TERMS OF SERVICE

Article 1 — Publisher, Intellectual Property and Structure

1.1 The Publisher

The MOBILE MONEY® application is published by AC Shining Stars Management Ltd (hereinafter "ACS"), a company incorporated under the laws of Ireland, registered under number 703071, with registered offices at 77 Camden Street Lower, Dublin 2, Ireland D02 XE80. ACS is the exclusive owner of all intellectual property assets underlying the application, including:

-     the international trademark MOBILE MONEY® (WIPO ref. ROM.1318304, INPI France No. 4263283, OAPI No. 92205), protected in 37 countries across Classes 9, 36 and 38;

-     the application technology, source code, software architecture, USSD automation algorithms and all technical know-how;

-     the Google Play Developer account registered in ACS's name as a registered organisation.

ACS is the publisher of the application, the GDPR data controller, and the sole contractual counterpart of the end user.

1.2 Local Operational Partner — MOBILE MONEY SARL

ACS works with MOBILE MONEY SARL (RCCM: TPPRR/RC/L'BE/2025/B/026, NIU: M032517654657Q, Half Mile, Oppose UBA, Limbe, Cameroon) as a local operational partner providing on-the-ground support, local representation and operational facilitation in Cameroon, under a services agreement with ACS. MOBILE MONEY SARL is not the publisher of the application, is not party to these Terms, and has no direct contractual relationship with the end user. All application claims must be addressed to ACS.

Asset protection: ACS retains in all circumstances full ownership and free disposal of the MOBILE MONEY® trademark and application technology, regardless of any event affecting MOBILE MONEY SARL or any other partner. These assets cannot be seized by creditors or jurisdictions linked to third-party partners.

1.3 Regulatory framework — Irish entity, no permanent establishment

ACS is an Irish company subject to Irish and European law. As application publisher, ACS has no permanent establishment in African deployment countries and is not subject to local PSP licensing requirements. This model follows established industry practice by Revolut (Dublin), N26 (Berlin) and Wise (London).

1.4 Application features

The MOBILE MONEY® application offers: SIM card detection and display of associated mobile payment services; virtual card services; and secure USSD transaction assistance (see Article 1.5).

1.5 USSD Transaction Assistance

The application includes a secure mobile payment transaction assistance feature via deterministic USSD automation:

-     the user enters transaction details (recipient number, amount, reason) in a secure form;

-     the user explicitly confirms the information before any action;

-     the application executes a static, pre-defined USSD navigation script for the relevant operator, running in the background;

-     the user manually enters their PIN at the final step — the application does not access, store or input the PIN;

-     the transaction is executed by the operator under its own regulated infrastructure.

This constitutes deterministic rule-based automation under Google Play policy (October 2025). No autonomous decisions are made. The user remains at all times the initiator and decision-maker.

Security purpose: this feature protects users against manual USSD input errors and USSD fraud attacks where third parties manipulate users into entering sequences that transfer their funds to fraudulent accounts.

1.6 What the application does not do

The application does not hold, transfer or retain funds. Transactions are executed by operators under their own regulatory licences. ACS does not intervene in the movement of funds. The application does not access, store or input the user's PIN.

Article 2 — Access, Eligibility and User Account

Access is reserved for natural persons aged at least 18 years (or legal majority age in their country), with a compatible Android (v8.0+) or iOS (v13.0+) device, active internet connection, and acceptance of these Terms. Account deletion is available at any time from the application and/or at www.acshiningstars.com/account-deletion. All associated data is deleted within 30 days.

Article 3 — Intellectual Property and Third-Party Trademarks

3.1 ACS intellectual property

All intellectual property rights relating to the MOBILE MONEY® application are the exclusive property of ACS (Reg. No. 703071), protected under the Irish Copyright and Related Rights Act 2000, EU (Protection of Trade Secrets) Regulations 2018, the OAPI Revised Bangui Agreement, and the WIPO Madrid Protocol. Any unauthorised reproduction or exploitation is strictly prohibited. IP claims: [email protected].

3.2 Licence to the user

ACS grants the user a personal, non-exclusive, non-transferable and revocable licence to use the application solely for the purposes set out in these Terms, without conferring ownership.

3.3 SIM detection and operator references

The application displays the trade names of operators accessible from detected SIM cards (MTN, Orange, Moov, Free, Airtel, Camtel, etc.) for purely informational purposes. Graphical icons are original ACS creations and do not reproduce official operator logos. No partnership is claimed unless publicly announced.

