1. Who We Are and What This Covers

ComGrow Technologies Limited ("ComGrow", "we", "us") operates a mobile application that helps trusted groups manage savings and loans digitally — also known as village banking. Through the ComGrow App, users can create groups, set rules ("constitutions"), record savings, loan disbursements, repayments, penalties, and payouts — all in one place. 

ComGrow is not a bank and does not hold or issue electronic money. All payments processed through the App are executed by Kazang Zambia Limited ("Kazang"), a Payments System Business licensed and regulated by the Bank of Zambia. Kazang is responsible for the movement and settlement of funds in connection with your transactions. The physical funds backing Kazang's e-money are held in a trust account at First Capital Bank Zambia.

ComGrow does not have custody of your funds at any point. Kazang's regulatory obligations under Zambian payments law apply to all transactions processed through the App.

These Terms outline your rights, responsibilities, and the conditions under which you may use the ComGrow App and related services ("the Services").

2. Definitions

In these Terms, the following words have the meanings set out below:

3. Who Can Use ComGrow

You must be at least 18 years old and have full legal capacity to enter into contracts. We may decline or restrict access to the Services if you fail identity checks, engage in fraud, or are located in a country where regulations prevent us from offering the Services.

4. Acceptance of These Terms

Before accessing the Services, you will be presented with these Terms during the sign-up process. By completing registration, you confirm that you have read, understood, and agreed to be bound by these Terms. If you do not agree, do not proceed with registration — you will not be able to use the Services.

These Terms are always available on our website at www.comgrow.org under the Help section.

Your continued use of the App after any updates to these Terms, following notification, will be treated as your acceptance of the revised Terms.

5. Registration, KYC, and Security

To use ComGrow, you must register using your valid email address and complete our identity verification (KYC) process, which includes providing your personal details, a copy of a valid identity document, and a selfie photograph of yourself holding your identity document. This information is reviewed by ComGrow to verify your identity and comply with our regulatory obligations.

Until your KYC is approved, your ability to transact on the App will be limited. ComGrow reserves the right to decline or revoke KYC approval at its discretion, without being required to give a reason.

You are responsible for ensuring that all information and documents you submit are accurate, genuine, and up to date. Submitting false or misleading information is a serious breach of these Terms and may result in immediate account suspension and referral to relevant authorities.

You are responsible for securing your device, app login credentials, and Mobile Money PIN. We treat all actions made from your verified account as authorised by you. If you suspect unauthorised access, contact us immediately through our Helpdesk or WhatsApp.

6. What the ComGrow App Does

Through the ComGrow App, you can:

• Group Creation and Management: Create or join a savings group with people you know and trust. The Primary Admin sets the Group Constitution and manages the group. ComGrow provides the tools and ledger — we do not manage your group or decide who gets loans.
• Transactions: Record and process savings contributions, loan disbursements, repayments, penalties, and payouts. Where funds are moved, the transaction is processed securely through Kazang Zambia Limited and reflected on your group dashboard.
•  Transparency: View real-time balances, pending loans, and transaction histories for full transparency.

Feature Scope (Important): ComGrow does not currently offer standalone wallets, public peer-to-peer transfers, agent cash-in/out, merchant payments, or cards. These features may be added later under separate terms and conditions.

7. Group Admins and Group Management

Each Group is managed by a Primary Admin and, optionally, a Secondary Admin.

The Primary Admin is responsible for setting and editing the Group Constitution, inviting members, managing transactions, and appointing a Secondary Admin if desired. The Secondary Admin has limited rights — their sole function is to approve loan requests, subject to the loan approval settings configured by the Primary Admin. The Secondary Admin has no other administrative powers over the Group.

Where a Group has both a Primary and Secondary Admin, the loan approval threshold may be configured to require both Admins to approve a loan before it is disbursed. This is an optional governance feature and it is the Group's responsibility to configure and use it appropriately.

Primary Admins act on behalf of their Group and are accountable to their Group members. ComGrow provides the platform tools but does not supervise, audit, or take responsibility for decisions made by Group Admins. If you believe a Primary Admin has acted improperly, this is a matter to be resolved within your Group according to your Group Constitution.

If a Primary Admin needs to be changed, please contact our Helpdesk at www.comgrow.org. ComGrow will require reasonable verification before making any changes to Group Admin status.

8. Group Constitution

When creating a Group, the Primary Admin configures the Group Constitution within the App — setting the savings target, interest rate, interest type, cycle length, and group type. This constitution governs the financial rules that apply to all members of that Group.

