REFUND AND CANCELLATION POLICY

INTRODUCTION AND SCOPE

Purpose of this Policy

URIGHTCOMPANY FINANCE LIMITED hereinafter — the "Company", "we", "us", or "our" — maintains this Refund and Cancellation Policy to establish clear rules and procedures regarding refunds, cancellations, reversals, failed transactions, duplicate payments, unauthorized activity, chargebacks, disputes, and related customer requests.

This Policy is designed to ensure that refund and cancellation requests are handled fairly, consistently, securely, and in accordance with applicable legal, contractual, payment network, AML/CTF, sanctions, fraud prevention, and risk-management requirements.

Application of this Policy

This Policy applies to transactions and services provided by the Company, including where applicable:

• payment processing services;
• merchant payment solutions;
• card payments;
• bank transfers;
• mobile wallet payments;
• payment links;
• subscription billing;
• foreign exchange services;
• money transfer and remittance services;
• virtual currency services;
• other payment-related or digital financial services provided by the Company.

This Policy applies unless a separate written agreement between the Company and the customer, merchant, or business client provides different refund, cancellation, reversal, or dispute terms.

Relationship with Other Policies

This Policy should be read together with the Company's Terms and Conditions, AML/CTF Policy, KYC Policy, Sanctions Policy, Privacy Policy, Security Policy, and any applicable merchant, customer, or service agreement.

Refunds and cancellations may be subject to compliance review, transaction monitoring, sanctions screening, fraud prevention checks, and other controls required by the Company's AML/CTF and risk-management framework.

GENERAL POLICY

Finality of Transactions

Due to the nature of payment processing, money transfer, foreign exchange, and virtual currency services, transactions are generally final once completed, settled, executed, transmitted, or otherwise processed.

The Company does not guarantee that a completed transaction can be cancelled, reversed, refunded, recalled, or amended.

Refunds Subject to Review

Refunds may be considered only where permitted by applicable law, payment network rules, contractual terms, operational feasibility, and the Company's internal risk assessment.

Refunds are not automatic and are subject to review by the Company's operational, risk, compliance, fraud prevention, and finance functions where applicable.

No Refund for Customer Error

The Company may refuse a refund or cancellation request where the issue resulted from:

• incorrect payment details provided by the customer;
• incorrect recipient, wallet, account, or beneficiary information;
• customer failure to review transaction details before confirmation;
• customer delay in submitting a request;
• violation of the Company's Terms and Conditions;
• use of the service for prohibited or unlawful purposes;
• inability to complete required KYC, AML/CTF, sanctions, or fraud prevention checks.

Compliance Restrictions

The Company may refuse, delay, suspend, or restrict a refund where the transaction or customer relationship is subject to:

• AML/CTF review;
• sanctions screening or sanctions-related restrictions;
• fraud investigation;
• chargeback or dispute review;
• law enforcement request;
• regulatory inquiry;
• account restriction, freezing, or reporting obligation;
• suspicion of money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime.

Where disclosure is restricted by law, the Company may not be able to provide full details regarding the reason for delay, refusal, or restriction.

CANCELLATION OF TRANSACTIONS

Cancellation Before Processing

A customer may request cancellation of a transaction before the transaction has been executed, transmitted, settled, or otherwise processed.

The Company will make reasonable efforts to process a cancellation request where operationally possible. However, cancellation is not guaranteed.

Transactions Already Processed

Once a transaction has been processed, executed, transmitted, settled, or completed, it may not be possible to cancel it.

This applies especially to:

• bank transfers already submitted to banking rails;
• card transactions already authorized or captured;
• money transfers already released;
• foreign exchange transactions already executed;
• virtual currency transactions already broadcast or confirmed on a blockchain;
• transactions already credited to a recipient, merchant, account, wallet, or beneficiary.

Merchant and Subscription Cancellations

Where the Company provides payment infrastructure for merchants or subscription billing, cancellation of the underlying goods, services, subscriptions, memberships, or merchant obligations is generally governed by the merchant's own terms and conditions.

The Company may process a refund or cancellation only where authorized by the merchant, required by applicable law, required by payment network rules, or otherwise approved under the Company's internal procedures.

ELIGIBLE REFUND CASES

Refunds Considered by the Company

The Company may consider a refund request in limited circumstances, including:

• duplicate transaction caused by technical error;
• incorrect amount charged due to system error;
• transaction failure directly attributable to the Company's platform;
• service delivery failure directly attributable to the Company;
• unauthorized transaction confirmed after investigation;
• funds received by the Company in error;
• transaction rejected or not completed but funds were debited;
• refund required by applicable law, payment network rules, or written agreement.

