LockBx Limited — Digital Credit & Lending Products

1. Regulatory Status and Introduction

LockBx Limited ("LockBx", "we", "us", "our") is a company duly incorporated in Kenya and licensed by the Central Bank of Kenya ("CBK") to carry out digital credit business as a Non-Deposit-Taking Credit Provider / Digital Credit Provider ("DCP") under the Central Bank of Kenya (Digital Credit Providers) Regulations, 2022 ("the DCP Regulations"), made pursuant to the Central Bank of Kenya Act (Cap. 491).

CBK Digital Credit Provider Licence No.: CBK/DCP/2024/68
LockBx is regulated by the Central Bank of Kenya, P.O Box 60000-00200, Nairobi.
LockBx does not accept deposits, savings, or cash collateral from the public in the course of its digital credit business.

These Terms and Conditions ("Terms and Conditions") set out the complete terms which apply to LockBx's mobile lending platform, USSD/online system and any physical application form, and are issued in compliance with the DCP Regulations, the Consumer Protection Act, 2012, and the Data Protection Act, 2019. These Terms and Conditions and any amendments or variations thereto take effect on their publication date, subject to the notice periods described in Clause 16.

2. Definitions

In these Terms and Conditions, the following words and expressions bear the following meanings:

Bank / CBK means the Central Bank of Kenya.

Borrower / You / Your means the person at whose request LockBx will advance a loan facility, and includes the personal representatives of the Borrower.

Call Centre means LockBx's customer service call centre.

Credit Reference Bureau (CRB) means a credit reference bureau duly licensed under the Banking (Credit Reference Bureau) Regulations to collect and facilitate the sharing of borrower credit information.

DCP Regulations means the Central Bank of Kenya (Digital Credit Providers) Regulations, 2022 and any amendments thereto.

Equipment means your mobile phone handset and/or other equipment which, when used together, enables you to access the online lending platform.

Key Facts / Key Information Document means the summarised, plain-language disclosure of a product's benefits, risks, total cost of credit and terms, provided before you take a loan.

LockBx / We / Our / Us means LockBx Limited, and includes its successors and assigns.

Non-Performing Loan means a loan in which the principal or interest is due and unpaid after the due date under the agreement between LockBx and the Borrower.

Products means the various loan facilities and services offered by LockBx, including payroll check-off loans, logbook (asset-backed) loans, earned-wage access via Wagelyft, mobile phone financing and electric three-wheeler (E3W) asset financing.

Request means an instruction received by LockBx from you, or purportedly from you, through the System, on which LockBx is authorised to act.

Services means any financial services or products that LockBx may offer you under this Agreement.

Total Cost of Credit means the sum of the principal, interest, fees, charges and any other liabilities payable by the Borrower over the life of the loan, expressed together with the Annual Percentage Rate (APR).

Security Agreement / Secured Asset means the legal, binding security instrument and the asset over which a loan facility is secured, respectively.

System means LockBx's electronic lending platform and communications software enabling the Borrower to communicate with LockBx.

Transaction Costs means charges levied by third-party service providers, including but not limited to M-Pesa and bank transaction charges.

Words importing the singular include the plural and vice versa. Headings are for convenience only and do not affect interpretation. The word "Borrower" includes both genders and juristic persons.

3. Acceptance of the Terms and Conditions

Before applying for any LockBx product, you should carefully read and understand these Terms and Conditions, the applicable Key Facts Document, and the product-specific terms, which together govern your use of our System and Services.
By registering, completing an application, or proceeding with a Request through our System, you agree to be bound by these Terms and Conditions and confirm that you have voluntarily and knowingly entered into this Agreement for your own benefit.
By accepting these Terms and Conditions, you authorise LockBx to assess your credit score and to access your credit history from a registered Credit Reference Bureau, for the sole purpose of credit appraisal and in accordance with Clause 6 (Credit Appraisal).
LockBx may amend or vary these Terms and Conditions from time to time. Save for changes required by law or by CBK directive, no variation that increases your charges, credit limit, or otherwise alters the credit terms in Clause 8 shall take effect unless LockBx has given you at least thirty (30) days' prior written notice and you have accepted the change, in line with Clause 16.

