By accessing, viewing the Platform or using the Services through any means, you accept our terms and conditions as our binding contract with you and agree to be so bound by same

1. Introduction
1.1 About

CFTL Digital Services Limited ("CFTL Digital", "we", "our", or "us") is registered with the Securities and Exchange Commission, Nigeria (the "Commission") as a digital sub-broker and is subject to the rules and regulations of the Commission, Nigerian Exchange Limited ("NGX") and other applicable rules. These Terms of Use (also referred to as the "Agreement"), together with any document(s) they expressly incorporate by reference, encompass any content, components, functionalities, and services offered on or through our website at cowrywise.com and/or our mobile applications (jointly referred to as the "Platform"). All references to "you" or "your", as applicable, mean a customer/client who accesses or uses our Platform.

1.2 Effective Date

This Agreement will be effective on your acceptance of its terms electronically or otherwise through the Platform.

1.3 Purpose

We offer a platform for Clients to buy and sell publicly traded securities on the stock exchange market across several jurisdictions ("our Services"). Further to this, we may include or make available certain content on our platform, which include, without limitation:

  1. Account positions, balances, transactions, confirmations, and transaction history;
  2. General news, informational content, commentary, research reports, educational materials, and data related to financial markets, securities, and other relevant subjects;
  3. Market data such as quotations for securities transactions and information on completed securities transactions reported in accordance with relevant securities regulations;
  4. Financial and investment trading systems, as well as interactive tools such as alerts or calculators;
  5. CFTL Digital's names, logos, product and service names, trade names, trademarks, and service marks (collectively referred to as "Marks") owned by CFTL Digital, as well as Marks owned by Third-Party Providers (defined below);
  6. Any other information, content, services, or software accessible through our website or our mobile application (the "App").

Some content may be provided by Third-Party Providers (referred to as "Third-Party Content"). These may include information, services, or software made available through our website or App, social media websites, blogs, wikis, online conferences, telecasts, podcasts, and other similar forums (collectively called "Forums"). Third-Party Content may be accessible through framed areas or hyperlinks leading to the websites of Third-Party Providers.

By using the Platform, you enter into a series of legally binding agreements. You also agree and expressly consent to be bound by our Privacy Policy, which covers how we collect, use, share and store your personal information.

1.4 Agreement

When you access the Platform as a Client, you agree to be bound by these Terms of Use. Consequently, please, take the time to read these Terms of Use. For the purpose of this Agreement, a "Client", "Customer", "you", "your" is an individual who uses our website or App to evaluate our service, or for educational purposes. A Client includes any individual who signs up on CFTL Digital which entitles the Client to buy and trade stocks on the Platform. If you do not agree to these terms (or any updates to them), please discontinue the use of the Platform immediately.

You also understand and accept that in using the payment channels on the Platform to fund your wallet or account on the Platform, you are agreeing to the conversion of one currency to another at the prevailing market rate of exchange as determined by CFTL Digital. Please verify the prevailing exchange rate before initiating payments on your account. If you do not agree with the terms, please do not proceed with using the payment channels.

This Agreement, as well as the Privacy Policy, applies to Clients. If you elect to become a Client, you shall be subject to these Terms of Use (as may be amended), our Privacy Policy (as may be amended) and any additional terms to which you agree, when you create a plan and/or transact on the Platform.

1.5 Duty to Review

Your use of the Platform is governed by the version of the Terms of Use in effect on the date you access the Platform. We reserve the right to modify, amend or change any portion of these Terms of Use at any time and without prior notice to you in any manner, and such changes shall be effective immediately. The most current version of these Terms can be reviewed by clicking the Terms hyperlink on our website. You acknowledge that by accessing the Platform and using the Services after such changes/modifications, you agree to be bound by the terms, as modified. If you do not agree with such modified Terms, please do not proceed with utilising the Platform and our Services.

