M-VTU Legal Documents

Terms of Service

Acceptance of Terms

By accessing and using M-VTU LTD's digital telecommunications and value-added services, you accept and agree to be bound by the terms and provisions of this agreement. If you do not agree to these terms, please do not use our services.

These Terms of Service ("Terms") govern your use of M-VTU LTD's website, mobile applications, and related services for purchasing airtime, data, giftcards, and managing digital wallets.

Service Description

M-VTU LTD provides comprehensive digital financial and telecommunications services through our secure wallet platform, including:

Wallet Services

• Wallet Funding: Fund your wallet via bank transfers, card payments, or mobile money
• Fund Holding: Secure storage of funds in partner bank accounts
• Money Transfers: Send money to other M-VTU wallet users instantly
• Receive Payments: Accept payments from other users and merchants
• Bill Payments: Pay utility bills, subscriptions, and other services
• Value-Added Services (VAS): Access various digital services and products

Telecommunications Services

• Airtime top-up for all major Nigerian networks (MTN, Airtel, Glo, 9mobile)
• Data bundle purchases and internet services
• Gift card and voucher services
• Voice and SMS services

Security & Compliance

• Bank-grade security with PCI DSS certified payment processing
• Know Your Customer (KYC) verification for all users
• Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance
• Nigerian Data Protection Regulation (NDPR) compliance
• Central Bank of Nigeria (CBN) regulatory compliance

Fund Custody: All customer funds are securely held by licensed Nigerian partner banks in segregated virtual accounts. M-VTU LTD provides the digital wallet interface and transaction processing technology but does not hold or have access to customer funds.

Nigerian Customer Verification Requirements

As a Nigeria-based platform, M-VTU LTD is committed to complying with all applicable Nigerian laws and regulations, including:

• Central Bank of Nigeria (CBN) Guidelines: Compliance with CBN regulations for mobile money and payment services
• Know Your Customer (KYC) Requirements: Mandatory identity verification for all Nigerian customers
• Anti-Money Laundering (AML) Regulations: Adherence to Nigerian AML laws and international standards
• Consumer Protection Council (CPC) Guidelines: Protection of consumer rights and fair practices

Customer Eligibility and Verification

To use our services, you must:

• Be a Nigerian citizen or legal resident with valid Nigerian identification
• Be at least 18 years old or have parental consent
• Provide accurate and complete verification information
• Complete mandatory KYC verification before any transactions
• Maintain valid Nigerian contact details and address

Verification Process for Nigerian Customers

• Identity Verification: Valid Nigerian government-issued ID (National ID, Passport, Driver's License, or Voter's Card)
• Address Verification: Proof of Nigerian residential address (utility bill, bank statement, or official document)
• Biometric Verification: Facial recognition or fingerprint verification where required
• Phone Number Verification: Nigerian mobile number linked to your identity
• BVN/NIN Verification: Bank Verification Number or National Identification Number validation

Transaction Limits and Verification Levels

• Level 1 (Basic): ₦50,000 daily limit after email/phone verification
• Level 2 (Verified): ₦500,000 daily limit after ID verification
• Level 3 (Enhanced): ₦2,000,000 daily limit after full KYC and biometric verification
• Business Accounts: Higher limits with additional business documentation

Verification Failure Consequences

Failure to complete required verification may result in:

• Temporary suspension of account services
• Transaction limits or restrictions
• Account termination for repeated non-compliance
• Reporting to regulatory authorities as required by law

User Accounts

You are responsible for maintaining the confidentiality of your account information and for all activities that occur under your account.

Payment Terms and Wallet Services

• All payments are processed securely through PCI DSS certified payment partners (Paystack, Flutterwave, Monnify)
• Wallet funding via bank transfers, card payments, or other approved methods
• Fund Custody: All customer funds are held securely by licensed Nigerian partner banks via virtual accounts. M-VTU LTD only provides the digital wallet interface and transaction processing services
• Transaction processing fees may apply and will be clearly displayed
• Successful transactions are irreversible once services are delivered
• Failed transactions are automatically refunded to your wallet within 2 minutes
• Refund requests for successful transactions are processed within 24-48 hours
• We accept major Nigerian bank cards, mobile money, and bank transfers
• Wallet balances are not interest-bearing and are held for transaction purposes only
• Minimum wallet funding amount: ₦100 | Maximum daily transaction limit based on verification level

