Chapsmart
Chapsmart

Terms and Conditions

Effective Date: 15 April 2026 · Last Updated: 15 April 2026

1.About Chapsmart

These Terms and Conditions (“Terms”) form a binding agreement between Chapsmart Payments (hereinafter “Chapsmart”, “we”, “us” or “our”) and any person who registers for or uses our Services (“User” or “you”).

Chapsmart is a business duly registered with the Business Registrations and Licensing Agency (BRELA) under Registration Number 638852, and operates exclusively within the United Republic of Tanzania. We operate a regulated-ecosystem bridge that converts Bitcoin (received via the Bitcoin Lightning Network) into Tanzanian Shillings (TZS) and delivers the proceeds to recipients in Tanzania through licensed mobile money channels, and vice versa. All of our domestic transactions are settled exclusively in Tanzanian Shillings (TZS), which is the sole legal tender of the United Republic of Tanzania under Section 26 of the Bank of Tanzania Act, 2006 (as amended by the Finance Act, 2024).

Location: Kilimanjaro, Moshi, United Republic of Tanzania.
Contact: support@chapsmart.com · www.chapsmart.com

2.Scope of Services

Chapsmart provides three core services within the territory of the United Republic of Tanzania. All disbursements to recipients in Tanzania are made exclusively in Tanzanian Shillings (TZS) through licensed mobile money channels.

ServiceDirection
RemittanceBitcoin → M-Pesa (TZS)
AirtimeBitcoin → Airtime
Buy SatsM-Pesa (TZS) → Bitcoin

Transaction amount limits apply to each Service and are displayed in the Platform at the time of transaction. Chapsmart may adjust these limits from time to time at its discretion, based on operational, risk, or regulatory considerations. The limits in effect at the point of transaction shall apply.

Chapsmart acts as a bridge between the Bitcoin Lightning Network and Tanzania’s licensed financial infrastructure. We do not hold, store, or take custody of user funds beyond the short time strictly necessary to complete each transaction. We are not a wallet, savings service, deposit-taking institution, or lender.

3.Authorized Business Activities

Chapsmart is authorized to operate under the following International Standard Industrial Classification (ISIC) codes, as recorded in our BRELA Extract from Register (Form 21, Registration No. 638852):

Chapsmart also holds a valid municipal business license authorizing “Huduma ya Miamala ya Simu na Huduma Ndogo za Kibenki” (Mobile Transaction Services and Small Banking Services), which is renewed annually in accordance with the Business Licensing Act, 1972 (Act No. 25).

4.Legal Framework Governing Chapsmart’s Operations

This section sets out the specific Tanzanian legal framework under which Chapsmart operates, and the basis on which our Services are lawful and compliant. We believe in transparency: our users deserve to know exactly where we stand under Tanzanian law.

4.1 Tanzanian Shilling as Sole Legal Tender

The Tanzanian Shilling (TZS) is the sole legal tender of the United Republic of Tanzania. This is established under:

How Chapsmart complies: Every domestic disbursement made by Chapsmart to a Tanzanian recipient is in Tanzanian Shillings (TZS). Chapsmart does not price, invoice, disburse, or settle any domestic transaction in Bitcoin, US Dollars, or any other non-TZS currency. Our service model converts Bitcoin received from senders into TZS before any payment is made inside Tanzania, thereby supporting the circulation and use of TZS in the domestic economy.

4.2 Bank of Tanzania Public Notice on Cryptocurrency (12 November 2019)

On 12 November 2019, the Bank of Tanzania (BoT) issued a Public Notice cautioning members of the public against trading, marketing, or using virtual currencies on the basis that such activities were contrary to the then-existing foreign exchange regulations, and reiterating that the Tanzanian Shilling is the sole legal tender of Tanzania. The BoT re-affirmed this position in subsequent communications.

How Chapsmart addresses this notice: Chapsmart does not treat Bitcoin as legal tender in Tanzania, does not market Bitcoin as a means of payment for domestic transactions, and does not disburse Bitcoin to recipients inside Tanzania as payment for goods or services. Chapsmart uses Bitcoin only as an input at the sender side of a transaction originating outside Tanzania (for Remittance and Airtime) or as an output delivered to a user’s external Lightning wallet (for Buy Sats). Our model reinforces TZS as the sole domestic medium of exchange, rather than substituting for it.