By joining a Group, you agree to be bound by that Group's Constitution. You are responsible for reviewing and understanding the Group Constitution before joining.

ComGrow provides the tools to set and record a Group Constitution but does not validate, enforce, or take responsibility for its contents. Primary Admins are responsible for ensuring that their Group Constitution does not conflict with Zambian law. ComGrow will not arbitrate disputes between members about the interpretation or enforcement of a Group Constitution. 

We encourage Groups to maintain a more detailed constitution outside the App to govern matters not covered by the App's settings, such as meeting schedules, member conduct, and dispute resolution procedures.

9. Your Responsibilities

• Know Your Members: Only form or join groups with people you know and trust. ComGrow does not match or assign members.
• Follow Group Rules: Each Group's Constitution governs contributions, loan terms, and payouts. By joining, you agree to those rules.
• Initiate Your Own Transactions: All transactions on the App are initiated by each user themselves. No user, including a Group Admin, can initiate a transaction on behalf of another member.
• Double Check Transactions: Always review details before confirming — incorrect entries may not be reversible.
• Act Legally and Respectfully: Don't use ComGrow for fraud, scams, or any illegal purpose.

10. Fees and Transaction Limits

Fees

ComGrow charges the following fees for use of the Services, which are automatically deducted at the time of the relevant transaction:

• Monthly Membership Fee: K20 per user, per Group, per month. If you are a member of more than one Group, the monthly fee applies separately for each Group.
• Loan Convenience Fee: 3% of the loan amount, charged at the time of loan disbursement.
• Payout Fee: 1% of the payout amount, charged at the time of payout.
• Mobile Money Transaction Fees: When making savings contributions or loan repayments through the App, fees charged by your Mobile Money Network will apply. For transactions made via MTN Money, standard MTN rates apply. For transactions made via Airtel Money or Zamtel Money, the fee is 3% for collections. 

All applicable fees will be clearly displayed in the App before you confirm any transaction. ComGrow reserves the right to amend its fees from time to time. We will notify you of any fee changes, giving you reasonable notice before changes take effect. 

Transaction Limits

Transaction limits on payments made through the App are set by your Mobile Money Network provider in accordance with the laws and regulations of the Bank of Zambia. These limits are outside ComGrow's control. Please contact your network provider or refer to their published tariffs for current limits.

11. Transactions and Authorisation

By using the Services, you authorise ComGrow and Kazang Zambia Limited to act on all transaction instructions submitted through the App from your account, including instructions submitted by someone purportedly acting as you.

Once a transaction instruction has been submitted and confirmed with your Mobile Money PIN, it is treated as authorised by you. ComGrow and Kazang may, at their absolute discretion, attempt to cancel or reverse a transaction at your request but are under no obligation to do so. 

Loan requests are subject to approval by the Group Admin(s) where the Group Constitution requires it. A loan will only be disbursed once the required approvals have been granted. 

ComGrow and Kazang are also authorised to comply with any order or instruction from a court, regulator, or other competent authority in relation to your account or transactions.

12. Mistakes and Transaction Issues

What if I make a mistake in a transaction?

All transactions should be carefully reviewed before confirmation. Once a transaction has been submitted and your Mobile Money PIN entered, it is considered final and is generally not reversible. If you believe a transaction was made in error, please contact us immediately via our Helpdesk at www.comgrow.org with your full name, the mobile number used, the amount, and a screenshot of the completed transaction. We will investigate and respond within 48 hours.

Where a reversal is possible, ComGrow will make reasonable efforts to facilitate it in cooperation with Kazang Zambia Limited and the relevant Mobile Money Network. However, ComGrow cannot guarantee that any transaction can be reversed once processed, and is not liable for losses arising from incorrectly submitted transactions.

My wallet was charged but it's not showing in the App. What do I do?

Don't worry — sometimes transactions take a little longer to reflect. Do not resubmit the transaction. Contact our Helpdesk at www.comgrow.org straight away with your full name, the mobile number used, and a screenshot of the completed transaction. We will trace and resolve it within 48 hours.

13. Payouts and Group Cycle-End

At the end of a Group Cycle, or at any point permitted by the Group Constitution, members may initiate a payout through the App. Payouts are settled to the member's mobile money wallet or bank account, where that option is available.

A payout fee of 1% of the payout amount will be automatically deducted at the time of processing.

