Terms & Conditions

1.1 Parties. This Membership Agreement (“Agreement”) is entered into between Ajyal Fintech Solutions L.L.C., a limited liability company incorporated and registered in the Qatar Financial Centre (“QFC”) under QFC No. 02719, trading under the name “Wafir”, and having its principal place of business at Floor No. 9, Tech Circle, QFC Tower 1, P.O. Box 35192 Doha-Qatar (“Wafir”), and the individual who registers for, accesses, or uses the Wafir mobile application or any related services (the “Member”).

1.2 Purpose. The purpose of this Agreement is to establish the legally binding terms governing the Member’s access to and use of the Wafir application (the “App”), including registration, Verification, account management, and compliance obligations. Wafir operates as a digital platform for community-based lending circles, also known as Rotating Savings and Credit Associations (ROSCA), where Members contribute fixed instalments and take turns receiving payouts.

1.3 Binding Nature of Agreement. By downloading, registering for, or using the App, the Member acknowledges and agrees that this Agreement constitutes a legally binding contract between the Member and Wafir. For clarity, this Agreement continues to apply at all times for use of the App, Verification, KYC/CDD, compliance obligations, and ongoing monitoring, whether or not the Member participates in a Circle.

1.4 Relationship with Other Documents. This Agreement shall be read together with, and incorporates by reference, the following documents, each of which forms an integral part of the Member’s contractual relationship with Wafir:

a. the Client Charter, which is made available for the Member’s review and provides information on Wafir’s service commitments, the Member’s key responsibilities, the risks of participation, and how Circles operate. The Client Charter is an information-based document and does not itself create binding obligations;

b. the Privacy Policy, which explains how Wafir collects, uses, retains, and protects personal data in accordance with applicable laws and regulations. The Privacy Policy is binding on the Member and must be accepted separately at the time of approval of this Agreement; and

c. the Circle Participation Terms & Conditions, which govern Circle participation, contributions, payouts, defaults, and related operational procedures. These terms are provided only to Members who have successfully completed Verification and elected to join a Circle and shall become binding upon the Member’s acceptance thereof.

1.5 Regulatory Compliance. Wafir has been admitted into the Qatar Central Bank (QCB) Regulatory Sandbox to test its model for community-based lending circles, also known as Rotating Savings and Credit Associations (ROSCA). For clarity, the following shall apply:

a. Sandbox Phase. Until Wafir exits the Sandbox and is formally licensed by QCB, Wafir is not a licensed ROSCA. By registering for and using the App during the Sandbox phase, the Member expressly acknowledges and consents to participation in a regulated test environment, with the understanding that certain features, controls, and processes may be subject to ongoing modification in consultation with QCB.

b. Post-Licensing Framework. Upon successful exit from the Sandbox, Wafir shall operate as a QCB-licensed ROSCA and shall remain registered within the Qatar Financial Centre (QFC). From that time, all services provided by Wafir shall be subject to the full licensing and supervisory framework of QCB and the applicable laws and regulations of the State of Qatar.

1.6 Allocation of Rights, Obligations, and Remedies. This Agreement allocates the respective rights and obligations of Members and Wafir with respect to App access and Verification. Nothing in this Agreement shall limit or prejudice Wafir’s right to take action against any Member in the event of fraud, misrepresentation, regulatory breach, or other contravention of this Agreement, the Privacy Policy, or, where applicable, the Circle Participation Terms & Conditions.

1.7 Shariah Compliance. Wafir confirms that the App and Circles have been reviewed and certified as compliant with the principles of Islamic Shariah by a recognised Shariah Authority. Wafir shall maintain this certification and operate in accordance with Shariah-compliant standards, subject to applicable laws and regulations. Wafir shall notify Members in the event of any change to its Shariah certification status, and details of the current Shariah Authority shall be made available in accordance with Section 23 (Contact & Regulatory Information).

1.8 Regulatory References. All references in this Agreement to laws, regulations, rules, instructions, directives, guidelines, or circulars issued by the Qatar Central Bank, the Qatar Financial Information Unit, the Qatar Financial Centre, or any other competent authority shall be deemed to include any amendments, replacements, or successor instruments thereto, as may be issued from time to time.

For the purposes of this Agreement, unless the context otherwise requires, the following terms shall have the meanings set out below.

2.1 “Account” means the unique digital profile created by a Member on the App, which serves as the gateway for accessing the Wafir services.

2.2 “Ajyal Fintech Solutions L.L.C.” means the company incorporated and registered in the Qatar Financial Centre (“QFC”) under Registration No. 02719, trading under the name “Wafir”, which is the contracting entity and service provider under this Agreement.

2.3 “AML/CFT” means Anti-Money Laundering and Combating the Financing of Terrorism, as defined under Qatar Law No. (20) of 2019 and any related QCB rules, instructions, or guidelines.

2.4 “App” means the mobile application branded as “Wafir,” owned and operated by Ajyal Fintech Solutions L.L.C., through which Members access the Circles and Wafir services.

2.5 “Circle” means a community-based rotating savings and credit association (“ROSCA”) facilitated through the App, under which Members contribute fixed Pay-ins over defined periods and take turns receiving Payouts, all in accordance with these Terms & Conditions and the Membership Agreement.

2.6 “Circle Participation Terms & Conditions” means the document governing Circle participation, contributions, payouts, defaults, remedies, and related operational procedures. This document is binding only upon a Member’s acceptance when electing to join a Circle.

2.7 “Client Charter” means the plain-language document published by Wafir and accessible to all Members, which summarises service commitments, risk disclosures, and the Member’s responsibilities.

2.8 “CDD” or “Customer Due Diligence” means the process of identifying and verifying the identity of a Member, assessing the purpose and intended nature of the Member’s relationship with Wafir, establishing the source of funds, and conducting ongoing monitoring in accordance with Qatar Law No. (20) of 2019 on Anti-Money Laundering and Combating the Financing of Terrorism, the rules and instructions of the QCB, and related regulatory requirements.

2.9 “e-KYC” or “Electronic Know Your Customer” means the process of verifying the identity and eligibility of a Member in accordance with QCB AML/CFT and e-KYC requirements, including but not limited to electronic identity validation, digital submission of documents, salary verification, bank details, and Credit Bureau checks.

2.10 “Force Majeure Event” means any event or circumstance beyond the reasonable control of the affected party, including but not limited to acts of God, natural disasters, war, terrorism, epidemic or pandemic, governmental orders or restrictions, labour disputes, systemic failures in telecommunications or banking infrastructure, or prolonged outages of third-party service providers.

