Complaints Handling Policy

This Complaints Handling Policy (hereinafter — the "Policy") sets out the procedure for submitting, registering, reviewing and resolving complaints related to the use of MulenPay services provided by RBY Commerce Ltd. (hereinafter — the "Company", "MulenPay").

The Company strives to provide a high level of customer service and reviews every complaint objectively, fairly and within a reasonable time.

The purpose of this Policy is:

• to provide a transparent complaint submission mechanism;
• to protect the rights of users and merchants;
• to ensure the timely review of requests;
• to improve the quality of the services provided;
• to prevent the recurrence of similar situations.

A complaint may be submitted by:

• a user of the Site;
• a client of the Company;
• a merchant;
• a partner;
• an authorized representative of a client;
• any other person whose rights or interests are affected by the actions of the Company.

A complaint may be submitted in the following ways:

• email: complaints@mulenpay.com;
• through the support service: support@mulenpay.com;
• through the feedback form on the website: mulenpay.com.

For the effective review of a request, the applicant is advised to provide:

• the name or the name of the organization;
• a contact email address;
• the account number (if available);
• a description of the situation;
• the date on which the problem arose;
• details of the transaction or service affected;
• supporting documents and materials.

The Company has the right to request additional information required to review the request.

Upon receipt of a complaint, the Company:

• Registers the request in the internal record-keeping system.
• Verifies the sufficiency of the information provided.
• Requests additional details if necessary.
• Assigns a responsible person to review the request.

The Company strives to observe the following time frames:

• acknowledgment of receipt of the complaint — up to 5 business days;
• initial analysis of the request — up to 10 business days;
• full review of the complaint — up to 30 calendar days.

In cases of increased complexity, the review period may be extended.

If an extension is necessary, the Company notifies the applicant of the reasons for the delay.

When reviewing a complaint, the Company may:

• analyze internal records and event logs;
• examine documents and correspondence;
• request additional details;
• interact with payment partners;
• conduct internal checks.

Each complaint is reviewed individually, taking into account the circumstances of the specific case.

Based on the results of the review, the Company may:

• recognize the complaint as fully justified;
• recognize the complaint as partially justified;
• decline to grant the complaint;
• propose measures to resolve the dispute.

The result of the review is sent to the applicant using the contact details provided.

The Company may decline to review a complaint in the following cases:

• the required information is missing;
• the request contains knowingly false information;
• the complaint concerns the activities of third parties not related to the Company;
• the request is offensive in nature;
• the matter has been reviewed previously and contains no new circumstances.

If a complaint relates to a payment transaction, the Company has the right to request:

• the payment identifier;
• details of the payer;
• confirmation of the transaction;
• documents confirming the circumstances of the dispute.

If the dispute relates to a bank card or a payment system, the applicant may be advised to contact their bank or financial institution.

All information provided as part of the review of a complaint is used solely for the purposes of investigating and resolving the request.

The Company takes reasonable measures to protect the information against unauthorized access and disclosure.

If the applicant disagrees with the results of the review of the complaint, the applicant has the right to:

• submit an additional request with new information;
• apply to the competent state authorities;
• use other methods of protecting the rights of the applicant provided for by law.

The Company reserves the right to change this Policy at any time.

The new version takes effect upon publication on the Site.

Continued use of the Company services constitutes consent to the current version of the Policy.