Refund and Chargeback Policy

This Refund and Chargeback Policy (hereinafter — the "Policy") governs the procedure for processing payment refund requests, settling customer claims, and reviewing chargeback procedures when using the MulenPay services.

RBY Commerce Ltd. (hereinafter — the "Company", "MulenPay") provides software and technological solutions for processing payment information and interacting with payment partners.

The Company is not a bank, an issuer of payment cards, an electronic money operator, or a payment aggregator.

MulenPay provides solely the technological infrastructure for accepting and processing payments.

The Company:

• is not a party to the contract between the Merchant and the customer;
• does not sell the goods and services of the Merchant;
• does not make decisions on commercial disputes between the Merchant and the buyer;
• does not hold customer funds.

Responsibility for the delivery of goods and the provision of services rests with the relevant Merchant.

The buyer is entitled to apply to the Merchant with a refund request in the cases provided for by:

• the applicable legislation;
• the contract between the Merchant and the buyer;
• the rules of the payment system;
• the refund policy of the Merchant.

The decision on a refund is made by the Merchant.

Upon approval of a refund, the Merchant initiates the refund procedure through the available tools of the payment partner.

After a refund is confirmed by the Merchant, processing is carried out within the time frames established by the relevant bank or payment institution.

The actual crediting of funds depends on:

• the card-issuing bank;
• the payment system;
• the payment partner;
• the internal procedures of the financial institution.

The Company cannot guarantee the exact time frames for the receipt of funds.

The possibility of cancelling a transaction depends on the status of the payment and the rules of the payment partner.

The Company is entitled to refuse to cancel a transaction if:

• the payment has already been completed;
• the funds have been transferred to the recipient;
• cancellation is not possible under the rules of the payment system or the bank.

A chargeback is a procedure for disputing a payment initiated by the holder of a bank card through the issuing bank.

Chargebacks are governed by the rules of:

• Visa;
• Mastercard;
• American Express;
• UnionPay;
• other payment systems.

The Company does not make decisions on chargeback disputes and does not influence the final decision of the issuing bank or the payment system.

Upon receiving notification of a chargeback, the Company is entitled to:

• notify the Merchant;
• request documents and evidence relating to the transaction;
• transfer information to the payment partner;
• temporarily withhold disputed amounts where the relevant requirements of the partner apply.

The Merchant is obliged to provide the required documents within the established time frame.

At the request of the Company or the payment partner, the Merchant may be required to provide:

• confirmation that the service was provided;
• confirmation that the goods were delivered;
• correspondence with the customer;
• bills and invoices;
• contracts and offers;
• IP addresses and technical logs;
• other documents confirming the legitimacy of the transaction.

Failure to provide documents may result in losing the chargeback dispute.

The Company monitors the level of refunds and chargebacks.

The following may be considered an elevated level of risk:

• an unusually high percentage of refunds;
• systematic customer complaints;
• signs of fraudulent activity;
• violations of the rules of payment systems.

If an elevated chargeback level is identified, the Company is entitled to:

• request additional information;
• conduct a review of the activity of the Merchant;
• establish restrictions on service;
• temporarily suspend payment processing;
• terminate cooperation.

The decision is made on the basis of a risk assessment and the requirements of the payment partners.

The Merchant is responsible for:

• the quality of goods and services;
• the accuracy of information about the offered goods and services;
• compliance with the legislation;
• the settlement of buyer claims.

The Company is not responsible for:

• the actions of buyers;
• the decisions of banks and payment systems;
• the outcome of chargeback procedures;
• losses arising from disputes between the Merchant and the buyer.

To reduce the number of refunds and chargebacks, the Company recommends that Merchants:

• provide an accurate description of goods and services;
• use up-to-date contact details;
• respond to customer enquiries in a timely manner;
• retain documents relating to transactions;
• comply with AML/KYC requirements and the rules of payment systems.

The Company is entitled to amend this Policy at any time.

The updated version takes effect upon publication on the Site.

Continued use of the services of the Company constitutes acceptance of the current version of the Policy.