Last Updated: May 26, 2025
Your use of the Cellus App is governed by the Cellus Terms of Service relevant to your jurisdiction, this Conditional Use Policy ("Policy"), and any other terms, policies and guidelines applicable to the Cellus Services (as the term is defined in the Cellus Terms of Service). We may modify this Policy by posting a revised version on https://cellus.app. By using Cellus Services, you agree to the latest version of this Policy. You are independently responsible for complying with all applicable laws in all of your actions related to your use of Cellus Services, regardless of the purpose of the use.
A. Prohibited Uses
You may not use, facilitate use of, or allow others to use, the Cellus Services to engage in the following activities ("Prohibited Uses"). The specific types of uses listed below are representative, but not exhaustive. By using Cellus Services, you acknowledge and agree that you will not use Cellus Services to do any of the following:
1. Accounts
Open or have more than one personal account with Cellus. Personal accounts are for use in person-to-person transfers with friends, family, and other people whom you know as well as to make authorized merchant payments. Each user is limited to one Cellus Tag and one account per individual.
2. Unlawful Activity
Activity which would violate, or assist in violation of, any law, statute, ordinance, or regulation. This includes engaging in any criminal or tortious activity, including without limitation:
- Child pornography or exploitation
- Trafficking in obscene material
- Drug dealing or illegal substance transactions
- Gambling or illegal betting activities
- Money laundering or terrorist financing
- Violation of Nigerian financial regulations or CBN guidelines
- Tax evasion or fraud
3. Abusive Activity
Activities which impose an unreasonable or disproportionately large load on our infrastructure, or detrimentally interfere with, intercept, or expropriate any system, data, or information, including:
- Transmit or upload any material to the Cellus Services that contains viruses, trojan horses, worms, or any other harmful or deleterious programs
- Attempt to gain unauthorized access to Cellus Services, other Cellus customer accounts, computer systems or networks connected to the Cellus Services, through password mining, scraping, or any other manual or automated processes
- Use Cellus account information of another party to access or use Cellus Services, except where expressly authorized by a user to access such information
- Transfer your account access or rights to your account to a third party
- Collect information from Cellus Services about others, including without limitation personal information such as phone numbers or customers' names, without proper consent
- Manipulate Cellus Tags or attempt to create fake identities
- Abuse currency conversion features or attempt to exploit exchange rate differences
4. Abuse of Other Cellus Customers or Cellus Employees
Engage in abusive activities or communications (oral or written) in connection with use of the Service that are explicit, abusive, or hate speech directed toward other Cellus customers or Cellus employees. This includes without limitation activities that:
- Defame, abuse, extort, harass, stalk, threaten or otherwise violate or infringe the legal rights (such as, but not limited to, rights of privacy, publicity and intellectual property) of others
- Interfere with another individual's or entity's access to or use of any Cellus Services, including other Cellus customers or Cellus employees
- Send threatening or abusive messages through Cellus Tags or payment descriptions
- Engage in discriminatory behavior based on race, religion, gender, or other protected characteristics
5. Fraud
Activity which operates to defraud Cellus customers, or any other person or entity, including:
- Provide any false, inaccurate, or misleading information to Cellus
- Create fake transactions or manipulate transaction history
- Use stolen or fraudulent payment methods
- Impersonate another person or entity
- Engage in advance fee fraud (419 scams) or romance scams
- Submit false KYC documentation or identity verification
- Engage in chargeback fraud or dispute legitimate transactions
6. Sanctioned Activity
Activity that may be in violation of regulations administered by relevant sanctions authorities, including but not limited to:
- The United States Department of the Treasury's Office of Foreign Asset Control (31 C.F.R. Parts 500-599)
- Nigerian sanctions and financial regulations
- United Nations Security Council sanctions
- European Union sanctions regimes
Prohibited activity includes but is not limited to the provision of Cellus Services to or for the benefit of a jurisdiction, entity, or individual blocked or prohibited by relevant sanctions authorities, including but not limited to activities in Iran, Cuba, North Korea, Syria, or the Crimea Region of Ukraine. If found to be in apparent violation of these restrictions, your account could be terminated and your funds could be held for an indefinite period of time.
