privacy

LibertyPay Terms and Conditions

The following Terms and Conditions govern your access to and use of the LibertyPay mobile application, website, Point of Sale (POS) terminals, agent platform, lending services, gaming services, and other related financial solutions operated by LibertyPay.

By downloading the LibertyPay Mobile Application, visiting the LibertyPay website, using a LibertyPay POS terminal, registering as a LibertyPay Agent, or accessing any LibertyPay services, you (“User”, “Agent”, “Loan Officer”, or “Representative”) agree to be bound by these Terms and Conditions.

If you do not agree with any part of these terms, you must discontinue use of the LibertyPay platform and services immediately

Services Available on LibertyPay

LibertyPay provides access to financial, lending, payment, and gaming-related services including but not limited to:

• Cash-In and Cash-Out services (Money Transfer and Withdrawal)
• Cardless Withdrawals
• Card Transfers
• Account Top-Up Services
• Bills and Utility Payments including:
  • GOtv
  • DStv
  • Electricity Bills
  • Cable TV
  • Betting Wallet Funding
  • Other bill payment services
• Airtime Recharge, Recharge Pins, and Data Subscription Services
• Agent and Customer Loan Services
• Lottery and Gaming Services operated through authorized agents
• Other financial or value-added services that may be introduced by LibertyPay from time to time

Eligibility Requirements

To operate as a LibertyPay Agent or Representative, the following conditions must be met:

• Applicants must be at least 18 years old. Any use of LibertyPay services by persons below the age of 18 is unauthorized and prohibited.
• Agents must operate from a secure and suitable physical business location conducive for conducting financial transactions.
• Agents must possess a compatible internet-enabled device capable of supporting LibertyPay services.
• Agents must maintain a minimum working capital of ₦100,000 or such amount as may be required by LibertyPay from time to time.
• Agents are expected to maintain operational activity levels, including minimum transaction count requirements as determined by LibertyPay.
• Agents must not have any criminal record involving:
  • Financial fraud
  • Money laundering
  • Identity theft
  • Cybercrime
  • Terrorism financing
  • Any related financial or criminal offense
• LibertyPay reserves the right to approve, reject, suspend, or terminate any application or account at its sole discretion where compliance requirements are not met.

Agent Obligations

All LibertyPay agents, representatives, and loan officers agree to:

• Operate in compliance with all applicable laws, regulations, and LibertyPay operational policies.
• Conduct transactions honestly, transparently, and professionally.
• Protect customer information and maintain confidentiality of all sensitive data obtained during service delivery.
• Refrain from engaging in:
  • Fraudulent activities
  • Suspicious transactions
  • Money laundering
  • Identity theft
  • Unauthorized charges
  • Gaming manipulation
  • Illegal lending practices
• Promptly report suspicious activities, security incidents, or fraudulent transactions to LibertyPay.
• Maintain accurate records of transactions conducted through the LibertyPay platform where required.
• Ensure that customers are properly informed before conducting transactions or financial services.

Lending Services

LibertyPay provides lending-related operational services through authorized loan officers and representatives.

The lending operations available through the LibertyPay platform are managed under Liberty Assured Limited, a sister company responsible for loan processing, borrower management, collections, and related lending activities in compliance with applicable financial and lending regulations.

The lending component of the LibertyPay platform is intended strictly for operational use by authorized personnel for activities including:

• Loan origination
• Borrower verification
• Loan processing
• Loan disbursement
• Loan repayment monitoring
• Loan recovery and collections
• Compliance and fraud prevention

Borrowers do not directly access or operate the LibertyPay application.

Borrower Data Collection & Protection

LibertyPay and Liberty Assured Limited may collect and process borrower information through authorized agents and loan officers, including but not limited to:

• Full name
• Phone number
• Residential address
• Means of identification
• Employment or business information
• Bank account details
• Transaction records
• Geolocation information where legally required

All personal data is processed in accordance with:

• Nigeria Data Protection Act (NDPA)
• Central Bank of Nigeria (CBN) guidelines
• Anti-Money Laundering (AML) regulations
• Know Your Customer (KYC) obligations
• Applicable consumer protection laws

LibertyPay implements reasonable administrative, technical, and physical safeguards to protect customer and borrower information from unauthorized access, disclosure, misuse, alteration, or destruction.

