Refund Policy

Last Updated: 5/11/2026 | Version 1.0

1. Overview

This Refund Policy explains how refund requests are handled in connection with the use of the software, technology, data, and program-administration services provided by Kashu, Inc. ("Kashu," "we," "us," or "our"), a Wyoming corporation, through the Kashu platform, mobile and web applications, websites, APIs, and related services (collectively, the "Services"). The Services consist of three integrated pillars: Platform Access, Transaction Intelligence, and Program Administration, as further described in the Kashu Terms of Service.

Kashu is a software platform. Kashu does not hold, transmit, or issue funds. Refund mechanics flow through Kashu's partners, as described in Section 3.

These rules exist to protect users, maintain regulatory and card-network compliance, and ensure proper reconciliation with Kashu's partners.

2. Definitions

• "User," "you," or "your" — the U.S.-organized business entity that is a customer of Kashu, together with its Authorized Individuals.
• "Authorized Individual" — a natural person authorized to act on behalf of the User, including a beneficial owner, control person, authorized signatory, or authorized employee.
• "Program Account" — the account established for a business User to access the Services. Funds associated with a Program Account are held in custodial For-Benefit-Of (FBO) accounts at Fresno First Bank, Member FDIC, by Monarch Technologies, Inc.
• "Platform Service Fee" — the fee paid to Kashu in consideration of the three pillars of the Services, as described in the Terms of Service and the STSA.
• "Business Day" — a day, other than a Saturday, Sunday, or U.S. federal holiday, on which commercial banks in the United States are open for business.

3. Custody and Refund Mechanics

Kashu has no legal, beneficial, or equitable interest in customer funds at any time and does not hold, transmit, settle, authorize, or directly issue refunds. Refund activity is performed by Kashu's partners, which include licensed acquirers and card payment providers, a licensed money transmitter, and a custodial bank. As of the date of this Policy, Kashu's partners include Monarch Technologies, Inc. (MSB Registration No. 31000186536125; NMLS ID 1908316), which holds customer funds in custodial For-Benefit-Of (FBO) accounts at Fresno First Bank, Member FDIC, and initiates ACH disbursements and ACH refunds where applicable. Card-funded transactions, including card-funded refunds, are authorized, settled, and issued by Kashu's acquirer and card payment providers in accordance with the rules of Visa, Mastercard, and other applicable card networks.

Kashu's role in connection with refunds is limited to reviewing requests, applying this Policy, and instructing the applicable Kashu partner to initiate approved refunds. Kashu does not directly process, authorize, settle, or issue any refund.

4. Eligibility for Refunds

A refund may be approved if one of the following applies:

• Duplicate Charge, the same transaction was processed more than once.
• Incorrect Amount Charged, a system or processing error caused an inaccurate debit.
• Transaction Cancelled Before Settlement, the transaction was stopped prior to final clearing through the card network.
• System or Processing Error, a technical or network failure resulted in an invalid or incomplete charge.
• Compliance or Regulatory Requirement, a refund is required to satisfy AML, KYC, KYB, OFAC, sanctions, or card-network obligations.

Refunds will not be issued for:

• Completed and settled transactions initiated correctly by the User;
• Funds that have already been transferred, withdrawn, or disbursed from the Program Account;
• Platform Service Fees, except as described in Section 6;
• Transactions under review for dispute, fraud, chargeback, or compliance investigation;
• Requests submitted by a person who is not an Authorized Individual of the User.

5. Refund Destination

Refunds are returned to the original funding instrument whenever possible, in accordance with the rules of the applicable card network, payment provider, and financial institution.

• If the funding instrument was a credit or debit card, the refund is issued back to the same card account by Kashu's partners in accordance with applicable card-network rules.
• If the funding instrument was a bank account, the refund is issued by ACH back to the originating account by Kashu's partners.
• Refunds will not be issued in cash, check, or to a financial instrument other than the original funding instrument.

If the original funding instrument has been closed or is otherwise unavailable, Kashu will work with its partners to determine the appropriate treatment, which may include holding the funds in the Program Account pending additional verification or returning the funds to the issuing institution in accordance with card-network or banking rules.

6. Platform Service Fee

The Platform Service Fee is consideration for the software, technology, data, and program-administration services provided, and is earned upon transaction completion and non-refundable, except in the following limited circumstances:

• The underlying transaction did not complete or did not settle, in which case the Platform Service Fee will not be charged;
• A duplicate transaction was processed in error, in which case the Platform Service Fee associated with the duplicate (and only the duplicate) will be refunded together with the duplicated principal;
• A refund of the Platform Service Fee is required by applicable law, regulator direction, or card-network rule.

Where a partial refund of principal is approved, the Platform Service Fee remains fully earned and non-refundable, except as set forth above.

7. Processing Timeframes

Kashu instructs its partners to initiate approved refunds promptly after approval. Settlement to the original funding instrument is performed by Kashu's partners and the issuing or receiving financial institution, and the time for funds to appear on the cardholder statement or in the receiving bank account varies depending on the card network, the financial institutions involved, and any additional review.

