Terms of Service

Draft under review. This text is a draft and is still being reviewed. It may change before RadiusOne starts taking real payments.

General

1. About these terms

These terms are a contract between you and Imara Systems Limited (“RadiusOne”, “we”, “us”). They apply when you use RadiusOne to run an internet service.

“You” means the internet service provider (ISP) that opens a RadiusOne account. The person who accepts these terms confirms that they are at least 18 years old and are allowed to bind the ISP.

Part A is for ISPs. Part B is for people who buy Wi-Fi access on a hotspot that uses RadiusOne. Schedule 1 contains terms that our payment provider, pawaPay, requires every ISP to accept.

You accept these terms when you register, when you sign an order with us, or when you first use the service, whichever comes first.

2. Words we use

• Platform: the RadiusOne software, servers and dashboard at app.radiusone.africa.
• Dashboard: the web pages where you and your staff manage your account.
• Customer: a person or business that buys internet access from you, for example a PPPoE subscriber or a hotspot user.
• End user: a person who pays with mobile money through the platform, for a voucher or an invoice.
• Voucher: a code that gives access to your hotspot for the time, data and speed of a package.
• Agent: a person you add to your account to sell vouchers for you.
• Wallet: the record in your dashboard of money we hold for you and money you owe us.
• pawaPay: pawaPay and its local payment partners, who collect and send mobile money for us.

Part A: Terms for ISPs

3. What RadiusOne does

RadiusOne lets you:

• connect your MikroTik routers to our RADIUS server through a secure tunnel;
• sell hotspot vouchers that are printed, sold by your agents, or bought by customers with mobile money on a captive portal;
• manage PPPoE customers, send them invoices by email, take payment, and cut off accounts that are not paid;
• receive mobile money into your wallet and withdraw it to a mobile money number.

RadiusOne is in a pilot. Features may change, be added or be removed while we learn from the first ISPs. We will tell you before we remove a feature you use, unless we must act quickly for security, legal or payment-provider reasons.

4. Your account

4.1 Opening an account

We may create your account for you, or you may register yourself on the dashboard if registration is open. You must give true, complete and current information and keep it up to date.

An account that registers itself starts with lower limits until our staff review it. Until then:

• your wallet cannot go below zero;
• you can connect only a small number of routers;
• the platform does not send emails or SMS for your account, apart from password emails to your administrator. Invoices and reminders that fall in this period are not sent, and are not sent later.

We may refuse or close a registration without giving a reason.

4.2 Staff and agents

You can add staff and agents and give each one a role. You are responsible for everything done through your account, including by your staff and agents. Make sure each person has their own login, keeps their password secret, and has only the role they need.

Your agents act for you, not for us. You set their commission. We do not charge agents anything; fees on agent sales are charged to you.

4.3 Security

Some actions that move money ask for your password again. Tell us at once at [email protected] if you think someone else has used your account.

5. Checking who you are (KYB)

pawaPay requires us to check every ISP that receives money through it. Within 7 days after you open your account, send us:

• your certificate of incorporation or business registration;
• your articles of association or equivalent documents, if you are a company;
• an identity document for each director and each person who ultimately owns or controls the business;
• a copy of your licence or authorisation from the Uganda Communications Commission, or from the regulator in your country;
• any other document we or pawaPay reasonably ask for, within 3 business days of the request.

We share these documents with pawaPay so that it can do its own checks. Until the checks are complete, or if they fail, we may decline to verify your withdrawal number, hold withdrawals, or stop mobile money payments for your account.

Tell us in writing, within 7 days, about any change to the information you gave us, any change of control of your business, and any change to your licences.

6. Your licences and lawful service

You are responsible for:

• holding every licence, authorisation and registration you need to provide internet service, including from the Uganda Communications Commission;
• following the laws that apply to your business, including consumer protection, tax, data protection and any rules about recording or keeping information about your customers’ use of the internet;
• providing the internet service your customers pay for, once they have paid;
• setting your own packages and prices, and showing them truthfully.

You may use RadiusOne only to sell internet access and related services that are lawful where you operate. You must not use it for any activity on pawaPay’s list of prohibited business activities, or on any mobile network operator’s prohibited list.

7. Your routers and network

To connect a router you run a command we give you. The command changes the router’s configuration: it adds a tunnel to our servers, RADIUS settings and hotspot pages. If you choose automatic setup, the router may be reset first.

• Back up your router configuration before you run any command from us.
• You are responsible for your routers, their security, their firewall and their passwords. Routers set up in automatic mode do not currently get a firewall from us.
• You are responsible for your network, your internet connection, and the equipment at your customers’ premises.
• Do not change or remove the RadiusOne settings on a connected router unless our guides say so. If you do, logins and payments for that router may stop working.

