Financial & Anti-Fraud Policy

1. Introduction

Ogle Property Technology Limited (‘Ogle’, ‘we’, ‘us’) operates a digital property marketplace within Nigeria — a sector uniquely exposed to financial and regulatory complexity. This document consolidates our contractual baselines to ensure a safe, transparent, and fair environment for all registered users, property owners, listers, and buyers.

This Policy is enacted in strict compliance with the statutory provisions of the Federal Republic of Nigeria, including but not limited to:

• Central Bank of Nigeria (CBN) Regulations and Guidelines on Electronic Payments and E-Money;
• CBN Guidelines for Payment Service Banks;
• The Money Laundering (Prevention and Prohibition) Act, 2022;
• The Economic and Financial Crimes Commission (Establishment) Act;
• The Advance Fee Fraud and Other Related Offences Act;
• The Cybercrime (Prohibition, Prevention, etc.) Act, 2015; and
• The Nigeria Data Protection Act, 2023 (NDPA).

2. Payment Processing and Billing

Accepted channels & currency: All financial settlements are processed exclusively in Nigerian Naira (NGN) unless a distinct global product or service is explicitly designated in a foreign currency. We support the following payment modalities:

• Debit and credit cards issued by licensed Nigerian and international banks (including Visa, Mastercard, and Verve);
• Direct bank transfers via the Nigerian Interbank Settlement System (NIBSS) and NIBSS Instant Payments (NIP);
• Unstructured Supplementary Service Data (USSD) channels supported by partner financial institutions; and
• The native Ogle Wallet infrastructure.

Where a user elects to use an internationally issued card denominated in a foreign currency, the transaction remains subject to the card issuer’s conversion parameters, exchange rates, and international settlement fees. Ogle exercises no authority over, and accepts no liability for, such external banking friction or variance.

Operational security & data protection: To preserve data integrity and comply with the NDPA 2023, Ogle delegates cardholder and payment credential storage to third-party payment service providers licensed by the CBN. We do not archive full primary account numbers (PANs), Card Verification Values (CVV/CVV2), or bank authentication secrets in our databases. All data transit occurs over encrypted channels adhering to the Payment Card Industry Data Security Standard (PCI DSS).

By executing any transaction, you warrant that you hold legitimate authority over the designated payment instrument and that the balance is sufficient to settle the charge. Every successful settlement triggers an electronic confirmation receipt via email and platform notification, containing a unique Transaction Reference Number, payment metrics, timestamp, and asset identification. This receipt denotes proof of payment but does not constitute automatic acceptance of a listing or booking agreement.

Subscription and recurring billing: Where you subscribe to premium plans or recurring visibility services, fees are auto-debited at the start of each billing cycle from your configured primary payment option or Ogle Wallet. We deliver advance notice of upcoming renewals. Subscriptions can be cancelled at any time via the account control panel; cancellations take effect at the end of the current billing cycle, and no partial or prorated refunds are issued for unused periods.

Statutory taxation: All prices displayed are inclusive of Value Added Tax (VAT) at the prevailing statutory Nigerian rate unless stated otherwise. Where a transaction triggers a requirement for Withholding Tax (WHT) or other fiscal deductions, Ogle acts as a collecting agent and will furnish appropriate tax credit notes on request. Users remain independently responsible for their own tax filings resulting from marketplace activity.

3. The Ogle Wallet Infrastructure

Legal nature and status: The Ogle Wallet (‘Wallet’) is a digital ledger interface provided to enhance transactional convenience within the marketplace. Store-of-value funds reflected in your Wallet are held, managed, and processed exclusively by our designated financial institutional partners, who are licensed by the CBN to provide e-money, escrow, and payment services. The Wallet is not a traditional deposit account with Ogle; balances do not yield interest and are not directly indemnified by Ogle under the Nigeria Deposit Insurance Corporation (NDIC) scheme.

Funding and balance thresholds: Wallets may be funded through the approved channels above. In alignment with CBN e-money directives and risk-management parameters, store-of-value limits are tightly controlled.

Withdrawal mechanisms and restrictions: You may request a manual withdrawal of unencumbered Wallet balances back to a liquid bank account. To curb illegal capital flight and illicit transfers, withdrawals are subject to the following conditions:

• The destination bank account must be a verified Nigerian financial institution registered under the exact legal name matching your KYC documentation on the Platform;
• Third-party payouts are strictly prohibited; and
• Standard withdrawal requests are completed within two to five business days. Payouts are subject to administrative delays or temporary freezes where transaction monitoring flags anomalous velocity or suspicious behaviour.

Dormancy, expiry, and reclamation: A Wallet is designated Dormant if it logs zero organic transactions (deposits, internal expenditures, or withdrawals) for a continuous 12 months. On transition, Ogle issues an electronic notice granting a 60-day remediation window. If the account remains inactive afterwards, the underlying capital is moved out of active ledgers into a secure, centralised Ogle suspense account.

