Founding Supporter Program

Issued by: FINFLO (U) LTD · Effective date: August 2026 · Last updated: 11 September 2026

FINFLO (U) LTD (“FINFLO”, “we”, “us”) is developing the systems, governance, technology, and compliance capabilities required to pursue authorization to operate payment services in Uganda.

The Founding Supporter Program allows eligible individuals to support this regulatory-readiness journey in return for the conditional benefits described below.

1) Regulatory status

FINFLO is not representing that it is currently licensed by the Bank of Uganda as a Payment Service Provider.

FINFLO will not provide regulated payment services or issue electronic money unless and until the applicable approvals, partnerships, and legal requirements are in place.

FINFLO will not claim to be licensed, approved, or regulated by any authority unless that status has formally been granted.

2) Our regulatory roadmap

FINFLO’s first priority is to satisfy the requirements applicable to a Payment Service Provider. Thereafter, we intend to assess and pursue other registrations, approvals, licenses, and regulatory engagements applicable to our products, including, where relevant, engagement with:

• the Bank of Uganda (BoU);
• the Capital Markets Authority (CMA);
• the Financial Intelligence Authority (FIA);
• the National Information Technology Authority — Uganda (NITA-U);
• the Insurance Regulatory Authority (IRA); and
• other competent authorities.

Any approval, registration, or license is subject to applicable law and the decision of the relevant authority. No timeline stated by FINFLO, in any medium, is a commitment or a guarantee of outcome.

3) Our reporting commitment

Because the benefits of this programme depend on a regulatory journey that takes time, we commit to reporting on that journey publicly rather than asking you to take it on trust.

FINFLO will publish a regulatory progress update at least once every calendar quarter on our public status page, stating for each regulatory track what has been completed, what is in progress, what is still pending, and the date the position was last reviewed:

View the regulatory progress status page

A progress update reports position and does not promise an outcome or a date. If we have not published an update for two consecutive quarters, that is a failure of this commitment and you may raise it with us under section 14; we will publish the overdue update and explain the delay.

4) Eligibility

To take part you must:

• be at least 18 years old and have legal capacity to contract;
• hold a FINFLO account registered in your own name;
• pay using funds that are lawfully yours, from a payment instrument in your own name; and
• accept these Terms and Regulatory Notice before payment.

FINFLO may decline or reverse participation where eligibility is not met, where information provided is inaccurate, or where accepting the payment would breach applicable law or a partner requirement.

5) Founding Supporter benefits

Subject to the terms of this notice, each eligible Founding Supporter may become eligible for the following. Every benefit is conditional. None of them is a payment, a cash balance, a stored-value credit, a loan, a return on the amount contributed, or a guarantee that any money will be placed in a wallet or paid to you.

5.1 Future wallet-limit benefit

FINFLO’s current standard maximum wallet balance is UGX 10,000,000, subject to the terms, identity-verification requirements, risk controls, and applicable limits of the wallet service.

Founding Supporters may become eligible for a higher maximum wallet-balance limit, calculated from the amount they have contributed as described above. A maximum-balance limit governs only how much a wallet is permitted to hold. It does not place, credit, or promise any money.

A higher limit will only be applied:

• after the relevant wallet service is lawfully available; and
• after you satisfy all applicable customer due-diligence, identity-verification, risk-assessment, regulatory, and partner requirements — including verified KYC on your FINFLO account.

FINFLO may decline, reduce, suspend, or vary a limit where required by law, a regulator, a licensed payment partner, fraud-prevention controls, or its applicable terms. The applicable tier, proposed limit, eligibility requirements, and effective date will be published before the benefit is activated.

5.2 Annual member reward (Rewards Cash)

A Founding Supporter whose tier carries an annual member reward may be granted that amount of Rewards Cash once in each membership year, where the conditions in this notice are met. The amount is calculated from what you have contributed, between the two figures shown for your tier in section 6, on the same basis as every other benefit.

Rewards Cash is not money and is not your money. It is a benefit balance that can only be applied to reduce what you pay for services within FINFLO. It cannot be withdrawn, cashed out, transferred to another person, sent to a bank or mobile-money account, or converted into currency, and it has no value outside FINFLO. It is not a deposit, not interest, not a dividend, not a return on your contribution, and not a refund of it.

The reward is paid for a limited number of years. It is granted at most 0 times in total, after which no further reward is granted, although every other benefit continues. The count is of rewards actually granted to you, so years in which you did not qualify are not counted against you.

A reward year runs for twelve months from the date of your first completed contribution, not from 1 January. The reward for a year is granted once. Where your total rises part-way through a year so that a larger amount would apply, you are granted the difference between the two — not a second full reward, and it does not count as an additional year. Where your total falls, a reward already granted for that year is not reclaimed.