Wallet Terms of Use

Wallet Creation and Management

• Wallets are created upon successful account registration and KYC verification
• You are responsible for maintaining the security of your wallet PIN and login credentials
• Wallet balances can be used for airtime, data, bill payments, transfers, and VAS purchases
• Unused wallet funds may be withdrawn to your verified bank account
• Minimum wallet balance: ₦0 | Maximum balance based on KYC tier

Money Transfers and Payments

• Peer-to-Peer Transfers: Send money instantly to other M-VTU wallet users
• Receiving Payments: Accept payments from individuals and businesses
• Merchant Payments: Pay for goods and services through integrated merchants
• Bill Payments: Pay electricity, water, cable TV, and other utility bills
• Transfer Limits: Daily limits based on KYC verification tier
• Transfer Times: Instant for wallet-to-wallet, 1-24 hours for bank withdrawals

Wallet Security

• Multi-factor authentication (MFA) required for all transactions above ₦5,000
• Biometric verification for high-value transactions
• Transaction alerts sent to registered email and phone
• Suspicious activity triggers automatic account freeze for security review
• Report lost or stolen credentials immediately via our 24/7 support
• M-VTU LTD is not liable for losses due to compromised credentials or unauthorized access

Wallet Fees and Charges

• Wallet Creation: Free
• Maintenance Fee: Free for active users
• Funding Fees: 1.5% for card payments, free for bank transfers
• Transfer Fees: ₦10 for wallet-to-wallet, ₦50 for bank withdrawals
• Bill Payment Fees: 1-2% depending on service provider
• Airtime/Data Purchase: 2-5% markup on face value
• Inactive Account Fee: ₦100 monthly after 12 months of inactivity
• Failed Transaction Fee: ₦50 for reversal of failed transactions

Transaction Disputes and Refunds

• Dispute Window: 30 days from transaction date
• Evidence Required: Screenshots, receipts, and transaction references
• Resolution Time: 5-10 business days for investigation
• Refund Process: Refunds credited to wallet within 48 hours of approval
• Escalation: Unresolved disputes can be escalated to consumer protection agencies

Service Usage and Restrictions

You agree to use our services only for lawful purposes and in accordance with these Terms. Prohibited activities include:

• Illegal activities, fraud, or money laundering
• Unauthorized resale or commercial exploitation of services
• Attempting to breach, hack, or disrupt our systems
• Using automated tools or bots to access our services
• Impersonating others or providing false information
• Violating telecommunications regulations or network policies
• Excessive usage that may impact service quality for others

M-VTU LTD reserves the right to suspend or terminate accounts engaged in prohibited activities.

Service Availability and Quality

While we strive for 99.9% uptime and instant delivery, we do not guarantee uninterrupted service availability. Service limitations may occur due to:

• Network maintenance or upgrades
• Telecommunications provider issues
• Payment gateway maintenance
• Force majeure events (natural disasters, etc.)
• Regulatory requirements or government actions

We will communicate scheduled maintenance in advance when possible and provide status updates during outages.

Intellectual Property

All content, trademarks, logos, and software associated with M-VTU LTD are protected by intellectual property laws. You may not copy, modify, or distribute our intellectual property without prior written consent.

Account Termination

Either party may terminate this agreement at any time. Upon termination:

• Your access to services will be immediately suspended
• Outstanding transactions will be completed
• Unused wallet funds will be refunded to your original payment method
• We may retain transaction records as required by law

Disclaimers and Limitation of Liability

Our services are provided "as is" without warranties of any kind. M-VTU LTD disclaims all warranties, express or implied, including merchantability and fitness for particular purpose.

M-VTU LTD's liability is limited to the amount paid for the specific transaction in question. We are not liable for:

• Indirect, incidental, or consequential damages
• Loss of profits, data, or business opportunities
• Service interruptions or delays caused by third parties
• Acts of god, war, terrorism, or other force majeure events
• Losses resulting from unauthorized account access

Indemnification

You agree to indemnify and hold M-VTU LTD harmless from any claims, damages, losses, or expenses arising from your use of our services, violation of these Terms, or infringement of any third-party rights.