2.11 “Intellectual Property” means all rights, title, and interests in and to patents, inventions, trademarks, trade names, service marks, logos, trade dress, domain names, copyrights, database rights, design rights, trade secrets, know-how, software, source code, object code, algorithms, user interfaces, data, documentation, and all other proprietary rights, whether registered or unregistered, and including applications for registration and renewals thereof, anywhere in the world.

2.12 “Net Eligible Income” means the portion of a Member’s verified monthly income remaining after deduction of all active financial commitments and obligations appearing in the Member’s credit information retrieved from the Qatar Credit Bureau.

2.13 “Member” means a natural person who has registered for an Account on the App in accordance with this Agreement and, where applicable, elected to join a Circle by accepting the Circle Participation Terms & Conditions.

2.14 “Member Content” means any data, information, materials, communications, documents, or other content uploaded, submitted, or transmitted by a Member through the App, including but not limited to verification documents, support queries, and communications with Wafir, but excluding any personal data processed by Wafir in accordance with Section 9 (Data Protection & Privacy).

2.15 “Participation Cap” means the maximum share of a Member’s verified monthly salary that may be allocated to participation in a Circle, as determined in accordance with Section 3.4.

2.16 “Qatar Credit Bureau” means the national credit information bureau established under the supervision of the Qatar Central Bank, responsible for collecting, maintaining, and providing credit information and reports on individuals and entities in the State of Qatar for the purposes of credit assessment, verification, and financial risk monitoring in accordance with applicable laws and regulations.

2.17 “Privacy Policy” means the document published by Wafir and accessible to all Members, which explains how personal data is collected, used, retained, and protected in accordance with applicable QCB and QFC Data Protection Regulations.

2.18 “QFC” or “Qatar Financial Centre” means the legal and regulatory jurisdiction established pursuant to QFC Law No. (7) of 2005, including its regulations, rules, and authorities, under which Ajyal Fintech Solutions L.L.C. is incorporated and registered.

2.19 “QCB” or “Qatar Central Bank” means the regulatory authority responsible for licensing, supervising, and overseeing Wafir, including its operations under the Regulatory Sandbox and any post-licensing framework.

2.20 “QFIU” or “Qatar Financial Information Unit” means the national financial intelligence unit of the State of Qatar, established under Law No. (20) of 2019 on Anti-Money Laundering and Combating the Financing of Terrorism, responsible for receiving, analysing, and disseminating information concerning suspected money laundering and terrorist financing activities.

2.21 “QID” or “Qatar Identification Card” means the official identification card issued by the State of Qatar to nationals and residents, containing the holder’s personal and residency details, and used as the primary form of identity verification for the purposes of registration, e-KYC, and CDD under this Agreement.

2.22 “ROSCA” means a digital rotating savings and credit association facilitated through the App, whereby Members contribute fixed instalments over defined periods and take turns receiving payouts. The ROSCA structure is enabled through Wafir’s regulated operations and is subject to QCB oversight and other applicable Qatari laws.

2.23 “Sandbox” means the Qatar Central Bank Regulatory Sandbox, under which Wafir has been admitted to test and refine its model for digital ROSCAs, subject to regulatory supervision and modification.

2.24 “Section” means a numbered section of this Agreement, including any subsections, schedules, or annexes referenced herein.

2.25 “Shariah Compliance” means that Wafir has been certified by a qualified Shariah advisory body as operating in compliance with Islamic finance principles. This certification applies to the structure of Circles (ROSCA) and related financial practices facilitated through the App.

2.26 “Shariah Authority” means the recognised independent advisory or certification authority that has reviewed and certified Wafir’s App and Circles as compliant with Islamic Shariah principles, as identified in Section 23 (Contact & Regulatory Information).

2.27 “Suspension” means the temporary restriction of a Member’s access to their Account or the App in accordance with Section 16 (Suspension & Termination).

2.28 “Termination” means the closure of the Member’s Account and the ending of the Membership Agreement, which governs access to the App and all services accordance with Section 16 (Suspension & Termination). Termination of the Membership Agreement shall automatically terminate the Member’s participation in any active Circle, subject to the Circle Participation Terms & Conditions.

2.29 “Verification” means the process of identity validation, e-KYC, Customer Due Diligence, and any required re-verification or ongoing monitoring conducted under Section 5 (Verification, e-KYC, CDD & AML Compliance).

3.1 Minimum Requirements. A Member must be at least eighteen (18) years of age, legally competent to contract under the laws of the State of Qatar, and in possession of a valid Qatar Identification Card (“QID”).

3.2 Residency and Employment. A Member must be lawfully resident in the State of Qatar and employed by an entity operating in Qatar. Verification of employment shall be conducted through submission of a salary certificate or such other equivalent documentation as Wafir may reasonably require in accordance with applicable QCB and Qatar Credit Bureau standards.

3.3 Exclusions. The App may not be accessed or used by minors, legally incapacitated persons, or any person appearing on sanctions, fraud, terrorism financing, or exclusion lists maintained by QCB, the QFIU, international sanctions authorities, or any other competent authority.

3.4 Participation Cap. A Member’s participation in any Circle shall be subject to the following rules, as summarised in the Client Charter and further detailed in the Circle Participation Terms & Conditions, and determined on the basis of the verification outputs under Section 5 (Verification):

a. As a general rule, participation shall not exceed twenty per cent (20%) of the Member’s Net Eligible Income. The calculation shall be made on the basis of the Member’s salary certificate together credit information retrieved directly by Wafir from the Qatar Credit Bureau and shall be applied prior to the Member joining any Circle.

b. The Member shall promptly notify Wafir of any material change in employment status, salary, or financial commitments that may affect the Member’s Net Eligible Income. Wafir may, at its discretion, re-assess the Member’s eligibility and participation limit and require updated verification or adjustment of Circle participation accordingly.

c. Wafir may at its sole discretion, increase the Participation Cap above twenty per cent (20%), provided that any such increase does not cause the Member to exceed the maximum contribution and debt burden ratio limits prescribed by the QCB, including the current limits of seventy-five per cent (75%) of salary for Qatari nationals, fifty per cent (50%) of salary for non-Qatari residents, and a maximum contribution of QAR 27,500 per member at any time.

d. Wafir may, acting reasonably and in accordance with its risk-based assessment obligations under applicable QCB regulations, impose a lower Participation Cap on a Member where its verification process indicates elevated credit, compliance, or fraud risk.

