DISPUTE RESOLUTION POLICY

This Policy expressly does not govern the following matters, each of which is subject to a separate regime:

• (a) Direct disputes between a User and a Listed Exchanger arising from or in connection with exchange transactions — all such transactions are conducted directly between the User and the relevant Listed Exchanger and are governed exclusively by that Listed Exchanger's own terms and conditions. The Company is not a party to such transactions and accepts no liability in respect of them (clauses 2.3, 4.2(d) and 9.5 of the Terms); This exclusion concerns the underlying dispute only; a User's Category B complaint about it remains subject to Sections 5–9 of this Policy, including the time limits and inadmissibility grounds set out therein.
• (b) Data protection complaints — complaints concerning the collection, processing, storage, or disclosure of personal data by the Company are governed by the Privacy Policy and the BVI Data Protection Act.

This Policy forms an integral part of the entire agreement constituted by the Terms, in accordance with clause 2.6.4 of the Terms. In the event of any conflict or inconsistency between this Policy and the Terms, the Terms shall prevail in accordance with clause 2.5 of the Terms.

The following terms, used in this Policy, have the meanings set out below. All other capitalised terms bear the meanings ascribed to them in Section 1 of the Terms.

As a reflection of its commitment to service quality and User care, the Company operates the Dispute Assistance Service. Where a User encounters a difficulty or dispute in connection with a transaction conducted through a Listed Exchanger discovered via the Platform, the User may request the Company's assistance in communicating the issue to the relevant Listed Exchanger and seeking an amicable resolution.

The Dispute Assistance Service is provided by the Company entirely voluntarily, as an expression of goodwill, and at its sole discretion. It does not form part of the Company's contractual obligations to Users, does not create any legally binding obligation on the Company to act, continue acting, or achieve any particular outcome, and is not considered for any purpose under the Terms.

In providing the Dispute Assistance Service, the Company expressly does not:

• act as an arbitrator, mediator, adjudicator, or neutral third party in respect of any dispute;
• make binding determinations as to the facts, merits, or outcome of any dispute between a User and a Listed Exchanger;
• guarantee, represent, or warrant that any dispute will be resolved, or that any particular outcome will be achieved;
• assume any obligation of result in respect of the actions or decisions of any Listed Exchanger;
• become a party to any legal relationship between the User and the Listed Exchanger as a result of providing assistance; or
• waive or modify any exclusion of liability set out in the Terms or this Policy.

The Company's participation in dispute assistance is undertaken as a voluntary, goodwill measure only. The Company shall not be liable to any User for any loss, damage, or prejudice arising from: any decision to provide, limit, suspend, or decline dispute assistance at any time; the outcome of any communication between the Company and a Listed Exchanger; any failure by a Listed Exchanger to respond, cooperate, or comply; or any delay in the provision of assistance. The limitations and exclusions of liability set out in Section 17 of the Terms apply fully and without qualification to the Dispute Assistance Service.

This Policy covers four categories of complaint:

• Category A — Platform Complaints concern the Company's own services, including the accuracy of information displayed on the Platform, moderation of User-Generated Content (including any decision issued under clause 11.4 of the Terms), access or functionality issues, the Company's handling of a previous complaint, or any other matter relating directly to the Company's conduct;
• Category B — Exchanger Disputes concern a User's experience with a Listed Exchanger, including alleged failures to execute transactions, delivery of incorrect amounts, delays, KYC-related issues, or suspected misconduct. These matters are primarily the responsibility of the relevant Listed Exchanger and are subject to that Exchanger's own complaints procedures. The Company may, at its discretion, provide voluntary assistance in accordance with Section 4 of this Policy;
• Category C — Qualifying Breach Claims. Concern a Qualifying Breach by a Listed Exchanger, as defined in clause 21.6 of the Terms. A Qualifying Breach Claim is submitted and assessed in accordance with Section 8 of this Policy and clause 21.6 of the Terms;
• Other — covers any complaint or Claim that does not fall within Category A, Category B, or Category C, including matters not otherwise addressed in this Policy. The Company will review the description provided and, where the complaint in substance corresponds to one of Categories A, B, or C, will handle it in accordance with the corresponding provisions of this Policy.

All complaints should be submitted to the Company using the Company's email address set out in Section 14 of this Policy. A complaint may be submitted in free-form writing, or by completing the Complaint and Claim Form.

To enable the Company to assess and respond promptly, a submission should include the following:

• full name and contact details (email address; and, if a legal entity, registered name and registration number);
• a clear description of the subject matter and the relevant facts, in chronological order;
• the name and website URL of the Listed Exchanger concerned, where applicable;
• transaction details, where relevant (date, amount, currency pair, transaction reference, wallet addresses, or transaction hashes); and
• all supporting documentation reasonably available (screenshots, correspondence, transaction confirmations, and any other evidence).

