TURIKUMWE CAMPAIGN CREATOR TERMS OF SERVICE

Effective Date: 17 June 2026 Version: 1.0 Last Updated: 17 June 2026

PREAMBLE

Welcome to Turikumwe ("Turikumwe", "we", "us", or "our"). The name "Turikumwe" means "we are together" in Kinyarwanda, and that idea is at the heart of what we do. Turikumwe operates an online crowdfunding platform (the "Platform") that allows individuals, families, communities, and organizations across Rwanda and East Africa to raise funds from donors in Rwanda and around the world for the causes they care about — including medical care, education, funerals and bereavement, weddings, business ventures, community projects, religious solicitation, political fundraising, legal defense, emergency relief, personal hardship, creative projects, and many more lawful purposes.

Turikumwe is operated by Astoria LTD, a private company incorporated under the laws of the Republic of Rwanda pursuant to the Law N° 007/2021 of 05/02/2021 governing companies (as amended), with RDB Company Code / TIN 156457878 and registered office at Runyonza Village, Nyagahinga Cell, Rusororo Sector, Gasabo District, Kigali City, Rwanda (the "Company").

In these Terms of Service (these "Terms"), "Turikumwe", "we", "us", and "our" refer to Astoria LTD in its operation of the Platform.

These Terms govern your use of the Platform as a Campaign Creator (defined below). By creating an Account, launching a Campaign, or otherwise using the Platform as a Campaign Creator, you agree to be legally bound by these Terms. If you do not agree, do not use the Platform.

Read carefully. Sections 9 (Fraud, Misrepresentation, and Law Enforcement Cooperation), 14 (Disclaimers and Limitation of Liability), 15 (Indemnification), and 17 (Dispute Resolution) contain particularly important provisions that affect your legal rights, including a mandatory arbitration agreement under the rules of the Kigali International Arbitration Centre (KIAC).

1. DEFINITIONS

In these Terms, the following capitalized terms have the meanings set out below.

1.1 "Account" means the user account a Campaign Creator registers on the Platform.

1.2 "Applicable Law" means all laws, statutes, regulations, rules, orders, judgments and binding regulatory guidance applicable to a party, including (without limitation) the laws of the Republic of Rwanda and any other jurisdiction whose laws apply to a transaction, Campaign, or user.

1.3 "Beneficiary" means the natural person, family, group, or legal entity for whose benefit a Campaign is created and who is intended to receive the Net Funds. The Beneficiary may be the Campaign Creator or a third party identified in the Campaign.

1.4 "Campaign" means a fundraising page or project created and published on the Platform.

1.5 "Campaign Creator" or "Organizer" means the natural person who registers an Account and creates, manages, or controls a Campaign.

1.6 "Content" means any text, photographs, images, videos, audio, links, documents, descriptions, beneficiary information, or other materials submitted by a Campaign Creator to the Platform.

1.7 "Donor" means any person or entity that makes a Donation to a Campaign.

1.8 "Donation" means a contribution of funds made by a Donor through the Platform in respect of a Campaign.

1.9 "Fees" means the Platform Fee and any Provider Fees, together with any applicable Taxes.

1.10 "Funds" means all monies contributed by Donors to a Campaign, before deduction of Fees.

1.11 "Gross Funds" means the total Donations received in respect of a Campaign, before deduction of Fees.

1.12 "KYC" means know-your-customer due diligence required by Applicable Law or by Turikumwe, including identity verification, source-of-funds checks, and sanctions screening.

1.13 "Mobile Money Account" means an electronic wallet held with a licensed Mobile Money Provider in the name of the Campaign Creator or Beneficiary.

1.14 "Mobile Money Providers" means MTN Rwanda (Mobile Money / MoMo), Airtel Rwanda (Airtel Money), and any other mobile money or electronic money issuer Turikumwe may integrate from time to time.

1.15 "Net Funds" means the Gross Funds minus the Platform Fee, any Provider Fees, Taxes, refunds, chargebacks, reversals, and any other lawful deductions.

1.16 "Platform Fee" means the fee charged by Turikumwe for the use of the Platform, currently two percent (2%) of Gross Funds (exclusive of VAT, if applicable), deducted upon withdrawal as described in Section 5.

1.17 "Provider Fees" means any fees, charges, levies, or commissions assessed by a Mobile Money Provider, bank, card network, or other payment service provider in connection with the contribution, holding, transfer, or withdrawal of Funds. Provider Fees are determined by the relevant provider, not by Turikumwe, and are passed through to the Campaign Creator and/or Donor as applicable.

1.18 "Platform" means the Turikumwe website, mobile applications, application programming interfaces (APIs), USSD/short-code services, and all related online services operated by Turikumwe.

1.19 "RWF" means the Rwandan Franc, the lawful currency of the Republic of Rwanda.

1.20 "Taxes" means any value-added tax (including Rwandan VAT under the Law establishing Value-Added Tax in Rwanda), withholding tax, sales tax, use tax, mobile-money transaction tax, or other governmental charge applicable to Fees, Donations, or transfers.

1.21 "Withdrawal" means the transfer of Net Funds from Turikumwe (or its custodial or partner trust account) to the Campaign Creator's or Beneficiary's verified Mobile Money Account or bank account.

Other capitalized terms are defined where they first appear.

2. ACCEPTANCE OF TERMS; ELIGIBILITY

2.1 Acceptance. By registering an Account, ticking an "I agree" box, clicking "Create Campaign", or otherwise using the Platform as a Campaign Creator, you confirm that you have read, understood, and agree to be legally bound by these Terms and by all policies incorporated herein by reference, including the Turikumwe Privacy Policy, Acceptable Use Policy, Donor Terms of Service, and Cookie Policy (collectively, the "Platform Policies").

2.2 Age and Capacity. You represent and warrant that:

(a) you are at least eighteen (18) years of age;

(b) you have full legal capacity to enter into a binding contract under the laws of your country of residence;

(c) if you are creating a Campaign on behalf of a legal entity, religious organization, NGO, cooperative, or other body, you are duly authorized to bind such entity, and references to "you" include that entity; and

(d) you are not a person who has previously been suspended, banned, or terminated by Turikumwe or any of its affiliates.

2.3 Residency and Reach. The Platform is operated primarily for users located in Rwanda and East Africa, but Donations may be received from Donors worldwide through integrated payment channels. You are solely responsible for ensuring that your use of the Platform complies with the laws of every jurisdiction relevant to you and to the Beneficiary.