3.5 Verification Requirements. Eligibility is subject to the Member’s successful completion of the electronic know-your-customer (“e-KYC”) process, together with Customer Due Diligence (“CDD”), and compliance with the Anti-Money Laundering and Combating the Financing of Terrorism (“AML/CFT”) requirements issued under Qatar Law No. (20) of 2019 and the related QCB instructions. Wafir may require submission of identity documents, proof of address, salary certificate, bank details, and shall retrieve the Member’s credit information directly from the Qatar Credit Bureau, and may conduct ongoing monitoring and re-verification as required by QCB, in accordance with Section 5 (Verification, e-KYC, CDD & AML Compliance).

3.6 Regulatory Oversight. Eligibility remains at all times subject to the regulatory requirements of the QCB, together with any other competent authority having jurisdiction over Wafir’s operations. Wafir reserves the right to deny or restrict access to any applicant who fails to satisfy such requirements, without obligation to provide reasons beyond those necessary to comply with applicable law.

4.1 Registration Process. To register an Account and access the App, a Member must complete the following steps:

a. Enter a valid Qatari mobile number and complete one-time password (OTP) verification.

b. Create a personal profile by providing full name, QID number, employment details, contact details, and such other information as Wafir may reasonably require.

c. Review and accept this Agreement and the Privacy Policy, both of which are made available within the App during the registration process.

d. Submit such information and documents as may be required for verification under Section 5 (Verification and Compliance).

4.2 Pre-Circle Access. Prior to joining any Circle, the Member may access the App without charge or financial commitment. Such access is limited to browsing certain App features, reviewing the Client Charter and the Privacy Policy, and completing verification requirements. No subscription fees are payable and no binding obligations relating to Circle participation arise until the Member elects to join a Circle and accepts the Circle Participation Terms & Conditions.

4.3 Truthful Information. The Member shall ensure that all information and documents submitted during registration are complete, accurate, and up to date. The Member must promptly update Wafir if any such information changes. Any misrepresentation or omission may result in rejection of the Member’s application, suspension of the Account, or Termination of access.

4.4 Single Account Policy. Each Member is permitted to maintain only one Account. A Member may not register or hold an Account on behalf of another person or entity. Shared, proxy, pooled, or third-party accounts are strictly prohibited.

4.5 Binding Effect. The Member becomes bound by this Agreement upon registration pursuant to Section 1.3. The Circle Participation Terms & Conditions become binding only when provided to a verified Member who elects to join a Circle, and only upon that Member’s express acceptance.

5.1 Initial Verification. Registration shall require completion of an electronic know-your-customer (“e-KYC”) process, including identity validation through the Member’s Qatari mobile number and QID.

5.2 Full Verification. and Customer Due Diligence. A Member shall not be permitted to join a Circle until full verification and CDD have been completed in accordance with the requirements of the Qatar Central Bank, the Qatar Financial Information Unit, and Law No. (20) of 2019 on Anti-Money Laundering and Combating the Financing of Terrorism. Full verification and CDD require submission of:

a. a valid QID;

b. proof of address in Qatar;

c. a salary certificate or equivalent proof of income;

d. bank account details; and

e. credit information retrieved directly by Wafir from the Qatar Credit Bureau as part of the e-KYC and AML/CFT verification process and for calculation of the Member’s Net Eligible Income.

f. confirmation through screening whether the Member, or their family members or close associates, are Politically Exposed Persons (“PEPs”), in which case enhanced due diligence will be applied in accordance with QCB requirements; and

g. any additional information or documentation required by Wafir to verify the Member’s identity, confirm the Member’s intended purpose of using the App, and establish the lawful source of funds.

The information obtained under sub-clauses (c), (e), and (f) shall be used to confirm the Member’s verified monthly salary, debt burden ratio, and financial profile for the purpose of determining the Participation Cap in accordance with Section 3.4. Wafir may periodically re-verify the Member’s information and credit status to ensure continued compliance with the Participation Cap and the Member’s obligation to maintain accurate disclosure of their Net Eligible Income.

5.3 Ongoing Monitoring and CDD. Wafir shall conduct ongoing CDD, including sanctions screening, transaction monitoring in line with QCB AML/CFT Instructions, fraud detection, and periodic re-verification of Members. Wafir may require the Member to provide updated documentation or information at intervals prescribed by the QCB or where Wafir considers it necessary based on its risk-based assessment.

5.4 Right to Suspend or Terminate.

a. Verification Stage. Wafir may, at its discretion, reject a Member’s application during the verification process where AML/CFT red flags, sanctions matches, incomplete or inconsistent information, or other verification concerns arise, or where required to do so by the QCB, the QFIU, or any other competent authority. In such a case, no Account shall be activated.

b. Post-Verification Stage. Where a Member’s Account has already been activated, Wafir may suspend or terminate the Account if AML/CFT red flags, sanctions matches, or other verification concerns subsequently arise, or where required to do so by the QCB, the QFIU, or any other competent authority. Such suspension or Termination shall apply to the Member’s access to and use of the App and related verification processes under this Agreement, and its effect shall be determined in accordance with Section 16 (Suspension & Termination) of this Agreement. Any effect on Circle participation shall be governed exclusively by the Circle Participation Terms & Conditions.

5.5 Use of Third-Party Providers. Wafir may engage third-party service providers that are authorised or otherwise permitted under applicable QCB outsourcing and e-KYC/CDD regulations to perform identity verification, sanctions screening, Credit Bureau checks, payment processing, or other compliance functions. Any such engagement shall be subject to confidentiality, security, data protection, audit, and regulatory access requirements, and Wafir shall at all times remain fully responsible for compliance with all applicable AML/CFT and related obligations under the laws and regulations of the State of Qatar.

5.6 Record Retention. Wafir shall retain Member identification, CDD, and transaction records in accordance with Section 9 (Data Protection & Privacy) and for the minimum periods required under applicable AML/CFT laws and regulations, which shall not be less than fifteen (15) years following account closure.

5.7 Member Cooperation. The Member shall promptly provide such additional information or documents as Wafir may reasonably request to satisfy its obligations under CDD and AML/CFT laws and regulations. Failure to do so may result in suspension or Termination of the Member’s Account.

5.8 Regulatory Reporting. Wafir may, without notice to the Member, disclose information or file reports with the QFIU, the QCB, or other competent authorities as required under applicable AML/CFT laws and regulations, in accordance with Section 13 (Consent to Regulatory Disclosure).

6.1 Accuracy of Information. The Member shall provide complete, accurate, and truthful information during registration and at all times thereafter. The Member shall promptly update Wafir if any information or documents previously provided become inaccurate or outdated, including without limitation any change in salary, employer, or debt obligations. Any material update may trigger re-verification in accordance with Section 5 (Verification, KYC & CDD) and may result in recalculation of the Participation Cap under Section 3.4.

