1. Purpose of this Policy
This Refund & Escrow Release Policy outlines how CoPay manages buyer and seller funds during transactions, including how payments are held, released, or refunded.
CoPay’s goal is to ensure transparency, fairness, and trust between buyers and sellers in every transaction. All processes under this policy comply with the Central Bank of Kenya (CBK) Guidelines for Payment Service Providers and the Kenya Data Protection Act, 2019.
2. Overview of CoPay Escrow
CoPay is a digital escrow payment platform that secures funds between buyers and sellers until both parties confirm that a transaction has been completed successfully.
The buyer’s funds are safely held in escrow by CoPay through Cellulant (Tingg), our licensed financial partners, until the product or service is delivered.
The seller’s goods remain safe with their own trusted delivery personnel until the buyer confirms satisfaction.
3. When Funds Are Held in Escrow
The buyer reserves the right to refunds. Funds enter escrow immediately after the buyer completes payment through CoPay’s STK prompt.
Both the buyer and seller receive SMS confirmations showing:
- Amount held in escrow
- Transaction reference number
- Time the payment was secured
- An OTP with a link to release payment or request a refund
CoPay does not release or transfer funds without explicit buyer authorization through the platform.
4. Escrow Release Conditions
Buyers and sellers are solely responsible for initiating their own release, withdrawal, or refund requests through official CoPay channels. CoPay does not manually process withdrawals or refunds without explicit in-platform authorization.
Funds are released only when the buyer releases them via USSD or the CoPay link received by SMS. The seller receives instant notification, and funds reflect immediately in their CoPay wallet. Sellers can then withdraw funds to M-Pesa, Airtel Money, or bank accounts anytime thereafter.
5. Refund Conditions
Funds are held in escrow for 3 hours, after which the buyer may activate a refund.
Refunds may be initiated if:
- The product is damaged, incorrect, or not as described.
- The buyer is unsure and requests a refund before confirming delivery.
When a refund is initiated:
- The buyer triggers a refund through CoPay.
- CoPay notifies the seller via SMS.
- Upon verification, funds are refunded instantly to the buyer’s payment method.
- Both parties receive SMS confirmations.
6. Buyer Non-Confirmation
- Funds remain safely in escrow under CoPay’s custody.
- CoPay does not auto-release funds.
- Delivery personnel must ensure on-site delivery confirmation.
- If the buyer is unreachable or undecided, they may refund themselves after 3 hours.
This ensures fairness and mutual protection — buyers control fund release, while sellers retain goods until payment confirmation.
7. Dispute Resolution
In case of a disagreement:
- Both parties may submit proof (delivery confirmations, screenshots, receipts).
- CoPay reviews evidence objectively.
- A final, binding decision is made based on verified records.
8. Refund Timelines
- Mobile Money (M-Pesa, Airtel Money): Instant
- Bank Transfers: Within 24 business hours (depending on the bank)
Refund processing begins immediately upon verification of refund eligibility.
9. Escrow Service Fees
CoPay charges a flat service fee per payout or refund (e.g., KES 45 for mobile withdrawals, KES 80 for bank payouts).
This covers payment processing, escrow protection, SMS confirmations, and operational security.
Example:
If a seller withdraws multiple accumulated sales at once, the KES 45 fee applies only to that withdrawal — not per sale.
10. Responsibility of Parties
Buyers:
- Use only official CoPay channels for payments.
- Confirm or refund after verifying product satisfaction.
- Keep transaction confirmation SMS secure.
- Do not share OTP or link with anyone.
Sellers:
- Use trusted riders for safe delivery.
- Ensure fund release before leaving the buyer’s location.
- Keep delivery evidence for dispute reference.
11A. Prohibited Transactions and Restricted Activities
CoPay prohibits transactions involving illegal or restricted goods/services, including but not limited to:
- Weapons, explosives, or defense items
- Drugs, narcotics, or unlicensed substances
- Counterfeit currency or stolen goods
- Pornographic or violent content
- Hate speech, terrorism financing, or illegal gambling
- Unlicensed trade in alcohol, tobacco, or pharmaceuticals
- Wildlife products regulated under CITES
- Hazardous or prohibited materials
- Unauthorized investment schemes or pyramid programs
- Adult entertainment or escort services
- Unlicensed e-pharma or online medical services
- Virtual-currency trading without CBK or Cellulant (Tingg) approval
- Political campaigning or unlicensed jewelry trade
Violations may lead to suspension, freezing, or termination of accounts and reporting to the CBK or FRC.
11B. Fraud and Misuse Prevention
CoPay actively monitors transactions to detect fraud or misuse. We may:
- Temporarily hold or suspend funds if fraud is suspected.
- Request additional verification.
- Report confirmed fraud to relevant authorities.
12. Liability
CoPay acts solely as an escrow intermediary. CoPay is not responsible for lost, damaged, counterfeit, or misrepresented goods or services. Shipment, delivery, and inspection are the sole responsibility of buyers and sellers.
13. Policy Updates
CoPay may update this Refund & Escrow Release Policy to reflect legal or operational changes. Updates will be communicated via SMS, email, or website notice. Continued use implies acceptance.