Governing Law and Dispute Resolution

These Terms are governed by the laws of the Federal Republic of Nigeria. Any disputes will be resolved through:

• Negotiation and mediation in good faith
• Arbitration under the rules of the Nigerian Arbitration and Conciliation Act
• Courts of competent jurisdiction in Lagos, Nigeria

Modifications to Terms

M-VTU LTD reserves the right to modify these Terms at any time. Changes will be effective immediately upon posting on our website. Continued use of our services constitutes acceptance of modified terms.

Contact Information

For questions about these Terms of Service, contact us:

• Email: contact@m-vtu.site
• Phone: +234 707 443 3094
• Live Chat: Available 24/7 on our platform
• Address: Lagos, Nigeria

Privacy Policy

Introduction

M-VTU LTD is committed to protecting the privacy and personal data of our customers, users, and partners. This Privacy Policy outlines how we collect, use, store, and protect personal information in compliance with the Nigerian Data Protection Regulation (NDPR) and other applicable data protection laws.

Information We Collect

M-VTU LTD collects information you provide directly to us for the purpose of providing our digital telecommunications and value-added services. This includes:

• Personal Information: Full name, email address, phone number, date of birth, and identification documents for account verification
• Payment Information: Bank account details, card information, and transaction history processed through our certified payment partners
• Transaction Data: Airtime and data purchase details, recipient phone numbers, and service usage patterns
• Device Information: IP address, browser type, device type, and operating system for security and service optimization
• Communication Data: Messages, support tickets, and feedback you send to us

All customer funds are securely held by our partner banks, and M-VTU LTD only processes transaction instructions and maintains digital wallet technology.

How We Use Your Information

We use the information we collect to:

• Process and complete airtime, data, giftcard, and wallet-based transactions
• Verify your identity and comply with Know Your Customer (KYC) regulations
• Provide customer support and respond to your inquiries
• Secure your account and prevent fraudulent activities
• Improve our services and develop new features
• Send important account updates, security alerts, and service notifications
• Comply with legal obligations and regulatory requirements
• Analyze usage patterns to enhance service quality and user experience

Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:

• Payment Partners: With Paystack, Flutterwave, and Monnify for processing payments and wallet funding
• Partner Banks: For secure fund holding and transaction processing as required by banking regulations
• Service Providers: With Reloadly and other telecommunications providers to deliver airtime and data services
• Legal Requirements: When required by law, court order, or regulatory authorities
• Business Protection: To protect against fraud, unauthorized transactions, or security threats
• Business Transfers: In connection with a merger, acquisition, or sale of assets

Data Security

M-VTU LTD implements comprehensive security measures to protect your personal information:

• Bank-level encryption for all data transmission and storage
• Secure payment processing through PCI DSS certified gateways
• Regular security audits and vulnerability assessments
• Multi-factor authentication for account access
• Secure data centers with 24/7 monitoring
• Employee access controls and confidentiality agreements
• Regular data backups and disaster recovery procedures

While we strive to protect your information, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but are committed to protecting your data to the fullest extent possible.

Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations:

• Account information: Retained while your account is active and for 7 years after account closure
• Transaction records: Retained for 7 years for regulatory compliance
• Communication records: Retained for 3 years or as required by law
• Identification documents: Retained for the duration required by KYC regulations

Your Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal requirements)
• Portability: Request transfer of your data in a structured format
• Restriction: Request limitation of how we process your information
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for processing where applicable

To exercise these rights, contact us at support@m-vtu.site with your request and proof of identity.

Cookies and Tracking

Our website uses cookies and similar technologies to enhance your experience:

• Essential Cookies: Required for website functionality and security
• Analytics Cookies: Help us understand how you use our services
• Preference Cookies: Remember your settings and preferences

You can control cookie settings through your browser preferences.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• Email: support@m-vtu.site
• Data Protection Officer: dpo@m-vtu.site
• Phone: +234 707 443 3094

KYC Policy

Introduction

M-VTU LTD is committed to maintaining the highest standards of compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. Our Know Your Customer (KYC) policy ensures that we verify the identity of our customers to prevent fraud, money laundering, and other illegal activities.

