Privacy Policy and Terms of Service
THUNDER PAY PRIVACY POLICY
Last Updated: June 10, 2026
1. Introduction
Thunder Pay (“Thunder”, “we”, “us”, “our”) is owned and operated by ThunderNetwork Limited.
We are committed to protecting the privacy, confidentiality, and security of personal data collected from individuals who access or use our mobile application, website, APIs, products, payment platforms, customer support channels, and related services (collectively, the “Services”).
This Privacy Policy explains the types of personal data we collect, how we collect it, the purposes for which we use it, the lawful basis for processing it, how we share and protect it, how long we retain it, and the rights available to you as a data subject.
This Policy is designed to comply with applicable data protection, financial services, anti-money laundering, counter-terrorism financing, fraud prevention, virtual asset, payment services, and regulatory requirements in jurisdictions where Thunder operates, including Nigeria and any other countries in which our Services become available.
By registering for, accessing, or using Thunder Pay, you acknowledge that you have read and understood this Privacy Policy. Where we rely on consent as the lawful basis for processing, you may withdraw your consent at any time, subject to legal, regulatory, contractual, and operational limitations.
2. Scope of this Policy
This Policy applies to personal data collected or processed through:
• The Thunder Pay mobile application;
• Thunder Pay websites, portals, dashboards, APIs, and online platforms;
• Account registration, onboarding, verification, and KYC processes;
• Cryptocurrency wallet services;
• Crypto-to-fiat payment services;
• Bill payment services;
• Transfers, withdrawals, deposits, and settlement services;
• Customer support channels, email communications, chat systems, and social media interactions;
• Marketing, promotional, and referral programs; and
• Automated technologies used in connection with our Services, including cookies, device logs, analytics tools, and fraud prevention systems.
This Policy does not apply to third-party websites, applications, wallets, exchanges, payment processors, merchants, banking partners, or services that are not owned or controlled by Thunder.
Where you access third-party services through Thunder, the privacy policy of that third party will govern their processing of your personal data.
3. Personal Data We Collect
We collect personal data reasonably necessary to provide secure, compliant, and reliable financial technology services.
The information collected may vary depending on the products you use, your location, your risk profile, regulatory obligations, and the level of verification completed on your account.
3.1 Information You Provide Directly
When you create an account, verify your identity, complete transactions, contact support, or otherwise use our Services, we may collect:
Identity Data
• Full name
• Date of birth
• Gender
• Nationality
• Username
• Customer identification number
• Profile photograph
• Signature
• Other account registration details
Contact Data
• Phone number
• Email address
• Residential address
• Mailing address
• Authorized contact details where applicable
Verification Data
• Bank Verification Number (BVN)
• National Identification Number (NIN)
• Passport information
• Driver’s licence
• National identity card
• Voter’s card
• Selfie photographs
• Facial verification data
• Liveness verification information
• Other government-issued identification documents
Financial Data
• Bank account information
• Naira account details
• Wallet addresses
• Cryptocurrency wallet information
• Payment information
• Settlement details
• Beneficiary information
• Source of funds information
Transaction Data
• Cryptocurrency deposits
• Cryptocurrency withdrawals
• Bill payment records
• Airtime purchases
• Data purchases
• Electricity bill payments
• Cable television subscriptions
• Transfer records
• Transaction references
• Refunds
• Reversals
• Chargebacks
• Dispute records
Compliance Data
• KYC documentation
• Customer due diligence records
• Enhanced due diligence information
• AML/CFT screening results
• Sanctions screening results
• Politically Exposed Person (PEP) screening results
• Risk assessment information
Communication Data
• Support tickets
• Emails
• Chat conversations
• Complaint records
• Feedback submissions
• Survey responses
Marketing Preference Data
• Communication preferences
• Notification settings
• Opt-in and opt-out records
3.2 Information We Collect Automatically
When you access or use Thunder Pay, we may automatically collect:
Device Data
• Device type
• Device model
• Operating system
• Browser type
• Mobile network information
• Device identifiers
• Advertising identifiers
Log and Usage Data
• IP address
• Login records
• Access timestamps
• Session duration
• Features used
• Clickstream data
• Error logs
• Crash reports
Location Data
• IP-based location information
• Approximate device location
• Precise device location where permission has been granted
Security and Fraud Data
• Device fingerprinting information
• Authentication attempts
• Behavioral analytics
• Transaction velocity monitoring
• Suspicious activity indicators
• Account access patterns
Cookies and Tracking Data
• Cookies
• Pixels
• SDKs
• Analytics technologies
• Tracking technologies
3.3 Information from Third Parties
We may receive information about you from:
• Identity verification providers
• Banking partners
• Payment processors
• Cryptocurrency infrastructure providers
• Blockchain analytics providers
• Fraud prevention databases
• Credit reference agencies
• Compliance screening providers
• Regulatory authorities
• Law enforcement agencies
• Merchants
• Business partners
• Public records
• Persons authorized by you
4. Legal Basis for Processing
We process personal data only where we have a lawful basis to do so.