4. Registration

You must register on our System, or complete an application form, to access our products.
You are responsible for maintaining the confidentiality of your passwords, PIN, and any other account identifiers, and for all activity on your Equipment.
You authorise LockBx to obtain your personal information from the Integrated Population Registration System (IPRS) of the Government of Kenya, where necessary for identity verification, and consent to the Government's disclosure of such information to LockBx.
You authorise LockBx to subject your information to its credit scoring engine to assess your creditworthiness, in accordance with Clause 6.
LockBx may request further information to process your application. Failure to provide this within the requested time may result in your request being declined.
If you do not accept these Terms and Conditions of Registration, you should not proceed with registration. Upon successful registration, you must read and familiarise yourself with each product's specific terms, which shall also bind you.

5. Responsible Lending and Credit Appraisal

In line with Regulation 18 of the DCP Regulations, LockBx will not advance credit to you until it has taken reasonable steps to assess your ability to repay the facility. This assessment may include, among other things, your income and employment information, repayment history, existing debt obligations, and a review of your credit report from a licensed Credit Reference Bureau. LockBx reserves the right to decline, reduce, or vary the terms of any credit request where, in its reasonable opinion, the facility is not affordable to you.

6. Fees, Charges, Taxes and Total Cost of Credit

You agree to pay all fees, commissions, costs and other charges payable in connection with your use of our System and/or incurred by LockBx in obtaining or attempting to obtain settlement of any loan, including but not limited to:

Legal charges, including advocate-client charges and costs incurred in legal, arbitration or other proceedings connected with your loan account;
Commissions at rates LockBx may determine from time to time, subject to Clause 16;
Other charges and expenses, including ledger fees, postage, telephone calls, taxes, duties and impositions.

All payments are calculated exclusive of applicable taxes. Where any tax (including excise duty) is payable in connection with a payment, you must pay LockBx an additional amount equal to that tax.

Before you take any loan, LockBx will disclose to you, in a Key Facts Document and in the applicable product terms, in a clear, simple and easily accessible format:

the loan amount;
the loan charges and the circumstances in which they may be imposed;
the interest rate charged, and whether it is charged on a reducing balance basis or otherwise;
all other charges applicable to the loan;
the date(s) on which the loan amount, interest, charges, fees or other liabilities are due, and how they are calculated;
the Total Cost of Credit, comprising the principal, interest, fees, charges and any other liabilities; and
the Annual Percentage Rate (APR) of the facility.

This disclosure is made pursuant to Regulation 27 of the DCP Regulations and the Consumer Protection Act, 2012.

7. Borrower's Equipment and Responsibilities

You shall provide and maintain your Equipment for accessing our System, at your own expense, in safe and efficient operating order.
LockBx shall not be responsible for errors or failures caused by any malfunction of your Equipment, nor for any computer virus or related problem associated with your use of our System.
You shall follow all instructions and procedures contained in these Terms and Conditions and any information provided by LockBx concerning use of our System.
You are solely responsible for the safekeeping and proper use of your Equipment, and shall ensure it does not come into the possession of an unauthorised person. LockBx shall not be liable for loss occasioned by any third party who gains access to your Equipment.

You shall immediately inform LockBx through the Call Centre at +254 709 320 100 or WhatsApp +254 719 658 223 if you believe your Equipment has been used to complete a transaction fraudulently or without your authorisation; LockBx shall nonetheless not be liable for such unauthorised use where it has acted in good faith on an instruction reasonably believed to be genuine.

8. Exclusion of Liability

LockBx shall not be responsible for any loss suffered by you where the System is interfered with or unavailable due to circumstances beyond LockBx's reasonable control, including force majeure, equipment failure, power loss, adverse weather, or failure of any public or private telecommunications system.
LockBx will not be liable for losses arising from: failure or unavailability of your Equipment; fraudulent or illegal use of the platform or Equipment; or your failure to comply with these Terms and Conditions.
All warranties and obligations implied by law are excluded to the fullest extent permitted by law. Nothing in this Clause excludes any liability which cannot lawfully be excluded, including liability arising from LockBx's own negligence, fraud, or non-compliance with the DCP Regulations.

