Complaints Policy

This Complaints Handling Policy describes how FinikPay Inc. ("Finik", "we", "us") receives, reviews, and responds to complaints from clients. It sets out our procedures for handling complaints, the timelines we commit to, how we keep records, and what options are available to you if you remain dissatisfied after our response.

We take all complaints seriously. Every complaint gives us an opportunity to improve our services and to put things right where they have gone wrong.

1. What Counts as a Complaint

1.1 A complaint is any expression of dissatisfaction — whether oral or written — made by a client or a person acting on a client's behalf, about any aspect of our services, our platform, or the conduct of our staff.

1.2 A complaint is different from a general enquiry or a request for information. If you have a question about how our services work, please contact us at hi@finik.ai. If you believe something has gone wrong and you want us to address it, this policy applies.

2. How to Submit a Complaint

2.1 You can submit a complaint through any of the following channels:

• Email: complaints@finik.ai
• In writing: Privacy Officer, FinikPay Inc., Suite 548, 1235 Bay Street, Toronto, ON, Canada M5R 3K4
• Through a member of our staff: by contacting our support team at hi@finik.ai
• Through a representative: a person authorised to act on your behalf may submit a complaint on your behalf, provided they identify themselves and their authority to act for you

2.2 We recommend submitting complaints in writing — by email or letter — so that there is a clear record of what you've reported and when. If you submit a complaint orally (by phone or in a support conversation), we will prepare a written record of what you have told us. You may request a copy of this record at any time.

2.3 To help us handle your complaint as quickly as possible, please include:

• your full name and the email address registered to your Finik account;
• a clear description of the issue and what went wrong;
• the date(s) on which the issue occurred;
• any relevant transaction IDs, screenshots, or other supporting information; and
• what outcome you are seeking.

3. How We Handle Your Complaint

3.1 Acknowledgement

3.1.1 We will acknowledge receipt of your complaint within 5 Business Days of receiving it. Our acknowledgement will confirm that we have received your complaint, provide you with a reference number, and tell you who is handling it.

3.2 Investigation

3.2.1 Once we have acknowledged your complaint, we will begin a thorough review. This includes:

• reviewing all relevant documentation from your account and our systems;
• interviewing any employees or other persons involved in the matter, where necessary;
• reviewing any applicable policies, procedures, and records; and
• assessing whether our services were provided in accordance with our Terms of Service, applicable law, and our internal standards.

3.2.2 We handle all complaints free of charge. We will never charge you for raising a concern.

3.3 Our Response

3.3.1 We will provide you with a substantive response within 30 calendar days of receiving your complaint.

3.3.2 In exceptional circumstances — for example, where your complaint involves complex factual or legal issues, or where we are waiting for information from a third party — we may not be able to respond within 30 calendar days. In that case we will:

• send you a holding reply before the 30-day deadline, explaining the reason for the delay and setting out the revised deadline; and
• provide our final response no later than 60 calendar days from the date we received your complaint.

3.3.3 Our final response will:

• set out our findings and the reasons for our conclusions;
• where we have found that something went wrong, explain what remedial action we will take or what redress we are offering; and
• where we are not upholding your complaint, explain our reasons clearly.

3.3.4 Our final response will also include information about your right to escalate the complaint to an external body if you are not satisfied with our response — see Section 5.

4. Complaints About Specific Matters

4.1 Compliance-Related Complaints

4.1.1 If your complaint relates to a compliance action we have taken — such as a transaction being declined, your account being suspended, or assets being frozen — we will review the matter carefully. However, you should be aware that in some cases we may be legally restricted from disclosing the full reasons for a compliance action. Where this applies, we will tell you that we are unable to provide further details and explain why, to the extent we are able.

4.2 Card Transaction Disputes

4.2.1 If your complaint relates to a card transaction dispute, the resolution of that dispute is governed by Visa card network rules and by the procedures set out in our Terms of Service (Schedule B). Card disputes are forwarded to our BIN Sponsor for processing through the Visa network. We will keep you informed of the progress and outcome.

4.3 Privacy Complaints

4.3.1 If your complaint relates to how we have handled your personal information, please address it to our Privacy Officer at privacy@finik.ai. Privacy complaints are handled in accordance with our Privacy Policy and applicable privacy legislation, including PIPEDA and Quebec Law 25. If your privacy complaint is not resolved to your satisfaction, you may escalate it to the Office of the Privacy Commissioner of Canada or the Commission d'accès à l'information du Québec — see Section 5.

5. If You Are Not Satisfied

5.1 If you have received our final response and you remain dissatisfied, or if we have not responded within the timeframes set out in Section 3, you have the right to escalate your complaint to an external body. The relevant body depends on the nature of your complaint:

(a) Bank of Canada — as our regulator under the Retail Payment Activities Act (RPAA), the Bank of Canada oversees our conduct as a registered Payment Service Provider. You can contact the Bank of Canada at: Website: www.bankofcanada.ca; Email: rpaa-lvprp@bankofcanada.ca

(b) FINTRAC — for complaints relating to our anti-money laundering and counter-terrorist financing compliance. Website: https://fintrac-canafe.canada.ca/intro-eng

(c) Office of the Privacy Commissioner of Canada — for complaints about how we have handled your personal information. Website: https://www.priv.gc.ca/en/; Telephone: 1-800-282-1376

(d) Commission d'accès à l'information du Québec — for Quebec residents with privacy-related complaints. Website: https://www.cai.gouv.qc.ca/

(e) Autorité des marchés financiers (Quebec) — for Quebec residents, where applicable. Website: https://lautorite.qc.ca/grand-public

(f) Courts — you have the right to bring a dispute before a court of competent jurisdiction in accordance with the governing law provisions in our Terms of Service.

6. Record Keeping

6.1 We keep a record of every complaint we receive, regardless of how it was submitted. Our complaint records include:

• the date and channel through which the complaint was received;
• the identity of the complainant (or their representative);
• a description of the complaint and the issues raised;
• all correspondence with the complainant;
• the outcome of our investigation and the basis for our decision;
• any remedial action taken or redress offered; and
• the date of our final response.

6.2 Complaint records are retained for a minimum of 5 years from the date of the final response, in accordance with our legal and regulatory obligations.

6.3 We use complaint data to identify patterns and recurring issues, to improve our services, and to report to our senior management and board as part of our ongoing compliance programme.

7. Reporting

7.1 Our CAMLO and senior management review complaint volumes, outcomes, and trends on a regular basis. Material complaints — including those that reveal systemic issues, significant client harm, or potential regulatory breaches — are escalated to the board.

7.2 Where required by applicable regulation, we include complaint data in our regulatory reporting.

8. Continuous Improvement

8.1 We are committed to learning from complaints and using them to improve our services. Where a complaint reveals a deficiency in our processes, controls, or communications, we will take steps to address it and to prevent the same issue from occurring again.

9. Contact

For all complaints, please contact us at:

Email	complaints@finik.ai
General enquiries	hi@finik.ai
Privacy complaints	privacy@finik.ai
Post	FinikPay Inc., Suite 548, 1235 Bay Street, Toronto, ON, Canada M5R 3K4
Phone	+1 647 277 2972
Website	https://finik.ai