2.4 Sanctions Screening. You represent and warrant that you, the Beneficiary, and any person whom you control or who controls you, are not:

(a) the subject of any sanctions administered or enforced by the United Nations Security Council, the Office of Foreign Assets Control of the U.S. Department of the Treasury ("OFAC"), the European Union, the United Kingdom, the African Union, or any other relevant authority; or

(b) located in or organized under the laws of any country or territory subject to comprehensive sanctions.

You agree that Turikumwe may screen you, the Beneficiary, and any related party against applicable sanctions lists (including the OFAC SDN List, the UN Consolidated Sanctions List, the EU Consolidated Financial Sanctions List, the UK OFSI Consolidated List, and lists maintained by the Republic of Rwanda) at onboarding and on an ongoing basis. Turikumwe may refuse, suspend, freeze, or reverse any transaction if a sanctions match is detected or suspected.

2.5 Conflicts. In the event of any conflict between these Terms and any Platform Policy, these Terms shall prevail unless the Platform Policy expressly states otherwise.

3. ACCOUNT REGISTRATION AND KYC

3.1 Account Registration. To create a Campaign you must register an Account by providing accurate, current, and complete information, including your full legal name, mobile telephone number, valid e-mail address, date of birth, and physical address. You agree to keep this information up to date and to notify Turikumwe promptly of any changes.

3.2 Identity Verification. Turikumwe is committed to a safe and trusted Platform. As a condition of creating a Campaign and/or withdrawing Funds, you agree to complete identity verification ("KYC"), which may include providing:

(a) for Rwandan citizens and residents: a valid Rwandan National Identity Card (Indangamuntu) issued by the National Identification Agency (NIDA), or a temporary resident permit issued by the Directorate General of Immigration and Emigration;

(b) for non-Rwandan users: a valid passport, national identity card, driver's licence, or other government-issued photo identification;

(c) a recent photograph or "selfie" (which may be matched biometrically against your ID);

(d) verification that the Mobile Money Account you supply is registered in your legal name with MTN Rwanda or Airtel Rwanda and has completed the Mobile Money Provider's own KYC requirements under Rwandan law and applicable BNR mobile-money KYC directives;

(e) proof of address, source of funds, source of wealth, beneficial-ownership information (for entities), or other documents reasonably required by Turikumwe to comply with Applicable Law, including:

(i) the Rwandan Law N° 75/2019 of 29/01/2020 on the prevention and punishment of money laundering, financing of terrorism and financing of proliferation of weapons of mass destruction, as amended by Law N° 038/2021 (the "Rwandan AML/CFT Law");

(ii) Law N° 045/2021 of 18/08/2021 governing the Financial Intelligence Centre (the "FIC Law"), as amended;

(iii) the FIC Regulations (Regulation N° 01/2022 of 16/02/2022) and FIC directives in force from time to time.

3.3 Enhanced Due Diligence. Turikumwe may require enhanced due diligence for high-value Campaigns, politically exposed persons (PEPs), Campaigns involving foreign beneficiaries, or Campaigns presenting elevated risk. Turikumwe may at any time request additional information or documentation, and may suspend an Account, freeze a Campaign, or delay a Withdrawal pending receipt of satisfactory information.

3.4 Account Security. You are solely responsible for safeguarding your login credentials, mobile-money PIN, and one-time passwords. You agree not to share your credentials and to notify Turikumwe immediately at security@turikumwerw.com of any unauthorized use of your Account. You are responsible for all activity conducted through your Account.

3.5 One Account. Each individual may maintain only one personal Account, unless Turikumwe expressly authorizes otherwise in writing.

4. CREATING A CAMPAIGN

4.1 Open to All Lawful Causes. Turikumwe does not restrict the categories of causes that may be fundraised for, provided the Campaign and its use of Funds are lawful under Applicable Law. Permitted causes include, without limitation:

• medical and healthcare costs;
• education, tuition, and school fees;
• funeral, bereavement, and memorial expenses;
• weddings and family celebrations;
• business and entrepreneurial ventures;
• community development and umuganda projects;
• religious solicitation, missions, and faith-based causes;
• political fundraising (subject to Section 4.7);
• legal defense and access-to-justice;
• emergency, disaster, and humanitarian relief;
• personal hardship;
• creative, artistic, and cultural projects;
• sports, scholarships, and youth programs; and
• any other lawful purpose.

The fact that Turikumwe permits a category does not constitute an endorsement of any particular Campaign, Campaign Creator, or Beneficiary.

4.2 Required Disclosures. For every Campaign, you must clearly and accurately disclose:

(a) your full legal name (or, where Turikumwe permits, a display name linked to your verified identity);

(b) the identity of the Beneficiary, including, where the Beneficiary is a third party, their name, your relationship to them, and (where applicable) their consent;

(c) a truthful, non-misleading description of the cause, including supporting facts;

(d) the fundraising goal, expressed in RWF;

(e) the intended use of Funds, with sufficient specificity to allow a reasonable Donor to make an informed decision;

(f) how Funds will be transferred to the Beneficiary, where you are not the Beneficiary; and

(g) any conflicts of interest, prior fundraising, or material risks reasonably relevant to Donors.

4.3 Beneficiary Consent. Where the Beneficiary is a third party, you represent and warrant that the Beneficiary (or their legal guardian, where the Beneficiary is a minor or lacks capacity) has consented to the Campaign and to the use of their name, image, and story. For minors, you must have the express written consent of a parent or legal guardian, and Funds must be either (i) paid into an account held in trust for the minor or (ii) used directly for the minor's documented benefit.

4.4 Accuracy of Content. You represent and warrant that all Content you submit — including photographs, videos, medical or financial documents, and stories — is true, accurate, current, complete, and not misleading. You will not exaggerate or fabricate facts to induce Donations.

4.5 Prohibited Content. Notwithstanding Section 4.1, you may not post Content that:

(a) is unlawful, fraudulent, defamatory, obscene, pornographic, or invasive of another's privacy;

(b) infringes any intellectual property right or other proprietary right;

(c) incites discrimination, genocide ideology, hatred, or violence (including any conduct prohibited by Rwanda's Law N° 59/2018 of 22/08/2018 on the crime of genocide ideology and related crimes);

(d) contains malware, spyware, or other harmful code; or

(e) is prohibited by the Acceptable Use Policy.

4.6 No Goods or Services in Return. Unless Turikumwe expressly authorizes a "rewards" or "products" feature, you must not offer or provide goods or services to Donors in return for Donations. Donations are gifts and are not consideration for any product or service.