9. Intellectual Property Rights

The intellectual property rights in our System, and all associated documentation, are vested in LockBx. You shall not duplicate, reproduce, or tamper with the System or associated documentation without LockBx's prior written consent.

10. Your Requests

All Requests received from your Equipment are presumed to have been made by you, and you irrevocably authorise LockBx to act on such Requests.
LockBx may, in good faith, act on a Request that is incomplete or ambiguous if it reasonably believes it can be corrected, or may decline to act pending further confirmation from you.
You agree to indemnify LockBx against claims, losses or costs arising from LockBx having acted in good faith on your Request, save where such loss arises from LockBx's own fraud, wilful default or gross negligence.
LockBx is authorised to act on your loan account as required by any court order or competent authority under applicable law.
In the event of conflict between any Request and these Terms and Conditions, these Terms and Conditions shall prevail.

11. Fair and Responsible Debt Collection

In line with Regulation 20 of the DCP Regulations, neither LockBx nor its officers, employees or agents shall, in the course of debt collection:

use threats, violence, or other means to harm you, your reputation, or your property;
use obscene or profane language directed at you or your references or contacts, or send messages intended to shame you;
access your phone contacts or phone records to send messages about a missed or late payment, without your consent;
post your personal or sensitive information online or in any public forum to shame you;
make unauthorised or unsolicited calls or messages to your contacts;
employ any improper or unconscionable debt collection tactic; or
engage in any conduct whose consequence is to harass, oppress or abuse you or any other person in connection with debt collection.

Any concern about the conduct of a LockBx staff member, agent or third-party debt collector should be raised immediately through the channels set out in Clause 18 (Customer Complaints and Redress) or by calling +254 709 320 100.

12. Check-Off Loan

12.1 The Loan

At your request, LockBx agrees to make available the advised loan amount on the terms set out in this Agreement and the applicable Key Facts Document.
You may repay the principal amount within three (3) business days of disbursement, upon payment of administration costs, to LockBx Limited NCBA A/C No. 8650550017, Branch: Kilimani, Account Name: LockBx Limited, and/or via M-Pesa Pay Bill No. 5479179 (Account: Borrower's ID No.).

12.2 Interest

Due to market conditions, LockBx may vary the interest charge by giving you at least one (1) calendar month's prior written notice, in accordance with Clause 16 and Regulation 29 of the DCP Regulations. Interest is charged as disclosed in the applicable Key Facts Document.

12.3 Cost of Credit

Appraisal fee: 25% of the loan amount (added to the loan amount, and disclosed upfront as part of the Total Cost of Credit);
Monthly collection fee: Kshs. 100;
Statement fee: Kshs. 300 (charged upon each request);
Third-party processing fee: activated upon request;
All fees above are exclusive of the applicable excise duty (currently 20%), which is charged separately and settled by the Borrower in addition to the fees above.

The Total Cost of Credit and the applicable Annual Percentage Rate (APR) for each Check-Off Loan will be disclosed to you in writing before disbursement, in accordance with Clause 6.

12.4 Cost of Credit and Execution Charges

A certified payoff statement will be issued upon request and payment of an upfront fee of Kshs. 300.
If LockBx must instruct lawyers to recover amounts owed because you have not fulfilled your obligations, you will bear the reasonable costs of LockBx's lawyers actually and properly incurred in that recovery.

12.5 Repayment

You must repay the loan in the instalments advised to you.
You authorise LockBx to deduct the monthly instalments directly from your salary through your employer's payroll.
If you leave your employer's service before the loan is fully repaid, you authorise LockBx to recover monies owed from any unpaid wages or other remuneration due to you, to the extent permitted by law.
No cash should be handed to any LockBx employee; LockBx accepts no responsibility for cash paid directly to its employees. All payments must be made to the LockBx bank account or Pay Bill number above. Payments by cheque or EFT are deemed received on the date funds clear, not the date of deposit or initiation.

