Legal

Terms & Conditions

Effective date: 07 Sept 2026

These Terms & Conditions ("Terms") govern your access to and use of the SmartPayGo mobile application, website, and related services (collectively, the "Service") provided by SmartPayGo Ltd, a company registered in Rwanda ("SmartPayGo", "we", "us", or "our").

By creating an account, accessing, or using SmartPayGo, you acknowledge that you have read, understood, and agreed to these Terms and our Privacy Policy. If you do not agree with these Terms, you must not use the Service.

1. About SmartPayGo

SmartPayGo is a digital payment-support and transaction-recording application designed primarily for users and businesses in Rwanda.

SmartPayGo currently allows users to:

  • Initiate supported mobile-money payments through their mobile network operator's USSD service.
  • Scan supported SmartPayGo business QR codes.
  • Select or enter a recipient's phone number or supported business identifier.
  • Keep records of payments and payment confirmations.
  • View transaction history and spending information.
  • Receive electronic SmartPayGo receipts for eligible transactions.
  • Interact with participating businesses through the SmartPayGo platform.

SmartPayGo may introduce additional services and features in the future.

2. SmartPayGo Does Not Hold Your Money

SmartPayGo does not currently hold, store, or take custody of customer funds.

When you initiate a supported payment through SmartPayGo, the payment is executed through the relevant mobile-money or payment network's own systems.

For example, where the payment is initiated through an operator's USSD service, the actual transfer of funds occurs through that operator's mobile-money system.

SmartPayGo provides the interface and supporting functionality that helps you initiate the payment and maintain a record of the transaction.

SmartPayGo does not receive your mobile-money PIN and does not control your mobile-money account.

3. Payment Authorization

You are responsible for reviewing the payment information before authorizing a transaction.

Before completing a payment, you should verify:

  • The recipient or business;
  • The payment amount;
  • The phone number or business identifier;
  • The purpose of the payment; and
  • Any other information displayed by SmartPayGo or your payment provider.

When you authorize a payment using your mobile-money PIN or other authentication method, you are authorizing the transaction through your mobile-money provider.

Never disclose your mobile-money PIN to SmartPayGo, a business, customer-support representative, or any other person.

SmartPayGo will never ask you to provide your mobile-money PIN.

Verifying the Recipient's Name

When using SmartPayGo to send money - whether by scanning a QR code, typing a recipient's phone number or MoMo code, or selecting a contact from your phone - you are solely responsible for verifying the recipient's name before confirming any payment. SmartPayGo operates on top of third-party mobile money and banking services (including MTN MoMo, e-Kash, Airtel Money, and participating banks), each of which independently displays the intended recipient's name for your confirmation before a transaction is finalized. It is your responsibility to review this confirmation carefully and cancel the transaction if the displayed name does not match your intended recipient.

SmartPayGo is not responsible for funds sent to an unintended recipient where the correct recipient name was correctly displayed by the payment provider and the user proceeded without verifying it.

4. Payment Status and Transaction Records

SmartPayGo may record information about a payment based on information available to SmartPayGo and/or confirmation provided by the customer or participating business.

Unless SmartPayGo has a direct verified connection to the relevant payment provider for a particular transaction, SmartPayGo may not be able to independently verify whether a USSD transaction was successfully completed.

Accordingly, a transaction record or electronic receipt in SmartPayGo should not be interpreted as proof of settlement by a bank or mobile-money provider unless explicitly identified as such.

Your mobile-money provider's transaction confirmation remains the authoritative record of the movement of funds.

This is consistent with the current SmartPayGo model described in your Privacy Policy: SmartPayGo does not have visibility into whether a USSD transaction actually succeeded on the operator's side unless the relevant result is otherwise made available or confirmed.

5. Business Payments

SmartPayGo allows customers to make payments to participating businesses.

A business may be identified through:

  • A SmartPayGo QR code;
  • A registered business phone number;
  • A merchant/business identifier; or
  • Another payment method supported by SmartPayGo.