Where any mandatory information is missing, the Company will notify the User and invite them to provide the missing particulars within a reasonable time. Failure to provide required information despite being requested to do so may result in the complaint being closed.

The Company will acknowledge receipt of every complaint within 15 Business Days of receipt. The acknowledgement will confirm the date of receipt, assign a reference number, and set out the applicable timelines.

The Company will assess the complaint and gather relevant information. For Category B complaints in respect of which the Company decides to provide voluntary dispute assistance, the Company may contact the relevant Listed Exchanger to obtain its response and seek to facilitate a resolution. The Company may, at its discretion, request further information from the User or consult third-party sources (including blockchain analytics tools) as it deems necessary.

The Company will use reasonable endeavours to provide a substantive response within 45 business days of the date on which the complaint is duly submitted with all required information (the "Support Review Period"), in accordance with clause 21.2.3 of the Terms. Where the Company requests additional information during the Support Review Period, that period is extended by the number of days between the request and the User's response. Where a complaint cannot be resolved within the Support Review Period, the Company will notify the User of the reason and indicate the revised expected timeframe.

On completion of the investigation, the Company will issue a written response containing: the Company's findings on the established facts; the Company's position on each element of the complaint; where applicable, any action taken or proposed; and information on further options available to the User, including the Pre-Litigation Procedure set out in Section 10 of this Policy.

The Company may decline to investigate or close a complaint without further action where:

• the complaint does not relate to the Platform or to a Listed Exchanger accessible through the Platform;
• the same complaint has already been investigated and determined;
• the matter is the subject of pending or concluded legal proceedings;
• the complaint is submitted outside the applicable time limits set out in Section 9 of this Policy;
• the User fails to provide required information or cooperation despite being requested to do so; or
• the complaint is manifestly vexatious, abusive, or submitted in bad faith.

The Company will notify the User of any inadmissibility decision, with reasons.

"Qualifying Breach" means a material failure by a Listed Exchanger in respect of a User transaction, including (without limitation):

• (a) failure to complete or deliver a confirmed exchange transaction;
• (b) delivery of a materially different amount of Crypto-Assets, fiat currency, or other property or valuables than confirmed;
• (c) confirmed fraud, scam, or misappropriation of User funds, Crypto-Assets, or other property or valuables by the Listed Exchanger;
• (d) manipulation of the outcome of a confirmed exchange transaction to the detriment of the User;
• (e) any other failure by the Listed Exchanger to honour the terms of a confirmed exchange transaction, regardless of the cause of such failure.

A Qualifying Breach Claim (a "QB Claim") may be submitted by a User who believes that a Qualifying Breach has occurred in connection with a transaction conducted through a Listed Exchanger discovered via the Platform. The definition of Qualifying Breach and the conditions of eligibility are set out in Section 1 and clauses 9.6.1–9.6.8 of the Terms. The QB Claim procedure in this Section supplements and is subject to the general Pre-Litigation Procedure in Section 10 of this Policy and clause 21.6 of the Terms.

For the avoidance of doubt:

• the Company is not a party to the transaction between the User and the Listed Exchanger;
• the existence of a Reserve Deposit does not constitute a guarantee, warranty, insurance product, or binding commitment that compensation will be paid in any case or in any amount (clause 9.6.4 of the Terms);
• Users have no direct legal claim over any Reserve Deposit, which is the absolute property of the Company following transfer (clause 9.6.1 of the Terms); and
• the determination of whether a Qualifying Breach has occurred, and whether any compensation is payable, rests exclusively with the Company in its sole and absolute discretion (clauses 9.6.5 and 21.6.6 of the Terms).

A QB Claim must be submitted no later than 45 calendar days after the date on which the User became aware, or ought reasonably to have become aware, of the alleged Qualifying Breach (clause 21.6.5 of the Terms). Any QB Claim submitted outside this period shall be inadmissible and the Company shall be under no obligation to review or consider it.

A QB Claim is submitted as a Stage 1 complaint under clause 21.2 of the Terms. In addition to the general requirements set out in Section 6 of this Policy, the submission must include the following, in accordance with clause 21.6.2 of the Terms:

• the full name and contact details of the User;
• the name of the relevant Listed Exchanger;
• a detailed description of the alleged Qualifying Breach, specifying: the date of the transaction; the amount and currency pair; the transaction reference number; and wallet addresses or transaction hashes where available; and
• all available supporting evidence, including: transaction confirmation records; screenshots of the exchange interface; correspondence with the Listed Exchanger; blockchain explorer confirmations; and any other relevant documentation;
• evidence of prior attempts to resolve the matter directly with the Listed Exchanger, including dates and substance of communications and any response received.

