Last updated: January 2, 2026
The following document applies to Lockpesa’s transaction platform (“The Platform”). The Platform is owned and operated by Teelpay Technologies Ltd (“Lockpesa”), a company incorporated in Kenya under the laws of the Republic of Kenya. Lockpesa grants you a non-exclusive licence to access the Platform and use the Services (defined below) subject to these terms and conditions (“Terms”).
In these Terms, “we”, “us” and “our” refer to Lockpesa and references to “you” and “your” refer to you, the user of the Platform and our customer (“Customer”). By accessing and using the Platform and Services, you agree to be bound by these Terms. If you do not agree with these Terms, you must immediately stop using the Platform. You agree that we may change, update, or otherwise amend the Platform, the Services, and these Terms at our absolute discretion, subject to paragraph 13.4.
1.1 Lockpesa Account
The registered profile of a Customer. “The Lockpesa Hold” refers to Lockpesa’s M-PESA Platform Account, which is the client monies account with Stripe, which monies are transferred to via Lockpesa during the process of a transaction. The Lockpesa Hold is a safeguarded Hold Account. This Hold Account is statutorily protected so that the funds are held safely for Customers even in the event of our insolvency.
1.2 Account
(i) a payment account or payment instrument of a Buyer held with or issued by a third-party payment service provider (e.g. Buyer’s M-PESA account) from which funds are transferred to the Lockpesa Hold; (ii) a payment account of a Seller held with or issued by a third-party payment service provider (e.g. Seller’s M-PESA account) to which funds are transferred from the Lockpesa Hold on completion of a Transaction.
1.3 Business Day
Monday through Friday between the hours of 9:00 a.m. and 5:00 p.m. East Africa Time (EAT), which are not public holidays in Kenya.
1.4 Payment
The transfer of Funds by Lockpesa from the Buyer to the Seller to satisfy the payment of the relevant Transaction.
1.5 Funds
The funds transferred to the Lockpesa Hold under a specific Transaction ID pursuant to these Terms and for the purpose of effecting the payment of the Transaction between Buyer and Seller.
1.6 Transaction ID
The unique identifier associated to a particular Payment Transaction identifying the funds transferred to the Lockpesa Hold on behalf of a specific Buyer and Seller.
1.7 Prohibited Transactions
Customers may not use the Platform or the Services in connection with any Transaction that is illegal or involves any illegal items, or is for any illegal purpose; involves any obscene or pornographic material; involves any munitions or firearm; involves pirated software or digital asset (s) otherwise infringing copyrighted works; involves illegal drugs or controlled substances; sale of alcohol to consumers; gambling and sale of electronic currencies.
1.8 Security Details
The personal username or password associated to your Lockpesa Account.
1.9 Seller
Has the meaning as set out in paragraph 5.1(a) of these Terms.
1.10 Services
The transaction management and escrow-like services provided in relation to the Lockpesa Hold and through the Platform.
1.11 Buyer
Has the meaning as set out in paragraph 5.1(a) of these Terms.
1.12 Writing
Includes emails. When we use the words “writing” or “written” in these terms, this includes emails.
1.13 Transaction
The sale of goods or services by the Seller to the Buyer.
1.14 Item
The object of the transaction. The item can refer to physical goods, digital goods, or services. The item must not be part of Lockpesa’s prohibited items list (please refer to the “Prohibited Transactions” section for our prohibited items list). The item description must reflect its quality and appearance precisely (including any defects or alterations) when the transaction is created, as it constitutes a sales agreement between the Buyer and the Seller.
You accept and acknowledge the following conditions to access and use of the Platform and any Services:
You are over the age of 18;
You only use the Platform and Services for lawful purposes and not for Prohibited Transactions; and you represent that you have the capacity to form a binding contract in your jurisdiction;
You have the authority to bind any business on behalf of which you use our Platform;
You register a Lockpesa Account;
You have the necessary equipment and access to the internet;
You must provide us with accurate personal and contact information and not share your personal information with other Customers;
You will only represent yourself and will not create false aliases or impersonate any other person or entity (with or without their consent) in connection with the Platform;
You are not breaking any local, county, national or international law in your relevant jurisdiction by accessing or using this Platform or the Services in Kenya.
