Cyphalet Membership Agreement
Version: terms-2026-04-19-v1 · Effective From: 19 April 2026
By proceeding with your Cyphalet account application, checking the acceptance box and clicking “Submit” you acknowledge and agree to the following terms and conditions. These terms constitute a legally binding agreement between you (“the User”) and Cyphalet Technology Ltd (“Cyphalet” “we” “us”).
1. Acceptance and Scope
- 1.1 This Membership Agreement governs your access to and use of Cyphalet's cross-border payments, wallet, foreign exchange and related financial services (“Services”).
- 1.2 You must be at least 18 years old and legally capable of entering into binding contracts within your jurisdiction.
- 1.3 By submitting your onboarding application, you warrant that all information provided is accurate, current and complete. Any misstatement, omission or falsification entitles Cyphalet to refuse service, terminate your account and report the matter to the relevant authorities.
2. User Information and Privacy
- 2.1 You agree to provide and maintain accurate, current and complete information throughout the duration of your relationship with Cyphalet.
- 2.2 Cyphalet processes personal data in accordance with its Privacy Policy and applicable data protection regulations including, where relevant, the Nigeria Data Protection Act 2023.
- 2.3 You authorize Cyphalet to share your personal and business data with regulated partners strictly for the purposes of identity verification, sanctions screening, fraud prevention, and the provision of payment services, subject to the safeguards described in our Privacy Policy.
3. Verification Process
- 3.1 Upon submission, your account will be placed under review. Cyphalet's compliance team, in conjunction with our regulated identity partners will verify the documents and information provided.
- 3.2 Review typically completes within 24 hours but may take longer where additional checks are required. Cyphalet will notify you of the outcome via the email address on file.
- 3.3 Cyphalet may request additional documentation or information at any time to meet its regulatory obligations, including requirements related to Know Your Customer (KYC), Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Source of Funds (SoF) verification.
4. Compliance, Sanctions, and Security
- 4.1 Cyphalet operates subject to financial services regulations. You agree to comply with all applicable laws, including those relating to AML, CTF, sanctions, and tax reporting.
- 4.2 Accounts associated with fraudulent information, sanctioned parties, or prohibited activities will be frozen or closed. Balances may be withheld pending investigation by Cyphalet or the competent authorities.
- 4.3 You are responsible for maintaining the confidentiality of your credentials and transaction PIN. You agree to notify Cyphalet immediately of any unauthorized access to or use of your account.
5. Prohibited Activities
5.1 You agree not to use Cyphalet directly or indirectly for any of the following:
- Money laundering, terrorist financing or the evasion of sanctions.
- Fraud, market manipulation, or any other criminal activity.
- Transactions connected to gambling, adult content, weapons, narcotics or other activities prohibited by our Acceptable Use Policy.
- Transactions on behalf of an undisclosed third party except where expressly authorized by Cyphalet in writing.
5.2 Cyphalet may refuse, reverse or delay any transaction that in its reasonable judgment breaches this clause or poses a regulatory, financial or reputational risk.
6. Custody of Assets
- 6.1 Fiat balances are held in segregated client-money accounts with regulated partner institutions. Stablecoin balances are held via regulated digital-asset custodians. Cyphalet does not commingle customer assets with its own corporate funds.
- 6.2 Cyphalet does not pay interest on balances unless expressly agreed upon in a separate written agreement.
7. Fees and Exchange Rates
- 7.1 Fees for Services are disclosed in the Cyphalet fee schedule and at the time of the transaction quote. Foreign exchange rates are quoted in real-time and are valid only for the duration stated in the quote.
- 7.2 You are responsible for any taxes, duties, or levies that apply to your use of the Services within your jurisdiction.
8. Limitation of Liability
- 8.1 Cyphalet provides the Services on an “as is” and “as available” basis. To the maximum extent permitted by law, Cyphalet disclaims all implied warranties, including merchantability and fitness for a particular purpose.
- 8.2 Cyphalet's total liability to you for any claim arising out of or in connection with this Agreement is limited to the fees you have paid to Cyphalet for the relevant Service in the 12 months preceding the event giving rise to the claim.
- 8.3 Nothing in this Agreement excludes or limits Cyphalet's liability for fraud, death or personal injury caused by negligence or any other liability that cannot lawfully be excluded or limited.
9. Record of Consent and Audit
- 9.1 By clicking “Submit” you consent to Cyphalet recording the following as durable evidence of your acceptance: the version of this document, a cryptographic hash of its contents, the server timestamp, your IP address, your browser user-agent and a correlation identifier for audit purposes.
- 9.2 This record is retained for the period required by applicable AML and financial services regulations and may be disclosed to regulators, auditors, courts or law enforcement authorities upon request.
10. Termination
- 10.1 You may close your account at any time via the in-app settings or by contacting support@cyphalet.xyz subject to the settlement of any pending transactions.
- 10.2 Cyphalet may suspend or terminate your account with notice or immediately and without prior notice in cases of suspected fraud, regulatory action or breach of this Agreement.
11. Changes to These Terms
- 11.1 Cyphalet may update these terms periodically. Material changes will be notified to you at least 30 days in advance via email and will require re-acceptance before you can continue using the affected Services.
- 11.2 Each published version of these terms carries a version identifier (e.g. “terms-2026-04-19-v1”). The version you accepted during onboarding remains binding until a later version is accepted.
12. Governing Law and Disputes
- 12.1 This Agreement and any non-contractual obligations arising out of it are governed by the laws of Nigeria.
- 12.2 The Supreme Court, High Court and Magistrates Court have exclusive jurisdiction to settle any dispute arising out of or in connection with this Agreement except that Cyphalet may bring proceedings in any jurisdiction where you are resident or where your assets are located.