Depending on the circumstances, we may process your personal data on the basis of:
• Your consent;
• Contractual necessity;
• Compliance with legal and regulatory obligations;
• Legitimate business interests including fraud prevention, platform security, dispute resolution, service improvement, risk management, and business continuity; and
• Protection of vital interests or public interest where permitted by law.
Where processing is based on consent, you may withdraw your consent at any time.
5. How We Use Your Personal Data
We may use your personal data to:
• Create, verify, and manage your Thunder Pay account;
• Perform identity verification and KYC checks;
• Facilitate cryptocurrency deposits and withdrawals;
• Process crypto-to-fiat conversions;
• Enable airtime, data, electricity, cable TV, and bill payment services;
• Process transfers and settlements;
• Monitor transactions for suspicious activity;
• Detect and prevent fraud;
• Comply with AML, CFT, sanctions, and regulatory requirements;
• Communicate with you regarding transactions, security alerts, and service updates;
• Provide customer support;
• Improve products and services;
• Conduct analytics and research;
• Personalize user experiences;
• Resolve complaints and disputes;
• Enforce our legal rights and agreements; and
• Fulfill any purpose disclosed at the time information is collected.
We do not sell your personal data.
6. Alerts, Service Communications and Marketing
By creating or using a Thunder Pay account, you agree that we may send:
• Transaction alerts;
• Security notifications;
• Verification requests;
• Service announcements;
• Compliance notifications;
• Regulatory notices;
• Product updates; and
• Marketing communications where permitted by law.
You may opt out of marketing communications at any time.
However, you cannot opt out of essential service, security, compliance, or transaction-related communications.
Thunder will never ask for your password, PIN, OTP, private keys, seed phrases, or complete authentication credentials through email, SMS, or phone calls.
7. Cookies and Similar Technologies
We may use cookies, pixels, SDKs, device identifiers, and similar technologies to:
• Operate our Services;
• Improve user experience;
• Analyze traffic;
• Prevent fraud;
• Secure accounts;
• Remember preferences;
• Measure platform performance; and
• Support marketing activities where permitted.
Disabling certain cookies may affect functionality or security.
8. How We Share Personal Data
We may share personal data only where necessary, lawful, and proportionate.
Recipients may include:
Regulatory Authorities
Including:
• Central Bank of Nigeria (CBN)
• Nigeria Data Protection Commission (NDPC)
• Nigerian Financial Intelligence Unit (NFIU)
• Economic and Financial Crimes Commission (EFCC)
• Securities and Exchange Commission (SEC)
• Tax authorities
• Courts and law enforcement agencies
Financial Partners
Including:
• Banking partners
• Settlement providers
• Payment processors
• Cryptocurrency infrastructure providers
• Virtual asset service providers
Compliance Providers
Including:
• Identity verification providers
• Fraud prevention providers
• AML monitoring providers
• Sanctions screening providers
Service Providers
Including:
• Cloud hosting providers
• Analytics providers
• Cybersecurity providers
• Customer support providers
• Technology vendors
Professional Advisers
Including:
• Auditors
• Lawyers
• Consultants
• Insurers
Corporate Transactions
Where Thunder undergoes a merger, acquisition, restructuring, financing transaction, or sale of assets.
