1. Introduction & Legal Status
Welcome to PlutoPay. PlutoPay is a financial technology platform developed and operated by Pluto Technology Solutions Limited. By accessing our platform, you agree to these terms.
IMPORTANT NOTICE: PlutoPay is a Technology Service Provider, not a Bank, Discount House, or Financial Institution.
We provide a user interface to access services offered by our licensed partners.
2. Banking & Fiat Services
All fiat currency wallet services (Naira, USD, GBP, etc.) are provided by our licensed banking partners:
- Paystack - Payment processing and virtual accounts
- Flutterwave - Payment processing and currency conversion
- Monnify - Virtual account management
- Partner Commercial Banks - Fund custody (including Wema Bank, Wema Bank)
PlutoPay does not directly hold customer deposits. All fiat funds are held by our licensed banking partners in segregated accounts.
3. PlutoPay Balance
PlutoPay Balance is a proprietary Digital Store of Value within the PlutoPay ecosystem for internal use only. PlutoPay Balance is:
- Not a national currency, legal tender, or stablecoin.
- An internal digital currency for fast, fee-efficient transfers between PlutoPay users only.
- Convertible to supported fiat currencies (NGN, USD, GBP, EUR, etc.) and cryptocurrencies (BTC, ETH, USDT, etc.) at prevailing market rates determined by PlutoPay's liquidity partners.
- NOT backed 1:1 by USD or any other fiat currency in any bank account.
IMPORTANT DISCLOSURE: PlutoPay Balance is an internal accounting unit, not a reserve-backed asset.
The value of PlutoPay Balance when converted to external currencies (fiat or crypto) is determined by the exchange rates
provided by PlutoPay's third-party liquidity partners (Paystack, Flutterwave, etc.) at the time of conversion.
PlutoPay Balance cannot be redeemed directly for USD or any other fiat currency at a fixed 1:1 rate.
Users acknowledge that PlutoPay Balance is designed for internal platform utility only.
4. Cryptocurrency Services
Crypto trading, custody, and transfer services are facilitated through our licensed Virtual Asset Service Provider (VASP) partners:
- Quidax - SEC-licensed Nigerian crypto exchange
PlutoPay does not act as the custodian of your private keys. Crypto assets are held by our licensed VASP partners. You acknowledge that PlutoPay is not liable for losses due to blockchain network failures, market volatility, or third-party VASP failures.
5. AI Assistant & Financial Advice
The PlutoPay AI Assistant is an informational tool. Responses generated by the AI regarding market trends, spending analysis, or budgeting are for informational purposes only and do not constitute professional financial advice. Always verify transaction details before confirming.
6. Bill Payments (VTU)
Bill payments (Airtime, Data, Electricity, TV) are processed via third-party aggregators (VTPass, Shago, etc.). PlutoPay is not responsible for service interruptions caused by the utility provider or network operator.
7. Anti-Money Laundering (AML) & KYC
We comply with strict AML laws. You agree to provide accurate identification (NIN, Face ID etc.) as required. We reserve the right to freeze accounts showing suspicious activity pending investigation.
8. AI Fraud Detection & Account Freezing
We utilize an automated AI Fraud Detection System to monitor transactions in real-time.
- Automated Actions: Our system may automatically flag or freeze transactions that appear suspicious (e.g., unusual high value, rapid velocity, new device).
- Right to Freeze: We reserve the right to temporarily restrict access to your account pending manual review if the AI detects security threats.
- False Positives: While we strive for accuracy, you acknowledge that automated security checks may occasionally cause delays.
9. Blockchain Staking & Yield
When you use the "Staking" feature, you are interacting directly with third-party blockchain validators (e.g., Lido, On-Chain Protocols) via our interface.
- Not a Bank Deposit: Staking rewards are generated by the blockchain network, not paid by PlutoPay as interest.
- Lock-up Periods: Funds staked may be locked by the blockchain protocol for a specific period (e.g., 30 days). PlutoPay cannot forcefully unlock these funds before the protocol allows.
- Risks: You acknowledge the risk of "Slashing" (validator penalties) inherent in blockchain proof-of-stake mechanisms.
