Complaint Handling Procedure

Last Updated: February 2026 — Version 1.0

1. Our Commitment

FIN TWIN TECHNOLOGIES INC., operating as FINTWIN PAY, is committed to resolving client complaints fairly, promptly, and transparently. This Complaint Handling Procedure outlines how you can submit a complaint and how we will handle it in accordance with the Retail Payment Activities Act (RPAA), the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), and other applicable Canadian regulatory requirements for Money Services Businesses.

2. What Is a Complaint?

A complaint is an expression of dissatisfaction relating to:

Our products or services
The processing, execution, or settlement of a transaction
Fees, charges, or exchange rates applied
The conduct of our employees or representatives
The handling of your personal information
Our policies, procedures, or any other aspect of your experience with us

3. How to Submit a Complaint

All complaints must be submitted in writing through one of the following channels:

Web Portal: Through the support section of your FINTWIN Account at my.fintwinpay.com
Live Chat: Available during business hours through the FINTWIN Pay Web Portal
Mail: FIN TWIN TECHNOLOGIES INC., Attention: Complaints, 1025 King Street East, Unit 107-1587, Cambridge, Ontario, N3H 3P5, Canada

4. Information to Include

To help us investigate and resolve your complaint efficiently, please include:

Your full name and FINTWIN Account identifier
A clear and detailed description of the issue or concern
The date(s) and amount(s) of any relevant transaction(s)
Any supporting documentation or evidence
The resolution or remedy you are seeking

5. Complaint Handling Process

Step 1: Acknowledgment

We will acknowledge receipt of your complaint within two (2) business days. You will receive:

A unique complaint reference number for tracking purposes
Confirmation that a designated complaint handler has been assigned
An outline of the expected timeline for resolution

Step 2: Investigation

We will conduct a thorough and impartial investigation of your complaint, which may include:

Reviewing all relevant records, transactions, and documentation
Consulting with relevant staff members
Contacting you if additional information is needed
Considering applicable laws, regulations, and our policies

Step 3: Resolution

We will endeavour to resolve your complaint within fifteen (15) business days of receipt. If we cannot meet this timeline due to the complexity of the matter or the need for additional information, we will:

Notify you in writing of the delay and the reason
Provide a new expected resolution date
Keep you updated on progress

In no event shall the resolution period exceed thirty-five (35) business days from the date of receipt, unless an extension is agreed upon by both parties in writing.

Step 4: Final Response

Upon completion of the investigation, we will provide you with a written final response that includes:

A summary of the complaint
The findings of the investigation
Our decision and the reasons for it
Any remedy or corrective action to be taken
Information about escalation options if you are not satisfied

6. External Escalation

If you are not satisfied with our final response, or if we fail to respond within the timelines set out above, you may escalate your complaint to the following external bodies:

Bank of Canada

For complaints relating to FINTWIN Pay's obligations under the Retail Payment Activities Act (RPAA).

Website: www.bankofcanada.ca

FINTRAC

For concerns relating to compliance with money laundering or terrorist financing regulations under the PCMLTFA.

Website: www.fintrac-canafe.gc.ca

Office of the Privacy Commissioner of Canada

For complaints relating to the handling of your personal information under PIPEDA.

Website: www.priv.gc.ca

Ontario Ministry of Public and Business Service Delivery

For complaints relating to consumer protection or obligations under the Ontario Business Corporations Act.

Website: ontario.ca

7. Mediation

Before commencing any formal legal proceedings, both parties agree to attempt to resolve any dispute through mediation administered by a mutually agreed-upon mediator in the Province of Ontario. The costs of mediation shall be shared equally unless otherwise agreed. If the dispute is not resolved through mediation within sixty (60) days of the appointment of the mediator, either party may proceed with formal legal proceedings.

8. Record Keeping

We maintain detailed records of all complaints received, including the nature of the complaint, the investigation process, the resolution, and any remedial actions taken. Complaint records are retained for a minimum of seven (7) years from the date the complaint is resolved, in accordance with applicable law and our record-retention policies.

9. No Retaliation

We will not retaliate against any client who submits a complaint in good faith. Filing a complaint will not adversely affect your FINTWIN Account or access to our Services, except where the complaint reveals information that requires us to take action under our Terms of Use or applicable law.

10. Accessibility

We are committed to ensuring our complaint process is accessible to all clients. If you require accommodations to submit or follow up on a complaint, please let us know through any of the channels listed in Section 3 and we will work with you to find a suitable solution.

11. Contact

For questions about this Complaint Handling Procedure, please contact us through the support section of your FINTWIN Account or via live chat on our Web Portal.

FIN TWIN TECHNOLOGIES INC.
1025 King Street East, Unit 107-1587
Cambridge, Ontario, N3H 3P5, Canada

Version	Effective Date	Approved By
1.0	February 2026	Pavel Martynov, Director