GUMBULI ONLINE MARKET LIMITED

Gumbuli Online Market Limited ("Gumbuli", "we", "us", "our") operates an online multi-vendor marketplace at www.gumbuli.com. These Payment and Inspection Policies govern all financial transactions and product quality control procedures conducted through the platform.

These policies apply to all registered buyers and sellers who use the Gumbuli platform, and form part of the binding agreement between Gumbuli and its users alongside the Terms and Conditions, Refund Policy, Vendor Policy, and Privacy Policy.

All payments on the Gumbuli platform are processed securely through OneKhusa — a Reserve Bank of Malawi licensed Payment System Operator (PSO). OneKhusa connects all major payment methods in Malawi including mobile money and bank transfers via the NATSWITCH interbank network.

1. Buyer browses products on gumbuli.com and proceeds to checkout.
2. At checkout, buyer selects their preferred payment method and confirms the order.
3. The system generates a unique Timed Account Number (TAN) via the OneKhusa payment gateway.
4. The TAN is displayed to the buyer with the exact amount payable and a 15-minute countdown timer.
5. The buyer sends the exact order amount to the TAN using their Airtel Money, TNM Mpamba, or bank app.
6. OneKhusa confirms receipt of payment and notifies Gumbuli automatically.
7. The order status is updated to "Payment Confirmed" and the seller is notified to prepare and submit the product.
8. Gumbuli holds the payment in escrow until the product passes inspection and is confirmed delivered.

• Expiry: Each TAN expires 15 minutes after generation. If the buyer does not pay within 15 minutes, the TAN expires and the order is cancelled automatically.
• Single Use: Each TAN is unique to one order and can only be used once. Do not use a TAN from a previous order.
• Exact Amount: The buyer must pay the exact amount displayed. No partial payments are accepted.
• No Sharing: Do not share your TAN with any third party. Gumbuli will never ask for your TAN via phone, email, or WhatsApp.
• Regeneration: If your TAN expires, contact Gumbuli support via WhatsApp to request a new TAN for your order.

Gumbuli operates an escrow-style payment system to protect both buyers and sellers:

• Your payment is held securely by Gumbuli from the time of payment until your product passes inspection and is confirmed delivered.
• If your product fails inspection or the seller fails to submit within the deadline, your full payment is refunded within 3–5 working days.
• Your money is never released to the seller until you have received a product that matches your order.

• Payment is confirmed to the seller once the buyer's payment is received by Gumbuli via OneKhusa.
• Seller payout (sale price minus 3.5% commission) is processed within 3–5 working days after successful delivery confirmation.
• No payment is released to the seller if the product fails inspection or if a valid buyer complaint is upheld.

Example: A buyer purchases a laptop for MK 80,000. The Buyer Protection Fee is MK 2,500. The payment processing fee is 1.5% (MK 1,200). Total paid by buyer: MK 83,700.

If the product fails inspection:

• Refunded to Buyer: MK 80,000 (product price) − MK 1,200 (1.5% processing fee) = MK 78,800
• NOT Refunded: MK 2,500 (Buyer Protection Fee) + MK 1,200 (1.5% Payment Processing Fee) = MK 3,700

The buyer receives a net refund of MK 78,800 within 3–5 working days.

• Commission Deduction: Gumbuli deducts 3.5% commission from the sale price before paying the seller.
• Payout Method: Seller payouts are made via Airtel Money, TNM Mpamba, or bank transfer to the account registered by the seller during onboarding.
• Payout Timeline: Payouts are processed within 3–5 working days after successful delivery confirmation.
• Minimum Payout: There is no minimum payout threshold — all completed order amounts are paid out.
• Payout Disputes: Sellers who dispute a payout calculation must raise the issue within 7 days of receiving the payout notification.
• Failed Payouts: If a payout fails due to incorrect seller account details, the seller must update their account information. Gumbuli is not responsible for payouts sent to incorrect details provided by the seller.

• Sellers who submit products that fail inspection receive NO commission and NO payment.
• Sellers cannot claim a "loss" or request a partial payout for failed submissions.
• Sellers are responsible for the full value of products that fail inspection — Gumbuli does not compensate sellers for losses.
• Sellers can minimise inspection failures by accurately describing products, disclosing all defects, and ensuring products are genuine and not on credit.

