Refund & Cancellation Policy

Last Updated: 2025-01-05 Effective Date: 2025-01-05 Version: 2.0 (Non-Custodial Remittance Orchestration Model)

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1. Introduction

1.1 Purpose

This Refund & Cancellation Policy ("Policy") explains when and how you may request cancellations of transfers and refunds of payments when using the PayWolt Platform for cross-border remittance orchestration services.

This Policy should be read in conjunction with our Terms of Service and Privacy Policy.

1.2 Service Model and Refund Responsibility

Critical Context:

PayWolt operates as a technology service provider (TSP) that orchestrates cross-border remittance transfers between licensed payment service providers. PayWolt does NOT hold, custody, or transmit customer funds.

Refund Responsibility:

• Payment Collection Refunds: Processed by Collection Providers (Stripe, Flutterwave) according to their terms and applicable payment network rules
• Payout Reversals: Subject to Payout Provider (Wise, Flutterwave) policies and beneficiary bank regulations
• PayWolt's Role: Facilitate refund requests, monitor processing, communicate status to you

Payment Service Providers:

Important: Refund processing times, eligibility, and procedures are determined by the relevant Provider and applicable payment network or banking regulations, not solely by PayWolt.

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2. General Refund Principles

2.1 Core Principles

2.2 Transfer Lifecycle and Refundability

Your rights to cancel or refund a transfer depend on which phase the transfer is in:

2.3 Refund Methods

All refunds are processed by the Collection Provider using the original payment method:

Important: PayWolt does NOT refund to alternative accounts or payment methods. Refunds are always processed by the Provider to the original payment source.

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3. Cancellation Rights by Transfer Phase

3.1 Quote Phase Cancellation

Timeframe: While transfer status is QUOTE_REQUESTED or QUOTE_RECEIVED (before payment submission)

Your Rights:

• You may abandon the quote at any time
• No payment has been collected
• No fees charged
• No cancellation required

How to Cancel:

• Simply do not proceed with payment
• Quote expires automatically after the validity period (typically 15-30 minutes)

3.2 Payment Collection Phase Cancellation

Timeframe: After payment submission but before payment capture/confirmation

3.2.1 Card Payments (Stripe)

Cancellation Window:

• Before Authorization: Until card authorization is completed (typically <30 seconds)
• After Authorization: Not cancellable; request refund instead (see Section 4)

How to Cancel:

• Contact Support immediately via in-app chat or support@paywolt.com
• Provide transfer reference ID
• PayWolt will request Stripe to void the authorization if not yet captured

Outcome:

• If voided successfully: No charge to your card
• If already captured: Proceeds to refund process (5-10 business days)

3.2.2 Bank Transfers (Flutterwave - Africa)

Cancellation Window:

• Before Bank Confirmation: Until Flutterwave confirms receipt of funds (1-24 hours depending on bank)
• After Confirmation: Not cancellable; request refund instead (see Section 4)

How to Cancel:

• Contact Support immediately
• Provide transfer reference ID and bank transfer details
• PayWolt will check with Flutterwave whether funds have been received

Outcome:

• If not yet received: You may cancel the bank transfer with your bank
• If received by Flutterwave: Proceeds to refund process (3-7 business days)

3.2.3 Mobile Money (Flutterwave - Africa)

Cancellation Window:

• Instant Payment: Mobile money payments are typically instant; cancellation is not possible once payment is confirmed
• Request refund instead (see Section 4)

3.3 Payout Pending Phase Cancellation

Timeframe: After payment confirmed but before payout execution begins

Your Rights:

• Limited cancellation rights
• Depends on Provider's payout processing timeline
• May incur fees if payout preparation has begun

How to Cancel:

1. Contact Support urgently via in-app chat or support@paywolt.com
2. Provide transfer reference ID
3. State reason for cancellation (optional but helpful)

PayWolt's Actions:

• Check payout status with Payout Provider (Wise, Flutterwave)
• If payout not yet initiated: Request cancellation and refund from Collection Provider
• If payout already initiated: Cancellation not possible; transfer will complete

Outcome:

• If Cancelled Successfully:

  • Collection Provider processes refund to original payment method
  • Refund timeframe: 3-10 business days (depends on payment method)
  • Fees: No cancellation fees; standard payment processing fees may be non-refundable (see Section 7)

• If Cancellation Not Possible:

  • Transfer proceeds to completion
  • No refund issued

Important: The window for cancellation during this phase is very short (typically 15 minutes to 2 hours). PayWolt cannot guarantee successful cancellation.

3.4 Payout Processing and Completed Phases

Transfer Status: PAYOUT_PROCESSING, COMPLETED

Cancellation Rights: ❌ Not Available

Once the Payout Provider has sent funds to the beneficiary bank account:

• The transfer is final and irreversible
• Cancellation is not possible
• Refunds are only available in exceptional circumstances (see Section 5)

Important Principle: Cross-border bank transfers, once executed, are governed by international banking regulations (SEPA, SWIFT) which generally do not permit sender-initiated reversals. The beneficiary bank and account holder are not obligated to return funds.

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4. Refund Eligibility and Scenarios

4.1 Automatic Refunds (Transfer Failures)

PayWolt automatically initiates refunds with the Collection Provider when transfers fail due to technical or operational issues.