3.4 Third-party trademarks — General disclaimer

All brand names, logos, trade names and distinctive signs mentioned in this application or in these Terms — including MTN, Orange, Moov, Free, Airtel, Camtel, Visa, Mastercard, and any other operator or service provider name — are the exclusive property of their respective owners. Their mention in the application or in these Terms is made for purely informational and referential purposes and does not constitute a claim of ownership, a partnership, or an endorsement by them. ACS is not affiliated with these brands and is not authorised to use them beyond what is permitted by applicable nominative reference law.

3.5 No partnership with MTN Group — Ongoing legal proceedings

Display of MTN services does not constitute a partnership between ACS and MTN Group Limited or any MTN subsidiary. Legal proceedings are ongoing between ACS and MTN Group before the Court of First Instance of Douala Bonanjo, Cameroon (ref. No. 3690 / ST 3154), relating to MTN Group's infringement of the MOBILE MONEY® trademark since 2016 across 14 countries.

Article 4 — Device Permissions and Accessibility Service

4.1 Required permissions

Permission  —  Purpose  —  Status

READ_PHONE_STATE  SIM card and network operator detection — core function  [Yes]

CALL_PHONE  USSD session initiation on explicit user action only  [Yes (USSD assist)]

Accessibility Service  Deterministic USSD menu navigation after explicit user confirmation  [Yes (USSD assist)]

INTERNET  Service connection and updates  [Yes]

CAMERA (optional)  QR code scanning — explicit consent required  [Optional]

BIOMETRIC (optional)  Secure authentication — explicit consent required  [Optional]

4.2 Accessibility Service Disclosure

IMPORTANT NOTICE — ACCESSIBILITY SERVICE: The MOBILE MONEY® application uses the Android Accessibility Service to automate USSD menu navigation when you perform mobile payment transactions. What the app does: automatically navigates USSD menus using only the information you have entered and confirmed. What the app does not do: initiate any transaction without your explicit confirmation, read your other applications, store your PIN, or access data unrelated to your transactions. Why: to protect your money against input errors and USSD fraud attacks.

Each permission is requested when the user accesses the relevant feature, not at launch. Permissions can be withdrawn at any time from device settings.

Article 5 — Personal Data and Privacy (GDPR)

5.1 Data Controller

ACS (AC Shining Stars Management Ltd, Reg. No. 703071, 77 Camden Street Lower, Dublin 2, Ireland D02 XE80) is the GDPR data controller. Lead supervisory authority: DPC Ireland — www.dataprotection.ie. Contact: [email protected].

5.2 Data collected

Category  —  Purpose  —  Legal basis (GDPR)

Identity (name, email)

  > Account management  (Art. 6(1)(b) — contract performance)

SIM data (operator, network)

  > SIM service display  (Art. 6(1)(b) — contract performance)

Transaction data (recipient, amount, reason)

  > USSD form pre-fill only — not retained after confirmation  (Art. 6(1)(b) — contract performance)

PIN code

  > NOT collected — NOT stored — NOT accessible to the application  (—)

Location (country)

  > Country-specific services  (Art. 6(1)(f) — legitimate interest)

Technical data (device, OS, logs)

  > Security and service improvement  (Art. 6(1)(f) — legitimate interest)

Virtual card data

  > Virtual card service  (Art. 6(1)(b) — contract performance)

5.3 User rights (GDPR Art. 15-22)

The following rights are exercisable at [email protected] (30-day response):

-     Right of access (Art. 15): obtain a copy of personal data;

-     Right to rectification (Art. 16): correct inaccurate data;

-     Right to erasure (Art. 17): obtain deletion of data;

-     Right to restriction of processing (Art. 18);

-     Right to data portability (Art. 20): receive data in a readable format;

-     Right to object (Art. 21): object to processing based on legitimate interest;

-     Right to lodge a complaint with the DPC: www.dataprotection.ie.

5.4 International transfers

EU user data is processed within the EEA. Transfers outside the EEA are governed by standard contractual clauses (EC Decision 2021/914, Art. 46 GDPR). African user data is processed in compliance with applicable national data protection legislation.

5.5 Data retention

Account data: duration of contractual relationship + 30 days post-deletion. Transaction data: deleted after confirmation unless explicit consent for history. Technical data: 12 months maximum. PIN: never collected or stored.