If a seller believes their payout amount is incorrect, the following process applies:

• Disputes raised after 7 days of the payout notification will not be considered.
• Sellers must provide supporting evidence (order confirmation, delivery confirmation, listing screenshots) when raising a dispute.
• Gumbuli will not entertain verbal or WhatsApp-only payout disputes — all disputes must be submitted in writing to support@gumbuli.com.

If a product passes inspection and is dispatched to the courier collection point, but the buyer fails to collect it within the 3-day window, the following additional provisions apply:

• Product confirmed dispatched but not returned: Gumbuli will investigate the status of the product with the courier. If the product is confirmed lost or unaccounted for by the courier, Gumbuli will pursue the courier for compensation. The seller will receive their payout (minus 3.5% commission) once the courier matter is resolved.
• Product returned to Gumbuli after failed delivery: The product becomes Gumbuli's property after 14 days as per section 2.7A.3. The seller receives NO payout in this scenario as the sale was not completed.
• Buyer abandons collection (no contact): If a buyer simply abandons their order and the product is returned to Gumbuli, the seller receives NO payout. The inspection and dispatch services were rendered, but the sale was not completed through no fault of the seller. Gumbuli will handle the product at its discretion.
• Seller's remedy: Sellers who lose a payout due to buyer non-collection may re-list the returned product on Gumbuli at no additional cost, provided the product is returned and remains in its inspected condition.

• Gumbuli monitors all transactions for fraudulent activity and reserves the right to suspend accounts and withhold payments pending investigation.
• Buyers or sellers who engage in fraudulent payment activity will be permanently banned and may be reported to relevant authorities.
• Gumbuli will never ask for your mobile money PIN, bank password, or any other sensitive financial credentials via phone, email, or WhatsApp.
• If you suspect fraudulent activity on your Gumbuli account, contact us immediately via WhatsApp or email at support@gumbuli.com.

Mobile money reversals are a known risk in Malawi's payment environment. The following policy applies when a buyer initiates a reversal or chargeback after payment has been confirmed:

• Reversal after payment confirmed: Once OneKhusa confirms receipt of payment and the order status is updated to "Payment Confirmed," the buyer's payment obligation is complete. Any reversal or chargeback initiated by the buyer after this point is considered fraudulent and will be treated accordingly.
• Immediate order suspension: If a reversal is detected, the order will be immediately suspended and the product will NOT be dispatched until the payment matter is resolved.
• Seller protection: Sellers will NOT be penalised for order delays caused by buyer-initiated reversals. The 72-hour submission deadline is suspended while a reversal investigation is ongoing.
• Buyer account action: A buyer who initiates an unjustified reversal will have their account suspended immediately. If the reversal is confirmed fraudulent, the buyer will be permanently banned and the matter referred to OneKhusa and relevant authorities.
• Legitimate reversal disputes: If a reversal was initiated due to a genuine technical error (e.g. wrong amount deducted, duplicate charge), the buyer must contact support@gumbuli.com with the OneKhusa transaction reference within 24 hours. Gumbuli will investigate and resolve within 5 working days.
• Gumbuli's liability: Gumbuli is not liable for losses resulting from reversals initiated by buyers through their mobile network operators or banks where such reversals are outside Gumbuli's or OneKhusa's control.

If a buyer or seller suspects their Gumbuli account has been accessed without their authorisation, the following applies:

• Immediate reporting: The account holder must report the suspected takeover immediately to support@gumbuli.com and via WhatsApp with their registered email address and details of the unauthorised activity.
• Account freeze: Gumbuli will freeze the affected account within 24 hours of a verified takeover report, preventing any further orders, listings, or payouts until the account is secured.
• Fraudulent orders placed during takeover: If fraudulent orders were placed on a buyer's account during the takeover, Gumbuli will work with OneKhusa to investigate and where possible reverse or refund the transactions. However, Gumbuli cannot guarantee recovery of funds where payment has already been processed and the product dispatched.
• Payouts redirected during takeover: If a seller's payout was sent to an unauthorised account during a takeover, Gumbuli will investigate and where possible re-issue the payout. Gumbuli's liability is limited to the payout amount of the specific orders affected.
• Account holder responsibility: Account holders are responsible for maintaining the security of their login credentials, email, and registered mobile number. Gumbuli is not liable for losses resulting from account takeovers caused by the account holder's own negligence (e.g. sharing passwords, responding to phishing messages).
• Account reinstatement: After a takeover is resolved and security is confirmed, Gumbuli will reinstate the account within 3 working days.