1.6 Third-Party Services

By using the Platform, we may allow you to engage in relationships and agreements with Third-Party Providers, granting you access to additional services. These services may include the ability to buy and sell publicly traded securities on the stock exchange market across several jurisdictions. We may also be required to engage some Third-Party Providers to provide the Services to you. To avail yourself of these Third-Party Provider services, it may be necessary for you to enter or opt into various agreements with the respective Third-Party Provider. These may involve agreements such as customer agreements, service agreements, or account agreements. These Terms of Use shall apply, in addition to those contained in any agreement entered into between CFTL Digital and Third Parties, in relation to the provision of the services. By using the Platform, you consent to us providing your information to these Third-Party Providers for the purpose of implementing the Services. CFTL Digital shall not be responsible for Third Party agreements that are relevant for accessing Third Party Provider services.

2. Obligations
2.1 Eligibility

The Platform and Services are intended solely for:

  • Anyone above 18 years of age with a valid Bank Verification Number (BVN); and
  • Anyone above 18 years of age who is a Nigerian citizen/legal resident in Nigeria.

Any access to the Platform or use of the Services by any person or entity who does not meet the above criteria is not allowed nor permitted and shall be a violation of these Terms of Use, for which CFTL Digital shall not be liable.

2.2 Content
  • Any inaccuracy, error, or delay in the content; or
  • Any loss or damage arising from or caused by (i) errors or delays in the transmission of such content; (ii) interruptions in the availability of such content resulting from negligent acts, omissions, or "force majeure" events (e.g., flood, extraordinary weather conditions, earthquake, acts of God, fire, war, insurrection, riot, labour disputes, accidents, actions of government, communication or power failures, equipment or software malfunctions); (iii) any other causes beyond the reasonable control of CFTL Digital and/or Third-Party Provider; or (iv) non-performance.

You agree that the publication of content or information on our Platform does not constitute solicitation. Additionally, the content provided on the Platform does not serve as investment, financial, or tax advice to you and you confirm that your activities and usage of the Platform are self-directed.

2.3 Your Access

To access certain features of the Platform, you must register to create an account ("Client Account"). When you register, you will be asked to provide a password, which you will be required to use to access your Client Account. CFTL Digital has physical, electronic and procedural safeguards that comply with regulatory standards to guard Clients' non-public personal information which are disclosed in our Privacy Policy. You are responsible for safeguarding your password and other Client Account information. You agree not to disclose your password to any third party, and you will notify CFTL Digital immediately if your password is lost or stolen or if you suspect any unauthorised use of your Client Account. As a Client, you agree that you shall be solely responsible for any activities or actions under your Client Account, whether or not you have authorised such activities or actions. You also confirm and warrant that the information you provide to us on account registration through our Platform is true, accurate, current, and complete.

2.4 Alerts, Notifications and Service Communications

By creating a Client Account, you automatically sign up for various types of alerts and notifications, including market notices and updates, via e-mail and mobile notifications. We never include your password in these communications, but we may include your name, email address and information about your portfolio(s) if you are a Client. Anyone with access to your e-mail or mobile device will be able to view these alerts. You may unsubscribe from marketing-oriented emails at any time.

2.5 Confidentiality

All information and documents obtained by CFTL Digital or its employees, consultants or agents which are not published or otherwise publicly available shall be kept confidential and not disclosed to third parties or the public. This restriction shall not apply to any information disclosed to legal advisers or to a third party to the extent that this is deemed by CFTL Digital as required for the purpose of providing the Services or by any court of competent jurisdiction or by a governmental or regulatory authority in Nigeria.

This covenant shall survive the termination of this Agreement.

3. Fee and Expenses

You hereby acknowledge that you may incur certain other charges imposed by third-party financial institutions. These additional costs may include, and are not limited to bank transfer fees, transfer taxes etc. You understand that these fees are not included in the fee that you pay to CFTL Digital.

3.1 Fee Payment

By signing this Agreement, you authorise CFTL Digital to deduct any fees applicable to your Client Account directly from your communicated bank account, stash or via bank transfer (the "Account Fees"). Until you terminate your Account, you will be deemed to continuously reaffirm your agreement that CFTL Digital may deduct the Account Fees from your stipulated means tied to your Client Account. Any unutilized amount initially debited shall be refunded to your stash upon transaction completion.