12.6 Non-Performing Loans and Breach

Where you fail to pay any amount owing in full and on time, or otherwise breach these Terms and Conditions, the full outstanding balance, together with accrued interest and other charges, becomes immediately due and payable, and LockBx may terminate this Agreement and recover any resulting loss, without prejudice to your rights below.

Cap on amounts recoverable from a non-performing loan: In line with Regulation 19 of the DCP Regulations, where your loan becomes non-performing, the maximum amount LockBx may recover from you is limited to the sum of: (i) the principal owing at the point the loan became non-performing; (ii) interest under this Agreement, which shall not exceed the principal owing at that point; and (iii) reasonable expenses actually incurred in recovering the amount owed. This cap does not limit any interest accruing under a court order made after judgment.

Where you default, LockBx will apply any payment you make first to legal and other recovery costs, then to interest, and lastly to the principal amount.
LockBx may engage a licensed third-party debt collector to recover an outstanding balance, at your cost, and any such collector shall be bound by the standards in Clause 11.
A statement of the amount you owe, prepared by a LockBx officer, shall be evidence of the amount owed and may be relied upon in any legal proceeding, unless you prove it to be incorrect.

12.7 General

LockBx will, on request, provide a statement of all deductions from your salary, the outstanding balance, and any amount in arrears, free of charge for your first request in any 12-month period and thereafter at the fee disclosed in Clause 6.
Check-Off Loans are disbursed via M-Pesa or directly into the Borrower's bank account.
The maximum amount approved and disbursed under the Check-Off Loan product is Kshs. 200,000, subject to LockBx's credit policy and CBK-approved pricing parameters.
The Check-Off Loan is governed by these Terms and Conditions. In the event of default, LockBx's normal collections process for civil servants' loan products, described in this Clause 12, will apply.

Applicants for a Check-Off Loan should read and familiarise themselves with these Terms and Conditions before proceeding.

13. Marketing Communications

LockBx may, with your consent, send you information about its products and services. You have the right to opt out of receiving marketing messages at any time, free of charge, by replying "STOP" to any marketing SMS, by emailing info@lockbx.io, or by calling the Call Centre. Opting out of marketing will not affect service messages relating to your loan account.

14. Data Protection

The data referred to in this Clause has been obtained directly from you (the Borrower) to facilitate the processing of the loan facility you have requested.

By signing this Agreement, you:

provide personal data required to process your loan facility, establish and maintain the business relationship, and enable LockBx to meet its contractual and legal obligations;
consent to LockBx processing your data in accordance with its internal Data Protection Policy and Privacy Policy;
consent to LockBx continuing to hold and process your data after your obligations under the loan have been settled, for purposes including research, product development, market analysis, and LockBx's regulatory and operational requirements, subject to the retention limits in LockBx's Privacy Policy; and
retain the right to exercise your rights as a data subject under the Data Protection Act, 2019, Laws of Kenya, including the right to access, correct, or request deletion of your data, and to lodge a complaint with the Office of the Data Protection Commissioner.
LockBx will only collect and process the personal data reasonably required for your credit appraisal, approval, disbursement and collection, in accordance with the data minimisation principle under Regulation 26 of the DCP Regulations.

15. Confidentiality

LockBx maintains appropriate policies, procedures and systems to protect the confidentiality of your information and transactions, and will not share your information with any other person except with your consent, or as required or permitted by law. LockBx's directors, officers, employees and agents are bound to protect the confidentiality of your information, both during and after their engagement with LockBx.

16. Variation of Terms, Pricing and Credit Limits

LockBx will not change its pricing model or parameters without the prior written approval of the CBK. LockBx will not increase your charges or credit limit, or otherwise vary the credit terms disclosed to you under Clause 6, unless it has given you at least thirty (30) days' prior notice clearly disclosing the change, and you have accepted it. LockBx will notify you of any variation to a product's features at least thirty (30) days before the variation takes effect.

17. Variation and Termination of the Borrower Relationship

The variation and termination of the relationship between LockBx and a Borrower are key aspects of loan management. Below is an overview of how these processes typically work.