9. International Data Transfers
Your personal data may be processed, stored, or accessed in jurisdictions outside your country of residence.
Where international transfers occur, Thunder will implement appropriate safeguards including:
• Contractual protections;
• Security measures;
• Regulatory approvals where required; and
• Other legally recognized transfer mechanisms.
10. Data Security
Thunder implements technical and organizational measures designed to protect personal data, including:
• Encryption of data in transit and at rest;
• Multi-factor authentication;
• Role-based access controls;
• Secure infrastructure monitoring;
• Fraud detection systems;
• Security audits and reviews;
• Employee confidentiality obligations;
• Vendor security assessments; and
• Incident response procedures.
No method of transmission or storage is completely secure.
Users are responsible for maintaining the confidentiality of passwords, PINs, OTPs, devices, and authentication credentials.
11. Data Retention
We retain personal data for as long as necessary to:
• Provide our Services;
• Maintain account records;
• Fulfill contractual obligations;
• Comply with AML/CFT requirements;
• Satisfy tax and accounting obligations;
• Resolve disputes;
• Enforce agreements; and
• Protect our legal rights.
Certain records may be retained after account closure where required by law or regulatory obligations.
12. Your Data Protection Rights
Subject to applicable law, you may have the right to:
• Access your personal data;
• Correct inaccurate information;
• Update incomplete information;
• Request deletion of personal data;
• Restrict processing in certain circumstances;
• Object to processing;
• Withdraw consent;
• Request data portability where applicable; and
• Lodge complaints with relevant data protection authorities.
Identity verification may be required before fulfilling requests.
13. Automated Decision-Making and Profiling
Thunder may use automated systems to support:
• Fraud detection;
• Risk scoring;
• Identity verification;
• Transaction monitoring;
• Account security;
• Compliance screening; and
• AML/CFT monitoring.
Where legally required, users may request human review of certain automated decisions.
14. Children’s Privacy
Thunder Pay is not intended for individuals under the age of 18.
We do not knowingly collect personal data from minors.
If we become aware that a minor has provided personal information without appropriate authorization, we may take steps to delete the information.
15. Third-Party Links and Services
Our Services may contain links to third-party websites, applications, exchanges, merchants, payment providers, advertisers, or partners.
Thunder is not responsible for the privacy practices, content, or security of third-party services.
Users should review the privacy policies of such third parties before providing personal information.
16. Account Security and User Responsibilities
You are responsible for safeguarding:
• Passwords;
• PINs;
• One-Time Passwords (OTPs);
• Authentication credentials;
• Devices used to access Thunder.
You must notify Thunder immediately if you suspect unauthorized access, credential compromise, fraud, or security incidents.
17. Nigeria-Specific Terms
For users in Nigeria, this Policy is intended to comply with:
• Nigeria Data Protection Act (NDPA);
• Nigeria Data Protection Regulation (NDPR);
• Applicable Central Bank of Nigeria regulations;
• AML/CFT laws;
• Financial services regulations; and
• Other applicable regulatory requirements.
Users may lodge complaints with the Nigeria Data Protection Commission where appropriate.
18. Changes to this Privacy Policy
Thunder may update this Privacy Policy periodically to reflect changes in:
• Law;
• Regulation;
• Technology;
• Product offerings;
• Security practices; or
• Business operations.
Material changes may be communicated through in-app notifications, email, SMS, website notices, or other appropriate channels.
Continued use of the Services following publication of an updated Policy constitutes acknowledgement of the updated Policy.