You accept and acknowledge the following conditions to access and use of the Platform and any Services:
To access the services, you will need to register a Lockpesa Account by providing the information requested on the Platform (including full name, email address, phone number, national ID/passport number and selfie) and creating a password.
You consent to the use of this information to create your Lockpesa Account in accordance with our Privacy Policy and acknowledge that we rely on the information provided by you during the registration process being true, accurate, current and complete.
You agree to provide all information and documents we need from time to time so we can verify your identity and/or your M-PESA account and so we may comply with our legal obligations to combat financial crime, including money laundering and fraud in Kenya. We may use third-party data services that specialize in customer due diligence services to verify your identity. You also authorize us to hold your information, including your browsing and activity history, so we may perform ongoing monitoring of the Services and your behaviours when using Lockpesa to comply with our legal and regulatory obligations.
If we are unsuccessful in receiving satisfactory information for us to verify your identity at the point of registration, we reserve the right to refuse to register your Lockpesa Account and prevent you from gaining access to the services. We may also have obligations to report such activity to governmental agencies and regulatory authorities in Kenya and we do not require your consent to do so.
If you are provided with a PIN and password to access the Platform, it is your responsibility to keep your PIN and password secure (Security Details). You indemnify us for any loss or damage we suffer as a result of your fraudulent use of your Lockpesa Account including you knowingly sharing your Security Details with a third party for the purposes of fraud. You must take all reasonable steps to avoid the loss, theft or misuse of the Security Details.
You warrant and represent that any information provided to us is accurate, complete and not misleading and remains so. You must notify us of any change to such information.
We may suspend your use of the Services if:
We have reasonable concerns about the security of the Lockpesa Account;
We are unable to confirm your identity or there is a potential risk of financial crime as part of our ongoing monitoring process;
We suspect the Services are being used in a fraudulent or unauthorised manner; or
We need to deal with technical problems or make minor technical changes.
We will notify you of any such suspension in advance, or immediately after if this is not possible, unless we have detected a problem which is urgent or an emergency. We will provide you with the reasons for the suspension, unless to do so would compromise reasonable security measures or otherwise be unlawful. We will lift the suspension and, where appropriate, issue new Security Details free of charge as soon as practicable once the reasons for the suspension cease to exist.
We cannot be held liable for any delay to the Services if we require to make an urgent change or deal with an emergency that may affect the security of our Platform, although we will at all times comply with our regulatory obligations to complete a payment transaction.
We may change the Platform at regular intervals to reflect changes in relevant laws and regulatory requirements in Kenya, to implement minor technical adjustments and improvements, for example to address a security threat or otherwise to enhance the Services we provide through the Platform. These changes should not affect your access to or use of the Platform or Services. If we make more significant changes to the Platform or the Services, we will use our reasonable endeavours to inform you by email or by posting information on our website and may make changes to these terms to reflect such changes.
Either party may start a Transaction. The Customer receiving the Payment Transaction shall be the Seller (“Seller”), and the Customer making the Payment Transaction shall be the Buyer (“Buyer”).
To initiate a Transaction, a Customer must log into their Lockpesa Account, or, if the Customer does not have a Lockpesa Account, register a Lockpesa Account (as set out in paragraph 2). Once logged into the Lockpesa Account and the details of the Transaction have been confirmed (including the Transaction value, details of the transaction, and the contact details of the counterparty to that Transaction (“Counterparty”)), a notification will be sent by Lockpesa to the Counterparty so they can join the transaction.
To join a transaction, the Counterparty shall be required to log into their Lockpesa Account or, if they do not already have one, register a Lockpesa Account (as set out in paragraph 2).
Once all the details have been confirmed as correct, the Buyer transfers the funds, including the applicable Lockpesa fee, to the Lockpesa Hold Account using M-PESA or any other supported payment method available on the Platform. The Funds will be debited from the Buyer’s M-PESA account and transferred to the Lockpesa Hold Account, identifiable by the Transaction ID.
Once the Buyer has authorised the Payment Transaction, the Buyer cannot revoke that consent and the Funds will not be released until the transaction has been completed or otherwise resolved in accordance with these Terms.
