Partner Disclosures

Why We Are Telling You This

We want you to know about the companies we work with and how those relationships affect the service you receive from us. This disclosure is part of your Client Agreement and is available in the compliance documents section of the app at any time.

Our Sponsoring Broker

Kudimata Securities Ltd. is a sub-broker. We do not execute trades directly on the Nigerian Exchange Group (NGX). All your orders are sent to Blue Marina Securities Limited (CAC 746044, SEC file 1507, 10 Keffi Street, S.W., Ikoyi, Lagos) for execution. Blue Marina is a licensed broker-dealer registered with the Securities and Exchange Commission of Nigeria.

Blue Marina holds client assets and handles trade settlement. We receive execution reports from Blue Marina and display them in your app. We compare our records with Blue Marina’s at the end of each trading day to ensure everything matches.

We do not receive any payment from Blue Marina for routing your orders to them. Our relationship with Blue Marina is governed by a sponsorship agreement filed with the SEC.

Our Technology Providers

We use the following companies to run the platform. We have written agreements with each of them. They do not access your account or make decisions about your investments.

FiberOps Tech (Fibrecops Technologies): Hosts our servers and data in their data centres in Lagos and Abuja, Nigeria. They provide the cloud infrastructure, firewall, and backup services. They do not access your data directly.

Flutterwave: Processes wallet funding (card, bank transfer, USSD) and withdrawals. Flutterwave receives your payment details when you fund or withdraw. We verify every webhook callback from Flutterwave with cryptographic signatures to prevent fraud.

LumiID (with Smile Identity as an alternate): Verifies your identity during onboarding. They receive your BVN, NIN, ID document images, and liveness selfie. If LumiID is unavailable, we switch to Smile Identity. Cases that cannot be cleared automatically are reviewed by our staff.

SendGrid: Sends transactional emails on our behalf, including one time passcodes, trade confirmations, and service notifications. They receive your email address but do not access your account.

Cloudflare: Provides security, content delivery, and DDoS protection at the edge of our network. They may see your IP address but do not access your account data.

Do We Get Paid by These Partners?

We do not receive commission, referral fees, or kickbacks from any of the providers listed above for using their services. We chose them based on their ability to meet our regulatory, security, and operational requirements.

If this changes in the future, we will update this disclosure and notify you in the app before the change takes effect.

Do Our Partners Affect Your Fees?

The fees you pay are set by Kudimata Securities Ltd. and are shown in the app before you confirm any transaction. Our partners do not add their own fees on top of what we charge. Flutterwave’s payment processing fees, where applicable, are absorbed by us and not passed on to you unless we clearly indicate this in the app before you confirm the transaction.

What If a Partner Has a Problem?

If any of our providers experiences an outage, the affected service will be paused. For example, if Flutterwave is down, funding and withdrawals will be temporarily unavailable. If LumiID is down, KYC verification will switch to Smile Identity. We will show you a clear message in the app explaining what is affected.

We are not liable for losses caused by provider outages, but we have backup systems and recovery plans to restore service as quickly as possible.

Your Right to Ask Questions

If you have any questions about our partners or how they affect your account, contact us at support@kudimata.securities. We will respond within 1 business day.

Changes to This Disclosure

We may update this disclosure if we add, remove, or change a partner. When we do, the new version will be published in the app with a new version number and effective date. You will be asked to review and accept the updated version before your next trade.

Acceptance

By tapping “I Accept” in the app, you confirm that you have read and understood this Partner Disclosures document. Your acceptance is recorded with the date, time, device identifier, IP address, and the exact version of this document.