Before making a payment, you are responsible for confirming that the business displayed by SmartPayGo is the business you intend to pay.

A business is responsible for providing accurate information about itself, including its business name, payment identifier, and other information required for its participation in SmartPayGo.

6. Business Confirmation of Payment

For participating businesses, SmartPayGo may allow the business owner or authorized business representative to confirm that a payment has been received.

Where SmartPayGo generates an electronic receipt based on such confirmation, the receipt represents a SmartPayGo electronic transaction receipt based on the relevant transaction and confirmation.

It is not automatically an RRA/EBM tax receipt.

Where EBM functionality is introduced and integrated into SmartPayGo in the future, EBM receipts will be subject to the applicable EBM system, business obligations, and regulatory requirements.

7. Electronic Receipts

For eligible transactions, SmartPayGo may generate an electronic receipt after the applicable payment and business confirmation process has been completed.

The receipt may include information such as:

  • Business name;
  • Amount;
  • Date and time;
  • Payment method;
  • Transaction reference;
  • Receipt reference;
  • Payment status.

The receipt is intended to provide users with a convenient electronic record of the transaction.

Users should retain the original mobile-money or payment-provider confirmation where applicable.

8. Business Accounts

Businesses may apply for a SmartPayGo Business Account.

Business accounts may provide access to features including:

  • Payment notifications;
  • Transaction records;
  • Customer transaction information;
  • Business dashboards;
  • Sales summaries;
  • Electronic receipts;
  • Other business-management features introduced by SmartPayGo.

SmartPayGo may require businesses to provide information or supporting documentation before approving a Business Account.

SmartPayGo may reject, suspend, or require additional verification for a business application where necessary to protect users, prevent fraud, comply with applicable law, or maintain the integrity of the Service.

9. Business Owner Responsibilities

Business owners are responsible for:

  • Providing accurate registration information;
  • Keeping their account credentials secure;
  • Ensuring only authorized persons access their Business Account;
  • Confirming payments accurately;
  • Providing goods or services as represented to customers;
  • Handling customer refunds and commercial disputes appropriately;
  • Complying with applicable tax, business, consumer-protection, and other legal requirements;
  • Ensuring that their use of SmartPayGo does not violate applicable law.

SmartPayGo does not become a party to the underlying sale of goods or services between a customer and a business merely because SmartPayGo facilitates or records the payment.

10. Refunds and Commercial Disputes

SmartPayGo does not automatically reverse or refund payments merely because a customer changes their mind or disputes a purchase.

Disputes concerning:

  • Goods;
  • Services;
  • Prices;
  • Quality;
  • Cancellations;
  • Refunds;
  • Appointments;
  • Transportation;
  • Other commercial matters

should normally be resolved directly between the customer and the relevant business.

Where a payment-provider dispute, reversal, or chargeback process is available, the customer may also need to contact the relevant mobile-money or payment provider.

SmartPayGo may assist with transaction information where appropriate but does not guarantee that a disputed payment will be reversed.

11. Unauthorized Transactions

You are responsible for protecting your phone, SIM card, mobile-money account, authentication credentials, and SmartPayGo account.

You must immediately notify the relevant mobile-money provider if you believe that:

  • Your mobile-money account has been compromised;
  • Your PIN has been disclosed;
  • Your SIM has been lost or compromised; or
  • An unauthorized transaction has occurred.

You should also contact SmartPayGo where the issue relates to your SmartPayGo account or transaction record.

SmartPayGo is not responsible for transactions authorized through your mobile-money account using credentials that you were responsible for keeping confidential, except where liability cannot legally be excluded.

12. QR Codes

SmartPayGo may allow users to scan QR codes to identify participating businesses or initiate supported payments.

You should only scan QR codes that you trust.

SmartPayGo may reject QR codes that:

  • Do not use a supported SmartPayGo format;
  • Contain invalid or incomplete information;
  • Identify an unregistered or unsupported business;
  • Contain malicious or unsupported content;
  • Appear to have been manipulated; or
  • Otherwise fail SmartPayGo's validation requirements.

