Acceptable Use Policy

1.1 Purpose: This Acceptable Use Policy (“AUP”) defines the conduct expected of every user of the Pairgate Platform and the activities that are strictly prohibited. It exists to protect our users, our partners, our Platform, and the integrity of Nigeria’s financial and telecommunications ecosystem.

1.2 Scope: This AUP applies to all users, resellers, sub-agents, API partners, and any person accessing the Platform, whether directly or indirectly.

1.3 Incorporation: This AUP is incorporated into and forms part of our Terms and Conditions. Capitalized terms not defined here carry the meanings assigned in the Terms.

1.4 Governing Law: This AUP is governed by the laws of the Federal Republic of Nigeria, including but not limited to the Cybercrimes Act 2015 (as amended), the Money Laundering (Prevention and Prohibition) Act 2022, and the Nigeria Data Protection Act 2023.

When using the Platform, you agree to:

• Provide accurate and truthful information at all times.
• Use the Platform only for lawful purposes.
• Respect the rights of other users, partners, and third parties.
• Comply with all applicable laws, regulations, and network provider rules.
• Cooperate with identity verification (KYC), source-of-funds checks, and reasonable investigations.
• Report any security vulnerability responsibly to [email protected].

You must not use the Platform to:

• Engage in any unlawful, fraudulent, or deceptive activity.
• Purchase or resell Virtual Top-Up Services using stolen, unauthorised, or fraudulent payment instruments.
• Fund betting wallets, airtime, data, or utilities with proceeds of crime.
• Launder money, finance terrorism, or evade sanctions.
• Bypass, disable, or interfere with Platform security or access controls.
• Use bots, scrapers, automated scripts, or unauthorized APIs.
• Violate any network, cable, utility, exam body, or betting platform terms.
• Misrepresent your identity, impersonate others, or create fake accounts.
• Distribute malware, phishing links, or harmful code.
• Harass, threaten, or abuse Pairgate staff, partners, or other users.
• Engage in any activity that damages the reputation, systems, or partners of Pairgate.

4.1 AML/CFT Compliance: Pairgate complies with the Money Laundering (Prevention and Prohibition) Act 2022, CBN AML/CFT Regulations, NFIU guidelines, and applicable sanctions regimes. We may monitor, screen, and report transactions as required by law.

4.2 KYC Requirements: You agree to complete identity verification (BVN, NIN, government ID, proof of address, selfie) when requested. Failure to comply may result in suspension, restriction, or termination.

4.3 Source of Funds: We may request documentation explaining the source of funds for any deposit or transaction.

4.4 Suspicious Activity: We may freeze or restrict your wallet and report to the NFIU or other competent authorities without prior notice where required by law.

4.5 Sanctions Screening: Users, transactions, and counterparties may be screened against Nigerian, UN, OFAC, EU, and UK sanctions lists. Accounts matching sanctions lists will be blocked.

4.6 Prohibited Sources: You must not fund your wallet with proceeds from theft, fraud, drug trafficking, terrorism, human trafficking, ransomware, or any other criminal activity.

You must not engage in:

• SIM-swap fraud: Using compromised or fraudulently obtained SIM cards.
• Account takeover: Accessing another person’s account without authorisation.
• Identity theft: Using another person’s identity, BVN, NIN, or credentials.
• Card fraud: Using stolen or unauthorised debit/credit cards.
• Chargeback fraud: Initiating chargebacks for delivered value.
• Refund abuse: Repeatedly claiming refunds for successful transactions.
• Phishing or social engineering: Deceiving users to obtain credentials or funds.
• BIN attacks or card testing: Attempting to validate stolen card numbers.
• Money mule activity: Allowing your account to be used to move illicit funds.

5.1 Cybercrimes Act: Violations may constitute offences under the Cybercrimes Act 2015 (as amended) and will be reported to the Nigeria Police Force – National Cybercrime Centre (NPF-NCCC) and other relevant authorities.

6.1 Age Restriction: You must be at least 18 years old to fund any betting wallet through the Platform. By funding a betting wallet, you represent that you meet this requirement and that betting is lawful in your jurisdiction.

6.2 Prohibited Conduct: You must not:

• Fund betting wallets on behalf of minors.
• Use the Platform to facilitate unlicensed betting operations.
• Use stolen or fraudulent funds to fund betting wallets.
• Engage in match-fixing, arbitrage abuse, or any activity prohibited by the betting operator.

6.3 Verification: We may request proof of age and may decline or reverse any betting wallet funding that violates this clause.

Resellers and API partners are subject to the additional rules in our Reseller & API Terms, and must additionally:

• Not use the API for unauthorized automation, scraping, or arbitrage.
• Not resell services at prices that misrepresent our brand or violate provider terms.
• Not use the Platform to operate an unlicensed money transmission or payment service.
• Protect API keys and report compromise immediately.
• Not offer Pairgate services to prohibited jurisdictions or sanctioned parties.

You must not:

• Share your account credentials with third parties.
• Operate multiple accounts to circumvent limits, promotions, or restrictions.
• Sell, transfer, or rent your account.
• Use another person’s account without authorisation.
• Create accounts with false or misleading information.
• Attempt to circumvent KYC, AML, or fraud controls.

If you become aware of any violation of this AUP, please report it promptly to [email protected]. Reports will be treated confidentially. We may offer rewards for information leading to the prevention of significant fraud, at our discretion.

10.1 Investigation: We reserve the right to investigate any suspected violation of this AUP, including reviewing transaction records, access logs, and communications.

10.2 Suspension and Termination: We may suspend, restrict, or terminate your account, with or without notice, if we reasonably believe you have violated this AUP.

10.3 Freezing of Funds: Where required by law or during investigation of fraud or AML concern, we may freeze wallet balances and transaction value.

10.4 Reporting to Authorities: We cooperate fully with law enforcement, the CBN, the NFIU, the NDPC, the NPF-NCCC, and other competent authorities. We may report suspected criminal activity without prior notice.

10.5 Legal Action: We may pursue civil or criminal remedies, including recovery of losses, legal fees, and damages.

10.6 No Liability: Pairgate shall not be liable to you for any loss arising from enforcement action taken in good faith under this AUP.

Pairgate Venture (RC: 3687598)
Email: [email protected]
Compliance: [email protected]
Website: https://pairgate.com