Effective Date: May 2025  |  Version 1.0  |  Issued by: Vestra Holdings

Introduction

This Refunds Policy sets out the terms and conditions under which Vestra Holdings may, at its discretion or as required by applicable law, process refunds in connection with transactions conducted on the Vestra Real Estate Investment Platform. Vestra operates as a modern, technology-driven real estate investment platform that enables users to invest in full or fractional shares of verified properties, trade through a peer-to-peer marketplace, and manage funds within a fully regulated fintech ecosystem.

Vestra maintains a strict approach to refunds. Given the nature of real estate investment and financial services, the vast majority of fees, charges, and completed transactions are final and non-refundable. Refunds are only considered in specific, clearly defined circumstances as outlined in this Policy.

By accessing or using the Vestra platform, users acknowledge and accept the terms of this Refunds Policy in full. Users are strongly encouraged to review this document carefully before initiating any transaction or fee payment.

Section 1: Definitions

For the purposes of this Policy, the following terms carry the meanings assigned to them below unless the context expressly requires otherwise.

Refund. The return of funds to a user following a determination by Vestra that a payment or transaction qualifies for reimbursement under the terms of this Policy.

Eligible Transaction. A transaction or fee payment that meets one or more of the qualifying conditions set out in Section 3 of this Policy, making it potentially eligible for refund consideration.

Non-Refundable Fee. Any fee or charge that is explicitly excluded from refund eligibility under this Policy, regardless of the circumstances surrounding the transaction.

Platform Error. A verified technical fault, system malfunction, or processing failure originating from within the Vestra platform infrastructure that directly caused an incorrect or unintended charge to a user's account.

Duplicate Transaction. An instance where an identical fee or charge has been processed more than once for the same transaction as a result of a system error, resulting in an unintended double or multiple debit.

Erroneous Transaction. A payment or charge applied to a user's account incorrectly due to a processing error, miscalculation, or administrative fault on the part of Vestra.

Business Day. Any day that is not a Saturday, Sunday, or a public holiday in the primary jurisdiction of operation of Vestra Holdings. Processing timelines referenced in this Policy are measured in business days.

Refund Request. A formal submission made by a user through Vestra's official support channels requesting the review and potential reimbursement of a specific transaction or fee.

Review Period. The period during which Vestra's compliance and support teams assess a submitted Refund Request to determine its eligibility and outcome.

Dispute. A formal objection raised by a user regarding a transaction, charge, or refund decision, submitted through the process described in Section 7 of this Policy.

Section 2: General Principles

Vestra's approach to refunds is grounded in the following core principles, which govern how all refund-related matters are assessed and handled.

Refund Eligibility. Refunds are not a standard feature of the Vestra platform. They are only considered in exceptional circumstances that fall within the specific qualifying conditions defined in this Policy. The fact that a user is dissatisfied with an investment outcome, a fee amount, or a platform feature does not in itself constitute grounds for a refund.

Finality of Completed Transactions. Once a transaction has been fully processed and confirmed on the Vestra platform, it is considered final. Completed deposits, investment commitments, marketplace trades, and associated fees are not reversible except in the limited circumstances described in Section 3 of this Policy.

No Refunds on Investment Returns or Losses. Vestra does not offer refunds in respect of investment performance, fluctuations in property value, changes in projected returns, or any losses incurred through participation in the marketplace or investment products available on the platform. All investments carry inherent risk and users accept this when engaging with the platform.

External Fee Payments. Fees paid externally outside of the Vestra platform — including Gateway Activation Fees — are governed by the terms of the relevant external payment provider. Vestra is not liable for and cannot process refunds for charges collected outside its platform infrastructure.

Good Faith Assessment. All Refund Requests will be assessed in good faith by the Vestra support and compliance teams. However, submission of a Refund Request does not guarantee a refund. The final determination rests with Vestra, subject to any applicable regulatory requirements.

Regulatory Compliance. In circumstances where a refund is required under applicable financial regulations, consumer protection legislation, or a binding legal order, Vestra will process such refunds in accordance with its legal obligations, irrespective of the general non-refundable nature of fees.