Both parties will always be able to check the progress of the transaction by clicking on the relevant transaction in the “My Transactions” section.
Once the item has arrived or the agreed service has been completed, Lockpesa gives the Buyer the authority to release Funds, and the Funds will automatically be released from the Lockpesa Hold Account to the Seller. Lockpesa always sends 4 digit release code to the Buyer when the Seller confirms the product is in transit. It is the responsibility of the Buyer to keep safe the release code Lockpesa send to their registered number with Lockpesa. The Buyer must not share the code with anyone even Lockpesa agents. Entry of the code confirms payment to the Seller and Lockpesa deem such entry as confirmation of valid transaction, after which the Buyer cannot make claim to the amount send to the Seller.
No interest will accumulate on the Funds while they are held in the Lockpesa Hold Account.
We do not require, but strongly recommend, that the Seller keeps records of any Transaction in case of a dispute, including photographs, delivery confirmations, screenshots, communication logs, or proof of completion of services.
The Funds remain in the Lockpesa Hold Account on behalf of the Buyer from receipt of the Funds until the transaction is completed. Lockpesa reserves the right to determine whether a transaction is complete or still in progress whenever necessary for operational, security, compliance, or dispute resolution purposes.
Upon completion of a transaction, the Payment is automatically executed. Once the Payment is executed, the Funds remain temporarily in the Lockpesa Hold Account on behalf of the Seller before transfer to the Seller’s nominated M-PESA number or approved payout method, subject to delays caused by anti-money laundering, fraud prevention, security reviews, or compliance checks.
Users will receive an indication of the anticipated completion time of the Transaction by checking the relevant transaction status. We will endeavour to notify Users of any delays and shall not be liable for delays caused by third-party payment service providers, telecommunications providers, M-PESA system interruptions, or government actions.
We reserve the right to conduct customer due diligence and verification checks on the Seller and/or Buyer at any time. In the event that the Seller and/or Buyer do not pass the required checks, the Funds will not be transferred until all checks have been successfully completed in accordance with applicable Kenyan laws and regulations. Depending on the outcome of such checks, the Funds may be transferred to an authorised third party or government agency where required by law.
Payments made through Lockpesa must be completed in advance using M-PESA or any other payment method specified on the Platform. Additional charges may apply depending on the selected payment method, including charges imposed by Safaricom or payment processors.
We shall charge fees as listed below. We reserve the right to amend these fees at any time by providing notice in accordance with paragraph 13.4.
The Buyer Protection Fee applies to all Lockpesa transactions made through the Platform or App. The fee is calculated and added to the total transaction amount before payment is submitted by the Buyer.
The standard Buyer Protection Fee rates are available.
The Buyer Protection Fee is non-refundable.
Lockpesa may also support split transaction fees between the Buyer and Seller where applicable.
Once the Funds have been deposited into the Lockpesa Hold, if the Transaction has not been completed, or as otherwise agreed/set by the parties on the Platform, the Buyer may lodge a complaint via the Platform. The Seller shall be notified of such Buyer request and, should the refund be agreed by both parties, a refund Payment Transaction shall be initiated and the Funds shall be returned to the Buyer through M-PESA or the original payment method used. We reserve the right to charge any administrative fees or other charges for a cancellation (“Cancellation Fees”). Both parties can mutually agree to cancel a transaction if the item hasn’t been posted yet; however, the Lockpesa fee will be non-refundable.
When you are a Buyer in a Transaction and you are an individual not engaged in conduct related to your trade or business, you are considered a consumer. A Seller shall be required to comply with the minimum requirements of the consumer protection laws in the Seller’s own jurisdiction in respect of cancellations, refunds and returns.
If the Seller is within Kenya, consumers may be protected under applicable Kenyan consumer protection laws and regulations governing electronic commerce, digital payments, and fair trade practices.
For each Transaction, you will be able to access all the following information in your Lockpesa Account, as available and applicable:
The unique alphanumeric code for any transaction that has started and information on the other party to the Transaction including a brief description of the item in question and the delivery service used if applicable;
The status of the Transaction;
The total amount, and the currency of, the Funds standing to the credit of the Lockpesa Hold relating to the Transaction in question;
The Fees and other charges for the Payment Transaction and, where applicable, a breakdown of these payable by you;
The date of receipt of the payment order.
