Country Addendum — Botswana

Effective date: 19 August 2026
Forms part of the Romela Pula Terms and Conditions for users in Botswana.

Contents

1. Status and who this covers
2. Contracting party and Payment Partners
3. Local marketing entity
4. Botswana collections, holding, and payouts
5. Your Romela Pula Balance in Botswana
6. Fees and set-off
7. Liability cap (Terms clause 15.4(b))
8. Complaints and regulators
9. Personal data
10. Changes

1. Status and who this covers

1.1 This Country Addendum (Addendum) is published under Terms clause 21. It applies if you use the Platform in Botswana, including where your registration number is a Botswana number, your Romela Pula Balance is denominated in Botswana Pula (BWP), or you fund or receive a payout through a Botswana bank or mobile-money channel.

1.2 Capitalised words have the meaning given in the Terms unless this Addendum says otherwise.

1.3 If this Addendum conflicts with the Terms, this Addendum prevails for Botswana collections, holding of funds, payouts, the figure in Terms clause 15.4(b), local complaints and regulatory referrals, and the Local Marketing Entity in Botswana. It does not change who you contract with under Terms clause 1.1.

2. Contracting party and Payment Partners

2.1 Your contract for the Platform remains solely with BrusselsMara Ltd (England and Wales, company number 15157581), as stated in Terms clauses 1.1, 2.1, and 4.3.

2.2 You are not a party to any master services agreement, API contract, or similar agreement BrusselsMara holds with a Payment Partner (Terms clause 2.3).

2.3 The Payment Partner that operates the Botswana collection account and payouts is not a party to the Terms or this Addendum. These documents do not create a contract between you and that Payment Partner, and they do not name it as your bank, e-money issuer, sponsor, or customer-facing principal (Terms clause 4.3).

2.4 For Botswana, our ability to provide the Platform depends on the Payment Partner acting as the licensed principal for collection, custody, and payout of funds, holding such funds in its own name and for its own regulatory account, and not as our agent or sub-contractor for regulatory purposes (Terms clause 3.6).

3. Local marketing entity

3.1 Terms clause 1.2 applies in Botswana. The Local Marketing Entity is RomelaPula (Pty) Ltd, incorporated in Botswana under CIPA number BW00009946653, a wholly-owned subsidiary of BrusselsMara Ltd.

3.2 Without limiting Terms clause 1.2, the Local Marketing Entity in Botswana:

• (a) is not a party to the Terms or this Addendum and has no contractual relationship with you for the Platform;
• (b) is not a party to, and has no rights or obligations under, any agreement with a Payment Partner;
• (c) does not at any time receive, hold, or control funds, your Balance, or any payment instruction;
• (d) does not make KYC/KYB decisions, conduct transaction monitoring, or perform sanctions screening; its personnel may assist in collecting documents on our behalf locally, but verification decisions remain with BrusselsMara Ltd or our Payment Partners;
• (e) where it collects documents from you, acts solely as our processor under our instructions, not as a controller (Terms clauses 6.2 and 13.1A).

4. Botswana collections, holding, and payouts

4.1 When you fund a Romela Pula Balance in Botswana by bank transfer or mobile money, you pay the amount and reference we show you into an account in Gaborone that is opened and held in the Payment Partner’s own name — not in BrusselsMara’s name and not in the Local Marketing Entity’s name. The bank, account name, and account number on your top-up instructions are those of that Payment Partner account. BrusselsMara has no signatory right, security interest, or operational control over that account (Terms clause 4.7).

4.2 No funds you pay in pass through, or come to rest in, any account BrusselsMara operates (Terms clause 7.2). A collection is complete only when we receive confirmation that the Payment Partner has accepted and cleared the funds (Terms clause 8.2).

4.3 After the Payment Partner accepts and clears a collection, it credits the funds to arrangements it operates and controls — which may include both amounts available for your payout instructions and amounts representing our software service fees. We may view balances reported by the Payment Partner. We may, on your confirmed instruction, transmit payout instructions to the Payment Partner by API. Separately, we may instruct the Payment Partner to pay our fees from those arrangements to an account BrusselsMara designates. We cannot otherwise move customer funds held by the Payment Partner (Terms clauses 4.1, 4.4, and 4.7).

4.4 The Payment Partner — not BrusselsMara — executes Botswana collections and payouts (sends, invoice settlement, and payroll). On those rails the Payment Partner is the licensed institution that receives, holds, and pays the money. We are a software provider that transmits your instruction and relays status to you (Terms clauses 3.1–3.3 and 4.2).

4.5 A payout leaves the Payment Partner’s arrangements when the Payment Partner executes it to the bank account or mobile-money number you confirmed. “Completed” on the Platform means we have been informed that the Payment Partner marked it complete (Terms clause 12.2).

4.6 Transfers between two Romela Pula Balances (Terms clause 9.10), where offered, remain a Platform ledger movement and are still subject to the Terms, including financial-crime controls.

4.7 Nothing in this clause 4 makes the Payment Partner a party to your contract with us.

4.8 If we suspend the Platform in Botswana under Terms clause 4.8, clauses 16.2A and 16.3 govern notification and return of your confirmed available Balance through the Payment Partner, including the 10 business-day target in clause 16.2A where applicable.

5. Your Romela Pula Balance in Botswana

5.1 Terms clause 7 applies to your Balance in BWP. Your Balance is a software record maintained by us. It reflects the amount our Payment Partners have confirmed to us as held on your behalf and available for you to instruct through the Platform. It is not itself an asset, bank account, e-money instrument, or deposit (Terms clauses 7.1 and 7.4).

