Legal Notice

Last updated: August 2026

Version: 1.1

Note: This English version is provided for convenience. In the event of any discrepancy or ambiguity, the French version (Mentions Légales) shall prevail and is the legally binding text.

Preamble

This legal notice sets out the terms of access to and use of the Kodo platform, operated by Kodo Financial Technology Inc. By accessing the Kodo platform, you acknowledge that you have read, understood, and accepted this legal notice in full. If you do not accept this legal notice, please stop using the platform immediately.

1. Publisher identity

1.1 Parent company and primary operator

Kodo Financial Technology Inc. A company incorporated under the laws of the State of Delaware (United States) Registered with the Delaware Secretary of State

Registered office address: 254 Chapman Rd, Ste 208 #28536 Newark, Delaware 19702 United States of America

General contact: Via the Kodo mobile app (Settings > Help & Support > Contact us) or by email at hello@kodo.sn

1.2 Operating subsidiary in Senegal

Kodo Financial Technology SAS A simplified joint-stock company (SAS) under Senegalese law Senegal

The Senegalese subsidiary, Kodo Financial Technology SAS, carries out local operations in Senegal and acts on behalf of Kodo Financial Technology Inc. in providing services to users based in Senegal.

1.3 Platform identification

Trade name: Kodo
Mobile app: Kodo (available on the App Store and Google Play)
Website: https://www.kodo.sn

2. Nature of the business and legal framework

2.1 Description of the business

Kodo is a digital platform that centralizes payments for essential services in Senegal, for residents and the Senegalese diaspora alike, with a built-in loyalty program (Kodo Points). It allows users to easily and quickly access the following services, exclusively for phone numbers and meters located in Senegal:

Prepaid mobile airtime top-ups
Mobile data top-ups
Water bill payments (SENEAU)
Electricity bill payments (SENELEC)
Prepaid electricity top-ups (Woyofal)

Kodo acts as a reseller of third-party services, relying on partner service aggregators for the actual delivery of these services to end users.

2.2 What Kodo is not

It is expressly stated that Kodo is not:

A regulated payment service provider or a licensed payment institution
A bank, financial institution, or credit institution
An e-money operator or electronic wallet
A financial intermediary or money transmission agent
A telecommunications operator

Kodo does not collect, hold, manage, or transfer users' funds within the meaning of payment services regulation. Payment processing is carried out exclusively by licensed third-party payment service providers (Orange Money, Wave, banking networks).

2.3 Applicable regulatory framework

Kodo operates as a service reseller and is subject to the regulations of the jurisdictions in which it operates. The parent company is governed by the laws of the State of Delaware (United States). The Senegalese subsidiary is subject to the laws and regulations of the Republic of Senegal.

3. Integrated payment services

3.1 Accepted payment methods

To pay for the services offered on the platform, users can use the following payment methods:

Orange Money: An electronic wallet service operated by Orange Sénégal
Wave: A mobile payment and money transfer app
Bank cards: Visa and Mastercard, processed via a secure payment gateway

3.2 Payment processing

Payments are processed by third-party payment service providers. Kodo does not store users' bank card information. All financial transactions are secured and encrypted in accordance with applicable security standards.

3.3 Fee policy

Kodo does not charge users any service fees. Transaction processing fees are fully covered by Kodo.

4. Kodo Points loyalty program

4.1 Nature of Kodo Points

Kodo offers an internal loyalty program called "Kodo Points." It is expressly stated that Kodo Points:

Do not constitute electronic money within the meaning of applicable regulations
Have no monetary value outside the Kodo platform
Cannot be exchanged for real money or other assets
Cannot be transferred between users
Can only be used exclusively within the Kodo ecosystem

4.2 Accumulation

For every 100 FCFA spent on the Kodo platform, the user earns 1 Kodo Point. Points are credited automatically to the user's account after payment confirmation.

4.3 Use

Kodo Points can be used to access perks, discounts, or special offers available exclusively on the Kodo platform, on terms defined by Kodo.

5. Publisher liability

5.1 General liability

Kodo strives to provide accurate and up-to-date information on its platform. However, Kodo cannot guarantee the accuracy, completeness, or relevance of the information available.

