SwarmPay

Terms of Service

Effective: 19 August 2026  ·  Last updated: 19 August 2026

These terms are the agreement between you and SwarmPay. They cover the wallet, sending and requesting money, SafePay escrow, selling through SwarmPay, and the WhatsApp channel. Please read them — particularly section 12 on liability and section 8 on disputed and pending payments.

1. Agreeing to these terms

By creating a SwarmPay account, sending a message to SwarmPay on WhatsApp, or using the SwarmPay app, you agree to these Terms of Service and to our Privacy Policy. If you do not agree, do not use SwarmPay.

These terms are between you and SwarmPayTech (Private) Limited, entity number 62300A02102025, a private limited company registered in Zimbabwe on 7 October 2025, with its head office in Harare, Zimbabwe, trading as SwarmPay.

Payments to mobile-money and banking rails are made through licensed payment providers.

2. Who can use SwarmPay

• You must be 18 or older.
• You must be using SwarmPay for yourself, or be properly authorised to act for a business you register.
• You must give us accurate information and keep it up to date.
• You must not be subject to sanctions, or barred from financial services under any law that applies to you.
• Certain features and limits require you to complete identity verification. We may refuse, restrict or reverse a verification decision where the law requires it.

One person gets one account. Your account is personal to you and cannot be sold or transferred.

3. Your account and security

Your mobile number identifies your account. You protect it with a password, and money-out actions additionally require a password or PIN.

• Keep your password, PIN, one-time codes and device secure. Never share them — SwarmPay staff will never ask you for them.
• You are responsible for everything done through your account by anyone who has your credentials.
• Tell us immediately if you suspect your account has been accessed without your permission, or your phone or number has been lost, stolen or taken over. Until you do, transactions authorised with your credentials are treated as authorised by you.
• We may require re-verification, apply a temporary hold, or lock the account after repeated failed password or PIN attempts.

4. The WhatsApp channel

SwarmPay works inside WhatsApp. By using it there, you agree that:

• We will send you messages on WhatsApp about your account — receipts, balances, payment confirmations, order updates, security notices and support replies.
• Messages you exchange with SwarmPay's business number are delivered through Meta's WhatsApp Business Platform and are also governed by WhatsApp's own terms and privacy policy.
• Buttons, lists and forms in a SwarmPay conversation are time-limited and single-use. An expired or already-used option will be refused, and you will be offered a fresh one.
• A live conversation is enough to check a balance. It is never enough to move money — every money-out action asks for your password or PIN.
• You can reply STOP or block our number to stop conversational messages. Security notices and legally required communications may still be sent by other means.
• WhatsApp delivery depends on Meta and on your network. We are not responsible for delays or failures in WhatsApp's own delivery.

5. Your wallet and your money

• Your SwarmPay wallet holds an electronic record of funds you have deposited or received. You may hold balances in more than one currency.
• SwarmPay is not a bank. Your balance is not a bank deposit, it does not earn interest, and it is not covered by deposit insurance.
• We hold customer funds separately from our own operating money.
• Your balance is what our records show. If our records and your recollection differ, we will investigate — but our records, and the payment provider's, are the authoritative account of what happened.
• We apply transaction and balance limits. Some are ours and vary with your verification level; others are regulatory and apply to every mobile wallet in the country. Regulatory limits can change without notice to us, and therefore without notice to you.
• Where a currency is presented under more than one name for accounting reasons, balances are consolidated. The amount you hold is unaffected.

6. Payments, deposits and cash-outs

• You can add funds from supported mobile-money and banking rails, send money to another SwarmPay user or a mobile number, request money, pay invoices and orders, and cash out to a supported rail.
• You are responsible for the details you enter. Check the number and the amount before you confirm. A payment sent to a number you typed incorrectly may be irrecoverable — we will try to help, but we cannot promise to get it back.
• If you send money to someone who does not yet have a SwarmPay account, we hold it against their number until they register and claim it. If it is never claimed, we may return it to you.
• Payments are final once completed. There is no general right to reverse a completed transfer. Refunds are between you and the person or merchant you paid, except where SafePay applies.
• We may decline, delay or reverse a transaction where we suspect fraud, where it would breach these terms or the law, where a limit is exceeded, or where a provider rejects it.
• We screen accounts and transactions against sanctions and watch lists. A match may hold or block a payment while we check it. Where the law requires, we may be unable to tell you why.
• Availability of any particular payment rail depends on the provider. Rails can be added, suspended or withdrawn.