Loan officers and agents are responsible for ensuring that borrowers provide valid consent before personal information is collected or processed through the LibertyPay platform.

Location Access & Background Location Usage

LibertyPay utilizes location services for operational monitoring, fraud prevention, compliance, agent accountability, and borrower address verification.

Authorized agents, loan officers, and representatives using the LibertyPay application may be required to grant location access permissions, including background location access where necessary for operational purposes.

Location data may be used for:

• Verifying agent operating locations
• Borrower address verification
• Loan recovery coordination
• Fraud detection and prevention
• Operational monitoring
• Security and compliance purposes

By using LibertyPay services, agents and representatives consent to the collection and processing of location data as permitted by applicable law.

LibertyPay does not sell location data or personal information to unauthorized third parties.

Lottery & Gaming Services

LibertyPay also operates licensed lottery and gaming services through authorized agents in compliance with applicable gaming laws and regulations within Nigeria.

The lottery and gaming operations available through the LibertyPay platform are operated and licensed under Whispa Konnect Limited, a sister company authorized to provide gaming-related services in accordance with applicable Nigerian laws and regulatory requirements.

Lottery and gaming transactions are facilitated by verified LibertyPay agents on behalf of customers at approved physical locations.

Customers do not directly operate the gaming systems within the LibertyPay application.

Responsible Gaming

LibertyPay and Whispa Konnect Limited promote responsible gaming practices.

• Participation in gaming activities is strictly restricted to persons aged 18 years and above.
• Agents are responsible for verifying player eligibility before facilitating gaming transactions.
• LibertyPay reserves the right to suspend or terminate gaming access where suspicious, unlawful, abusive, or fraudulent activities are detected.
• LibertyPay shall not be responsible for losses arising from gaming participation except as required under applicable law.
• All gaming activities conducted through the LibertyPay platform are subject to the terms, policies, and regulatory obligations applicable to Whispa Konnect Limited.

Compliance with Laws and Regulations

LibertyPay complies with all applicable laws and regulations governing:

• Financial services
• Agency banking
• Digital payments
• Lending operations
• Gaming and lottery services
• Data protection and privacy
• Anti-money laundering and counter-terrorism financing obligations

LibertyPay reserves the right to monitor accounts, transactions, device usage, and operational activities to ensure compliance with regulatory obligations and internal security policies.

Privacy & Data Usage

By using LibertyPay services, users, agents, and representatives consent to the collection and processing of operational and technical data necessary for:

• Transaction processing
• Service delivery
• Compliance monitoring
• Fraud prevention
• Customer support
• Security enhancement
• Operational analytics
• Regulatory reporting

Such information may include:

• Device information
• IP address
• Transaction logs
• Activity records
• Geolocation data
• Application usage data

LibertyPay does not sell personal information to unauthorized third parties.

Information may only be disclosed:

• Where required by law
• To regulatory authorities
• For fraud prevention purposes
• For dispute resolution
• For legitimate operational requirements

Suspension & Termination

LibertyPay reserves the right to suspend, restrict, or terminate access to its services where any user, agent, or representative:

• Violates these Terms and Conditions
• Provides false information
• Engages in fraudulent or suspicious activities
• Breaches regulatory obligations
• Misuses the platform
• Violates gaming or lending regulations

Limitation of Liability

LibertyPay shall not be liable for any indirect, incidental, consequential, or special damages arising from:

• Service interruptions
• Network failures
• Delayed transactions
• Unauthorized access caused by user negligence
• Gaming losses
• Regulatory actions outside LibertyPay’s control

Users and agents are responsible for maintaining the confidentiality and security of their login credentials and devices.

Amendments

LibertyPay reserves the right to update, modify, or amend these Terms and Conditions at any time without prior notice.

Continued use of LibertyPay services after any updates constitutes acceptance of the revised Terms and Conditions.

Contact Information

For inquiries, complaints, privacy concerns, or regulatory issues, please contact:

LibertyPay Customer Support Team

Email: support@libertypay.ng