Kudimata Securities · Legal

Terms of Service

Last updated 19 August 2026

Using the App

These Terms of Service set out rules for using the Kudimata Invest app, owned and operated by Kudimata Securities Ltd. By creating an account, you agree to these terms. If you do not agree, please do not use the app.

For any questions, contact us at support@kudimata.securities.

Current Test Environment Notice

The app is currently running in a test environment and is available only to invited testers. Market data and order fills are simulated. No real trading is taking place. No real money is at risk. When the platform moves to production, it will connect to Blue Marina Securities for real order execution and the NGX Market Data API for real prices. Live trading will begin only after SEC approval is granted.

Eligibility

To use the app, you must be at least 18 years old, a resident of Nigeria, and legally able to enter into a binding contract. You must provide accurate and complete information when you create your account. You can only have one account. You must not share your account with anyone else.

Account Security

You are responsible for keeping your account safe. Here is what you must do:

  • Choose a strong password and keep it private.
  • Set a 6-digit passcode on your device and do not share it.
  • Turn on biometric unlock (Face ID or fingerprint) if your device supports it.
  • Tell us immediately if you think someone has accessed your account without permission.
  • Keep your contact details up to date so we can reach you about your account.

Your passcode and biometric data are stored only on your device. We never see or store them. If you lose your device, contact us at support@kudimata.securities so we can secure your account.

Acceptable Use

You agree to use the app only for its intended purpose: managing your personal investments. You agree with:

  • Provide true and accurate information at all times.
  • Complete the suitability questionnaire honestly.
  • Keep your KYC information up to date.
  • Use your own identity card and your own bank account.
  • Follow all applicable laws and regulations.

Prohibited Activities

You must not:

  • Use the app for any illegal or fraudulent purpose.
  • Try to manipulate market prices or trading activity.
  • Use someone else’s identity or bank account.
  • Try to hack, disrupt, or reverse engineer the app.
  • Share your login details with anyone.
  • Use the app to launder money or finance illegal activity.
  • Place orders you do not intend to settle.
  • Copy or redistribute content from the app without our permission.

If we detect any of these activities, we may suspend or close your account immediately and report the matter to the relevant authorities.

Market Information

In the current test environment, all market data shown in the app is simulated. It is not real NGX market data. Prices and fills are generated by our servers for testing. They should not be relied on for any investment decision.

When the platform moves to production, market data will come from the NGX Market Data API. However, market data may be delayed or unavailable at times. We are not responsible for losses caused by delayed or inaccurate market data.

Service Availability

We aim to keep the app available at all times, but we cannot guarantee uninterrupted access. The app may be unavailable during:

  • Scheduled maintenance (we will notify you in advance where possible).
  • Outages at our providers (FiberOps Tech, Flutterwave, LumiID, SendGrid, Cloudflare, NGX).
  • Network or internet problems outside our control.
  • Regulatory or legal requirements.

We are not liable for losses caused by the app being unavailable.

Third Party Services

The app relies on third-party providers to deliver some services:

  • Flutterwave for payment and withdrawals.
  • LumiID (and Smile Identity as an alternate) for identity verification.
  • SendGrid for email delivery.
  • Cloudflare for security and content delivery.
  • Blue Marina Securities for order execution (when live).
  • FiberOps Tech for hosting.

We are not responsible for the performance of these providers. If a provider is unavailable, the affected service will pause, and we will show you a clear message in the app.

Intellectual Property

The app, its design, its content, and the Kudimata Invest name belong to Kudimata Securities Ltd. You may not copy, modify, or redistribute any part of the app without our written permission. You retain ownership of the data you provide to us.

Updates to the App

We may update the app from time to time to improve it, fix issues, or add features. We will try to give you notice before major changes. We may also update these Terms of Service. 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.

Suspension or Termination

We may suspend or close your account if:

  • You breach these Terms of Service or the Client Agreement.
  • We suspect fraudulent or unauthorised activity.
  • We are required to do so by law or by a regulator.
  • You are no longer eligible to use the app.

You can close your account at any time by contacting us at support@kudimata.securities. When your account is closed, we will return any remaining balance to your saved bank account (in the production environment) and retain your records for the period required by SEC rules.

Liability

We provide the app with reasonable care and skill. We are not liable for:

  • Losses caused by market movements or the performance of your investments.
  • Outages or failures at third-party providers.
  • Events outside our reasonable control.
  • Your failure to protect your passcode or device.
  • Losses from decisions made based on simulated market data in the test environment.

We do not guarantee that the app will be error-free or available at all times.

Governing Law

These terms are governed by the laws of the Federal Republic of Nigeria. Any dispute will be resolved in the courts of Nigeria, unless we agree otherwise in writing.

Acceptance

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

Document Version: 1.0 Effective Date: 17 August 2026 Owner: Kudimata Securities Ltd.