Terms of service
Draft of 16 October 2026
The terms that apply when you use Nomapay, the software that lets you hold and send dollars by phone number.
Nomapay is a financial technology company, not a bank
Nomapay is provided by [Nomapay legal entity name, company number and registered address] ("Nomapay", "we"). Nomapay is a financial technology company. It is not a bank, and your balance is not a deposit with us or with anyone else.
The Nomapay app lets you hold, send and receive digital US dollars by phone number. By creating an account you agree to these terms.
Only you control your account
Your account is controlled by a key (a passkey) created in your phone's secure chip and unlocked by your face or fingerprint, or by a PIN on a basic phone. We do not hold your key, and we cannot move, freeze or reverse payments from your account.
- You are responsible for keeping your phone, your Apple or Google account and your PIN safe.
- Recovery needs your two guardians (our recovery service and an independent guardian service, or a trusted contact you add) and a 72-hour wait. We cannot recover your account or your money alone.
- If you lose your key, your Apple or Google account, and the help of your guardians, nobody can recover your account, including us.
On a basic phone, payments are signed for you by a key held by [the licensed partner that holds basic-phone keys], only after you confirm with your PIN. [Counsel: terms for basic-phone accounts]
Digital dollars are issued by third parties
The digital dollars in your account (USDC and USDT) are issued by third parties, not by Nomapay. Their value, availability and redemption depend on those issuers. An issuer can freeze addresses, for example under a legal order, and we cannot reverse that. See our disclosures for the risks.
Services processed by partners
Cash-outs to a bank or mobile money, bill payments and buying dollars are processed by our licensed payment partners. When you use one of these services, the partner converts and pays out, and its own terms may also apply. We show you the rate and every fee before you confirm.
If a partner cannot complete a cash-out or a bill, the amount and our fee are returned to your account. [Counsel: partner terms incorporated by reference, and how customers are told]
Fees
Our fees are listed in the fee schedule, which matches the fees page and the app. Every fee is shown on its own line before you confirm, and is not charged unless you confirm. We will give you [notice period] notice before we change a fee.
Prohibited use
You must not use Nomapay:
- for anything unlawful, including fraud, money laundering, terrorist financing or evading sanctions;
- with someone else's phone number or identity, or to impersonate anyone;
- to deceive people into sending you money;
- to interfere with, probe or overload our systems, except under our security reporting process;
- [Counsel: other restricted activities and countries].
We may refuse or end our services to you, including access to our app features, where the law or these terms require it. Because only you control your account, this does not give us the ability to move your money. [Counsel: suspension wording]
Country availability
Holding, sending and receiving by phone number are designed to work in any country. Other services (cash-out, bills, buying dollars and basic-phone use) are switched on country by country and may not be available where you are. The app shows "Coming soon" for anything that is not available in your country. Today the first countries for these services are Ghana, Kenya, Nigeria.
[Counsel: list of countries where the service may not be used]
Disputes
If something goes wrong, please tell us first: see complaints. These terms are governed by the law of [governing law], and disputes will be resolved by [courts or arbitration body, seat]. Nothing here removes rights you have under the consumer law of the country you live in.
Limits on our liability
We provide the software with care, but we cannot promise it will always be available or free of errors. We are not responsible for:
- losses caused by the actions of digital-dollar issuers, networks, or payment and bills partners;
- losses caused by you sharing your phone, key, code or PIN, or by sending to the wrong number or address;
- losses we could not reasonably have foreseen.
Our total liability to you is limited to [cap]. Nothing in these terms limits liability that cannot be limited by law. [Counsel: liability wording per country]
The disclosure. Nomapay is a financial technology company, not a bank. Digital dollars (USDC, USDT) are issued by Circle and Tether. Cash-outs, bill payments and dollar purchases are processed by our licensed payment partners. Availability varies by country.
Questions about this page? Write to support@nomapay.co. To complain, see complaints.