6.2 Account Security. The Member shall safeguard their account credentials, passwords, PINs, and any other authentication methods used to access the App. The Member must ensure that their registered mobile device remains under their possession and control and shall take all reasonable steps to prevent unauthorised access to their Account. The Member shall also comply with all authentication and security measures implemented by Wafir in accordance with applicable laws and regulations. The Member shall not use default or easily guessable passwords and must follow any password strength requirements communicated by Wafir in line with QCB security standards.

6.3 Compliance Cooperation. The Member shall cooperate fully with Wafir’s ongoing compliance and verification requirements, including responding to requests for updated documents, information, or confirmations necessary to satisfy obligations under Qatar’s AML/CFT framework.

6.4 Proper Use. The Member shall not use the App, including all features related to registration, verification, compliance, or Circle participation (as governed by the Circle Participation Terms & Conditions), for any fraudulent, unlawful, or misleading purpose, or in any manner that contravenes this Agreement, the Circle Participation Terms & Conditions, or applicable laws and regulations. Without limitation, the Member shall not:

a. use the App including all features related to registration, verification, compliance, or Circle participation (as governed by the Circle Participation Terms & Conditions), to engage in money laundering, terrorism financing, sanctions evasion, or any other prohibited financial activity;

b. submit false, forged, or misleading information or documents, including salary certificates, bank details, or identification records;

c. attempt to circumvent or interfere with the security, authentication, or compliance features of the App; or

d. act on behalf of any other person or permit any third party to use their Account.

e. harass, abuse, defame, or otherwise harm other Members or Wafir personnel;

f. upload, transmit, or distribute viruses, malicious code, or harmful software; or

g. copy, distribute, or resell the App or any part of the Platform without Wafir’s prior written consent.

h. reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code, underlying ideas, or algorithms of the App.

6.5 Prohibition on Account Sharing. Each Account is personal to the Member. The Member shall not share, transfer, lend, or pool their Account with any other person or entity, and shall not act on behalf of another individual or institution in using the App. A Member may not open or maintain more than one Account. Any attempt to do so shall constitute improper use under Section 6.4.

6.6 Notification of Misuse. The Member shall promptly notify Wafir if they suspect or become aware that their Account has been accessed or used without their authorisation. Such notification may be made through the in-app reporting feature, via the Wafir Customer Trust Center (including its WhatsApp channel), or by email to the contact address provided in Section 23 (Contact & Regulatory Information). Upon receiving such notice, Wafir shall take reasonable steps, in accordance with applicable laws and regulations, to investigate the matter and, where appropriate, suspend, secure, or restore the Account. The Member acknowledges that Wafir may also be required to report suspected fraud, misuse, or suspicious activity to the QCB, the QFIU, or other competent authorities.

6.7 Lawful Source of Funds. The Member represents and warrants that all funds used in connection with the App originate from lawful sources and are not derived from criminal activity, money laundering, or terrorism financing.

6.8 Tax Obligations. The Member is solely responsible for reporting and paying any taxes, duties, or other charges that may arise from their use of the App or participation in any Circle, in accordance with the laws applicable to them.

6.9 Device & Network Responsibility. The Member is responsible for maintaining their own device, operating system, and internet connection in good order. Wafir shall not be liable for failures caused by the Member’s equipment or connectivity.

6.10 Liability for Account Activity. The Member is fully responsible for all actions taken through their Account, including any actions by third parties using the Account, whether authorised or unauthorised. Such responsibility includes, without limitation:

a. the accuracy, completeness, and truthfulness of all information and documents submitted;

b. the safeguarding of account credentials, authentication methods, and the registered mobile device; and

c. compliance with this Agreement and all applicable laws and regulations.

6.11 Indemnity for Breach. The Member shall indemnify and hold Wafir harmless from and against any losses, damages, penalties, or claims incurred by Wafir or any third party as a result of the Member’s breach of this Agreement, the Circle Participation Terms & Conditions, or any applicable law.

6.12 Member Security Awareness. The Member shall review and comply with Wafir’s security guidance provided in the Client Charter and Privacy Policy, including best practices for safeguarding devices, credentials, and communications.

7.1 Access Prior to Verification. Before completing full verification, the Member may download and browse the App free of charge. During this stage, the Member may access and review the Client Charter and view available Circles but shall not be able to join or participate in any Circle until verification is completed and the Circle Participation Terms & Conditions have been accepted. The Member acknowledges that failure to maintain valid Verification status, as required under Section 5, may result in temporary suspension or denial of access to certain features of the App.

7.2 Access Following Verification. Upon successful completion of Verification under Section 5, the Member may be eligible to participate in a Circle. Such participation shall be subject to the Member’s acceptance of the Circle Participation Terms & Conditions, which are provided separately at the point of Circle entry.

7.3 Personal, Non-Transferable Licence. Access to and use of the App is granted strictly on a personal, limited, revocable, and non-transferable basis. The Member shall not sublicense, assign, or otherwise transfer their access rights to any other person. The Member shall not use the App in any manner that interferes with its normal operation, security controls, or availability to other Members.

7.4 Suspension or Restriction of Access. Access to the App may be suspended or restricted in accordance with Section 16 (Suspension & Termination). Such suspension or restriction may also occur where required by the QCB, the QFIU, or other competent authorities under applicable laws and regulations.

8.1 No Fees Prior to Circle Participation. The Member shall not be charged any fees for downloading, registering with, or browsing the App. No payment obligations of any kind arise at the App usage or Verification stage. Fees become payable only when the Member elects to join a Circle.

8.2 Circle Participation Fees. Fees relating to Circle participation, including subscription fees or any applicable charges, shall be governed exclusively by the Circle Participation Terms & Conditions and disclosed to the Member in advance through the Client Charter and further detailed in the Circle Participation Terms & Conditions, in accordance with QCB requirements.

9.1 Compliance. Wafir shall collect, process, store, and protect personal data in compliance with the QCB’s Data Handling and Protection Regulation, the QFC Data Protection Regulations 2021, Law No. (13) of 2016 on the Protection of Personal Data, Law No. (20) of 2019 on Anti-Money Laundering and Combating the Financing of Terrorism, and any other applicable laws and regulations.