4.1.1 Payment Collection Failures

Scenarios:

• Card payment declined after initial authorization
• Bank transfer rejected by Flutterwave
• Mobile money payment timeout
• Payment processing error

Refund Process:

• Automatic initiation by PayWolt within 1 business day of failure detection
• Processing time:
  • Card refunds: 5-10 business days (processed by Stripe)
  • Bank transfer refunds: 3-7 business days (processed by Flutterwave)
  • Mobile money refunds: 1-3 business days (processed by Flutterwave)
• Notification: Email and in-app notification when refund is initiated and completed

Your Action Required: None - refunds are processed automatically.

4.1.2 Payout Execution Failures

Scenarios:

• Beneficiary bank account invalid, closed, or frozen
• Beneficiary bank rejects transfer due to compliance reasons
• Payout Provider encounters technical error
• Insufficient liquidity at Payout Provider (rare; pre-checked)

Refund Process:

• Detection: Payout Provider notifies PayWolt of payout failure (typically within 1-5 business days)
• Refund Initiation: PayWolt requests refund from Collection Provider within 1 business day of notification
• Processing time: Same as Section 4.1.1 above
• Notification: Email and in-app notification with failure reason and refund timeline

Common Payout Failure Reasons:

Important: If you receive a refund due to payout failure and wish to retry the transfer:

1. Verify beneficiary details carefully (especially account number and name)
2. Contact beneficiary to confirm their bank account is active and able to receive international transfers
3. Request a new quote - exchange rates may have changed

4.2 Refunds for Incorrect Transfer Amounts

4.2.1 You Paid More Than Quoted Amount

Scenario: The amount debited from your payment method exceeds the quoted transfer amount (including fees).

Your Rights:

• Full refund of the excess amount
• Immediate investigation by PayWolt

How to Request Refund:

1. Contact Support within 7 days of payment
2. Provide:
   • Transfer reference ID
   • Screenshot of quote showing expected amount
   • Bank/card statement showing actual charged amount
3. PayWolt will investigate within 2 business days

Refund Process:

• If error confirmed: PayWolt requests refund of excess amount from Collection Provider within 1 business day
• Processing time: 3-10 business days (depends on payment method)
• You receive email confirmation when refund is initiated

4.2.2 Beneficiary Received Less Than Quoted Amount

Scenario: The amount delivered to the beneficiary is less than the quoted payout amount shown at the time of payment confirmation.

Your Rights:

• Investigation of discrepancy
• Refund or reimbursement of shortfall if caused by PayWolt or Provider error

How to Report:

1. Obtain confirmation from beneficiary of exact amount received
2. Contact Support within 14 days of transfer completion
3. Provide:
   • Transfer reference ID
   • Screenshot of quoted payout amount
   • Evidence of amount received (beneficiary bank statement or screenshot)

Investigation Process:

1. PayWolt retrieves execution records from Payout Provider (Wise, Flutterwave)
2. PayWolt compares quoted rate and amount with executed rate and amount
3. PayWolt determines cause of discrepancy

Possible Outcomes:

4.2.3 Beneficiary Bank Fees (Deductions)

Important Limitation:

PayWolt quotes and guarantees the payout amount sent by the Payout Provider to the beneficiary bank. However:

• Intermediary banks (in SWIFT transfers) may deduct fees before delivering funds
• Beneficiary banks may charge receiving fees (especially for international transfers)
• These fees are charged by third-party banks and are NOT controlled by PayWolt or our Providers

When Beneficiary Bank Fees Apply:

• SWIFT transfers (global): Intermediary bank fees common; typically €5-€25 per transfer
• SEPA transfers (Europe): Generally no beneficiary fees; SEPA regulations prohibit receiving bank charges
• African local transfers (Flutterwave): Beneficiary bank fees vary by country and bank

How to Minimize Beneficiary Fees:

• Use SEPA for European beneficiaries (no intermediary fees)
• Use local payout providers where available (Flutterwave for Africa)
• Verify with beneficiary whether their bank charges receiving fees before initiating transfer

No Refund Available: PayWolt cannot refund beneficiary bank fees as we do not receive or control these charges. However, we display warnings in the quote screen when beneficiary fees are common for the selected corridor.

4.3 Refunds for Duplicate Transfers

Scenario: You were charged multiple times for the same transfer due to system error or accidental re-submission.

Your Rights:

• Full refund of duplicate charges
• Immediate investigation

How to Report:

1. Contact Support within 30 days
2. Provide:
   • All transfer reference IDs involved
   • Bank/card statement showing multiple charges
   • Description of what happened

Refund Process:

• PayWolt investigates within 2 business days
• If duplicate confirmed: PayWolt initiates refund of duplicate charges immediately
• Processing time: 3-10 business days (depends on payment method)

Prevention: PayWolt implements idempotency controls to prevent duplicate submissions. However, if you:

• Click "Pay" multiple times in quick succession
• Submit payment via multiple browser tabs
• Experience network timeout and retry immediately

Duplicates may occasionally occur. We automatically detect and refund duplicates, but please report if you notice charges before our systems detect them.

4.4 Refunds for Unauthorized Transfers

Definition: An unauthorized transfer is one that you did NOT initiate, approve, or consent to.

Examples of Unauthorized Transfers:

• Someone accessed your PayWolt account without your permission and initiated a transfer
• Your payment credentials (card, bank account) were used without your authorization
• A transfer was initiated through fraud or account takeover

NOT Unauthorized:

• You authorized the transfer but made a mistake (wrong beneficiary, wrong amount) - see Section 5.1
• You shared your account credentials with someone and they initiated a transfer
• You initiated a transfer under deception by a third party (potential fraud - see Section 6)

4.4.1 Your Rights Under PSD2

If you are based in the European Economic Area (EEA) or UK, you have strong consumer protection rights under PSD2 (Payment Services Directive 2):

Your Liability for Unauthorized Transfers:

Important: Prompt reporting significantly improves fund recovery chances, even though you have 13 months to report.

