Last Updated: January 05 2025

About VerySell Technologies

VerySell Technologies (Uganda) Limited, part of Verysell Technologies S.A. (herein collectively referred to as “VerySell”, “VerySell Technologies”, the “Company”, “we”, “our”, “us”), offers app-based companion solutions for e-wallets (the “VeryPay Apps”), and allows customers and merchants to manage e-payments in a secure and more economical way.

We are registered with the Uganda Registration Services Bureau in Uganda with registration number 80020003834350, with corporate offices at Zebra Plaza, Plot 23, Kampala Road of P. O. Box 21975, Uganda.

USER AGREEMENT

This User Agreement (“Agreement”) is a contract between you, the User, and VerySell Technologies and it applies to your use of VerySell Technologies’s products and services and all other VerySell Technologies’s features, technologies, and/or functionalities offered on our website, in the VeryPay Apps or through any other means (collectively, the “Services”) whether as visitors, registered users, or account holders.

The Services provided to you are subject to this Agreement as well as our Privacy Policy (“Privacy Policy”) which is incorporated in this Agreement by reference. By using the VerySell Technologies’s Services, you accept and agree to be bound and abide by the terms and conditions of this Agreement.

If you do not agree with any part of the Agreement, you should not use the VerySell Technologies’s Services. We may terminate, suspend, or restrict your access to our Services at any time if you violate the terms of this Agreement.

1. Opening An Account

1. In order to use some of our Services, you may first need to register an account by registering your details on our VeryPay Apps or via a 3rd party portal (app, website). As part of the registration process, you will need to accept the terms of this Agreement and you must have legal capacity to accept them.

   If you are an individual, you must be 18 years or older to use our Services and by opening an account with our Services you declare that you are 18 years or older.

   In addition to opening an account with a third party e-wallet provider, you will need to open an account with us.

   We offer the following different types of accounts:

   1. PERSONAL ACCOUNT: or use in person-to-person transfers with friends and family, and other people whom you know. Personal accounts may also be used to make authorized merchant payments, that is a means a payment transaction between you and an authorized merchant made via the Services where such authorized merchant payments are available. Some features of personal accounts may be limited based on how you wish to use the Services, how much you need to send or spend, and what we know about you. We may also require that you provide additional information in order to complete a transaction. Personal accounts have a group sharing functionality for personal use only. Personal accounts may not be used to receive business, commercial or merchant transactions.

      On the VeryPay Apps you will be asked to provide first name, last name, email address, phone number and billing address. The application has an OTP verification procedure which means that during the registration process a code will be sent to your cell phone and you will need to enter this code into the application form in order to open an account with our Services.

   2. BUSINESS ACCOUNT: Business accounts must be applied for and explicitly authorized by us once they are available. By opening a business account and accepting the terms as outlined in this Agreement, you confirm that neither you, nor your business, is establishing a business account primarily for personal, family, or household purposes. We may reverse or place a hold on your transactions or place a reserve on your funds if you are in breach of this Agreement, including, but not limited to, if you are using a personal account for business purposes or vice versa.

      On the VeryPay Apps you may be asked to provide full registered name, registered address, business operating address (if different to registered address), tax or business ID; first name, last name and email of the business account manager, phone number and billing address. The application has an OTP verification procedure which means that during the registration process a code will be sent to your cell phone and this code needs to be entered into the application form in order to open an account with our Services.

2. We may request, in our sole discretion, you to provide one or more answers to security questions and additional information or documents it deems necessary and appropriate in line with its assessment of risks relevant to you both in course of its review of your application and during the whole period of validity of this Agreement. You undertake that all information and documents which you present to us are true, accurate and up to date. If, at any point during the term of the Agreement, any of the information and documents presented to us should change or you identify that they were false, inaccurate and / or incorrect in any form, then you shall promptly present us with the respective updated information and documents. You can update the information and documents presented to us by email at support@verypay.ch and we may ask you at any time to confirm the accuracy of your information and / or provide additional supporting documents. We may also contact third parties to collect and / or verify the information and documents presented by you under this Agreement. We may limit your access to our Services until such collection of information and / or verification is completed.