4.7 Political and Election-Related Campaigns. Political fundraising is permitted, but you remain solely responsible for compliance with all applicable Rwandan electoral, campaign-finance, and political-party laws (including the laws and regulations administered by the National Electoral Commission and the Rwanda Governance Board), and, where Donors or Beneficiaries are in other jurisdictions, the campaign-finance laws of those jurisdictions. Turikumwe is not a political committee and does not provide political-finance advice.

4.8 Religious Campaigns. Religious solicitation is permitted across faith traditions. You are responsible for any registration or reporting obligations under Rwandan laws governing faith-based organizations.

4.9 Tax Reporting. You are solely responsible for determining whether Funds raised constitute taxable income or trigger any reporting obligation under the laws of Rwanda (including the Rwanda Revenue Authority's rules) or any other jurisdiction relevant to you or the Beneficiary, and for complying with those obligations.

5. FEES AND PAYMENTS

5.1 Currency. All transactions on the Platform are denominated in Rwandan Francs (RWF), unless Turikumwe expressly enables another currency. Donations made in foreign currencies will be converted into RWF at a rate determined by the relevant Mobile Money Provider, payment processor, or foreign exchange partner, and any conversion costs will be borne by the Campaign Creator and/or Donor as applicable.

5.2 Turikumwe Platform Fee. Turikumwe charges a Platform Fee of two percent (2%) of Gross Funds. The Platform Fee is deducted at Withdrawal from the Funds otherwise payable to you. The Platform Fee may be adjusted from time to time in accordance with Section 19.

5.3 VAT. Where Rwandan value-added tax ("VAT") is chargeable on the Platform Fee under the Rwandan Law establishing the Value-Added Tax (as amended), VAT (currently 18% standard rate) will be added to and shown separately from the Platform Fee, and you authorize Turikumwe to deduct VAT at Withdrawal.

5.4 Mobile Money and Other Provider Fees. Donors and Campaign Creators are also subject to fees, charges, taxes (including any mobile-money transaction tax administered by the Rwanda Revenue Authority, where applicable), and limits set independently by the Mobile Money Providers and other payment processors. These are Provider Fees. Turikumwe does not set, control, or receive Provider Fees; they are determined and administered by the relevant provider (e.g., MTN Mobile Money, Airtel Money) under that provider's own terms and applicable BNR regulations governing payment service providers and electronic money issuers.

5.5 Transparency. Turikumwe will display in the user interface, before you finalize a Withdrawal: (a) Gross Funds; (b) the Platform Fee (and any VAT); (c) the estimated Provider Fees; and (d) the estimated Net Funds.

5.6 No Hidden Fees. Turikumwe does not charge sign-up fees, monthly fees, or per-donation fees beyond the Platform Fee. New fees, if introduced, will be added only in accordance with Section 19.

5.7 Tax Withholding. Where Applicable Law requires Turikumwe to withhold any tax on payments to you, Turikumwe will do so and remit such tax to the relevant authority, and you will be entitled to the net amount.

6. WITHDRAWAL OF FUNDS

6.1 Withdrawal Eligibility. You may request Withdrawal of available Net Funds at any time, provided that (a) your KYC is complete and current; (b) your Campaign and Account are in good standing; (c) no investigation, dispute, freeze, or hold is in effect; and (d) you meet any minimum Withdrawal threshold posted on the Platform.

6.2 Withdrawal Destinations. Net Funds will be transferred to a verified Mobile Money Account or bank account in the legal name of the Campaign Creator or, where Turikumwe approves a direct payout to the Beneficiary, in the legal name of the Beneficiary. Withdrawals to accounts that are not in the verified name of an approved recipient are not permitted.

6.3 Standard Payout Timing. Turikumwe will use commercially reasonable efforts to initiate Withdrawals within two (2) to five (5) business days of a complete and valid request. Actual receipt depends on the Mobile Money Provider's or bank's processing time and is not guaranteed by Turikumwe.

6.4 Verification Holds. Turikumwe may place a hold on, delay, or refuse a Withdrawal where it reasonably believes that:

(a) verification of identity, beneficiary information, or use of funds is incomplete; (b) the Campaign or any Donation may be the subject of dispute, chargeback, or refund; (c) the Campaign may violate these Terms or Applicable Law; (d) fraud, money laundering, terrorism financing, sanctions risk, or other unlawful conduct is suspected; (e) compliance with a court order, regulatory request, or law-enforcement request requires it; or (f) the financial integrity of the Platform requires it.

A hold may continue for as long as is reasonably necessary, and may be permanent where required by Applicable Law.

6.5 Failed or Reversed Transfers. Mobile money transfers may fail for many reasons (e.g., wallet inactive, daily limit exceeded, wrong number, network outage, provider compliance hold). If a Withdrawal fails:

(a) Turikumwe will use reasonable efforts to investigate and re-attempt the transfer to the same verified account; (b) the failed Withdrawal will be re-credited to your Platform balance, less any non-refundable Provider Fees actually incurred; and (c) you authorize Turikumwe to debit your Account or Withdrawal balance to recover any amounts erroneously paid to you or required to be returned to a Donor or Mobile Money Provider.

6.6 Irreversibility of Mobile Money. You acknowledge that, once mobile money has been credited to a recipient's wallet and accepted, it is generally irreversible without the cooperation of the receiving party. Turikumwe is not liable for funds that have been delivered to an incorrect recipient because of inaccurate or misleading information you supplied.

6.7 Right of Set-Off. Turikumwe may set off against any amount payable to you any amount you owe to Turikumwe, including for Provider Fees, chargebacks, refunds, reversals, taxes, indemnification obligations, or amounts due under Section 9.

6.8 Dormant Funds. If you fail to withdraw Net Funds within twelve (12) months after the close of the Campaign and do not respond to Turikumwe's reasonable outreach, Turikumwe may, in its sole discretion and subject to Applicable Law (including any Rwandan unclaimed-property rules), refund Donors, donate the funds to a charitable beneficiary aligned with the original Campaign purpose, or transfer the amounts to the relevant unclaimed-property authority.

7. USE OF FUNDS; BENEFICIARY OBLIGATIONS

7.1 Exclusive Use for Stated Purpose. You covenant that all Funds received in respect of a Campaign will be used exclusively for the purpose described in the Campaign. You will not use Funds for any other purpose, including any personal benefit not described to Donors.