4. Disclaimer and Limit of Liability

By signing this Agreement, you authorise CFTL Digital to deduct any fees applicable to your Client Account directly from your communicated bank account, stash or via bank transfer (the "Account Fees"). Until you terminate your Account, you will be deemed to continuously reaffirm your agreement that CFTL Digital may deduct the Account Fees from your stipulated means tied to your Client Account. Any unutilized amount initially debited shall be refunded to your stash upon transaction completion.

4.1 For a Client

You understand and acknowledge that the investment results you obtain from investment information and financial insights provided by CFTL Digital or a Third-Party Provider cannot be guaranteed and that CFTL Digital shall not be held responsible in any way for such investment results.

All investments entail a risk of loss, and you may lose money. It is important to note that the stock market can be volatile and lead to losses. You are required to carefully consider your investment objectives, investment tenor, risks, charges and expenses involved in investing in the stock markets prior to signing up for any investment on CFTL Digital's Platform.

You agree and understand that your use of CFTL Digital's materials is for educational purposes only and you acknowledge that the materials are not intended to provide any legal, tax or financial planning advice. You agree as a Client, that you are responsible for your own investment research and investment decisions, and that trading in equities or other instruments on any exchange, is subject to varying elements of risk and may not be suitable for persons with limited investment or trading experience.

You further agree that you do not and will not rely on communication or information from CFTL Digital or any of its affiliates as the basis of your investment decisions and, except as otherwise provided for herein, CFTL Digital shall not be liable for decisions/actions you take or authorise third parties to take on your behalf, based on information you receive as a Client or information you otherwise see on our website.

4.2 Non-Exclusive Services

You understand and agree that we provide the Services for other Clients. You further understand that we and our affiliates may take investment actions on behalf of such other Clients that differs from investment action taken on behalf of your account.

4.3 Investment Risks

You recognise that there may be loss or depreciation of the value of any investment and the assets, due to the fluctuation of market values, and accordingly, the value of your Client Account may change and decrease. You acknowledge and confirm that we have not made any guarantee, either oral or written, that your investment objective will be achieved or that the value of any assets in your account(s) on the Platform will not decline. Nothing in this Agreement shall be deemed a waiver of any right or remedy that you may have under the applicable laws. All investments involve risk, and the past performance of a security or financial product may not be replicated in the future and does not guarantee future results or returns.

4.4 Disclaimer Warranties

Your use of CFTL Digital's Platform and the personal information you provide is at your sole discretion. CFTL Digital's Platform and all materials, information, products and services included therein, are provided on an as-is and available basis without warranties of any kind from CFTL Digital

CFTL DIGITAL EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, EXPRESS, IMPLIED OR STATUTORY, RELATING TO CFTL DIGITAL'S WEBSITE, APP, CONTENT AND/OR CLIENT INFORMATION, INCLUDING WITHOUT LIMITATION, THE WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OF PROPRIETARY RIGHTS, COURSE OF DEALING OR COURSE OF PERFORMANCE. CFTL DIGITAL DISCLAIMS ANY WARRANTIES, EXPRESS OR IMPLIED:

  • a. REGARDING THE AVAILABILITY, SECURITY, ACCURACY, RELIABILITY, TIMELINESS AND PERFORMANCE OF CFTL DIGITAL'S WEBSITE, CONTENT AND/OR CLIENT INFORMATION;
  • b. THAT CFTL DIGITAL'S WEBSITE AND APP WILL BE ERROR-FREE OR THAT ANY ERRORS WILL BE CORRECTED;
  • c. THAT CFTL DIGITAL'S WEBSITE AND APP WILL BE FREE FROM ELECTRONIC VIRUSES; OR
  • d. REGARDING THE PERFORMANCE OF OR ACCURACY, QUALITY, CURRENCY, COMPLETENESS OR USEFULNESS OF ANY INFORMATION PROVIDED BY CFTL DIGITAL ON ITS WEBSITE, INCLUDING BUT NOT LIMITED TO INFORMATION OBTAINED THROUGH SOCIAL MEDIA.

