Terms of Use
Last updated: June 30, 2026
These Terms of Use govern your access to and use of Kairo's products and services — Kairo Personal, Kairo Business, and Kairo Enterprise (together, the “Services”) — provided by First Frontier Technologies Limited, a company incorporated in Nigeria with its registered address at 4b Babatope Bejide Street, Lekki Phase 1, Lagos.
By creating a Kairo account, accessing Kairo through WhatsApp or any other channel, or otherwise using any Kairo Service, you agree to be bound by these Terms. If you are using Kairo Business or Kairo Enterprise on behalf of a company or other legal entity, you represent that you have the authority to bind that entity to these Terms, and “you” refers to both you individually and that entity.
If you do not agree to these Terms, you must not access or use the Services.
These Terms apply to all three Services. Sections 3, 4, and 5 set out provisions specific to each product; all other sections apply across all Services unless stated otherwise.
Eligibility
To use Kairo's Services, you must:
- Be at least 18 years old, or the minimum age required under applicable law to enter binding financial agreements and hold a BVN.
- Have the legal capacity to enter into a binding contract.
- Possess a valid Bank Verification Number (BVN) or other identity credential acceptable to Kairo, where required to activate a wallet.
- Not be barred from using financial services under any applicable law, including sanctions, anti-money laundering (AML), or counter-terrorism financing (CTF) regulations.
- For Kairo Business: be authorized to act on behalf of the business you are registering, where applicable.
- For Kairo Enterprise: be a duly licensed or regulated financial institution, or an entity otherwise approved by Kairo to access Enterprise products, and have entered into an applicable Master Services Agreement.
Kairo reserves the right to refuse, suspend, or terminate access to the Services for any person or entity that does not meet, or ceases to meet, these eligibility requirements.
Kairo Personal — Terms of Use
2.1 Wallet services
Kairo Personal provides you with a digital wallet in accordance with applicable Central Bank of Nigeria regulations. Funds held in your Kairo wallet are subject to applicable banking and e-money regulations.
2.2 Sending and receiving money
You may use Kairo Personal to send and receive money, pay bills, and make purchases by communicating your instructions via WhatsApp, voice, chat, or other supported channels. You are responsible for the accuracy of the instructions you provide — including recipient details, amounts, and payment references — and Kairo is not liable for funds sent to an incorrect recipient as a result of inaccurate information you provided.
2.3 Transaction confirmation
Kairo will, wherever reasonably possible, present a summary of your intended transaction (recipient, amount, and source) for your confirmation before the transaction is executed. By confirming — whether by tapping a button, replying “yes,” or other affirmative action — you authorize Kairo to execute that transaction.
2.4 Wallet limits
Your wallet may be subject to transaction and balance limits based on your verification tier (e.g., BVN-verified status), as required by applicable CBN tiered KYC regulations. These limits may change from time to time and will be communicated to you through the Services.
2.5 Promotional credits and referral bonuses
From time to time, Kairo may provide promotional credits, welcome bonuses, or referral rewards (such as airtime or wallet credit) subject to specific terms communicated at the time of the offer, including expiry periods. Kairo reserves the right to reclaim or void promotional credits obtained fraudulently or in violation of these Terms.
Kairo Business — Terms of Use
3.1 Business wallet and account
Kairo Business provides a business wallet, invoicing tools, a storefront, and related features to help you collect payments and operate your business through WhatsApp and the Kairo web dashboard. Your business wallet is subject to the same regulatory framework applicable to Kairo Personal wallet services.
3.2 Storefront content
You are solely responsible for the accuracy, legality, and appropriateness of all content you upload to your Kairo storefront, including product listings, descriptions, prices, and images. You represent that you have the right to sell the products or services you list, and that your listings do not infringe any third party's intellectual property or violate applicable law.
3.3 Invoicing and payment collection
You are responsible for ensuring that invoices you send through Kairo accurately reflect the goods or services provided and the amounts owed. Kairo facilitates the transmission and payment of invoices but is not a party to the underlying transaction between you and your customer, and is not responsible for disputes regarding the quality, delivery, or fitness of goods or services sold.