8. Mobile money payments

8.1 How the money flows

We collect mobile money through our merchant account with pawaPay:

1. A customer pays for a voucher on your captive portal, or pays one of your invoices, using MTN, Airtel or another supported operator.
2. pawaPay collects the money into our merchant account.
3. We credit the full price to your wallet and deduct our fee for that payment (section 10).
4. You withdraw your wallet balance when you want (section 12).

We collect this money on your behalf. The customer’s contract for internet service is with you, not with us.

8.2 Rules that come from pawaPay and the mobile networks

Because the money goes through pawaPay, you agree to the terms in Schedule 1. In short, you must:

• not add any surcharge or extra fee for paying by mobile money. Your customers pay the price of the package or invoice, nothing more;
• not give customers who pay by mobile money worse terms than customers who pay in other ways, including on refunds and reversals;
• follow the payment processes and branding rules of the mobile network operators;
• sell only lawful products that are not on a mobile network operator’s prohibited list;
• keep records of each sale (date and time, amount and currency, what was sold, and where) for at least 6 years, or longer if the law requires;
• give us those records within 1 business day if pawaPay or a mobile network operator asks for them;
• answer any fraud enquiry within 1 business day;
• run reasonable controls against money laundering, terrorist financing, fraud and bribery, and give us or pawaPay information we need to meet our own legal duties;
• cooperate with any identification of customers that the law, pawaPay or a mobile network operator requires.

pawaPay can stop providing its service to you if you break these rules or do not pass its checks. If that happens, mobile money payments for your account will stop. We are not responsible for losses caused by a decision of pawaPay, a regulator or a mobile network operator.

8.3 Payments that fail or are disputed

The platform asks pawaPay for the result of every payment and credits your wallet only when pawaPay confirms it. If a payment is later reversed, or found to be fraudulent or made in error, we may take the amount back from your wallet.

9. Your wallet

• Your wallet shows, in your account’s currency, the money we hold for you and the money you owe us. Each entry is listed in the dashboard.
• It is not a bank account. It does not earn interest. Each account has one currency, which cannot be changed once money has moved.
• Money comes in from mobile money sales, paid invoices and your own top-ups. Money goes out for fees, withdrawals, SMS, and corrections.
• If we find an error, such as a fee charged by mistake or a payment credited twice, we may correct it. Every correction appears in your wallet history.
• We may use money in your wallet to pay amounts you owe us under these terms.

10. Fees

Our fees are set for each ISP. You pay the fees agreed with you in writing or shown in your dashboard. We do not publish a standard price list.

Fees may apply to:

• each voucher sold through the captive portal with mobile money;
• each printed voucher, charged when it is first used;
• each voucher sold by your agents;
• each PPPoE account that paid for service in a month, charged after that month ends;
• invoices paid with mobile money, and invoices your staff mark as paid in cash, bank transfer or another way;
• each withdrawal from your wallet;
• each SMS sent for you (section 13).

If no fee has been agreed for one of these, we do not charge it.

How fees are taken:

• Fees are taken from your wallet when the event happens.
• If your wallet cannot cover a fee, the fee waits. It is taken from the next money that comes into your wallet, and before any withdrawal.
• If you undo a cash payment you recorded, the fee already charged is not returned automatically. Ask us if you think a fee is wrong.
• Fees do not include tax. If tax applies to our fees, we will add it.

We may change your fees with at least 30 days’ notice by email or in the dashboard. New fees apply to events after the change.

11. Negative balance and limit

Your wallet may go below zero, for example when fees for printed vouchers are larger than the money in your wallet. It can go down only to the limit shown in your dashboard.

• If what you owe goes past your limit, you cannot create new voucher batches until you pay.
• Mobile money sales on your captive portal keep working, and the money they bring in reduces what you owe.
• You pay what you owe by topping up your wallet with mobile money from the dashboard.
• We may raise or lower your limit. A lower limit applies to new events only.
• What you owe is a debt. If you do not pay it, we may suspend your account (section 17) and recover it by other lawful means.

12. Withdrawals

• You can withdraw your wallet balance at any time to a mobile money number you have added in the dashboard.
• Our staff must verify each number, its operator and the name of its owner before you can use it. If you change any of these, the number must be verified again.
• A withdrawal charge applies. It covers what pawaPay charges us plus a small margin, as agreed with you in writing or shown in your dashboard. The charge is added on top of the amount you withdraw, is taken only if the withdrawal succeeds, and appears in your wallet history.
• You cannot withdraw more than your balance, and the platform keeps enough in your wallet for fees that are still waiting.
• pawaPay and the mobile networks set minimum and maximum amounts for one transfer. A withdrawal outside those limits fails.
• If a withdrawal fails, the money and the charge go back to your wallet.
• We may delay or refuse a withdrawal if we suspect fraud or a mistake, if your KYB checks are not complete, if the law or pawaPay requires it, or if your account is suspended.

