Refund & Cancellation Policy

1. Overview

This Refund and Cancellation Policy (the “Policy”) establishes the framework, principles and procedures governing refund requests, trade cancellations and complaints for all clients of Glacierpay Inc. (“Glacierpay”, the “Company”, “we”, “us” or “our”), a corporation incorporated under the laws of the Province of Ontario, Canada. “Client” means a corporate, institutional or professional business client that has been onboarded to use Glacierpay's services; Glacierpay does not serve consumers.

Digital asset transactions are inherently irreversible once broadcast to the blockchain. Unlike traditional financial transactions, cryptocurrency transfers cannot be recalled, reversed or charged back by any party — including the Company. This fundamental characteristic of blockchain technology necessitates a clear and comprehensive policy that protects both Glacierpay and its Clients.

Glacierpay is committed to fair and transparent dealings with all Clients. Where a legitimate error attributable to the Company has occurred, Glacierpay will investigate promptly and, where appropriate, issue a refund in accordance with the terms set forth herein.

This Policy should be read in conjunction with the Glacierpay Terms and Conditions (available at /legal/terms-and-conditions), which govern trade execution, finality and dispute resolution, and with the applicable Fee Schedule. In the event of any inconsistency between this Policy and the Terms and Conditions, the Terms and Conditions prevail.

2. General Principle — Trade Finality

2.1 Irreversibility of Digital Asset Transactions

All executed trades are final and non-refundable. This principle reflects the fundamental nature of blockchain technology and applies without exception to the following:

• Once a digital asset transaction has been broadcast to the applicable blockchain network, it cannot be reversed, recalled or cancelled by Glacierpay or any other party;
• Once a fiat-to-crypto or crypto-to-fiat trade has been confirmed as “Executed” in the Company's systems, the trade is final;
• Glacierpay does not guarantee, control or have the ability to influence blockchain confirmation times, network congestion, or the actions of miners or validators;
• The Company has no ability to reverse, freeze or intercept digital asset transfers once they have left the Company's custodial infrastructure.

2.2 Client Acknowledgement

As part of the onboarding process and prior to executing any trade, all Clients acknowledge in writing that:

• Digital asset transactions are irreversible once broadcast;
• The Client is solely responsible for providing accurate wallet addresses and transaction details;
• Market price movements do not constitute grounds for a refund;
• The Client has read, understood and accepted this Refund and Cancellation Policy.

3. When Refunds May Be Issued

Glacierpay may, at its sole discretion and following investigation, issue a refund in the following limited circumstances. Each case is reviewed individually by the Compliance team, and the issuance of a refund in one instance does not create a precedent or entitlement for any future claim.

3.1 Glacierpay Operational Error

A refund may be issued where a demonstrable error attributable to Glacierpay has occurred, including but not limited to:

• Incorrect amount: The Company sent a digital asset amount or fiat amount materially different from the confirmed trade details;
• Wrong asset delivered: The Company delivered a digital asset other than the asset specified in the trade confirmation;
• System malfunction:A verifiable technical failure in the Company's trading or settlement systems resulted in an erroneous transaction.

In all cases, the Client must provide evidence that the error was caused by Glacierpay and not by any action or omission of the Client.

3.2 Duplicate Transactions

A refund may be issued where the Company's systems have caused a duplicate transaction — i.e., the same trade was executed and settled more than once due to a system error. The Client must notify Glacierpay promptly upon discovering the duplication.

3.3 Failed Settlement

A refund may be issued where funds were debited from the Client's account or received by Glacierpay, but the corresponding trade was not executed and the digital assets or fiat funds were not delivered. In such cases, the Company will either complete the original trade or refund the full amount received, at its discretion and in consultation with the Client.

4. When Refunds Will Not Be Issued

Glacierpay will not issue a refund under any of the following circumstances, regardless of the amount involved:

5. Claim Process

5.1 Filing a Claim

To initiate a refund claim, the Client must comply with the following requirements:

• Timing:The claim must be submitted in writing within five (5) business days of the date on which the Client became aware, or ought reasonably to have become aware, of the issue giving rise to the claim — and in any event no later than thirty (30) calendar days after the date of the transaction. Claims received outside these time limits may be rejected at the Company's discretion;
• Method:Claims must be submitted via email to [email protected] with the subject line “Refund Claim — [Client Name] — [Transaction ID]”;
• Required information: The claim must include:
  • Transaction ID (as shown on the trade confirmation);
  • Date and time of the transaction;
  • Amount and currency/asset involved;
  • Detailed description of the issue, including the basis for the refund request;
  • Any supporting evidence (screenshots, correspondence, blockchain explorer links).

5.2 Investigation & Resolution

Upon receipt of a complete refund claim, the following process applies:

The Company reserves the right to extend the investigation period in complex cases, provided the Client is notified of the extension and the reasons therefor.