2. Keeping Your Account Safe

You must take all reasonable steps to always keep your account password with us and any other security features safe and never disclose them to anyone. Our personnel will never ask you to provide your password or other security features to us or to a third party. Any message you receive or website you visit that asks for your password or other security features should be reported to us. If you are in doubt whether a website is genuine, you should contact our Customer Service. It is advisable to change your password regularly (at least every three (3) to six (6) months) in order to reduce the risk of a security breach in relation to your account. We also advise you not to choose a password that is easily guessed from information someone might know or gather about you or a password that has a meaning. You must never allow anyone to access your account or watch you accessing your account.

If you have any indication or suspicion of your account, login details, password or other security feature being lost, stolen, misappropriated, used without authorization or otherwise compromised you must contact our Customer Service without undue delay on becoming aware of any loss, theft, misappropriation or unauthorized use of your account, login details, password or other security features. Any undue delay in notifying us may not only affect the security of your account but may result in you being liable for any losses as a result where your failure to notify us is intentional or grossly negligent. If you suspect that your account was accessed by someone else, you should also contact the police and report the incident.

3. Prohibited Transactions

It is strictly forbidden to send or receive payments as consideration for the sale or supply of: drugs and drug paraphernalia, weapons (including without limitation, knives, guns, firearms or ammunition), material which incites violence, hatred, racism or which is considered obscene, government IDs and licenses including replicas and novelty items and any counterfeit products, unlicensed or illegal lotteries or unlicensed or illegal gambling services (including without limitation the use of or participation in illegal gambling houses), unregistered charity services, items which encourage or facilitate illegal activities, prepaid debit cards or other stored value cards that are not associated with a particular merchant and are not limited to purchases of particular products or services, third party processing or payment aggregation products or services, multi-level marketing, pyramid selling or Ponzi schemes, matrix program or other “get rich quick” schemes or high yield investment program, goods or services that infringe the intellectual property rights of a third party, un-coded/miscoded gaming, timeshares or property reservation payments (on and off plan). We reserve the right, in our sole discretion, to add categories of prohibited transactions by adding such categories to the terms of this Agreement.

It is strictly forbidden to make payments to or to receive payments from persons or entities offering illegal gambling services, including (but not limited to) illegal sports betting, casino games and poker games. We may suspend or terminate your account at any time or refuse to execute if we believe that you directly or indirectly use or have used your account for or in connection with illegal gambling transactions. This list is not exhaustive and it is your responsibility to ensure that you do not use our services for transactions that may be considered illegal in your jurisdiction.

It is strictly forbidden to use your account for any illegal purposes including but not limited to fraud, money laundering, bribery. We will investigate and report any suspicious activity to the relevant law enforcement agency. You are prohibited from using your account in an attempt to abuse, exploit or circumvent the usage restrictions imposed by a merchant or a third-party provider on the services it provides.

If you conduct or attempt to conduct any transaction in violation of the prohibitions contained in this section, any unlawful and/or abusive activity, we reserve the right to: close or suspend your account; and/or report the transaction to the relevant law enforcement agency; and/or claim damages from you.

It is your and not our responsibility to ensure that you only send payments to or receive payments from persons or entities for the sale or supply of goods and services that you may provide or receive in compliance with any applicable laws and regulations. The mere fact that a person or entity accepts payments through us is not an indication of the legality of the supply or provision of their goods and services. If you are in doubt as to the legality of a supply or purchase, you should not continue with your payment.

4. Chargebacks, Disputed Transactions, and Payment Protection Policy

1. The amount of a transaction may be charged back or reversed to the User’s e-wallet provider payment account (a “Chargeback”) if the transaction (a) is disputed by the sender, (b) is reversed for any reason by the participating mobile money provider or financial institution, (c) was not authorized or we have any reason to believe that the transaction was not authorized, or (d) is allegedly unlawful, suspicious, or in violation of the terms of this Agreement.

