Legal Notice

This Legal Notice informs you of who we are, our current regulatory status, the basis on which we provide information through this website, and the limitations that apply to our services.

If you read only one part of it, read section 2. It sets out what Koya is and is not authorised to do today, and that is the fact most likely to matter to you.

Koya Labs Ltd ("Koya", "we", "us", "our") is a private company limited by shares, incorporated under the laws of the Republic of Kenya, Registration No. PVT-MA15BD72.

Our registered office is Prestige Building, Ngong Road, Highridge, Westlands, Nairobi, Kenya.

Koya operates the koyabank.com platform, which is being developed to provide conversion between Kenyan Shillings and Bitcoin, and related remittance services.

A note on our name

The name "koyabank.com" is a domain name. It is not a representation that Koya Labs Ltd is a bank, and Koya is not a bank. Section 2 sets out what we are and are not.

This section states our position plainly. It is the most important part of this Notice and it is not qualified anywhere else in it.

Koya is pursuing applicable licensing under Kenya's Virtual Asset Service Providers Act, 2025, which will, upon grant, be jointly administered by the Central Bank of Kenya and the Capital Markets Authority.

This section will be updated to reflect Koya's regulatory status, including licence numbers and regulator details, once applicable licensing is obtained and live services commence. Until that update appears here, assume the position in the table above is current.

Nothing on this website should be read as a statement that licensing has been granted, is imminent, or is certain to be granted.

What "pre-launch, sandbox and testnet" actually means

These are technical words and they matter, so here is what each one means in practice rather than in the abstract.

• Pre-launch. The service is not open to the public. Nobody can complete a live conversion on it today.
• Sandbox. The platform runs against test facilities provided by our payment and identity partners rather than their live systems, so no real payment instruction is issued.
• Testnet. Bitcoin operations run on a test network. Test network coins have no monetary value and cannot be exchanged for anything. A balance or transaction shown in a test environment is not money and is not an asset.

Taken together: any amount, balance, rate or transaction you see on the platform today is illustrative. It is not a holding, not a claim against Koya, and not redeemable.

Information you give us before launch

If you provide information to Koya during the pre-launch period, for example by joining a waitlist or beginning identity verification, that information is handled under the Privacy Notice in the same way as any other personal data.

Providing it does not create an account entitlement, does not reserve anything for you, and does not oblige Koya to offer you the service when it launches.

Information on this website is provided for general informational purposes only and does not constitute a recommendation, an offer, or a solicitation to enter into any agreement or transaction with Koya.

Your access to and use of this website, and any request for information you make through it, is entirely on your own initiative and not the result of any direct solicitation by Koya.

No content on this website is investment, financial, legal, or tax advice. Any figure, rate, projection or illustration shown is indicative only and is not a quote, an offer, or a commitment to transact.

The products and services described on this website may change, be updated, or be withdrawn as Koya's platform develops and as regulatory approvals are obtained.

Any communication from Koya about new features or updates is provided for information only and should not be read as a solicitation or invitation to use those features ahead of their formal, licensed availability.

A feature being visible on this website, described in a roadmap, or demonstrated in an interface does not mean it is available to you, or that it is authorised for live use.

Information on this website is not directed at, and must not be relied upon by, any person in a jurisdiction where such information, or the services described, would be contrary to local law or regulation.

Koya's services are not currently available to residents of jurisdictions where those services would require licensing or registration that Koya does not yet hold. Given section 2, that presently includes every jurisdiction.

Persons outside Kenya should consult their own professional advisers or their local regulator before relying on any information on this website.

On specific jurisdictional exclusions

This Notice does not list named jurisdictional exclusions. Koya has not yet confirmed the scope of any such exclusion with counsel, and publishing a list we had assumed rather than verified would be worse than publishing none. The general restriction above applies in the meantime.

Questions about this Legal Notice can be directed to Koya Labs Ltd at the registered office below, or by email to legal@koyabank.com.

This Legal Notice is governed by the laws of the Republic of Kenya.

The courts of Kenya shall have exclusive jurisdiction over any dispute arising out of or in connection with this Legal Notice.

This Legal Notice is supplemented by the documents below. Together they are the complete set of public legal information Koya publishes, and each is linked from the footer of every page.

The Koya legal section

• Privacy Notice. What personal data we collect, why, who we share it with, how long we keep it, and the rights you hold over it under the Kenya Data Protection Act, 2019.
• Terms of Use. The terms governing your use of this website. They are not the customer agreement for conversion services, which is the separate document below.
• Customer Agreement. The contract between you and Koya for conversion and remittance services: eligibility, fees and rates, transaction processing, custody, and liability.
• Cookie Notice. What Koya stores on your device, an audited inventory of every entry, and how you control it.
• Risk Disclosure. The risks of converting into and holding digital assets, including price volatility.
• Responsible Disclosure Policy. How to report a security vulnerability in a Koya product or service, and the commitment we make to good faith researchers.

Where this Legal Notice and one of those documents address the same subject, the more specific document governs that subject. Nothing in this Notice is intended to narrow a right given to you by any of them, or by law.

Parts of this website describe what Koya intends to build, apply for, or offer. Those statements are about the future and are inherently uncertain.

A plan described on this website may change, be delayed, or be abandoned. A licence we are pursuing may not be granted, may be granted on conditions we did not anticipate, or may take materially longer than expected. A feature shown in an interface may never reach live service in that form.

Nothing on this website is a promise that any of it will happen, and no statement about the future should be relied on as if it were a statement of present fact. Statements of present fact in this Notice, in particular the regulatory position in section 2, are accurate as at the date shown at the top of the page and are not updated continuously.

The Koya name, the Koya logo, and the branding used across this website are the property of Koya Labs Ltd or its licensors.

Nothing on this website grants any licence to use them. Their use is governed by section 7 of the Terms of Use, which sets out what you may do without asking and what needs our written permission.

Third party names, marks and logos that appear on this website, including those of payment providers, identity verification providers and infrastructure providers, remain the property of their respective owners. Their appearance is descriptive and does not imply any endorsement of Koya by them.

If you are unhappy with something Koya has done, tell us first. Write to legal@koyabank.com setting out what happened and what you would like us to do about it, and we will look into it.

Where else you can go

You are not required to come to us first, and the routes below are open to you regardless of anything in this Notice.

• Data protection. If your complaint concerns personal data, you may complain to the Office of the Data Protection Commissioner at www.odpc.go.ke. The Privacy Notice sets out that right in full.
• Financial services. Koya is not currently licensed, so no financial services ombudsman or dispute scheme presently covers it. When licensing is obtained this section will be updated with the applicable route.
• The courts. Section 7 of this Notice sets out the governing law and jurisdiction.

We would rather hear a complaint than have you leave with it unresolved, and raising one will never affect how you are treated.