The Company will use reasonable endeavours to review a QB Claim within the Support Review Period (45 business days) in accordance with clause 21.6.3 of the Terms. The Company may, at its sole discretion:

• request additional documentation from the User or the relevant Listed Exchanger;
• consult third-party experts or blockchain analytics providers;
• contact the relevant Listed Exchanger for its response; and
• draw such inferences as it considers appropriate from any failure by the Listed Exchanger to cooperate.

The Company's review constitutes a good-faith factual inquiry only. It does not constitute arbitration, mediation, or any legally binding determination, and the Company assumes no obligation to reach any particular conclusion.

8.5.1. Following assessment, the Company will notify the User of its determination in writing. If the Company, in its sole and absolute discretion, determines that a Qualifying Breach has occurred and that the User is eligible for compensation (a Compensation Event within the meaning of Section 1 of the Terms), it will issue a written compensation offer specifying the amount and currency of the proposed payment.

8.5.2. Acceptance of any compensation offer is conditional upon the User executing and returning a Settlement Release in a form prescribed by the Company. The Settlement Release shall constitute a full and final settlement and release of all Claims, rights of action, and causes of action — whether known or unknown, arising in contract, tort, equity, statute, or otherwise — that the User has or may have against the Company arising out of or connected with the relevant Qualifying Breach and the subject matter of the QB Claim. Payment will not be made until the Company has received a duly executed Settlement Release. No compensation shall be paid and no Compensation Event shall be deemed to have occurred unless and until the Settlement Release has been received and accepted by the Company.

8.5.3. Neither the making of a compensation offer nor the payment of any compensation sum shall operate as a release or satisfaction of any Claim unless and until a Settlement Release has been duly executed by the User, delivered to, and accepted by the Company. The principle of accord and satisfaction under BVI common law shall not arise solely from payment without an executed Settlement Release.

8.5.4. Where the User accepts a compensation offer and executes the Settlement Release, the Company shall effect payment of the agreed sum within 30 Business Days of the date on which it receives the duly executed Settlement Release. This obligation is not subject to the general discretion set out in clause 9.6.6 of the Terms, which applies solely prior to the issuance and acceptance of a compensation offer.

8.5.5. The amount of any compensation will be determined having regard to such factors as the Company considers relevant, including: the nature and severity of the breach; the User's documented loss; the remaining Reserve Deposit balance; any competing claims; and applicable law (clause 9.6.6 of the Terms). Where multiple QB Claims are submitted in respect of the same Listed Exchanger's Reserve Deposit and the aggregate eligible claims exceed the remaining balance, the Company may allocate available funds on a pro rata basis or on such other basis as it determines in its sole discretion (clause 21.6.4 of the Terms).

8.5.6. The User is not obliged to accept any compensation offer. Declining an offer does not affect the User's right to escalate to Stage 2 of the Pre-Litigation Procedure in accordance with Section 8.7 and Section 10.3 of this Policy.

The Company is under no obligation to investigate, assess, or pay any QB Claim (clause 9.6.7 of the Terms). Without limiting the foregoing, the Company may reject a QB Claim, in whole or in part, on any one or more of the following grounds:

• (a) No Qualifying Breach — the Company determines, in its sole and absolute discretion, that no Qualifying Breach within the meaning of Section 1 and clause 9.6 of the Terms has occurred in connection with the relevant transaction;
• (b) Insufficient evidence — the User has failed to provide sufficient evidence of either the alleged breach or the loss or damage claimed, and has not remedied that deficiency within a reasonable period following a request from the Company to do so;
• (c) Failure to mitigate or cooperate — the User failed to take reasonable steps to mitigate their loss, or failed to cooperate with the Listed Exchanger's own dispute resolution or complaint procedure, prior to submitting the QB Claim, without reasonable justification;
• (d) Contributory conduct — the User's own act, omission, error, breach of the Listed Exchanger's terms, or failure to exercise reasonable care contributed materially to the loss or the occurrence of the alleged breach;
• (e) Limitation — the QB Claim was submitted outside the 45-calendar-day time limit prescribed in clause 21.6.5 of the Platform Terms of Use and Section 8.2 of this Policy;
• (f) Reserve Deposit exhausted or insufficient — the Reserve Deposit of the relevant Listed Exchanger has been exhausted, or the remaining balance is insufficient to fund a payment to the User, and the Company elects in its sole discretion not to pay from other funds;
• (g) Competing claims take priority — competing QB Claims from other Users in respect of the same Listed Exchanger have been determined to take priority, whether on the basis of chronological order of submission, severity of loss, or such other criteria as the Company determines in its sole discretion; or
• (h) Legal, sanctions, or compliance reasons — payment is prohibited or restricted by applicable law, BVI sanctions obligations, AML/CFT obligations, or any order or direction of a competent Regulatory Authority.

