COMPLAINTS AND DISPUTE RESOLUTION PROCEDURE

Last updated: 01.07.2026

1. General Provisions

1.1. This Complaints and Dispute Resolution Procedure sets out the basic procedure for submitting, reviewing and responding to complaints, requests, claims, objections or disputes raised by users of the OurExchangeClub platform.

1.2. This Procedure applies where a User has a complaint, claim or objection concerning the use of the Website, a user account, Identification, a Transaction request, a payment, a Crypto-asset transfer, a Transaction status, rejection, suspension, cancellation, return or any other matter relating to OurExchangeClub’s services.

1.3. This Procedure forms an integral part of OurExchangeClub’s Terms of Use, Privacy Policy, KYC/AML/CFT and Sanctions Compliance Policy, Crypto-asset Risk Disclosure Statement, Payments and Cash Operations Policy, Tariffs, Commissions and Limits Policy and other documents published on the Website.

1.4. The Company strives to review Users’ complaints and claims in good faith, objectively and within reasonable timeframes, taking into account the nature of the matter, the factual circumstances, the documents submitted, the Transaction status, technical data, payment or blockchain information and applicable legal or compliance requirements.

1.5. Submission of a complaint or claim does not in itself suspend the progress of a Transaction, a restriction on a user account, a compliance check, a return process or any other action by the Company, unless the Company decides otherwise in the particular circumstances or such suspension is required by applicable law.

1.6. The User must submit a complaint or claim in good faith, clearly and fully, providing the factual information, documents, payment or blockchain information and contact details necessary to review the matter.

1.7. The Company may decline to review, or leave without consideration on the merits, submissions that do not relate to OurExchangeClub’s services, are submitted through unofficial communication channels, do not contain sufficient identification or Transaction data, are manifestly unfounded or repetitive, or are submitted in an abusive manner.

1.8. The procedure set out herein does not limit the parties’ right to apply to competent public authorities or a court in the circumstances provided for by applicable law. However, the parties undertake first to seek to resolve the matter through communication in good faith and an examination of the facts.

2. Procedure for Submitting a Complaint or Claim

2.1. The User may submit a complaint, request, claim or objection through the official communication channels listed on the Website or in another official format prescribed by the Company.

2.2. A complaint must be submitted in writing or in an electronic form that allows the User to be identified, the substance of the claim to be understood and the related factual information to be examined.

2.3. In the complaint or claim, the User must state the following as clearly as possible:

a) the User’s first name and surname or the name of the legal entity;

b) the email address registered on the Website or other contact details;

c) the user account or Transaction identifier, if available;

d) the substance of the complaint or claim;

e) the date, period or Transaction stage to which the complaint relates;

f) the User’s demand or expected resolution;

g) documents supporting the complaint, payment data, the blockchain transaction hash, receipts, communications or other evidence, if available.

2.4. If the complaint concerns a payment, return, bank or card transaction, EasyWallet, EasyPay or a cash operation, the User must provide the relevant proof of payment, the time of payment, the amount, the payment method and other data necessary to identify the payment.

2.5. If the complaint concerns a Crypto-asset transfer, the User must provide the type of Crypto-asset, the blockchain network, the Crypto Wallet Address, the transaction identifier (Transaction Hash or TxID), the time of the transfer, the amount and other necessary data establishing the connection with the Transaction.

2.6. If the complaint is submitted by the User’s representative, the Company may request documents confirming the representative’s identity and authority, as well as other information confirming the right to act on the User’s behalf.

2.7. The Company may request additional information or documents if the complaint as submitted does not provide sufficient information to identify and review the User, the Transaction, the payment, the Crypto-asset transfer or the substance of the claim.

2.8. If the User does not provide the requested additional information or documents, or if the data provided are insufficient to review the complaint, the Company may suspend its review of the complaint or respond on the basis of the available data.

2.9. Expressions of dissatisfaction submitted through unofficial communication channels, social networks, personal messengers, third parties or orally may not be regarded as an official complaint or claim unless the Company expressly accepts them as an official submission.

2.10. The User must provide accurate and truthful data when submitting a complaint. Submission of false, altered, incomplete, contradictory or misleading information may constitute grounds for rejecting the complaint, conducting an additional check or taking other applicable measures.

3. Receipt of a Complaint and the Review Process

3.1. Upon receiving a complaint, the Company may register it, classify it according to the nature of the matter and refer it to the appropriate responsible person or department within the Company for review.

3.2. As part of its review of a complaint, the Company may compare the data provided by the User with the Website’s Transaction records, payment data, blockchain information, user account activity history, communications, technical records and internal recordkeeping data.

3.3. If the complaint concerns a third-party service, including a bank, payment system, EasyWallet, EasyPay, partner organisation, blockchain network, Crypto Wallet service or technical provider, the Company may, where necessary, send an enquiry to the relevant third party or await the data to be provided by that party.

3.4. The time required to review a complaint may depend on the complexity of the matter, the completeness of the data submitted, the need for Additional Documents, the time required to obtain data from third parties, the scope of technical checks and compliance requirements.

3.5. If additional information, documents or explanations are required during the review, the Company may ask the User to provide them. In that case, the review of the complaint may be continued or finalised after the additional data have been received.

3.6. If several complaints submitted by the same User concern the same Transaction, the same factual circumstances or related matters, the Company may review them under a single procedure and provide one consolidated response.

3.7. If, during the handling of a complaint, it becomes apparent that the matter is connected with an ongoing compliance check, a requirement of a competent authority, a technical failure, a postponement by a payment system or the condition of a blockchain network, the Company may extend the review until the relevant circumstance has been clarified.

3.8. The Company may temporarily maintain the current Transaction status while reviewing the complaint if resolution of the matter requires further verification of facts or the receipt of data from third parties.