No reward is granted until your tier is active under section 5.1, including verified KYC. Where you satisfy those conditions part-way through a year, the reward for the year then in progress is granted at that point.

Amounts and the number of years may be varied on notice published on this page. FINFLO may reverse Rewards Cash granted in error, obtained through abuse of the programme, or attached to a contribution that is later reversed or charged back.

5.3 Monthly free trades

A Founding Supporter whose tier carries a monthly free-trade allowance may have the FINFLO fuel fee waived on a number of qualifying YEM transactions in each calendar month. That number is calculated from the amount you have contributed, between the two figures shown for your tier in section 6, and is rounded to a whole number of trades. Qualifying transactions are those that carry the fuel fee — buying and selling YEM on the exchange, YEM crypto trades, and agent YEM float top-ups.

The allowance is a monthly count, not a balance. Unused trades do not roll over into the next month and are never paid out in any form. Where the allowance for a month is exhausted, ordinary fees apply to further trades. Where a trade is reversed, the allowance used on it is returned. Other fees, including the YEM network fee, are unaffected by this benefit.

5.4 Micro-insurance cover (closed to new enrollments)

Micro-insurance cover was previously offered with certain tiers. It is no longer part of any tier, and no new enrollment is opened under this programme. It is replaced by the annual member reward in section 5.2.

Where an insurance enrollment was already opened for you, it is unaffected by that change and continues under the terms of the applicable policy schedule until it lapses, expires, or is cancelled under the policy. Cover began only where the insurer or authorized provider confirmed enrollment and issued a policy, certificate, or other evidence of cover; no cover ever began merely because a payment was made. FINFLO is not the insurer and does not underwrite, guarantee, or settle claims. Any claim is determined by the insurer under the policy terms.

5.5 Head start on new features

Where FINFLO gives a new feature or product a members-first window, Founding Supporters reach it before other users. The length of that window is calculated from the amount you have contributed, between the two figures shown for your tier in section 6, rounded to a whole number of days, and counted backwards from the date the feature opens to everyone. A 30-day head start reaches a feature launching on 1 October from 1 September; a 7-day head start reaches it from 24 September.

Every feature opens to all users on its published public date, whatever tier you hold or do not hold. The head start brings a launch forward for members; it never keeps a feature away from anyone permanently, and no feature is reserved to Founding Supporters indefinitely.

A head start applies only where FINFLO gives a particular launch one. It is not automatic, it is not applied to every new feature, and FINFLO may launch a feature to everyone at once. Where a launch has no published public date, no head start runs on it. Dates may move, and a feature may be changed, delayed or withdrawn before it launches.

This benefit follows the same conditions as the rest of section 5, including verified KYC. Where a feature is unavailable to you for another reason — it is switched off for your account, unavailable in your app, or restricted by law, a regulator or a partner — a head start does not override that.

6) Tiers and indicative benefit levels

Your tier is determined by the total of your completed contributions, not by any single payment: you are placed in the highest active tier whose minimum your lifetime total has reached. Repeat contributions can therefore move you to a higher tier. Pending, failed, or reversed payments do not count.

A tier marked arranged directly with us cannot be paid for in the app. Contributions to it are made by bank transfer after speaking to our team, and are recorded against your account once the transfer is received. It is not part of the automatic progression in section 6.1: reaching it is a conversation, not a running total.

6.1 Paying a tier in installments

You do not have to reach a tier in one payment. You may contribute toward a tier in installments — for example 30,000 UGX now and 20,000 UGX later — until your total reaches that tier’s minimum. A minimum amount applies to each individual installment; it is shown to you before you pay and may be varied on notice published on this page.

While you are contributing toward a tier, that tier is the only one you can contribute toward. You cannot begin paying toward a different tier until the one in progress is complete. Once your total reaches it, the tier is applied to you and any further contribution automatically counts toward the next tier above.

No tier, and no benefit attached to a tier, applies until your total actually reaches that tier’s minimum. Until then, you hold no tier and receive none of the benefits in section 5, however many installments you have made.

Nothing you contribute is lost if you stop part-way. Every completed contribution stays on your lifetime total permanently and continues to count toward any tier you reach later, whether that is a month or a year afterwards. Amounts contributed are not forfeited, do not expire, and are not reduced for stopping, and we do not require you to keep paying.

The cancellation right in section 8 applies to each installment separately, and the period for it runs from the date that individual installment completed — not from the date the tier is finished.

7) Payment and use of funds

Contributions are paid by mobile money, card, or PayPal. Your FINFLO wallet balance is never debited to make a contribution — a contribution is a separate payment made to FINFLO. Where a contribution is charged in another currency, the amount and exchange rate applied are recorded against your contribution.