19. Contact Us
For privacy-related questions, requests, complaints, or to exercise your rights, please contact:
Company: ThunderNetwork Limited
Product: Thunder Pay
Email: support@paywiththunder.com
Website: https://www.paywiththunder.com
Customer Support: Available through the Thunder Pay application and official support channels.
If you are not satisfied with our response, you may contact the appropriate data protection authority in your jurisdiction.
20. Version Control
Policy Owner: ThunderNetwork Limited
Effective Date: June 10, 2026
Review Cycle: At least annually or whenever required by legal, regulatory, operational, security, or product changes.
THUNDER PAY TERMS OF SERVICE
Last Updated: June 10, 2026
Notice
Please note that your use of and access to the Services (as defined below) are subject to the following Terms of Service. If you do not agree to all of these Terms, you may not access or use the Services in any manner.
1. INTRODUCTION
1.1 Purpose
Thunder Pay (“Thunder Pay,” “Thunder,” “we,” “our,” or “us”), operated by ThunderNetwork Limited, provides cryptocurrency-powered payment solutions, digital wallet services, bill payment services, and related financial technology products.
Our mission is to enable users to spend, transfer, and manage digital assets seamlessly while maintaining compliance with applicable laws and regulations.
Depending on the services available in your jurisdiction, Thunder Pay may provide one or more of the following:
Current Services
* Cryptocurrency wallet services
* Cryptocurrency deposits
* Airtime purchases
* Data bundle purchases
* Electricity bill payments
* Cable television bill payments
Additional Services (Current or Future)
* Crypto-to-Naira transfers
* Naira accounts
* Fiat deposits and transfers
* Cashback programs
* Referral programs
* Ambassador programs
* Virtual cards
* Physical cards
* International accounts
* Multi-currency wallets
* Cross-border payment services
* Merchant payment services
* Contactless payment services
* Additional financial technology products and services
Collectively, these services are referred to as the “Services.”
Availability of specific Services may vary based on location, regulatory approvals, operational requirements, and eligibility criteria.
1.2 Agreement
By accessing or using:
* Thunder Pay mobile applications;
* Thunder Pay websites;
* Thunder Pay APIs;
* Customer support channels;
* Any products, software, content, or services provided by Thunder Pay;
you agree to be bound by these Terms of Service.
You also agree to our Privacy Policy and any additional agreements, disclosures, policies, or terms presented to you while using the Services.
For the purposes of these Terms:
User
A User is any individual or entity that accesses, browses, or uses the Services.
Customer
A Customer is a User who creates an account and utilizes one or more Thunder Pay financial services.
These Terms apply to all Users and Customers.
Thunder Pay makes no representation that its Services are lawful or available in every jurisdiction. If you access our Services from a location outside Nigeria, you do so at your own risk and are solely responsible for compliance with local laws.
2. ACCOUNT REGISTRATION AND ACCESS
2.1 Eligibility
To use Thunder Pay, you must:
* Be at least 18 years old;
* Have the legal capacity to enter into binding agreements;
* Complete any required identity verification procedures;
* Provide accurate, complete, and current information.
Thunder Pay reserves the right to refuse registration, suspend access, or terminate accounts that do not meet these requirements.
2.2 Account Security
You are responsible for:
* Maintaining the confidentiality of your login credentials;
* Protecting your device and account access;
* Promptly notifying Thunder Pay of any unauthorized access or security breach.
Any activity conducted through your account shall be deemed authorized by you unless proven otherwise through our investigation process.
Thunder Pay shall not be liable for losses resulting from your failure to protect your account credentials.
2.3 Identity Verification
To comply with applicable laws, regulations, anti-money laundering requirements, and fraud prevention measures, Thunder Pay may require:
* Government-issued identification;
* Selfie verification;
* Proof of address;
* Source of funds documentation;
* Additional information as reasonably requested.
