Terms & Conditions

The legal agreement governing your access to and use of the Kuata application and services

Version 1.0   ·   Effective Date: 1 May 2026

1. Acceptance of These Terms

By downloading, installing, accessing, or using the Kuata application ("App"), its website (kuata.ao), or any service provided by Kuata Tecnologias Lda. (collectively "the Services"), you ("User", "you", "your") confirm that you have read, understood, and agree to be legally bound by these Terms and Conditions ("Terms").

If you do not agree to these Terms in their entirety, you must not use the Services. Your continued use of the Services following any update to these Terms constitutes acceptance of the updated version.

These Terms constitute a legally binding agreement governed by the laws of the Republic of Angola and applicable international best-practice standards referenced herein. They are subject to the following regulatory framework:

2. About Kuata — Nature of the Service

2.1 Company Identity

Kuata Tecnologias Lda. ("Kuata", "we", "us", "our") is a technology company incorporated in Angola, with registered offices in Luanda, Angola. Kuata operates under regulatory oversight of the Banco Nacional de Angola (BNA) for its payment service activities.

Kuata Tecnologias Lda.  |  Registered address: [LUANDA ADDRESS — TO BE COMPLETED]  |  Company Registration No.: [TO BE COMPLETED]  |  BNA Registration/Authorisation No.: [TO BE COMPLETED UPON GRANT]  |  Contact: legal@kuata.ao

2.2 What Kuata Provides

The Kuata App provides the following services to eligible users:

• Digital Identity Wallet: secure, biometric-protected storage, management, and presentation of Angolan government-issued identity and travel documents (Bilhete de Identidade, driver's licence, vehicle registration, insurance, passport, birth and marriage certificates)

• Document Verification: cryptographically signed offline and online document verification via QR code and NFC for law enforcement, employers, banks, and other authorised verifying entities

• Payment Initiation Services: facilitation of bill payments, mobile top-ups, and public service payments via the EMIS/Multicaixa national payment infrastructure, acting strictly as a payment initiator

• Digital Key Access: NFC-based digital key functionality for compatible access systems where enabled

• Stop History & Audit Trail: citizen-owned tamper-evident record of law enforcement verification events

2.3 Critical Architecture Disclosure — Payment Initiator Only

IMPORTANT: Kuata is a payment initiation service provider only. Kuata does not hold, store, custody, or transmit user funds at any time. All payments are processed through EMIS/Multicaixa infrastructure, debited directly from your linked bank account and credited directly to the biller. Kuata's role is solely to transmit the payment instruction. This is not an e-money or stored-value service.

Legal basis:  Law 40/20 (payment service provider classification); BNA authorisation framework

3. Eligibility Requirements

Legal basis:  Law 5/20 Art. 8 (KYC); Law 40/20; Law 22/11

To register and use the Kuata App, you must satisfy all of the following conditions at all times:

By registering, you represent and warrant that you meet all eligibility requirements and that all information you provide is accurate, complete, and current. Providing false information is a breach of these Terms and may constitute a criminal offence under Angolan law.

4. Account Registration & Security

4.1 Registration Process

Account registration follows a mandatory Customer Due Diligence (CDD) process in compliance with Law 5/20 Art. 8 and BNA Notice 02/24. The process includes phone number verification (OTP), government identity verification via DNIRN API, biometric binding, and device attestation.

4.2 Your Security Obligations

You are personally responsible for:

• Keeping your biometric credentials and device PIN secure and not sharing them with any person

• Ensuring your registered phone number remains under your control and is kept up to date

• Activating Remote Wallet Lock immediately if your device is lost, stolen, or compromised

• Notifying Kuata at security@kuata.ao within 24 hours of any suspected unauthorised access to your account

• Not registering multiple accounts, sharing your account, or allowing any other person to use your account

4.3 Account Responsibility

You are liable for all activity conducted through your account, including any payment initiations, document presentations, and verification events that occur with your authenticated biometric or PIN. Kuata is not liable for losses resulting from your failure to secure your account or your failure to activate Remote Wallet Lock after a device compromise.

