My Purse Pay - Wallet Policy

1. Custody & Ownership

All customer funds held within Mypursepay wallets are custody of Sterling Bank Plc via the Embedly platform. Mypursepay does not hold customer funds in any corporate account or other custodian account. Sterling Bank retains legal custody and settlement responsibility.

2. Single Wallet Model and Logical Allocations

Each user has one legal wallet on the Embedly platform. Mypursepay implements logical allocations (Spending Balance and Holding Balance) that represent user-directed categorisations of the True Balance. These do not represent separate bank accounts; they are records in our application that control access by enforcing transaction rules.

3. Deposit & Allocation Flow

When a deposit is initiated, the funds are credited to the user's Sterling/Embedly wallet. Embedly issues a webhook event; Mypursepay reconciles the event and updates the user's True Balance and the application-level allocations according to the user's selection (Spending or Holding).

4. Spending & Holding: Definitions and Enforceable Rules

Spending Balance: funds available to initiate transfers, bill payments, and withdrawals. Holding Balance: funds the user elects to lock; Mypursepay enforces this lock at the application layer and will block transfer instructions that would reduce Spending below zero or breach the Holding allocation.

5. Withdrawal & Transfer Execution

All withdrawals and transfers are executed by Sterling Bank/Embedly. Mypursepay performs a pre-execution check: verifying that requested amounts are within the user's available Spending Balance. If the check passes, Mypursepay instructs Embedly to execute the transaction. If the check fails, the request is blocked and notified to the user.

6. Escrow & Conditional Holds

Escrow may be implemented using Embedly's native escrow features where available, or via application-level conditional holds. Release triggers (e.g., delivery confirmation, time-based release, dispute resolution) must be clearly defined in the transaction metadata. Mypursepay will only instruct Embedly to release funds upon verified satisfaction of triggers.

7. P2P Transfers & Mapping

P2P transfers are performed via Embedly's wallet-to-wallet API. Mypursepay maps user identifiers (phone, email, username) to Embedly wallet IDs and submits the transfer request. Timestamps, reference IDs, and status codes returned by Embedly are recorded in Mypursepay's immutable transaction logs.

8. Reconciliation and Audit Procedures

Mypursepay follows a webhook-first reconciliation model: webhooks are the primary source of truth for transactional events. In the event of missed webhooks, periodic polling of Embedly's balance API occurs. Daily full reconciliations are run comparing Embedly balances to the sum of classified allocations (Spending + Holding). Any variance beyond predefined thresholds is escalated to finance and operations.

9. Exception Handling & Dispute Process

When discrepancies or failed transactions occur, the user files a dispute via the support channel. Mypursepay logs the dispute, conducts preliminary technical checks, and escalates to Embedly/Sterling as required. Resolution timelines are tracked and disclosed to the user.

10. Security & Data Protection

KYC data and transaction records are stored securely with encryption in transit and at rest. Access to production systems is strictly role-based. Breach notification procedures and data retention policies comply with applicable laws.

11. Operational Controls & Audit Trail

All changes to user allocation (Spending/Holding) are recorded with timestamps, actor IDs, and reasons. A minimum retention period for financial logs is maintained for regulatory and audit purposes.

12. User Controls & Consent

Users provide affirmative consent to allocation changes. Scheduled or automated releases of Holding funds require explicit user confirmation at the point of scheduling and are reversible only per the defined window in platform controls.

13. Contact & Escalation

For wallet inquiries: support@mypursepay.com.ng. For custody & settlement issues: hello@embedly.ng. For compliance escalation: compliance@mypursepay.com.ng.