   Under our payment protection policy (the “Policy”), we will not hold you liable for Chargebacks if you and the transactions meet all the requirements of the Policy.

   To qualify for coverage under the Policy, the following requirements apply:

   • You must be registered with a VeryPay Service account.
   • You must provide all requested information within the time limit specified by the email sent by us, including without limitation valid proof of delivery.
   • The transaction and your User e-wallet provider payment account do not violate the terms of this Agreement and policies.

Excessive Chargebacks: If we determine that the User is incurring an excessive amount of Chargebacks, we may establish controls or conditions governing your account, including without limitation, by (a) limiting acceptance or sending privileges, and (b) terminating or suspending the Services.

Contesting Chargebacks: The User agrees to assist us when requested, at your expense, to investigate any of your transactions processed through the Services. You, the User, acknowledge that your failure to timely assist us in investigating a transaction, including without limitation providing necessary documentation within five (5) days of our request, may result in an irreversible Chargeback.

5. Complaints & Dispute Resolution

Any complaint relating in any way to the use of the VeryPay Apps, or the Services should be addressed to our Customer Service team at support@verypay.ch. Our aim will be to address your complaint as soon as practically possible and within a reasonable time frame. We will strive to achieve an amicable resolution where appropriate. In all cases we will endeavor to resolve the matter within 2 weeks from the point at which we have been supplied by you with all relevant information.

6. Personal data and Confidentiality

1. WHAT TYPE OF PERSONAL INFORMATION WE COLLECT:

   1. Information About You that You Share with Us Directly: When you use our Services, you may give us personal information directly (for example, details you register with us when setting up your account), and we will store that personal information on our systems and process it for the purposes described in this Personal Data and Confidentiality section, also known as our Privacy Policy. Depending on the Service, the personal information we collect will be relevant to providing that Service and include some or all of the following:

      • Name
      • Email
      • Your company name
      • Username
      • Password
      • Avatar image
      • Card Number and Pin
      • Card Limits
      • Transaction ID and other financial information that we may need in order to provide our Services
      • “Identifiers” – information which we treat as your personal information as it relates to you and your use of our Services but is not directly provided by you from your device (e.g. geolocation data & IP address, device manufacturer and model, iOS version)
      • personal information you provide when you ask for help from our customer support team, including the content of that communication with our team
      • language selection
      • History of purchases including specific items, quantities and price – with participating merchants
      • Geolocation

   2. Information Shared About Others: We may give you the ability to invite people you know to use our Services. You are responsible for ensuring your sharing of this personal information with us is compliant with applicable laws. In some countries, this may require you to get permission from the people you invite before you share their information. We may also get personal information about you from other App users. We process this personal information to help you and your contacts connect through our Services. If you want to remove personal information stored by us, follow any instructions under the CONTACT US section below.

   3. Information You Generate Using Our Services: Transaction activity and history on the Services. When you use our Services, we will collect personal information about the ways in which you use and interact with our Services, such as any purchases you make, money you send. We will also create an App ID to identify your account.

   4. Information We Receive About You From Connected Third Party Platforms: The information we mat receive from third party e-wallet platforms to provide you the Services includes:

      • first name
      • last name
      • address (city, zipcode, state, country)
      • email address
      • phone number
      • e-wallet ID
      • e-wallet balances
      • voice balances
      • currency used
      • History of purchases including specific items, quantities and price – with participating merchants
      • Geolocation

      If you access our Services from a third-party platform or connect our Services to a third-party account, you should also read that third-party platform’s terms of service and privacy policy.