7. Fees

• The fee for a transaction is shown before you confirm it. If you do not want to pay it, do not confirm.
• Fees may differ by transaction type, amount, currency and payment rail, and may change. Current fees are always the ones shown at the moment you transact.
• Payment providers and mobile networks may charge their own fees, which are outside our control.
• Where a fee has been earned on a completed service — including the SafePay fee taken when an escrow is accepted — it is not refundable even if the underlying trade is later refunded or split.

8. Pending, failed and disputed payments

• Pending transactions normally resolve within minutes, occasionally longer when a provider is degraded.
• If a payment fails after funds left your wallet, the amount is returned to your wallet once the provider confirms the failure.
• If you believe a transaction on your account is wrong or unauthorised, tell us as soon as you notice, and in any event within 30 days of the transaction date. We acknowledge within 2 business days, and aim to complete the investigation and tell you the outcome within 30 days. Where a payment provider or bank has to be involved, it can take longer — we will tell you if it will, and why.
• Reporting late does not automatically forfeit your claim, but it can make the transaction impossible to trace or recover. Report promptly.
• We may ask you for information to investigate. Where a claim turns out to be knowingly false, we may recover our costs and close the account.

9. SafePay escrow

SafePay holds the buyer's money while a trade completes, so neither side has to go first.

• Funds are locked when the escrow is created by a buyer, or when the buyer accepts a seller-initiated escrow. Locked funds leave your available balance and cannot be spent elsewhere.
• The SwarmPay fee is taken when the escrow is accepted. Release, refund and split are themselves fee-free.
• The buyer confirms delivery to release the funds to the seller. Confirming delivery is irreversible.
• Either side may raise a dispute before release. Both sides can upload evidence and propose a resolution. Where both agree a resolution, we apply it.
• Where the parties cannot agree, SwarmPay will review the evidence and resolve the escrow in favour of the buyer, in favour of the seller, or as a split. Our determination is made in good faith on the evidence available and is final as regards the release of the escrowed funds. It does not decide your wider legal rights against each other.
• An escrow left unattended may expire under the timescales shown in the app, with funds returned to the buyer.
• SwarmPay is a payments intermediary, not a party to your trade. We do not inspect, guarantee, insure or take title to the goods or services involved.

10. Selling through SwarmPay

If you list products or take orders through SwarmPay, you additionally agree that:

• You are the seller of record. The contract for the goods or services is between you and your customer. SwarmPay processes the payment.
• You will describe what you sell accurately, honour the prices you publish, and deliver what you have sold.
• You will comply with all laws that apply to your trade, including licensing, consumer protection and tax. You are responsible for your own taxes.
• You will handle your customers' personal information lawfully. Where SwarmPay holds customer records on your behalf, you are responsible for how you use them, and you will not use them for unsolicited marketing without a lawful basis.
• You will handle refunds, returns and complaints from your own customers fairly and promptly.
• You will only upload content you have the right to use, and nothing unlawful, misleading or infringing.
• If you connect your own WhatsApp Business Account, you remain responsible for complying with WhatsApp's Business Messaging Policy and Commerce Policy. A breach of Meta's policies can cost you your WhatsApp channel, and we cannot restore it.
• Excessive chargebacks, disputes or policy breaches may lead us to suspend your shop or withhold settlement pending investigation.

Tap cards

Where you use a SwarmPay tap card, the card is a pointer to your shop. Keep it physically secure; anyone holding it can reach your payment page. Tell us at once if it is lost, so we can deactivate it.

