Refund & Cancellation Policy

1. Overview

This Refund and Cancellation Policy (“Policy”) establishes the framework, principles, and procedures governing refund requests, trade cancellations, and dispute resolution for all clients of Glacierpay Inc. (“Glacierpay” or the “Company”).

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 client's Master Services Agreement, Terms of Service, Fee Schedule, and Complaints Handling Policy.

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 of the transaction giving rise to the claim. Claims received after this period 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. Dispute Escalation

8.1 Internal Escalation

If a client is unsatisfied with the outcome of a refund claim, the client may escalate the matter 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 CEO for final internal determination.

8.2 Formal Complaint

Clients who have exhausted the internal escalation process may file a formal complaint in accordance with the Company's Complaints Handling Policy. The Complaints Handling Policy sets forth the procedures for formal complaint submission, investigation, and resolution, including applicable timelines and the client's rights.

8.3 Governing Law

This Policy and any disputes arising hereunder shall be governed by and construed in accordance with the laws of the Province of Ontario, Canada, without regard to conflict of law principles. The courts of the Province of Ontario shall have exclusive jurisdiction over any dispute arising in connection with this Policy, subject to any mandatory dispute resolution provisions in the client's Master Services Agreement.

9. Contact Information

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