13. Email and SMS

• When you invoice PPPoE customers, the platform emails them the invoice, a reminder on the due day, and a notice when they are cut off. Emails go out from our email service with your ISP’s name, and replies go to the reply address you set.
• SMS is optional. It is off until you turn it on, where available. SMS sent for you are charged at our provider’s cost plus a margin, as agreed with you in writing or shown in your dashboard.
• You are responsible for having your customers’ contact details lawfully, and for what you ask us to send them.

14. Your customers’ data

You decide why and how your customers’ personal data is used. You are the data controller for it. We process it on your behalf, as your data processor, to run the service. Our Privacy Policy explains what the platform stores.

When we process your customers’ data for you, we will:

• use it only to provide RadiusOne to you, to follow your instructions in the dashboard, and to meet our legal duties;
• keep it confidential, and allow access only to staff and contractors who need it and are bound to keep it confidential;
• keep it secure, using the measures described in our Privacy Policy;
• use only the service providers listed in our Privacy Policy, and tell you before we add a new one that would receive your customers’ data. If you object, you may end the service;
• tell you without undue delay if we learn that your customers’ data has been accessed without permission, and help you meet your duty to tell the Personal Data Protection Office;
• help you answer requests from your customers about their data;
• when the service ends, delete or return your customers’ data on request, except what the law or our payment provider requires us to keep. Copies in backups are removed as the backups expire.

You must:

• tell your customers how their data is used, for example by linking to our Privacy Policy and your own notice;
• have a lawful reason to collect and use their data, including their consent where it is needed;
• not enter personal data that you do not need.

Some data is ours as well as yours. For mobile money payments we keep payment records for our own duties to pawaPay and to the law, as explained in our Privacy Policy.

15. What you must not do

You must not:

• use RadiusOne for anything unlawful, fraudulent or harmful;
• send spam or misleading messages through the platform;
• try to get into another ISP’s data, or to test, scan or overload our systems, without our written permission;
• copy, resell, decompile or reverse engineer the platform, or build a competing product from it;
• share your account with another business.

16. Availability and support

During the pilot we do not guarantee that the platform will be available at any particular time or for any amount of time.

• We will try to keep the platform running and to do planned maintenance at quiet times.
• Some things are outside our control: pawaPay, the mobile networks, our hosting and email providers, the internet, power, and your own routers and links.
• We back up the database regularly, but a restore may lose the most recent minutes of data.
• Support is by email at [email protected] and by phone at +256 770 495 640.

17. Suspension and ending the service

17.1 Suspension

We may suspend your account if you break these terms, do not pay what you owe, do not complete KYB checks, or if the law, a regulator or pawaPay requires it. We will tell you why unless the law prevents us.

While your account is suspended:

• your staff cannot use the dashboard;
• your routers, customer logins, captive portal and invoicing keep working, so that your customers are not cut off because of a dispute with you;
• money from sales keeps coming into your wallet, but you cannot withdraw it yourself;
• if pawaPay or the law requires it, we may also stop mobile money payments for your account.

17.2 Ending the service

• You may end the service at any time by writing to [email protected].
• We may end the service by giving you 30 days’ notice.
• We may end it at once if you seriously break these terms, act unlawfully or fraudulently, become insolvent, lose a licence you need, or if pawaPay or a regulator requires it.

When the service ends:

• we pay your wallet balance, minus what you owe us, to your verified mobile money number, after any checks the law or pawaPay requires;
• you must pay anything you still owe;
• you must remove the RadiusOne settings from your routers. Logins through RadiusOne stop working;
• section 14 applies to your customers’ data.

18. Ownership

The platform, its software and its content belong to us and our licensors. We give you a right to use the platform while you are our customer. It cannot be transferred. You keep all rights in your own data. If you send us ideas or feedback, we may use them freely.

19. Confidentiality

Each of us will keep the other’s non-public business information confidential and use it only for this contract. This does not stop either of us sharing information with professional advisers, with pawaPay or a mobile network operator where Schedule 1 or their rules require it, or when the law or a court requires it.

20. Promises you make

You confirm that you, your directors and the people who own or control your business:

• have not been convicted of a crime, except minor offences;
• are not under investigation or in dispute with a tax authority, other than routine matters;
• are not subject to proceedings by a regulator, or to court orders about fraud or money laundering;
• have not paid or offered bribes, and will not do so.