Section 3: Refund Eligibility

Refunds on the Vestra platform are strictly limited. The only category of payment that may be considered for a refund under this Policy is the deposit fee, and only where one or more of the qualifying conditions below is established and verified by Vestra.

3.1 Refundable Payment Category

Deposit Fee. The standard deposit may be eligible for a refund in the limited circumstances set out in Section 3.2. All other fees charged on the Vestra platform — including but not limited to KYC verification fees, reinstatement fees, processing fees, gateway activation fees, marketplace transaction fees, and currency conversion charges — are strictly non-refundable under all circumstances.

3.2 Qualifying Conditions for Refund Eligibility

A deposit fee refund will only be considered where at least one of the following conditions is present and can be verified by Vestra to its reasonable satisfaction.

  • Platform Error or Technical Fault. A verified malfunction, system error, or processing failure originating from within the Vestra platform directly caused the deposit fee to be applied incorrectly, applied more than once, or charged at an amount inconsistent with the rate disclosed to the user at the time of the transaction.

  • Duplicate or Erroneous Transaction. The deposit fee was charged more than once for the same single deposit transaction due to a technical or administrative error on the part of Vestra, or the fee was applied to a transaction that should not have attracted a charge under the prevailing fee schedule.

  • Regulatory or Legal Obligation. A refund of the deposit fee is required under applicable financial regulation, consumer protection law, or a binding order from a competent regulatory authority or court of jurisdiction.

  • User Dispute Upheld After Review. A user has submitted a formal Refund Request and, following full review by Vestra's compliance team through the dispute process described in Section 7 of this Policy, Vestra determines that the fee was charged in error or that the circumstances of the transaction warrant reimbursement.

The mere submission of a Refund Request or Dispute does not establish eligibility. Eligibility is determined solely by Vestra following a completed review of the submitted evidence and transaction records.

3.3 Non-Qualifying Circumstances

The following circumstances do not constitute grounds for a refund under any provision of this Policy.

  • Change of mind or a decision by the user to withdraw from a deposit after it has been processed and confirmed.

  • Dissatisfaction with investment performance, returns, or platform outcomes.

  • Failure by the user to read or understand the applicable fee schedule prior to initiating a transaction.

  • Disputes with third-party payment providers, banks, or cryptocurrency networks that are unrelated to a fault originating from the Vestra platform.

  • Transactions that have been flagged, suspended, or restricted due to compliance, anti-money laundering, or fraud investigations.

  • Requests submitted outside the timeframe specified in Section 4 of this Policy.

Section 4: Refund Request Timeframe

Users who believe they have grounds for a refund under Section 3 of this Policy must submit their Refund Request within the timeframe prescribed below. Requests submitted outside this window will not be considered, except where required by applicable law.

  • Standard Submission Window: All Refund Requests must be submitted within 14 calendar days of the date on which the transaction giving rise to the request was processed and confirmed on the platform.

  • Platform Error or Duplicate Transaction: Where the basis of the request is a platform error or duplicate charge, the 14-day window begins from the date the user became aware of, or reasonably ought to have become aware of, the error — provided this does not exceed 30 calendar days from the original transaction date.

  • Regulatory or Legal Basis: Where a refund is required under a regulatory obligation or legal order, the timeframe is governed by the applicable legal instrument and is not subject to the standard 14-day window.

Vestra reserves the right to decline Refund Requests submitted outside the applicable timeframe, unless exceptional circumstances are demonstrated and accepted at Vestra's sole discretion.

Section 5: Refund Processing Timeline

Where a Refund Request has been reviewed and approved by Vestra, the refund will be processed in accordance with the following timeline.

  • Standard Refund Processing Period: Approved refunds are processed within 30 business days from the date on which the Refund Request is formally approved by Vestra's compliance team.

  • Acknowledgement: Upon receipt of a Refund Request, Vestra will issue an acknowledgement to the user within 3 business days confirming that the request has been received and is under review.

  • Review and Determination: Vestra will complete its internal review and communicate a decision to the user within 10 business days of acknowledging receipt of the request. Complex cases involving regulatory assessment or disputed records may require additional time, in which case the user will be notified of the extended review period.