9.2 Purpose of Processing. Personal data may be collected and processed for the purposes of:

a. conducting verification, including identity and eligibility checks, in accordance with Section 5 (Verification);

b. supporting App registration and, where applicable, Circle participation in accordance with the Circle Participation Terms & Conditions;

c. conducting ongoing monitoring, sanctions screening, and compliance checks;

d. meeting legal, regulatory, and reporting obligations; and

e. providing App functionality, customer support, and security.

f. recording and monitoring telephone calls, online communications, or in-App support interactions for Verification, compliance, quality assurance, and security purposes.

g. establishing, exercising, or defending legal claims, and cooperating with regulators, law enforcement, or courts in the context of investigations or proceedings; and

h. sending marketing or promotional communications strictly subject to the Member’s explicit prior consent, which may be withdrawn at any time without affecting other lawful processing.

9.3 Retention. Records containing personal data shall be retained for a minimum period of fifteen (15) years from the Termination of the Member relationship, or such longer period as may be required under AML/CFT laws, the Qatar Central Bank’s Data Handling and Protection Regulation, the QFC Data Protection Regulations, or any other applicable laws and regulations.

9.4 Third-Party Service Providers. Wafir may engage authorised third-party service providers (such as identity verification vendors, payment processors, cloud service providers, or compliance platforms) to process personal data solely for the purposes set out in this Section, subject always to confidentiality, security, and regulatory access requirements. The Member’s explicit consent shall be obtained before sharing personal data with third parties for purposes not required by law, regulation, or contract fulfilment.

9.5 Cross-Border Transfers. Personal data shall be processed and stored in Qatar. Transfer outside Qatar shall only occur where Wafir has obtained any required approvals from the QCB or the QFC Data Protection Office, and only where adequate safeguards are implemented in accordance with applicable data protection laws and regulations.

9.6 Breach Notification. In the event of a personal data breach that presents a risk to the Member’s rights or security, Wafir shall notify the Member and the competent authority, including the Qatar Central Bank (QCB), the QFC Data Protection Office, the National Cyber Security Agency, and the Ministry of Interior where applicable, in accordance with applicable laws and regulations.

9.7 Member Rights. Subject to applicable law, the Member has the right to:

a. request access to their personal data held by Wafir;

b. request correction of inaccurate or incomplete data;

c. request deletion of personal data, where permitted by applicable data protection laws and regulations, subject always to mandatory record-keeping obligations under AML/CFT and financial services regulations;

d. withdraw consent to processing, where processing is based on consent; and

e. lodge a complaint with the Qatar Financial Centre Data Protection Office, the Qatar Central Bank, or any other competent authority designated under applicable data protection laws and regulations, regarding Wafir’s processing of personal data.

9.8 Privacy Policy. The Privacy Policy sets out in detail how Wafir collects, uses, retains, transfers, and protects personal data. The purposes listed above are subject to and further detailed in the Privacy Policy. The Privacy Policy is presented to the Member at the time of registration and must be accepted separately, in addition to this Agreement. Acceptance of the Privacy Policy is a condition for opening and maintaining an Account on the App.

10.1 Authentication. Wafir implements strong authentication measures, including multi-factor authentication, one-time passwords, and device verification, in compliance with the QCB’s Information and Cyber Security Regulation. The Member is required to comply with all authentication measures as a condition of accessing the App.

10.2 Device and Connection Security. The Member remains responsible for maintaining the security of their mobile device, operating system, and internet connection. Wafir shall not be liable for failures, losses, or delays caused by the Member’s equipment or connectivity. The Member shall not share their credentials, PINs, or authentication methods with any third party under any circumstances.

10.3 Technology Infrastructure. Wafir shall ensure that its technology infrastructure, including servers, applications, and APIs, is maintained in accordance with the QCB’s Technology Risk Instructions and Cloud Computing Regulation. Security controls shall include encryption, logging, monitoring, and periodic penetration testing.

10.4 System Upgrades. Wafir may enhance, upgrade, or modify its technology infrastructure, provided such modifications remain consistent with QCB approvals and applicable regulatory standards. Members will be notified of any material changes that impact access, security, or the operation of the App.

10.5 Incident Response. In the event of a material cyber security incident, Wafir shall follow its regulator-approved incident response procedures, notify the QCB and other competent authorities where required, and take all reasonable steps to mitigate impact and restore services. The Member may report suspected fraud, unauthorised access, or other security concerns through the Wafir Customer Trust Center, which shall serve as the primary channel for Member incident reporting. Wafir shall notify the Qatar Central Bank and other competent authorities of material cyber security incidents in accordance with applicable laws, regulations, and regulatory timeframes, and shall inform Members where their rights or data are materially impacted.

10.6 Member Security Awareness. Wafir shall provide Members with security awareness information, including guidance on safe use of the App, fraud prevention, and protection against phishing, malware, or social engineering threats, in accordance with QCB requirements.

10.7 Data Backup & Recovery. Wafir shall maintain secure data backup, disaster recovery, and business continuity arrangements to ensure availability and resilience of the App in accordance with QCB requirements and international best practices.

10.8 Access Controls. Wafir shall implement strict access and privilege management controls to ensure that only authorised personnel may access systems and data necessary for the provision of the App, in accordance with the principle of least privilege.

10.9 Third-Party Technology Providers. Where Wafir engages third-party technology providers, including cloud or infrastructure services, such engagements shall comply with QCB outsourcing and cloud regulations. Wafir shall remain fully responsible for ensuring that such providers meet equivalent security and regulatory standards.

11.1 Ownership. All Intellectual Property in the App, including its design, software, source code, databases, trademarks, trade names, branding, graphics, and related materials, together with any derivatives, enhancements, modifications, or improvements thereto, is and shall remain the exclusive property of Ajyal Fintech Solutions L.L.C. (trading as Wafir) or its licensors. No ownership rights are transferred to the Member under this Agreement. The Member acknowledges that any feedback, suggestions, or improvements provided to Wafir in relation to the App shall be deemed a non-exclusive, royalty-free, perpetual and irrevocable licence to Wafir, and all rights in such feedback shall vest exclusively in Wafir without obligation of compensation.

11.2 Member Licence. Subject to the Member’s compliance with this Agreement, Wafir grants the Member a limited, non-exclusive, non-transferable, and revocable licence to download and use the App for personal use only, strictly in accordance with this Agreement. This licence does not include any right to commercially exploit, publicly perform, or make derivative works of the App. This licence does not grant any ownership interest in the App or any Intellectual Property, and does not include any right to commercially exploit, sublicense, publicly perform, distribute, or make derivative works of the App.