6. Refund Limitations

Where a refund is approved, the following limitations apply:

• Maximum refund amount: The maximum refund is limited to the fee charged by Glacierpay on the specific transaction in question. Refunds do not extend to the underlying trade value, market losses, or any consequential or indirect damages;
• Original currency only: Refunds are processed in the same currency (fiat or digital asset) in which the original fee was charged. No currency conversion will be performed for refund purposes;
• Blockchain network fees: Network fees (gas/miner fees) are non-refundable in all cases, as they are paid directly to network validators and cannot be recovered;
• Wire transfer fees: Wire transfer fees charged by Glacierpay are non-refundable in all cases, as corresponding costs are incurred with banking partners upon initiation;
• No interest: No interest is payable on refunded amounts, regardless of the time elapsed between the original transaction and the refund;
• Set-off: Glacierpay reserves the right to set off any refund amount against outstanding balances, fees or obligations owed by the Client to the Company.

7. Cancellation of Pending Trades

7.1 Pre-Execution Cancellation

A trade may be cancelled by the Client only before the trade has been confirmed as “Executed” in the Company's systems. The following rules apply:

• Cancellation requests must be submitted in writing to [email protected] or through the Client's designated account manager;
• Once a trade status shows “Executed”, the trade is final and cannot be cancelled under any circumstances;
• Trades in “Pending”, “Awaiting Settlement” or “Quote Accepted” status may be eligible for cancellation, subject to operational feasibility;
• Glacierpay will use commercially reasonable efforts to process cancellation requests promptly, but cannot guarantee cancellation if execution has already commenced;
• No cancellation fee applies to successfully cancelled trades.

7.2 Pending Fiat Transfers

Where a Client has initiated a fiat transfer to Glacierpay for the purpose of funding a trade, but the trade has not yet been executed:

• The Client may request cancellation and return of the fiat funds before the trade is executed;
• Return of funds will be processed to the originating bank account only;
• Applicable wire transfer fees (incoming and outgoing) will be deducted from the returned amount;
• Processing time for fiat returns is typically five (5) to ten (10) business days, depending on the payment rail and banking partner.

8. Complaints & Dispute Resolution

8.1 Internal Escalation of Refund Decisions

If a Client is unsatisfied with the outcome of a refund claim, the Client may request a review of the decision as follows:

• First escalation: Submit a written request for review to the Compliance team at [email protected]. The Compliance team will conduct an independent review of the original decision within ten (10) business days;
• Second escalation: If the Client remains unsatisfied following the Compliance review, the matter may be escalated to the Chief Compliance Officer (MLRO) for final internal determination.

8.2 Complaints

A Client may make a complaint about any aspect of Glacierpay's services, including the handling of a refund claim or cancellation request. Complaints are handled as follows:

• How to complain: Submit the complaint in writing to [email protected], describing the issue, the outcome sought, and any relevant transaction references and supporting documents. Glacierpay will acknowledge the complaint within two (2) business days;
• Escalation:If the complaint is not resolved to the Client's satisfaction, or if it concerns compliance matters, it may be escalated in writing to [email protected], where it will be reviewed under the authority of the Chief Compliance Officer (MLRO);
• Final internal response: Glacierpay will issue its final internal response to a complaint within thirty (30) business days of receipt. If more time is required in exceptional circumstances, Glacierpay will inform the Client of the delay, the reasons for it and the expected response date;
• Unresolved disputes:If the Client is unsatisfied with Glacierpay's final internal response, the dispute will proceed in accordance with the dispute-resolution clause of the Terms and Conditions, as summarised in Section 8.3 below.

8.3 Dispute Resolution & Governing Law

This Policy and any dispute arising out of or in connection with it are governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to conflict of law principles.

Any dispute that is not resolved through the internal processes described in this Section 8 will be resolved in accordance with the dispute-resolution clause of the Terms and Conditions (available at /legal/terms-and-conditions), which provides, in summary, for:

• Good-faith negotiation for thirty (30) days following written notice of the dispute;
• Optional mediation, where the parties agree;
• Final and binding arbitration administered by the ADR Institute of Canada (ADRIC) under its Arbitration Rules, before a single arbitrator, seated in Toronto, Ontario, conducted in English and confidential — subject to the carve-outs set out in the Terms and Conditions (injunctive or equitable relief and small-claims matters).

In the event of any inconsistency between this summary and the Terms and Conditions, the Terms and Conditions prevail.

9. Contact Information

For enquiries regarding this Refund and Cancellation Policy, or to submit a refund claim, cancellation request or complaint, please contact:

Glacierpay Inc. — FINTRAC MSB Registration No. C10001598 — Ontario, Canada