  • Processing upon Approval: Once approved, the refund will be initiated within the 30 business day window. The refund will be returned via the same payment method or channel through which the original deposit was made, where technically feasible.

  • Cryptocurrency Refunds: Where the original deposit was made in cryptocurrency, the refund will be processed in the equivalent value at the exchange rate applicable at the time of the refund initiation, not at the time of the original deposit. Vestra is not liable for any difference in value arising from exchange rate fluctuations between the two dates.

Important: The 30 business day processing period begins from the date of formal approval and not from the date of submission of the Refund Request. Users should account for the review period prior to the commencement of processing.

Section 6: Refund Method and Conditions

All approved refunds are subject to the following conditions regarding the method and manner of reimbursement.

  • Same Channel Refund: Refunds will be returned to the original payment source used to make the deposit. Vestra does not process refunds to a different account, wallet, or payment method than the one originally used, except in cases where the original channel is no longer active or available, and only at Vestra's discretion.

  • Currency: Refunds will be processed in the same currency as the original deposit where possible. Where currency conversion is required due to technical or regulatory reasons, the applicable exchange rate at the time of processing will be used, and any resulting conversion costs will be borne by the user.

  • Partial Refunds: In circumstances where only a portion of a fee was applied in error, only the erroneous portion will be refunded. Vestra does not issue refunds in excess of the amount determined to have been incorrectly charged.

  • No Interest on Refunds: Vestra does not pay interest on any refunded amount, regardless of the time elapsed between the original charge and the refund.

  • Third-Party Processing Delays: Vestra is not responsible for delays in the receipt of refunded funds caused by third-party payment processors, banking institutions, or cryptocurrency network conditions. Once Vestra initiates the refund, the time taken for funds to appear in the user's account is outside Vestra's control.

Section 7: Dispute and Appeals Process

Vestra provides a structured process through which users may formally dispute a transaction charge or appeal a refund decision. All disputes and appeals must be submitted through official Vestra support channels and will be handled in accordance with the procedure below.

Step 1: Initial Submission

The user must submit a formal Refund Request or Dispute through Vestra's official support channels within the timeframe specified in Section 4. The submission must include all of the following information to be considered valid.

  • Full name and registered account email address

  • Transaction reference number or date of the transaction in question

  • The specific nature of the dispute or grounds for the refund request

  • Supporting documentation, where available, including transaction receipts, screenshots, or any relevant correspondence

  • A clear statement of the outcome the user is seeking

Incomplete submissions may be returned to the user for further information, which may affect the review timeline.

Step 2: Acknowledgement

Upon receipt of a complete submission, Vestra will issue a written acknowledgement to the user within 3 business days confirming receipt and providing a reference number for the case. This acknowledgement does not constitute acceptance of the claim or any indication of likely outcome.

Step 3: Internal Review

Vestra's compliance and support teams will conduct a thorough review of the submitted information, the relevant transaction records, platform logs, and any applicable regulatory requirements. The standard review period is 10 business days from the date of acknowledgement.

Where the case is complex, involves third-party providers, or requires regulatory input, Vestra may extend the review period. The user will be notified in writing if an extension is required and will be provided with a revised expected response date.

Step 4: Decision Notification

Upon completion of the review, Vestra will notify the user of its decision in writing. The notification will set out whether the Refund Request has been approved or declined and will include a summary of the reasons for the determination.

  • Approved: The refund will be processed within 30 business days of the approval notification in accordance with Section 5 and Section 6 of this Policy.

  • Declined: The user will be informed of the grounds for the decision. A declined decision at this stage may be escalated through the formal appeal process described in Step 5.

Step 5: Formal Appeal

Where a user believes that the initial decision was made in error, was based on incomplete information, or did not adequately consider the circumstances of the case, the user may submit a formal written appeal within 7 calendar days of receiving the decision notification.

The appeal must be clearly marked as an appeal and must identify specifically the grounds on which the original decision is being challenged. Appeals that simply restate the original submission without identifying a specific error in the review process will not be entertained.