To the extent permitted by law, we are not liable to you, except:
As a direct consequence of our fraud;
For death or personal injury caused by us as a result of our negligence (or any other act or omission caused by our negligence that cannot be excluded by law).
Subject to the rest of this paragraph 6, we are not liable for:
Any loss of profit, business, contracts, revenue or anticipated savings;
Any special, indirect or consequential damages.
As a Buyer, except where you have acted fraudulently, you will not be liable for losses incurred in respect of an unauthorised Payment. We will assume that all Payments are authorised by you unless you notify us otherwise. If you believe you did not authorise a particular Payment or that a Payment was incorrectly carried out, you must contact us as soon as possible.
Except where we are not liable for an unauthorized Payment (for example, if we obtained liability protection from the payment provider) or an incorrectly executed Payment, we will refund without undue delay the amount of the Payment and any associated fees payable under the Terms subject to the rest of this paragraph. We may require you to complete a dispute declaration form. We may conduct an investigation either before any refund has been made. We will let you know as soon as possible the outcome of any such investigation.
If you are a Seller, you are liable for all claims, expenses, fines and liability we incur arising out of:
A refund, over-payment, payment error, or other invalid payment you cause (collectively “Invalidated Payment”);
Any error, negligence, misconduct or fraud by you, your employees, or someone acting on your behalf;
Any losses resulting from your failure to comply with the terms of this Agreement.
In the event of an Invalidated Payment or other liability, you authorise us to collect from you any amount due pursuant to these Terms by retrieving the funds from the M-PESA account or payment method associated with your account, by withholding the amount due from your future Payout(s), or by issuing you with an invoice payable within 7 days.
Your personal details, payout method, and identity documents must be up to date at all times if you intend to transact on our platform as a Seller. We are not responsible for any loss suffered by you as a result of incorrect personal and/or payout information provided by you.
We may temporarily place a hold, suspend, or cancel any Payout for the purposes of preventing unlawful activity or fraud, risk assessment, security, or completing an investigation; or if we are unable to verify your identity or where applicable the identity of your representative(s) or beneficial owner(s), or to obtain or verify requested information.
You can contact Lockpesa via the contact numbers on the Platform. Alternatively, you can contact Lockpesa by email at support@lockpesa.com. Lockpesa will contact you using your email address or/and phone number. All communications with respect to the Services will be in English/Swahili. Notices regarding changes to these Terms or the termination of these Terms will be made in writing including by sending you an email. The language of the Terms is English/Swahili and any translation provided is for information purposes only.
You may terminate these Terms at any time by contacting us. Notwithstanding the termination, any ongoing Transactions will continue in accordance with these Terms until completed unless the parties agree otherwise. Termination of these terms means you cannot use our services via accessing the Platform.
We may terminate these Terms, your right to access the Platform and Services, for any reason and at any time by giving you two months’ notice in writing.
Upon termination of these Terms, and provided that these Funds are not held in relation to a Dispute or otherwise required by law, we shall repay the Funds to the party who is a Buyer in a Transaction through M-PESA.
The termination of these Terms does not affect the parties’ rights in respect of periods before the termination of these Terms.
Although Lockpesa acts as the payment escrow and transaction facilitator, Lockpesa does not buy, sell, manufacture, store, inspect, or deliver any items sold through its services. Lockpesa operates as a neutral intermediary that securely holds payments made through M-PESA and facilitates the transfer of funds between buyers and sellers while managing dispute resolution within the scope of this policy. Note that Lockpesa as the facilitator for transactions is done automatically by the Platform, unless where human intervention is not avoidable like disputes, refunds and returns.
Lockpesa Buyer Protection applies to transactions where the buyer has paid the Buyer Protection fee, as clearly shown during checkout. The fee will appear as a separate line item before payment confirmation through M-PESA.
Lockpesa categorises disputes into two types:
Lockpesa governs the resolution of Order Issues for all transactions, regardless of whether Buyer Protection applies.