7.2 Transfer to Beneficiary. Where you are not the Beneficiary, you covenant to transfer the Net Funds to the Beneficiary promptly and without unreasonable deduction, in a manner that allows traceability. You agree to maintain records of the transfer and provide them to Turikumwe upon request.

7.3 Reporting to Donors. You agree to keep Donors reasonably informed via Campaign updates about the progress and use of Funds, particularly for Campaigns that remain open for an extended period or that exceed their original goal.

7.4 Reporting to Turikumwe. Turikumwe may, at any time and in its sole discretion, require you to:

(a) provide evidence of how Funds have been or will be used (e.g., invoices, receipts, hospital bills, school fee invoices, photographs of project deliverables); (b) provide proof that the Beneficiary has received the Funds; (c) provide a written statement from the Beneficiary confirming receipt; or (d) provide such other information as Turikumwe reasonably requires to confirm compliance with Section 7.1.

Failure to respond within a reasonable time may result in suspension of the Campaign, holding of Withdrawals, refund to Donors, and/or referral to law enforcement.

7.5 Surplus Funds. If Funds raised exceed the amount needed for the stated purpose, you must use the surplus in a manner consistent with the spirit of the Campaign and reasonable Donor expectations, or contact Turikumwe to facilitate refunds, redirect to a related charitable purpose, or transfer to a charitable beneficiary.

7.6 Change of Purpose. A material change in the use of Funds requires (a) prominent disclosure to Donors on the Campaign page, (b) a reasonable opportunity for Donors to request a refund, and (c) Turikumwe's prior written approval where the change is significant.

8. PROHIBITED CONDUCT

8.1 General Prohibition. You agree that you will not, and will not allow any third party acting on your behalf to, use the Platform to:

(a) engage in any illegal activity under Applicable Law, including any predicate offence to money laundering;

(b) commit, attempt, or facilitate fraud, theft, embezzlement, misrepresentation, or deception of any kind (see Section 9);

(c) launder the proceeds of crime, finance terrorism, or finance the proliferation of weapons of mass destruction, in violation of the Rwandan AML/CFT Law or any equivalent law;

(d) breach economic or trade sanctions imposed by the United Nations, the European Union, the United States (including OFAC), the African Union, the Republic of Rwanda, or any other competent authority;

(e) finance, facilitate, or benefit from human trafficking, modern slavery, child labour, child sexual abuse material, or the trafficking of human organs;

(f) finance, facilitate, or promote terrorism, violent extremism, the recruitment of mercenaries, or activities of any organization designated as terrorist by a competent authority;

(g) finance, distribute, or promote firearms, explosives, ammunition, drug paraphernalia, narcotics, or other controlled goods in violation of Applicable Law;

(h) promote, facilitate, or finance illegal gambling, pyramid schemes, multi-level marketing fraud, Ponzi schemes, or any "investment" promising guaranteed returns;

(i) harass, intimidate, defame, or "doxx" any person, or use the Platform to dox, threaten, or coerce a Donor, Beneficiary, or third party;

(j) infringe any intellectual property, publicity, or privacy right;

(k) impersonate any person or entity, or misstate your affiliation with any person or entity;

(l) use bots, scrapers, or automated tools to access or interact with the Platform without authorization, or otherwise attack, probe, or interfere with the Platform's infrastructure;

(m) circumvent or attempt to circumvent any KYC, sanctions, fraud, or risk control implemented by Turikumwe, a Mobile Money Provider, or any payment processor;

(n) post Content that violates Rwanda's Law N° 60/2018 of 22/08/2018 on prevention and punishment of cyber-crimes, including unlawful access, illegal interception, computer-related fraud, identity-related offences, spamming, or the dissemination of false information;

(o) violate Rwanda's genocide-ideology and divisionism laws, or use the Platform to deny, minimize, or justify the 1994 Genocide against the Tutsi;

(p) engage in any conduct that is, in Turikumwe's reasonable judgment, contrary to public order or morality in Rwanda; or

(q) violate the Acceptable Use Policy.

8.2 No Restriction on Lawful Causes. Nothing in Section 8.1 shall be construed to prohibit fundraising for any lawful cause, including religious, political, medical, educational, legal-defense, or hardship causes that are otherwise legal. The categories of causes permitted under Section 4.1 remain unrestricted, subject only to the prohibitions of this Section 8 and to Applicable Law.

9. FRAUD, MISREPRESENTATION, AND LAW ENFORCEMENT COOPERATION

This Section 9 is among the most important provisions of these Terms. Please read it carefully.

9.1 Express Representations and Warranties

By creating a Campaign, you irrevocably represent, warrant, and covenant to Turikumwe and to every Donor that:

(a) You are not engaged in fraud, misrepresentation, or deception of any kind. You are not creating the Campaign with any intent to deceive, mislead, or defraud Turikumwe or any Donor.

(b) All statements are truthful. Every statement, photograph, video, document, identity record, financial record, beneficiary description, story, name, relationship, medical claim, educational claim, business claim, and projection you provide in connection with the Campaign is true, accurate, complete, current, and not misleading in any material respect.

(c) The Beneficiary is real and has been correctly identified. The Beneficiary actually exists, is in the circumstances described, and (where required) has consented to the Campaign.

(d) Funds will be used exclusively for the stated purpose. You will not use Funds, in whole or in part, for any purpose other than that described in the Campaign.

(e) You are not a sanctioned, proscribed, or wanted person, and you are not raising funds for a sanctioned, proscribed, or wanted person.

(f) You have all necessary rights and consents to provide the Content (including the right to use names, images, and personal data of any third party featured in the Campaign).

(g) You will not solicit Donors through false, misleading, or deceptive means, including spam, deepfakes, manipulated media, fake testimonials, or impersonation.

(h) You will not request, accept, or facilitate the payment of Donations outside the Platform for the purpose of evading Turikumwe's compliance controls.

