● Legal Document

ACCEPTABLE
USE POLICY

Effective Date: 26 June 2026
Operated by: EscrowLink Technologies Limited
RC: 9473181
01

About this Policy

This Acceptable Use Policy explains what users may and may not do when using the EscrowPay platform (the "Platform"), which is operated by EscrowLink Technologies Limited ("EscrowPay", "we", "us" or "our").

This Policy forms part of the EscrowPay legal framework and should be read together with the Terms of Service, the Escrow Agreement, the Privacy Policy, and the Cookie Policy.

By using the Platform, you agree to comply with this Policy.

02

Scope of Application

This Policy applies to all users of the Platform, including buyers and sellers.

This Policy applies to all transactions facilitated through EscrowPay, including those initiated via WhatsApp or any supported channel.

03

Permitted Use

The Platform may be used for lawful commercial transactions involving consumer goods, professional services, and business services, or such other lawful transactions as may be permitted by EscrowPay from time to time.

3.2 Sellers must ensure that:

  • The goods or services offered are legal under Nigerian law
  • The goods or services match the description provided to the buyer
  • They have the legal right to sell the goods or provide the services

3.3 Buyers must ensure that:

  • They are purchasing goods or services for lawful purposes
  • They do not use the Platform to facilitate fraudulent and illegal activity

3.4 Identity Verification as a Condition of Use

NIN Verification RequiredMandatory

Access to and use of the Platform is conditional upon the successful completion of identity verification. All users, whether acting as buyers or sellers, are required to verify their identity by way of National Identification Number ("NIN") authentication in conjunction with date of birth confirmation prior to initiating or participating in any transaction.

No user may create a transaction, make a payment, or receive a payout through the Platform without having first successfully completed NIN verification. EscrowPay reserves the right to refuse, suspend, or cancel access to the Platform for any user who fails to complete or maintain satisfactory verification.

04

Prohibited Use

You must not use EscrowPay for any unlawful, fraudulent, or harmful activity. Without limitation, the following are strictly prohibited:

  • Illegal goods or services under Nigerian law
  • Weapons, firearms, explosives, or related accessories
  • Controlled substances, narcotics, or drugs
  • Stolen goods or property obtained unlawfully
  • Counterfeit or fake goods
  • Adult content, pornography, or sexually explicit material
  • Gambling services, betting schemes, or lottery services not authorised by law
  • Pyramid schemes, Ponzi schemes, or similar financial schemes
  • Any activity involving fraud, deception, or misrepresentation
  • Cryptocurrency or digital asset transactions
  • Unofficial foreign exchange or parallel market currency transactions
  • Unlicensed or unregulated financial services, including lending, investment schemes, or deposit-taking activities
  • Political donations, campaign financing, or electioneering expenditure
  • Goods or services subject to import prohibition or restriction under applicable Nigerian law or regulation
Discretion
EscrowPay reserves the right to determine, at its sole discretion, whether a transaction or activity is prohibited.
05

Seller Responsibilities

By creating a transaction on EscrowPay, the seller represents and warrants that:

  • The goods or services are lawful
  • The goods or services are accurately described
  • The seller has the right to sell the goods or provide the services

5.2 Sellers must not:

  • Misrepresent the condition, authenticity, or quality of goods
  • List or transact in prohibited items
  • Use the Platform to deceive or defraud buyers
06

Buyer Responsibilities

Buyers must not use the Platform to:

  • Engage in fraudulent activity
  • Make payments for prohibited goods or services
  • Abuse the dispute process

6.1.1 Dispute Process Abuse

Dispute process abuse means any use of the dispute resolution process in bad faith or for improper purposes, and includes but is not limited to:

  • Raising a dispute without reasonable grounds or any supporting evidence
  • Raising a dispute after confirmation of receipt of goods or services through the Platform
  • Using the dispute process as a means to renegotiate agreed price, scope, or delivery terms after payment has been made
  • Providing false, misleading, or fabricated information, evidence, or documentation in connection with a dispute
  • Repeatedly raising disputes in a manner that indicates a pattern of abusive or fraudulent conduct
  • Any other conduct which EscrowPay reasonably determines to constitute misuse of the dispute resolution process

Buyers are responsible for ensuring that the transaction they enter into is lawful.

6.3 Collection by Buyer's Representative

Where a buyer arranges for a representative, rider, or agent to collect an item directly from the seller, the buyer accepts full responsibility for the item from the point of handover by the seller to the buyer's representative. The buyer shall not raise a dispute on grounds of non-delivery or damage where such loss or damage occurred after the seller handed the item to the buyer's representative.
07

Monitoring & Enforcement

EscrowPay may monitor transactions and activity on the Platform to ensure compliance with this Policy.

Where EscrowPay reasonably suspects or determines that a User has breached this Policy, EscrowPay may take any one or more of the following actions:

  • Cancel or reverse any transaction
  • Freeze, hold, or withhold Escrowed Funds pending investigation or resolution
  • Suspend or restrict access to the Platform (temporarily or indefinitely)
  • Terminate the User's account and permanently ban access to the Platform
  • Report the User's conduct to relevant law enforcement or regulatory authorities where required or permitted by law
  • Blacklist the User's National Identification Number (NIN), thereby preventing the User from creating or maintaining any account on the Platform using the same NIN, regardless of the telephone number or other registration details used
No prior notice required
EscrowPay is not required to provide prior notice before taking enforcement action where it reasonably believes a breach has occurred.
08

Reporting & Regulatory Obligations

EscrowPay may report suspected or confirmed illegal activity to relevant Nigerian authorities, including but not limited to:

  • Economic and Financial Crimes Commission (EFCC)
  • Nigerian Financial Intelligence Unit (NFIU)
  • Central Bank of Nigeria (CBN)

EscrowPay may cooperate with law enforcement agencies in connection with investigations involving the Platform.

09

Limitations

EscrowPay does not guarantee the legality, quality, or authenticity of any goods or services transacted through the Platform.

EscrowPay is not responsible for user conduct but reserves the right to take action where this Policy is breached.

10

Changes to this Policy

Material updates to this Policy will be communicated to Users via the Platform, WhatsApp, or email at least seven (7) days prior to the effective date of such changes, in addition to publication on the Platform.

Non-material updates (including clarifications, typographical corrections, or updates that do not materially affect Users' rights or obligations) may be published on the Platform with a revised effective date without prior notification.

Continued use of the Platform after the effective date of any updated Policy constitutes acceptance of the updated Policy.

11

Contact Information

If you have any questions about this Acceptable Use Policy, please contact:

General Enquiries
legal@escrowpay.app
12

Related Documents

This Acceptable Use Policy shall be read together with the following EscrowPay Platform Policies. In the event of any inconsistency, the Terms of Service shall prevail except where this Policy specifically governs prohibited activities, user conduct, or enforcement action.