Cleva Technologies Inc. (“Cleva”, “We”, “Our”) is a technology platform that enables Users to operate a USD wallet, convert and transfer USD to their local currency account, and use a dollar card for online purchases (the "Core Services").

To improve user experience and offer additional value, Cleva has launched a Supplementary Service feature. This new feature provides users with access to various supplementary services, such as purchasing airtime, subscribing to data plans, and paying utility bills, all directly within the Cleva platform.

This Supplementary Service Policy (“Policy”) governs your use of the Cleva Supplementary Service. It sets out the terms, conditions, eligibility criteria, and processes that apply when you access or use any supplementary service through the Cleva platform.

By using the Cleva supplementary service feature, you confirm that you have reviewed this Policy. We encourage you to read it to understand your rights and obligations. By accessing the platform and clicking 'I Agree,' you confirm that you have reviewed this Policy and accept its terms and conditions.

We may update this Policy from time to time to reflect changes in our services, applicable laws, or service provider requirements. When we make material changes, we may notify you through your registered email address or through a notice on the Cleva platform. However, you understand that this may not always be practicable, and when that occurs, you agree to waive your right to notification.

It is your responsibility to review this Policy frequently and to stay informed of all changes that may be made to it. By using our services after a revision to this Policy, you consent to be bound by the changes we made.

The following words shall have the meaning assigned to them in this Policy:

3.1

“AML/CFT/CPF” means anti-money laundering, counter-terrorism financing, counter-proliferation financing, sanctions compliance, and any related financial crime prevention laws, regulations, and regulatory guidance applicable to Cleva or our Service Providers.

3.2

"Aggregator” means a licensed intermediary that connects Cleva to Network Operators and other market players for the delivery of value-added services.

3.3

Business Day means any day other than a Saturday, Sunday, or public holiday in the jurisdiction of our service providers.

3.4

“Cleva" means Cleva Technologies Inc., the technology platform operator providing the digital interface for the Cleva supplementary service feature.

3.5

“Cleva Platform” means the web and/or mobile application operated by Cleva through which Users access the Cleva supplementary service feature.

3.6

“Customer" or “User" means any individual or business entity that has completed Cleva’s onboarding requirements, who operates a Cleva wallet, and is subscribed to the Cleva supplementary service feature.

3.7

"Cleva Account” means the USD-denominated wallet or NGN-denominated wallet made available to Users on the Cleva Platform from which Users may pay for the value-added service.

3.8

“Cleva Points” means loyalty credits earned by Users through eligible activity on the Cleva platform (including use of Cleva Pots), which may be redeemed for supplementary service subject to the Cleva Points Policy.

3.9

“Cleva Supplementary Services” means the list of additional services made available through the Cleva platform beyond our Core Services, including but not limited to airtime purchases, data subscriptions, and utility bill payments.

3.10

“Network Operator” means a licensed telecommunications operator (including MTN, Airtel, Glo, and Ikeja Electric) whose services are made accessible to Users through Value Added Service Providers and the Aggregator.

3.11

“NCC” means the Nigerian Communications Commission, the regulatory body responsible for licensing and overseeing Value Added Service Providers and Network Operators in Nigeria.

3.12

“Value Added Service (VAS) Provider” means any person or organization that engages in the provision of value-added mobile/fixed services, including premium-rated services.

3.13

“OPT-IN” means the process by which a User actively elects to access and use the Cleva supplementary service feature.

3.13

“OPT-IN” means the process by which a User actively elects to access and use the Cleva supplementary service feature.

3.14

“OPT-OUT” means the process by which a User elects to deactivate or discontinue access to the Cleva supplementary service feature

3.15

“Fraudulent Activities” means any actions that violate Cleva’s policies, including but not limited to unauthorized transactions, abuse or misuse of Cleva supplementary service, or any attempts to manipulate this feature for illicit purposes. Fraudulent activities may include any action that involves the exploitation of loopholes within the Cleva platform.

3.16

“Service Providers” means collectively the VAS Aggregator, VAS Provider, and Network Operator engaged by Cleva to facilitate delivery of value-added services to Users.