No advice or information, whether oral or written, obtained by you from CFTL Digital's Platform shall create any warranty not expressly stated in this Agreement. If you choose to rely on such information, you do so solely at your own risk. CFTL Digital makes no warranties or representations, express or implied, on products and services offered through the Platform. CFTL Digital accepts no liability for any damages or losses which may be incurred with the use of related services on its Platform.

4.5 Indemnity

You hereby undertake to defend, indemnify and hold harmless, CFTL Digital and any third party it engages to provide the Services to you, their directors, officers, employees, agents, successors or assigns from and against any and all claims, losses, demands, actions, damages, liabilities, costs and expenses (including but not limited to reasonable legal fees) while acting in accordance with the terms of this Agreement and that are not a direct result of a breach of the terms herein stated, bad faith, negligence, and material violation of applicable laws.

CFTL Digital shall not be liable for any loss whatsoever affecting the assets held by it on behalf of the Client, and it shall also not be liable for any act or failure to act by any third party.

4.6 Limitation of Liability

IN NO EVENT SHALL CFTL DIGITAL OR ANY OF ITS OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE TO YOU FOR ANY DAMAGES WHATSOEVER OR ANY OTHER MATTER RELATING TO THE SERVICE, INCLUDING WITHOUT LIMITATION, INDIRECT, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, CONSEQUENTIAL DAMAGES, LOSS OF PROFITS, REVENUE, INCOME, OR TRADING LOSSES, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OR INABILITY TO USE CFTL DIGITAL'S PLATFORM OR THE SERVICE, CONTENT AND/OR CLIENT INFORMATION, INCLUDING BUT NOT LIMITED TO THE QUALITY, ACCURACY, OR UTILITY OF THE INFORMATION PROVIDED AS PART OF OR THROUGH CFTL DIGITAL OR FOR ANY INVESTMENT DECISIONS MADE ON THE BASIS OF SUCH INFORMATION, WHETHER THE DAMAGES ARE FORESEEABLE AND WHETHER OR NOT CFTL DIGITAL HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION AND FOR THE AVOIDANCE OF DOUBT, IN NO EVENT SHALL CFTL DIGITAL'S CUMULATIVE LIABILITY TO YOU EXCEED NGN10,000 (TEN THOUSAND NAIRA) ONLY. THE COMPANY SHALL NOT BE HELD RESPONSIBLE FOR ANY LOSSES INCURRED BY YOU OR ANY OTHER PARTY DUE TO FACTORS BEYOND ITS CONTROL. THESE INCLUDE, BUT ARE NOT LIMITED TO, FAILURES OF ELECTRONIC OR MECHANICAL SYSTEMS, DISRUPTIONS IN COMMUNICATION NETWORKS (SUCH AS TELEPHONE, CABLE, OR INTERNET), UNAUTHORISED ACCESS, CYBER THREATS (INCLUDING VIRUSES OR THEFT), HUMAN ERRORS, WEATHER EVENTS (SUCH AS FLOODS OR EARTHQUAKES), NATURAL DISASTERS, FIRES, CIVIL UNREST, TERRORISM, RIOTS, LABOR STRIKES OR DISPUTES, ACCIDENTS, EMERGENCIES, OR GOVERNMENTAL ACTIONS.

5. Anti-Money Laundering

You represent and warrant the following on a continuing basis, and shall promptly notify CFTL Digital if any of the following ceases to be true and accurate:

Payment of fees generally will be made first from Client Account assets in cash, next from the liquidation of cash equivalents, and finally from liquidation of securities held in your Account. Until you terminate your Account, you will be deemed to reaffirm continuously your agreement that Cowrywise may deduct the Account Fees from your Client Account.