Duplicate Transactions

Where a duplicate transaction is confirmed, the Company may refund the duplicate amount to the original payment method or account, subject to verification and compliance checks.

Technical or System Errors

Where a technical or system error directly attributable to the Company caused an incorrect charge, failed transaction, duplicate debit, or other processing issue, the Company will review the matter and may issue a refund or correction where appropriate.

Unauthorized or Fraudulent Activity

Where unauthorized or fraudulent activity is alleged, the Company may conduct an investigation before approving or denying a refund.

The customer may be required to provide supporting evidence, including confirmation that the activity was unauthorized, account access details, payment instrument information, correspondence, police reports, or other documentation where appropriate.

The Company may refuse a refund if the investigation indicates that the customer authorized the transaction, failed to secure account credentials, acted negligently, participated in fraud, violated terms, or provided misleading information.

NON-REFUNDABLE CASES

General Non-Refundable Circumstances

The Company may refuse a refund where:

• the transaction was properly authorized and completed;
• the customer changed their mind after confirmation;
• the customer provided incorrect payment, beneficiary, bank, wallet, or transaction details;
• the recipient, merchant, or beneficiary has already received the funds;
• the customer failed to submit the request within the applicable timeframe;
• the transaction involved prohibited activity;
• the refund would breach law, sanctions, payment network rules, AML/CTF obligations, or regulatory requirements;
• the customer failed or refused to complete KYC, AML/CTF, sanctions, fraud, or security checks;
• the request is unsupported, abusive, fraudulent, or inconsistent with Company records.

Fees and Charges

Unless otherwise required by law or written agreement, processing fees, network fees, bank fees, card scheme fees, foreign exchange spreads, blockchain gas fees, intermediary fees, and other third-party charges may be non-refundable.

Exchange Rate Differences

Where a refund involves a currency conversion, the refunded amount may be affected by exchange rate movements, conversion costs, spreads, bank fees, network fees, or market fluctuations.

The Company is not responsible for losses caused by changes in exchange rates, virtual asset prices, or third-party charges unless the loss was directly caused by the Company's error.

REFUND REQUEST PROCEDURE

Submission of Request

To request a refund, the customer must submit a written request to the Company at:

[email protected]

The request should include:

• customer name or business name;
• account or customer reference, where applicable;
• transaction ID or payment reference;
• transaction date;
• transaction amount and currency;
• payment method used;
• reason for the refund request;
• supporting evidence, where applicable;
• contact information of the requester;
• confirmation of authority to act on behalf of the customer, where applicable.

Timeframe for Refund Requests

Refund requests should be submitted within seven (7) business days from the transaction date, unless a different timeframe applies under applicable law, payment network rules, or a written agreement.

Requests submitted after this period may be rejected, especially where the transaction has already been settled, released, converted, transmitted, withdrawn, or otherwise completed.

Additional Information

The Company may request additional information or documentation to assess the refund request.

Failure to provide requested information within a reasonable period may result in rejection, delay, suspension, or closure of the refund request.

REVIEW AND DECISION

Review Process

Refund requests are reviewed by the relevant Company functions, which may include operations, customer support, finance, risk, fraud prevention, and compliance teams.

The Company may verify:

• transaction status;
• payment method;
• customer identity and authorization;
• KYC status;
• fraud indicators;
• sanctions exposure;
• technical logs;
• merchant or beneficiary status;
• settlement or transfer status;
• applicable contractual terms;
• legal, regulatory, and payment network requirements.

Decision

Following review, the Company may:

• approve the refund in full;
• approve a partial refund;
• reject the refund request;
• request additional information;
• suspend the decision pending compliance, fraud, sanctions, or regulatory review;
• restrict or freeze funds where required by law;
• escalate the matter to the Compliance Officer / MLRO.

Notification

The Company will notify the customer of the decision where permitted by law.

Where the refund request is connected to an AML/CTF, sanctions, fraud, law enforcement, or regulatory review, the Company may be restricted from providing full details.

Processing Time

If a refund is approved, the Company will use reasonable efforts to process it within ten (10) business days after approval.

Actual receipt of funds may depend on banks, payment processors, card networks, blockchain networks, intermediaries, or other third parties and may take longer.

METHOD OF REFUND

Original Payment Method

Where possible, refunds will be made to the original payment method, bank account, card, wallet, or source from which the original transaction was made.

Closed Loop Principle

In accordance with fraud prevention, AML/CTF, and risk-management standards, the Company may require refunds, withdrawals, or redemptions to follow the "Closed Loop" principle, meaning funds are returned to the same payment method or account used for the original transaction.