The Gumbuli Inspection Policy governs the physical quality control process that every product on the platform must pass before being dispatched to the buyer. This policy applies to all sellers and all products listed and sold on gumbuli.com without exception.

• Products are held securely at the Gumbuli Lilongwe office.
• Inspection will proceed as soon as capacity allows, but not exceeding 72 hours for standard items or 5 working days for high-value electronics.
• If inspection is delayed beyond these periods due to Gumbuli operational issues, the seller may request cancellation and product return without penalty.
• Sellers may request a status update on their submitted product at any time by contacting support@gumbuli.com or WhatsApp.

Upon receiving an order notification, the seller has 72 working hours to physically deliver the product to the Gumbuli Lilongwe office. Working hours are Monday to Friday, 08:00 to 17:00 CAT, excluding public holidays.

• Order Reference: Bring the order reference number (found in the order notification email).
• Matching Product: Deliver the exact product listed — correct model, colour, size, quantity, and specification.
• Accessories: Include all accessories, manuals, chargers, and other items listed in the product description.
• Packaging: Products should be reasonably packaged to prevent damage during inspection and dispatch.
• Condition: Products must be in the condition stated in the listing (new, used, refurbished etc.).
• Authenticity: Products must be genuine and not counterfeit. Counterfeit products will be rejected and the seller may be permanently banned.

• Accurate Product Descriptions: All product descriptions must be truthful, accurate, and complete.
• Defect Disclosure: Sellers MUST disclose all defects, damage, or issues they are aware of. Knowingly hiding defects is a violation and results in account suspension or permanent ban.
• Condition Representation: Used items must be clearly marked as "used" and accurately described. Selling a used item as "new" will result in inspection failure and account penalties.
• Complete Information: All specifications (brand, model, colour, size, storage, RAM, battery health) must be exact and verifiable.

• Genuine Products Only: All products must be 100% genuine and not counterfeit. Counterfeit products result in immediate account ban.
• Ownership & Legal Right: Seller warrants that they own the product and have full legal right to sell it. Products must not be stolen, on credit, or subject to any lien or encumbrance.
• No Restricted Goods: Products must not be on any prohibited list and must comply with Malawi law.

• IMEI & Serial Numbers: Seller warrants that IMEI and serial numbers are legitimate and match the device. Devices must not be reported as stolen or blacklisted.
• Activation Locks Removed: Seller warrants that all activation locks (iCloud, Google, Samsung Account, etc.) have been removed or credentials provided to buyer.
• No Finance/Credit: Seller warrants that the device is not subject to any credit, hire purchase, lease, or financing agreement.
• Network Unlocked: Seller warrants that devices are not SIM-locked or carrier-locked unless explicitly disclosed.
• Warranty Status Accurate: If claiming warranty coverage, seller warrants that warranty documentation is legitimate and the device is eligible for warranty.

• Intentional Misrepresentation: Account suspended pending investigation; may result in permanent ban.
• Repeated Inspection Failures: Sellers may be required to undergo additional quality assurance checks or have their account suspended.
• Fraudulent Activity: Account permanently banned and may be reported to authorities.
• No Commission on Failed Submissions: Sellers receive zero commission and no payment if their product fails inspection.

For ANY product listed as "new," Gumbuli reserves the absolute and unqualified right to:

• Open the original packaging to inspect the product contents
• Remove product from packaging to verify authenticity, serial numbers, and condition
• Test the product to confirm it is genuinely new and functional
• Inspect all accessories and components listed as included
• Verify manufacturing date, serial numbers, and authenticity markers
• Check for evidence of previous use (dust, scratches, signs of opening, battery residue)

This right applies to ALL new products, regardless of the seller's history or reputation. Sellers cannot opt out or request exceptions.

• Authenticity Verification: Many counterfeit products are sold in authentic-looking packaging. Opening the box is the only way to verify the actual product inside is genuine.
• Condition Verification: Unopened boxes can hide damage, used items, or wrong items inside.
• Buyer Protection: Unpacking during inspection ensures buyers receive genuinely new products as advertised.
• Fraud Detection: Counterfeiters often use original packaging with counterfeit contents. Inspection catches this.

