General Acceptable Use Policy

1. Purpose and Scope

2. General Principles

3. Prohibited Financial Activities

• Engage in money laundering, terrorist financing, proliferation financing, or any other financial crime as defined under the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, and the Proceeds of Crime (Recovery and Management) Act 2022.
• Transact with, on behalf of, or for the benefit of any person or entity appearing on: (i) the OFAC Specially Designated Nationals (SDN) list; (ii) the UN Security Council Consolidated Sanctions List; (iii) any Nigerian government sanctions list; or (iv) any other applicable sanctions list.
• Structure transactions to evade reporting obligations, including splitting payments below regulatory thresholds ('smurfing').
• Process transactions linked to illegal arms dealing, the trade of protected wildlife, or trafficking in human beings; or
• Operate or participate in any financial pyramid scheme, Ponzi scheme, or investment arrangement that violates Applicable Law.

• Process transactions involving stolen, unauthorised, or fraudulently obtained payment credentials.
• Submit false, fabricated, or inflated invoices or transaction records.
• Use another person's identity, BVN, account details, or payment instrument without authorisation.
• Initiate or participate in chargeback fraud ('friendly fraud') or return fraud.
• Conduct wash trading, round-tripping, or any other scheme designed to artificially inflate transaction volumes or revenues; or
• Use the Platform to receive, hold, or transfer funds on behalf of a third party without the appropriate regulatory authorisation.

• Accepting deposits from the public without a CBN banking licence.
• Operating a payment service or switching service without a CBN Payment Service Provider licence.
• Operating a virtual assets exchange or wallet without a valid SEC VASP registration; or
• Providing insurance intermediation without NAICOM authorisation.
• Providing insurance intermediation without NAICOM authorisation.

4. Prohibited Business Categories

• Sale, distribution, or facilitation of the trade in controlled or prohibited drugs and substances under the NDLEA Act.
• Sale of prescription medications without a valid pharmacy licence and NAFDAC authorisation.
• Unlicensed trade in firearms, ammunition, or military equipment.
• Sale of counterfeit, pirated, or intellectual property-infringing goods.
• Sale of illegally obtained wildlife or wildlife products.
• Distribution of child sexual abuse material (CSAM) or any content that sexually exploits minors.

• Adult entertainment platforms, including pornographic content distribution services.
• Escort services or platforms facilitating commercial sex work.
• Any service that facilitates sexual exploitation or trafficking.

• Online gambling, sports betting, casino operations, or lottery services unless operated under a valid licence issued by the National Lottery Regulatory Commission (NLRC), Lagos State Lotteries and Gaming Authority (LSLGA), or other competent licensing authority.
• Unlicensed peer-to-peer betting exchanges or prediction markets.

• Operation of a virtual asset exchange, broker, or custodian service without a valid SEC VASP registration.
• Promotion of initial coin offerings (ICOs), token sales, or digital asset investment schemes without regulatory approval.
• Use of the Platform to circumvent CBN guidelines on virtual assets or cryptocurrency transactions.

• Multi-level marketing (MLM) operations structured in violation of Applicable Law.
• Get-rich-quick schemes, high-yield investment programmes (HYIPs), or Ponzi structures.
• Collection of funds for politically exposed organisations or political campaigns without compliance with applicable campaign finance law.
• Debt collection services that violate FCCPA consumer protection provisions.
• Debt collection services that violate FCCPA consumer protection provisions.
• Any business Ascent determines, in its reasonable discretion, to pose an unacceptable legal, reputational, or compliance risk.

5. Prohibited Technical and Platform Conduct

• Access the Platform or any part of its systems, networks, or infrastructure without authorisation.
• Attempt to gain unauthorised access to another user's Account, data, or resources.
• Exploit, probe, or test the security of the Platform or its supporting infrastructure without Ascent's prior written authorisation (i.e., outside of an agreed bug bounty programme).
• Bypass, disable, or circumvent any authentication, security, or access control mechanism on the Platform.
• Use stolen credentials, session hijacking, or brute-force attacks to access the Platform.
• Interfere with, disrupt, or degrade the performance, availability, or integrity of the Platform or its servers; or
• Launch or participate in any distributed denial-of-service (DDoS) attack or any other cyber attack against the Platform or its infrastructure.

• Computer virus, worm, trojan horse, ransomware, spyware, or adware.
• Keystroke logger, rootkit, or other surveillance or data-exfiltration software.
• Any code or script designed to interfere with, corrupt, or destroy data, software, or hardware; or
• Any software designed to exploit vulnerabilities in Ascent's systems or those of other users.

• Use bots, spiders, crawlers, scrapers, or other automated tools to access, extract, or harvest data from the Platform, except through APIs provided by Ascent for that purpose.
• Conduct bulk or automated account creation.
• Engage in any activity that imposes an unreasonably large or disproportionate load on Ascent's infrastructure; or
• Use the Platform to train, fine-tune, or develop artificial intelligence or machine learning models without Ascent's prior written authorisation.

• Reverse engineer, decompile, disassemble, or attempt to derive the source code of any component of the Platform.
• Copy, modify, adapt, translate, or create derivative works based on the Platform's software or content.
• Remove, alter, or obscure any copyright, trademark, or proprietary rights notice on the Platform; or
• Frame, mirror, or embed the Platform or any part of it on any other website or application without Ascent's written consent.

6. Prohibited Content and Communications

• Is false, misleading, defamatory, or constitutes fraud or misrepresentation.
• Is obscene, offensive, threatening, abusive, or constitutes harassment or hate speech targeting individuals or groups based on race, ethnicity, religion, gender, sexual orientation, disability, or any other protected characteristic.
• Infringes the copyright, trade mark, patent, trade secret, or other Intellectual Property rights of any third party.
• Constitutes unsolicited commercial communication (spam) or mass marketing without valid consent.
• Facilitates or encourages any illegal activity; or
• Violates the privacy, dignity, or data protection rights of any person.

• Impersonate Ascent, its employees, officers, or representatives.
• Impersonate any other person, organisation, or regulatory body.
• Create a false or misleading impression of their identity, qualifications, or regulatory status; or
• Represent that Ascent endorses, approves of, or is affiliated with any product, service, or activity without Ascent's express written consent.

7. Responsible Disclosure and Security Reporting

8. Monitoring and Enforcement

• Issue a formal warning to the User.
• Temporarily suspend the User's Account or restrict access to specific Platform features.
• Place a hold on settlement or funds pending investigation.
• Permanently terminate the User's Account.
• Remove, disable, or flag any content or transaction that violates this AUP.
• Report the violation to relevant law enforcement or regulatory authorities, including the EFCC, NPF, CBN, NDPC, or FCCPC.
• Pursue civil or criminal remedies available under Applicable Law.

9. User Reporting

10. Liability for Violations

11. Amendments

12. Governing Law

13. Contact