11. What you may not do

You may not use SwarmPay:

• For anything unlawful, including fraud, money laundering, terrorist financing, sanctions evasion or tax evasion.
• To sell anything you are not legally allowed to sell, or that WhatsApp's Commerce Policy prohibits.
• To run a pyramid, ponzi or matrix scheme, an unlicensed lottery, or unlicensed gambling.
• To impersonate anyone, to open an account in someone else's name, or to give us false verification documents.
• To send unsolicited bulk messages, spam or scams through the WhatsApp channel.
• To probe, scrape, reverse-engineer, overload or interfere with the service or its security, or to access any part of it you are not authorised to reach.
• To operate a payment service for third parties, or to pass another person's transactions through your account.

12. Our responsibility, and its limits

We will provide SwarmPay with reasonable care and skill, and we take our obligations around your money seriously. Within that:

• SwarmPay is provided "as is" and "as available". We do not promise it will be uninterrupted or error-free. We may need to suspend it for maintenance, or because a provider, network or Meta is unavailable.
• We are not responsible for: the acts or omissions of the person or merchant you transact with; the quality, safety or legality of anything bought or sold; failures of mobile networks, payment providers, WhatsApp or your device; or losses caused by you sharing your credentials or entering details incorrectly.
• We are not liable for indirect or consequential loss, or for loss of profit, business, goodwill or opportunity.
• Where we are liable to you, our total liability for any claim is limited to the greater of the amount of the transaction giving rise to the claim and the fees you paid us in the three months before the claim arose.
• Nothing in these terms excludes liability that cannot lawfully be excluded — including for fraud, or for our own failure to safeguard funds we hold for you.

13. Suspension and closure

• You may close your account at any time from Settings in the app. Withdraw your balance first — we cannot close an account that still holds funds. Closing starts a 30-day period during which the account is closed but recoverable: sign back in and choose Keep my account to cancel. After 30 days your data is deleted automatically and permanently. See Deleting your data.
• We may suspend or restrict your account, with notice where we reasonably can, if we suspect fraud or unauthorised access, if you breach these terms, if we are required to by law or a provider, or if we cannot verify who you are.
• We may close your account on 30 days' notice, or immediately for serious breach or where the law requires. We will return any balance you are entitled to.
• Closing an account does not cancel obligations that already exist — settled transactions, disputes in progress, or amounts you owe.

14. Inactive accounts and unclaimed funds

• An account with no customer-initiated activity for 12 months is treated as inactive. We will contact you on your registered number before that point.
• An inactive account holding a balance stays yours. We do not charge inactivity or dormancy fees, and we do not absorb the balance.
• We may require you to re-verify your identity before an inactive account is used again — the longer an account sits idle, the more attractive it is to take over.
• Money sent to a phone number that never registers is held for the sender's benefit. If it is unclaimed after 90 days, we return it to the sender's wallet. If we cannot return it, it stays held for you and we will keep trying to reach you.
• Where Zimbabwean law requires unclaimed balances to be dealt with in a particular way after a longer period, we follow that law and will tell you before it applies to your balance.

15. Complaints and disputes with us

Tell us first: support@swarmpay.app, or through Support in the app, or on WhatsApp. We will acknowledge your complaint and aim to resolve it within 30 days. If you are not satisfied, you may take it to the relevant regulator or to the courts of Zimbabwe.

16. Changes to the service and these terms

We are actively developing SwarmPay: features will be added, changed and sometimes withdrawn. We may update these terms as the service or the law changes. For material changes we will give you notice in the app and on WhatsApp before they take effect. If you do not accept a change, close your account. Continuing to use SwarmPay after a change takes effect means you accept it.

17. General

• These terms and the Privacy Policy are the whole agreement between us about SwarmPay.
• If a court finds any part unenforceable, the rest continues to apply.
• If we do not enforce a right straight away, we do not lose it.
• You may not transfer your rights under these terms. We may transfer ours to a successor of the business, without reducing your protections.
• These terms are governed by the laws of Zimbabwe, and the courts of Zimbabwe have jurisdiction.

18. Contact us

• Support: support@swarmpay.app
• Privacy: privacy@swarmpay.app
• Post: SwarmPayTech (Private) Limited, Harare, Zimbabwe