Complaints are only covered for transactions protected under Lockpesa Buyer Protection.
For transactions without Buyer Protection, Lockpesa only governs the following Order Issues:
Complaints arising after fulfilment must be resolved directly between the buyer and seller. Lockpesa bears no responsibility for those resolutions.
For protected transactions, Lockpesa governs:
Fulfilment-related complaints
Item-related complaints
Refunds approved by sellers or merchants are also covered.
A buyer using Lockpesa with Buyer Protection may initiate a dispute if:
The order has not yet been confirmed as fulfilled and there is an issue with the transaction.
The dispute process must be followed through the Lockpesa platform to allow Lockpesa to pause the transaction and hold funds during investigations.
Where the seller is a registered business:
Where the transaction occurs between private individuals:
This policy overrides any conflicting dispute resolution clause contained in another agreement governing the transaction.
The complaint period begins once the order is confirmed as fulfilled through any of the following:
Where a user remains unresponsive for more than 48 hours after contact attempts, Lockpesa may confirm delivery on the user’s behalf.
Once the complaint period begins, the buyer has 24 hours to file a complaint unless otherwise specified.
Buyers and sellers may report issues before fulfilment confirmation by:
The report must include a detailed explanation and any supporting evidence.
Only buyers may file complaints.
The complaint must:
Once a complaint is submitted:
Failure to follow the official complaint process may result in automatic release of funds to the seller.
If the seller fails to confirm shipment or exchange within 4 days (unless otherwise agreed), the buyer may file an Order Issue.
Lockpesa may:
Lockpesa will refund the buyer where:
Buyer Protection fees remain non-refundable.
Funds will be released to the seller where sufficient delivery evidence is provided and the buyer confirms satisfaction or remains inactive for 24 hours.
If a service was started but not completed by the agreed date, the buyer may file an Order Issue.
Lockpesa may request:
Lockpesa may:
Funds may be partially released to the seller for completed portions of work.
A package is considered lost if no tracking updates occur for 5 days after elapse of transaction period specified.
If confirmed lost:
If a buyer refuses delivery, they must report it immediately.
Lockpesa may refund the item price where:
Shipping fees and Buyer Protection fees remain non-refundable.
If a seller falsely confirms handover, the buyer must file a complaint within the complaint period.
Lockpesa may request:
Refunds may be issued where sufficient proof of successful handover is not provided.
If an item arrives visibly damaged:
Buyers may be asked to provide:
Where evidence confirms damage:
If tracking shows delivery to the wrong address (excluding buyer mistakes), the buyer must file a complaint promptly.
Where confirmed:
Sellers remain responsible for courier claims.
It is the responsibility of the Buyer to protect their release code to prevent unauthorised release of funds to the Seller. Entry of the code makes the transaction valid and complete and the Buyer is not eligible to refunds and complaints to Lockpesa will not be considered. At this stage, Lockpesa will only assist with investigation by government agencies including providing transaction details and details of the Seller.
Sellers are responsible for ensuring that the Item they send or hand over accurately matches the listing description and illustration. Any defects or issues must be clearly disclosed prior to shipment, delivery, or handover. If the buyer believes that the item does not match the description made by the seller, the buyer must file a complaint.
Once a complaint is filed, Lockpesa Support will initiate a dispute investigation (10.5). During the investigation, Lockpesa may:
Lockpesa will evaluate the evidence provided by both parties on a case-by-case basis, striving to reach a fair and impartial decision for both the buyer and seller. If the complaint is deemed valid:
(Custom-made items, all services including digital services, and items that cannot be returned for technical or hygienic reasons outside of the buyer’s control):
In the specific situation where the item is determined to be counterfeit, and the fact was not disclosed to the buyer before shipment or exchange:
Lockpesa defines a counterfeit item as any item that has been illegally replicated, imitated, reproduced, or manufactured, or that is falsely represented by the seller as being made, authorised, or endorsed by a legitimate brand. This includes unauthorised replicas, fake branded goods, and items that use protected trademarks, logos, or packaging without proper authorization.