11.3 Restrictions. The Member shall not:

a. copy, modify, distribute, or create derivative works of the App;

b. reverse-engineer, decompile, disassemble, or otherwise attempt to derive the source code of the App;

c. use Wafir’s trademarks, trade names, or branding in any manner without Wafir’s prior written consent.

d. remove, obscure, or alter any copyright, trademark, or proprietary rights notices contained in the App; or

e. use any automated tools, bots, or scripts to access, monitor, or interfere with the App.

f. use the App in any manner that could damage, disable, overburden, or impair Wafir’s systems or networks.

g. use the App in violation of applicable laws, regulations, or regulatory instructions issued by the Qatar Central Bank, the National Cyber Security Agency, or any other competent authority.

11.4 Member Content. To the extent the App permits Members to upload, submit, or transmit content (such as communications with Wafir or support queries), the Member warrants that such content shall be lawful, accurate, and non-infringing. The Member grants Wafir a limited, non-exclusive, royalty-free licence to store, use, and process such content solely for the purpose of providing App, Verification, and related support functions under this Agreement. The Member acknowledges that Wafir is under no obligation to monitor or pre-screen content, but reserves the right to review, remove, or restrict any content at its discretion for compliance, security, or legal reasons. Wafir shall process any Member Content that includes personal data in accordance with Section 9 (Data Protection & Privacy).

11.5 Third-Party Rights. The Member shall not upload or submit any content that infringes the intellectual property or proprietary rights of any third party. Wafir may remove or restrict any content that it reasonably believes violates this Section. The Member shall indemnify Wafir against any claims, damages, or liabilities arising from Member Content that infringes third-party rights.

11.6 Reservation of Rights. All rights not expressly granted to the Member under this Agreement are reserved by Wafir. Any unauthorised use of Wafir’s intellectual property or breach of this Section shall constitute a violation of this Agreement and may give rise to remedies available under Section 21 (Disclaimers & Liability), including injunctive relief, damages, and recovery of costs. Wafir further reserves the right to suspend or terminate access in accordance with Section 16 (Suspension & Termination).

12.1 No Deposit-Taking. The Member acknowledges that Wafir is not a bank, payment institution, or deposit-taking entity. Use of the App for registration, Verification, or account access does not constitute the opening of a bank account, savings product, or investment. All risks relating to Circle participation shall be addressed separately in the Wafir Client Charter and the Circle Participation Terms & Conditions, which govern participation, contributions, payouts, and related matters.

12.2 App Usage Risks. The Member acknowledges that use of the App during registration and Verification may involve operational risks, including temporary unavailability of the App, delays in processing verification requests, or interruptions caused by technical issues, service provider downtime, or regulatory reviews. Wafir shall take all reasonable steps to maintain secure and continuous access but does not guarantee uninterrupted operation of the App. For clarity, no financial loss can occur at this stage, as no Member funds are collected until Circle participation begins.

12.3 Circle Participation Risks. All risks relating to Circle participation shall be addressed separately in the Wafir Client Charter and the Circle Participation Terms & Conditions, which govern participation, contributions, payouts, and related matters.

13.1 Regulatory Access. The Member expressly consents to Wafir disclosing information, records, and documentation relating to the Member and their Account to the Qatar Central Bank (QCB), the Qatar Financial Information Unit (QFIU), the Qatar Credit Bureau, the Qatar Financial Centre Data Protection Office, the National Cyber Security Agency, the Ministry of Interior, and any other competent authority, as required under applicable laws, regulations, and regulatory instructions.

13.2 AML/CFT Obligations. The Member acknowledges and agrees that such disclosures may include personal data, financial information, and transaction records, where necessary for the purposes of:

a. complying with AML/CFT obligations under Law No. (20) of 2019 and the related instructions and guidelines issued by the QCB;

b. sanctions screening, fraud monitoring, and suspicious transaction reporting; and

c. fulfilling supervisory or regulatory reporting requirements.

13.3 Credit Bureau. The Member consents to Wafir directly retrieving, sharing, and disclosing information about the Member with the Qatar Credit Bureau, for the purposes Verification including but limited to, verifying salary, indebtedness, and credit history, and for ongoing monitoring of eligibility and Participation Caps.

13.4 Confidentiality. Disclosures under this Section shall be limited to what is reasonably necessary to comply with legal and regulatory obligations. Wafir shall at all times maintain appropriate safeguards to ensure that such disclosures are made securely and in accordance with applicable data protection laws and regulations.

14.1 Electronic Acceptance. The Member agrees that their acceptance of this Agreement and the Privacy Policy by electronic means (including click-through acceptance within the App) constitutes valid, binding, and enforceable consent, equivalent to a handwritten signature, in accordance with Law No. (16) of 2010 on the Promulgation of the Electronic Commerce and Transactions Law and applicable QCB regulations.

14.2 Electronic Records. The Member agrees that records generated and stored electronically by Wafir, including records of registration, Verification, App usage, compliance checks, communications, and consents, shall have the same legal validity, enforceability, and evidentiary value as paper-based records.

14.3 Communications. Notices, disclosures, and other communications under this Agreement may be delivered electronically, including through email, SMS, in-App notifications, or other electronic channels designated by Wafir. The Member agrees to receive such communications electronically.

14.4 Recorded Communications. Wafir may record telephone calls, in-App communications, or other customer interactions for purposes of compliance, monitoring, dispute resolution, and regulatory reporting. Such recordings shall be made in accordance with QCB Consumer Protection Instructions, QFC Data Protection Regulations, and applicable Qatari data protection and telecommunications laws. All records shall be retained in accordance with Section 9 (Data Protection & Privacy) and may be relied upon by Wafir as evidence of instructions or communications.

14.5 Access to Records. Wafir shall retain electronic records in accordance with applicable laws and regulatory requirements, as set out in Section 9 (Data Protection & Privacy). The Member may request access to copies of their electronic records by contacting Wafir through the Wafir Customer Trust Center, subject to reasonable identity verification and security procedures.

14.6 Enforceability. All electronic signatures, records, and communications under this Agreement shall be valid, binding, and enforceable in accordance with applicable laws and regulations.

15.1 Inactivity. Where a Member’s Account remains unverified or inactive for a continuous period of twelve (12) months, Wafir may classify the Account as dormant and suspend it in accordance with Section 16 (Suspension & Termination).

15.2 Permanent Closure of Dormant Accounts. Dormant Accounts shall remain suspended for a maximum period of six (6) months. If the Member does not re-activate their Account within this suspension period, the Account shall be permanently terminated and closed. Dormant Accounts that have been permanently closed cannot be re-activated. For clarity, closure of an inactive Account prior to Circle participation does not affect any Member funds, as no financial contributions are collected until the Member has accepted the Circle Participation Terms & Conditions. Where the Member has entered the Circle participation phase, any financial obligations shall be governed by the Circle Participation Terms & Conditions.