A decision to reject a QB Claim on any of the grounds set out above shall be notified to the User in writing with reasons. Such a decision does not affect the User's right to escalate to Stage 2 of the Pre-Litigation Procedure and, thereafter, to seek judicial redress in accordance with Section 10 of this Policy.

If a QB Claim is not resolved at Stage 1 to the User's satisfaction, the User may proceed to Stage 2 by submitting a Notice of Claim in accordance with Section 10.3 of this Policy and clause 21.3 of the Terms.

9.1. Requests for Voluntary Dispute Assistance (Category B) and Qualifying Breach Claims (Category C) must be submitted within 45 calendar days of the date on which the User became aware, or ought reasonably to have become aware, of the relevant circumstances. Any other complaint or Claim may be submitted as a Stage 1 complaint at any time within the limitation period set out in clause 22.4 of the Terms.

9.2. The contractual limitation period for formal Claims against the Company is one (1) year from the date on which the cause of action first arose (or, if later, the date on which the User knew or ought reasonably to have known of the facts giving rise to it), as set out in clause 22.4.1 of the Terms. This period is subject to the mandatory limitation provisions of the Limitation Ordinance (Cap. 43) of the British Virgin Islands.

9.3. The running of the contractual limitation period is suspended (tolled) for the duration of the Pre-Litigation Procedure, commencing on the date on which the Stage 1 complaint is submitted under clause 21.2 of the Terms, and ending on the earlier of:

• (a) the date on which the Claim is resolved and a resolution is agreed by both parties in writing;
• (b) the date on which the Good Faith Negotiation Period expires without resolution; or
• (c) the date falling thirty (30) business days after the expiry of the Support Review Period referred to in clause 21.2.3 of the Terms, if no Notice of Claim has been submitted by the Claimant under clause 21.3.1 of the Terms by that date, (clauses 21.4.1, 21.6.7 of the Terms), provided that, where a Notice of Claim is submitted within the 30-business-day period referred to in sub-clause (c) above but is subsequently deemed invalid under clause 21.3.4 of the Terms, the tolling shall instead continue until the earlier of:
  • (i) the expiry of the cure period referred to in clause 21.3.4 of the Terms without a valid resubmission; or
  • (ii) the date determined under sub-clause (a) or (b) above.

The tolling mechanism applies solely to the contractual limitation period in clause 22.4 of the Terms and does not extend to any statutory limitation period under BVI law, save to the extent permitted by any non-mandatory provision of that law.

Any formal Claim by a User against the Company must be preceded by compliance with the mandatory Pre-Litigation Procedure set out in Section 21 of the Terms of Use (the "Terms"). Compliance with this procedure is a condition precedent to the commencement of any legal proceedings. The procedure consists of two consecutive stages:

• Stage 1 — submission of a written complaint to the Company's email address set out in Section 14 and a Support Review Period of 45 business days (clause 21.2 of the Terms); and, if unresolved,
• Stage 2 — submission of a formal Notice of Claim and a Good Faith Negotiation Period of 60 business days to the Company's email address set out in Section 14 (clauses 21.3–21.4 of the Terms).

Only upon the expiry or earlier completion of Stage 2 without resolution may legal proceedings be commenced in accordance with clause 22.2 of the Terms.

The Claimant must submit a written complaint to the Company's email address set out in Section 14 of this Policy, in accordance with clause 21.2.1 of the Terms. The complaint must comply with clause 21.2.2 of the Terms and Section 6 of this Policy. The Company will use reasonable endeavours to respond within 45 business days (the Support Review Period, as defined in clause 21.2.3 of the Terms). If the Claim is not resolved within that period, or if no substantive response is received, the Claimant may proceed to Stage 2 in accordance with clause 21.2.4 of the Terms.