Legal basis:  Codigo Civil de Angola — contributory negligence principles

4.4 One Account Per Person

Each person may hold only one active Kuata account, linked to a single verified BI. Creating multiple accounts to circumvent identity verification, AML limits, or transaction limits is a material breach of these Terms and will result in immediate account suspension and reporting to the UIF where required by Law 5/20.

5. Digital Documents — Legal Status, Accuracy & Limitations

5.1 Legal Validity

Digital documents presented via the Kuata App are legally valid for identification and verification purposes in Angola pursuant to applicable legislation and the agreements between Kuata and the relevant government ministries. Kuata documents carry a PKI-backed cryptographic signature that government-authorised verifier devices can validate online and offline.

Legal basis:  Government ministry API agreements; applicable Angolan digital identity legislation

5.2 Dependence on Government Registry Accuracy

The accuracy of your digital documents is entirely dependent on the accuracy of the government registry records from which they are sourced (DNIRN, Ministerio dos Transportes, SME). Kuata does not modify, interpret, or supplement government registry data. If your document shows inaccurate information:

• The error originates in the government registry, not in Kuata

• You must contact the relevant government ministry or registration office to correct the source record

• After the registry record is corrected, your Kuata wallet will update at the next sync (typically within 1–3 business days)

• Kuata is not liable for consequences arising from inaccuracies in government source records

5.3 Document Revocation

Government authorities may revoke any document at any time (e.g., suspended driver's licence, cancelled passport). Kuata reflects revocation in real time or at the next sync. A revoked document will be marked as invalid in your wallet and cannot be presented for verification. You are responsible for ensuring your App is connected to the internet regularly so that revocations are reflected promptly.

5.4 Offline Validity Period

Offline cryptographic signatures on your documents are refreshed on each connection to the internet. If you have been offline for more than 30 days, some verifier devices may decline to accept your offline presentation. Connect to the internet to refresh your signatures before attending a checkpoint or event requiring verification.

5.5 Document Accuracy Your Responsibility

You must present only the documents and data that are accurate and current. Presenting a Kuata document that you know to be expired, revoked, or inaccurate is a misuse of the App and may constitute fraud under Angolan law. Kuata is not a party to any misrepresentation you make to a verifying entity.

6. Payment Initiation Services — Full Terms

6.1 Nature of Service — Initiator Only

Kuata provides payment initiation services only. By using the payment features of the App, you authorise Kuata to transmit your payment instruction to EMIS/Multicaixa on your behalf. The legal and financial relationship for the payment is between you, your bank, and the biller. Kuata is not a party to the payment transaction itself.

Legal basis:  Law 40/20 Art. 18 (payment initiation service definition); BNA authorisation

6.2 User Authorisation & Irrevocability

When you confirm a payment initiation by authenticating with your biometric or PIN, you provide an irrevocable authorisation for that specific transaction. Once the payment instruction has been transmitted to EMIS:

• Kuata cannot cancel, reverse, or modify the payment

• You must contact your bank directly for any post-initiation dispute regarding the debit

• You must contact the biller directly for any dispute regarding the service being paid for

The authorisation covers only the specific payment you have confirmed. Kuata does not hold a standing mandate to initiate payments without your per-transaction biometric or PIN confirmation.

6.3 Payment Accuracy — User Responsibility

You are solely responsible for:

• Selecting the correct biller from the available list

• Entering the accurate account reference, contract number, or service reference for the biller

• Confirming the correct payment amount (where manual entry is required)

Kuata is not liable for payments made to incorrect billers, for incorrect amounts, or using incorrect references due to user error. If a payment is initiated to the wrong biller due to your error, your only recourse is with your bank and the biller.

6.4 Payment Limits

Kuata applies transaction limits in compliance with BNA regulatory requirements and as a fraud prevention measure. Current default limits (subject to periodic review by BNA):

Limits may be temporarily reduced by Kuata where unusual transaction patterns are detected. Limits may be increased for business users upon request and additional due diligence.