15.3 Retention of Data. Notwithstanding closure, Wafir shall retain all personal data, records, and transaction history associated with the Account for a minimum of fifteen (15) years, or such longer period as required under applicable laws and regulations.

16.1 Grounds for Suspension. Wafir may suspend a Member’s Account, either temporarily or indefinitely, where:

a. the Member is in breach of this Agreement and/or, once accepted, the Circle Participation Terms & Conditions;

b. verification, monitoring, or compliance obligations under Section 5 (Verification) require such action;

c. red flags, sanctions matches, or fraud concerns are identified;

d. the Account has been classified as dormant under Section 15 (Dormant / Inactive Accounts); or

e. Wafir is instructed to do so by the QCB, the QFIU, or any other competent authority.

16.2 Grounds for Termination. Wafir may permanently terminate a Member’s Account where:

a. the Member repeatedly or materially breaches this Agreement and/or, once accepted, the Circle Participation Terms & Conditions;

b. the Member fails to remedy a breach or outstanding obligation within the period specified by Wafir following written notice;

c. the Account is permanently closed in accordance with Section 15 (Dormant / Inactive Accounts); or

d. Termination is required by order of the QCB, the QFIU, or other competent authority.

e. Termination may also occur in accordance with Section 19.4 (Force Majeure).

16.3 Member-Initiated Termination. The Member may terminate their Account at any time. Prior to Circle participation, such Termination shall take effect immediately and only affect access to the App. Where the Member has entered the Circle participation phase, Termination shall be subject to the Circle Participation Terms & Conditions, including settlement of any outstanding contributions, payouts, fees, penalties, or other obligations.

16.4 Effect of Suspension. Suspension of an Account shall not relieve the Member of any obligations that arose prior to suspension. For the avoidance of doubt:

a. the Member remains liable for all outstanding contributions, fees, charges, and any damages arising from their use of the App;

b. Wafir retains the right to investigate, enforce, and pursue legal action in respect of any breach occurring prior to or during suspension.

c. the Member shall remain bound by all ongoing obligations under this Agreement, including but not limited to Verification, e-KYC, CDD, AML/CFT compliance, cooperation, and lawful source of funds requirements.

16.5 Effect of Termination. Upon Termination of an Account:

a. the Member shall lose access to the App;

b. Wafir shall retain the Member’s personal data and transaction records in accordance with applicable laws and regulatory requirements; and

c. Wafir’s rights and remedies in respect of any breach, fraud, or outstanding obligation (including contributions, fees, and charges) shall survive Termination.

16.6 Reactivation of Suspended Accounts. Accounts suspended under Section 16.1 may, at Wafir’s discretion, be re-activated subject to successful completion of re-Verification, compliance checks, and any conditions Wafir may impose at the time. Accounts that have been permanently closed under Section 15 (Dormant / Inactive Accounts) cannot be re-activated.

16.7 Notice of Suspension or Termination. Wafir shall provide the Member with notice of suspension or Termination, including the reasons for such action, except where prohibited by law (e.g., AML/CFT restrictions on tipping-off). Notice shall be delivered through the Member’s registered contact details.

16.8 Right of Recourse. If the Member believes that suspension or Termination was unjustified, they may contact Wafir through the Wafir Customer Trust Center for review. This does not affect the Member’s right to escalate complaints to the Ministry of Commerce and Industry’s Consumer Protection Department or to the QCB, as applicable under Law No. 8 of 2008.

17.1 Free and Accessible Complaints. Lodging a complaint shall be free of charge and may be done easily by contacting the Wafir Customer Trust Center through the channels made available in the App. Wafir shall acknowledge receipt of any complaint within two (2) Business Days.

17.2 Timelines and Resolution. Wafir shall investigate and provide a response to complaints within five (5) Business Days. Where additional time is reasonably required, Wafir shall notify the Member within this period, explain the reason for the delay, and inform the Member of their right to escalate the matter to the Qatar Central Bank.

17.3 Escalation Within Wafir. If the complaint is not resolved within the timeframes set out in Section 17.2, the Member may request escalation to Wafir’s designated senior officer responsible for complaints handling. Such officer shall have sufficient competence and authority to resolve complaints or direct access to a person who has such authority, and shall provide a written response within ten (10) Business Days of escalation.

17.4 Systemic Issues. Wafir shall monitor and review complaints to identify recurring or systemic failures, ensure root-cause analysis, and implement remedial measures to prevent recurrence.

17.5 Third-Party Referrals. Where Wafir has reasonable grounds to believe that a third party may be fully or partly responsible for the subject of a complaint, Wafir shall refer the matter to the relevant third party within three (3) Business Days and notify the Member in writing of such referral, including the third party’s contact details. Unless Wafir is satisfied that the third party is solely responsible, Wafir shall continue to process the complaint in accordance with this Section.

17.6 Final Response. Every final response to a complaint shall:

a. adequately address the substance of the complaint;

b. provide appropriate redress where the complaint is upheld; and

c. if the complaint is not upheld, provide clear reasons for such a decision.

17.7 Regulatory Escalation. If the Member is not satisfied with Wafir’s final response, the Member may escalate the matter to the QCB’s Consumer Protection Department or any other competent authority designated under applicable law.

17.8 Client Charter and Complaints Guide. The complaint-handling process shall be operated consistently with the principles of transparency, fairness, and accountability set out in the Wafir Client Charter. A simple and easy-to-use guide to the complaints process shall also be made available to all Members and prominently displayed on the App.

17.9 Record Keeping. Wafir shall maintain complete records of all complaints, correspondence, and resolutions for a minimum period of fifteen (15) years from the date of receipt, in accordance with Section 9 (Data Protection & Privacy) and applicable AML/CFT and consumer protection laws.

17.10 Mediation and Alternative Dispute Resolution (ADR). Prior to initiating court proceedings, the parties may agree to resolve disputes through mediation or another recognised alternative dispute resolution process. Any such mediation or ADR shall be conducted in the State of Qatar, under a recognised framework such as the Qatar International Center for Conciliation and Arbitration (QICCA) or another competent authority approved under applicable Qatari laws. Mediation or ADR shall be completed within thirty (30) days of referral. If no resolution is reached, either party retains the right to pursue formal legal remedies. For the avoidance of doubt, nothing in this Section shall restrict Wafir’s right to seek urgent precautionary or enforcement measures before the competent Qatari courts or authorities at any time.

17.11 Governing Law and Jurisdiction. Disputes not resolved through the procedures in this Section shall be subject to Section 22 (Governing Law and Jurisdiction).