The amount paid under the Founding Supporter Program will be used for FINFLO’s lawful licensing, regulatory-readiness, technology, and compliance purposes.

Payments under this programme:

• do not create ownership, shares, dividends, interest, repayment rights, or financial returns;
• are not withdrawable wallet funds;
• do not guarantee that FINFLO will obtain a license, launch by a particular date, or provide a particular product; and
• are not refundable on request once the cancellation window in section 8 has closed.

Where a payment fails, is duplicated in error, or is charged incorrectly by a payment provider, contact us using the details in section 14 so the transaction can be investigated and corrected.

8) Cancellation and refunds

8.1 Your 14-day cancellation window

You may cancel a contribution and receive it back in full, for any reason and without having to give one, if you request the cancellation within 14 days of the date the payment completed and before any benefit has been activated for you — that is, before a higher wallet-balance limit has been applied to your account, before any annual member reward has been granted to you, and before you have used any free trade under your tier.

Where a benefit has already been activated, the contribution that unlocked it can no longer be cancelled under this section, because the benefit has already been provided.

8.2 Discretionary refunds outside that window

After the cancellation window closes, contributions are not refundable on request. FINFLO may nevertheless return a contribution, at its discretion, where:

• you were charged twice for the same contribution, or charged an amount you did not authorize;
• a payment provider processed the payment in error;
• you were not eligible to take part under section 4, and no benefit has been activated;
• FINFLO closes or withdraws the Founding Supporter Program before any benefit has been activated for you; or
• we consider a refund appropriate in the particular circumstances.

Section 8.2 is a discretion we may exercise, not a right you can require us to exercise. It does not make your contribution repayable on demand or on the occurrence of any condition, and it does not make this programme a deposit, savings product, or investment.

8.3 How to request a refund

Email refund-founder@finflo.net from the email address on your FINFLO account, stating:

• your full name and the phone number on your FINFLO account;
• the payment reference, date, and amount; and
• whether you are cancelling within the 14-day window (section 8.1) or asking us to consider a discretionary refund (section 8.2), and why.

We aim to acknowledge a refund request within 5 business days and to decide it within 30 days of receiving the information we need. Where we decline a discretionary request we will tell you why. Approved refunds are returned to the original payment method where possible, and otherwise to an account in your own name; we do not refund to a third party.

8.4 What a refund reverses

A refunded contribution stops counting as a contribution. This means:

• your lifetime contribution total is recalculated without it, which may reduce or remove your tier;
• any wallet-balance uplift granted by that tier is reduced or removed accordingly, and you must bring your balance within the applicable limit;
• no further annual member reward is granted, and any unused Rewards Cash and unused free trades attached to that tier cease to be available; and
• the contribution stops counting toward any published progress figure, and your recognition entry is updated or removed.

A refund is not available in respect of a benefit you have already used.

9) Recognition and publicity

Founding Supporters may be listed in FINFLO recognition features. You may choose to be listed anonymously; your contribution still counts in full. You may ask us to change or withdraw how you are displayed at any time.

10) Financial crime, source of funds, and sanctions

FINFLO applies anti-money-laundering and counter-terrorist-financing controls. We may request information on your identity and source of funds, and may decline, delay, or report a payment where required by law. Participation is not available where it would breach applicable sanctions or where the payer cannot be adequately identified.

11) Data protection

Personal data collected for this programme is processed to administer participation, verify identity, meet legal and regulatory obligations, and arrange insurance enrollment where applicable. Data may be shared with payment providers, the insurance partner, professional advisers, and competent authorities where lawfully required. Data is handled in accordance with applicable Ugandan data-protection law and the FINFLO privacy policy.

12) Taxation

You are responsible for your own tax position in relation to your participation and any benefit received. FINFLO does not provide tax advice.

13) Changes, suspension, and closure

FINFLO may amend this notice, and may pause, close, or withdraw the Founding Supporter Program, including where required by law, a regulator, or a partner. Material changes will be published on this page with an updated “last updated” date. Where a change materially reduces a benefit already indicated to you, we will publish the change before it takes effect.

Nothing in this notice limits any right you have that cannot lawfully be excluded.

14) Questions and complaints

For programme questions or to raise a complaint, contact:

FINFLO (U) LTD
Email: info@finflo.net
Telephone: +256 757 884396 or +256 789 569871

For cancellations and refund requests, use refund-founder@finflo.net instead, as set out in section 8.3.

Please include your name, the phone number on your FINFLO account, and the payment reference. We aim to acknowledge complaints within 5 business days. Complaints about an insurance policy or a claim may also be raised directly with the insurer named in your policy schedule.

15) Governing law

This notice is governed by the laws of the Republic of Uganda, and the courts of Uganda have jurisdiction over any dispute arising from it.

See also: Transparency & Compliance Statement · Policies