Failure to provide requested information may result in account restrictions, suspension, or termination.
2.4 Alerts, Notifications, and Communications
By creating an account, you consent to receive:
* Security alerts;
* Transaction notifications;
* Service announcements;
* Compliance notices;
* Promotional communications;
* Product updates.
These communications may be delivered via:
* Email;
* SMS;
* Push notifications;
* In-app notifications;
* Telephone calls where necessary.
Certain service-related communications are mandatory and cannot be disabled.
3. FEES, CHARGES, AND FINANCIAL TERMS
3.1 Service Fees
You agree to pay all applicable fees associated with your use of the Services.
Such fees may include:
* Transaction fees;
* Withdrawal fees;
* Conversion fees;
* Network fees;
* Card issuance fees;
* Card maintenance fees;
* Replacement fees;
* International transaction fees;
* Merchant processing fees;
* Cross-border payment fees;
* Account maintenance fees where applicable.
Applicable fees will be displayed within the platform or otherwise communicated before completion of a transaction where required.
Thunder Pay reserves the right to modify fees at any time.
3.2 Funding and Withdrawals
Users may fund their accounts through approved methods available on the platform.
Thunder Pay reserves the right to:
* Set minimum or maximum transaction limits;
* Delay withdrawals for security reviews;
* Conduct fraud investigations;
* Conduct compliance reviews;
* Request additional verification documentation.
All transactions remain subject to applicable laws and internal compliance procedures.
3.3 Cryptocurrency Transactions
Cryptocurrency transactions are irreversible once confirmed on the blockchain.
Users are solely responsible for:
* Entering correct wallet addresses;
* Selecting the correct blockchain network;
* Verifying transaction details before submission.
Thunder Pay shall not be responsible for losses resulting from incorrect wallet addresses, incompatible networks, user errors, or blockchain-related issues.
3.4 Exchange Rates
Where currency conversion occurs, Thunder Pay may apply exchange rates available at the time of processing.
Exchange rates may include:
* Market spreads;
* Liquidity provider charges;
* Banking partner fees;
* Service margins.
Rates may change without notice due to market conditions.
3.5 Taxes
Users are solely responsible for determining and paying any taxes, duties, levies, or governmental charges arising from their use of the Services.
Thunder Pay may withhold or report information where required by applicable law.
4. PROHIBITED ACTIVITIES
4.1 Restricted Activities
You may not use Thunder Pay for:
* Fraudulent activities;
* Money laundering;
* Terrorism financing;
* Sanctioned transactions;
* Human trafficking;
* Child exploitation;
* Illegal gambling;
* Ponzi or pyramid schemes;
* Unlicensed financial services;
* Unauthorized payment processing;
* Market manipulation;
* Cryptocurrency scams;
* Sale of illegal goods or services;
* Intellectual property infringement;
* Any unlawful purpose.
4.2 Compliance Monitoring
Thunder Pay reserves the right to monitor account activity and transactions for:
* Fraud prevention;
* Risk management;
* Regulatory compliance;
* Financial crime detection.
Suspicious activities may be reported to relevant authorities without prior notice.
4.3 Right to Amend Restrictions
Thunder Pay reserves the right to modify, expand, or amend prohibited activities at any time as necessary to:
* Comply with laws and regulations;
* Manage operational risks;
* Protect users;
* Protect the integrity of the platform.
Continued use of the Services constitutes acceptance of such changes.
5. ACCOUNT RESTRICTIONS, SUSPENSION, AND TERMINATION
Thunder Pay may suspend, restrict, freeze, or terminate accounts where:
* Fraud is suspected;
* Verification fails;
* Compliance concerns arise;
* Illegal activity is detected;
* Security risks are identified;
* Regulatory obligations require such action;
* Risk levels exceed acceptable thresholds.
Thunder Pay may place temporary holds on transactions pending review and investigation.
Funds may remain restricted until compliance obligations are satisfied.