18.1 Right to Amend. Wafir may amend, modify, or supplement this Agreement, the Privacy Policy, or the Client Charter from time to time, provided that any such amendments are consistent with applicable laws, regulations, and regulatory directions, including those issued by the QCB.

18.2 Notice of Amendments. Members shall be notified of any amendments at least fifteen (15) calendar days prior to their effective date, through the App and their registered contact details, unless an earlier effective date is required by law or by direction of the QCB. Wafir shall clearly indicate whether an amendment is material or administrative in nature, and may, at its discretion, provide a longer notice period where appropriate.

18.3 Member Rights. If the Member does not agree to any material amendment, the Member may close their Account in accordance with Section 16 (Termination), provided that all outstanding obligations are first discharged. For clarity, where the Member has joined a Circle, all obligations relating to Circle participation remain governed exclusively by the Circle Participation Terms & Conditions. For the avoidance of doubt, immaterial or administrative amendments (such as updates for accuracy, formatting, or regulatory cross-references) shall become effective without requiring express Member consent.

Neither Wafir nor the Member shall be liable for any delay or failure to perform their obligations under this Agreement to the extent such delay or failure is caused by a Force Majeure Event.

19.1 The affected party shall notify the other as soon as reasonably practicable of the occurrence and expected impact.

19.2 Obligations shall be suspended for the duration of the Force Majeure Event, except that payment obligations of Members under any Circle Participation Terms & Conditions shall resume once the Force Majeure Event has ceased. Nothing in this Section relieves Wafir of its obligations to comply with mandatory requirements imposed by the QCB, the QFIU, or any other competent authority, including reporting, disclosure, or record-keeping obligations.

19.3 If the Force Majeure Event continues for more than sixty (60) calendar days, either party may terminate this Agreement by written notice, without prejudice to accrued rights and obligations.

20.1 Third-Party Dependencies. The Member acknowledges that certain aspects of the App, including but not limited to payment processing, banking integrations, cloud hosting, identity verification, sanctions screening, and communication services, depend on third-party providers that are not controlled by Wafir.

20.2 Delays and Interruptions. Delays, interruptions, or failures caused solely by third-party providers shall not constitute a Force Majeure Event under Section 19, but Wafir shall not be liable for such failures provided it has exercised due care in selecting, monitoring, and engaging such providers.

20.3 Wafir’s Responsibilities. Notwithstanding Section 20.2:

a. Wafir remains fully responsible for compliance with all applicable AML/CFT, e-KYC, and CDD obligations under Qatari law and regulations, including where third-party providers are engaged.

b. Wafir shall ensure that all third-party providers are subject to confidentiality, data protection, security, and regulatory access requirements in accordance with Section 9 (Data Protection & Privacy).

c. Wafir shall take commercially reasonable steps to maintain continuity of services and mitigate the impact of any third-party failure.

20.4 No Waiver of Member Protections. Nothing in this Section shall limit the Member’s rights under applicable consumer protection laws, data protection regulations, or mandatory requirements imposed by the QCB, the QFIU, or other competent authorities.

21.1 “As Is” Provision. The App is provided on an “as is” and “as available” basis during the registration and Verification phase. Wafir makes no representation or warranty that the App will be uninterrupted, error-free, or free of vulnerabilities, except as required under applicable law and regulations.

21.2 Limitation of Liability. To the maximum extent permitted by law:

a. Wafir shall not be liable for any indirect, consequential, incidental, special, or punitive damages, including loss of profits, revenue, or data, arising out of or in connection with the Member’s use of the App.

b. Wafir’s liability for direct damages shall be limited to actual direct losses proven to have been caused by Wafir’s breach of this Agreement, subject always to the exclusions in this Section.

c. Nothing in this Section shall exclude or limit liability for fraud, gross negligence, wilful misconduct, or any liability that cannot lawfully be excluded under Qatari law or QCB regulations.

21.3 Member Liability. Wafir may claim damages, recover unpaid amounts, impose charges, and take legal action against the Member for any breach of this Agreement, including but not limited to, misrepresentation, fraudulent use of the App, or violations of AML/CFT obligations.

21.4 Third-Party Systems. Wafir shall not be liable for delays, interruptions, or failures attributable to third-party systems (including telecommunications, banking, cloud, or payment gateway providers), provided that Wafir has taken commercially reasonable steps to ensure continuity of service and compliance with applicable laws and regulations.

21.5 ROSCA Participation. Liability relating to Circle participation, escrow funds, contributions, payouts, or any other financial obligations shall be governed exclusively by the Circle Participation Terms & Conditions.

22.1 Governing Law. This Agreement shall be governed by and construed in accordance with the laws of the State of Qatar, together with all applicable regulations, instructions, and directives issued by the QCB and other competent Qatari authorities.

22.2 Jurisdiction. The courts of the State of Qatar shall have exclusive jurisdiction to hear and resolve any dispute, controversy, or claim arising out of or in connection with this Agreement, without prejudice to any mandatory regulatory or supervisory escalation processes provided under Qatari law or by the QCB.

22.3 Consumer Rights. Nothing in this Agreement shall limit or prejudice the Member’s rights under applicable Qatari consumer protection laws and regulations.

23.1 Legal Identity. The App is operated by Ajyal Fintech Solutions LLC, a company registered in the Qatar Financial Centre under Commercial Registration No. 02719 (“Wafir”).

23.2 Regulatory Oversight. Wafir has been admitted to the Qatar Central Bank Regulatory Sandbox for the testing of community-based lending circles (ROSCA). Wafir remains subject to the supervisory oversight of the Qatar Central Bank (QCB) and the Qatar Financial Information Unit (QFIU), together with any other competent Qatari authority. A full QCB licence will be obtained upon successful exit from the Sandbox.

23.3 Wafir’s model has been reviewed and certified for compliance with Shari’ah principles by the Prof. Dr. Ali M. Al.Quradaghi (the “Shariah Authority”). The certificate remains available for Member review upon request.

23.4 Contact Information. Members may contact Wafir through any of the following channels:

a. Registered Address: Office No. 1, Floor No. 9, Tech Circle, QFC Tower 1, P.O. Box 35192 Doha-Qatar

b. Email: info@wafir.app

c. Telephone: +974 4450 2181, +974 7700 0107

d. In-App: via the Wafir Customer Trust Center, including the in-App chat and WhatsApp support function.

23.5 Member Rights. Members may also escalate unresolved complaints to the QCB – Consumer Protection Department or any other competent authority as specified under Section 17 (Complaints & Dispute Resolution).

23.6 Data Protection Oversight. For data protection oversight, see Section 9 (Data Protection & Privacy).