10. Virtual Card Services & Issuance
PlutoPay offers virtual debit cards ("Virtual Cards") denominated in various currencies (including but not limited to NGN, USD, GBP, and EUR) to eligible, fully KYC-verified Premium users.
- Third-Party Issuers: PlutoPay is a technology platform. Virtual Cards are issued by our licensed acquiring bank partners and regulated card networks (such as Visa® and Mastercard®) via third-party API providers (e.g., Stripe, Flutterwave, Bridgecard). By creating a Virtual Card, you also agree to the respective terms and conditions of our issuing partners.
- Prepaid Nature: Virtual Cards are strictly prepaid debit instruments. They are not credit cards. You can only spend up to the available balance specifically funded to the card. Overdrawing the card is prohibited and may result in immediate account suspension.
- Address Verification System (AVS): For international online purchases, merchants may require a valid Billing Address. You are solely responsible for providing an accurate home/billing address during card creation. PlutoPay is not liable for transactions declined by external merchants due to AVS mismatches or merchant-specific geographic restrictions.
- Fees and Foreign Exchange: Card creation, monthly maintenance, and transaction fees apply as outlined in the PlutoPay Fee Schedule. If a transaction is made in a currency different from the card's native currency, the network (Visa/Mastercard) will apply their foreign exchange conversion rate, plus any applicable PlutoPay foreign transaction markup fees.
- Disputes and Chargebacks: PlutoPay provides the interface for card management. However, any disputes regarding goods or services purchased must be resolved directly with the merchant. While PlutoPay will assist in submitting legitimate chargeback requests to the issuing network, we do not guarantee the recovery of funds and are not liable for merchant fraud.
- Right to Freeze: PlutoPay reserves the right to instantly freeze, suspend, or permanently terminate any Virtual Card without prior notice if we detect suspicious, fraudulent, or illegal activity, or if the user fails to maintain sufficient funds in their primary wallet to cover monthly maintenance fees.
11. User Responsibility
You are responsible for keeping your PIN, Password, and Biometric access secure. PlutoPay will never ask for your PIN. Transactions confirmed with your PIN are final and non-reversible.
12. Governing Law & Jurisdiction
These Terms shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, without regard to its conflict of law principles. Any disputes arising from or relating to these Terms shall be subject to the exclusive jurisdiction of the competent courts of Nigeria, unless otherwise required by applicable law.
13. Limitation of Liability
To the maximum extent permitted by law, PlutoPay, its directors, officers, employees, partners, and affiliates shall not be liable for any indirect, incidental, consequential, special, or punitive damages, including but not limited to loss of profits, loss of data, loss of goodwill, or service interruption, arising out of or related to your use of the platform, even if PlutoPay has been advised of the possibility of such damages.
PlutoPay's total liability for any claim shall not exceed the total fees paid by you to PlutoPay in the twelve (12) months preceding the event giving rise to the claim.
14. User Indemnification
You agree to indemnify, defend, and hold harmless PlutoPay, its affiliates, officers, directors, employees, and partners from and against any claims, damages, liabilities, losses, costs, or expenses (including reasonable legal fees) arising from:
- Your misuse of the platform
- Violation of these Terms
- Breach of applicable laws or regulations
- Fraudulent or unauthorized activities conducted through your account
15. Account Suspension & Termination
PlutoPay reserves the right to suspend or permanently terminate your account without prior notice if:
- You violate these Terms
- You engage in fraudulent, illegal, or abusive activities
- Required KYC/AML verification cannot be completed
- Regulatory or legal obligations require account restriction
Upon termination, access to the platform will be revoked, subject to applicable laws governing fund withdrawals and compliance holds.
16. Service Availability & Downtime
PlutoPay does not guarantee uninterrupted or error-free operation of the platform. Services may be temporarily unavailable due to system maintenance, upgrades, network failures, third-party service outages, or events beyond our reasonable control (force majeure).
PlutoPay shall not be liable for losses arising from such service interruptions.
17. Amendments to Terms
PlutoPay reserves the right to modify or update these Terms at any time. Material changes will be communicated through the platform or other appropriate channels. Continued use of the platform after such changes constitutes acceptance of the revised Terms.
18. Severability
If any provision of these Terms is found to be unlawful, void, or unenforceable, such provision shall be severed, and the remaining provisions shall remain valid and enforceable.