6.5 Supported Billers

Kuata supports payment initiation for the following categories, subject to EMIS network availability and ongoing commercial agreements:

• Electricity: EDEL, ENDE and regional providers

• Water: EPAL, regional water companies (EASB, ESAL, and others on EMIS network)

• Telecommunications: Angola Telecom, Unitel, Movicel, Africell (voice, data, and SMS top-ups)

• Television and internet subscriptions: providers on the EMIS network

• Insurance premiums: ENSA, Nossa Seguros, AAA Seguros, and others registered with EMIS

• Government fees and taxes: via RUPE (Referencia Unica de Pagamento ao Estado) references

• Educational fees: registered educational institutions on the EMIS network

Kuata makes no guarantee that any specific biller will remain available. Biller availability is subject to EMIS network status and commercial agreements. Kuata is not responsible for interruptions to biller services outside its control.

6.6 Service Availability & EMIS Dependency

Payment initiation services depend on:

• EMIS/Multicaixa national infrastructure availability (operated by a third party — Empresa Interbancaria de Servicos S.A.)

• Your bank's real-time systems and transaction processing capability

• Your internet connection at the time of initiation

• The biller's receiving systems

Kuata does not guarantee uninterrupted payment service availability. Kuata is not liable for losses arising from EMIS outages, bank system failures, or connectivity issues. In the event of a failed payment, check your Service Payment History before retrying — your bank may have processed the debit even if the App showed an error.

6.7 No Financial Advice

Kuata does not provide financial advice, investment advice, or credit services. The payment initiation feature is a transactional utility only. Kuata is not a bank and is not regulated as a bank.

7. Law Enforcement Verification & Stop History

7.1 How Stop History Works

When a police officer or other authorised law enforcement officer scans your QR code using a Kuata Verifier device, the following occurs automatically:

• A verification event is logged in your wallet (stop record)

• The record includes date, time, location (if GPS is enabled), officer unit identifier, documents verified, stop reason, duration, and outcome

• The record is cryptographically signed and is tamper-evident from the moment of creation

• The record cannot be altered by any party — including Kuata — after creation

7.2 Your Rights in Relation to Stop Records

• You own your stop history — it is your personal audit trail

• You may add personal notes to any stop record at any time after the stop

• You may flag a dispute against any stop record, which routes to the relevant oversight mechanism

• Kuata will not share your stop history with any government authority without your explicit consent or a valid legal order

• Stop records are retained for 10 years under Law 22/11 audit trail obligations

Legal basis:  Law 22/11 Art. 7(c); Angolan Law 22/11 data subject rights

7.3 Legal Status of Stop Records

Stop records generated by Kuata may be relevant in legal proceedings as evidence of a verification event. Kuata's tamper-evident records may be presented in proceedings. However, Kuata does not provide legal advice and you should consult an attorney if you believe a stop record is relevant to a legal matter.

8. Acceptable Use Policy

8.1 Prohibited Activities

You agree that you will not, and will not attempt to:

• Present forged, expired, revoked, or otherwise invalid documents via the App

• Defeat or circumvent biometric authentication using spoofing, synthetic media, deepfakes, or device manipulation

• Use the payment initiation feature for money laundering, structuring, terrorist financing, or any activity prohibited by Law 5/20

• Register multiple accounts or create accounts on behalf of other persons without lawful authority

• Share your account credentials, biometric access, or device with any other person

• Use the App to present another person's identity documents without their knowledge and consent

• Reverse-engineer, decompile, disassemble, or otherwise attempt to derive the source code of the App

• Attempt to access, probe, or test the security of Kuata's systems, APIs, or databases without authorised written permission

• Scrape, harvest, or extract data from the App or the Kuata API by automated means

• Upload malware, viruses, or any harmful code to the App or Kuata's systems

• Use the App in a manner that violates any applicable Angolan or international law

8.2 Consequences of Prohibited Use

Breach of the Acceptable Use Policy may result in:

• Immediate account suspension without notice

• Permanent account termination

• Reporting to the BNA, UIF, or law enforcement authorities as required by Law 5/20

• Civil liability for damages caused to Kuata or third parties

• Criminal liability where the prohibited activity constitutes an offence under Angolan law

8.3 AML/CFT Obligations

As a payment service provider, Kuata is legally required to monitor payment initiation activity for money laundering and terrorist financing indicators. We will file Suspicious Transaction Reports (STRs) with the UIF where required by Law 5/20, without notice to the subject of the report. This is a legal obligation and cannot be waived by any user agreement.