4.3 Finance Act, 2024 — Statutory Recognition of Digital Assets for Tax Purposes

The Finance Act, 2024 (effective 1 July 2024) introduced the first formal statutory recognition of digital assets in Tanzanian law, specifically by amending the Income Tax Act (Cap. 332) as follows:

How Chapsmart complies: Chapsmart is registered with the Tanzania Revenue Authority for tax purposes. We apply the 3% withholding tax to every qualifying digital asset transaction, collect it at the point of transaction, and remit it to the TRA as required by law. The withholding tax is disclosed transparently in our Fees section below.

4.4 Yellow Card Tanzania Ltd v. Nyamwero Michael Nyamwero (2024) — Judicial Precedent

Case: Yellow Card Tanzania Ltd v. Nyamwero Michael Nyamwero, Commercial Case No. 12171 of 2024, High Court of Tanzania (Commercial Division), decided on 13 December 2024.

In this landmark decision, the High Court of Tanzania (Commercial Division) established three key principles concerning cryptocurrency in Tanzania:

  1. The validity of a contract is independent of whether its subject matter is regulated. The mere absence of a bespoke regulatory framework does not render a contract involving cryptocurrency invalid.
  2. Cryptocurrency transactions are not inherently illegal in Tanzania. Service providers and users engaged in cryptocurrency transactions are required to comply with existing taxation and financial laws; where they do so, their transactions cannot be declared unlawful.
  3. Virtual currency transactions become unlawful only if linked to money laundering, terrorism financing, or other illicit activities.

How this supports Chapsmart: Chapsmart’s operations are fully aligned with the principles established in the Yellow Card precedent. We are registered with BRELA, licensed by Moshi Municipal Council, and registered with the TRA for tax purposes. We comply with the 3% withholding tax introduced by the Finance Act, 2024, and we maintain active anti-money laundering and counter-terrorism-financing procedures. Our contracts with Users, and the transactions we process, are therefore valid and enforceable under Tanzanian law as interpreted by the High Court in the Yellow Card Precedent.

4.5 Executive Policy Direction

In June 2021, Her Excellency President Samia Suluhu Hassan publicly urged the Bank of Tanzania to “be prepared” for the advent of cryptocurrencies and blockchain technology, in line with global trends, to ensure Tanzania is not caught unprepared by global financial innovation. This executive direction has informed subsequent policy developments including the Finance Act, 2024, and the Bank of Tanzania’s ongoing research into Central Bank Digital Currency (CBDC). Chapsmart operates in a manner consistent with this forward-looking policy direction, while strictly respecting the legal status of TZS as sole legal tender.

4.6 Summary Table of Applicable Laws

5.Operating Model — Working with Licensed Payment Partners

Chapsmart processes all M-Pesa disbursements and Tanzanian payment flows through licensed third-party payment partners that hold the relevant authorizations from the Bank of Tanzania under the National Payment Systems Act, 2015, and the Payment Systems (Licensing and Approval) Regulations, 2015. These partners include, but are not limited to, licensed Payment System Providers (PSPs), Mobile Network Operators (MNOs), and telecom service platforms.

By operating through these licensed channels, every transaction processed by Chapsmart flows through a fully regulated segment of Tanzania’s national payment system. This structure ensures that customer funds are handled through supervised, audited, and compliant infrastructure at every stage, consistent with Section 15 of the National Payment Systems Act, 2015, and the BoT’s additional requirements set out in its notice LB.178/179/01/8 of 15 October 2019.

6.Definitions

7.User Account

To use the Services, you must create a User Account on the Platform. Upon registration, you will be assigned a unique 16-digit Account Number, which serves both as your identifier and your login credential. No government-issued identification documents are required for basic account registration, although Chapsmart may request additional verification information for compliance purposes where reasonably required (see Section 12).

You must treat your Account Number as confidential and must not disclose it to any third party. Any activity through your User Account is deemed to be conducted by you or on your behalf, and you are solely responsible for such activity.

If you suspect your Account Number has been compromised, you must contact Chapsmart immediately at support@chapsmart.com.

8.Eligibility

By registering for a Chapsmart User Account, you represent and warrant that:

9.Nature of Service: Bridge, Not Custodian

Chapsmart operates strictly as a bridge between Bitcoin (via the Lightning Network) and Tanzania’s licensed financial ecosystem. When you use the Services:

No Custody of User Funds: Chapsmart does not hold, store, or take custody of your Bitcoin or TZS beyond the time strictly necessary to complete the conversion and disbursement. We are not a wallet, savings service, lending institution, or deposit-taking entity. Once a transaction is completed, Chapsmart does not retain any user funds.