If a payout fails — for example due to an incorrect mobile number, insufficient network availability, or a bank processing issue — please contact our Helpdesk at www.comgrow.org immediately. ComGrow will work with Kazang Zambia Limited to trace and resolve the issue. ComGrow is not liable for delays in payout settlement caused by Mobile Money Network providers or banks.

14. Financial Records and Statements

You can view your Group's financial activity at any time through the Financial Report section of the App, which shows savings, loans, repayments, and payouts filtered by period and member.

Transaction records displayed in the App are the official record of activity on your account. Save for a clear error, these records are conclusive evidence of transactions carried out through the App.

Formal transaction statements are not available on demand. Where a statement is required for the purposes of an investigation or dispute resolution, ComGrow may produce one at its discretion and deliver it electronically to your registered email address.

ComGrow does not issue printed statements. All records are provided electronically.

15. Acceptable Use and Financial Crime

You agree not to:

• Use the App for unlawful purposes, including fraud or money laundering.
• Misuse or attempt to hack, disrupt, or reverse-engineer the ComGrow platform.
• Operate or share your account with others.
• Post harmful, misleading, or offensive content.
• Use the App for money laundering, terrorist financing, fraud, sanctions evasion, or any other financial crime under Zambian law.

ComGrow and Kazang Zambia Limited are required by law to monitor transactions for suspicious activity. Where we have reasonable grounds to suspect that a transaction or account may be connected to financial crime, we are obligated to report this to the Financial Intelligence Centre (FIC) and other relevant authorities under the Financial Intelligence Centre Act and applicable AML/CFT regulations — without notifying you that a report has been made. 

In such circumstances, we may suspend or freeze your account or withhold a transaction without prior notice and without liability to you. We will cooperate fully with the FIC, the Bank of Zambia, law enforcement agencies, and any other competent authority as required by law.

You warrant that all funds you contribute through the App come from legitimate sources. 

We may suspend or terminate accounts that breach this policy without notice.

16. Suspension, Termination, and Inactivity

We may suspend or close your account if:

• You engage in fraud or illegal activity.
• You fail to comply with these Terms or provide false information.
• Required KYC verification steps are incomplete.
• We are required to do so by a court, regulator, or other competent authority.
• Your account remains inactive for a period determined by ComGrow in accordance with guidelines issued by the Bank of Zambia.

Before taking action on a dormant account, ComGrow will make reasonable attempts to contact you using your registered email address and phone number. Any funds associated with a dormant account will continue to be held securely by Kazang Zambia Limited in accordance with applicable regulations until they are claimed or otherwise dealt with as required by law.

You may close your account at any time by contacting our Helpdesk at www.comgrow.org. Before closing, you must ensure all outstanding Group obligations — including any unpaid loans, pending contributions, and unsettled payouts — are resolved. ComGrow will not close an account with unresolved Group obligations without first notifying you.

If a Group is dissolved, any remaining funds held within the Group must be paid out to members before dissolution is finalised. The Primary Admin is responsible for initiating and completing this process through the App. Where a Group cannot be dissolved in an orderly manner, please contact our Helpdesk and we will assist where we are able to. ComGrow's involvement in Group dissolution is limited to providing transaction records and technical assistance.

17. Death or Incapacitation

In the event of your death or legal incapacitation, ComGrow will not permit any operation or withdrawal from your account until we have received satisfactory documentation from a duly authorised legal representative, such as a Grant of Letters of Administration or Probate issued by a competent court.

If you become aware of the death or incapacitation of a Group member, please notify our Helpdesk at www.comgrow.org as soon as possible so we can take appropriate steps to protect that member's account.

18. Privacy and Data Protection

We collect and process your personal and transactional data to provide the Services, comply with legal and regulatory requirements (including AML/CFT obligations), and improve user experience. We may share data with authorised partners such as Kazang Zambia Limited, Mobile Money Networks, and regulators as required by law.

Your data will be processed and stored in accordance with Zambia's Data Protection Act (2021) and our Privacy Policy, which forms part of these Terms. You can request the deletion of your personal data by contacting us at info@comgrow.org.

19. Intellectual Property and Licence

We grant you a limited, personal, non-transferable, and revocable licence to use the ComGrow App. All intellectual property — including our software, brand, and design — remains owned by ComGrow. You may not copy, modify, distribute, or reverse-engineer any part of our platform.