Legal basis:  Law 5/20 Art. 22 (tipping-off prohibition); Art. 16–20 (STR obligations)

9. Intellectual Property

9.1 Kuata's Intellectual Property

All intellectual property rights in the App, website, software, design, trademarks, trade names, logos, brand elements, documentation, and content (collectively "Kuata IP") are owned by or licensed to Kuata Tecnologias Lda. Kuata IP is protected by Angolan intellectual property law and applicable international conventions.

9.2 Licence to You

Kuata grants you a limited, personal, non-exclusive, non-transferable, revocable licence to install and use the App on your personal device solely for the purposes set out in these Terms. This licence does not include:

• Any right to copy, reproduce, modify, or distribute the App or any part of it

• Any right to create derivative works based on the App

• Any right to use Kuata's trademarks, brand names, or logos without written permission

• Any right to sublicense the App to any third party

9.3 Your Content

Any personal notes or content you add to stop records or other user-generated fields remain your property. By adding such content, you grant Kuata a limited licence to store and display it to you within the App.

9.4 Government Data

Document data sourced from Angolan government registries (DNIRN, Ministerio dos Transportes, SME) remains the property of the Republic of Angola. Kuata acts as a data processor for this information on your behalf. No intellectual property claim is made by Kuata over government-sourced data.

10. Limitation of Liability

Legal basis:  Codigo Civil de Angola — liability principles; GDPR Art. 82; Law 40/20

10.1 Scope of Liability

To the maximum extent permitted by applicable Angolan law, Kuata's aggregate liability to you for all claims arising under or in connection with these Terms, the App, or the Services, is limited to the greater of: (a) the total fees paid by you to Kuata in the 12 months preceding the claim (which, for free consumer services, is zero), or (b) AOA 50,000.

10.2 Excluded Liability

Kuata is not liable — whether in contract, tort (including negligence), breach of statutory duty, or otherwise — for:

• Any indirect, incidental, consequential, special, or punitive damages

• Loss of profits, revenue, data, goodwill, or business opportunity

• Losses arising from EMIS/Multicaixa infrastructure failures, bank system failures, or government API unavailability

• Losses arising from user error in payment initiation (wrong biller, wrong reference, wrong amount)

• Losses arising from your failure to activate Remote Wallet Lock after a device compromise

• Losses arising from inaccuracies in government registry records

• Losses arising from revocation of your documents by government authorities

• Losses caused by events beyond our reasonable control (force majeure)

10.3 Consumer Rights Preserved

Nothing in this Section limits Kuata's liability for: death or personal injury caused by Kuata's negligence; fraud or fraudulent misrepresentation; any liability that cannot be excluded under applicable Angolan consumer protection law; or data protection liability under Law 22/11 and GDPR.

10.4 Force Majeure

Kuata is not liable for any failure or delay in performing its obligations where such failure or delay results from events beyond its reasonable control, including: acts of God, war, civil unrest, government action, regulatory changes, power outages, internet infrastructure failures, cyberattacks by third parties, or failures of EMIS or government registry infrastructure.

11. Indemnification

You agree to indemnify, defend, and hold harmless Kuata, its directors, officers, employees, and agents from any claims, damages, losses, fines, or expenses (including reasonable legal fees) arising from:

• Your breach of these Terms

• Your breach of any applicable law in your use of the App

• Your misrepresentation of identity or fraudulent presentation of documents

• Your use of the payment initiation service for prohibited purposes

• Any third-party claim arising from your use of the App

12. Account Suspension & Termination

12.1 Termination by You

You may terminate your account at any time by accessing Account Management > Delete Account in the App. Upon deletion: your wallet data and biometric binding are immediately removed; legally mandated compliance records (KYC, transaction history) are retained in encrypted archives for 10 years as required by Law 5/20; all other data is deleted within 30 days. See our Privacy Policy for the full retention schedule.