10.Exchange Rate and Transaction Confirmation

Chapsmart quotes an exchange rate at the time you initiate each transaction. The quoted rate is derived from prevailing market rates, adjusted for our applicable service fee and the statutory 3% withholding tax (where applicable). Exchange rates may change between transactions and are displayed clearly before you confirm any transaction.

Once you confirm a transaction, the rate and fees shown at the point of confirmation apply to that transaction, regardless of subsequent market movements. Chapsmart is not liable for adverse exchange rate movements occurring outside the confirmation window.

11.Fees and Taxes

Chapsmart charges a service fee on each transaction, calculated as a percentage of the TZS transaction amount. We operate a three-tier loyalty system that rewards users with lower fees as they increase their cumulative transaction volume on the Platform. In addition to the service fee, a 3% statutory withholding tax is applied to all qualifying transactions, as required by Section 83C of the Income Tax Act (Cap. 332), introduced by the Finance Act, 2024.

TierCumulative SpendService FeeGov. TaxTotal
BRONZE0 – 5,000,000 TZS2.20%3%5.20%
SILVER5,000,001 – 25,000,000 TZS1.87%3%4.87%
GOLD25,000,001+ TZS1.32%3%4.32%

* The 3% government tax is the withholding tax on digital asset transactions under Section 83C of the Income Tax Act (Cap. 332), applied uniformly to all tiers. Buy Sats transactions do not receive tier discounts.

Tax remittance: Chapsmart is registered with the Tanzania Revenue Authority and remits the 3% withholding tax collected on qualifying transactions in accordance with its statutory obligations as a digital asset exchange platform under the Income Tax Act (Cap. 332).

Other taxes: Chapsmart also complies with applicable Value Added Tax (VAT) obligations, corporate/individual income tax, municipal levies, annual business license renewal fees, and all other statutory tax and levy requirements under Tanzanian law.

User’s tax obligations: Users located outside Tanzania are solely responsible for determining, reporting, and fulfilling any tax obligations that may apply under the laws of their own jurisdiction. Chapsmart does not provide tax advice, and the 3% withholding tax applied by Chapsmart does not satisfy any tax obligation you may have in another jurisdiction.

Your loyalty tier is determined automatically based on your cumulative transaction volume across the Platform. Chapsmart reserves the right to modify the fee structure and tier thresholds at any time, with reasonable notice provided to users.

12.Anti-Money Laundering, Counter-Terrorism Financing & Compliance

Chapsmart is committed to preventing money laundering, terrorism financing, and other financial crimes. In line with the Anti-Money Laundering Act, 2006 (Cap. 423 R.E. 2022) and its implementing regulations, Chapsmart maintains internal procedures for:

Users agree not to use Chapsmart’s Services for any unlawful purpose, including but not limited to money laundering, terrorism financing, sanctions evasion, fraud, tax evasion, human trafficking, drug trafficking, or any other activity prohibited under Tanzanian law or any other applicable law.

Chapsmart may, at its sole discretion and without prior notice, suspend, freeze, or terminate a User Account where there are reasonable grounds to suspect that the account is being used in breach of these Terms or of applicable law.

13.Data Protection and Privacy

Chapsmart collects only the minimum personal information necessary to provide the Services and to comply with legal obligations. We process personal data in accordance with the Personal Data Protection Act, 2022, and its implementing regulations.

Where disclosure is required by law or by a duly authorized Tanzanian authority (such as the FIU, TRA, or BoT), Chapsmart may be required to share user transaction data. Otherwise, we do not sell or share user data with third parties. For full details of how we collect, store, use, and protect your data, please refer to our separate Privacy Policy.

14.Risks Associated with Digital Assets

Before using Chapsmart’s Services, you should carefully consider the following risks:

The above list is not exhaustive. By creating a User Account, you acknowledge that you have assessed your financial standing and risk tolerance and confirm they are suitable for your use of Chapsmart’s Services.

15.Prohibited Activities

You may not use Chapsmart’s Services to:

Breach of this Section 15 may result in immediate suspension or termination of your User Account, forfeiture of pending transactions, and reporting to law enforcement and regulatory authorities.

16.Liability

Users are responsible for their actions in connection with the use of the Platform, the Services, and their Accounts, and for protecting their Account Number and other access credentials.

Chapsmart shall not be liable for any transaction failure or loss caused by fault on the part of the User, including the User providing incorrect phone numbers, wrong Lightning invoices, wrong account details, or false information. If a User deliberately provides false information, impersonates another person, or attempts to breach these Terms, the User shall be liable to indemnify Chapsmart, and Chapsmart may take all necessary legal action, including criminal action.