Kodo cannot be held liable for direct or indirect damages resulting from use of the platform, including, but not limited to:

Errors in published information
Technical compatibility issues
Service interruptions or unavailability
Failures on the part of third-party providers

5.2 Liability of third-party providers

Kodo cannot be held liable for the acts, omissions, or failures of its third-party providers (service aggregators, telecommunications operators, payment service providers) in delivering services. Kodo acts solely as an intermediary between users and these providers.

5.3 Liability cap

To the extent permitted by law, Kodo's total liability to a user cannot exceed the total amount of transactions made by that user over the 30 days preceding the occurrence of the damage.

6. Intellectual property

6.1 Kodo's rights

All elements making up the Kodo platform (including, without limitation, text, images, logos, trademarks, icons, graphics, brand guidelines, source code, features, databases, algorithms, and all content) are protected by applicable intellectual property rights and are the exclusive property of Kodo Financial Technology Inc. or its licensors.

The "Kodo" brand, the Kodo logo, and all associated distinctive signs are registered or pending trademarks of Kodo Financial Technology Inc.

6.2 Usage restrictions

Without Kodo's prior written authorization, it is strictly forbidden to:

Reproduce, copy, download, or print all or part of the platform's content
Modify, adapt, translate, or create derivative works from the content
Use the content for commercial or advertising purposes
Remove or alter intellectual property notices
Decompile, disassemble, or reverse-engineer the platform's code
Reproduce or imitate the platform's appearance, design, or functionality

6.3 License to use

Kodo grants you a personal, non-exclusive, non-transferable, and revocable license to access and use the platform in accordance with this legal notice and the Terms of Use.

6.4 Hyperlinks

Creating hyperlinks to the Kodo platform requires Kodo's prior written authorization. Kodo is not responsible for the content of third-party sites that link to its platform.

7. Personal data and cookies

7.1 Data protection policy

Kodo collects and processes personal data in connection with use of the platform. This data is processed in accordance with Kodo's Privacy Policy, which forms an integral part of this legal notice.

7.2 Cookies

The Kodo platform uses cookies and similar tracking technologies to improve the user experience, analyze platform usage, and secure transactions. You can configure your browser or device to refuse cookies, but this may affect how the platform works.

8. Service availability

8.1 Availability commitment

Kodo strives to keep its platform available 24 hours a day, 7 days a week, 365 days a year. However, interruptions may occur for reasons of technical maintenance, security, or external causes beyond Kodo's control.

8.2 Scheduled maintenance

In the event of scheduled maintenance likely to affect service availability, Kodo commits to informing users in advance via available communication channels (in-app notification, email if available).

8.3 Emergency interruptions

Kodo reserves the right to interrupt the service without notice in the event of an emergency related to security, platform integrity, or user protection.

9. Governing law and jurisdiction

9.1 Applicable law

This legal notice is governed by:

The law of the State of Delaware (United States) with respect to the parent company, Kodo Financial Technology Inc.
The law of the Republic of Senegal with respect to services provided to users in Senegal by the subsidiary, Kodo Financial Technology SAS

9.2 Dispute resolution

Any dispute relating to the interpretation or performance of this legal notice shall first be submitted to an attempt at amicable resolution. Should this fail, the parties agree to resort to mediation before any legal action.

9.3 Jurisdiction

Should amicable resolution or mediation prove impossible, any dispute relating to the parent company shall be submitted to the competent courts of the State of Delaware (United States). Disputes involving users in Senegal and relating to services provided by the subsidiary may be submitted to the competent courts of Senegal.

10. Changes to this legal notice

Kodo reserves the right to modify this legal notice at any time and without notice. Changes take effect as soon as they are published on the platform.

It is your responsibility to check this legal notice regularly for any changes. Continued use of the platform after a change to the legal notice constitutes your acceptance of the new provisions.

11. Severability

If any provision of this legal notice is declared void or unenforceable by a court decision, the other provisions shall remain in full force and effect.

12. Contact

For any question, request, or complaint relating to this legal notice, you can contact us:

Via the app: Settings menu > Help & Support > Contact us

By email: hello@kodo.sn

By post: Kodo Financial Technology Inc., 254 Chapman Rd, Ste 208 #28536, Newark, Delaware 19702, United States of America

Response time: We are committed to responding to any request within a reasonable time, generally within 7 business days and 30 days maximum.

Legal Notice.