SmartPayGo may modify its QR-code format or validation requirements from time to time for security or operational reasons.

13. Contact Access

Where you choose to use the contact-selection feature, SmartPayGo may request permission to access contacts stored on your device.

Contact access is used to help you select a payment recipient.

You may refuse contact permission and manually enter a recipient number where that option is available.

SmartPayGo's handling of contact information is subject to the SmartPayGo Privacy Policy.

14. Fees

SmartPayGo may offer certain services free of charge and may introduce paid features, subscriptions, or other charges. SmartPayGo is currently provided without a subscription or paid feature purchase within the mobile application. SmartPayGo may introduce fees for certain services in the future. If fees are introduced, the applicable fees and payment arrangements will be communicated to users before the relevant paid service is provided. Any fees charged by mobile network operators, payment providers, or other third-party services are separate from SmartPayGo fees and may be subject to those providers' own terms and charges. The introduction of any future paid service will be subject to applicable laws, regulations, and platform requirements.

Where SmartPayGo charges a fee, the applicable fee will be presented to you before you are required to pay it.

Mobile-money operators, banks, payment providers, telecommunications providers, or other third parties may independently charge fees for their services.

SmartPayGo does not control fees charged by those third parties.

15. Third-Party Services

SmartPayGo depends on third-party services and infrastructure, which may include:

  • Mobile network operators;
  • Mobile-money providers;
  • Telecommunications networks;
  • Hosting and database providers;
  • SMS providers;
  • App stores;
  • Payment and technology providers.

These services are outside SmartPayGo's direct control.

SmartPayGo is not responsible for interruptions, failures, delays, network problems, or errors caused solely by third-party systems.

Your use of third-party services may also be subject to the third party's own terms and conditions.

16. Service Availability

We aim to keep SmartPayGo available and reliable, but we do not guarantee uninterrupted or error-free operation.

The Service may occasionally be unavailable because of:

  • Maintenance;
  • Software updates;
  • Telecommunications failures;
  • Mobile-money provider outages;
  • Internet outages;
  • Security incidents;
  • Infrastructure failures;
  • Circumstances beyond our reasonable control.

Where reasonably practical, we may notify users about significant planned or unplanned service interruptions.

17. Account Security

You are responsible for maintaining the security of your SmartPayGo account and device.

You must not:

  • Share your account credentials;
  • Allow unauthorized persons to use your account;
  • Attempt to bypass security controls;
  • Impersonate another person or business;
  • Provide false registration information.

You must notify SmartPayGo if you believe that your account has been accessed without authorization.

18. Prohibited Activities

You must not use SmartPayGo to:

  • Commit fraud;
  • Launder money;
  • Finance illegal activities;
  • Facilitate theft or unauthorized transactions;
  • Impersonate another person or business;
  • Submit false business information;
  • Distribute malware;
  • Interfere with SmartPayGo's systems;
  • Attempt to gain unauthorized access to another user's account;
  • Manipulate transaction records;
  • Create fraudulent QR codes;
  • Use the Service for unlawful purposes;
  • Abuse, threaten, harass, or defraud other users or businesses;
  • Reverse engineer or attempt to extract the source code of the Service except where permitted by applicable law.

We may suspend or terminate accounts involved in prohibited activity.

19. Intellectual Property

SmartPayGo and its associated software, branding, logos, designs, interfaces, content, and technology are owned by or licensed to SmartPayGo Ltd unless otherwise stated.

Your use of SmartPayGo does not transfer ownership of any SmartPayGo intellectual property to you.

You receive a limited, non-exclusive, non-transferable right to use the Service for its intended purpose while your account remains in good standing.

You may not copy, modify, distribute, sell, sublicense, or create derivative works from SmartPayGo without our written permission, except where permitted by applicable law.

20. App Store Terms

If you download SmartPayGo through Apple App Store or Google Play, your use of those platforms is also subject to the applicable terms and policies of Apple or Google.

