Acceptable Use Policy
This policy sets out the rules for using NillarPay responsibly. Violations may result in account suspension, legal action, and regulatory reporting.
Table of Contents
1. Policy Overview
This Acceptable Use Policy ("AUP") applies to all users of the NillarPay platform operated by Nillar Technology Limited. It describes the standards of behaviour we expect from all users and the activities that are strictly prohibited.
This AUP is incorporated into our Terms of Service. By using NillarPay, you agree to comply with both documents. Violations of this AUP may result in immediate account suspension, fund freezing, and reporting to Nigerian law enforcement or regulatory authorities.
2. Prohibited Activities
2.1 Financial Crimes
The following are strictly prohibited and constitute criminal offences under Nigerian law:
- Money laundering: Attempting to disguise the origin of illegally obtained funds through NillarPay transactions.
- Fraud: Using NillarPay to deceive others, obtain money under false pretences, or perpetrate financial fraud of any kind.
- Terrorist financing: Sending or receiving funds intended to support terrorist activities or designated terrorist organisations.
- Identity theft: Registering an account or conducting transactions using another person's identity.
- Advance fee fraud (419 scams): Using NillarPay to solicit upfront payments with false promises of future large returns.
- Ponzi and pyramid schemes: Operating or participating in investment schemes that are unsustainable and rely on recruiting new participants.
2.2 Unauthorised Services
NillarPay is not licensed to provide these services. Using NillarPay to facilitate any of the following is prohibited:
- Cryptocurrency buying, selling, exchange, or any digital asset transactions.
- International money transfers, remittances, or foreign exchange transactions.
- Unlicensed lending, money lending, or credit services.
- Investment services, portfolio management, or financial advisory services.
- Gambling, sports betting, lottery, or any game of chance — even if provided by a licensed entity.
- Operating as an unlicensed payment service provider.
- Reselling or white-labelling NillarPay services without our written authorisation.
2.3 Account Misuse
- Registering multiple accounts to circumvent transaction limits, KYC requirements, or suspensions.
- Using another person's account or allowing others to use your account.
- Providing false identity documents or information during registration or KYC.
- Using NillarPay accounts as pass-through accounts to transfer funds on behalf of unlicensed third parties.
- Structuring transactions to avoid AML monitoring thresholds (smurfing).
2.4 Platform Abuse
- Attempting to gain unauthorised access to NillarPay systems, servers, or databases.
- Using automated bots, scripts, or crawlers to interact with the NillarPay platform.
- Reverse-engineering, decompiling, or attempting to extract source code from the NillarPay application.
- Interfering with the availability, performance, or security of NillarPay.
- Uploading malware, viruses, or any malicious code.
- Exploiting referral or promotional programmes in bad faith or through coordinated artificial means.
2.5 Harassing or Harmful Conduct
- Using NillarPay to harass, threaten, or harm other users or NillarPay staff.
- Transmitting abusive, offensive, or defamatory content through NillarPay messaging or support channels.
- Using NillarPay to facilitate human trafficking or any form of exploitation.
3. Fraud Prevention Measures
NillarPay employs the following measures to prevent and detect fraud on our platform. By using NillarPay, you consent to and cooperate with these measures:
- Real-time transaction monitoring: All transactions are monitored in real time using automated AML/fraud detection systems.
- Velocity checks: We monitor the frequency, volume, and pattern of transactions to detect unusual activity.
- Device fingerprinting: We collect device identifiers to detect account access from unfamiliar devices.
- IP address monitoring: We track IP addresses to identify unusual geographic access patterns.
- Behavioural analytics: We analyse user behaviour patterns to detect deviations that may indicate fraud.
- Manual review: Our compliance team reviews flagged accounts and transactions.
- Third-party fraud scoring: We may use third-party fraud intelligence services to assess transaction risk.
4. Restricted Transactions
Certain transaction types require additional review or are subject to enhanced due diligence before processing:
- Large-value transactions: Transactions above CBN-prescribed reporting thresholds will be subject to enhanced monitoring and may require additional documentation.
- Politically Exposed Persons (PEPs): Accounts identified as belonging to PEPs or their associates are subject to enhanced due diligence.
- High-risk transactions: Transactions to or from accounts flagged as high-risk by our AML systems may be delayed pending review.
- New account activity: Unusual high-value activity on newly created accounts may trigger automatic review holds.
5. Account Misuse Prevention
To protect all users of the NillarPay platform, we implement the following safeguards:
5.1 Account Limits
Transaction limits are set per KYC tier as prescribed by CBN guidelines. Attempting to circumvent these limits through structuring or multiple accounts is a prohibited activity.
5.2 Suspicious Activity Reporting
We are obligated under the Money Laundering (Prevention and Prohibition) Act 2022 to report Suspicious Transaction Reports (STRs) to the Nigerian Financial Intelligence Unit (NFIU) for any account or transaction that raises money laundering or terrorism financing concerns.
5.3 Account Freezing
We may freeze your account without prior notice if we suspect fraudulent activity, receive a law enforcement order, or identify patterns consistent with AML violations. We will notify you of a freeze (where legally permitted) and provide an opportunity to respond.
6. Consequences of Violations
Violations of this Acceptable Use Policy may result in any or all of the following actions, depending on the severity of the violation:
| Severity | Consequence |
|---|---|
| Minor violation | Warning notification via app/email |
| Moderate violation | Temporary transaction suspension pending review |
| Serious violation | Account suspension and fund freeze |
| Severe / criminal violation | Permanent account termination, fund confiscation, and reporting to EFCC/NFIU/CBN/Police |
We reserve the right to recover losses caused by your violation of this AUP from any funds held in your NillarPay wallet before account closure.
7. Reporting Violations
If you suspect that another user is violating this Acceptable Use Policy or engaging in fraudulent activity on NillarPay, please report it to us immediately:
Report Fraud or Policy Violations
Fraud: fraud@nillar.com
Support: support@nillar.com
In-app: Use the "Report" feature in any transaction screen
All reports are treated confidentially. Reporting in good faith will not result in any negative consequences to the reporter.