Refund Policy

Orion Transact Inc.

REFUND POLICY

1. Finality of Conducted Transactions

All transactions processed by Orion Transact Inc. are considered final and non-reversible once settlement has occurred. In accordance with the operational nature of asset transfers and our obligations as a federally registered Money Services Business (MSB) under Canadian legislation, we do not provide refund options for completed transactions that have been accurately processed and settled.

Orion Transact Inc. provides services exclusively to corporate clients. We act solely as a technical and transactional facilitator for these legal entities and do not manage or influence the commercial terms, refund policies, or service outcomes offered by our clients to their end-customers. As such, any payment made by an end-user through our system is processed strictly based on the instructions of the corporate client (merchant), and Orion Transact Inc. does not intervene in the commercial relationship between the end-customer and the merchant.

We are not able to reverse or recover assets in the following situations: where the client has submitted incorrect banking or payment information resulting in delivery to an unintended recipient, where market fluctuations affect the value of the transacted assets after the settlement is confirmed, where a transaction has been fulfilled in accordance with the originally submitted payment order, or where the customer mistakenly authorizes a transfer to a third-party beneficiary. Once payment instructions are confirmed by our client and execution is initiated, the transaction cannot be stopped, altered, or recalled without explicit written consent from the client.

Due to the nature of settlement through external financial institutions, correspondent agents, or custodial service providers, we may be unable to retrieve assets or redirect transfers once a transaction enters the settlement process. In particular, cases involving client-side bank accounts or custodial structures beyond our operational control may result in a permanent delivery to the instructed destination, and Orion Transact Inc. assumes no responsibility for such outcomes.

While Orion Transact Inc. is not a party to disputes between end-customers and the merchant, we will receive and document complaints submitted by end-users and forward them to the respective corporate client for consideration. However, unless we receive formal instructions from our client, we are not authorized to process refunds or issue reversals. The final decision rests solely with the legal entity that contracted our services.

2. No Refunds in Cases of Regulatory Restrictions

Orion Transact Inc. operates under the legal obligations outlined in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and follows all regulatory guidance issued by FINTRAC. As a federally registered Money Services Business, we are required to apply rigorous compliance measures, including client due diligence, identity verification, transaction monitoring, and reporting obligations in accordance with federal anti-money laundering and counter-terrorist financing regulations.

Our services are provided exclusively to legal entities. We perform onboarding, risk scoring, and ongoing monitoring of our corporate clients. In this capacity, Orion Transact Inc. does not manage the onboarding or due diligence of the end-customers that interact with our clients, nor are we responsible for the nature or purpose of the services offered to them.

In compliance with Canadian law, we do not issue refunds for transactions that are blocked, rejected, or suspended due to regulatory restrictions, suspicious behavior, or incomplete compliance procedures. If a client fails to pass our mandatory identity checks or provides false, misleading, or invalid documentation, we will not release or return any assets unless formally required to do so by competent regulatory or judicial authorities.

Assets associated with flagged transactions may be frozen and retained under the authority granted by Sections 7 and 9 of the PCMLTFA. These cases may be reported to FINTRAC or relevant enforcement bodies where appropriate. Orion Transact Inc. is not liable for any loss, delay, or missed opportunity resulting from actions taken in good faith to comply with applicable Canadian compliance laws.

Complaints raised by end-customers regarding such holds or restrictions will be documented and forwarded to the relevant corporate client. However, Orion Transact Inc. will not process or evaluate refund demands submitted by third-party users and will act only upon direct instructions issued by our contracted legal entity.

3. Exceptional Cases of Asset Refunds

Refunds involving transferred assets may only be considered under rare and clearly justified circumstances where a technical or operational failure is directly attributable to Orion Transact Inc. As a federally registered Money Services Business operating under Canadian legislation, we do not process discretionary refunds once a transaction has been properly executed and assets have been transferred according to the instructions received from our corporate client.

Our services are provided exclusively to legal entities. As such, Orion Transact Inc. does not independently validate or authorize the purpose of payments initiated by end-customers and has no role in the underlying commercial agreement. Any refund related to the conduct of the merchant remains strictly within the decision-making authority of our corporate client.

Nonetheless, a refund may be reviewed for approval where the following internal errors can be demonstrated: if the client is charged twice for the same transaction due to a system malfunction on our side, if multiple identical instructions were submitted unintentionally by the client and resulted in double deduction of assets, or if a cancellation request was formally submitted before the start of the execution process and the assets remained under our operational custody at that time.

Such refund requests must be submitted in writing, including transaction identifiers, supporting evidence of the error, and verified client identification. Orion Transact Inc. reserves the right to review, reject, or escalate such claims in accordance with its internal compliance program. If a refund is approved, it may require extended processing time due to involvement of external financial institutions, reconciliation procedures, and anti-fraud screening as required under the PCMLTFA.