19. Entire Agreement
These Terms constitute the entire agreement between you and PlutoPay regarding the use of the platform and supersede any prior agreements or understandings, whether written or oral.
20. No Stablecoin or Reserve Claims
PlutoPay does not issue stablecoins. PlutoPay Balance is a proprietary internal digital token with no claim to any specific fiat currency reserve. For the avoidance of doubt:
- 1 unit of PlutoPay Balance does NOT equal 1 USD or any other fiat currency held in any bank account.
- PlutoPay Balance cannot be redeemed directly for USD, NGN, EUR, GBP, or any other fiat currency at a fixed rate.
- PlutoPay Balance can be converted to supported fiat currencies or cryptocurrencies at variable market rates determined by PlutoPay's third-party liquidity partners at the time of conversion.
- Any references in marketing materials to "pegged," "backed," "stable," or similar terms are aspirational or refer to conversion rates available at the time of transaction, not to actual reserves held in custody.
- PlutoPay reserves the right to modify, suspend, or discontinue the PlutoPay Balance feature at any time without prior notice.
Users acknowledge that they have read and understood this disclosure before using any PlutoPay Balance-related features on the PlutoPay platform.
21. Privacy Policy
This Privacy Policy explains how PlutoPay collects, uses, discloses, and protects your personal information when you use our platform.
21.1 Information We Collect
- Personal Information: Full name, phone number, email address, date of birth, government-issued ID (NIN, BVN, Passport, Driver's License), and residential address.
- Financial Information: Bank account details, transaction history, wallet balances, and payment card information (where applicable).
- Technical Information: IP address, device information, browser type, operating system, and usage logs.
- Biometric Information: Facial recognition data and fingerprint data (stored locally on your device, not on our servers).
- Communication Data: Chat logs with our AI assistant, support ticket history, and voice/image files you upload.
21.2 How We Use Your Information
- To verify your identity and comply with KYC/AML regulations
- To process transactions and maintain your account
- To improve our AI assistant and personalize your experience
- To detect and prevent fraud, money laundering, and other illegal activities
- To communicate important updates, security alerts, and transaction confirmations
- To comply with legal and regulatory obligations
21.3 Information Sharing
We do not sell your personal information. We share your information only with:
- Licensed Banking Partners: Paystack, Flutterwave, Monnify, and other financial institutions to process your transactions.
- Crypto Service Providers: Quidax to facilitate crypto trades and staking.
- Regulatory Authorities: When required by law, court order, or government request.
- Service Providers: Cloud hosting (Render), database (PostgreSQL), email services, and fraud detection tools.
- KYC Verification Providers: Didit, Sumsub, Veriff, Persona, Google Cloud Vision, and Microsoft Azure Face API to verify your identity, detect liveness, and prevent fraud.
21.4 Data Retention
We retain your personal information for as long as your account is active and for a minimum of five (5) years after account closure to comply with AML/KYC record-keeping requirements under Nigerian law and international financial regulations.
21.5 Your Rights
Under the Nigeria Data Protection Act (NDPA) and applicable laws, you have the right to:
- Access the personal information we hold about you
- Request correction of inaccurate information
- Request deletion of your information (subject to legal retention requirements)
- Object to processing of your information
- Data portability (receive your data in a structured format)
To exercise these rights, contact us at privacy@plutopay.com.
21.6 Data Security
We implement industry-standard security measures including:
- End-to-end encryption for all sensitive data
- Hashed and salted passwords and PINs (SHA-256)
- Regular security audits and penetration testing
- Multi-factor authentication options
- Automated fraud detection systems
However, no method of transmission over the Internet is 100% secure. You use PlutoPay at your own risk.
21.7 Children's Privacy
PlutoPay is not intended for persons under 18 years of age. We do not knowingly collect information from minors. If we discover we have collected information from a minor, we will delete it immediately.
21.8 International Data Transfers
Your information may be transferred to and processed in countries outside Nigeria where our service providers operate. We ensure appropriate safeguards are in place for such transfers.
21.9 Updates to This Policy
We may update this Privacy Policy from time to time. Material changes will be notified via email or platform notification. Continued use of PlutoPay after changes constitutes acceptance.
21.10 Contact Us
For privacy-related questions or concerns:
22. Risk Disclosure Statement
⚠️ IMPORTANT WARNING: Using PlutoPay involves significant financial risks. You should not use this platform with money you cannot afford to lose. Read this entire disclosure carefully before using any PlutoPay service.
22.1 General Risks
- Loss of Funds: Transactions on PlutoPay are irreversible. If you send funds to the wrong recipient, we cannot recover them.
- Account Security: If your PIN, password, or biometric credentials are compromised, you may lose all funds in your account. PlutoPay is not liable for unauthorized access due to your negligence.
- Technical Failures: Platform downtime, bugs, or cyberattacks may temporarily or permanently affect your ability to access your funds.
- Regulatory Changes: Laws governing crypto, virtual cards, and digital payments may change unexpectedly, potentially affecting your ability to use certain features.
22.2 Cryptocurrency Risks
- Extreme Volatility: Cryptocurrency prices can fluctuate dramatically within minutes. You may lose a significant portion of your investment.
- Blockchain Risks: Network congestion, forks, or validator failures may delay or prevent transactions from completing.
- Staking Risks ("Slashing"): When you stake crypto, blockchain validators may be penalized ("slashed") for protocol violations, resulting in permanent loss of staked funds. PlutoPay is not responsible for slashing penalties imposed by blockchain networks.
- Regulatory Bans: Some countries may ban or restrict cryptocurrency ownership or trading. You are responsible for complying with your local laws.
- Irreversible Transactions: Crypto transactions cannot be reversed or cancelled once broadcast to the blockchain.
22.3 PlutoPay Balance Risks
- Not a Stablecoin: PlutoPay Balance is NOT a stablecoin. It is an internal digital token with no backing by USD or any other fiat currency.
- Value Fluctuation: The value of PlutoPay Balance when converted to external currencies depends on market rates determined by third-party liquidity providers.
- Platform Dependency: PlutoPay Balance has no value outside the PlutoPay ecosystem. If PlutoPay ceases operations, PlutoPay Balance may become worthless.
- No Redemption Guarantee: PlutoPay does not guarantee the ability to convert PlutoPay Balance to fiat currency at any specific rate or at all.
22.4 Virtual Card Risks
- Merchant Disputes: If a merchant fails to deliver goods or services purchased with your virtual card, PlutoPay cannot guarantee a refund. You must resolve disputes directly with the merchant.
- Foreign Exchange Fees: Transactions in currencies different from your card's native currency may incur significant conversion fees charged by the card network (Visa/Mastercard).
- Merchant Declines: Some merchants may decline virtual cards or prepaid cards. PlutoPay has no control over merchant acceptance policies.
- Card Freezing: If you fail to pay monthly maintenance fees, your card may be frozen or closed, potentially affecting pending transactions.
22.5 AI Assistant Risks
- Not Financial Advice: The PlutoPay AI Assistant is for informational purposes only. It does not provide professional financial, investment, or legal advice.
- Possible Errors: AI may misinterpret your requests, suggest incorrect actions, or provide inaccurate information. Always verify transaction details manually before confirming.
- No Liability: PlutoPay is not liable for any losses resulting from reliance on AI-generated suggestions or automated transactions triggered by AI.
22.6 Third-Party Risks
- Banking Partners: Paystack, Flutterwave, Monnify, and other banking partners may experience outages, freeze accounts, or change terms without notice.
- Crypto Partners: Quidax may suspend services, experience hacks, or face regulatory actions affecting your crypto assets.
- Card Issuers: Stripe, Marqeta, or other card issuers may decline transactions, freeze cards, or change fee structures.
- No Recourse: PlutoPay is not responsible for losses caused by third-party service providers.
22.7 Acknowledgement
By using PlutoPay, you acknowledge and agree that:
- You have read, understood, and accepted all risks described in this disclosure.
- You are solely responsible for all financial losses incurred while using PlutoPay.
- PlutoPay, its founders, employees, and partners are not liable for any losses arising from your use of the platform.
- You will not hold PlutoPay responsible for market volatility, technical failures, regulatory actions, or third-party service interruptions.
- You are using PlutoPay at your own risk.
If you do not agree with any part of this Risk Disclosure, do not use PlutoPay.