6. CRYPTOCURRENCY RISK DISCLOSURE
You acknowledge that cryptocurrency transactions involve substantial risk, including:
* Market volatility;
* Rapid price fluctuations;
* Liquidity risks;
* Blockchain congestion;
* Smart contract failures;
* Regulatory changes;
* Network outages;
* Cybersecurity threats.
Past performance does not guarantee future results.
You accept full responsibility for evaluating these risks before using cryptocurrency-related Services.
7. REFERRAL, CASHBACK, REWARDS, AND INCENTIVES
Thunder Pay may operate promotional programs including:
* Bolt Rewards;
* Cashback programs;
* Referral incentives;
* Ambassador rewards;
* Marketing campaigns;
* Loyalty programs.
Thunder Pay reserves the right to:
* Modify reward structures;
* Change reward values;
* Adjust conversion rates;
* Disqualify participants;
* Reverse improperly earned rewards;
* Suspend fraudulent accounts.
All reward decisions made by Thunder Pay shall be final.
8. INTELLECTUAL PROPERTY
All intellectual property rights relating to Thunder Pay, including:
* Trademarks;
* Logos;
* Brand names;
* Software;
* Source code;
* Designs;
* Graphics;
* User interfaces;
* Documentation;
* Content;
remain the exclusive property of ThunderNetwork Limited or its licensors.
No rights are granted except as expressly stated in these Terms.
9. DISCLAIMER OF WARRANTIES
The Services are provided on an “as is” and “as available” basis.
Thunder Pay makes no warranties, express or implied, regarding:
* Availability;
* Reliability;
* Accuracy;
* Security;
* Fitness for a particular purpose;
* Continuous operation without interruption.
To the fullest extent permitted by law, all implied warranties are disclaimed.
10. LIMITATION OF LIABILITY
To the maximum extent permitted by law, Thunder Pay, ThunderNetwork Limited, its directors, officers, employees, affiliates, and partners shall not be liable for:
* Indirect losses;
* Consequential damages;
* Lost profits;
* Lost revenue;
* Lost business opportunities;
* Loss of digital assets;
* Third-party service failures;
* Blockchain network failures;
* Regulatory restrictions;
* Service interruptions beyond our reasonable control.
Thunder Pay’s total liability shall not exceed the amount of fees paid by the user to Thunder Pay during the six (6) months preceding the event giving rise to the claim.
11. GOVERNING LAW AND DISPUTE RESOLUTION
These Terms shall be governed by and interpreted in accordance with the laws of the Federal Republic of Nigeria.
Any dispute arising from or relating to these Terms or the Services shall be subject to the exclusive jurisdiction of the competent courts of Nigeria.
Nothing in these Terms shall prevent Thunder Pay from seeking injunctive or equitable relief where necessary.
12. CHANGES TO THESE TERMS
Thunder Pay may modify these Terms at any time.
Where required, users will be notified through:
* The app;
* Email;
* Website notices;
* Other communication channels.
Continued use of the Services following any updates constitutes acceptance of the revised Terms.
13. CONTACT INFORMATION
For questions regarding these Terms, our Privacy Policy, or any Thunder Pay service, please contact:
ThunderNetwork Limited
Thunder Pay (Pay With Thunder)
Email: support@paywiththunder.com
Web app: app.paywiththunder.com
Website: www.paywiththunder.com
By continuing to use Thunder Pay, you acknowledge that you have read, understood, and agreed to these Terms of Service, including all applicable fees, risks, restrictions, and compliance obligations.