Alternative Refund Method

The Company may approve an alternative refund method only where the original method is unavailable, legally permissible, operationally feasible, and approved through risk-based review.

Additional KYC, AML/CTF, sanctions, or fraud prevention checks may be required before an alternative refund method is used.

VIRTUAL CURRENCY TRANSACTIONS

Irreversibility of Virtual Currency Transactions

Virtual currency transactions are generally irreversible once broadcast, validated, confirmed, or recorded on a blockchain or distributed ledger.

The Company does not guarantee that a virtual currency transaction can be cancelled, reversed, refunded, or recovered.

Eligible Virtual Currency Refunds

A virtual currency refund may be considered only in limited circumstances, including:

• virtual currency received by the Company in error;
• duplicate transaction caused by Company system error;
• technical issue directly attributable to the Company;
• transaction rejected by the Company before completion;
• refund required by applicable law or written agreement.

Network Fees and Market Fluctuations

Virtual currency refunds may be subject to:

• blockchain gas fees;
• network fees;
• miner or validator fees;
• exchange rate fluctuations;
• market value fluctuations;
• wallet or intermediary fees.

The refunded amount may differ from the original value due to market movement or network costs.

High-Risk Wallets and Compliance Review

The Company may refuse, delay, or restrict a virtual currency refund where the wallet, transaction, source of funds, or destination is associated with:

• sanctioned wallets;
• mixers or tumblers;
• darknet markets;
• ransomware;
• fraud;
• stolen assets;
• terrorism financing;
• high-risk or illicit activity;
• anonymity-enhancing technologies;
• suspicious or unverifiable ownership.

CHARGEBACKS AND DISPUTES

Chargeback Process

Where card payment networks or acquiring banks provide a chargeback process, chargebacks may be governed by the applicable rules of the relevant payment network, bank, processor, or acquirer.

The Company may cooperate with chargeback investigations and may provide transaction records, authorization evidence, KYC information, fraud indicators, delivery records, or other relevant documentation where permitted by law.

Improper Chargebacks

Improper, abusive, fraudulent, or bad-faith chargeback attempts may result in:

• suspension or restriction of services;
• termination of the customer relationship;
• recovery of losses, fees, penalties, or administrative costs;
• reporting to payment partners, regulatory authorities, or law enforcement where appropriate;
• legal action where necessary.

Merchant Disputes

Where the Company acts as a payment service provider, payment processor, or payment infrastructure provider, the Company is not the seller or supplier of the underlying goods or services and is not responsible for the quality, delivery, legality, cancellation, or performance of the merchant's products or services.

Such disputes should generally be resolved directly between the customer and the relevant merchant, unless otherwise required by applicable law, payment network rules, or a written agreement.

COMPLIANCE, FRAUD, AND SANCTIONS REVIEW

Compliance Review

Refunds, cancellations, reversals, withdrawals, and disputes may be subject to compliance review under the Company's AML/CTF Policy, KYC Policy, Sanctions Policy, and fraud prevention procedures.

Suspicious Activity

Where the Company has reasonable grounds to suspect that a refund, cancellation, reversal, withdrawal, chargeback, or dispute may be connected to money laundering, terrorist financing, sanctions evasion, fraud, account takeover, mule activity, or other financial crime, the matter will be escalated to the Compliance Officer / MLRO.

Reporting and Non-Disclosure

Where required, the Company may file reports with FINTRAC or other competent authorities.

The Company and its employees will not disclose to any customer or third party that a report has been filed, that a report is being considered, or that an AML/CTF, sanctions, fraud, or compliance investigation is underway, where such disclosure is prohibited by law.

EXCEPTIONS

Written Agreement

This Policy may be modified by a separate written agreement between the Company and the customer, merchant, or business client.

Any exception must be documented in writing and approved by the Company.

Legal Requirements

Nothing in this Policy limits any rights or obligations that cannot be excluded under applicable law.

Where applicable law, payment network rules, court orders, regulatory requirements, or sanctions obligations require a different outcome, those requirements will prevail.

POLICY REVIEW AND UPDATES

Periodic Review

This Policy is reviewed periodically to ensure alignment with applicable laws, payment network rules, regulatory expectations, business operations, products, services, technology, and the Company's risk profile.

Publication of Updates

The Company may amend this Policy from time to time. The latest version will be published on the Company's website with a revised effective date.

CONTACT INFORMATION

For refund, cancellation, dispute, or payment-related inquiries, please contact:

• Email: [email protected]
• Address: 1 - 4903 54 STREET, LLOYDMINSTER, SASKATCHEWAN, CANADA, S9V 0N6
• Regulatory Reference: FINTRAC MSB Registration #C100000462