If the Claim has not been resolved at Stage 1, the Claimant must submit a Notice of Claim in writing to the Company's email address set out in Section 14 in accordance with clause 21.3.1 of the Terms. The Notice of Claim must contain all information required by clause 21.3.2 of the Terms, including:

• the full legal name, address, and contact details of the Claimant;
• a clear and detailed description of the nature and legal basis of the Claim, including all relevant facts in chronological order and the provisions of the Terms alleged to give rise to the Company's liability;
• a precise statement of the specific relief or remedy sought, including the amount claimed (expressed in a specific currency);
• a reference to the Stage 1 complaint, including the submission date and any reference number assigned by the Company;
• copies of all documents, correspondence, and evidence relied upon; and
• where the Claim relates to a Qualifying Breach, all information required by clause 21.6.2 of the Terms.

A Notice of Claim that does not materially comply with clause 21.3.2 shall be deemed invalid and shall not trigger the Good Faith Negotiation Period. The Company will notify the Claimant of any material deficiency within 14 business days of receipt, and the Claimant may resubmit a corrected Notice within 14 business days of that notification (clause 21.3.4 of the Terms).

Following submission of a valid Notice of Claim, the Company and the Claimant shall negotiate in good faith for 60 business days (the Good Faith Negotiation Period), with a view to reaching an amicable resolution (clause 21.4.1 of the Terms). Neither party shall take any action the primary purpose of which is to obstruct, delay, or frustrate resolution (clause 21.4.2 of the Terms).

Nothing in this Policy or Section 21 of the Terms prevents the Company from seeking injunctive or other urgent equitable relief at any time from any court of competent jurisdiction (clause 21.7.1 of the Terms). A Claimant who can demonstrate immediate and irreparable harm may apply for urgent interim relief prior to completion of the Pre-Litigation Procedure (clause 21.7.2 of the Terms). The seeking or granting of such relief does not constitute a waiver of the obligation to complete the Pre-Litigation Procedure in respect of the underlying Claim.

No User is obliged to accept any outcome, decision, or proposal issued by the Company under this Policy. The Company's decisions on complaints and QB Claims are internal determinations only and do not limit a User's right to pursue legal or other available remedies.

Upon completion of the Pre-Litigation Procedure in accordance with Section 10 of this Policy and Section 21 of the Terms, and in the absence of a mutually agreed resolution, either party may commence legal proceedings before the Commercial Division of the Eastern Caribbean Supreme Court sitting in the British Virgin Islands, which has exclusive jurisdiction over such disputes (clause 22.2 of the Terms).

Nothing in this Policy, the Terms, or any Associated Document shall operate to exclude or limit any mandatory rights a User may have as a consumer under applicable law to the extent that such law is applicable to the Company under the conflict-of-laws rules binding on the Company.

Where, and only to the extent that, the Company is required under Regulation (EU) 2022/2065 (the Digital Services Act) to provide access to an out-of-court dispute settlement body, EU-resident Users may refer a dispute concerning a decision to remove, restrict the visibility of, or suspend a User's ability to submit UGC — as described in clause 11.2 of the Terms — to a certified out-of-court dispute settlement body. The Company will engage with any such body in good faith where this obligation applies.

Where no such obligation applies to the Company, disputes concerning such decisions are to be resolved through the Company's standard complaint-handling procedure set out in clause 11.5 of the Terms and Sections 7–10 of this Policy and, if unresolved, through the Pre-Litigation Procedure and the court of competent jurisdiction referred to in clause 22.2 of the Terms. In either case, this clause does not exclude or limit any mandatory right a User may have as a consumer under applicable law, nor does it affect the User's right to seek judicial redress in respect of the content moderation decision.

The Company maintains an internal register of all complaints and QB Claims received. Each entry records: the date of receipt; the complaint category and reference number; a summary of the subject matter; the current status; the outcome; and the resolution date where applicable.

Complaint records are retained in accordance with the following schedule:

• General Complaints (Category A and Category B): 5 years from the date of resolution or closure.
• Qualifying Breach Claims: 5 years from the date of final determination or settlement.

Where the applicable retention period under the BVI law has expired and records have been lawfully deleted, that expiry may constitute grounds for treating any associated complaint or claim as inadmissible for lack of documentary evidence.

All personal data processed in connection with complaints handling is processed in accordance with the Privacy Policy and the BVI Data Protection Act, 2021 (No. 3 of 2021). Complaint records are confidential and will not be disclosed to third parties except as required by law, by a competent authority, or as otherwise permitted under the Privacy Policy.

In the event of any conflict between this Policy and the Terms, the Terms shall prevail in accordance with clause 2.5 of the Terms.

The Company reserves the right to amend this Policy at any time in accordance with the amendment procedure set out in Section 19 of the Terms. The current version is published on the Platform and is dated at the head of this document.

All complaints, QB Claims, and enquiries relating to this Policy should be addressed to: