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Terms and Conditions of Service

Bright Future Hybrid Solutions Limited, trading as BemPay · Version 1.0

Effective DateApril 24, 2026
Version1.0
OperatorBright Future Hybrid Solutions Limited

These Terms and Conditions ("Terms") govern access to and use of lending and related technology services offered by Bright Future Hybrid Solutions Limited, trading as BemPay ("BemPay", "the Company", "we", "us" or "our"). They are intended to promote clear disclosure, fair treatment, responsible lending, data protection and accessible complaint resolution. A Customer should read the applicable loan offer and these Terms before accepting any facility.

1. Regulatory Status and Scope

Bright Future Hybrid Solutions Limited is a Nigerian company operating lending activities pursuant to its applicable lender's/money lender's permit and other laws and regulatory requirements applicable to its operations.

Bright Future Hybrid Solutions Limited is not a bank, microfinance bank, deposit money bank or CBN-licensed payment service provider and shall not represent itself as such.

Where BemPay provides access to banking, payment processing, virtual-account or other separately regulated functionality, that functionality may be supplied by an appropriately licensed third-party institution and may also be subject to that provider's terms.

Where the Company's activities fall within the Digital, Electronic, Online or Non-Traditional Consumer Lending regulatory framework administered by the Federal Competition and Consumer Protection Commission (FCCPC), the Company shall comply with applicable registration, consumer-protection, disclosure, data-protection and conduct requirements.

2. Eligibility and Customer Registration

A Customer must be at least 18 years old, legally capable of entering into a binding agreement, provide accurate information, satisfy applicable KYC requirements and meet BemPay's credit criteria.

Registration or submission of an application does not guarantee approval of a loan.

3. KYC, Identity and Fraud Prevention

BemPay may request and verify information including name, date of birth, address, telephone number, email, NIN, BVN, identification documents, photograph or facial-verification information, employment or business information, bank details and guarantor information where applicable.

Verification may be performed through authorised identity-verification providers and other lawful sources. False, fraudulent, misleading or materially incomplete information may result in rejection, restriction or termination and may be reported where required by law.

4. Responsible Lending and Credit Assessment

Before granting credit, BemPay may assess identity, income or business activity, repayment capacity, existing financial obligations, credit history and other relevant risk information.

BemPay will not treat submission of an application as automatic authorisation to disburse a loan. A loan will only be disbursed after the applicable assessment, approval and Customer acceptance.

BemPay may approve a lower amount than requested or decline an application, subject to applicable law.

5. Pre-Contract Disclosure

Before a Customer accepts a loan, BemPay shall make the material terms of that loan available in clear and understandable language. The disclosure shall include, as applicable:

6. Interest, Fees and Charges

BemPay shall disclose applicable interest, fees and charges before the Customer concludes the loan transaction. Undisclosed charges shall not be intentionally imposed.

Current lending rates and associated charges applicable to products offered digitally shall be made reasonably accessible on the BemPay website, application or other relevant digital platform.

Where an approved product requires interest to be paid upfront, the amount and effect of the upfront interest shall be clearly disclosed before acceptance.

No fee or charge shall be imposed for a product or service that the Customer did not request or agree to, except where a charge is expressly required by law.

7. Loan Offer, Acceptance and Contract Delivery

Following approval, BemPay shall provide the Customer with the applicable loan offer or agreement for review. Acceptance may be recorded through a lawful electronic mechanism, OTP, electronic confirmation, signature or other approved method.

The Customer shall be provided with or given continuing access to the accepted loan terms and repayment schedule in an electronic or other durable form reasonably capable of being retained or reproduced.

8. Disbursement

After approval, satisfaction of applicable conditions and Customer acceptance, the approved facility may be disbursed through an approved payment channel.

Disbursement does not convert Bright Future Hybrid Solutions Limited into a bank or payment service provider. Banking and payment-processing components may be performed by appropriately licensed partners.

9. Repayment and Early Repayment

The Customer shall repay the loan according to the accepted repayment schedule and is responsible for ensuring payment on or before the due date.

Where permitted by the applicable loan agreement and law, a Customer may make early repayment. Any financial consequence of early repayment shall be disclosed where applicable.

10. Changes to an Accepted Loan

An accepted loan's interest rate, fees, charges, repayment obligations or other material financial terms shall not be retrospectively or arbitrarily changed merely because BemPay later changes its general Terms.

Any variation of an existing loan must be permitted by the applicable contract and law, communicated clearly to the Customer and, where Customer agreement is legally required, shall not take effect without that agreement.

General updates to these Terms shall apply prospectively as permitted by law and shall not be used to impose an unfair term or an unrestricted unilateral variation of an existing credit agreement.

11. Fair Treatment and Prohibited Practices

BemPay shall treat Customers fairly and shall not intentionally use misleading representations, hidden charges, coercion or deceptive practices in connection with its lending services.

BemPay shall not knowingly disburse an unsolicited or pre-authorised loan merely because a Customer has registered, installed an application or previously borrowed.

Customers shall not be required to purchase or accept an unrelated service as a condition of obtaining a loan except where the requirement is lawful, reasonably connected to the facility and clearly disclosed.

12. Late Payment, Default and Ethical Recovery

A Customer may be in default where repayment is not made when due or another material obligation under the loan agreement is breached.

BemPay may use lawful and proportionate recovery measures, including repayment reminders, direct contact with the Customer, contact with an authorised guarantor where appropriate, authorised recovery providers, lawful credit-bureau reporting and legal proceedings.

BemPay and persons acting on its behalf shall not use public shaming, defamatory messages, intimidation, threats, unlawful harassment, unauthorised disclosure of debt information, abusive contact-list practices or other prohibited recovery conduct.

13. Credit Bureau Checks and Reporting

Where lawful and appropriate, BemPay may obtain credit information from licensed credit bureaus for assessment, fraud prevention and portfolio management, and may report relevant credit and repayment information to authorised credit bureaus.

Such processing shall be subject to applicable data-protection and credit-reporting requirements.

14. Payment, Virtual Account and Third-Party Services

BemPay may integrate with licensed banks, payment service providers, identity-verification providers, credit bureaus, communications providers and technology providers.

A virtual account presented through BemPay may be issued or maintained by a licensed financial institution. Its availability does not represent that Bright Future Hybrid Solutions Limited holds a banking or deposit-taking licence.

Where applicable, Customers may also be bound by the relevant third party's lawful terms for the regulated service it provides.

15. Customer Funds and Savings-Related Features

Bright Future Hybrid Solutions Limited does not represent itself as a deposit-taking institution.

Any feature involving the holding, custody or regulated processing of Customer funds must be structured in accordance with applicable law and, where required, through an appropriately licensed partner. Nothing in these Terms grants the Company deposit-taking authority.

16. Data Protection and Privacy

BemPay shall process personal data in accordance with applicable Nigerian data-protection law and its Privacy Policy. Data may be processed for KYC, identity verification, credit assessment, fraud prevention, loan administration, repayment processing, customer support, legal compliance and other lawful purposes.

Where necessary and lawful, relevant data may be shared with licensed banks or payment providers, identity-verification providers, credit bureaus, technology providers, professional advisers, authorised recovery providers and competent public authorities.

BemPay shall not use access to personal information as a basis for unlawful debt-shaming, unauthorised disclosure or abusive recovery.

17. Electronic and Marketing Communications

BemPay may send service-related communications such as OTPs, security alerts, transaction notices, loan information and repayment reminders through approved channels.

Promotional or marketing communications shall be sent only as permitted by applicable law. Where an opt-out right applies, Customers shall be provided with a reasonable means to stop further marketing communications. Opting out of marketing does not prevent necessary service, security, contractual or repayment communications.

18. Customer Security Responsibilities

Customers must protect passwords, PINs, OTPs and other security credentials, use the platform lawfully, provide accurate information and promptly report suspected unauthorised access or fraud.

19. Service Availability

BemPay will take reasonable steps to maintain service availability but does not guarantee uninterrupted access. Banking, telecommunications, identity-verification, credit-bureau or other third-party outages may affect availability.

20. Complaints, Redress and Escalation

Customers may submit complaints through BemPay's designated support channels. BemPay shall maintain a fair process for receiving, acknowledging, investigating and resolving complaints in accordance with applicable requirements.

A Customer should ordinarily first give BemPay an opportunity to resolve a complaint. If the matter remains unresolved, the Customer may exercise any right to escalate the complaint to the Federal Competition and Consumer Protection Commission (FCCPC), another competent regulator or a court or dispute-resolution forum of competent jurisdiction.

BemPay shall not retaliate against a Customer merely for making a complaint or exercising a lawful consumer right.

21. Suspension and Termination

BemPay may suspend, restrict or terminate access where reasonably necessary because of suspected fraud, false information, security compromise, material breach, legal or regulatory requirements or protection of the platform and Customers.

Suspension or termination does not extinguish a valid outstanding repayment obligation.

22. Limitation of Liability

Nothing in these Terms excludes or limits a statutory consumer right or liability that cannot lawfully be excluded. Any limitation of liability shall be interpreted subject to applicable consumer-protection law and shall not operate as an unfair term.

23. Amendments to General Terms

BemPay may update these general Terms to reflect changes in law, regulation, technology or services. Material changes shall be communicated as required by law. Updates shall not be used to retrospectively impose undisclosed interest, fees or material obligations on an existing accepted loan.

24. Governing Law and Dispute Resolution

These Terms are governed by the laws of the Federal Republic of Nigeria. The parties should first seek to resolve a dispute through BemPay's complaint process, without restricting a Customer's statutory right to seek redress from a competent authority or court.

25. Customer Rights

Nothing in these Terms is intended to waive or restrict rights granted to a consumer under applicable Nigerian consumer-protection, data-protection or other mandatory law.

Where any provision conflicts with a mandatory statutory consumer right, the mandatory law shall prevail to the extent of the conflict.

26. General Provisions

If a provision is held unlawful or unenforceable, the remaining provisions continue to apply to the extent permitted by law. These Terms should be read together with the applicable loan offer, loan agreement, repayment schedule, Privacy Policy and any lawful product-specific terms.

Contact Information

Bright Future Hybrid Solutions Limited (Trading as BemPay)

Customer Support Telephone: +234 902 309 0581

Official Email: info@bempay.online

Website: BemPay.online

These Terms should be read together with our Privacy Policy and the applicable loan offer, loan agreement and repayment schedule.

© 2026 BemPay — Bright Future Hybrid Solutions Limited. All rights reserved.