5.1 To the best of your knowledge, based on appropriate diligence and investigation, none of the cash or assets to be invested in the trading of stocks on CFTL Digital's Platform has been or shall be derived from or related to any activity that is deemed to be in contravention of the Money Laundering Prohibition (Amendment) Act, 2022, the Securities and Exchange Commission (Capital Market Operators Anti-Money Laundering, Combating Terrorism Financing and Proliferation Financing) Regulations, 2022, Terrorism (Prevention and Prohibition) Act, 2022 ("AML Laws") and other applicable laws; and

5.2 No contribution or payment by you to CFTL Digital shall cause CFTL Digital to be in violation of the AML Laws and other applicable laws.

Where we discover that the representations above are untrue or inaccurate or that our Platform and/or Services are being used contrary to the AML Laws or other applicable laws or to launder money or for any suspicious transactions, we have an obligation to report your activities to the relevant regulatory authorities without recourse to you.

6. Representations and Warranties

6.1 You represent and warrant that:

  • a. you have full power and authority to enter into this Agreement to access the Platform and our Services;
  • b. the terms hereof do not violate any obligation by which you are bound, whether arising by contract or operation of law, or otherwise;
  • c. the assets in the Client Account are and shall be free from all liens and charges; and
  • d. you shall promptly notify CFTL Digital if any of your representations or warranties in this Agreement are no longer true or completely accurate.
7. Termination

You agree that we reserve the right to terminate or suspend your access to the Platform, with or without cause at any time or without prior notice to you, effective immediately, if your account is found to be fraudulent or exhibits fraudulent or suspicious behaviour, or if you have breached any part of these Terms of Use.

Upon termination of your use of the Platform, your login access will be promptly disabled. If you need assistance or encounter any issues during the termination process, please reach out to us via email at support@cowrywise.com .

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity of anyone posting, publishing, or otherwise making available any Client information, emails, or other materials that are believed to violate these Terms of Use. Any suspension, termination, or cancellation shall not affect your obligations to CFTL Digital under these Terms of Use (including but not limited to ownership, indemnification, and limitation of liability), which by their sense and context are intended to survive such suspension, termination, or cancellation.

8. CFTL Digital's "Dos" and "Don'ts"

CFTL Digital grants you a limited, non-exclusive license, which may not be sub-licensed, to use our Platform, so long as you comply with all our rules.