• Professional Repacking: Products are repacked in a clean, professional manner using new packaging materials.
• All Contents Included: All original items, accessories, documentation, and components are included in the repacked box.
• Protective Packaging: Products are wrapped with protective materials to prevent damage during courier transit.
• Sealed Packaging: Repacked products are sealed with Gumbuli tape/sticker for security.
• Inspection Label: A "Gumbuli Inspected & Verified" label is applied to the repacked box.
• No Damage from Unpacking: If damage occurs during Gumbuli's inspection, it is treated as a product failure and buyer is refunded.

• The product is genuinely new and has never been opened or used.
• The product is in original manufacturer packaging or factory-sealed packaging.
• All original components, accessories, and documentation are present and unused.
• The seller consents to Gumbuli unpacking the product to verify authenticity.
• The seller accepts that Gumbuli may repack the product before dispatch.
• There are no hidden defects, cosmetic issues, or damage inside the packaging.

If during unpacking, Gumbuli discovers that a product listed as "new" is used, counterfeit, missing components, damaged, or refurbished — the product AUTOMATICALLY FAILS inspection, and:

• Buyer receives full refund (minus inspection fee and OneKhusa fee)
• Seller receives zero commission
• Strike is recorded against seller's account
• If counterfeit, seller faces immediate account ban and referral to authorities

Gumbuli bears the cost of repacking materials and labour. However: sellers accept that their original packaging may not be reused if damaged during opening, and repacked products are in professional Gumbuli packaging.

When a buyer receives a Gumbuli "Inspected & Verified" repacked product marked as "new," they can be confident that the product is genuinely new, all components are authentic and included, it has been physically verified by Gumbuli staff, it is not counterfeit, and if it's not as claimed, the buyer is fully refunded.

• The buyer is immediately notified via email and WhatsApp that their product has been verified and is being dispatched.
• The product is professionally packaged and dispatched to the buyer's chosen courier collection point.
• The seller receives a pass notification confirming the product has been dispatched.
• Seller payout is scheduled for processing within 3–5 working days after delivery confirmation.

• The seller is immediately notified with a detailed written explanation of the failure reason(s), supported by inspection photos.
• The buyer is immediately notified and offered: (a) full refund within 3–5 working days; (b) wait for seller to resubmit (24 additional working hours); or (c) choose an alternative product.
• The failed product is held at the Gumbuli office for 7 days for the seller to collect. After 7 days, uncollected products become the property of Gumbuli.
• A failed inspection is recorded as a strike against the seller's account.

Strikes are recorded for: (a) product failing inspection; (b) missing the 72-hour submission deadline; (c) submitting a different product from the one ordered; (d) submitting counterfeit or illegal goods.

Sellers may appeal a strike decision by submitting a written appeal to support@gumbuli.com within 5 working days. Gumbuli management will review and respond within 5 working days.

• Buyer Responsibility: Buyer must provide a correct, reachable delivery address at checkout.
• Address Changes: If buyer needs to change address after payment, they must contact Gumbuli WhatsApp immediately BEFORE dispatch. Changes cannot be made after dispatch.
• Unreachable Address: Courier will attempt re-delivery for up to 3 days. If unsuccessful, the package returns to Gumbuli.
• Failed Deliveries: If delivery fails due to buyer being unavailable, Gumbuli will hold the product for 14 days. After 14 days, the product becomes the property of Gumbuli.

This rule exists to protect sellers who have fulfilled all their obligations — submitting the product on time and passing inspection. It would be unfair to hold a seller's payout indefinitely because of a buyer's failure to collect.

• Collection Window: Buyers must collect from the courier collection point within 3 working days of notification. Failure to collect within 3 working days automatically triggers seller payout and forfeits the buyer's right to any refund or complaint. See full details in the 3-Day Collection Rule section immediately above.
• Re-delivery Attempts: Courier will make up to 3 re-delivery attempts over 3 days after a missed collection.
• Returned Products: If a product is returned to Gumbuli due to failed delivery, buyer may request a refund or re-dispatch (buyer may incur additional courier fee).
• No Collection Within 14 Days: Product becomes Gumbuli's property and no refund will be issued.

Gumbuli dispatches products to the courier collection point addressed to the buyer. Identity verification requirements at the point of collection — including whether ID is required and whether a third party may collect on the buyer's behalf — are determined solely by the courier company and are outside Gumbuli's control. Buyers should contact their courier directly to understand what identification or authorisation is required before sending someone else to collect their order. Gumbuli accepts no responsibility for products collected by unauthorised persons where the courier releases the product without proper verification.