2. WHY WE PROCESS YOUR INFORMATION AND OUR LEGAL GROUNDS:The main reason we process your personal information is to provide you with the Services and to improve your experience, but there are other reasons as well. We process your information for the purposes below:

   • Set up your account and to provide our Services (e.g. process your transaction requests)
   • Identify and authenticate your access to certain features of the Services;
   • Improve, optimize and personalize our Services and our users’ experiences;
   • Help you to connect with other people you know and other third-party platforms you use;
   • Communicate with you about the Services you are using or we think you will like, including new Services;
   • Customer service, including technical support;
   • Protect the safety and well-being of customers;
   • Maintain our business operations, including any business transition, like a merger, acquisition by another company, or sale of all or part of our assets;
   • For security purposes and to prevent fraud or potentially illegal activities;
   • Cooperate with public authorities and law enforcement where lawfully permitted or required;
   • Protect our’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties.

   Our legal grounds for collecting and using the information described above depends on what the information is, the context in which we collect it and applicable privacy laws. Those grounds are as follows:

   • Establish and perform our agreement with you to provide you the Services
   • For our or our partners’ legitimate interests
   • Consent (where applicable)
   • Compliance with a legal obligation
   • Protect your vital interests or those of another person

   If you have questions, need further information or want to withdraw your consent please see the CONTACT US section below.

3. HOW WE SHARE INFORMATION:

   We share your information with our group companies, people you know, other VeryPay App users and certain other third parties when you use our Services. We may share your personal information from our Services with others in the ways described below.

   People You Know and Other App Users: Our Services support you to transact with users. Other users can send you transaction requests through our Services.

   Our Group Companies: We’ll share your information with other companies in the Verysell group. We may share your personal information within the Verysell group companies to enable the Verysell group to carry out the purposes set out in this Privacy Policy.

   Safety, Security and Compliance with Law: We’ll share your information if necessary for safety, security, or compliance with legal obligations. Your information, and the contents of all of your online communications, transactions when using our Services and between you and us may be accessed and monitored as needed to provide our Service and may be disclosed:

   • to satisfy any applicable legal obligations;
   • when we have a good faith belief that we have to disclose personal information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
   • when we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
   • when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
   • to protect the rights or our property or applicable third parties

   Third Party Service Providers: We’ll share your information with the third-party service providers and business partners that we work with to bring you our Services and that support us with our business. We will share your information with third-parties who assist us in delivering and optimizing our Services or perform services on our behalf, like payment processing, analytics, analysis, hosting services, customer service.

   Sale or Merger: We may share your information with a third party in connection with a business transition, like a merger or acquisition. Where we consider a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, we may disclose or transfer your information, including personal information, to the purchaser.

4. YOUR RIGHT:

   Depending on what privacy laws apply to you, you and/or your legal representative have certain legal rights in connection with your personal information. Your privacy rights are explained below.

   Subject to certain exemptions, you have the right to:

   • Request a copy of your personal information (known as ‘accessing your data’).
   • Delete your information. When you ask us to delete your personal information please remember that there may be lawful limitations on this right. For example, we will keep certain payment records or customer service records where we need to, including for legal or accounting purposes. We’ll also keep information in order to exercise, protect, defend, or establish our rights or the rights of third parties.
   • Correct or update your personal information where it is inaccurate. To review and update personal information associated with your account profile, visit the ‘Account details’ page in our VeryPay Apps.
   • Withdraw your consent by CONTACTING US. Withdrawing your consent will not affect the processing already undertaken before your withdrawal. Also, it will not affect processing of your personal information under other lawful grounds.
   • Ask us to restrict processing of your personal information or request portability of your personal information. Complain to a data protection authority. A list of privacy authorities is available here.
   • Manage personal information we receive from third parties’ applications/platforms and from your mobile device: To manage the information we receive from third-party applications or platforms and from your mobile device, use the tools and settings provided by those third-party applications and devices.

5. HOW WE STORE AND SAFEGUARD YOUR PERSONAL INFORMATION:

   We work hard to protect your information but you also have a role to play. We implement reasonable and appropriate security measures to help protect the security of your information and to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information. It is important that you protect and maintain your VeryPay account’s security and that you immediately tell us of any unauthorized use of your account.