4.4.2 How to Report Unauthorized Transfers

URGENT - Report Immediately:

1. Secure Your Account:

   • Change your PayWolt password immediately
   • Enable two-factor authentication (2FA) if not already enabled
   • Log out of all devices via Account Settings
   • Review and revoke any suspicious API access or connected apps

2. Report to PayWolt:

   • Email: security@paywolt.com (monitored 24/7)
   • In-App: Account > Security > Report Unauthorized Activity
   • Phone: [Emergency line if available]

3. Provide Information:

   • Which transfer(s) are unauthorized (reference IDs)
   • When you noticed the unauthorized activity
   • When you last accessed your account
   • Any suspicious emails, SMS, or calls you received recently
   • Whether you shared your credentials with anyone
   • Whether your device was lost, stolen, or compromised

4. Report to Payment Provider (if applicable):

   • If your card was used: Contact your card issuer to report fraud
   • If your bank account was used: Contact your bank to report unauthorized debit

4.4.3 Investigation Process

Provisional Credit: Under PSD2, if your unauthorized transaction report is not resolved within 10 business days, PayWolt will provide a provisional refund while the investigation continues. This credit may be reversed if the investigation determines the transaction was authorized.

4.4.4 Investigation Outcomes

4.4.5 Fund Recovery Attempts

PayWolt will attempt to recover funds from beneficiaries of unauthorized transfers:

Recovery Actions:

1. Immediate: Request Payout Provider to freeze beneficiary account (if transfer not yet completed)
2. Within 24 hours: Contact beneficiary via email/phone to request return of funds
3. Within 3 days: Coordinate with Provider to initiate reversal if beneficiary account still holds funds
4. Ongoing: Cooperate with law enforcement if criminal investigation is opened

Recovery Success Factors:

• High chance if transfer not yet completed (payout pending phase)
• Medium chance if completed <24 hours ago and beneficiary account still holds funds
• Low chance if completed >24 hours ago or beneficiary has withdrawn funds
• Very low chance if beneficiary account was closed or belongs to organized fraud operation

Your Refund Does Not Depend on Recovery: Under PSD2, if the transfer is determined to be unauthorized and you kept your credentials secure, you receive a full refund regardless of whether PayWolt successfully recovers funds from the beneficiary. PayWolt bears the loss in such cases.

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5. Refunds for Errors and Disputes

5.1 Transfers Sent to Wrong Beneficiary (User Error)

Scenario: You authorized the transfer, but you entered incorrect beneficiary details (wrong account number, wrong name, wrong country).

Important Distinction: This is NOT an unauthorized transfer. You authorized the payment and confirmed the beneficiary details. These transfers are generally final and non-refundable.

Your Responsibility: You are responsible for verifying beneficiary details before confirming payment. PayWolt provides:

• Beneficiary confirmation screen before payment
• Account number format validation
• Warnings for first-time beneficiaries
• Opportunity to review and edit before final submission

However, we cannot verify that the account number you entered belongs to the intended person.

5.1.1 If Beneficiary Details Were Invalid

Scenario: The account number or IBAN you entered does not exist or is invalid.

Outcome:

• Payout will fail (typically within 1-5 business days)
• Automatic refund initiated by PayWolt (see Section 4.1.2)
• Refund timeframe: 3-10 business days to your original payment method

No action required - you will be notified of the payout failure and refund.

5.1.2 If Beneficiary Details Were Valid But Wrong

Scenario: The account number you entered is valid, but it belongs to someone other than your intended beneficiary.

Outcome:

• Payout will succeed - funds will be delivered to the account number you provided
• No automatic refund - the transfer executed as you instructed

Your Options:

1. Contact the Beneficiary (if known):

   • Request they return the funds voluntarily
   • Provide your bank account details for them to send funds back

2. Contact PayWolt Support:

   • We will provide full transaction details for your records
   • We will attempt to contact the beneficiary on your behalf (best-effort basis)
   • We will coordinate with Payout Provider to request voluntary return

3. Contact Your Bank/Card Issuer (last resort):

   • If funds sent via card payment, you may have limited chargeback rights depending on your card network's rules
   • If funds sent via bank transfer, recovery options are extremely limited under banking regulations

Important Limitations:

Legal Context: Under international banking regulations (SEPA, SWIFT), once funds are delivered to a valid bank account, they belong to the account holder. The account holder is not legally obligated to return funds sent to them in error, though they may choose to do so voluntarily.

Recovery Success Rate:

• High (>80%) if beneficiary is known to you personally and cooperative
• Medium (30-50%) if beneficiary is unknown but responsive to PayWolt's contact attempts
• Low (<10%) if beneficiary does not respond or refuses to return funds

Prevention Tips:

• Double-check beneficiary account number before confirming
• Verify beneficiary name matches the name on their bank account exactly
• Send a small test transfer (€1-€10) before sending large amounts to a new beneficiary
• Request confirmation from beneficiary when they receive the test transfer before sending the full amount

5.2 Exchange Rate Disputes

Scenario: You believe the exchange rate applied to your transfer was incorrect or differs from the rate quoted.