3.9. Review of a complaint does not mean that the User’s claim has been accepted in advance, that the Transaction status must be changed, that the payment must be returned or that the Crypto-asset transfer must be completed before the review has concluded.

3.10. During the review, the Company may use only the data and sources necessary to establish the factual circumstances of the complaint, formulate the Company’s position and provide an appropriate response.

3.11. The Company may decline to continue reviewing a complaint if the User abuses the complaints procedure, repeatedly submits unfounded claims with the same content, threatens or obstructs the Company’s normal operations, or fails to provide the minimum data necessary for the review.

4. Provision of a Response and Outcome of the Complaint

4.1. Upon completion of the review of a complaint, the Company shall provide the User with a response through an official communication channel listed on the Website or using the User’s registered contact details.

4.2. The Company’s response may include the general outcome of the review, the Company’s position, the decision taken, possible actions or further steps to be taken by the User.

4.3. Depending on the nature of the complaint and the results of the review, the Company may:

a) uphold the complaint in whole or in part;

b) reject the complaint;

c) propose an adjustment relating to the Transaction, payment, return or communications;

d) maintain the current Transaction status;

e) propose an additional procedure or clarification;

f) inform the User that resolution of the matter depends on an action by a third party, bank, payment system, blockchain network, partner organisation or competent authority.

4.4. If the complaint is upheld in whole or in part, the Company may make an appropriate correction, provide further clarification, make a return, change the Transaction status or take another reasonable action within the limits permitted by the Terms of Use and the policies published on the Website.

4.5. If the complaint is rejected, the Company may provide the User with the general grounds for rejection to the extent that their disclosure does not harm compliance, security, AML/CFT, sanctions, anti-corruption, fraud prevention, technical or internal control systems.

4.6. The Company is not required to provide the User with the complete materials of the internal review, internal notes, risk assessments, verification sources, complete responses from third parties or information whose disclosure could violate the law, third-party rights, security requirements or the Company’s legitimate interests.

4.7. The response to a complaint may be prepared in the language in which the complaint was submitted or in the Website’s primary language, unless the Company considers another format appropriate.

4.8. If the User disagrees with the response to the complaint, the User may submit a further substantiated objection, together with new or previously unsubmitted facts, documents or information.

4.9. A further objection concerning the same matter may be reviewed only if the User presents new material circumstances or evidence that were not known or available during the previous review.

4.10. Providing a response to a complaint does not mean that the Company waives any rights granted to it by the Terms of Use, the policies published on the Website or applicable law.

5. Negotiated Settlement of a Dispute and Further Steps

5.1. If the User disagrees with the Company’s response to the complaint or the proposed solution, the parties may seek to resolve the matter through further communication, clarification or negotiation.

5.2. During further communication, the parties must act in good faith, provide only information material to the resolution of the matter and avoid unnecessary repetition, inappropriate demands or abuse of the procedure.

5.3. At the negotiated settlement stage, the Company may propose a practical solution if that solution is possible given the state of the Transaction, legal requirements, technical capabilities, the involvement of third parties and the documents published on the Website.

5.4. The Company’s proposal of a negotiated or out-of-court solution does not constitute an admission of fault, an admission of breach of an obligation or confirmation that the User’s claim is fully substantiated.

5.5. If the matter is not resolved through the complaint review or further negotiations, the parties may use the dispute resolution mechanisms provided for in the Terms of Use and applicable law.

5.6. The existence of a dispute does not release the User from obligations that are not disputed or that are necessary for the Transaction, a compliance check, clarification of data, provision of documents or compliance with legal requirements.

5.7. If the dispute relates to an unfinished Transaction, the Company may maintain the current Transaction status until the matter has been clarified between the parties, additional checks have been completed, data have been received from third parties or a competent authority has stated its position.

5.8. The Company may retain communications between the parties during the dispute, documents submitted, proposals and responses for dispute resolution, legal protection, accounting, compliance and evidentiary purposes.

5.9. If a dispute is subject to judicial proceedings, it shall be resolved in accordance with the provisions on applicable law and jurisdiction set out in OurExchangeClub’s Terms of Use.

6. Final Provisions

6.1. This Procedure applies in conjunction with OurExchangeClub’s Terms of Use, Privacy Policy, KYC/AML/CFT and Sanctions Compliance Policy, Crypto-asset Risk Disclosure Statement, Payments and Cash Operations Policy, Tariffs, Commissions and Limits Policy and other documents published on the Website.

6.2. In the event of a difference between this Procedure and other documents published on the Website, the provision that specifically governs the nature of the complaint, claim, objection or dispute in question shall apply.

6.3. The Company has the right to amend, supplement or update this Procedure at any time, taking into account changes in services, Website functions, internal procedures and legal, technical, compliance or operational needs.

6.4. The amended Procedure is published on the Website or made available through the Company’s official communication channels and takes effect upon publication or on another date specified in the Procedure.

6.5. The User must periodically familiarise themselves with the current version of this Procedure. Continued use of the Website, a user account or OurExchangeClub’s services following changes constitutes the User’s acceptance of the amended Procedure.

6.6. If any provision of this Procedure is held to be invalid, unlawful or inapplicable, this does not affect the validity, lawfulness or applicability of the remaining provisions.

6.7. The Armenian version of this Procedure is the primary and prevailing version. In the event of any conflict, difference or inconsistency in interpretation between translations into English, Russian or other languages and the Armenian version, the Armenian version shall prevail.

6.8. Provisions of this Procedure which, by their nature, must remain in effect after the completion of the complaint review, completion of the Transaction, a request to close the user account or cessation of the use of services shall continue to apply to the extent necessary for legal, accounting, compliance, dispute resolution and evidentiary purposes.