straitPay

Terms and Conditions

Effective date: 10 June 2026

Last updated: 10 June 2026

1. Introduction

Welcome to straitPay — the fast, low-cost way to send money to Africa. These Terms and Conditions ("Terms") govern your use of the straitPay website, mobile application, and MiniPay mini application (together, the "Services"). Please read them carefully. By accessing or using the Services, you agree to be bound by these Terms. If you do not agree, you must not use the Services.

These Terms should be read alongside our Privacy Policy, which is available at www.straitpay.com/privacy.

2. Who We Are and Our Regulatory Status

straitPay is a trading name of Strait Sahara Limited, a company incorporated in Nigeria with its registered address at 20 Park Lane, Apapa, Lagos, Nigeria ("straitPay", "we", "us", "our").

straitPay operates as part of the Strait Sahara group of companies. Regulated activities are conducted by the relevant licensed entity within the group depending on the jurisdiction in which the activity takes place, as set out below.

Regulatory licences held within the Strait Sahara group:

3. How straitPay Works

3.1 The Service

straitPay enables senders located in the United States, Canada, United Kingdom and other supported countries to transfer funds to recipients holding bank accounts or mobile money wallets across Africa. Recipients receive funds in their local currency directly into their existing account. Recipients are not required to download any application, create an account, or take any action to receive funds.

3.2 Supported Corridors

straitPay currently supports transfers to the following recipient countries and currencies:

• Nigeria — Nigerian Naira (NGN) to any Nigerian bank account
• Ghana — Ghanaian Cedi (GHS) to mobile money wallets
• Kenya — Kenyan Shilling (KES) to M-Pesa and other mobile money wallets
• Uganda — Ugandan Shilling (UGX) to mobile money wallets
• Additional African corridors as supported by our licensed off-ramp partners

The full list of supported corridors is displayed within the application and updated as new corridors become available.

3.3 Technology and Blockchain Infrastructure

straitPay is operated as a mini application within the MiniPay wallet, developed by Opera Norway AS. Wallet infrastructure, stablecoin balances and on-device authentication are provided by MiniPay. straitPay is an independent service operating within the MiniPay ecosystem and is not affiliated with Opera Norway AS.

Transfers are settled using stablecoin technology on the Celo blockchain. When you confirm a transfer, USDT or USDC is sent from your MiniPay wallet directly to our licensed off-ramp partner's Celo wallet address. The off-ramp partner then converts the stablecoin to local currency and credits the recipient's bank account or mobile money wallet.

Important: blockchain transactions are irreversible:

Once a transfer is confirmed and the on-chain transaction is executed, it cannot be reversed or recalled by straitPay. Blockchain transactions are final. Please verify all recipient details carefully before confirming. If a transfer fails at the payout stage after the on-chain transaction has completed, our off-ramp partner will initiate a refund of the stablecoin amount to the originating wallet. Refund timelines depend on the off-ramp partner and are typically completed within 1-5 business days.

3.4 Non-Custodial Model

straitPay does not hold, custody, or control customer funds at any point in the transaction. Funds move directly from your MiniPay wallet to our licensed off-ramp partner's designated Celo wallet address. straitPay acts as an instruction and routing layer only. We do not maintain customer fund balances. There is no straitPay wallet balance to withdraw or refund.

4. Eligibility

You must be at least 18 years old to use our Services. By registering or using the Services, you confirm that:

• You are at least 18 years of age;
• You are legally capable of entering into a binding contract under the laws of your jurisdiction;
• You are not located in, or a national or resident of, any country subject to applicable sanctions or export controls;
• You will use the Services only for lawful purposes; and
• All information you provide is accurate, current and complete.

We reserve the right to refuse service to any person at our discretion.

5. Verification (KYC) and Compliance

5.1 Identity Verification

To comply with Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Know Your Customer (KYC) obligations under our licences in Nigeria, the United States, Canada and the United Kingdom, we are required to verify the identity of all senders before their first transaction and on an ongoing basis as required by regulation.

You agree to provide, when requested:

• Valid government-issued photographic identification (passport, national identity card or driving licence);
• Proof of address (utility bill, bank statement or equivalent, dated within 90 days);
• Source of funds information where required; and
• Any additional documentation reasonably requested for compliance purposes.

Identity verification for sender users is conducted by Veriff, a regulated identity verification provider. Recipient bank accounts in Nigeria are verified using Youverify's BVN lookup and account name confirmation service. Your acceptance of this verification process is a condition of using the Services.

5.2 Transaction Monitoring and Limits

All transactions are subject to automated sanctions screening and real-time AML monitoring. Transaction limits apply based on your verification level and applicable regulatory thresholds. Applicable limits are displayed within the application. We are required under our IMTO, MSB and SPI licences to apply reporting thresholds and may request additional information for transactions above certain values.