3.4 AI auto-responder
If you enable Kairo's AI-powered auto-responder to handle customer inquiries on your behalf, you acknowledge that responses are generated by an automated system based on information you provide (such as your storefront catalogue and business details). You are responsible for reviewing and ensuring the accuracy of the information used to power these responses, and Kairo is not liable for losses arising from inaccurate information you provided to the system.
3.5 Subscription plans and billing
Kairo Business offers tiered plans (including a free Starter tier and paid Growth tier) as described on our pricing page. Paid subscriptions are billed in advance on a recurring basis and will automatically renew unless cancelled prior to the renewal date. Transaction fees applicable to your plan are disclosed at the time of each transaction or in your account settings.
3.6 Customer data you upload
Where you upload customer contact lists or other customer data to Kairo Business, you represent that you have the necessary rights and consents to share that data with Kairo for the purposes of providing the Services (including sending promotions and invoices on your behalf), in compliance with applicable data protection law.
Kairo Enterprise — Terms of Use
4.1 Relationship to the Master Services Agreement
Access to and use of Kairo Enterprise products (including Reconcile, Fraud, Support, Flow, Relay, Insight, and Risk) by a financial institution or other licensed entity (“Enterprise Client”) is governed primarily by a separate Master Services Agreement (“MSA”) and accompanying Data Processing Agreement (“DPA”) entered into between Kairo and the Enterprise Client. These Terms apply to the extent not superseded by the specific provisions of the applicable MSA.
4.2 License grant
Subject to the MSA and payment of applicable fees, Kairo grants the Enterprise Client a non-exclusive, non-transferable license to access and use the contracted Kairo Enterprise products for the Enterprise Client's internal business operations, for the duration of the applicable subscription term.
4.3 API access and integration
Enterprise Clients accessing Kairo's products via API are responsible for the security of their own API credentials and for ensuring their integration complies with any technical and security requirements specified by Kairo. Kairo reserves the right to suspend API access that poses a security risk or violates rate limits or usage terms specified in the applicable MSA.
4.4 Data processing role
Where Kairo processes data on behalf of an Enterprise Client relating to that client's own customers, Kairo acts as a data processor under the client's instructions, as set out in the applicable DPA. The Enterprise Client remains the data controller responsible for ensuring it has appropriate legal basis to share such data with Kairo.
4.5 Service levels and support
Specific service level commitments (including uptime, response times, and support availability) applicable to Enterprise Clients are set out in the applicable MSA or a separate Service Level Agreement (SLA), and are not modified by these general Terms.
4.6 Pilot programs
Where Kairo and an Enterprise Client agree to a pilot or trial period, the terms of that pilot (including duration, scope, and any special pricing) will be set out in a separate pilot agreement or order form, which will govern in the event of any conflict with these Terms.
5. Account Registration & Identity Verification
To activate a Kairo Personal or Kairo Business wallet, you must complete identity verification, including providing your Bank Verification Number (BVN) and confirming the identity details returned by the verification process, as described in our Privacy Policy.
- You agree to provide accurate, current, and complete information during registration and to keep such information updated.
- You are responsible for maintaining the confidentiality and security of your account and any credentials associated with it.
- You agree to notify Kairo immediately of any unauthorized use of your account or any other breach of security.
- Kairo reserves the right to decline registration, or to suspend a wallet, where identity verification fails, raises fraud or compliance concerns, or where required by applicable law.
- You may only maintain one personal Kairo wallet linked to a single verified identity, unless otherwise permitted by Kairo.
Fees & Charges
Transaction fees as disclosed at time of transaction; subject to change with notice.
- Kairo Personal — wallet transactions
- Transaction fees as disclosed at time of transaction; subject to change with notice
- Kairo Business — Starter plan
- Free; transaction fee per payment collected, as disclosed in-app
- Kairo Business — Growth plan
- Recurring monthly subscription fee; reduced/zero transaction fees up to a stated monthly volume
- Kairo Enterprise
- As set out in the applicable Master Services Agreement and order form, which may include onboarding fees, per-instruction/usage-based fees, and recurring license fees
Kairo reserves the right to change its fees from time to time. For Kairo Personal and Kairo Business, material fee changes will be communicated to you with reasonable advance notice through the Services. For Kairo Enterprise, fee changes are governed by the applicable MSA. Continued use of the Services after a fee change takes effect constitutes acceptance of the new fees.