Except where liability cannot be lawfully excluded, in no event shall Chapsmart or its operators, agents, employees, or suppliers be liable for lost profits, lost data, business interruption, or any special, incidental, or consequential damages arising out of or in connection with the use of the Platform, the Services, or these Terms. Chapsmart’s aggregate liability in respect of any claim arising from a User’s use of the Platform shall, in no circumstances, exceed the value of the specific transaction giving rise to the claim, less any applicable fees.

Chapsmart has no control over, and accepts no liability for, the delivery, quality, safety, legality, or any other aspect of goods or services that you may pay for through third parties using the Services.

17.System Availability, Security, and Maintenance

Chapsmart places a high priority on system security and implements industry-standard measures (including TLS encryption, rate limiting, reverse-proxy hardening, and application-layer access controls) to safeguard the Platform and its infrastructure. However, we do not guarantee that the Platform will always be available or uninterrupted. We may suspend, withdraw, discontinue, or change all or any part of the Platform — with or without notice — for reasons including scheduled maintenance, security incidents, regulatory requirements, or events of force majeure.

Chapsmart will not be liable for losses arising from Platform unavailability, including losses due to exchange-rate movements during periods of downtime. Users are encouraged to transact during published operating hours and to contact support promptly in the event of any disruption.

18.Communication

When you visit the Platform or send emails to us, you are communicating with us electronically, and you consent to receive communications from us electronically. We will communicate with you by email or by posting notices on the Platform. All electronic communications satisfy any legal requirement that such communications be in writing.

If your contact details change, you are solely responsible for updating them on the Platform. Communications sent to your registered email address or phone number shall be deemed received by you.

19.Dispute Resolution

Chapsmart and the User agree that any dispute arising between them shall initially be resolved through mutual negotiations conducted in good faith. To initiate this process, the User shall contact Chapsmart by email at support@chapsmart.com, clearly describing the nature of the dispute and any relevant transaction details.

Chapsmart will respond using the email address registered on the User’s account or another channel the User has provided. Both parties commit to making reasonable efforts to resolve disputes amicably before resorting to formal proceedings. If mutual negotiation fails within thirty (30) days from the date the dispute is notified, either party may refer the matter to the courts of Tanzania in accordance with Section 20 below.

20.Governing Law and Jurisdiction

These Terms, and any dispute arising out of or in connection with them, shall be governed by and construed in accordance with the laws of the United Republic of Tanzania. The parties submit to the exclusive jurisdiction of the courts of the United Republic of Tanzania.

21.Intellectual Property

All copyright and other intellectual property rights in the content and materials provided through the Platform — including the Chapsmart name, logo, designs, text, graphics, software, and the arrangement thereof (collectively “Chapsmart Materials”) — are the proprietary property of Chapsmart or its licensors. You may not copy, modify, distribute, or use Chapsmart Materials without prior written consent from Chapsmart.

22.Amendments

Chapsmart may revise these Terms at any time by updating this page. Users are encouraged to check this page regularly, as changes become binding upon publication. For material changes, Chapsmart will make reasonable efforts to notify users through the Platform or registered email address.

Chapsmart may also change the Services, add or remove features, or establish usage limits without prior notice, provided such changes do not adversely affect transactions already in progress.

23.Customer Support

Chapsmart is committed to providing responsive customer support.

24.Assignment

You acknowledge and agree that Chapsmart may freely assign these Terms or any of its rights under these Terms to any successor entity, affiliate, or acquirer of its business without your consent. You, however, may not assign these Terms or any rights under them to another person without the prior written approval of Chapsmart.

25.Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a competent authority or court, the remaining provisions shall continue in full force and effect, and the invalid provision shall be interpreted or reformulated in a manner that gives effect to its intent as closely as possible while being lawful.

26.Entire Agreement

These Terms, together with Chapsmart’s Privacy Policy, constitute the entire agreement between you and Chapsmart concerning your use of the Services. They supersede any prior agreements, understandings, or communications, whether written or oral, between you and Chapsmart on the same subject matter.

By registering a User Account and using Chapsmart Services, you confirm that you have read, understood, and accepted these Terms and Conditions in full.

General Notice: These Terms are a statement of Chapsmart’s current operating framework and legal compliance posture. They do not constitute legal or financial advice to any User. Users are encouraged to seek independent legal or financial advice where appropriate. Legal citations are as of the Effective Date and may be subject to legislative or regulatory change.