Refunds will not be processed in any situation where assets have already entered the clearing cycle, where execution has been completed based on the client’s instructions, or where Orion Transact Inc. is not the party responsible for the error. Requests submitted by end-customers regarding such scenarios will be forwarded to the relevant corporate client. Orion Transact Inc. does not resolve or mediate refund requests between merchants and their customers, nor do we have legal authority to reverse a successful transaction without written consent from our contractual client.

4. Cases Where Asset Refunds Cannot Be Processed

Refunds will not be issued in any of the following circumstances, regardless of the nature of the request or the identity of the party submitting it. Once assets have been used to fulfill the original payment instruction issued by our corporate client and the transfer has been successfully completed, the transaction is final and cannot be reversed.

Refunds cannot be processed where the transaction was executed in accordance with the merchant's submitted instructions and the assets have been delivered to the designated receiving account. Orion Transact Inc. does not assess the purpose or destination of the transfer and has no role in evaluating whether the transaction was initiated by the end-customer in error, for the wrong product, or under commercial misunderstanding. We do not monitor or approve the business logic behind our clients’ activities and are not in a position to intervene once execution is complete.

If our corporate client or its end-customer fails to meet applicable AML standards, provides misleading or fraudulent documentation, or violates compliance obligations during onboarding or during the transaction process, no refund will be considered, and the matter may be escalated to appropriate regulatory authorities in line with Canadian law.

Refund requests based on changes in exchange rates, the current market value of assets, or dissatisfaction with how the corporate client conducted the service are not grounds for reconsideration. Likewise, any complaint related to system design, payment timing, or operational limitations imposed by third-party institutions lies outside the responsibility of Orion Transact Inc.

Requests or complaints submitted directly by end-customers in relation to these types of cases will be documented and forwarded to our corporate client. However, Orion Transact Inc. will not review such complaints substantively, nor will we authorize refunds or returns without a formal and verifiable instruction from the legal entity with whom we maintain the contractual relationship.

5. Outstanding or Irregular Payments

Orion Transact Inc. processes transactions exclusively upon receipt of the full and correct amount of assets within the timeframe defined at the time of payment instruction. Transactions that fall outside of these defined parameters,due to underpayment, delay, duplication, or misalignment of asset type, may be treated as unpaid or irregular. In such instances, the received amount may be returned to the originator following internal reconciliation and subject to applicable administrative or banking deductions. All return decisions are contingent upon compliance review under the PCMLTFA framework.

A delayed payment occurs when assets are transmitted after the processing session has expired. Such transfers may be declined or held, and returned only after full review depending on transaction integrity and risk profile.

Duplicate or unsolicited transfers received after a transaction has already been fulfilled will be treated as irregular and will not be applied to any future operations. These may be returned upon verification, provided that no compliance concerns arise and the source is deemed legitimate.

If the sender transmits an asset other than the one originally specified in the transaction request, the operation may result in a misapplied or unrecognized settlement. In these cases, Orion Transact Inc. does not guarantee return of funds. Each such incident will be reviewed on a case-by-case basis, taking into account technical compatibility, asset traceability, and compliance feasibility.

Where such irregularities originate from end-customers, Orion Transact Inc. will notify the contracting legal entity and await formal instructions before initiating any refund or resolution process. We are not authorized to resolve disputes or handle refund demands directly from individuals not party to our commercial agreement.

6. Refund Processing Timelines and Conditions

All refund requests submitted to Orion Transact Inc. are subject to operational and compliance review in accordance with Canadian regulatory requirements. Our services are provided exclusively to legal entities, and refund processing is initiated only upon the instruction or approval of the contracting corporate client. Requests submitted by end-customers will be received and recorded but cannot be acted upon unless expressly authorized by the merchant.

Upon receiving a complete refund request and required supporting documents, Orion Transact Inc. will typically complete the initial eligibility assessment within 5 to 7 business days. This review includes verification of the transaction data, internal error traceability, and risk assessment under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

If the request is approved and authorized by the corporate client, the return of assets will generally be processed within 10 to 14 business days. In some cases, processing may take longer due to external banking procedures, extended verification requirements, or reporting obligations triggered by the transaction characteristics.

Orion Transact Inc. shall not be held liable for delays caused by intermediary institutions, regulatory screenings, or force majeure events. No interest, compensation, or damages shall be due for additional time required to complete compliance obligations or third-party coordination. All actions are carried out in good faith and strictly within the legal framework governing Money Services Businesses in Canada.

7. Contact Information

If you have any questions or require clarification regarding this Refund Policy, please contact Orion Transact Inc. using our official communication channel. All inquiries must be submitted to the following email address: info@oriontransact. To assist us in addressing your request efficiently, please include relevant transaction references, your company name or the name of the client entity you are representing, and a concise summary of your inquiry.