You are responsible for any third-party charges (such as charges from your bank, mobile network operator, or internet service provider) incurred in connection with your use of the Services.
Prohibited Uses
You agree not to use the Services to:
- Engage in money laundering, terrorism financing, fraud, or any other illegal financial activity
- Send or receive funds derived from, or intended to further, illegal activity
- Impersonate any person or entity, or misrepresent your affiliation with any person or entity
- Circumvent, disable, or otherwise interfere with security-related features of the Services, including identity verification and fraud detection systems
- Use the Services in any manner that could damage, disable, overburden, or impair Kairo's systems, or interfere with any other party's use of the Services
- Reverse engineer, decompile, or attempt to extract the source code of any software underlying the Services, except as permitted by applicable law
- Use automated systems, bots, or scripts to access the Services in a manner inconsistent with normal conversational use, without Kairo's prior written consent (this does not apply to authorized Enterprise API integrations)
- For Kairo Business: list or sell goods or services that are illegal, counterfeit, or that infringe third-party intellectual property rights
- Violate any applicable law, regulation, or third party's rights in connection with your use of the Services
AI Features, Conversational Commands & Your Responsibility
Kairo's Services rely on artificial intelligence to interpret natural language, voice, and image-based instructions (such as a photograph of an account slip) and convert them into transaction requests. This section sets out important responsibilities relating to these features.
- You are responsible for reviewing any transaction summary or confirmation presented by Kairo before approving it. Approving a transaction confirms that the details shown (recipient, amount, and source) are correct, to the best of your knowledge
- Kairo's AI systems are designed to interpret instructions accurately, but no automated system is infallible. You should review confirmations carefully, particularly for high-value transactions
- Where Kairo's AI generates content on your behalf (such as promotional messages for Kairo Business, or automated customer responses), you are responsible for reviewing and approving that content before it is sent, where such review is offered, and for the consequences of content sent using auto-approval features you have enabled
- Voice-based instructions are processed to extract transactional intent; background noise, accents, or ambiguous phrasing may occasionally result in misinterpretation, which is why confirmation steps exist before funds are moved
- Kairo is not liable for losses arising from a transaction that was accurately summarized in a confirmation step and that you approved, even if the underlying instruction was given in error
Intellectual Property
The Services, including all software, designs, text, graphics, logos, and the Kairo name and trademarks, are owned by Kairo or its licensors and are protected by intellectual property laws. These Terms do not grant you any right, title, or interest in the Services other than the limited right to use them in accordance with these Terms.
You retain ownership of content you upload to the Services (such as Kairo Business storefront listings and images), but grant Kairo a non-exclusive, worldwide, royalty-free license to use, host, store, reproduce, and display that content as necessary to provide the Services to you and your customers.
Third-Party Services (Including WhatsApp)
Kairo Personal and Kairo Business operate primarily through WhatsApp, using the WhatsApp Business Platform operated by Meta Platforms, Inc. Your use of WhatsApp to access Kairo is also subject to WhatsApp's own Terms of Service and Privacy Policy, available at whatsapp.com. Kairo is not responsible for the availability, performance, or security of WhatsApp's infrastructure, and any interruption in WhatsApp's services may affect your ability to access Kairo through that channel.
The Services may also integrate with or rely on other third-party services (including identity verification providers, payment networks, cloud infrastructure providers, and telecommunications providers). Kairo is not responsible for the acts or omissions of these third parties, except to the extent required by applicable law.
Disclaimers & Limitation of Liability
11.1 Service provided “as is”
The Services are provided on an “as is” and “as available” basis. To the maximum extent permitted by applicable law, Kairo disclaims all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, and non-infringement. Kairo does not warrant that the Services will be uninterrupted, error-free, or completely secure.