9.2 Acknowledgement of Criminal Exposure

You acknowledge and understand that fraud, theft by deception, embezzlement, misrepresentation, money laundering, and the financing of terrorism are serious crimes under, among others:

(a) The Rwandan Penal Code (Law N° 68/2018 of 30/08/2018 determining offences and penalties in general, as amended including by Law N° 059/2023 of 04/12/2023), including, without limitation:

• the offences within Chapter on Fraudulent Appropriation of the Property of Others, including Article 165 (definitions of terms relating to fraudulent appropriation), Article 166 (penalties for theft), Article 167 (aggravating circumstances of theft), Article 168 (theft with violence), and the related provisions on theft, theft by deception, and aggravated theft;
• the offence of fraud (escroquerie) (Article 299) — obtaining property of another by deceitful manoeuvres;
• the offence of embezzlement / breach of trust (Article 314);
• forgery, use of forged documents, and false statements; and
• attempt and complicity in any of the foregoing;

(b) the Rwandan AML/CFT Law (Law N° 75/2019 of 29/01/2020 as amended by Law N° 038/2021), which provides for substantial imprisonment terms and fines (including, for legal entities, fines of ten (10) to twenty (20) times the amount laundered or financed, and imprisonment of seven (7) to ten (10) years for money laundering and twenty (20) to twenty-five (25) years for terrorism financing);

(c) the Rwandan Cyber-Crime Law (Law N° 60/2018 of 22/08/2018), including provisions on computer-related fraud, identity theft, and dissemination of false information; and

(d) any other Applicable Law of any jurisdiction in which you, the Beneficiary, the Donor, Turikumwe, or its payment partners operate.

You further acknowledge that serious cross-border fraud may trigger an Interpol Red Notice, extradition proceedings, or coordinated multi-jurisdictional enforcement.

9.3 Consent to Law Enforcement Cooperation and Data Sharing

You expressly consent, on a continuing and irrevocable basis, that Turikumwe may, in its sole discretion and without prior notice to you (where notice would prejudice an investigation or breach Applicable Law), do any of the following in connection with confirmed, suspected, or alleged fraud, money laundering, terrorism financing, sanctions evasion, or other criminal conduct:

(a) Report and refer your Account, Campaign, identity records, KYC documents, transaction records, IP addresses, device identifiers, mobile money records, communications on the Platform, and any other data in Turikumwe's possession to any competent authority, including but not limited to:

• the Rwanda Investigation Bureau (RIB);
• the National Public Prosecution Authority (NPPA) of Rwanda;
• the Rwanda National Police;
• the Financial Intelligence Centre (FIC) of Rwanda, including the filing of Suspicious Transaction Reports (STRs);
• the National Bank of Rwanda (BNR);
• the Rwanda Revenue Authority (RRA);
• the National Cyber Security Authority (NCSA) of Rwanda;
• INTERPOL, including via the Rwandan National Central Bureau;
• AFRIPOL and other regional law-enforcement bodies; and
• any other regulator, prosecutor, court, financial intelligence unit, tax authority, or police service with jurisdiction.

(b) Respond to subpoenas, court orders, search warrants, production orders, mutual legal assistance treaty (MLAT) requests, Hague Evidence Convention requests, regulatory demands, and other lawful process from any of the above authorities, and disclose any information Turikumwe reasonably believes is responsive.

(c) Cooperate proactively with such authorities, including by participating in joint operations, providing witness testimony, preserving evidence, freezing funds at the request of a competent authority, and assisting in the recovery of misappropriated Funds.

(d) Share information with payment processors, Mobile Money Providers, banks, fraud-prevention networks, and other platforms, to detect, prevent, investigate, and remediate fraud, money laundering, and related misconduct.

(e) Preserve evidence, including by retaining your Account data, Content, and transaction records for as long as Turikumwe reasonably believes is necessary for investigation, prosecution, civil recovery, or regulatory compliance, notwithstanding any earlier deletion request from you.

9.4 Waiver of Certain Privacy Claims in Fraud Contexts

To the maximum extent permitted by Applicable Law, you waive and release Turikumwe, its affiliates, officers, directors, employees, and agents from any claim, complaint, demand, or cause of action — including under Rwanda's Law N° 058/2021 of 13/10/2021 on the protection of personal data and privacy (the "DPPL") or any other applicable privacy or data-protection law — arising out of Turikumwe's disclosure of your information in good faith to:

(a) a competent law-enforcement, prosecutorial, regulatory, judicial, or financial-intelligence authority; (b) a court, arbitrator, or other adjudicator pursuant to lawful process; (c) a Donor, Beneficiary, or potential victim where Turikumwe reasonably believes disclosure is necessary to prevent or remedy fraud or other harm; or (d) a payment partner, fraud-prevention network, or insurer in connection with a confirmed or suspected violation.

Nothing in this Section 9.4 limits the rights you cannot waive under Applicable Law, including any non-waivable rights under the DPPL.

9.5 Turikumwe's Remedies in Cases of Fraud

If Turikumwe reasonably believes (in its sole and good-faith judgment, based on available information) that you have engaged in fraud, misrepresentation, or any conduct described in Section 8 or this Section 9, Turikumwe may, in addition to its other rights, take any one or more of the following actions, at any time and without prior notice:

(a) immediately suspend, restrict, or terminate your Account and any associated Campaigns; (b) delist or take down the Campaign from the Platform; (c) freeze, hold, and refuse to release any Funds, whether collected, in transit, or already credited to your Platform balance; (d) reverse Donations and refund Donors to the extent technically and legally possible, including by debiting your Withdrawals already disbursed; (e) claw back disbursed Funds through chargebacks, reversals, civil recovery, or set-off, including against your Mobile Money Account or bank account; (f) publish factual information about the misconduct where lawful and consistent with our Privacy Policy and the DPPL; (g) bar you (and any related person) permanently from the Platform; (h) commence civil proceedings in any competent court (including in Rwanda) to recover losses, costs, and damages; (i) refer the matter to any of the authorities listed in Section 9.3; and (j) pursue any other remedy available at law or in equity.

9.6 Indemnification for Fraud

Without prejudice to Section 15, you agree to indemnify, defend, and hold harmless Turikumwe, its affiliates, officers, directors, employees, and agents from and against any and all losses, damages, fines, penalties, settlements, refunds, chargebacks, reversed transfers, taxes, investigative costs, legal fees (including reasonable attorneys' fees), forensic-accountant fees, and other costs and expenses arising out of or relating to:

(a) any actual, alleged, or suspected fraud, misrepresentation, deception, money laundering, terrorism financing, sanctions violation, or other unlawful conduct by you or by any person acting on your behalf; (b) any breach of the representations and warranties in Section 9.1; or (c) any cooperation by Turikumwe with law enforcement, regulators, or payment partners in respect of your conduct.

This indemnity is uncapped and survives termination of these Terms.

9.7 Survival

Sections 9.1 (Representations), 9.3 (Law-Enforcement Cooperation), 9.4 (Privacy Waiver), 9.5 (Remedies), and 9.6 (Indemnification) survive termination of these Terms indefinitely.