5.2 Increasing your Balance does not create a debt, deposit, or claim against BrusselsMara. We do not owe you the value shown in your Balance. Displaying a Balance is solely a convenience so you can see what a Payment Partner has confirmed is available for you to instruct (Terms clause 7.3).

5.3 If your displayed Balance differs from the amount the Payment Partner confirms as held and available, the Payment Partner’s confirmation governs, and we will correct the display when we can (Terms clause 7.6).

5.4 When you submit a payout, invoice payment, or payroll instruction, we reduce your displayed Balance and transmit the instruction to the Payment Partner. That reduction is record-keeping only; the underlying payment is discharged when the Payment Partner executes the instruction (Terms clause 7.5).

5.5 On closure or a country suspension, we instruct the Payment Partner to pay out your confirmed available Balance to an account in your name, subject to Terms clauses 16.1–16.5, checks, fees, and any lawful withholding. Our role is limited to submitting that instruction and relaying the Payment Partner’s confirmation; the payment obligation is owed by, and discharged by, the Payment Partner (Terms clauses 16.3, 16.5, and 7).

6. Fees and set-off

6.1 Before you confirm a top-up, payout, invoice payment, or payroll run, we show a single combined quote that includes our software service fee and the costs of using Payment Partners and networks (Terms clause 8.3).

6.2 Our software service fees for Botswana transactions may be retained in the Payment Partner’s arrangements described in clause 4.3 until we instruct the Payment Partner to pay them to an account BrusselsMara designates. That withdrawal is separate from your payout instructions.

6.3 BrusselsMara may set off amounts you owe under the Terms — including shortfalls under Terms clause 8.7 — against your Balance or any amount otherwise payable to you, without prior notice (Terms clause 8.8).

7. Liability cap (Terms clause 15.4(b))

7.1 For Botswana users, the figure referenced in Terms clause 15.4(b) is USD 5,000 (or its BWP equivalent at the conversion rate in clause 7.3 below).

7.2 Terms clauses 15.1–15.6 apply in full. In particular:

• (a) the aggregate cap in Terms clause 15.4 is the lesser of the fees you actually paid in the calendar month of the relevant Event (as defined in Terms clause 15.3) and USD 5,000;
• (b) if you paid no fees, or fees below USD 5,000, in that month, the cap equals the fees actually paid that month, including zero (Terms clause 15.4(i));
• (c) the cap is measured over a rolling twelve (12) month period backwards from the date each claim is first notified to us in writing, and aggregate recovery across all claims in that period shall in no event exceed USD 5,000 (Terms clause 15.4(ii));
• (d) where you are a Consumer (Terms clause 15.3), Terms clause 15.5 may limit how clauses 15.2, 15.4, and 15.6 apply to you.

7.3 Where a claim or the fees used to calculate the cap are in BWP, amounts are converted to US dollars at the Bank of Botswana published USD/BWP mid-rate on the date we first receive written notice of the claim. If that rate is not published on that date, the OANDA mid-market USD/BWP rate on that date is used. For aggregating claims in different currencies within the rolling 12-month period, Terms clause 15.4(ii) uses the OANDA mid-market rate on the date each relevant claim is first notified.

7.4 This clause 7 does not limit liability that Terms clause 15.1 says cannot be limited.

8. Complaints and regulators

8.1 Complaints about the Platform should be sent to info@brusselsmara.com. We will acknowledge your complaint within 2 business days and provide a substantive response within 15 business days (Terms clause 18.1).

8.2 Disputes about whether a specific Botswana collection or payout was executed may need to be raised through the Payment Partner’s own complaints process. We will provide those details on request where we are allowed to (Terms clause 18.1).

8.3 Nothing in the Terms or this Addendum stops you using mandatory rights or complaint routes in Botswana, including:

• the Bank of Botswana, for electronic payment services and related supervision (bankofbotswana.bw);
• the Competition and Consumer Authority, for consumer-protection complaints (cca.co.bw);
• the Information and Data Protection Commission, for personal-data complaints, as described in our Privacy Policy.

8.4 The Platform is not offered in the United Kingdom or the EEA (Terms clause 5.1). Escalating a complaint to a Botswana authority does not make BrusselsMara a Bank of Botswana-licensed principal to you; Botswana collection and payout rails are operated by the Payment Partner as described in clause 4.

8.5 Where you are an individual consumer, mandatory law of Botswana may entitle you to bring proceedings or use dispute routes that Terms clause 18.2A preserves.

9. Personal data

9.1 Terms clause 13 applies. BrusselsMara Ltd remains the controller under UK GDPR for account data, as set out in the Privacy Policy. Botswana’s Data Protection Act may also apply because you are in Botswana.

9.2 Paying in or paying out in Botswana necessarily involves sharing identity, account or wallet numbers, amounts, and purpose with the Payment Partner and Botswana banks or mobile-money operators (Terms clause 13.2).

9.3 Where the Local Marketing Entity assists with collecting documents locally, it does so solely as our processor, not as a controller (Terms clause 13.1A).

10. Changes

10.1 We may update this Addendum as described in Terms clauses 17 and 21. A change applies from the effective date stated in the updated Addendum. It does not apply retrospectively to Events that occurred before that date (Terms clause 21.4).

10.2 If we update the figure in Terms clause 15.4(b) for Botswana, the updated figure applies only to Events on or after that effective date (Terms clauses 21.4 and 21.5).