3.17

“Pin” means the User’s Personal Identification Number used to authenticate and authorise transactions on the Cleva Platform.

• 4.1

  Cleva offers supplementary service through a technology interface available on its Cleva Platform. All supplementary services are provided by Service Providers who possess the necessary licenses from the NCC. We do not approve or process supplementary service requests independently; our role is solely to provide the digital interface that allows Users to initiate and manage their supplementary service transactions.

• 4.2

  The Cleva supplementary service feature enables Users to:

  4.2.1

  Purchase airtime and data subscriptions for any NCC-licensed network operator;

  4.2.2

  Make payments for utility services (e.g., electricity, and any other approved bill categories); and

  4.2.3

  Redeem Cleva Points earned through eligible platform activity toward selected supplementary service purchases.

• 4.3

  Users may fund supplementary service purchases in either of the following ways:

  4.3.1

  Direct debit from their Cleva USD Wallet or Cleva NGN Wallet; or

  4.3.2

  Redemption of accumulated Cleva Points, subject to the Cleva Points Policy.

• 4.4

  All Users who access the VAS feature receive a discount on eligible supplementary service transactions. The applicable discount rate will be disclosed on the transaction summary page before authorisation.

• 5.1

  Users can activate the Cleva supplementary service feature by acknowledging this policy and confirming their agreement within the Cleva platform. By opting in, users authorize Cleva to debit their Cleva Account or deduct Cleva Points for any supplementary service transactions they initiate and approve.

• 5.2

  Once opted in, Users may initiate a supplementary service transaction following this process:

  • 5.2.1

    Select the desired supplementary service category (e.g., airtime, data, bill payment).

  • 5.2.2

    Enter the relevant details, including the beneficiary phone number or account reference.

  • 5.2.3

    For airtime and data purchases, the associated Network Operator is automatically detected; Users may make manual selections.

  • 5.2.4

    Choose the preferred payment method: Cleva NGN Wallet, Cleva USD Wallet, or Cleva Points. Where payment is made in USD, the NGN equivalent and applicable conversion rate are displayed for transparency.

  • 5.2.5

    Review the transaction summary page, which clearly sets out:

    • 5.2.5.1

      the service requested;

    • 5.2.5.2

      the Network Operator;

    • 5.2.5.3

      the service value;

    • 5.2.5.4

      the Cleva discount to be applied;

    • 5.2.5.5

      the amount payable by the User; and

    • 5.2.5.6

      the conversion rate and debited amount (where paying through the Cleva USD Wallet).

  • 5.2.6

    Authorise the transaction by entering the Cleva PIN.

  • 5.2.7

    A success notification is displayed upon fulfilment of the request.

• 5.3

  No payment may be made directly from outside the Cleva platform for any supplementary service request, and no third-party payments on behalf of a User will be accepted.

• 5.4

  Users can opt out of the supplementary service feature at any time by ceasing to make further supplementary service requests.

• 5.5

  We may also deactivate a User's access to the supplementary service feature for reasons set out in this Policy

6.1

All supplementary service transactions may be subject to a discount. We adjust applicable discount rates from time to time based on market conditions, arrangements with our Service Providers, or regulatory requirements.

6.2

Where a User funds a supplementary service transaction through the Cleva USD Wallet, the applicable NGN conversion rate and the exact naira equivalent to be debited are displayed on the transaction summary page before authorisation.

6.3

We apply internal controls and reconciliation processes to all supplementary service transactions. Where a supplementary service request is not fulfilled, We will promptly credit the debited amount back to the User's originating payment method, either the Cleva Account or the Cleva Points balance, within a reasonable time.

6.4

We reserve the right to decline processing a supplementary service request via Cleva Points if the User has violated the Cleva Points Policy or for any other reasonable operational or compliance reason.

7.1

The Cleva Supplementary Service feature is available exclusively to users who have verified and active accounts on the Cleva platform.

7.2

Continued access to this feature is contingent upon compliance with this Policy, Cleva's general Terms of Service, and all applicable laws and regulatory requirements.