Purpose of KYC

The primary purposes of our KYC policy are to:

• Verify the identity of customers using our digital wallet and telecommunications services
• Prevent money laundering, terrorist financing, and other financial crimes
• Ensure compliance with Nigerian financial regulations and international standards
• Protect our customers from fraud and unauthorized transactions
• Maintain the integrity and security of our digital payment ecosystem
• Build trust and transparency in our service offerings

KYC Requirements

All customers must complete KYC verification before accessing certain services. The level of verification depends on the service type and transaction amount:

Basic Verification (All Users)

• Full name and date of birth
• Valid email address and phone number
• Residential address in Nigeria

Enhanced Verification (High-Value Transactions)

• Government-issued identification document (National ID, Passport, or Driver's License)
• Proof of address (utility bill, bank statement, or official document)
• Source of funds declaration for transactions above ₦100,000
• Biometric verification where required

Business Customers

• Certificate of Incorporation or Business Registration
• Tax Identification Number (TIN)
• Authorized signatories' identification
• Business address and contact details

Verification Process

Our KYC verification process is designed to be efficient while maintaining security:

Account Registration

• Provide basic personal information during signup
• Email and phone number verification
• Initial account limits applied until full verification

Document Submission

• Upload clear, high-quality images of identification documents
• Documents must be current and not expired
• Selfie verification for biometric matching

Review and Approval

• Automated and manual document verification
• Verification typically completed within 24-48 hours
• Additional information may be requested if needed
• Account upgrade upon successful verification

Ongoing Monitoring

KYC is not a one-time process. We continuously monitor customer accounts to ensure compliance:

• Regular review of transaction patterns for suspicious activities
• Periodic updates of customer information
• Enhanced due diligence for high-risk customers
• Transaction monitoring for unusual or large-value activities
• Compliance with regulatory reporting requirements

Risk-Based Approach

We apply a risk-based approach to KYC verification:

Low Risk

• Basic verification for standard retail customers
• Transaction limits up to ₦50,000 per day
• Simplified documentation requirements

Medium Risk

• Enhanced verification for business customers
• Transaction limits up to ₦500,000 per day
• Additional source of funds verification

High Risk

• Full enhanced due diligence
• Unlimited transaction limits with approval
• Regular account reviews and updates

Non-Compliance Consequences

Failure to comply with KYC requirements may result in:

• Temporary suspension of account services
• Transaction limits or restrictions
• Account termination in severe cases
• Reporting to regulatory authorities as required by law
• Loss of access to certain service features

We will always provide notice and opportunity to rectify compliance issues before taking adverse actions.

Data Protection in KYC

KYC information is handled with the highest level of security and privacy:

• Encryption of all personal data in transit and at rest
• Access restricted to authorized personnel only
• Secure storage in compliance with data protection regulations
• Regular security audits and compliance reviews
• Data retention only as required by regulatory obligations
• Secure disposal of documents when no longer needed

Third-Party Verification

We may use third-party service providers for KYC verification:

• Government databases for identity verification
• Credit bureaus for additional due diligence
• Biometric verification services
• AML screening databases

All third-party providers are vetted for security and compliance standards.

Customer Rights

Customers have rights regarding their KYC information:

• Access to their KYC records and verification status
• Correction of inaccurate information
• Understanding of verification requirements
• Appeal process for verification decisions
• Data portability and deletion rights (subject to legal requirements)

Contact Information

For KYC-related inquiries or assistance:

• Email: compliance@m-vtu.site
• Phone: +234 707 443 3094
• Support Hours: Monday - Friday, 9:00 AM - 6:00 PM WAT

Data Protection Policy

Introduction

M-VTU LTD is committed to protecting the privacy and personal data of our customers, users, and partners. This Data Protection Policy outlines how we collect, use, store, and protect personal information in compliance with the Nigerian Data Protection Regulation (NDPR) and other applicable data protection laws.