Kashu does not control downstream processing or settlement timelines. Delays may occur due to additional verification, intermediary-bank holds, card-network settlement cycles, or compliance review.

8. How to Request a Refund

To request a refund, an Authorized Individual must submit a written request to the address listed in Section 16 (Contact Information) with the following details:

• Business legal name and Employer Identification Number (EIN);
• Program Account identifier;
• Name, title, and role of the Authorized Individual submitting the request;
• Transaction ID, date, and amount;
• Funding instrument identifier (e.g., last four digits of the card or bank account);
• Detailed reason for the refund request;
• Any supporting documentation.

For security, additional identity verification or supporting documentation may be required before a review can begin.

9. Review and Approval Process

All refund requests are reviewed by Kashu's Risk and Compliance teams. Each request is assessed to confirm that:

• The transaction qualifies under the eligibility criteria in Section 4;
• There is no indication of fraud, misuse, chargeback abuse, or AUP violation;
• The refund complies with Visa, Mastercard, and other applicable card-network rules; and
• The refund complies with applicable banking, AML, KYC, KYB, OFAC, and sanctions standards.

Refunds are approved or denied at Kashu's sole discretion in accordance with this Policy and applicable law. If denied, the requesting Authorized Individual will receive a written explanation. Once an approved refund has been instructed and settled by Kashu's partners, the refund is final.

10. High-Value Refunds

Larger refund requests may require additional verification, enhanced due diligence, and internal sign-off. These reviews help ensure that refund instructions are consistent with anti-money-laundering standards, card-network settlement requirements, and the rules of Kashu's partners. Processing times for larger refunds may be extended.

11. Holds and Freezes

Kashu may instruct its partners to hold or freeze a refund amount, or to delay an instruction, pending compliance review, dispute investigation, regulatory cooperation, or partner direction. Refunds released after a hold are subject to the same downstream processing timelines as approved refunds.

12. Refunds vs. Chargebacks

Refunds are reviewed by Kashu and, if approved, instructed by Kashu to the applicable Kashu partner. Chargebacks, by contrast, are initiated by a cardholder through their issuing bank under the dispute process defined by the applicable card network, and are processed by the card network, the cardholder's issuing bank, and Kashu's partners without Kashu's involvement in the decisioning step.

If a chargeback is filed while a refund request is pending, Kashu will suspend its refund review until the chargeback is resolved by the card network. Card-network rules and the cardholder's agreement with the issuing bank govern chargeback rights, not this Policy. Duplicate or coordinated refund and chargeback claims for the same transaction may result in account suspension, instructions to hold funds in the Program Account.

13. Compliance and Limitations

All refunds are subject to applicable:

• Visa, Mastercard, and other applicable card-network operating regulations;
• Banking, AML, KYC, KYB, OFAC, and sanctions compliance standards;
• The processing, settlement, and ACH rules of Kashu's partners; and
• Kashu's internal Risk Management and Fraud Prevention policies and the Acceptable Use Policy.

Kashu reserves the right to deny, delay, or instruct the hold of refunds that:

• Conflict with ongoing investigations, legal holds, or regulatory cooperation;
• Appear to circumvent AML, KYB, sanctions screening, or fraud-prevention controls;
• Are otherwise inconsistent with card-network, partner, financial-institution, or regulatory obligations.

Refund instructions may be reversed by Kashu's partners where fraudulent behavior, chargeback misuse, or non-compliance is identified after issuance.

14. Liability Disclaimer

Kashu is not responsible for delays or actions caused by Kashu's partners, card networks, issuing banks, intermediary banks, network outages, or other third-party financial institutions or processors.

Refunds are issued only to the verified original funding instrument. Kashu bears no liability for losses arising from changes to user banking details, account closures, card expirations, or instructions provided by the User that are subsequently disputed. A refund cannot exceed the original transaction amount.

15. Relationships to Other Policies

This Policy forms part of, and is incorporated by reference into, the Kashu Terms of Service and the Kashu Software & Technology Services Agreement ("STSA") (the master platform agreement for the Kashu Wallet, entered into between Kashu and each business customer at onboarding; it does not apply to Kashu Pay payment-processing services), and is read together with the Acceptable Use Policy, the Privacy Policy, and any other published Kashu compliance documents. In the event of any conflict between these documents, the order of precedence is: (1) STSA → (2) Terms of Service → (3) Acceptable Use Policy → (4) this Refund Policy. All other policies and disclosures are subordinate to the above.

16. Contact Information

For refund requests, questions about this Policy, or to check the status of a submitted refund, you may contact us as follows:

Kashu, Inc.

Attn: Refunds, Risk & Compliance

1603 Capitol Ave, Ste 415 #674380

Cheyenne, WY 82001

Email: help@kashupay.com

17. Modifications

Kashu reserves the right to modify or update this Policy at any time to reflect changes in regulations, card-network rules, the requirements of Kashu's partners, or internal processes. Non-material changes are effective upon posting. Material changes will be communicated through the Services or by email at least thirty (30) days before they take effect, unless a shorter period is required by law, regulator direction, or partner-institution requirements. Your continued use of the Services after the effective date constitutes acceptance of the modified Policy.