1. Purpose and scope

This Complaints Handling Policy explains how TERALEX PAY LIMITED, a company incorporated in Canada, registration number BC1536949, office address 5307 Victoria Drive #787, Vancouver, BC V5P 3V6, Canada, receives, reviews and responds to complaints, transaction queries, service concerns and error-related requests in connection with its website, client portal, payment-related services, virtual currency-related services and related support channels. In this Policy, TERALEX PAY LIMITED is referred to as "TERALEX", "we", "us" or "our".

This Policy should be read together with the Terms and Conditions, Privacy Policy, Cookie Policy, Regulatory Disclosures and any product-specific terms or notices that apply to the relevant service. This Policy does not replace any mandatory legal right, consumer protection right, regulatory remedy, court process or reporting obligation that may apply under applicable law. If any mandatory rule requires a different complaint, error-resolution, notice or remedy process, that mandatory rule will apply to the extent required.

2. What may be submitted as a complaint

A complaint or error-related request may relate to any concern about the Services, including account access, onboarding, customer support, delays, fees, transaction status, payment returns, rejected instructions, virtual currency transfers, suspected errors, privacy requests, information handling or the way a compliance review was managed.

Some matters are subject to legal, sanctions, anti-money laundering, fraud prevention, payment network, blockchain or third-party provider restrictions. In those cases, TERALEX may not be able to provide all details, reverse a transaction or disclose the reason for a hold, rejection, account restriction, report or investigation.

3. How to submit a complaint

Complaints and error-related requests should be submitted through the client portal, support channel or by email to support@teralex.com. Where a matter is urgent, such as suspected unauthorised account access, fraud, lost credentials or a security incident, the Client should contact TERALEX as soon as possible using the available support channel.

To help TERALEX review the matter, the Client should provide the following information where available:

• Name of the Client and, for a corporate client, the name and role of the person submitting the complaint.
• Account identifier, client reference, transaction reference or other relevant reference number.
• Date, amount, currency, virtual currency, wallet address, beneficiary or payment rail involved.
• A clear description of the issue and the result requested by the Client.
• Copies of supporting documents, screenshots, confirmations, payment instructions or correspondence.

4. Review process and timeframes

TERALEX will review complaints in a fair, practical and risk-based manner. The review may involve support, operations, compliance, legal, technology, payment partners, banks, virtual currency infrastructure providers, screening providers or other third-party providers involved in the relevant matter.

Intake — the complaint is received, logged and checked for basic information. Indicative timing: as soon as practicable.

Acknowledgement — TERALEX may acknowledge receipt and request missing information if needed. Indicative timing: usually within 5 business days.

Review — relevant records, transaction data, communications and partner information are reviewed. Indicative timing: depends on complexity.

Response — TERALEX aims to provide a written response after receiving the information required to review the matter. Indicative timing: usually within 30 business days.

If the matter is complex, depends on a third-party provider, involves a payment network or blockchain network, requires compliance review, raises fraud or sanctions issues, or requires additional documents, TERALEX may need more time. The timeframes in this Policy are indicative unless applicable law requires a mandatory timeframe. Where appropriate and legally permitted, TERALEX may provide an update or explain that more time is required.

5. Possible outcomes

After review, TERALEX may take one or more of the following actions, depending on the facts, applicable law, mandatory rights, service terms, safeguarding arrangements, product-specific terms, partner or network rules and operational limitations:

• Provide an explanation or clarification;
• correct an administrative, communication or account record issue;
• request additional information or documents from the Client;
• escalate the matter internally or to a third-party provider for further review;
• attempt a recall, return, correction or reversal where available and permitted;
• provide a refund, fee correction, return of available balance or other remedy where TERALEX determines that it is appropriate or where required by applicable law;
• maintain a hold, restriction, rejection or termination where required or permitted by law, risk controls or service terms.

TERALEX does not guarantee that a payment, blockchain transaction, virtual currency transfer or third-party provider action can be reversed, cancelled or recovered. Some transactions may be final, irreversible, unavailable for recall, or subject to the rules and technical limitations of banks, payment networks, blockchain networks, wallet infrastructure providers or other third parties. Where a complaint concerns end-user funds, safeguarded funds, protected client assets or virtual currency recorded for a Client, the treatment of those funds or assets will be reviewed in accordance with the Terms and Conditions, applicable product terms, safeguarding or custody arrangements and applicable law.

6. Holds, restrictions and legally limited explanations

Where a complaint relates to a transaction hold, account restriction, onboarding refusal, rejected instruction, blocked wallet, frozen balance, sanctions match, fraud concern or anti-money laundering review, TERALEX may be legally or operationally restricted from giving a full explanation.

Nothing in this Policy requires TERALEX to disclose information where disclosure could breach law, compromise an investigation, create a tipping-off risk, facilitate evasion of controls, prejudice sanctions or fraud controls, reveal confidential risk rules, conflict with a request from a regulator, law enforcement authority, court, bank or payment partner, or interfere with a legally required hold, freeze, report or compliance review.

7. Privacy complaints and individual requests

Complaints about privacy, access to personal information, correction of personal information, consent, cookies, marketing preferences, cross-border processing or service provider processing will be handled in accordance with the Privacy Policy and applicable privacy law.

Where a privacy complaint cannot be resolved by TERALEX, the individual may have the right to contact the Office of the Privacy Commissioner of Canada, a competent provincial privacy authority, an EU data protection authority where EU law applies, or another competent authority depending on the facts and applicable law.

8. Escalation and external rights

If the Client is not satisfied with the response, the Client may request that the matter be escalated for further internal review. The request should explain why the Client disagrees with the response and include any additional documents or information not previously provided.

Nothing in this Policy prevents a Client from contacting a competent regulator, privacy authority, consumer protection authority, law enforcement authority, court, bank, payment provider or other competent body where permitted by applicable law. Nothing in this Policy limits any mandatory consumer, regulatory, privacy, court or error-resolution right that cannot be limited by contract. TERALEX may also report or provide information to competent authorities where required or permitted by applicable law.

9. Records and confidentiality

TERALEX may keep records of complaints, correspondence, supporting documents, internal review notes, transaction data, decisions, outcomes and follow-up actions for legal, regulatory, audit, risk management, fraud prevention, dispute resolution and compliance purposes.

Complaint records may contain confidential business information, personal information, transaction information, compliance information and legally sensitive materials. Access to complaint records is restricted to personnel and third parties who need the information for the purposes described in this Policy or as required or permitted by law.

10. Changes to this Policy

TERALEX may update this Policy from time to time to reflect changes in law, regulation, services, operational arrangements, internal procedures or complaint handling practices. The current version will be made available through the website, legal hub, client portal or another official communication channel. Where a material change requires notice under the Terms and Conditions or applicable law, TERALEX will provide notice in the manner and within the timeframe required.

11. Contacts

• Company: TERALEX PAY LIMITED
• Registration number: BC1536949
• Office address: 5307 Victoria Drive #787, Vancouver, BC V5P 3V6, Canada
• Website: https://teralex.com/
• Contact email: support@teralex.com