10. CONTENT LICENSE

10.1 Your Ownership. You retain ownership of the Content you submit. You do not transfer ownership to Turikumwe.

10.2 License to Turikumwe. You grant Turikumwe and its affiliates a worldwide, non-exclusive, royalty-free, sublicensable, transferable license to host, store, reproduce, modify (for technical reasons, e.g., formatting, resizing), publicly display, publicly perform, distribute, translate, and otherwise use the Content for the purposes of:

(a) operating, marketing, and improving the Platform; (b) displaying the Campaign to Donors and the public; (c) preventing fraud, abuse, and misuse; (d) complying with Applicable Law and lawful requests; and (e) creating aggregated, anonymized, or de-identified analytics.

10.3 Duration. The license continues for as long as the Content remains on the Platform plus a reasonable period for archival, legal, and fraud-prevention purposes after termination.

10.4 Third-Party Rights. You represent and warrant that you have all rights and consents necessary to grant this license, including, where applicable, rights of publicity and consents from any individuals depicted in or referenced by the Content.

10.5 Feedback. Any feedback, suggestions, or ideas you provide regarding the Platform are non-confidential, and you grant Turikumwe a perpetual, irrevocable, royalty-free license to use them without compensation.

11. INTELLECTUAL PROPERTY

11.1 Platform IP. The Platform, including all software, designs, logos, trade marks (including "Turikumwe"), trade names, text, graphics, photographs, videos, databases, and the selection and arrangement thereof, is owned by Turikumwe or its licensors and is protected by Rwandan and international intellectual property laws, including Rwanda's Law N° 31/2009 of 26/10/2009 on the protection of intellectual property (as amended).

11.2 Limited License to You. Subject to your compliance with these Terms, Turikumwe grants you a personal, limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Platform solely to manage your Campaign(s).

11.3 Restrictions. You will not (and will not permit any third party to) (a) copy, modify, distribute, sell, lease, or sublicense any part of the Platform; (b) reverse engineer, decompile, or attempt to extract the source code; (c) circumvent any technical protection measure; or (d) use the Platform to build a competing service.

11.4 Trademark Use. You may not use Turikumwe's name, logos, or marks except as expressly permitted by Turikumwe's brand guidelines or with prior written consent.

11.5 Copyright Complaints. Turikumwe will respond to notices of alleged copyright infringement under Rwandan intellectual-property law and applicable international treaties. Send notices to copyright@turikumwerw.com with all information required by Applicable Law.

12. PRIVACY AND DATA PROTECTION

12.1 Privacy Policy. Turikumwe's processing of personal data is described in detail in the Turikumwe Privacy Policy, which is incorporated by reference into these Terms.

12.2 Rwandan DPPL. With respect to personal data of individuals in Rwanda, Turikumwe acts as a data controller within the meaning of the DPPL (Law N° 058/2021). Astoria LTD is registered (or is in the process of registering) with the National Cyber Security Authority (NCSA) as a data controller in accordance with the DPPL. You acknowledge that:

(a) Turikumwe processes personal data on lawful bases recognized by the DPPL, including your consent, performance of a contract with you, compliance with legal obligations, and legitimate interests (including fraud prevention);

(b) personal data may be processed in Rwanda and, where lawfully permitted (including under an authorization issued by the NCSA), transferred outside Rwanda, including to the United States, to Turikumwe's service providers;

(c) personal data breaches that meet the DPPL threshold will be notified to the NCSA within forty-eight (48) hours of Turikumwe becoming aware; and

(d) you have rights of access, rectification, erasure, restriction, objection, portability, and (where applicable) to designate an heir to your personal data, exercisable by contacting vbutera@turikumwerw.com.

12.3 Cross-Border Transfers. You consent to the transfer of your personal data outside Rwanda, including to the United States and other countries that may not provide the same level of data protection as Rwanda, subject to appropriate safeguards under the DPPL and to an authorization issued by the NCSA.

12.4 Cookies. The Platform uses cookies and similar technologies as described in the Turikumwe Cookie Policy.

12.5 Data Protection Officer. Turikumwe has appointed a Data Protection Officer ("DPO") and registered the appointment with the NCSA. The DPO may be contacted at vbutera@turikumwerw.com.

12.6 Sensitive Personal Data. Certain Campaigns may involve sensitive personal data within the meaning of the DPPL (e.g., health, religious belief, political opinion). By submitting such data, you provide explicit consent to its processing for the purposes of operating the Campaign and the Platform.

13. REFUNDS AND CHARGEBACKS

13.1 General Rule. Donations are intended as gifts and are generally final. However, Turikumwe may issue refunds in accordance with this Section 13 and the Turikumwe Donor Terms of Service.

13.2 When Refunds May Be Issued. Turikumwe may refund a Donation, in whole or in part, where:

(a) the Donation was made in error and is reported promptly; (b) the Campaign was fraudulent, misrepresented, or otherwise violated these Terms; (c) Funds have not been used for the stated purpose, or are unlikely to be; (d) the Campaign is closed and unused Funds remain; (e) Turikumwe is required to do so by Applicable Law, by a Mobile Money Provider, or by a competent authority; or (f) Turikumwe, in its sole discretion, determines a refund is appropriate.

13.3 Mobile Money Irreversibility. You acknowledge that mobile money transfers are typically irreversible once accepted at the recipient wallet, and that this is a feature of the MTN MoMo and Airtel Money networks operated by licensed e-money issuers under BNR regulations. Where Funds have already been withdrawn by you and a refund becomes due, you authorize Turikumwe to (a) demand repayment from you; (b) set off the refund against any future Withdrawals; and (c) commence collection or legal proceedings to recover the amount. You agree to cooperate in returning Funds to Donors where directed by Turikumwe.

13.4 Chargebacks. If a Donor disputes a Donation through a payment card or other instrument and a chargeback is issued, Turikumwe may immediately debit your Platform balance, suspend Withdrawals, or invoice you for the chargeback amount plus reasonable administrative fees. You authorize Turikumwe to take these actions without further consent.

13.5 Dispute Handling. Turikumwe's Trust & Safety team will investigate refund and abuse reports in good faith. Turikumwe's decision under this Section 13 is final, subject to dispute resolution under Section 17.