Dormant balances remain the property of the user. Capital can be reclaimed without penalty at any time, conditional on passing refreshed identity verification checks and submitting a formal petition to compliance@ogle.ng. If an account is closed permanently, the unencumbered balance is transferred back to the verified bank account on file within 14 business days, subject to final security clearance.

4. Refund Framework and Cancellation Protocols

Core disbursal principles: Refunds are never issued universally; they are subject to granular, case-by-case evaluation. All validated refunds adhere to the following baseline rules:

• Funds must return to the exact source payment method from which they originated (the specific card, bank ledger, or Ogle Wallet). Redirection to alternative third-party accounts or different instruments is strictly banned to prevent money-laundering bypasses;
• Ogle Platform service fees remain non-refundable, except where the transactional failure stems directly from an internal system failure or mathematical error on Ogle’s part; and
• All reversals are settled in Nigerian Naira (NGN), using the historical exchange rate captured at the moment of the original transaction.

Processing timelines: Native Ogle Wallet adjustments are concluded within 1 business day of authorisation. Reversals to external card networks or bank accounts require 5 to 10 business days, dictated by interbank clearing schedules.

Valid grounds for refund claims: You are entitled to request a reversal in the following circumstances:

• Technical Duplication: multiple debits from a single checkout action, logged within 30 days of the incident.
• Failed Service Delivery: where Ogle or a verified service provider completely fails to deliver a confirmed booking for reasons entirely within Ogle’s or the provider’s control.
• Material Misrepresentation or Listing Inaccuracy: where a booked property is substantially different from its listing (e.g., non-existent structure, complete unavailability, or fraudulent location). Upon independent validation, a full refund is issued and the errant lister faces enforcement action.
• Unauthorised / Fraudulent Transactions: reversals due to stolen credentials or compromised cards, provided investigation shows the account owner did not act negligently or facilitate the breach.
• Regulatory or Judicial Decree: reversals ordered by the CBN, a court of competent jurisdiction, or an active law enforcement directive.

Cancellation matrix: In the absence of bespoke cancellation clauses explicitly highlighted on a specific property checkout screen, the following standardised architecture governs all user-initiated cancellations:

Refund escalation process: To initiate a formal refund review, submit a comprehensive petition to billing@ogle.ng, or use the designated portal, within 90 days of the transaction timestamp. Failure to notify us within this window may affect our ability to recover funds from external payment networks or third-party listers, but it does not waive or extinguish your statutory rights under the applicable limitation laws of the Federal Republic of Nigeria. Submissions must include your full legal name, registered credentials, the Transaction Reference Number, the exact amount claimed, and supporting evidence (screenshots, bank statements, or written logs).

We provide an official acknowledgement within 2 business days. Straightforward duplicate debits are typically cleared within 7 business days, whereas multi-party property disputes requiring field inspections or third-party bank collaboration may require up to 30 business days.

5. Billing Disputes and Chargebacks

First-instance resolution: A chargeback is an external intervention whereby a card issuer or bank forcefully reverses a transaction under card-network rules (Visa, Mastercard, Verve). While a valid consumer-protection protocol, Ogle enforces a mandatory internal dispute timeline: you must notify us of any billing discrepancy or perceived erroneous charge via billing@ogle.ng within 30 days of the transaction date before escalating externally.

We aim to complete our initial evaluation of standard internal billing disputes within 14 business days of receipt. Complex multi-party property claims, automated network failures, or field inspections may extend the resolution period to up to 30 business days, and we will notify you of the extension. Straightforward technical duplications remain expedited and are cleared within 7 business days.

Institutional response: When an external chargeback is launched against Ogle, our compliance team compiles a response packet within the windows specified by the card scheme, including transaction metadata, system access logs, behavioural analytics, geographical markers, and platform correspondence. If the card network or arbitrator rules in Ogle’s favour, the original transaction value is reinstated and the user’s profile is frozen pending a secondary security review.

Abusive chargebacks and friendly fraud: A chargeback is abusive or fraudulent where a user knowingly initiates a claim despite having received the digital asset, property placement, or service, or generates false assertions of non-authorisation. Ogle enforces a zero-tolerance policy. Confirmed abuse triggers immediate action, including:

• Suspension or termination of the primary Ogle account and all affiliated sub-identities;
• Direct administrative recovery of the disputed amount from your active Ogle Wallet balance or incoming revenue pipelines;
• Reporting of verified fraud to lawful regulatory authorities, credit reference bureaus, and industry fraud-prevention desks, strictly to the extent permitted by applicable CBN regulations and data-protection laws — we will not disclose Bank Verification Numbers (BVNs) to unauthorised third parties or private databases; and
• Civil litigation to recover the original sum together with accrued investigative costs and legal fees.

