may be required to provide identification and undergo KYC verification in accordance with CBN and AML regulations. freemoney reserves the right to suspend or terminate accounts that fail to meet KYC/AML requirements.

16.3 Consumer Protection

freemoney is committed to fair and transparent practices and will address user complaints and disputes in accordance with Nigerian consumer protection laws.

17. Recordkeeping, Audit Rights, and Compliance Documentation

17.1 Recordkeeping

freemoney will maintain accurate records of user transactions, account activity, and compliance documentation for at least two years, or as required by law.

17.2 Audit Rights

Regulatory authorities may audit freemoney's operations and records to ensure compliance with applicable laws and regulations.

18. Accessibility, Updates, and Changes to the EULA

18.1 Accessibility

This EULA is available within the App's onboarding process, settings menu, and on the freemoney website. Users may request a copy of the EULA at any time.

18.2 Updates to the EULA

freemoney reserves the right to modify or update this EULA at any time. Users will be notified of material changes via in-app notifications, email, or other appropriate means. Continued use of the App after changes take effect constitutes acceptance of the revised EULA.

18.3 User Notification

If you do not agree to any changes to this EULA, you must discontinue use of the App and uninstall it from your device.

19. Severability and Entire Agreement

If any provision of this EULA is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect. This EULA, together with the Privacy Policy and any additional terms referenced herein, constitutes the entire agreement between you and freemoney regarding the App and supersedes all prior agreements or understandings.

20. Contact Information

For questions, support, or to exercise your data subject rights, please contact:

21. Acknowledgement

By downloading, installing, or using the FreeMoney App, you acknowledge that you have read, understood, and agree to be bound by this EULA, including the zero-tolerance policy for objectionable content and abusive behaviour, and all applicable Nigerian laws, Apple App Store Guidelines, and Google Play Store requirements.