13.6 No Insurance. Nothing in this Section 13 constitutes insurance or a guarantee against fraud or misuse.

14. DISCLAIMERS AND LIMITATION OF LIABILITY

14.1 Turikumwe Is a Platform. Turikumwe is a technology platform that enables Campaign Creators to receive Donations from Donors. Turikumwe is not: (a) a charity or fiduciary; (b) a guarantor of any Campaign, Beneficiary, or use of Funds; (c) a payment service provider that holds customer funds on its own account beyond what is permitted by Applicable Law and any applicable BNR license, where applicable; (d) a financial, tax, legal, or other professional advisor; (e) an employer or principal of any Campaign Creator; or (f) a party to the relationship between a Campaign Creator and a Beneficiary or Donor.

14.2 Pass-Through of Funds. Where Turikumwe (directly or via a licensed payment partner or trust account) handles Funds, it does so as a technical intermediary. To the extent required by Law N° 061/2021 of 14/10/2021 governing the Payment System and BNR Regulation N° 74/2023 of 18/09/2023 Governing Payment Service Providers (and the BNR Regulation Governing the Electronic Money Issuers), Funds are held in segregated trust or settlement accounts at licensed Rwandan commercial banks. Funds do not constitute deposits with Turikumwe and are not subject to deposit insurance protection except as expressly provided by Applicable Law.

14.3 AS-IS. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE PLATFORM IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT. TURIKUMWE DOES NOT WARRANT THAT THE PLATFORM WILL BE UNINTERRUPTED, SECURE, OR ERROR-FREE.

14.4 No Verification of Campaigns. Turikumwe applies reasonable trust-and-safety measures but does not, and cannot, verify the truthfulness of every statement made by every Campaign Creator. Donors donate at their own risk. Turikumwe is not liable for losses arising from a Campaign Creator's breach of these Terms.

14.5 Limitation of Liability. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

(a) IN NO EVENT WILL TURIKUMWE OR ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING LOST PROFITS, LOST DONATIONS, LOST DATA, OR LOSS OF GOODWILL, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

(b) TURIKUMWE'S TOTAL AGGREGATE LIABILITY TO YOU UNDER OR IN CONNECTION WITH THESE TERMS (WHETHER IN CONTRACT, TORT, OR OTHERWISE) WILL NOT EXCEED THE GREATER OF (i) THE TOTAL PLATFORM FEES PAID BY YOU TO TURIKUMWE IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM AND (ii) RWF 500,000 (FIVE HUNDRED THOUSAND RWANDAN FRANCS) OR ITS EQUIVALENT.

14.6 Non-Excludable Liability. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under Applicable Law, including liability for fraud, willful misconduct, or gross negligence, or any non-waivable rights under Rwandan consumer-protection law.

15. INDEMNIFICATION

15.1 General Indemnity. You agree to indemnify, defend, and hold harmless Turikumwe and its affiliates and their respective officers, directors, employees, contractors, and agents (the "Indemnified Parties") from and against any and all claims, demands, suits, proceedings, losses, damages, liabilities, fines, penalties, judgments, settlements, refunds, chargebacks, taxes, and expenses (including reasonable attorneys' fees and forensic costs) arising out of or relating to:

(a) your Campaign, Content, or use of the Platform; (b) your breach of these Terms or the Platform Policies; (c) your violation of Applicable Law; (d) your infringement of any third-party right, including IP, privacy, or publicity rights; (e) any dispute between you and a Donor, Beneficiary, or third party; and (f) the matters described in Section 9.6 (Fraud Indemnity).

15.2 Procedure. Turikumwe will provide reasonable notice of any claim subject to indemnification and may, in its discretion, control the defense and settlement of any such claim. You will not settle any claim that imposes liability on Turikumwe without Turikumwe's prior written consent.

16. ACCOUNT SUSPENSION AND TERMINATION

16.1 Termination by You. You may close your Account at any time by following the Platform's account-closure instructions. Closure does not relieve you of obligations accrued prior to closure, nor of any obligations that survive termination.

16.2 Termination by Turikumwe. Turikumwe may, in its sole discretion and with or without prior notice, suspend, restrict, or terminate your Account or any Campaign, and remove or modify any Content, if:

(a) you breach these Terms or the Platform Policies; (b) Turikumwe reasonably believes fraud, misrepresentation, or other prohibited conduct has occurred (see Section 9); (c) required by Applicable Law, court order, or regulator; (d) the Campaign or Account presents undue risk to Turikumwe, Donors, the Beneficiary, or the Platform; or (e) Turikumwe ceases to offer the Platform in your jurisdiction.

16.3 Handling of Funds on Termination. On suspension or termination, Turikumwe may:

(a) freeze Funds pending verification, investigation, or refund; (b) refund Donors; (c) release Net Funds to the Beneficiary or to an alternative recipient consistent with the Campaign's stated purpose; (d) escheat unclaimed funds to the relevant authority under Applicable Law; or (e) take any other action permitted by Section 9.5.

16.4 Survival. The following sections survive termination: 1 (Definitions), 5.7 (Tax Withholding), 6.6–6.7 (Mobile Money Irreversibility and Set-Off), 7 (Use of Funds), 9 (Fraud / Law Enforcement), 10.2–10.5 (Content License surviving), 11 (IP), 12 (Privacy), 13 (Refunds), 14 (Disclaimers / Limitation of Liability), 15 (Indemnification), 17 (Dispute Resolution), 20–22 (Notices, Misc., Contact), and any other provision that by its nature should survive.

17. DISPUTE RESOLUTION; GOVERNING LAW

Read this section carefully. It affects how disputes are resolved and contains an arbitration agreement.

17.1 Governing Law

These Terms and any non-contractual obligations arising out of them are governed by the laws of the Republic of Rwanda, without regard to its conflict-of-law principles.

17.2 Informal Resolution

Before commencing arbitration, you and Turikumwe will attempt in good faith to resolve any dispute informally for at least thirty (30) days after written notice of the dispute is sent to legal@turikumwerw.com.

17.3 Arbitration at KIAC

Any dispute, controversy, or claim arising out of or relating to these Terms, including its existence, validity, breach, or termination, that is not resolved informally shall be referred to and finally resolved by arbitration administered by the Kigali International Arbitration Centre (KIAC), established by Law N° 51/2010 of 10/01/2010, in accordance with the KIAC Arbitration Rules in force at the date of commencement. The seat and legal place of arbitration shall be Kigali, Rwanda. The language shall be English. The tribunal shall consist of one (1) arbitrator, unless either party requests three (3) arbitrators and the value in dispute exceeds RWF 50,000,000. The arbitration shall be governed by Rwanda's Law N° 005/2008 of 14/02/2008 on arbitration and conciliation in commercial matters (as amended). The award shall be final and binding and enforceable in any competent court.