We may pause, delay or cancel transactions where:

• Identity verification is incomplete or cannot be confirmed;
• The source or purpose of funds is unclear;
• Activity appears suspicious or potentially contrary to applicable AML or CTF laws; or
• A transaction would cause us to breach applicable regulatory requirements.

5.3 Suspicious Activity

We are obliged under our regulatory licences to file Suspicious Activity Reports (SARs) or equivalent disclosures with the relevant authorities (CBN, FinCEN, FINTRAC, FCA) where we identify activity that may constitute money laundering, terrorist financing or other financial crime. We are legally prohibited from disclosing to you whether or when such a report has been filed.

6. Fees, Exchange Rates and Transaction Limits

We are committed to full transparency on pricing. Before you confirm any transfer:

• The transfer fee is displayed in your chosen display currency (USD or CAD);
• The exchange rate applied to the transfer is shown and locked for ten (10) minutes from display;
• The exact amount the recipient will receive in their local currency is shown; and
• The total amount to be debited from your MiniPay wallet is shown.

Exchange rates reflect live interbank market values with a disclosed margin applied. We obtain rates from our licensed off-ramp partners in real time. The rate shown to you is the best available rate from our partner network at the time of your transfer.

Fees and exchange rates may change from time to time. We will notify you of material changes via the application or our website. Your transaction will always be processed at the rate and fee shown and agreed at the time of confirmation.

7. Account Security

straitPay operates as a mini application within MiniPay. You do not create a separate straitPay account or password. Your access to the Services is authenticated through your MiniPay wallet, which is managed by Opera Norway AS. You are responsible for maintaining the security of your MiniPay wallet and device.

You must:

• Keep your device secure and not share access with third parties;
• Notify us immediately at support@straitpay.com if you believe your MiniPay wallet has been compromised and a straitPay transaction has been made without your authorisation; and
• Take reasonable steps to secure your device including using device-level security (PIN, fingerprint or face recognition) as provided by your device and MiniPay.

We monitor all transactions for unusual activity. We are not responsible for losses arising from your failure to maintain the security of your device or MiniPay wallet.

8. Third-Party Partners and Off-Ramp Providers

straitPay works with regulated third-party partners to deliver the Services. These include:

• Off-ramp providers (currently Partna and Fonbnk) who receive USDT on the Celo blockchain and execute local currency payouts to recipient bank accounts and mobile money wallets;
• Identity verification providers (Veriff for sender KYC and Youverify for Nigerian recipient account verification);
• SMS notification providers (Termii and Twilio) for transaction confirmations; and
• MiniPay (Opera Norway AS) which provides the wallet infrastructure and distribution platform.

While we select and oversee our partner relationships, straitPay is not responsible for technical failures, delays or service interruptions caused by third-party infrastructure beyond our reasonable control. In the event of a payout failure caused by an off-ramp partner, we will work to ensure a refund is returned to your MiniPay wallet as promptly as practicable.

9. Data Protection and Privacy

We take the protection of your personal data seriously. Your personal data is collected, processed and retained only as necessary to deliver the Services, meet our legal and regulatory obligations, and comply with applicable anti-money laundering and financial crime prevention requirements.

We comply with applicable data protection laws in the jurisdictions in which we operate, including:

• The Nigeria Data Protection Act 2023 and the Nigeria Data Protection Regulation;
• The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, for users accessing the Services from the United Kingdom; and
• Canadian provincial privacy legislation including PIPEDA, for users accessing the Services from Canada.

We may share limited personal data with our regulated partners, banks, compliance providers and regulatory authorities as required by law. We do not sell your personal data to third parties for marketing purposes.

You have the right to access, correct, or request deletion of your personal data, subject to our legal retention obligations. Full details of how we collect, use, share and protect your personal data are set out in our Privacy Policy at www.straitpay.com/privacy.

10. Prohibited Activities

You must not use straitPay to:

• Conduct illegal, fraudulent, deceptive or unauthorised transactions;
• Violate foreign exchange laws, export controls or regulatory reporting requirements in any applicable jurisdiction;
• Facilitate money laundering, terrorist financing, sanctions evasion or other financial crime;
• Process payments related to gambling, illegal weapons, controlled substances, human trafficking, or other prohibited goods or services;
• Misuse, misappropriate or misrepresent the personal or financial data of a third party;
• Circumvent transaction limits, verification requirements or security measures; or
• Interfere with, disrupt or attempt to gain unauthorised access to the Services, our systems or those of our partners.

We reserve the right to restrict, suspend or permanently terminate your access to the Services if any such activity is detected or suspected, and to report such activity to the relevant regulatory or law enforcement authorities.