• Gumbuli is NOT responsible for product damage that occurs while at the courier collection point.
• If damage occurs at the courier location, the courier is responsible. Buyer should report to courier and copy Gumbuli on WhatsApp.

• Serial Number Verification: Cross-referenced against manufacturer databases where available.
• Physical Authentication Checks: Inspectors check for authentic packaging, labels, holograms, and manufacturing marks.
• Proof of Purchase Verification: Original receipts and warranty documentation verified for high-value items.
• Manufacturer Database Checks: Serial numbers verified directly with manufacturer systems where available.

• Counterfeit products automatically FAIL inspection.
• Buyer receives a full refund of the product price within 3–5 working days.
• Seller receives a strike and is referred to management for investigation.
• Repeated counterfeit submissions result in immediate permanent account ban and potential referral to authorities.

IMPORTANT: Gumbuli is NOT a returns or restocking marketplace. Once a product passes inspection and is dispatched to the buyer, the sale is final.

• Buyers CANNOT return products for change of mind, colour preference, size preference, or buyer's remorse.
• Buyers CANNOT request refunds because they expected something different from what was advertised.
• Products that match the listing description cannot be returned simply because the buyer dislikes them.

• The product received is DIFFERENT from what was inspected and dispatched by Gumbuli.
• The product was DAMAGED during courier transit in ways not visible during inspection.
• The product is BROKEN or NON-FUNCTIONAL despite being tested and passed at inspection.
• The courier delivered the WRONG product entirely.
• The product quantity received is LESS than what was dispatched.

• Order Reference Number: The original order ID
• Date of Collection: When product was collected from courier
• Photo Evidence: Clear photos of the product showing the issue/damage
• Detailed Description: Specific explanation of what is wrong with the product
• Video Evidence (Optional but Helpful): Short video showing the issue

Claims without adequate photographic evidence will be rejected.

• Buyers have a strict 24-hour window from time of collection to raise complaints.
• This window is FIRM and not extended. After 24 hours, NO complaints will be accepted.
• The 24-hour period is calculated from the time the courier notifies the buyer to collect, not from when the buyer actually collects.

Where a buyer places an order containing multiple items and one or more items fail inspection while others pass, the following policy applies:

When part of a multi-item order fails inspection, Gumbuli will immediately notify the buyer in writing with details of which items passed and which failed, and the reasons for each failure. The buyer then has 24 working hours to choose one of the following options:

• If the buyer does not respond within 24 working hours of notification, Gumbuli will default to Option A (Partial Fulfillment) — passed items will be dispatched and a proportional refund issued for failed items.
• Once the buyer selects an option, the decision is final and cannot be reversed.
• The Buyer Protection Fee is not refunded regardless of which option is chosen, as the inspection service was performed for all items.

• Sellers whose items fail inspection in a partial order receive zero commission and no payout for the failed items.
• Sellers whose items pass inspection receive their normal payout (minus 3.5% commission) for the passed items within 3–5 working days after delivery confirmation.
• A strike is recorded against the seller's account for each item that fails inspection.
• If multiple items from the same seller fail in the same order, this counts as one strike but is flagged as a pattern violation and may trigger enhanced scrutiny on future submissions.

Where Option A (Partial Fulfillment) is chosen, the Buyer Protection Fee is NOT refunded for any portion of the order. The Buyer Protection Fee covers the inspection of all items in the order, regardless of pass/fail outcome. Only the product price (minus 1.5% payment processing fee) is refunded for the failed items.

Example: A buyer orders 5 items for a total of MK 100,000. Buyer Protection Fee is MK 2,500. 3 items (MK 60,000) pass and 2 items (MK 40,000) fail. If buyer chooses Option A: Buyer receives a refund of MK 40,000 − MK 600 (1.5% processing fee on MK 40,000) = MK 39,400. The MK 2,500 Buyer Protection Fee is retained in full.

If a buyer raises a complaint about a product and Gumbuli's initial assessment determines the damage was pre-existing (i.e. present before dispatch) rather than transit damage, but the buyer disagrees, the following escalation process applies:

To raise a post-delivery complaint, buyers must contact Gumbuli via WhatsApp within 24 hours of collection, providing: (a) order reference number; (b) photos of the product received; and (c) description of the issue.