B. Prohibited Business List
You may not engage, help the use of or allow others to use, Cellus and its Payment Service Provider(s) (PSP) to engage in the following Prohibited Business List. Deviation from these guidelines may result in termination of client agreement. This is not an exhaustive list, and Cellus and its PSP providers reserve the right to add or amend this list at any time. Choosing to use Cellus Services means that you agree and consent to not participate in the following:
Financial Services
- • Unlicensed Financial Services (where licensing is required)
- • Pyramid or Ponzi Schemes
- • Multi-Level Marketing Programs
- • Hawala or informal money transfer
- • Unlicensed FOREX Brokers
- • Binary Options
- • Debt Restructuring, Credit Repair, Debt Settlement
- • Debt Collections
- • Get Rich Quick Schemes
Illegal Activities
- • Gambling and betting
- • Activities Aimed at Circumventing Security Controls
- • Unregulated Pharmaceuticals / Food Supplements
- • Piracy or Illegal Streaming
- • Counterfeit Goods and IP Violations
- • Arms / Dual Use Goods / Human Organs
- • Adult Services Connected to Human Trafficking
- • Production or Distribution of Pornography
Business Structures
- • Unlicensed Charities
- • Shell Companies
- • Companies Formed of Bearer Shares
- • Remittances Funded in Cash
- • Offshore Bank Transactions / Shell Banks
- • Fourth Party Payment & Multi-Layered MSB Arrangements
- • Political / Religious Organizations designated as Hate Groups
- • Sanctioned Entities / Individuals
Restricted Transactions
- • Transactions for Goods Subject to Export Prohibition
- • Transactions with Living Animals (exceptions for services)
- • Unauthorized cryptocurrency trading
- • Manipulation of currency conversion rates
- • Abuse of Cellus Tag system
- • Circumventing transaction limits
- • Creating multiple accounts
- • Violating Nigerian financial regulations
⚠️ Nigerian-Specific Prohibitions
In addition to the above, the following activities are specifically prohibited under Nigerian law:
- • Violation of Central Bank of Nigeria (CBN) foreign exchange regulations
- • Unauthorized bureau de change activities
- • Violation of Nigerian Anti-Money Laundering laws
- • Unauthorized remittance services
- • Violation of Nigerian Data Protection Act (NDPA) 2023
- • Activities that violate Nigerian cybercrime laws
- • Unauthorized financial advisory services
- • Violation of Nigerian Securities and Exchange Commission (SEC) regulations
Investigation and Enforcement
We have no obligation to monitor Cellus Services for violations of this Policy but we have absolute discretion to take any action up to and including suspending or terminating your use of Cellus at any time without notice for any violations of this Policy.
We may investigate any suspected violation of this Policy, and remove or disable access to any content or resources that violates this Policy. You agree to cooperate with us to remedy any violation.
If we reasonably suspect that your account has been used for an unauthorized, illegal, or criminal purpose, you give us express authorization to share information about you, your account, and any of your transactions with law enforcement.
Enforcement Actions
Depending on the severity of the violation, we may take the following actions:
- • Warning: First-time minor violations may result in a warning
- • Account Restriction: Temporary limitation of account features
- • Account Suspension: Temporary suspension of account access
- • Account Termination: Permanent closure of account
- • Fund Freezing: Temporary or permanent freezing of funds
- • Legal Action: Reporting to law enforcement or regulatory authorities
Reporting Violations
If you become aware of any violation of this Conditional Use Policy, please report it immediately to our compliance team:
- Send an email to compliance@cellus.app
- Use the in-app reporting feature
- Contact customer support at support@cellus.app
- Call our compliance hotline (details available in the app)
Updates to this Policy
We reserve the right to modify this Conditional Use Policy at any time. We will notify users of significant changes through the app, email, or by posting updates on our website. Your continued use of Cellus Services after any modifications constitutes acceptance of the updated policy.
Policy Acknowledgment
By using Cellus, you acknowledge that you have read, understood, and agree to comply with this Conditional Use Policy. This policy forms part of our Terms of Service and should be read in conjunction with our Privacy Policy and other legal documents.
Compliance: This Conditional Use Policy is designed to ensure compliance with Nigerian laws and international best practices for financial technology services.