12.2 Suspension and Termination by Kuata

Kuata may immediately suspend or permanently terminate your account, with or without notice, where:

• You have breached any provision of these Terms

• You have provided false identity information or circumvented KYC processes

• Your account is the subject of an active AML/CFT investigation or has been flagged by the UIF

• Kuata is required to do so by a BNA regulatory order or court order

• Continued account access poses a material security or compliance risk

• You have been dormant for more than 24 months and we are unable to reach you after reasonable attempts

Where Kuata terminates for regulatory reasons, we may be legally prohibited from explaining the specific reason. We will notify you of the suspension or termination itself where permitted.

12.3 Consequences of Termination

Upon termination, your licence to use the App immediately ceases. All active payment initiations in progress will be completed before account closure. Kuata will retain all data required by applicable law and will delete all other personal data in accordance with our Privacy Policy.

13. Dispute Resolution

13.1 Internal Complaint Process

If you have a complaint about the App or our services, contact support@kuata.ao. We will acknowledge your complaint within 3 business days and provide a substantive response within 15 business days. For payment-related complaints, we will provide a final written response within 30 days in line with BNA payment service provider complaint handling requirements.

13.2 BNA Supervisory Complaints

If you are dissatisfied with our final response to a payment-related complaint, you may refer the matter to the Banco Nacional de Angola (BNA) in its supervisory capacity over payment service providers.

13.3 Data Protection Complaints

Complaints relating to data protection may be referred to the Agencia de Protecao de Dados (APD) — Angola's data protection supervisory authority — at any time, independent of any internal complaint process.

13.4 Governing Law & Jurisdiction

These Terms are governed by and construed in accordance with the laws of the Republic of Angola. Any dispute arising out of or in connection with these Terms that cannot be resolved through the complaint process shall be subject to the exclusive jurisdiction of the courts of Luanda, Angola, without prejudice to the rights of any EU-resident user to bring proceedings before their local courts.

Legal basis:  Codigo Civil de Angola; Lei de Arbitragem Voluntaria (where applicable)

14. General Provisions

14.1 Entire Agreement

These Terms, together with our Privacy Policy, Cookie & Tracking Policy, and any specific service addenda, constitute the entire agreement between you and Kuata with respect to the App and Services. They supersede all prior discussions, representations, or agreements.

14.2 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a competent court, that provision will be severed from the Terms. The remaining provisions will continue in full force and effect.

14.3 No Waiver

Kuata's failure to enforce any provision of these Terms on any occasion does not constitute a waiver of its right to enforce that provision on any future occasion.

14.4 Assignment

You may not assign or transfer your rights or obligations under these Terms without Kuata's prior written consent. Kuata may assign its rights and obligations under these Terms in connection with a merger, acquisition, or sale of assets, provided that it notifies you in advance and the acquirer agrees to honour these Terms.

14.5 Changes to These Terms

Kuata may update these Terms from time to time. Material changes will be communicated via in-app notification and, where an email address is registered, by email, at least 14 days before the effective date. If you do not agree to the updated Terms, you must stop using the App before the effective date. Continued use after the effective date constitutes acceptance. Changes required by regulatory direction may take immediate effect; we will notify you as soon as practicable.

14.6 Language

These Terms are available in Portuguese (official version) and English (reference translation). In the event of a conflict between the Portuguese and English versions, the Portuguese version prevails.

15. Contact

Legal enquiries: legal@kuata.ao  |  General support: support@kuata.ao  |  Security issues: security@kuata.ao  |  Data protection: privacy@kuata.ao  |  Address: [LUANDA REGISTERED ADDRESS — TO BE COMPLETED]