5.2.1 Rate Discrepancy vs. Quoted Rate

Your Rights:

• You are entitled to receive the exchange rate that was displayed and accepted by you at the time of payment confirmation
• If the executed rate differs, you are entitled to a refund of the difference

How to Dispute:

1. Gather evidence:

   • Screenshot of quoted exchange rate (if you took one)
   • Transfer reference ID
   • Expected payout amount based on quoted rate
   • Actual payout amount received by beneficiary

2. Contact Support within 7 days of transfer completion

3. Provide all evidence listed above

Investigation:

• PayWolt retrieves quote record and execution record from Payout Provider
• PayWolt compares quoted rate with executed rate
• PayWolt calculates any discrepancy

Outcomes:

Important: PayWolt guarantees the exchange rate shown at the time you confirm payment, NOT the rate you saw when you initially requested a quote. Exchange rates can change between quote request and payment confirmation (typical quote validity: 15-30 minutes).

5.2.2 Rate Comparison with Other Services

Scenario: You believe the rate you received was worse than rates advertised by other services or shown on Google/XE.com.

Important Limitation: PayWolt is NOT obligated to match rates offered by other services or mid-market rates shown on currency converters.

How Rates Are Determined:

• Payout Providers (Wise, Flutterwave) set exchange rates based on their own pricing
• Rates include provider's margin (spread) and are commercially determined
• Rates vary by corridor, amount, and market conditions
• PayWolt displays the exact rate offered by the Provider; we do not add additional markup

No Refund Available: If the executed rate matches the rate you accepted at payment confirmation, no refund is available even if:

• Other services offer better rates
• Mid-market rates are better
• Rates improved shortly after your transfer

Your Options:

• Compare quotes from multiple corridors/providers before confirming payment
• Use a different service if you find a better rate elsewhere
• Wait for better rates (if time-sensitive transfers allow)

5.3 Transfer Delays

Scenario: Your transfer is taking longer than the estimated delivery time shown in the quote.

Estimated Delivery Times:

Important: Delivery times are estimates, not guarantees, unless specifically labeled as "guaranteed delivery."

5.3.1 Delays Within Estimated Timeframe

If your transfer is still within the estimated delivery window:

• No action required - wait for the full delivery window to elapse
• Check transfer status in the PayWolt app for real-time updates
• Contact Support for updates if you have urgent concerns

No refund available for delays within estimated timeframe.

5.3.2 Delays Beyond Estimated Timeframe

If your transfer has not completed after the estimated delivery window:

1. Contact Support immediately with transfer reference ID
2. PayWolt will:
   • Trace transfer with Payout Provider
   • Identify cause of delay (e.g., compliance review, beneficiary bank processing, intermediary bank delay)
   • Provide updated delivery estimate
   • Escalate with Provider if necessary

Possible Outcomes:

Compensation for Delays:

• If delay caused by PayWolt error: Refund of fees + compensation
• If delay caused by Provider error: PayWolt requests compensation from Provider on your behalf
• If delay caused by beneficiary bank or force majeure: No compensation available

5.3.3 Guaranteed Delivery Transfers

For corridors offering "Guaranteed Delivery" (if explicitly labeled in quote):

Guarantee:

• Transfer completes within guaranteed timeframe or full fee refund
• Does not apply if delay caused by force majeure, compliance holds, or incorrect beneficiary details

How to Claim:

• Transfer must exceed guaranteed delivery time
• Contact Support within 7 days of guaranteed delivery deadline
• Provide transfer reference ID

Remedy:

• Full refund of PayWolt fees
• Transfer still completes (you receive both fee refund and transfer completion)

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6. Refunds for Scams and Fraud (Authorized Push Payment Fraud)

6.1 Definition: Authorized Push Payment (APP) Fraud

Scenario: You were deceived or manipulated into authorizing a legitimate transfer to a fraudster.

Common Examples:

• Romance scams: Someone you met online built a relationship and convinced you to send money
• Investment scams: Fake investment opportunities promising high returns
• Impersonation scams: Fraudster pretended to be your bank, government, or PayWolt requesting payment
• Purchase scams: You paid for goods/services that were never delivered
• Invoice fraud: Fraudster intercepted legitimate invoice and changed bank details
• Family emergency scams: Fraudster claimed to be family member in urgent need

Critical Distinction:

• You authorized the transfer (entered your password, confirmed payment)
• You were deceived about the beneficiary's identity or purpose
• The transfer itself was processed correctly by PayWolt

Legal Position: Unlike unauthorized transactions (Section 4.4), APP fraud cases involve transfers that were technically authorized by you, even though you were deceived. Your refund rights depend on jurisdiction and specific circumstances.

6.2 Your Rights in APP Fraud Cases

6.2.1 European Economic Area (EEA) & UK

Regulatory Framework:

• PSD2 does NOT mandate refunds for APP fraud (only unauthorized transactions)
• Voluntary Codes: Some countries have voluntary APP fraud reimbursement codes (e.g., UK Contingent Reimbursement Model Code)
• Provider Discretion: Refunds are at the discretion of Collection Providers and PayWolt

PayWolt's Approach: We handle APP fraud reports on a case-by-case basis with good faith consideration of:

• Sophistication of the scam
• Whether you conducted reasonable due diligence
• Whether you ignored warnings from PayWolt or payment provider
• Whether fraud was reported promptly
• Likelihood of fund recovery

Factors Supporting Refund:

• ✅ Scam was highly sophisticated (e.g., impersonated bank using cloned website)
• ✅ You reported fraud within 24 hours of discovering it
• ✅ You had no reason to suspect fraud (credible story, professional appearance)
• ✅ PayWolt or Provider failed to display adequate fraud warnings
• ✅ Beneficiary account shows pattern of fraud (reported by others)

Factors Against Refund:

• ❌ You ignored warnings from PayWolt (e.g., "Are you sure you know this person?")
• ❌ Scam involved obvious red flags (e.g., "Send money to claim lottery winnings")
• ❌ You delayed reporting for weeks/months after discovering fraud
• ❌ You were conducting illegal activity (e.g., paying for prohibited goods)
• ❌ You failed to conduct basic due diligence (e.g., verify seller legitimacy)

6.2.2 Other Jurisdictions

APP Fraud Protections: APP fraud refund rights vary significantly by jurisdiction. Some countries have consumer protection laws that may apply.