8.1 Dos: You agree that you will:
  • a. Comply with all applicable laws, including, without limitation, privacy laws, AML laws, intellectual property laws, anti-spam laws, export control laws, tax laws, and regulatory requirements;
  • b. Provide accurate information to us, whether reported directly or through a third party whom you authorise;
  • c. Keep your personal and account information on the Platform accurate and updated;
  • d. Use the Services solely for your personal, non-commercial use;
  • e. Use your real name on your personal profile and keep your password confidential; and
  • f. Use the Services in a reasonable and professional manner and ensure there is no breach of these Terms of Use.
8.2 Don'ts: You agree that you shall not:
  • a. Circumvent, disable, or otherwise interfere with security-related features of the Platform or features that prevent or restrict use or copying of any content or Client information;
  • b. Upload, email, transmit, provide, or otherwise make available:
    • Any information which you do not have the lawful right to use, copy, transmit, display, or make available (including any Client information that would violate any confidentiality or fiduciary obligations that you might have with respect to the Client information);
    • any Client information that infringes the intellectual property rights of, or violates the privacy rights of CFTL Digital or any third-party (including, without limitation, copyright, trademark, patent, trade secret, or other intellectual property right, moral right, or right of publicity);
    • unsolicited or unauthorised advertising, promotional materials, junk mail, spam, chain letters, pyramid schemes, or any other form of solicitation;
    • any personal information that is unlawful, obscene, harmful, threatening, harassing, defamatory, or hateful, or that contains objects or symbols of hate, invades the privacy of any third-party, contains nudity, is deceptive, threatening, abusive, inciting of unlawful action, or is otherwise objectionable in the sole discretion of CFTL Digital;
    • any personal information that contains software viruses or any other computer code, files, or programs designed to (i) interrupt, destroy, or limit the functionality of any computer software; or (ii) interfere with the access of any user, host or network, including by way of overloading, flooding, spamming, mail-bombing, or sending a virus to CFTL Digital;
    • any personal information that includes code that is hidden or otherwise surreptitiously contained within the Client information;
    • Use any meta tags or other hidden text or metadata utilising CFTL Digital's name, trademark, URL or product name;
    • Forge any TCP/IP packet header or any part of the header information in any posting, or in any way use CFTL Digital to send altered, deceptive, or false source-identifying information;
    • Interfere with or disrupt (or attempt to interfere with or disrupt) any CFTL Digital web page, server, or network, or the technical delivery systems of CFTL Digital's providers, or disobey any requirements, procedures, policies, or regulations of networks connected to CFTL Digital;
    • Attempt to probe, scan, or test the vulnerability of any CFTL Digital system or network or breach or impair or circumvent any security or authentication measures protecting CFTL Digital;
    • Attempt to decipher, decompile, disassemble, or reverse-engineer any of the software used to provide CFTL Digital's Services;
    • Attempt to access, search, or meta-search CFTL Digital or content thereon with any engine, software, tool, agent, device, or mechanism other than software and/or search agents provided by CFTL Digital or other generally available third- party web browsers, including without limitation, any software that sends queries to CFTL Digital to determine how a website or web page ranks;
    • Violate the terms of use or any other rule or agreement applicable to you or CFTL Digital's inclusion in, reference to, or relationship with any third party or third-party site or service, or your use of any such third-party site or service;
    • Collect or store personal information about other users without their express permission;
    • Impersonate or misrepresent your affiliation with any person or entity, through pretexting or some other form of social engineering, or commit fraud;
    • Solicit any other user of the Platform for any investment or other commercial or promotional transaction;
    • Violate any applicable law, regulation, or ordinance;
    • Scrape or copy information through any means (including crawlers, browser plugins and add-ons, and any other technology or manual work);
    • Use, launch, or permit to be used any automated system, including without limitation "robots," "crawlers," or "spiders"; or
    • Copy or use the information, content or data on CFTL Digital in connection with a competitive service (as determined by CFTL Digital);
    • Monitor CFTL Digital's availability, performance or functionality for any competitive purposes;
    • Use CFTL Digital or its content thereon in any manner not permitted by these Terms of Use;
    • Conduct unauthorized use of copyrighted materials. If you become aware of misuse of CFTL Digital or content thereon by any person, please contact CFTL Digital (via cftlcompliance@cowrywise.com ) to report any abuse.
9. Intellectual Property

The content contained on the Platform is owned or licensed by CFTL Digital and is protected by applicable copyrights, trademarks, service marks, and/or other intellectual property rights. Such content is solely for your personal, non-exclusive and non-commercial use. Accordingly, you shall not copy, distribute, modify, post, frame or deep link this Platform, including any text, graphics, video, audio, software code, user interface design or logos.

All trademarks, service marks, tradenames and logos displayed on the Platform are proprietary to CFTL Digital and Cowrywise Financial Technology Limited ("Cowrywise Entities"). Nothing contained on the Platform should be construed as granting by implication, estoppel or otherwise, any license or right to use any trademark displayed on the Platform, without the written permission of the Cowrywise Entities or such other third party that may own the trademark displayed on the Platform. Your use of the trademarks displayed on the Platform, except as provided herein, is strictly prohibited.

The use of the images displayed on the Platform by you, or anyone else authorised by you, is prohibited. Any unauthorised use of the images may violate copyright laws, trademark laws, and the laws of privacy and publicity, and communications, as well as other regulations and statutes.

10. General Terms

In the event that any provision in these Terms of Use is held to be invalid or unenforceable, the remaining provisions will remain in full force and effect. The failure of a party to enforce any right or provision of these Terms of Use will not be deemed a waiver of such right or provision. You may not assign this Agreement (by operation of law or otherwise) without the prior written consent of CFTL Digital, and any prohibited assignment will be null and void.