   All connections to our VeryPay Appsdatabase through the use of the Services are secured with HTTPS ( TLS 1.2) technology. The database network connection is protected by strict firewall rules. Only verified accounts can log in to VeryPay Apps database via VPN by Secure Shell (SSH). Only key-based authentication is allowed to access users’ accounts. Each user’s private key must be password protected. If the key authentication was successful and the account is allowed to log in on that particular system, the user is granted access to the system.

   While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Services. Any transmission is at your own risk

6. INTERNATIONAL OPERATIONS AND TRANSFERS:

   When you use our Services, your personal information may be processed in Uganda and other countries. As part of our international operations, we may transfer personal information to our group companies, business partners and service providers located internationally for our legitimate business purpose. We store personal information about you on servers located in the Switzerland. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is processed may be different from the privacy laws applicable to the place where you are resident. When we transfer your personal information internationally we treat your personal information securely.

7. HOW LONG WE KEEP YOUR INFORMATION:

   We’ll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights. How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for to provide you with the Services or for our legal requirements. We will retain personal information that is connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

7. Consumer Protection

1. The Company shall develop and conduct a consumer awareness program tailored to the category of the consumer.
2. The Company shall conduct programs through public awareness campaigns and information resources that empower the consumer. The information awareness shall be developed in English language and translated into other languages based on geographical location and needs of the consumer.
3. The Company uses a comprehensive and systematic strategy to ensure that consumers’ rights are protected, and the Company follows all related legislation and regulatory requirements. The strategy includes:
   • Fairness,
   • fair sales practices,
4. DISCLOSURE OF INFORMATION ON PRODUCTS AND SERVICES

   The Company shall disclose complete and accurate information to its consumer in simple, and plain language through inter-alia,

   • advertisements,
   • direct contact to the consumer
   • sales promotions
   • any other media of communication

   The disclosure shall be legible in a font size of not less than 10 points with spacing easy to read. Further, it shall contain highlights of key features of the product or services.

   The Company shall provide information on a product or service to a consumer before a consumer signs up for any product or service. The information required to be provided to
   a consumer above shall include;

   • updated information of a product or service whether in writing, electronically or orally in a fair, clear, and transparent manner.
   • an explanation in plain English of key features of the range of products or services that the consumer is interested in including benefits, risk, any charges, and fees which would be incurred.
   • inquiry or disputes resolution procedure.
   • information needed to verify whether or not the consumer is eligible for a product or service in which the consumer is interested.

   Where a Consumer or User has chosen a product or service, the Company shall before the consumer acquires the product or service, provide the consumer with a key fact document for the product or service. The key documents referred to above shall include;

   • charges
   • fees
   • interest where applicable
   • statement on whether charges or fees are instant or deferred payment
5. RECORD KEEPING

   The following information and documentation will be kept by the Company for at least 10 years, so it can be available if it is ever requested for by any other authority:

   • Documentation obtained during the KYC and Due Diligence procedures for identification of partners, which shall be kept for at least 10 years after the termination of the business relationship with the partner;- (Subject to confirmation with the Companies data privacy policies)

   Original documentation or certified copies of the transactions carried out by partners and the information related to them, which shall be kept for a minimum of 10 years after the completion of the transaction or operation carried out;

   • Any report of suspicious Transactions issued, and the documentation and information attached to it, which shall be kept during the 10 years following the date of the report.
6. RESPONSIBILITIES

   The Board of Directors of the Company shall be responsible for;

   • Approving the policy on consumer protection prepared by the Company.
   • Overseeing the implementation of the consumer protection policy.
   • Ensuring that a licensee complies with provisions of the Law and the Regulations on Consumer protection.
   • Verifying that management has put in place adequate processes for providing information necessary for monitoring and evaluation of the consumer protection initiatives through internal audit reports and risk management reports.

   The Board of Directors shall before approving the Consumer protection policy ascertain that the policy is adequate to protect the interests of the consumer and that the policy is up to date.