Contact Support: If you believe you were scammed, contact Support immediately regardless of jurisdiction. We will:

• Assess your case individually
• Attempt fund recovery from beneficiary
• Coordinate with Providers and law enforcement
• Consider refund/compensation based on circumstances

6.3 How to Report APP Fraud

URGENT - Report Immediately:

1. Contact PayWolt:

   • Email: fraud@paywolt.com
   • In-App: Help > Report Fraud
   • Provide:
     • Transfer reference ID
     • Description of scam (how you were deceived)
     • Evidence (screenshots of conversations, fake websites, emails, etc.)
     • When you discovered the fraud

2. Report to Authorities:

   • Your local police - file fraud report
   • Action Fraud (UK): https://www.actionfraud.police.uk
   • FBI IC3 (US): https://www.ic3.gov
   • Europol (EU): Contact your national cybercrime unit

3. Report to Platform (if applicable):

   • If scam occurred via social media, dating app, or marketplace, report the fraudster's profile

4. Warn Others:

   • Share your experience on scam reporting sites (e.g., ScamAdviser, Trustpilot) to prevent others from falling victim

6.4 Investigation and Recovery

PayWolt's Actions:

Recovery Outcomes:

Discretionary Refund Decision:

Even if funds cannot be recovered, PayWolt may provide a discretionary refund in exceptional cases where:

• You exercised reasonable caution
• PayWolt or Provider failed to display adequate fraud warnings
• Scam was highly sophisticated
• You are experiencing financial hardship due to the fraud

Decisions are made on a case-by-case basis and are not guaranteed.

6.5 Preventing Future APP Fraud

PayWolt's Fraud Prevention Measures:

• ⚠️ Warnings when sending to new beneficiaries for the first time
• ⚠️ Alerts for high-risk corridors or unusual transfer patterns
• ⚠️ Confirmation screens: "Do you personally know this beneficiary?"
• 🔒 Mandatory cooling-off period for large first-time transfers (amount thresholds vary)

Your Responsibilities:

Resources:

• Which? Scam Alerts (UK): https://www.which.co.uk/consumer-rights/scams
• FTC Scam Alerts (US): https://www.ftc.gov/scams
• EU Consumer Protection: https://ec.europa.eu/info/live-work-travel-eu/consumer-rights-and-complaints

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7. Fee Refunds

7.1 PayWolt Platform Fees

Fee Structure:

PayWolt charges a platform orchestration fee for facilitating transfers. This fee is displayed separately in the quote breakdown:

7.2 Fee Refund Scenarios

7.2.1 Transfer Cancelled Before Payout

Scenario: You cancel transfer during "Payout Pending" phase (see Section 3.3).

Fee Refunds:

• PayWolt Platform Fee: ✅ Full refund
• Provider Payout Fee: ✅ Full refund (payout not executed)
• Provider Collection Fee: ❌ No refund - collection already processed; payment network fees incurred
• FX Spread: ✅ Full refund (no FX conversion occurred)

Example:

• Transfer Quote: Send ₦500,000 → Receive €1,000
• Fees Breakdown:
  • PayWolt Fee: €5.00
  • Flutterwave Collection Fee: ₦2,000 (~€4.00)
  • Wise Payout Fee: €3.00
• Total Cost: ₦500,000 + ₦2,000 = ₦502,000 (€1,012 equivalent)

If Cancelled:

• Refund to your payment method: ₦502,000
• Minus Flutterwave Collection Fee: ₦2,000 (non-refundable)
• Net Refund: ₦500,000 (~€1,008)
• Cost to You: ₦2,000 (~€4.00)

7.2.2 Transfer Failed (Technical Error)

Scenario: Transfer failed due to PayWolt system error, Provider system error, or technical issue.

Fee Refunds:

• All fees: ✅ Full refund (PayWolt, Provider collection, Provider payout)

Processing:

• Automatic refund initiated within 1 business day
• Timeframe: 3-10 business days to original payment method

7.2.3 Transfer Failed (Invalid Beneficiary Details)

Scenario: Transfer failed because you entered invalid beneficiary account details (see Section 5.1.1).

Fee Refunds:

• PayWolt Platform Fee: ✅ Full refund
• Provider Payout Fee: ✅ Full refund (payout rejected)
• Provider Collection Fee: ❌ No refund - payment processing fees incurred by Provider

Rationale: Collection Providers (Stripe, Flutterwave) incur payment network fees when processing your payment, regardless of whether the payout succeeds. These fees are non-refundable.

How to Avoid:

• Double-check beneficiary account number before confirming payment
• Use PayWolt's account number format validation
• Send a small test transfer first for new beneficiaries

7.2.4 Fee Charged in Error

Scenario: You were charged a fee that was not disclosed in the quote or was higher than quoted.