THUNDER PAY REFUND POLICY Last Updated: June 2026 Notice Please note that your use of Thunder Pay’s Services is subject to this Refund Policy. By accessing or using Thunder Pay, you acknowledge and agree to the terms outlined below. Due to the nature of cryptocurrency transactions and financial services, not all transactions are eligible for refunds. Refund requests are reviewed on a case-by-case basis and remain subject to compliance, fraud prevention, and regulatory requirements. 1. INTRODUCTION 1.1 Purpose At Thunder Pay (“Thunder Pay,” “Thunder,” “we,” “our,” or “us”), we are committed to providing a transparent, secure, and reliable payment experience. This Refund Policy explains: * Which transactions may be eligible for refunds; * Circumstances under which refunds may be granted; * Refund review procedures; * Processing timelines; and * User responsibilities when requesting refunds. By using Thunder Pay, you agree to the terms of this Refund Policy. 1.2 Scope This Refund Policy applies to all Thunder Pay products and services, including but not limited to: Current Services * Cryptocurrency deposits * Cryptocurrency wallet services * Airtime purchases * Data bundle purchases * Electricity bill payments * Cable television subscriptions Additional Services (Current or Future) * Crypto-to-Naira transfers * Naira accounts * Fiat deposits and transfers * Virtual cards * Physical cards * International accounts * Multi-currency wallets * Cross-border payments * Cashback and rewards programs * Other financial technology services offered by Thunder Pay Refund eligibility may vary depending on the specific service involved. 2. GENERAL REFUND PRINCIPLES 2.1 Transaction Finality Many transactions processed through Thunder Pay are irreversible once successfully completed. Refund eligibility depends on: * The type of transaction; * Transaction status; * Whether the issue originated from Thunder Pay or a third-party provider; * Applicable regulatory requirements; * Fraud and compliance review outcomes. Submission of a refund request does not guarantee approval. 2.2 Review Process All refund requests are subject to review by: * Customer Support; * Risk Management Teams; * Compliance Teams; * Fraud Prevention Teams where applicable. Thunder Pay reserves the right to request additional information before determining refund eligibility. 3. CRYPTOCURRENCY DEPOSITS 3.1 Successful Crypto Deposits Once a cryptocurrency deposit has been successfully confirmed on the blockchain and credited to a user’s Thunder wallet, the deposit is generally non-refundable. Users are solely responsible for: * Selecting the correct cryptocurrency; * Using the correct wallet address; * Choosing the correct blockchain network; * Verifying transaction details before submission. 3.2 User Errors Thunder Pay shall not be responsible for losses arising from: * Deposits sent to incorrect wallet addresses; * Unsupported tokens or assets; * Incorrect blockchain network selection; * User input errors; * Transactions sent to third-party wallets outside Thunder Pay’s control. Such transactions are generally not eligible for refunds. 4. BILL PAYMENT SERVICES 4.1 Covered Services This section applies to: * Airtime purchases; * Data bundle purchases; * Electricity bill payments; * Cable television subscriptions; * Any similar utility payment services offered by Thunder Pay. 4.2 Successful Transactions Where a payment has been successfully processed and delivered to the relevant service provider, the transaction is considered final and is generally not refundable. 4.3 Failed Transactions Where: * Funds are debited; and * The requested service is not delivered, Thunder Pay will investigate the transaction. Where the failure is confirmed, Thunder Pay may: * Reprocess the transaction; * Credit the affected account; or * Issue a refund where appropriate. Refund approval remains subject to verification from the relevant service provider. 5. CRYPTO-TO-NAIRA TRANSFERS 5.1 Successful Transfers Where cryptocurrency has been successfully converted and Naira settlement has been completed to the intended recipient, the transaction is final and cannot be reversed. 5.2 Failed Settlements Where: * Cryptocurrency has been debited; but * Naira settlement fails or remains incomplete, Thunder Pay will investigate the transaction and may: * Complete the settlement; * Reverse the transaction where technically possible; or * Refund the equivalent value where appropriate. Additional compliance verification may be required before any refund is approved. 