To protect sellers and the integrity of the Gumbuli platform, Gumbuli operates a progressive strike system for buyers who abuse the complaint, refund, or dispute process.

• Filing a complaint claiming damage or wrong product when the product was correctly inspected and dispatched, with no credible evidence of an issue.
• Initiating a mobile money reversal after receiving or collecting a product.
• Claiming non-delivery when courier records confirm the product was collected.
• Providing false photos or fabricated evidence in support of a complaint.
• Creating multiple accounts to circumvent a suspension or ban.
• Colluding with a seller to create false orders for the purpose of extracting refunds or commissions.

A buyer who believes a strike has been issued unfairly may appeal by submitting a written appeal to support@gumbuli.com within 5 working days of the strike being issued. The appeal must include the order reference, a clear explanation of why the strike is unjustified, and any supporting evidence. Gumbuli management will review and respond within 5 working days. The management decision is final.

The following products are strictly prohibited and will be rejected at inspection, with possible immediate seller ban and referral to authorities:

• Counterfeit goods: Any product bearing a trademark, brand name, or logo without authorisation.
• Illegal goods: Any product whose sale is prohibited under the laws of Malawi.
• Weapons: Firearms, ammunition, knives designed as weapons, or weapon components.
• Controlled substances: Drugs, narcotics, or any substance regulated under Malawi's pharmacy and poisons laws.
• Expired food: Any food product past its expiry or best-before date.
• Hazardous materials: Flammable, explosive, or dangerous materials.
• Stolen goods: Any product reasonably suspected to have been obtained through theft or fraud.
• Adult content: Any sexually explicit material or product.
• Wildlife products: Ivory, protected animal products, or items prohibited under wildlife protection laws.

Gumbuli has a strict zero-tolerance policy for electronics that are subject to credit agreements, hire purchase agreements, or any financing arrangement.

Any electronic device that has not been fully paid for by the seller — meaning it is still under a credit, hire purchase, lease, or other financing obligation — is strictly prohibited on the Gumbuli platform.

• Checking for IMEI blocking, blacklisting, or flagging on stolen/financed device databases.
• Reviewing seller declarations and accompanying documentation.
• Conducting device verification checks where technically feasible.

If during inspection it is discovered or suspected that an electronic device is on credit, hire purchase, or any financing agreement:

• The product will automatically FAIL inspection.
• The order will be immediately cancelled.
• The buyer will receive a full refund within 3–5 working days.
• The seller will receive a strike on their account.
• Gumbuli may refer the matter to relevant authorities if fraud is suspected.

By listing and submitting an electronic product to Gumbuli, the seller explicitly warrants that the device is fully owned by the seller with no outstanding credit, is not subject to any hire purchase or lease, is not blacklisted or flagged, and the seller has full legal authority to sell the device and transfer ownership.

Sellers who knowingly submit devices on credit will face immediate account suspension and permanent ban, and may be reported to law enforcement authorities.

• Photo Evidence: Gumbuli photographs every product received before and after inspection. Photos are stored for a minimum of 90 days.
• Inspection Records: All inspection results (pass/fail), timestamps, and inspector details are logged in the Gumbuli system.
• Audit Trail: A complete audit trail of every order — from payment to inspection to dispatch — is maintained for compliance and dispute resolution.
• Access to Records: Buyers and sellers may request inspection records relating to their own orders by contacting support@gumbuli.com.

In addition to the product prohibitions in section 2.8, the following seller behaviours are strictly prohibited on the Gumbuli platform and may result in immediate account suspension or permanent ban:

To maintain a fair marketplace and protect the integrity of Gumbuli's commission structure, the following pricing rules apply to all sellers:

• Accurate pricing required: Sellers must list products at their genuine selling price. Artificially inflating a product's listed price on Gumbuli while offering the same product at a lower price through direct/outside sales is a violation of this policy and of section 3.2A.
• No price manipulation to avoid commission: Sellers must not artificially inflate listed prices on Gumbuli with the intention of making the platform price appear uncompetitive, directing buyers to purchase directly and outside the platform to avoid Gumbuli's 3.5% commission.
• Consistent pricing: Where a seller sells the same product through other channels (shops, social media, other platforms), the price listed on Gumbuli must be genuinely competitive and must not be deliberately inflated relative to other channels for the sole purpose of commission avoidance.
• Price changes: Sellers may update their listed prices at any time. However, price changes do not affect orders already placed and paid for — those orders are fulfilled at the price agreed at the time of purchase.
• Consequences for pricing manipulation: Sellers found to be deliberately inflating prices to drive buyers off-platform will receive a written warning. Repeated violations will result in listing removal, account suspension, and potential permanent ban.