Your Rights:

• Full refund of incorrectly charged fee
• Immediate investigation

How to Report:

1. Contact Support within 30 days of transfer
2. Provide:
   • Transfer reference ID
   • Screenshot of fee breakdown in quote (if available)
   • Bank/card statement showing fee charged

Refund:

• If error confirmed: Full refund within 3-5 business days
• If no error found: Explanation of fee breakdown

7.2.5 Subscription/Membership Fees (Future Feature)

Not Currently Applicable: PayWolt does not currently charge subscription or membership fees. All fees are per-transfer and disclosed in quotes.

If subscription fees are introduced in the future:

• Separate refund policy will be published
• Subscription fees are generally non-refundable after the billing period begins

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8. Refund Processing Timelines

8.1 Refund Initiation Timeline

When PayWolt Initiates Refunds:

Business Days: Business days exclude weekends and public holidays in the jurisdiction of the Collection Provider:

• Stripe: US business days (NYSE calendar)
• Flutterwave: Nigerian business days (CBN calendar)

8.2 Refund Processing Timeline (by Payment Method)

Once PayWolt initiates a refund with the Collection Provider, processing time depends on the payment method and Provider:

Important Notes:

1. Card Refunds (Stripe):

   • Stripe processes the refund immediately
   • Timeframe depends on your card issuer (bank): 5-10 business days is typical, but some banks may take up to 15 days
   • Refund appears as a credit on your card statement (may show as separate transaction, not reversal of original charge)

2. Bank Transfer Refunds (Flutterwave):

   • Flutterwave initiates bank credit within 24 hours
   • Timeframe depends on your bank's processing speed: 1-5 business days additional
   • Refund appears as a credit to your bank account

3. Mobile Money Refunds (Flutterwave):

   • Fastest refund method
   • Refund credited directly to your mobile wallet
   • You receive SMS notification when refund is completed

8.3 Tracking Your Refund

Visibility:

If Refund Is Delayed:

1. Wait the full expected timeframe (including maximum time)
2. Check your bank/card statement - refund may have been completed but not yet visible
3. Contact Support if refund not received after maximum timeframe:
   • Provide transfer reference ID and refund reference ID
   • PayWolt will trace with Provider and provide evidence of refund completion
   • If Provider confirms refund sent but you did not receive, contact your bank/card issuer with Provider reference ID

8.4 Refunds for Closed Accounts

Scenario: Your bank account or card used for payment has been closed since the original transfer.

Refund Process:

Alternative Refund Method:

If refund to original payment method is not possible:

1. Contact Support with:
   • Transfer reference ID
   • Proof that original account is closed (bank letter)
   • Alternative bank account details (in your name)
2. PayWolt will verify your identity
3. Refund processed to alternative account (may take additional 5-10 business days for verification and processing)

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9. Disputes and Escalation

9.1 How to Dispute a Refund Decision

If you disagree with PayWolt's refund decision:

1. Request Reconsideration:

   • Email: complaints@paywolt.com
   • Subject: "Refund Dispute - [Transfer Reference ID]"
   • Provide:
     • Transfer reference ID
     • Original refund request details
     • PayWolt's decision and reason
     • Why you believe the decision is incorrect
     • Any new evidence not previously provided

2. Escalation Review:

   • Complaint reviewed by senior compliance officer
   • Fresh assessment of case
   • Response within 15 business days

3. Final Decision:

   • PayWolt provides final written decision with full reasoning
   • Decision includes information about external dispute resolution options (see Section 9.2)

9.2 External Dispute Resolution

If you are not satisfied with PayWolt's final decision, you have the right to refer the matter to external dispute resolution services. These services are free of charge to you.

9.2.1 Alternative Dispute Resolution (ADR)

European Economic Area (EEA) Residents:

National Financial Ombudsmen (Selected Countries):

United Kingdom Residents:

Before Using ADR:

1. You must first raise your complaint with PayWolt
2. Allow PayWolt 15 business days to investigate and respond
3. If unresolved or if you are dissatisfied with the response, proceed to ADR

ADR Process:

1. Submit complaint to relevant ADR service
2. ADR service reviews evidence from both parties
3. ADR service issues decision (typically within 90 days)
4. Decision is binding on PayWolt if you accept it
5. You retain right to court proceedings if you reject decision

9.2.2 Regulatory Complaints

If you believe PayWolt violated regulations:

PayWolt partners with licensed Payment Service Providers. You may direct regulatory complaints to:

For Services Provided via Stripe:

• Ireland: Central Bank of Ireland - https://www.centralbank.ie
• US (if applicable): State financial regulators or CFPB - https://www.consumerfinance.gov

For Services Provided via Wise:

• Belgium: National Bank of Belgium (NBB) - https://www.nbb.be

For Services Provided via Flutterwave:

• Nigeria: Central Bank of Nigeria (CBN) - https://www.cbn.gov.ng
• Kenya: Central Bank of Kenya - https://www.centralbank.go.ke
• Other African jurisdictions: Contact Support for relevant regulator

For General Data Protection (GDPR) Complaints:

• Your national Data Protection Authority (DPA)
• EU DPA List: https://edpb.europa.eu/about-edpb/board/members_en

9.2.3 Legal Action

Your Right to Court:

You retain the right to bring legal proceedings in a court of competent jurisdiction at any time, regardless of whether you use ADR or regulatory complaint procedures.

Applicable Law and Jurisdiction:

See Terms of Service Section 18 (Governing Law and Jurisdiction) for details on applicable law and jurisdiction.

Small Claims:

For disputes involving smaller amounts, you may be able to use small claims court procedures in your jurisdiction, which are typically faster and less expensive than full court proceedings.

Legal Advice:

If considering legal action, we recommend seeking independent legal advice. Some jurisdictions offer free legal aid for consumers.