17.4 Courts of Kigali

Notwithstanding the foregoing, either party may seek interim or injunctive relief from the Commercial Court of Nyarugenge in Kigali, or any other competent Rwandan court, in support of arbitration or to enforce an award.

17.5 Exception for Fraud and Injunctive Relief

Notwithstanding Sections 17.1 to 17.4, Turikumwe may bring an action in any competent court anywhere in the world to (a) seek injunctive or equitable relief to protect its IP, confidential information, or Platform security; (b) recover Funds or damages arising from fraud, money laundering, sanctions violations, or other criminal conduct; or (c) enforce these Terms generally. You consent to the personal jurisdiction of the courts of Rwanda for these purposes.

17.6 Limitation Period

Any claim arising out of these Terms must be brought within one (1) year after the cause of action arose, or such longer period as may be required by Applicable Law, failing which the claim is permanently barred.

18. FORCE MAJEURE

Neither party will be liable for any delay or failure to perform (other than payment obligations) caused by events beyond its reasonable control, including: acts of God; natural disasters; fire; flood; epidemic or pandemic; war, terrorism, civil unrest; government action, sanctions, embargo, or regulatory change; failure or interruption of telecommunications, internet, electricity, or banking systems (including Mobile Money Providers, the BNR's Rwanda Integrated Payments Processing System, or other clearing/settlement infrastructure); cyberattacks; or labour disputes. The affected party will notify the other promptly and resume performance as soon as reasonably possible.

19. MODIFICATIONS TO THESE TERMS

19.1 Right to Modify. Turikumwe may modify these Terms from time to time, including to reflect changes in law, Platform features, or business practices.

19.2 Notice. Turikumwe will provide at least thirty (30) days' notice of material changes by (a) posting the revised Terms on the Platform with an updated "Effective Date"; (b) sending notice to the e-mail address on file; and/or (c) displaying an in-app notification.

19.3 Continued Use = Acceptance. Your continued use of the Platform after the effective date of the revised Terms constitutes acceptance. If you do not agree, you must stop using the Platform and may close your Account; any Funds remaining will be handled under Section 6.

19.4 Immediate Changes. Changes required by Applicable Law or for security/fraud-prevention reasons may take effect immediately.

20. NOTICES

20.1 Notices to You. Turikumwe may send notices to the e-mail address, SMS number, or in-app inbox associated with your Account. Such notices are deemed received on transmission.

20.2 Notices to Turikumwe. Legal notices must be sent in writing to: Astoria LTD, Attn: Legal, Runyonza Village, Nyagahinga Cell, Rusororo Sector, Gasabo District, Kigali City, Rwanda, with a copy to legal@turikumwerw.com.

20.3 Service of Process. Service of process is accepted at the addresses in Section 20.2.

20.4 Law-Enforcement Process. Lawful legal process from competent authorities should be directed to lawenforcement@turikumwerw.com and, where required by Applicable Law, served at the registered office in Section 20.2.

21. SEVERABILITY; ENTIRE AGREEMENT; ASSIGNMENT; MISCELLANEOUS

21.1 Severability. If any provision of these Terms is held invalid or unenforceable, that provision will be modified to the minimum extent necessary to make it enforceable, and the remaining provisions will remain in full force.

21.2 Entire Agreement. These Terms (together with the Platform Policies incorporated by reference) constitute the entire agreement between you and Turikumwe regarding the subject matter and supersede all prior agreements, understandings, and communications.

21.3 Assignment. You may not assign or transfer these Terms or any rights or obligations hereunder without Turikumwe's prior written consent. Turikumwe may assign these Terms, in whole or in part, to any affiliate, successor, or in connection with a merger, acquisition, restructuring, or sale of assets, without your consent.

21.4 No Waiver. No failure or delay by Turikumwe in exercising any right is a waiver. A waiver in any one instance does not waive any future right.

21.5 No Agency or Partnership. Nothing in these Terms creates any agency, partnership, joint venture, employment, or fiduciary relationship between you and Turikumwe.

21.6 No Third-Party Beneficiaries. Except as expressly stated (for example, with respect to the Indemnified Parties under Section 15), these Terms are not intended to confer rights on any third party.

21.7 Headings. Headings are for convenience only and do not affect interpretation.

21.8 Language. These Terms are drafted in English. If translated into Kinyarwanda, French, or another language for convenience, the English version controls in case of conflict, except where Rwandan law mandates otherwise. Where Rwandan consumer-protection law requires provision of contracts in Kinyarwanda, Turikumwe will make a Kinyarwanda version available on request.

21.9 Electronic Communications and Signatures. You consent to receive communications and to transact electronically. Electronic signatures, click-through acceptance, and electronic records are deemed valid and enforceable under Rwanda's Law N° 24/2016 of 18/06/2016 governing Information and Communication Technologies (the "Rwandan ICT Law") and related electronic-transactions provisions.

21.10 Export Controls. You will comply with all applicable export, re-export, and sanctions laws of Rwanda and any other competent jurisdiction.

21.11 Compliance With Consumer Protection Law. Nothing in these Terms is intended to derogate from any non-waivable rights you may have under Rwanda's Law N° 36/2012 of 21/09/2012 on competition and consumer protection (the "Rwandan Consumer Protection Law").

21.12 Anti-Corruption. You will comply with all applicable anti-corruption laws, including Rwandan anti-corruption legislation (administered in part by the Office of the Ombudsman) and any other applicable anti-corruption law.

22. CONTACT INFORMATION

For questions, support, or notices under these Terms, contact:

• General Support: support@turikumwerw.com
• Trust & Safety / Fraud Reports: trust@turikumwerw.com
• Privacy / Data Protection Officer: vbutera@turikumwerw.com
• Legal & Regulatory: legal@turikumwerw.com
• Law-Enforcement Requests: lawenforcement@turikumwerw.com
• Telephone: +1 918 413 9217
• Postal: Astoria LTD, Runyonza Village, Nyagahinga Cell, Rusororo Sector, Gasabo District, Kigali City, Rwanda

BY CREATING A CAMPAIGN OR OTHERWISE USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ THESE TERMS, UNDERSTAND THEM, AND AGREE TO BE BOUND BY THEM.

Turikumwe — We Are Together.