When products become the property of Gumbuli (as per sections 2.5.2 and 2.7A.3), Gumbuli reserves the right to determine the disposition of such products on a case-by-case basis. Gumbuli's disposition decision takes into account the product type, condition, value, and any applicable legal or regulatory considerations. Possible dispositions include but are not limited to:

• Re-listing on the platform: Gumbuli may list the product for sale on gumbuli.com at a price determined by Gumbuli. Proceeds from such sales are retained by Gumbuli.
• Donation: Products of appropriate type and condition may be donated to registered charitable organisations at Gumbuli's discretion.
• Disposal: Products that are expired, damaged, hazardous, prohibited, or otherwise unsellable will be disposed of appropriately in accordance with applicable law.
• Return to seller (at Gumbuli's discretion): In exceptional circumstances, Gumbuli may offer to return a product to the original seller. Any such return is entirely at Gumbuli's discretion and does not create an obligation or entitlement for the seller.

Neither the buyer nor the seller retains any claim or interest in a product once it has become Gumbuli's property under these policies. No compensation will be paid to any party for products disposed of by Gumbuli under this section.

Gumbuli reserves the right to update or amend these policies at any time. Changes will be communicated to registered users via email and published on www.gumbuli.com. Continued use of the platform after notice of changes constitutes acceptance of the updated policies.

These policies are governed by and construed in accordance with the laws of the Republic of Malawi. Any disputes arising under these policies shall be subject to the jurisdiction of the courts of Malawi.

To the maximum extent permitted by the laws of Malawi, Gumbuli's liability to any buyer or seller arising out of or in connection with these policies, any transaction on the platform, or the use of Gumbuli's services is subject to the following limitations:

• No liability for indirect or consequential losses: Gumbuli shall not be liable for any indirect, special, incidental, consequential, or punitive losses or damages of any kind, including but not limited to: loss of profit, loss of business, loss of income, loss of anticipated savings, loss of data, loss of goodwill, or any other economic loss — even if Gumbuli has been advised of the possibility of such losses.
• Direct losses only: Where Gumbuli is found liable, its liability is limited strictly to direct and proven losses directly caused by Gumbuli's actions or omissions in connection with the specific order or transaction in dispute.
• Maximum liability cap: Gumbuli's maximum aggregate liability to any buyer or seller in respect of any single transaction or order shall not exceed the total amount paid by the buyer for that specific order (product price + Buyer Protection Fee), regardless of the nature of the claim.
• No liability for third-party actions: Gumbuli is not liable for losses caused by the actions of third parties, including but not limited to courier companies, OneKhusa, mobile network operators, banks, or other sellers and buyers on the platform.
• Force Majeure: Gumbuli is not liable for any failure or delay in performing its obligations caused by a Force Majeure event as defined in section 3.4.

Nothing in this section limits Gumbuli's liability for death or personal injury caused by Gumbuli's negligence, or for fraud or fraudulent misrepresentation, or for any other liability that cannot be excluded or limited under the laws of Malawi.

Gumbuli Online Market Limited is VAT-registered in the Republic of Malawi. The following applies to VAT and tax obligations for all transactions on the platform:

• All prices are VAT-inclusive where applicable: All product prices listed on gumbuli.com are displayed inclusive of VAT where the seller is required by law to charge VAT. Buyers will not be charged additional VAT on top of the listed price.
• Seller's VAT responsibility: It is the seller's sole responsibility to determine whether they are required to charge VAT on their products under Malawian law, to set their prices accordingly, and to account for and remit any VAT to the Malawi Revenue Authority (MRA). Gumbuli does not collect, remit, or account for VAT on behalf of sellers.
• Gumbuli's commission and VAT: Gumbuli's 3.5% commission is subject to VAT as applicable under Malawian law. Where VAT applies to Gumbuli's commission, this is accounted for by Gumbuli directly and does not result in an additional charge to the seller beyond the stated 3.5% commission rate unless otherwise communicated in writing.