11.2 Limitation of liability
To the maximum extent permitted by applicable law, Kairo's total liability to you for any claim arising out of or relating to these Terms or the Services shall not exceed the fees you paid to Kairo in the twelve (12) months preceding the claim. Kairo shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including loss of profits, data, or goodwill.
11.3 No liability for unauthorized access due to your negligence
Kairo is not liable for losses arising from unauthorized access to your account resulting from your failure to safeguard your account credentials, device, or WhatsApp account, except where such access results from Kairo's own negligence or breach of these Terms.
Indemnification
You agree to indemnify, defend, and hold harmless Kairo, its officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or in any way connected with: (a) your access to or use of the Services; (b) your violation of these Terms; (c) your violation of any applicable law or the rights of any third party; or (d) for Kairo Business users, any dispute between you and your customers relating to goods or services sold through your storefront.
Suspension & Termination
13.1 Termination by you
You may stop using the Services and close your account at any time by contacting Kairo support, subject to settlement of any outstanding obligations (including outstanding Kairo Business subscription fees or unresolved transaction disputes).
13.2 Suspension or termination by Kairo
Kairo may suspend or terminate your access to the Services, with or without notice, where:
- You violate these Terms, including the Prohibited Uses in Section 8
- Kairo reasonably suspects fraudulent, illegal, or unauthorized activity on your account
- Required to do so by a regulator, court order, or applicable law
- Your identity verification cannot be confirmed or is found to be inaccurate
- For Kairo Business: non-payment of subscription fees beyond an applicable grace period
- For Kairo Enterprise: as set out in the applicable Master Services Agreement
13.3 Effect of termination
Upon termination, your right to access the Services will cease. Kairo will facilitate the withdrawal of any remaining wallet balance to a verified bank account, subject to completion of any pending fraud or compliance review, and subject to applicable regulatory requirements. Provisions of these Terms that by their nature should survive termination (including Sections 10, 12, 13, and 15) will continue to apply.
Dispute Resolution & Governing Law
14.1 Governing law
These Terms are governed by and construed in accordance with the laws of the Federal Republic of Nigeria, without regard to its conflict of law principles.
14.2 Informal resolution first
Before initiating any formal dispute resolution process, you agree to first contact Kairo's support team to attempt to resolve the matter informally. Most concerns can be resolved quickly through this channel.
14.3 Enterprise disputes
Disputes arising under a Kairo Enterprise Master Services Agreement shall be resolved in accordance with the dispute resolution provisions set out in that agreement, which shall govern in the event of any conflict with this Section.
Changes to These Terms
Kairo may update these Terms from time to time to reflect changes in our Services, legal or regulatory requirements, or for other operational reasons. We will notify you of material changes through the Services (such as a WhatsApp message or in-app notification) and will update the “Last updated” date at the top of these Terms. Your continued use of the Services after a change takes effect constitutes your acceptance of the revised Terms. If you do not agree to the revised Terms, you must stop using the Services.
General Provisions
16.1 Entire agreement
These Terms, together with our Privacy Policy and (where applicable) any Master Services Agreement, constitute the entire agreement between you and Kairo regarding your use of the Services, and supersede any prior agreements.
16.2 Severability
If any provision of these Terms is found to be unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary, and the remaining provisions will remain in full force and effect.
16.3 No waiver
Kairo's failure to enforce any right or provision of these Terms will not be considered a waiver of that right or provision.
16.4 Assignment
You may not assign or transfer these Terms, or any rights or obligations under them, without Kairo's prior written consent. Kairo may assign these Terms in connection with a merger, acquisition, or sale of assets, or by operation of law.
16.5 Force majeure
Kairo will not be liable for any failure or delay in performance resulting from causes beyond its reasonable control, including natural disasters, acts of government, network or infrastructure failures (including WhatsApp or telecommunications outages), or other events of force majeure.
Contact Us
If you have questions about these Terms, please contact:
Kairo Support & Legal
Email: legal@usekairo.co
Address: 4b Babatope Bejide Street, Lekki Phase 1, Lagos.