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10. Important Limitations and Exclusions

10.1 PayWolt's Role and Liability

PayWolt is a Technology Service Provider, NOT a Payment Institution:

We Are Responsible For:

• ✅ Accurate quote display
• ✅ Secure transmission of instructions to Providers
• ✅ Monitoring transfer status and notifying you
• ✅ Facilitating refund requests with Providers
• ✅ Communicating with you regarding refunds

We Are NOT Responsible For:

• ❌ Provider payment processing failures or delays (except where caused by our incorrect instructions)
• ❌ Payment network or banking system failures
• ❌ Beneficiary bank fees or delays
• ❌ Provider refund processing delays beyond our control
• ❌ Inability to recover funds sent to correct beneficiary account (user error - see Section 5.1)
• ❌ APP fraud where you authorized transfer (discretionary refunds only - see Section 6)

Liability Cap:

To the maximum extent permitted by law, PayWolt's total aggregate liability for any refund-related claims is limited to:

• Direct damages: The amount of the transfer (send amount + fees)
• Indirect damages: No liability for consequential, incidental, or punitive damages

Exceptions to Liability Cap:

• Death or personal injury caused by our negligence
• Fraud or fraudulent misrepresentation by PayWolt
• Violations of consumer protection laws that cannot be limited by contract
• Gross negligence or willful misconduct by PayWolt

10.2 Force Majeure

No Refund or Compensation for Force Majeure Events:

We are not liable for delays or failures in refund processing caused by events beyond our reasonable control, including:

• Natural disasters (earthquakes, floods, hurricanes, pandemics)
• War, terrorism, civil unrest, or riot
• Government actions (sanctions, capital controls, regulatory changes)
• Strikes or labor disputes affecting payment networks or banking systems
• Widespread internet or power outages
• Provider system failures (where Provider is also affected by force majeure)

Our Commitment:

• We will notify you promptly of force majeure events affecting your refund
• We will resume normal refund processing as quickly as reasonably possible once the event ends
• We will cooperate with you to minimize impact where possible

Your Rights: Force majeure does not affect your legal rights under mandatory consumer protection laws. If a force majeure event persists for an unreasonable duration, you may have additional rights (consult legal advice).

10.3 Third-Party Actions

Provider Refund Policies:

PayWolt facilitates refunds, but refunds are executed by Collection Providers (Stripe, Flutterwave). Provider refund policies and processing times apply:

• Stripe Refund Policy: https://stripe.com/refund-policy
• Flutterwave Refund Policy: https://flutterwave.com/refund-policy
• Wise Terms: https://wise.com/terms

PayWolt Cannot Guarantee:

• Provider refund processing times (we display typical timeframes)
• Provider willingness to process discretionary refunds
• Provider system availability

Provider Disputes:

If you believe a Provider mishandled your refund:

1. Contact PayWolt first - we will escalate with the Provider
2. If unresolved, you may contact the Provider directly:
   • Stripe Support: https://support.stripe.com
   • Flutterwave Support: support@flutterwave.com
   • Wise Support: https://wise.com/help
3. You may file complaint with Provider's regulator (see Section 9.2.2)

10.4 Refund Abuse and Account Suspension

Prohibited Conduct:

The following behaviors constitute abuse of our refund and cancellation policies:

• Filing false unauthorized transaction claims
• Disputing legitimate transfers via card chargeback
• Repeatedly canceling transfers to exploit exchange rate fluctuations
• Using refunds to obtain interest-free short-term loans
• Providing false information in refund requests
• Coordinating with beneficiaries to falsely claim non-delivery

Consequences:

Investigation:

Before taking action, PayWolt will:

• Review evidence (transaction history, communications, patterns)
• Provide opportunity for you to explain
• Consider good faith mistakes vs. intentional abuse

Legitimate Disputes:

Using your legitimate consumer rights (e.g., filing chargeback for genuinely unauthorized transaction, reporting legitimate fraud) is NEVER considered abuse and will not result in account suspension.

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11. Special Circumstances

11.1 Deceased Account Holder

Scenario: Account holder has passed away and estate/family seeks refund of pending transfer.

Required Documentation:

To process refund to estate:

1. Death certificate (certified copy)
2. Proof of executor/administrator appointment (letters of administration, probate grant)
3. Identification of executor/administrator
4. Bank account details in name of estate or executor

Process:

• Contact Support at estates@paywolt.com
• Provide required documentation
• PayWolt verifies authenticity (may take 10-20 business days)
• Refund processed to estate account

Timeframe: 20-40 business days from receipt of complete documentation

11.2 Account Compromised (Ongoing Unauthorized Activity)

Scenario: Your account is currently being accessed by unauthorized party and transfers are being initiated in real-time.

EMERGENCY ACTIONS:

1. Immediately:

   • Email security@paywolt.com with subject "URGENT - Account Compromise"
   • Request immediate account freeze

2. PayWolt's Response:

   • Account frozen within 2 hours (24/7 monitoring)
   • All pending transfers cancelled
   • Investigation initiated

3. Refund Process:

   • Pending transfers: Cancelled before payout (full refund)
   • Completed transfers: See Section 4.4 (Unauthorized Transactions)

Prevention:

• Enable two-factor authentication (2FA)
• Use strong, unique password
• Monitor account regularly
• Log out of shared devices

11.3 Bankruptcy or Insolvency

Your Bankruptcy:

If you declare bankruptcy or enter insolvency proceedings:

• Pending transfers may be cancelled by your insolvency practitioner
• Refunds processed to insolvency practitioner's client account
• Contact insolvencyLawyers@paywolt.com with court documents

PayWolt's Insolvency (Hypothetical):

PayWolt does NOT hold customer funds. In the unlikely event of PayWolt insolvency:

• Your funds are safe - held by licensed Providers (Stripe, Wise, Flutterwave), not PayWolt
• Pending refunds will be processed by Providers according to their terms
• You may contact Providers directly to request refund completion

Provider Insolvency:

Payment Service Providers are regulated and must maintain safeguarding arrangements:

• Stripe: Customer funds segregated per regulatory requirements
• Wise: Customer funds protected under EMI safeguarding rules (Belgium)
• Flutterwave: Customer funds held in trust accounts per CBN regulations

In event of Provider insolvency, contact the Provider's regulator or appointed administrator.