   The management of the Company shall be responsible for;

   • Establishing functional consumer protection coordination and collaboration mechanisms and preparation of reports;
   • Monitoring enterprise-wide operations and functional compliance with consumer protection requirements;
   • Providing consumer protection compliance guidance in accordance with this policy and the regulations;
   • Overseeing any agent or third party through which the company provides payment services;
   • Conducting consumer protection risk assessment on product and services and put in place risk mitigation measures;
   • Deploying professional and experienced personnel to handle consumers’ complaints;
   • Conducting research and analysis on the patterns and trends associated with complaints from consumers;
   • Providing relevant training and supervision for the employees, agents and third parties on the requirements of the regulations.
7. Consumer/User Protection Complaints and redress mechanism

   A User that has an issue or an inquiry arising from the conduct of business of the company may request the Company for clarification on the subject matter. The Company shall immediately acknowledge in writing receipt of an inquiry or request of the User that has applied above.The Company shall handle the request and give clarification or decision in writing within 2 working days.

   A User who is aggrieved or dissatisfied with the clarification or decision made by the Company in lieu of the complaint may lodge a complaint with the Central Bank in accordance with the National Payment Systems (Consumer Protection) Regulations, 2022.

Step 1 : Receiving and Handling Range of entry points for customer inquiries.

This step of the customer inquiry procedure involves receiving inquiry submissions from the public. Inquires may come into the department in person at a Physical Office location, by telephone, letter, via the company inquiry online inquiry form or email address, direct referral from any public office.

Customer inquiries lodged directly with business unit Frontline employees who receive complaints at a point of service should attempt to resolve the matter if it is a simple, informal type of complaint. If the matter cannot be resolved at the point of service, it should be sent to the relevant Quality Assurance Control Officer who will assess the inquiry and lodge it into the registry (or the local record keeping system) if it meets the definition of a customer inquiry or request or refer the matter to another inquiry process if this is more appropriate.

A customer inquiry lodged into the department via the company online complaints form or email address, or by the direct reference from a public office, Quality Assurance Control Office team will assess the submission to identify if it is a customer inquiry, lodged into the company as appropriate, and refer on to the relevant Officer. If the complaint relates to another complaint process, Quality Assurance team will refer it to the business area that manages that process.

Customer complaints received by the Online Support Team or If correspondence received through these areas are identified as customer inquiries, they are to be sent to Assurance Control Office for lodging into the registry, who then allocate to the relevant officer for further action. Identifying the complaint category In the first instance, the Quality Assurance Control office will assess what complaint process is the most appropriate to refer to for action.

STEP 2 : Internal Assessment and Resolution

Step 2 involves the following key participants:

• • Quality Assurance Office
  • Quality Assurance Control Officer
  • Consumer

During this step the Complaint Manager assesses the complexity, severity, safety implications, urgency and if an investigation is required. The expected timeframes for resolving a complaint are determined by this assessment. Refer to the table below for details of timeframes

At the completion of the process undertaken, the Responsible Officer responds to the Consumer. The response is to include review options, and the timeframes involved in these processes.

8. Termination & Suspension

You can delete your account with us at any time via the VeryPay Apps account management screen. Such action will result in the termination of our agreements, as well as the deletion of
your account and the data collected through your use of our Services.

We can decide to suspend your account or restrict your ability to use our Services if we believe that you have used our service for illegal purposes or with stolen payment methods that are not your own or if you are in breach of any terms of this Agreement. If we reasonably suspect this may be the case, you authorize us to share information about you and any transactions conducted through your account with law enforcement authorities if they request it.

9. Changes to the Terms of this Agreement

We’ll let you know about any material changes to the terms of this Agreement. We may update this Agreement from time to time. When we do, we will revise the “last updated” date. If we make changes that we deem material, we will use reasonable efforts to notify (such as by placing a notice in the VeryPay Apps or on www.verypay.ch). We encourage you to periodically check this Agreement for updates.

10. Contact Us

You can contact us with your questions, comments, or concerns. If you have any questions, comments, or concerns regarding our Agreement, please send an email to support@verypay.ch or contact us our registered address Zebra Plaza, Plot 23, Kampala Road of P. O. Box 21975, Uganda.