Appeals will be reviewed by a senior member of the Vestra compliance team who was not involved in the original determination. A final decision on the appeal will be issued within 10 business days of receipt of the appeal submission.

Step 6: Final Decision

The outcome of the formal appeal constitutes Vestra's final internal decision on the matter. Once a final decision has been issued, the case is closed and no further internal review will be conducted.

Where a user believes that Vestra has failed to comply with applicable regulatory requirements in handling the dispute, the user retains the right to escalate the matter to the relevant financial regulatory authority in their jurisdiction.

Section 8: Non-Refundable Fees — Absolute Exclusions

For the avoidance of doubt, the following fees and charges are strictly non-refundable under all circumstances and are not subject to the refund or dispute process set out in this Policy, except where required by a binding legal obligation.

  • KYC Verification Fees (all tiers, whether fresh or repeated, regardless of outcome)

  • Gateway Activation Fees (paid externally; outside Vestra's refund jurisdiction)

  • Withdrawal Processing Fees (once a withdrawal has been initiated and processed)

  • Reinstatement and Unban Fees (non-refundable regardless of the outcome of the reinstatement review)

  • Marketplace Transaction Fees (once a trade has been confirmed on the peer-to-peer marketplace)

  • Currency Conversion Charges (applied at the point of conversion and not recoverable)

  • Investment Principal or Returns (Vestra does not refund invested capital, matured or unmatured returns, or any amount arising from active or closed investments)

Users are advised to review all applicable fees carefully before initiating any transaction. The non-refundable nature of these fees is disclosed in the Vestra Fees and Charges Policy and is accepted by the user upon use of the platform.

Section 9: Fraudulent or Abusive Refund Requests

Vestra takes the integrity of its refund and dispute process seriously. Any user found to have submitted a Refund Request or Dispute based on false, misleading, or fabricated information may be subject to immediate account restriction or permanent suspension, in addition to any legal remedies available to Vestra under applicable law.

Vestra reserves the right to report suspected fraudulent activity to relevant financial intelligence units, regulatory bodies, or law enforcement agencies where required or deemed appropriate.

Section 10: Limitation of Liability

Vestra Holdings and its affiliates, officers, directors, employees, and authorized agents shall not be held liable for any losses, damages, or costs arising from a refund determination, a delay in processing an approved refund, or any fluctuation in currency value occurring between the date of the original transaction and the date of the refund.

To the maximum extent permitted by applicable law, Vestra's liability in connection with any refund matter shall be limited to the specific amount of the fee determined to have been charged in error. Vestra shall not be liable for any consequential, indirect, incidental, or punitive damages arising from any refund-related matter.

Vestra is not responsible for delays or costs arising from the processes or systems of third-party payment providers, banking institutions, or cryptocurrency networks involved in returning refunded funds to the user.

Section 11: Amendments

Vestra Holdings reserves the right to amend, update, or revise this Refunds Policy at any time. Such amendments may be made in response to changes in regulatory requirements, operational practices, platform developments, or other relevant factors.

Users will be notified of material changes to this Policy through official communication channels, including in-platform notifications, registered email communications, or updates published on the Vestra website. It is the responsibility of each user to review updated versions of this Policy upon notification.

Continued use of the Vestra platform following the publication of any amendments shall be deemed to constitute the user's acceptance of the revised terms. If a user does not agree with any amendment, they should discontinue use of the platform and contact the Vestra support team.

The effective date displayed at the top of this document will be updated each time a new version is published.

Section 12: Contact Information

For questions regarding this Refunds Policy, to submit a Refund Request, or to initiate a formal Dispute, users are encouraged to contact Vestra Holdings exclusively through official support channels.

All refund and dispute communications must be made through official channels to be considered valid. Requests or appeals submitted through unofficial means, including personal email addresses or social media platforms, will not be processed.

Contact details for all official support channels are available on the Vestra website and within the platform interface. Users are reminded that communicating through official channels protects the security and integrity of their account and ensures that their submission is properly logged and tracked.

This document constitutes the complete and authoritative Refunds Policy of Vestra Real Estate Investment Platform as of the effective date stated above. It supersedes all prior versions of this Policy and any informal representations made regarding refunds on the platform.

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