CFTL Digital may assign these Terms of Use/Agreement or any rights hereunder without your consent. CFTL Digital's role under these Terms of Use is that of an independent contractor, and these Terms of Use will not be construed to imply that either party is the agent, employee, or joint venture of the other. Note that if you elect to become a Client, the relationship of the parties will be governed by these Terms of Use, our Privacy Policy and any additional terms to which you agree when you create and fund an investment account. We reserve the right to change this Agreement by posting a revised Terms of Use, and we agree that changes cannot be retroactive. If you do not agree with these changes, do not continue the use of CFTL Digital's Services. You agree that the only way to provide us with legal notice is at the address provided in Section 13.4.

11. International Use

CFTL Digital is only for use in Nigeria.

CFTL Digital is only available for use in Nigeria. We make no representation that CFTL Digital is appropriate or available for use outside Nigeria. Similarly, we make no representations that accessing CFTL Digital's platform from locations outside Nigeria is legal or permissible by local law. If you access CFTL Digital's platform from areas outside of Nigeria, you do so at your own risk and are personally responsible for compliance with local laws.

12. Monitoring and Recording

CFTL Digital retains the right to observe, monitor, and record activities on our sites without providing prior notice or seeking permission from you. By signing up to and using the Platform, you authorise CFTL Digital to engage vendors to verify your identity or the information you have provided. Any information obtained through the monitoring, review, or recording of activity on the website or our App may be subject to review by law enforcement agencies in connection with investigations or prosecutions of potential criminal activity, as well as by regulatory agencies or self-regulatory bodies with supervisory authority over CFTL Digital. In addition, CFTL Digital will comply with all Nigerian federal or state court orders requesting such information. As part of our commitment to ensuring quality service and safeguarding our customers, CFTL Digital reserves the right to record all telephone calls, chat conversations, and other communications between you and CFTL Digital for appropriate purposes.

13. Miscellaneous

This Terms of Use/Agreement together with CFTL Digital's Privacy Policy and any other terms or policies which you agree or consent to when opening and funding your account form the complete and exclusive agreement between you and CFTL Digital with respect to your use of our website and App, and other subject matters contemplated by this Agreement, superseding and replacing any and all prior or contemporaneous agreements, communications, and understandings, both oral and written, regarding that subject matter.

13.1 Governing Law and Dispute Resolution

This Agreement shall be governed, construed, and enforced pursuant to the laws of the Federal Republic of Nigeria.

Any disagreement, dispute or difference howsoever arising, from this Agreement, including its interpretation and validity or as to the rights, duties and liabilities of the Parties hereto or as to any other matter in any way connected with or arising out of or in relation to the subject matter of this Agreement, which cannot be amicably resolved by the Parties within 30 (thirty) days shall be referred to arbitration in accordance with and subject to the provisions of the Arbitration and Mediation Act, 2023 or any amendments thereof.

13.2 Integration & Severability

If any provision of this Agreement is found to be illegal, unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that this Agreement will otherwise remain in full force and effect.

13.3 Waivers

The failure of either party to exercise in any respect any right provided for herein shall not be deemed a waiver of any further rights hereunder.

13.4 Communication: Any notice or communication will be in writing by email

By accepting these terms and executing this Agreement, you further agree and acknowledge that these Terms of Use and the rules, restrictions, and policies contained herein, and CFTL Digital's enforcement thereof, are not intended to confer and do not confer any rights or remedies on any person other than you and CFTL Digital.

You hereby authorise the delivery of notices required under this Agreement by:

  • a. CFTL Digital, via email (in each case to the email address that you provide); or
  • b. You, via email to – cftlcompliance@cowrywise.com or to such other addresses as CFTL Digital may specify in writing. The date of receipt shall be deemed the date on which such notice is transmitted.

You can also contact CFTL Digital by phone at +234 (0) 903 000 0857

You undertake to notify CFTL Digital if you have any reason to believe your email address or account may have been compromised by any third party.