Who we are, what we're building, and where we're going next.
Everything you need to move, spend and grow your money — in one app.
Collect payments, pay staff and grow your operations with ComePay Business.
Hold, send and convert money in 7 global currencies at interbank rates.
These Terms of Service ("Terms", "Agreement") govern your access to and use of the mobile applications, websites, APIs, and financial services provided by Cometstar Technologies Limited and ComePay (collectively, "ComePay", "we", "us", or "our"). By creating an account, downloading the ComePay application, or utilizing any of our services, you ("User", "Customer", "Merchant", "Agent") agree to be bound by these Terms.
To utilize ComePay services, you must be at least 18 years of age (or legal age in your jurisdiction) and possess full capacity to enter into binding agreements. During registration, you must provide accurate, complete, and up-to-date information, including your legal name, residential address, legal identification document, phone number, and Bank Verification Number (BVN) or National Identification Number (NIN) where applicable.
You are strictly responsible for maintaining the confidentiality of your credentials, including account passwords, Transaction PINs, and One-Time Passwords (OTPs). Any activity conducted through your account will be deemed authorized by you.
ComePay facilitates virtual bank account creation to enable seamless local transfers and wallet funding. You acknowledge and accept that ComePay is not a bank or deposit-taking institution. Funds maintained in your ComePay wallet are held in segregated trust/custodial accounts maintained at CBN-licensed financial institutions.
You agree not to use ComePay for any unlawful, fraudulent, or abusive activities. Prohibited activities include, but are not limited to:
Applicable fees for transactions (including transfer charges, POS processing rates, bill payment convenience fees, FX conversion spreads, and card issuance costs) are displayed transparently prior to transaction execution or outlined in public fee schedules. ComePay reserves the right to adjust fee structures upon prior notice.
ComePay reserves the right to restrict, suspend, or terminate your account immediately without prior notice if: (i) required by law enforcement or regulatory authorities; (ii) we detect suspicious or fraudulent activity; (iii) you breach any provision of these Terms; or (iv) your account presents unacceptable legal or security risks.
To the maximum extent permitted by law, ComePay, its parent company Cometstar Technologies Limited, directors, employees, and partners shall not be liable for any indirect, incidental, or consequential damages arising from service interruptions, banking network downtime, third-party software failures, or unauthorized access to your account resulting from negligence on your part.
ComePay is committed to protecting consumer privacy and personal data. This Privacy Policy outlines our compliance with the Nigeria Data Protection Act (NDPA) 2023, the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), and international data protection standards.
We collect personal information necessary to fulfill our service delivery and regulatory obligations, including:
Your data is processed strictly for legal and operational purposes: verifying your identity via automated identity verification services (e.g., Prembly); processing payments and transfers; issuing virtual cards; managing POS agent terminals; detecting financial fraud; communicating service updates via Termii/Zendesk; and complying with regulatory reporting.
We do not sell consumer data. We share your personal data only with trusted third-party processors necessary for core service fulfillment, including: CBN-regulated banking partners (for account generation and settlement); PCI-DSS card processors (Bridgecard); identity verification platforms (Prembly); SMS/OTP routing gateways (Termii); and regulatory bodies (CBN, NFIU, FINTRAC) when legally required.
We employ industry-standard encryption (TLS 1.3 in transit and AES-256 at rest), firewall defenses, and access controls to safeguard your information. Regulatory frameworks require us to retain customer KYC and transaction data for a minimum of five (5) to seven (7) years following account termination.
This Agreement governs all business entities, merchants, and field agents utilizing the ComePay Business application, merchant web portal, and Horizonpay Smart POS terminals for agency banking, cash-in/cash-out (CICO), card processing, and merchant collection operations.
Smart POS terminals (including Horizonpay S60 devices) deployed to agents remain the property of Cometstar Technologies Limited unless explicitly purchased under a buyout agreement. Merchants/agents agree to: (i) keep hardware in good working condition; (ii) prevent unauthorized software modifications; (iii) report stolen or damaged hardware within 12 hours; and (iv) return assigned hardware upon account closure.