Tell us at once if any of this changes.

21. Liability

• We provide the platform “as is” during the pilot. We do not promise that it is free of errors or suits every purpose.
• We are not responsible for loss of profit, loss of business, or other indirect loss.
• We are not responsible for problems caused by your routers, your network, your staff or agents, pawaPay, the mobile networks, or other events outside our reasonable control.
• Our total liability to you for all claims is limited to the fees you paid us in the 3 months before the event that caused the claim.
• These limits do not reduce our duty to pay you your wallet balance, and do not limit liability that the law does not allow us to limit, such as for fraud.
• You will cover our losses, costs and fines, including claims by pawaPay or a mobile network operator, that are caused by your breach of these terms, of Schedule 1, or of the law.

22. Changes to these terms

We may change these terms. We will give you at least 30 days’ notice of a change that harms you, by email or in the dashboard, unless the law or pawaPay requires a faster change. If you do not agree, you may end the service before the change takes effect. If you keep using RadiusOne after that, the new terms apply.

23. Law and disputes

These terms are governed by the laws of Uganda. If we disagree, we will first try to settle it by talking. If that fails within 30 days, either of us may take the dispute to the courts of Uganda.

Schedule 1 is governed by the law stated in it.

24. Other terms

• Notices. We send notices to the email address of your account’s administrator. You send notices to [email protected].
• Transfer. You may not transfer this contract without our written consent. We may transfer it to a business that takes over RadiusOne, and will tell you.
• Whole agreement. These terms, Schedule 1, our Privacy Policy and any written fee agreement are the whole agreement between us about RadiusOne.
• If part is invalid. If a court finds part of these terms invalid, the rest still applies.

Part B: Buying Wi-Fi access on a hotspot

This part is for you if you buy a Wi-Fi voucher on a hotspot page that uses RadiusOne.

25. Who you are dealing with

Your contract for internet access is with the internet service provider (ISP) whose name is on the hotspot page. The ISP sets the packages, prices, speeds and rules, and is responsible for the internet service. RadiusOne runs the payment page and the login system for the ISP, and collects your mobile money payment on the ISP’s behalf.

26. Paying

• You pay the price shown for the package. Neither RadiusOne nor the ISP adds any extra charge for paying by mobile money.
• You approve the payment with your mobile money PIN on your phone. The name on the PIN request may be our payment provider’s company rather than the ISP. The payment page tells you which name to expect when the payment provider gives it.
• One phone number can have at most two payments waiting at the same time on one ISP’s hotspot.

27. Your voucher code

• When the payment succeeds, the page shows your voucher code and normally logs you in.
• If you bought for someone else, the code is not sent to them. Copy it and share it yourself. The page does not log you in, so the voucher is not used on your phone.
• The package time starts when the code is first used to log in, not when you buy it.
• Keep your code private. Anyone who has the code can use it. A lost or shared code cannot normally be replaced.

28. If something goes wrong

• You closed the page before the code appeared. Open the hotspot page again and follow the link to find your code. Enter the number you paid from and the transaction ID from your mobile money SMS. For security, only a few tries are allowed in a short time.
• The payment failed. No code is created. The page shows the reason when it can, and lets you try again. A failed payment should not take money from your account. If money was taken and no code appears, use the “find your code” link. If that does not help, contact the ISP with your transaction ID.
• You paid twice. Each successful payment gives its own code, and each code can be found with its own transaction ID. Codes bought on the hotspot page do not currently have a deadline for first use. If you want money back instead, ask the ISP. Refunds are not automatic, but your rights under the law are not affected.
• The internet does not work after you log in. Contact the ISP. It is responsible for the connection.

If the ISP cannot help with a payment problem, contact RadiusOne at [email protected] or +256 770 495 640.

29. Your personal data

When you buy, the platform records your phone number, the payment and your device’s hardware (MAC) address. Our Privacy Policy explains how this data is used and what your rights are.

Schedule 1: pawaPay sub-merchant terms

pawaPay provides the mobile money service that RadiusOne uses. Its Merchant Terms of Service require every business that receives money through a platform like ours to accept pawaPay’s sub-merchant terms.

By accepting these terms, you also accept the sub-merchant terms in Appendix 1 to Schedule 2 of the pawaPay Merchant Terms of Service, as published at https://www.pawapay.io/merchant-terms-of-service and updated by pawaPay from time to time. In those terms, “you” means your business. pawaPay can enforce them directly against you.

The main points are summarised in section 8.2. The summary does not replace pawaPay’s text. If the two differ, pawaPay’s text applies to your relationship with pawaPay.