These Terms are between you and SmartPayGo Ltd.

Apple and Google are not responsible for SmartPayGo's payment services, business relationships, transaction records, or customer support obligations except to the extent required under their respective platform terms or applicable law.

21. Privacy

Your use of SmartPayGo is also governed by our Privacy Policy, which explains what information we collect, how we use it, how we protect it, and the circumstances in which information may be shared.

The Privacy Policy forms part of these Terms.

Our Privacy Policy states, among other things, that SmartPayGo does not sell users' personal information.

22. Suspension and Termination

We may suspend or terminate your access to SmartPayGo if:

  • You materially breach these Terms;
  • You provide false or misleading information;
  • Your account is involved in suspected fraud or unlawful activity;
  • Suspension is necessary for security reasons;
  • Suspension is required by law or a competent authority;
  • Continued access presents a material risk to SmartPayGo, another user, or a business.

Where appropriate and legally permitted, we may provide notice before termination.

You may stop using SmartPayGo at any time.

Account termination does not necessarily require us to delete records that we are legally required to retain.

23. Limitation of Liability

To the maximum extent permitted by applicable law, SmartPayGo will not be liable for losses resulting solely from:

  • Mobile network outages;
  • Mobile-money provider failures;
  • Incorrect recipient information entered by you;
  • Unauthorized use resulting from your failure to secure your device or credentials;
  • Delays or failures of third-party services;
  • Inaccurate information provided by a business;
  • Disputes between customers and businesses;
  • Goods or services supplied by businesses;
  • Circumstances outside our reasonable control.

Nothing in these Terms excludes or limits liability where such exclusion or limitation is prohibited by applicable law.

24. No Guarantee of Business Goods or Services

SmartPayGo provides technology that supports payments and transaction records.

Unless explicitly stated otherwise, SmartPayGo does not guarantee:

  • The quality of goods or services provided by a business;
  • That a business will fulfill an order;
  • That a business will provide a refund;
  • That a business is financially solvent;
  • That a business will remain registered with SmartPayGo;
  • That a business will remain available.

Customers should independently evaluate the businesses they choose to purchase from.

25. Changes to the Service

We may modify, add, suspend, or remove features from SmartPayGo as the Service develops.

For example, features currently under development or not yet available may be introduced in future versions.

We will not intentionally misrepresent unavailable features as completed services.

Where a material change substantially affects these Terms, we may notify users through the App or another reasonable method.

26. Changes to These Terms

We may update these Terms from time to time.

When we make material changes, we may notify you through the App, website, email, or another reasonable method.

The updated Terms will become effective on the date stated in the updated Terms.

Your continued use of SmartPayGo after the effective date of the updated Terms constitutes acceptance of the revised Terms, to the extent permitted by applicable law.

27. Governing Law

These Terms are governed by the laws of the Republic of Rwanda, unless applicable law requires otherwise.

Any dispute arising from these Terms or your use of SmartPayGo shall be handled in accordance with applicable Rwandan law and the jurisdiction of the competent courts of Rwanda, subject to any mandatory consumer or regulatory dispute-resolution rights.

28. Complaints and Support

If you have a complaint, payment-related concern, account issue, security concern, or other problem with SmartPayGo, please contact us first so that we can investigate and attempt to resolve the issue.

SmartPayGo Ltd
Email: contact@smartpaygo.rw
Website: www.smartpaygo.rw

Where a complaint concerns the underlying movement of funds, you may also need to contact the relevant mobile-money provider or payment service provider.

29. Severability

If any provision of these Terms is found to be invalid, unlawful, or unenforceable, that provision will be limited or removed to the minimum extent necessary, and the remaining provisions will continue to apply.

30. Entire Agreement

These Terms, together with the SmartPayGo Privacy Policy and any additional terms presented for specific SmartPayGo services, constitute the agreement between you and SmartPayGo concerning your use of the Service, unless otherwise required by applicable law.

SmartPayGo Ltd
Rwanda
contact@smartpaygo.rw
www.smartpaygo.rw