• Each seller is an independent vendor responsible for their own tax affairs, including income tax, VAT, and any other applicable taxes and levies under the laws of Malawi.
• Gumbuli does not provide tax advice to sellers. Sellers are encouraged to consult a qualified tax professional or the Malawi Revenue Authority regarding their tax obligations.
• Gumbuli may be required by law to report seller transaction data to the Malawi Revenue Authority or other regulatory bodies. By selling on Gumbuli, sellers consent to such reporting where required by law.
• Gumbuli is not responsible for any tax penalties, assessments, or liabilities incurred by sellers as a result of their activities on the platform.

CRITICAL POLICY: Gumbuli is NOT responsible for, and will NOT provide any support for, any transaction that occurs outside the Gumbuli platform — regardless of whether the product is listed on Gumbuli or not.

An "outside-platform sale" is any transaction where payment is made outside the OneKhusa payment gateway, the product is delivered directly without passing through Gumbuli inspection, or where buyer and seller agree to transact via WhatsApp, phone, SMS, in-person, or any method other than through gumbuli.com.

For ANY transaction that occurs outside the Gumbuli platform, Gumbuli accepts ZERO responsibility and will provide NO support for product quality, payment disputes, non-delivery, counterfeit products, damaged products, fraud or scams, payment recovery, or dispute resolution.

Gumbuli's entire value proposition is built on three pillars: (1) Secure Payment through OneKhusa escrow, (2) Quality Assurance through physical inspection, and (3) Dispute Resolution as a neutral arbitrator. When a transaction occurs outside the platform, ALL THREE protections are eliminated.

Sellers conducting outside sales lose fraud protection, accept full risk of non-payment, and have no recourse if buyers dispute product quality. Buyers lose the quality assurance guarantee, escrow protection, and the 24-hour post-delivery dispute window.

If a buyer or seller approaches Gumbuli with a complaint about an outside-platform transaction, Gumbuli will ask for proof that the transaction occurred through the Gumbuli platform (order ID, OneKhusa payment confirmation). If proof is NOT provided, Gumbuli will refuse to engage.

• Order ID: A unique Gumbuli order reference number (visible in order confirmation email and SMS).
• OneKhusa Payment Confirmation: Email or SMS from OneKhusa confirming payment via TAN.
• Gumbuli Inspection Report: Detailed inspection failure email with photos and failure reasons.
• Dispatch Notification: Email and WhatsApp from Gumbuli with courier details and tracking information.

Screenshots of WhatsApp conversations between buyer and seller are NOT proof of a Gumbuli platform transaction.

Any dispute shall first be referred to Gumbuli's customer service team. If unresolved within 10 working days, it shall be referred to mediation. If mediation fails, the dispute shall be resolved through arbitration in accordance with Malawian law.

• Gumbuli Response Timeline: Gumbuli customer service will respond to all dispute claims within 2 working days with initial assessment.
• Appeal Process: Either party may appeal an initial decision by submitting written appeal to support@gumbuli.com within 5 working days.
• Mediation: If dispute is unresolved after internal appeal, either party may request mediation with a neutral third party within 10 working days.

• If Gumbuli office becomes temporarily inaccessible, all 72-hour submission deadlines are automatically extended for the duration of closure, plus 3 additional working days after reopening.
• If OneKhusa or payment systems are unavailable, payment deadlines will be extended and buyers will be notified immediately.
• In case of extended Force Majeure lasting more than 7 days, Gumbuli will issue full refunds to all affected buyers and cancel all pending orders without penalty.
• All buyer and seller timelines are suspended during Force Majeure events. No party will be penalized for delays caused by Force Majeure.

• Gumbuli will NEVER ask for passwords, PINs, security codes, or sensitive credentials via WhatsApp, email, or phone.
• Gumbuli will NEVER ask for credit card details or bank account information via message.
• If you receive such requests claiming to be from Gumbuli, it is FRAUD. Report immediately to support@gumbuli.com.

• Seller Responsibility: Sellers must remove all personal data, accounts, and private files from devices before submission. Gumbuli is NOT responsible for any data loss.
• Factory Reset Requirement: For phones and computers, sellers MUST perform a factory reset before submission.
• Gumbuli's Data Handling: Gumbuli inspectors will NOT intentionally access, store, or view any personal data.
• Locked/Inaccessible Devices: If seller cannot provide unlock credentials, device automatically FAILS inspection.
• Data Protection: All devices are thoroughly wiped before dispatch to buyers. Inspection photos may be stored for 90 days for quality assurance purposes.