17.1 Variation of Loan Terms

Variation refers to changes to the original loan agreement, arising from changes in your financial situation, market interest rate movements, or mutual agreement to restructure the loan. Common variations include:

Interest rate adjustments due to market conditions or a variable-rate agreement;
Repayment schedule changes, extending or shortening the loan term;
Loan restructuring of the principal amount or repayment terms, typically to avoid default;
Payment holidays — a temporary suspension of payments, often granted during financial hardship; and
Refinancing — replacing the existing loan with a new one on better terms.

Process: you submit a request detailing the change sought; LockBx assesses your financial situation, creditworthiness and reasons for the request; if reasonable, both parties negotiate new terms; the agreed terms are documented and signed; and the new terms are then implemented.

17.2 Termination of the Borrower Relationship

Termination refers to the end of the borrowing arrangement, whether through full repayment, default, or mutual agreement.

Full Repayment: you make the final payment covering principal, interest and fees; LockBx issues a statement confirming the loan is paid off and releases any collateral; both parties receive documentation confirming closure.
Default and Foreclosure: LockBx initiates collection efforts, in line with Clause 11, after missed payments; where you cannot repay, LockBx may proceed with foreclosure (for secured loans) to recover the amount owed through sale of collateral; you may face legal consequences and an impact on your credit score.
Mutual Agreement: both parties negotiate terms for early termination; you may pay a settlement amount; LockBx provides documentation confirming termination and any release of collateral.

18. Customer Complaints and Redress

LockBx has established a dedicated complaints and redress mechanism in accordance with Regulation 22 of the DCP Regulations. Full details of how to lodge a complaint, the information to include, and our resolution timelines are set out in our Customer Redress Mechanism, available on our website and on request. In summary:

You may lodge a complaint by phone, WhatsApp, email or in writing, at no cost to you;
LockBx will acknowledge your complaint within 24 hours and resolve it as promptly as possible, and in any event within thirty (30) days of receipt, as required by Regulation 22(2) of the DCP Regulations;
LockBx will keep a record of all complaints and their resolution, and will, on request, issue you a transaction receipt or a comprehensive statement of your account, in line with Regulation 21 of the DCP Regulations.

Contact our Customer Service team on +254 709 320 100 or WhatsApp +254 719 658 223, or by email at info@lockbx.io or hello@lockbx.io.

19. Dispute Resolution, Jurisdiction and Arbitration

You may contact our Customer Service / Support team on +254 709 320 100 or WhatsApp +254 719 658 223 to report any dispute, claim or complaint.

Any dispute arising out of or in connection with this Agreement that is not resolved by our Customer Service team should be reported in writing to info@lockbx.co.ke.

Any dispute not resolved by LockBx shall be referred to arbitration by a single arbitrator appointed by agreement between the parties, or, failing agreement within sixty (60) days of notification of the dispute, appointed upon application of either party by the Chairman for the time being of the Chartered Institute of Arbitrators (Kenya Branch). Arbitration shall be conducted in English, in Nairobi, in accordance with the Arbitration Act.

The parties agree the Arbitrator shall have power, inter alia, to:

consolidate proceedings and hold concurrent hearings;
award security for costs and order preservation of evidence;
make provisional awards;
act in default of a party; and
apply the law determined by the applicable conflict-of-laws rules.

To the extent permissible by law, the Arbitrator's determination shall be final, conclusive and binding on the parties. Nothing in this Clause prevents you from referring a complaint to the Central Bank of Kenya or any other applicable regulator or ombudsman.

20. General Provisions and Contact Details

This Agreement is governed by the laws of Kenya. If any provision of these Terms and Conditions is found unenforceable, the remaining provisions shall continue in full force. LockBx's failure to enforce any provision shall not constitute a waiver of that provision.

You can reach LockBx Limited at:

Address: Sifa Towers, 6th Floor, 6A Lenana Road, Kilimani, P.O Box 25590-00603, Nairobi, Kenya

Phone: +254 709 320 100

WhatsApp: +254 719 658 223

Email: info@lockbx.io or hello@lockbx.io
Website: https://www.lockbx.io

LockBx Limited is licensed and supervised by the Central Bank of Kenya as a Non-Deposit-Taking Credit Provider / Digital Credit Provider. LockBx does not take deposits from members of the public.

Terms & Conditions