11.4 Sanctions or Regulatory Holds

Scenario: Your refund is delayed due to sanctions screening or regulatory investigation.

Explanation:

PayWolt and our Providers are required by law to:

• Screen all transactions against sanctions lists (EU, UN, OFAC, UK)
• Freeze funds if sanctions match is detected
• Cooperate with law enforcement and regulatory investigations
• Comply with court orders

Your Rights:

If your refund is held due to sanctions or regulatory reasons:

1. You will be notified (unless prohibited by law - e.g., "tipping off" restrictions)
2. Explanation provided to the extent legally permissible
3. Opportunity to provide clarification (e.g., proof you are not the sanctioned individual with similar name)

Resolution:

• False Positive Match: Refund released within 5-10 business days after clarification
• Ongoing Investigation: Refund held until investigation concludes (timeframe varies)
• Sanctions Violation Confirmed: Funds may be frozen indefinitely or transferred to authorities per legal requirements

Legal Advice:

If your refund is held for regulatory reasons, we strongly recommend seeking independent legal advice. PayWolt cannot provide legal advice and must comply with legal obligations regardless of impact on you.

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12. Contact Information

12.1 Refund and Cancellation Requests

12.2 Required Information

When contacting us regarding refunds, please provide:

✅ Always Include:

• Full name on account
• Email address associated with account
• Transfer reference ID (e.g., TXN-ABC123-XYZ)
• Transaction date and amount
• Clear description of issue

✅ Include If Applicable:

• Screenshots of quotes, confirmations, or errors
• Bank/card statements showing charges
• Evidence of issue (e.g., beneficiary confirmation of amount received)
• Correspondence with beneficiary (if relevant)

12.3 Business Hours and Response Times

PayWolt Support Availability:

Response Time Targets:

• Emergency (unauthorized transactions, ongoing fraud): 2 hours
• Urgent (cancellations, time-sensitive refunds): 4 hours
• Standard (general refund inquiries): 24-48 hours
• Complex (investigations, disputes): 5-15 business days

Public Holidays:

Support may be limited on public holidays in Greece (PayWolt HQ location) and provider jurisdictions. Automated responses will provide expected response time.

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13. Policy Updates and Changes

13.1 Updates to This Policy

We may update this Refund & Cancellation Policy from time to time to reflect:

• Changes to our service model or provider partnerships
• Changes to applicable laws or regulations
• Improvements to our refund processes
• User feedback and operational experience

Notification of Changes:

Material Changes Definition:

Changes that materially affect your rights include:

• Reduction in refund eligibility
• Increase in refund processing timeframes
• New fees or charges related to refunds
• Changes to liability limitations

Your Rights:

If you do not agree with material changes:

• You may close your account before the effective date
• Existing pending refunds will be processed under the policy version in effect at the time of the original transfer

13.2 Version History

Accessing Previous Versions:

Previous versions of this policy are available upon request. Contact legal@paywolt.com.

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14. Regulatory and Legal Information

14.1 Regulatory Framework

This Refund & Cancellation Policy is designed to comply with:

• PSD2 (Payment Services Directive 2 - Directive (EU) 2015/2366): Unauthorized transaction rights, execution timeframes
• Consumer Rights Directive (Directive 2011/83/EU): Right of withdrawal (where applicable)
• GDPR (General Data Protection Regulation - Regulation (EU) 2016/679): Data processing in refund investigations
• National consumer protection laws of EEA member states
• Payment network rules (Visa, Mastercard, SEPA, SWIFT)

Important: PayWolt is a technology service provider, not a regulated payment institution. However, we design our policies to align with payment services regulations to protect consumers.

14.2 Payment Service Provider Regulation

Our licensed payment service provider partners are regulated as follows:

Implications:

• Providers must comply with regulatory requirements for refund processing
• You have regulatory complaint rights against Providers (see Section 9.2.2)
• Provider funds safeguarding protects your money in event of Provider insolvency

14.3 Governing Law

This Refund & Cancellation Policy is governed by:

• Primary: Laws of the Hellenic Republic (Greece) - PayWolt's country of incorporation
• Consumer Protection: If you are a consumer resident in the EEA/UK, you benefit from mandatory consumer protection laws of your country of residence, which cannot be excluded by contract

Jurisdiction:

Disputes may be brought in:

• Courts of Athens, Greece (PayWolt's jurisdiction)
• Courts of your country of residence (if you are a consumer in the EEA/UK)

See Terms of Service Section 18 for full details on governing law and jurisdiction.

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15. Document Information

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16. Glossary

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This Refund & Cancellation Policy is provided in English. The English version prevails in case of any discrepancy with translations.

Last Updated: 2025-01-05 Version: 2.0 © 2025 PayWolt Platform - All Rights Reserved