7.3

We may suspend, restrict, or revoke access to Cleva Supplementary Service when necessary for operational reasons, regulatory compliance, risk management, fraud prevention, or other compliance-related purposes.

7.4

We reserve the right to amend eligibility criteria, impose restrictions, or suspend access to Cleva Supplementary Service as needed to maintain regulatory compliance, manage risk, protect the platform, and safeguard the interests of users, partners, and other stakeholders.

8.1

The Cleva Supplementary Service feature operates in compliance with the regulatory framework established by the NCC, including the NCC Value Added Service Regulations and any applicable guidelines.

8.2

All supplementary service transactions are subject to Cleva's AML/CFT/CPF compliance obligations.

8.3

We prohibit any acts by Users to use the supplementary service feature to launder money or obscure the source, nature, or purpose of funds

8.4

We may monitor, review, delay, block, or report supplementary service transactions to competent authorities where required by law or regulation. Users must cooperate with any verification or due diligence requests from Cleva in connection with their supplementary service requests.

8.5

In line with our efforts to promote transparency, We ensure Users receive a full summary of the service, pricing, discounts, and applicable exchange rates before any transaction is completed.

9.1

We acknowledge that all technology-based services carry inherent operational and technical risks.

9.2

We are not responsible for interruptions, delays, or failures caused by our Service Providers. Our supplementary service delivery depends on the continued availability and performance of our Service Providers and Network Operators.

9.3

Once a supplementary service transaction is authorised by the User, it may not be possible to reverse it. Users should carefully review the transaction summary before entering their PIN.

9.4

Where a User makes a supplementary service payment from their Cleva USD Wallet, the applicable conversion rate is confirmed at the time of transaction authorisation. We will not be liable for any exchange rate movements occurring after authorisation.

9.5

The quality and continuity of supplementary service are determined by our Service Providers. We have no control over and do not guarantee third-party service quality.

Cleva is committed to safeguarding the personal data of all Cleva supplementary service Users as stated in our Privacy Notice.

11.1

We maintain primary responsibility for handling supplementary service-related complaints, including those that may involve Service Providers.

11.2

All Users have access to fair, transparent, and efficient complaint resolution mechanisms.

11.3

We maintain multiple channels through which customers can submit complaints, including in-app reporting, email, and designated customer support lines.

11.4

We will acknowledge all complaints promptly and ensure the timelines for investigation and resolution are clearly communicated to the customer.

11.5

Where a complaint involves our Service Provider, We will coordinate resolution in accordance with their contractual obligations and applicable regulatory requirements.

11.6

Where a complaint relates to a Network Operator, We will escalate the matter through the Aggregator and keep the User informed of progress.

12.1

We rely on licensed third-party Service Providers, including Aggregators and VAS Providers, to deliver our supplementary services to Users. All Service Providers engaged by Cleva are subject to contractual obligations that include service quality standards, data protection requirements, and compliance with applicable law.

12.2

We may change or add Service Providers from time to time without prior notice to Users, provided that any such change does not materially affect the service delivered to Users.

12.3

We are not responsible for the independent acts or omissions of our Service Providers, except to the extent that such acts or omissions arise from our failure to exercise reasonable oversight.

13.1

Users must comply with all applicable laws and regulations and must not engage in any fraudulent, deceptive, or abusive practices.

13.2

Users must not engage in any fraudulent, deceptive, or abusive conduct in connection with the supplementary service feature.

13.3

We retain transaction records for the periods required by applicable law and will cooperate with law enforcement or regulatory investigations as required.

14.1

Cleva is not an agent, partner, or representative of any Network Operator. Cleva accesses network services exclusively through our licensed Aggregator and does not assume liability for any default, outage, or service failure attributable to a Network Operator. We remain responsible for billing, revenue collection, and the settlement of applicable amounts to our Service Providers.

14.2

We will not be liable for any damages, losses, or expenses arising out of or related to the Cleva supplementary service, including but not limited to the inability to access value-added services or any technical issues related to the Cleva supplementary service feature

This policy shall be governed and construed in accordance with the laws of the State of Delaware, United States.

If you have any questions, requests, or concerns regarding this Policy, please contact us atcontact@getcleva.com.