Except in situations where the item is determined to be counterfeit, the complaint will be deemed invalid if Lockpesa determines that the Item has been tampered with, used, modified, or altered by the buyer in any way.
Lockpesa is not liable for any loss incurred by the seller or merchant when the item was determined to be “Not as Described”.
When a buyer files a dispute on a transaction with Lockpesa Buyer Protection, Lockpesa initiates a dispute investigation. Lockpesa may contact the buyer and the seller via email, SMS, phone call, or in-app communication to request additional information and evidence, as detailed in each dispute reason section (10.4). This may include business agreements, quotations, images or videos relative to the transaction, proof of recorded or courier delivery, expert statements, police reports, CCTV footage, M-PESA transaction confirmations, and/or any correspondence or other documentation related to the transaction.
For disputes involving courier-delivered items, Lockpesa may also contact the courier company for verification.
Lockpesa does not cover the cost of obtaining the requested evidence and does not facilitate its collection.
For transactions initiated through a partner platform, Lockpesa Support may consult the platform for assistance in the investigation. In certain cases, Lockpesa may delegate the dispute resolution process to the platform itself, provided the platform is neither the Buyer nor the Seller in the disputed transaction.
If the buyer claims that the item received is “Not as Described” for a transaction conducted via a partner platform, Lockpesa will refer to the platform’s terms of service and supporting documentation when assessing the claim. A final decision will be made in good faith based on the available evidence and documentation.
Both the buyer and the seller are expected to actively cooperate during the dispute process. Failure to respond within 24 hours of being contacted by Lockpesa will be interpreted as final acceptance of the opposing party’s claim.
While Lockpesa aims to resolve disputes promptly, each party will be given a fair and reasonable period to collect and provide their supporting evidence. Both the buyer and the seller acknowledge and agree that the complaint investigation may take up to 7 days to complete, and that the payment amount will be retained by Lockpesa during the entire investigation. No refund to the buyer or release of funds to the seller will be processed until the investigation is concluded.
If a buyer initiates a reversal request through M-PESA or another payment provider, Lockpesa may close its internal dispute investigation and handle the matter directly with the relevant payment provider. If the dispute is decided in Lockpesa’s favour, the buyer will not be eligible for a refund.
In certain situations, the buyer may have the ability to cancel their complaint independently. Similarly, the seller may have the ability to accept the complaint independently. It is expressly understood that:
Consequently, the transaction will be definitively concluded without any possibility of opening a further dispute for the same item.
Except where the buyer and seller have independently resolved a dispute, Lockpesa reserves the right to investigate, mediate, and determine responsibility for disputes arising from transactions completed through the platform. Any determination made by Lockpesa after reviewing the evidence submitted by both parties shall be considered final and binding, and both parties agree to comply with the outcome.
If the seller fails to respond to the Lockpesa Support Team within 48 hours during an active dispute investigation, the dispute may automatically be resolved in favor of the buyer unless Lockpesa grants an exceptional extension due to special circumstances.
If the buyer fails to respond to the Lockpesa Support Team within 48 hours during an active dispute investigation, the dispute may automatically be resolved in favor of the seller unless Lockpesa grants an exceptional extension due to special circumstances.
Once a final decision has been reached, both parties will receive notification through email or the registered mobile number linked to their M-PESA transaction. Where a dispute is resolved in favor of the buyer, the buyer may be required to return the item to the seller before any refund is processed in accordance with Section 10.6.
Lockpesa reserves the right to temporarily suspend or permanently terminate accounts involved in fraudulent activity, abuse of the escrow system, misuse of M-PESA payments, chargeback fraud, or conduct that violates the principles of fairness, honesty, and good faith.
To protect users and maintain the integrity of the Lockpesa escrow platform, all deposits made through M-PESA, including STK Push payments facilitated by Teelpay Technologies Ltd, may be subject to a temporary holding period of up to one hundred and twenty (120) minutes before the funds become fully available for transactions, withdrawals, transfers, or releases.
This temporary restriction is implemented as a fraud prevention and compliance measure intended to protect both registered and non-registered users from unauthorized transactions, payment reversals, social engineering scams, account compromise, suspicious financial activity, and fraudulent deposits initiated without the genuine consent of the payer.