20. Our Liability

ComGrow will provide its Services with reasonable care but makes no warranties about uninterrupted or error-free operation. We are not liable for:

• User mistakes or incorrect payment instructions.
• Failures by Mobile Money Networks, Kazang Zambia Limited, or other third-party providers.
• Disputes among Group members.
• Any indirect, incidental, or consequential loss.
• Any financial loss you suffer as a result of joining a Group, participating in Group savings or lending, or as a result of the actions or inactions of other Group members or Admins.

ComGrow provides a platform for groups to manage their savings and lending activities. We do not vet, endorse, or take responsibility for the financial decisions made by any Group or its members. You acknowledge that village banking involves financial risk, including the risk that other members may default on loans, that a Group may not achieve its savings targets, or that a Group may dissolve before a payout is made.

Our maximum liability for any claim will not exceed your current balance in the affected Group or the direct amount lost due to proven negligence — whichever is lower. Nothing in these Terms limits liability that cannot be limited by Zambian law.

21. Force Majeure

ComGrow will not be liable for any failure or delay in providing the Services caused by circumstances beyond our reasonable control, including but not limited to acts of God, floods, fire, earthquakes, power failures, telecommunications outages, internet disruptions, failures of third-party systems including Mobile Money Networks and Kazang Zambia Limited, government action, civil unrest, or any other event outside our control.

In such circumstances, we will make reasonable efforts to restore the Services as soon as possible and will communicate with users where we are able to do so.

22. Indemnity

By using the Services, you agree to indemnify and hold ComGrow, its directors, employees, and partners (including Kazang Zambia Limited) harmless from any loss, damage, cost, or claim arising from:

• Your breach of these Terms.
• Your provision of false, inaccurate, or misleading information.
• Any unauthorised use of your account or credentials.
• Your use or misuse of the App or Services.
• Any transaction you initiate, including incorrectly submitted transactions.
• Any dispute between you and other Group members or Admins.
• Your failure to keep your Mobile Money PIN or login credentials secure.
• 
  

23. Communications and Consent

By registering for and using the ComGrow App, you consent to receiving communications from ComGrow Technologies Limited through all available channels, including in-app notifications, email, and SMS to your registered contact details. These communications may include transactional messages (such as payment confirmations, service alerts, and maintenance notices) as well as updates about new features, changes to the Services, and other marketing or promotional content.

If you wish to opt out of any communications, you may do so at any time by writing to info@comgrow.org. Please note that opting out of transactional communications (such as payment confirmations and service alerts) may affect your ability to use the Services effectively.

Your contact details will be used solely for the purposes described in these Terms and our Privacy Policy, and will not be sold to third parties.

24. Availability of Services

We aim to provide ComGrow 24/7, but we cannot guarantee uninterrupted access. Delays may occur due to maintenance, telecom issues, or external outages. Always ensure you have the latest version of the App installed for the best experience.

25. Help, Disputes, and Support

If you face an issue, please contact us through any of the following channels:

• Helpdesk (recommended): Submit a support ticket via our website at www.comgrow.org
• WhatsApp: https://wa.me/message/4MXWH27STBAFH1 or +260 965 231 104
• Email: info@comgrow.org

 We will acknowledge your request promptly and aim to resolve most issues, including transaction queries, within 48 hours.

If your complaint is not resolved within 60 days, the matter shall be referred to arbitration in Lusaka, in accordance with the Arbitration Act No. 19 of 2000 of the Laws of Zambia.

If you feel your complaint has not been adequately resolved through our internal process or arbitration, you may also refer the matter to the Bank of Zambia as the regulatory authority overseeing payment systems in Zambia.

26. Changes to These Terms

ComGrow reserves the right to amend these Terms at any time, including to reflect new features, changes to the Services, updates to our fee structure, or changes required by law or regulation.

We will notify you of any material changes, giving you reasonable notice before changes take effect. Your continued use of the App after notification constitutes your acceptance of the updated Terms. If you do not agree with any changes, you must stop using the App and contact our Helpdesk at www.comgrow.org to close your account.

The most current version of these Terms is always available on our website at www.comgrow.org.

27. Governing Law

These Terms are governed by the laws of the Republic of Zambia. If any part of these Terms is found unenforceable, the remaining sections will still apply.

28. Contact Us

ComGrow Technologies Limited

Plot 377A/A/1/2 Bishops Road, Kabulonga, Lusaka, Zambia

Email: info@comgrow.org

WhatsApp: +260 965 231 104

Website: www.comgrow.org