Chargeback processing fees: Where an external chargeback causes our merchant clearing bank to levy administrative penalties against Ogle, we reserve the right to debit the exact cost of that penalty from your account ledger, provided an internal review confirms the chargeback was initiated without a reasonable or objective basis.

6. Anti-Fraud & Security Protocols

Risk taxonomy: Ogle recognises that digital property platforms in Nigeria operate in a high-risk environment. Our protocols are designed to combat, in particular:

• Property Listing Fraud: listing assets one does not own or have authority to transact, to collect off-platform deposits — often signalled by prices far below market value and pressure to bypass Ogle’s escrow.
• Identity and Account Takeover (ATO) Fraud: fabricated identities using forged credentials, or unauthorised takeover of existing profiles via credential stuffing or social engineering.
• Advance Fee Fraud: soliciting off-platform fees (viewing, premium registration, accelerated processing) as a precondition to view a fictitious asset. Ogle never mandates fees outside its official on-platform channels.
• Payment and Chargeback Fraud: using stolen cards, cloned instruments, or compromised accounts to fund Wallets, and malicious chargebacks.
• Money Laundering: layering or integrating illicit capital into real estate value or the Wallet infrastructure.
• Phishing & Social Engineering: actors impersonating Ogle to harvest account secrets, OTP codes, or PINs. Ogle personnel will never request an active password, full card number, or CVV.

Proactive control measures: Ogle operates a multi-layered defensive posture across our ecosystem:

• Mandatory KYC verification: users cannot list assets or execute payments above defined thresholds without completing identity verification — government-issued ID (International Passport, NIN, Driver’s Licence, or Voter’s Card), biometric liveness validation, and automated address verification.
• Automated transaction monitoring: real-time behavioural and velocity analytics assess payment streams for laundering or card-fraud indicators, holding flagged activity for manual review.
• Device & behavioural analytics: continuous monitoring of IP anomalies, device fingerprinting, and unusual login patterns, with automated multi-factor authentication where needed.
• Listing integrity auditing: every proposed listing undergoes an automated metadata scan and manual review before it goes live; listers may be required to upload land titles, Certificates of Occupancy, Deeds of Assignment, or powers of attorney.
• Sanctions and PEP screening: routine checks against international sanctions databases, Nigerian law-enforcement watchlists, and Politically Exposed Person indices.
• Staff & compliance readiness: personnel undergo regular training on emerging financial-crime typologies and local fraud trends.

7. Incident Reporting & Enforcement

Reporting channels: If you detect suspicious listings, unauthorised communication requests, or suspected fraudulent behaviour, report it immediately to fraud@ogle.ng, including relevant transaction numbers, profile URLs, and evidentiary screenshots. All submissions are treated with strict confidentiality. In accordance with Section 6 of the Cybercrime Act 2015, users are also encouraged to escalate severe criminal acts directly to the EFCC Lagos Zonal Office or the Nigeria Police Force.

Statutory consequences: Where an internal compliance investigation confirms that a user has facilitated, attempted, or executed fraud, identity theft, or money laundering via the Platform, Ogle will enforce strict measures, including:

• Restriction of platform access and a temporary administrative freeze on the associated Wallet balance, preserved pending a formal determination or forfeiture order from a court of competent jurisdiction or an authorised law enforcement agency (such as the EFCC);
• Termination of associated user accounts and blacklisting of matching hardware fingerprints and BVNs, to the extent permitted by law;
• Civil litigation to recover damages, lost revenue, and professional fees; and
• Mandatory statutory referral: transfer of the complete case file, user logs, and identity profiles to the EFCC, the Nigeria Police Force, or the Special Fraud Unit.

Ogle cooperates fully with all lawful government investigations. We reserve the right to share account records and transactional histories with authorised regulatory entities in response to an active subpoena or judicial warrant, without prior notice to the target account holder where permitted by law.

8. Operational Guidance for Users

To maximise safety within the marketplace, all users should observe the following:

• Never settle payments off-platform: any demand to transfer funds to a private bank account for a transaction originating on Ogle is a policy violation and a primary indicator of fraud. Ogle will never ask you to send money to a personal bank account.
• Exercise professional verification: insist on reviewing valid ownership documents and physical structures before committing, and retain an independent, qualified legal practitioner to perform title searches at the land registry before entering complex arrangements.
• Account hardening: activate Two-Factor Authentication (2FA) via an authenticator app or SMS token, and never disclose OTP codes, passwords, or transactional PINs to anyone — including individuals claiming to be Ogle support.

9. Policy Evolution and Amendments

This consolidated document reflects our policy baseline as of June 2026. Ogle reserves the right to modify or restructure elements of this Policy at any time to remain aligned with changing CBN circulars, updated federal legislation, or card-network directives. Material amendments will be preceded by a minimum of 14 days’ advance notice via registered user emails or prominent interface alerts. Continued use of the Platform or Wallet after the notice period expires constitutes full, legally binding acceptance of the revised Policy.

For clarifications, contact us at support@ogle.ng.