Legal Framework

Our data protection practices are governed by:

• Nigerian Data Protection Regulation (NDPR) 2019
• Nigerian Data Protection Act (when enacted)
• International data protection standards and best practices
• Telecommunications and financial services regulations

Data Protection Principles

We adhere to the following data protection principles:

Lawfulness, Fairness, and Transparency

• Personal data is processed lawfully and fairly
• Data subjects are informed about processing activities
• Privacy notices are clear and accessible

Purpose Limitation

• Data is collected for specified, legitimate purposes
• Further processing is compatible with original purposes
• Purpose limitations are respected

Data Minimization

• Only necessary personal data is collected and processed
• Data collection is adequate and relevant
• Excessive data collection is avoided

Accuracy

• Personal data is kept accurate and up-to-date
• Reasonable steps are taken to correct inaccuracies
• Outdated data is deleted or rectified

Storage Limitation

• Data is retained only as long as necessary
• Retention periods are defined and enforced
• Data is securely deleted when no longer needed

Integrity and Confidentiality

• Data is protected against unauthorized access
• Appropriate security measures are implemented
• Data breaches are prevented and responded to

Accountability

• We are responsible for compliance with data protection principles
• Data protection impact assessments are conducted
• Records of processing activities are maintained

Data Subject Rights

Under the NDPR, you have the following rights regarding your personal data:

Right to Information

• Receive clear information about data processing
• Understand purposes and legal basis for processing
• Know about data sharing and retention periods

Right of Access

• Request confirmation of data processing
• Obtain copies of your personal data
• Access information about processing activities

Right to Rectification

• Request correction of inaccurate data
• Complete incomplete personal data
• Update outdated information

Right to Erasure

• Request deletion of personal data
• Right to be forgotten in certain circumstances
• Data deletion when no longer necessary

Right to Restriction

• Limit processing of personal data
• Object to processing in certain situations
• Restrict data sharing or further processing

Right to Data Portability

• Receive data in a structured format
• Transmit data to another controller
• Obtain copies of data for reuse

Right to Object

• Object to processing based on legitimate interests
• Object to direct marketing communications
• Withdraw consent for processing

Automated Decision Making

• Not subject to automated decision making without consent
• Right to human intervention in automated processes
• Right to express views on automated decisions

Data Security Measures

We implement comprehensive security measures to protect personal data:

Technical Measures

• Encryption of data in transit and at rest
• Multi-factor authentication for system access
• Regular security updates and patches
• Firewall and intrusion detection systems
• Secure backup and disaster recovery systems

Organizational Measures

• Staff training on data protection
• Access controls and role-based permissions
• Regular security audits and assessments
• Data protection impact assessments
• Incident response and breach notification procedures

Physical Measures

• Secure data center facilities
• Controlled access to physical premises
• Secure document storage and disposal
• 24/7 monitoring and surveillance

Data Breach Procedures

In the event of a data breach, we follow these procedures:

Breach Detection and Assessment

• Immediate identification of security incidents
• Risk assessment of potential harm to individuals
• Determination of breach scope and impact

Breach Containment

• Immediate actions to contain the breach
• Isolation of affected systems
• Prevention of further data exposure

Notification Requirements

• Notification to NITDA within 72 hours
• Communication to affected data subjects
• Provision of breach details and mitigation steps

Post-Breach Actions

• Investigation and root cause analysis
• Implementation of corrective measures
• Review and update of security procedures

International Data Transfers

When transferring data outside Nigeria, we ensure:

• Adequate protection in recipient countries
• Standard contractual clauses or adequacy decisions
• Compliance with NDPR transfer requirements
• Additional safeguards for sensitive data

Data Protection Officer

M-VTU LTD has appointed a Data Protection Officer (DPO) responsible for:

• Monitoring compliance with data protection regulations
• Acting as point of contact for data subjects and regulators
• Conducting data protection impact assessments
• Providing advice on data protection matters
• Coordinating data breach responses

Third-Party Processors

When engaging third-party processors, we ensure:

• Written contracts with data protection clauses
• Processor compliance with data protection requirements
• Regular audits of processor activities
• Right to terminate non-compliant processors

Complaints and Enforcement

If you believe your data protection rights have been violated:

• Contact our Data Protection Officer
• Lodge a complaint with NITDA
• Seek redress through appropriate legal channels
• Access to data protection complaint procedures

Contact Information

For data protection inquiries or to exercise your rights:

• Data Protection Officer: dpo@m-vtu.site
• General Support: support@m-vtu.site
• Phone: +234 707 443 3094
• Address: Lagos, Nigeria

Response time: We aim to respond to all data protection requests within 30 days.