ComePay facilitates instant or batch settlement into merchant wallets for legitimate card roll, transfer, and POS transactions, subject to partner bank clearing windows and risk monitoring holds. ComePay reserves the right to hold settlement funds suspected of chargeback exposure, card fraud, or system manipulation.
Agents operating on the ComePay network must strictly adhere to the following principles:
Agents and merchants are fully liable for fraudulent transactions, card skimming attempts, or chargebacks arising from failure to follow operational verification guidelines. ComePay is authorized to debit the agent's wallet or offset future earnings to recover chargeback losses.
Cross-border remittance and international money transfer services offered via ComePay are operated in compliance with FINTRAC Canada MSB registration standards (Registration No. M24892147). Transfers must comply with the Canadian Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and applicable Nigerian foreign exchange regulations.
Foreign exchange (FX) rates offered on ComePay are dynamic and calculated based on prevailing interbank rates plus an operational margin. The total payable amount, exchange rate, guaranteed delivery amount, and transfer fees are explicitly presented to the sender prior to transaction confirmation.
Remittance transfers are subject to daily, weekly, and monthly limits based on user verification tiers. Transfers exceeding specified thresholds require Enhanced Due Diligence (EDD), including proof of source of funds, bank statements, and destination relationship confirmation.
While most cross-border transactions settle instantly or within a few business hours, delivery timelines may vary due to correspondent bank processing windows, compliance reviews, or regional holidays. Senders may request a transfer cancellation and refund only if the payout has not already been disbursed or settled to the beneficiary.
Virtual and physical debit payment cards available on ComePay are issued by licensed issuing financial institution partners and technical aggregators (Bridgecard). By creating or requesting a ComePay Card, you accept the card scheme rules (Mastercard/Visa/Verve) and issuer terms.
Cards issued under ComePay may be utilized for online e-commerce transactions, subscription renewals, POS terminal payments, and ATM cash withdrawals (physical cards only). Cards must not be used for illegal online purchases, prohibited merchant categories, or unauthorized currency arbitrage schemes.
Card transactions are debited directly from your associated ComePay card wallet balance. Pre-authorizations by merchants (e.g., hotels, rideshare services) may result in temporary authorization holds on your funds until final settlement.
You are strictly responsible for safeguarding card details (16-digit PAN, CVV, expiry date, PIN). If you suspect your card has been compromised, lost, or stolen, you must freeze the card immediately within the ComePay application and notify support.
Cometstar Technologies Limited and ComePay maintain a strict zero-tolerance policy towards money laundering, financial crime, and terrorism financing. Our AML program is designed in alignment with CBN AML/CFT Regulations, NFIU guidelines, and Canadian PCMLTFA regulations.
To balance financial inclusion with risk mitigation, ComePay enforces a tiered Customer Due Diligence (CDD) structure:
| KYC Tier | Requirements | Daily Limit | Max Wallet Balance |
|---|---|---|---|
| Tier 1 (Basic) | Phone Number, Full Name, Basic Identity Verification | ₦50,000 / $100 | ₦300,000 / $500 |
| Tier 2 (Standard) | BVN, Verified NIN, Government Photo ID | ₦200,000 / $1,000 | ₦500,000 / $2,500 |
| Tier 3 (Enhanced) | Proof of Address (Utility Bill), Live Selfie, In-Person Verification | ₦5,000,000+ / Custom | Unlimited |
All transactions are screened in real-time using automated transaction monitoring tools. Suspicious patterns — such as rapid velocity spikes, unusual high-value transfers, or structured deposits — will trigger account freezes and mandatory Suspicious Transaction Reports (STRs) to the Nigerian Financial Intelligence Unit (NFIU) or FINTRAC Canada.
All customers and ultimate beneficial owners are screened against global sanction lists (UN, OFAC, EU, UK, Canada) and Politically Exposed Persons (PEP) databases prior to onboarding and on an ongoing automated basis.