5.6 Security

Encryption in transit TLS 1.3, at rest AES-256. PIN is never accessible to ACS or its systems.

Article 6 — Regulatory Compliance

6.1 Irish publisher — no permanent establishment

ACS is an Irish company without permanent establishment in African deployment countries, not subject to local PSP licensing requirements as application publisher. This follows established practice by Revolut, N26 and Wise operating in Africa under European entities.

6.2 Regulatory status by country

Country  —  Local PSP regulator  —  ACS status (Irish publisher)

Cameroon  COBAC — Regulation n°04/18

Irish entity, no permanent establishment. Not subject to COBAC Regulation. MOBILE MONEY SARL = local support partner only.

Cote d'Ivoire / Benin / Guinea-Bissau  BCEAO — Instruction n°001-01-2024

Not subject to BCEAO Instruction.

Congo / Guinea  COBAC / BCRG

Not subject to local PSP regulations.

Ghana  Bank of Ghana — Act 987/2019

Foreign publisher — no local PSP licence required.

Rwanda / Kenya  BNR / CBK

Not subject to local PSP licensing.

Botswana / Zambia / Namibia / Liberia  National regulators

Not subject to local PSP licensing.

France  ACPR / PSD2

Irish EEA entity. Deterministic USSD assistance not subject to PSP licensing under PSD2.

Ireland / EU (home)  DPC / GDPR / PSD2

Irish company, GDPR compliant. DPC lead supervisory authority.

Google Play Financial Features Declaration: Publisher — AC Shining Stars Management Ltd (ACS), registered Irish company, Reg. No. 703071. Service: SIM-linked service visualisation + deterministic USSD transaction assistance. The application does not hold funds, does not process payments, and does not store PIN codes. Status: not a payment service provider — users retain full transaction control including PIN confirmation.

Article 7 — User Conduct and Prohibited Uses

Strictly prohibited: fraudulent use, money laundering, terrorist financing or illegal activities; unauthorised access to ACS, MOBILE MONEY SARL or operator systems; decompilation, reverse engineering or source code reproduction; use of the MOBILE MONEY® trademark without ACS's written authorisation; attempts to circumvent transaction confirmation or intercept USSD data; any act damaging ACS's or third parties' rights.

Article 8 — Liability

8.1 ACS liability

ACS commits to providing a quality service but is not liable for interruptions due to force majeure, telecommunications network failures, or necessary maintenance.

8.2 Operator liability

Each mobile network operator (MTN, Orange, Moov, Free, Airtel, Camtel, etc.) is solely responsible for its payment services under its own regulatory licences. USSD transaction assistance does not transfer operator responsibility to ACS.

8.3 MOBILE MONEY SARL

MOBILE MONEY SARL is a local operational partner. ACS is not liable for its acts or omissions in carrying out local support missions.

Article 9 — Modifications to Terms

ACS may modify these Terms at any time. Material modifications notified with at least 30 days' notice by in-app notification and/or email. Current version always accessible at www.acshiningstars.com/terms. Continued use after notice period constitutes acceptance.

Article 10 — Advertising and In-App Purchases

No third-party advertising in the application. Premium subscriptions presented explicitly (price, duration, renewal, cancellation) before subscription. All in-app purchases final unless required by law. Subscriptions manageable from Google Play settings.

Article 11 — Governing Law and Dispute Resolution

These Terms are governed by Irish law. For EU consumer users, mandatory consumer protection provisions of their country of residence remain applicable (Rome I Regulation). Claims first to ACS ([email protected] — 30-day response). Absent amicable resolution: exclusive jurisdiction of Irish courts. CEMAC/UEMOA users may submit local feature disputes to competent national courts under OHADA law.

AC Shining Stars Management Ltd (ACS)

Publisher — MOBILE MONEY® app

77 Camden Street Lower, Dublin 2, Ireland D02 XE80  —  Reg. No. 703071

[email protected]  |  [email protected]  |  www.acshiningstars.com

MOBILE MONEY®  —  WIPO ROM.1318304  —  INPI FR 4263283  —  OAPI 92205  —  37 countries  —  Classes 9, 36, 38

Local operational partner:

MOBILE MONEY SARL  —  RCCM : TPPRR/RC/L'BE/2025/B/026  —  NIU : M032517654657Q  —  Half Mile, Oppose UBA, Limbe, Cameroun