11. Intellectual Property

All software, content, designs, trademarks and materials available through straitPay are the property of Strait Sahara Limited or our licensors. The Celo blockchain infrastructure underlying the Services is provided under open source and commercial licences by Celo and its contributors. You may use the Services only for personal or business money transfer purposes as authorised. You may not copy, reproduce, reverse engineer, resell or create derivative works from any part of the Services without our express written consent.

12. Service Availability

We aim to keep straitPay available at all times, but access may occasionally be interrupted due to maintenance, system updates, network issues, blockchain congestion, or regulatory requirements. We will use reasonable endeavours to notify users of planned maintenance in advance.

We are not liable for delays or interruptions caused by third-party systems including MiniPay wallet infrastructure, off-ramp provider systems, banking networks, mobile money networks, or the Celo blockchain.

13. Limitation of Liability

To the fullest extent permitted by applicable law, straitPay is not liable for:

• Delays or failures caused by third-party systems, off-ramp partners, banking networks or regulatory actions beyond our reasonable control;
• Losses arising from your breach of these Terms or your provision of incorrect recipient details;
• Losses arising from the irreversibility of blockchain transactions following your confirmation;
• Indirect, incidental, special or consequential losses including loss of profit, loss of revenue, loss of data or loss of business opportunity; or
• Losses arising from your failure to maintain the security of your MiniPay wallet or device.

Nothing in these Terms limits our liability for fraud, wilful misconduct, or death or personal injury caused by our negligence. Where liability cannot be excluded, our total liability to you in connection with any single transaction shall not exceed the value of that transaction.

If you are a consumer user, nothing in these Terms affects your statutory rights under the laws of your jurisdiction.

14. Dispute Resolution and Regulatory Complaints

14.1 Internal Complaints

If you have a complaint about the Services, please contact our support team in the first instance:

• Email: support@straitpay.com
• Subject line: COMPLAINT — [your reference or transaction number]
• We aim to acknowledge all complaints within 2 business days and provide a substantive response within 15 business days.

14.2 Regulatory Escalation

If your complaint is not resolved to your satisfaction, you may escalate it to the relevant regulator for your jurisdiction:

14.3 Governing Law

These Terms are governed by and construed in accordance with the laws of Nigeria for cross-border and platform-wide matters. Users accessing the Services from the United Kingdom retain all statutory rights available to them under English law and the protections applicable under FCA regulation. Users in Canada retain their rights under applicable Canadian consumer protection legislation.

15. Updates and Amendments

We may update these Terms from time to time to reflect changes in our Services, regulatory requirements, or applicable law. Where changes are material, we will provide at least 14 days' notice via email, in-app notification or a prominent notice on our website before the changes take effect. Continued use of the Services after the effective date of any updated Terms constitutes your acceptance of those changes. If you do not accept the updated Terms, you must stop using the Services.

16. Termination

You may stop using the Services at any time. To formally close your straitPay account, contact support@straitpay.com.

We may suspend or terminate your access to the Services with or without notice where:

• You breach these Terms;
• We are required to do so by law or regulatory requirement;
• We have reasonable grounds to suspect fraud, money laundering or other financial crime; or
• We cease to offer the Services in your jurisdiction.

Because straitPay does not hold customer funds (see Section 3.4), there is no balance to return on account closure. If a transfer is in progress at the time of termination and the on-chain transaction has completed but the payout has not yet been made, we will work with our off-ramp partner to ensure the stablecoin amount is returned to the originating wallet where technically possible.

17. General

17.1 Entire Agreement

These Terms, together with our Privacy Policy, constitute the entire agreement between straitPay and you in relation to your use of the Services and supersede all prior terms, conditions, representations or understandings.

17.2 Severability

If any provision of these Terms is found to be invalid, unlawful or unenforceable by a court of competent jurisdiction, that provision shall be severed and the remaining provisions shall continue in full force and effect.

17.3 No Waiver

Our failure to enforce any right or provision of these Terms shall not constitute a waiver of that right or provision.

17.4 Assignment

We may assign or transfer our rights and obligations under these Terms to a successor entity in connection with a merger, acquisition, or sale of all or substantially all of our assets. You may not assign your rights under these Terms without our prior written consent.

18. Contact Us

If you have any questions about these Terms, please contact us:

• Email: support@straitpay.com
• Website: www.straitpay.com
• Privacy Policy: www.straitpay.com/privacy
• Registered address: Strait Sahara Limited, 20 Park Lane, Apapa, Lagos, Nigeria

straitPay is a trading name of Strait Sahara Limited. Regulated activities are conducted by the appropriate licensed entity within the Strait Sahara group as described in Section 2 of these Terms. These Terms were last updated on 10 June 2026.