6. NAIRA DEPOSITS AND TRANSFERS 6.1 Naira Deposits Successfully credited Naira deposits are generally non-refundable. Exceptions may include: * Duplicate funding; * System processing errors; * Unauthorized transactions confirmed after investigation. 6.2 Naira Transfers Completed transfers to valid bank accounts are final and cannot ordinarily be reversed. Users are responsible for ensuring: * Correct account numbers; * Correct recipient names; * Accurate transfer details. Thunder Pay shall not be liable for losses resulting from incorrect beneficiary information supplied by the user. 7. CARD SERVICES 7.1 Virtual and Physical Cards Where Thunder Pay offers virtual cards, physical cards, or card-related services: * Card issuance fees are generally non-refundable once a card has been successfully issued; * Subscription or maintenance fees may be non-refundable unless otherwise required by law; * Merchant disputes remain subject to the applicable card network’s dispute and chargeback procedures. Refund eligibility may vary depending on the specific card product and provider requirements. 8. CASHBACK, REWARDS, REFERRALS, AND BOLT CREDITS 8.1 Rewards Programs Thunder Pay may operate various incentive programs including: * Bolt Rewards; * Cashback campaigns; * Referral rewards; * Ambassador rewards; * Promotional bonuses; * Loyalty programs. 8.2 Reward Adjustments Thunder Pay reserves the right to: * Modify reward structures; * Adjust reward values; * Change conversion rates; * Suspend campaigns; * Reverse rewards obtained through abuse, fraud, manipulation, or system errors. 8.3 Bolt Credits Bolt Credits and similar promotional rewards: * Are promotional in nature; * May not have direct cash value; * Are subject to Thunder Pay’s reward policies; * May expire where permitted by applicable law. 9. FRAUD, ABUSE, AND COMPLIANCE REVIEWS Thunder Pay reserves the right to: * Delay transactions; * Restrict transactions; * Freeze accounts; * Suspend withdrawals; * Hold refunds pending review. Such actions may be necessary for: * Fraud investigations; * Regulatory obligations; * AML compliance; * Counter-terrorism financing reviews; * Sanctions screening; * Risk management procedures. Accounts found to be involved in prohibited activities may lose refund eligibility entirely. 10. UNAUTHORIZED ACTIVITY AND ACCOUNT COMPROMISE Users must immediately notify Thunder Pay if they believe: * Their account has been compromised; * Their credentials have been exposed; * Unauthorized transactions have occurred. Thunder Pay will investigate reported incidents and determine appropriate remedies based on available evidence and applicable regulations. Refund requests relating to unauthorized activity are evaluated on a case-by-case basis. 11. REFUND PROCESSING TIMELINES 11.1 Approved Refunds Where a refund is approved: Internal Wallet Refunds Typically processed within: 24 to 72 hours Third-Party Provider Refunds May require additional processing time depending on: * Banking partners; * Card providers; * Utility providers; * Payment processors; * Regulatory requirements. 11.2 Compliance Delays Certain refunds may require enhanced verification procedures. Where legally required, refund processing may be delayed pending: * Identity verification; * Compliance reviews; * Regulatory reporting obligations. Thunder Pay shall not be liable for delays resulting from such requirements. 12. HOW TO REQUEST A REFUND To submit a refund request, users should provide: * Full name; * Registered email address; * Transaction reference number; * Transaction date; * Description of the issue; * Any supporting documentation requested by Thunder Pay. Refund requests may be submitted through: * In-app support; * Official customer support channels; * Official support email. Incomplete requests may delay review and processing. 13. CHANGES TO THIS POLICY Thunder Pay reserves the right to update, amend, or modify this Refund Policy at any time. Updates may be communicated through: * The Thunder Pay application; * Email communications; * Website notices; * Other official communication channels. Continued use of the Services following publication of updates constitutes acceptance of the revised Refund Policy. CONTACT INFORMATION For refund-related inquiries, disputes, or support requests, please contact: ThunderNetwork Limited Thunder Pay (Pay With Thunder) Email: support@paywiththunder.com Website: app.paywiththunder.com Instagram: @paywiththunder By using Thunder Pay, you acknowledge that you have read, understood, and agreed to this Refund Policy.