DAlphaPay CUSTOMER PROTECTION POLICY

1. OUR CUSTOMER PROTECTION COMMITMENT

DAlphaPay aims to provide payment technology that is safe, transparent and understandable. We will design customer-protection controls around security, accurate information, fair treatment, complaint handling, transaction integrity, privacy and responsible use of third-party payment infrastructure.

Where a regulated partner is responsible for holding, settling or otherwise controlling customer funds, DAlphaPay will coordinate with that partner and apply the protection required by applicable law and the relevant service agreement.

2. WHO THIS POLICY APPLIES TO

This Policy applies to DAlphaPay customers using services covered by the User Agreement, including individual users and, where expressly stated, merchants and business users. Additional product-specific protections may apply to merchants, agents, developers, remittance users or card users when those services are launched.

3. CUSTOMER RIGHTS AND INFORMATION

Receive material information about applicable fees, limits and important service conditions before or during use, as required.

Receive transaction information and records through the channels provided by DAlphaPay.

Know how to contact DAlphaPay about an error, suspected fraud or complaint.

Have complaints investigated through a documented process.

Receive the protection required by applicable law where DAlphaPay or an applicable regulated partner is responsible for a loss.

Have personal information handled according to the DAlphaPay Privacy Policy and applicable law.

Receive notice of material changes where required.

4. SECURITY OF CUSTOMER ACCOUNTS

DAlphaPay will maintain reasonable controls to protect customer accounts and transaction systems. Controls may include multi-factor authentication, OTP verification, transaction monitoring, device and session controls, rate limits, fraud detection, access controls, security logging, vulnerability management and incident response.

Customers must protect passwords, PINs, OTPs, recovery codes, devices, SIM cards and email accounts. DAlphaPay will never ask a customer to disclose an OTP or password through an unsolicited communication.

5. REPORTING A SUSPECTED UNAUTHORISED TRANSACTION

Customers should report suspected unauthorised transactions immediately through the official DAlphaPay support channel. Prompt reporting helps DAlphaPay restrict access, investigate the event and coordinate with relevant payment partners.

A report should include, where available, the transaction reference, amount, date/time, affected account, device or phone number and a description of what occurred.

DAlphaPay may temporarily block transactions, reset credentials, restrict an account or take other protective measures while investigating.

6. INVESTIGATION OF UNAUTHORISED TRANSACTIONS

DAlphaPay will investigate reported unauthorised transactions using available account, authentication, device, transaction and partner records. Customers may be asked to cooperate and provide reasonable information.

Where applicable BSL customer-protection requirements apply, the investigation and reimbursement process will be handled consistently with those requirements. BSL's Financial Consumer Protection Guidelines state that covered financial service providers are liable for losses due to fraud or misuse involving customer assets held, administered or controlled by the institution, including misuse of customer data and data-security breaches, except in cases of customer fraud or gross negligence, and require reimbursement of the full value of an unauthorised transaction with communication during the investigation.

7. WHEN CUSTOMER PROTECTION MAY NOT APPLY

Subject to mandatory law, protection may be limited where evidence shows that the customer intentionally committed fraud, deliberately shared credentials to facilitate the transaction, acted dishonestly, or was grossly negligent where the applicable legal framework permits that distinction.

DAlphaPay will not treat ordinary mistakes, temporary network failures or genuine uncertainty as proof of customer fault without investigation.

8. TRANSACTION ERRORS

Duplicate transaction or duplicate debit.

Incorrect amount processed by DAlphaPay or a relevant partner.

Transaction incorrectly recorded.

Transaction shown as completed when it did not complete.

Payment failure where the customer's account was nevertheless debited.

Incorrect fee or currency information caused by a processing error.

Other operational or reconciliation errors attributable to DAlphaPay or a relevant service provider.

Customers should report errors promptly. DAlphaPay may request supporting records and will investigate and correct confirmed errors in accordance with applicable law, partner rules and service terms.

9. WRONG RECIPIENT OR CUSTOMER-ENTERED ERROR

If a customer sends money to the wrong recipient or enters the wrong amount, DAlphaPay will distinguish the mistake from an unauthorised transaction. DAlphaPay may attempt to assist with recovery where technically and legally possible, but recovery is not guaranteed.

Customers should carefully confirm recipient information, amount and currency before authorising a transaction.

10. FAILED, PENDING AND REVERSED TRANSACTIONS

A transaction may be pending while DAlphaPay or a partner completes security, routing, settlement or reconciliation checks. A failed transaction may later be reversed or corrected. DAlphaPay will provide transaction status information where available and will coordinate with relevant partners to resolve outstanding transaction states.

11. COMPLAINTS PROCESS

DAlphaPay will maintain a documented complaints process. Customers should first submit complaints through the official DAlphaPay customer-support channel.

A complaint should contain the customer's details, transaction/account reference where applicable, date of the issue, description of the complaint, evidence and the requested resolution.

For payment services governed by the National Payment Systems Act, 2022, the Act requires payment service providers to adopt policies for prompt responses to inquiries, complaints, refund demands and

disputes, provide a customer complaint channel, establish rapid dispute-resolution mechanisms and communicate the complaints-redress process. It also states that a payment service provider should respond to a complaint no later than 7 business days after receipt and that customers should be informed of their right to refer an unresolved complaint to the Central Bank or another authorised body. DAlphaPay's final operational procedure should be aligned with the exact license and regulatory status applicable to the service at launch.

12. COMPLAINT ESCALATION

Stage 1: Customer submits the complaint through DAlphaPay support.

Stage 2: Customer support acknowledges, categorises and records the complaint.

Stage 3: Relevant operations, fraud, compliance or technical team investigates.

Stage 4: DAlphaPay communicates the outcome and any corrective action.

Stage 5: Customer may request escalation through the published escalation route.

Stage 6: Where applicable, the customer may use the external regulatory or statutory escalation route available under Sierra Leone law.

13. REFUNDS, REVERSALS AND CHARGEBACKS

Refunds and reversals depend on the transaction type and the institutions involved. DAlphaPay will not promise a universal refund or chargeback right where no such mechanism exists for the transaction rail.

Where a card, bank, mobile-money or other payment network provides a formal dispute or chargeback process, the applicable network and partner rules will govern. DAlphaPay will communicate the relevant process where it is responsible for administering it.

14. FEES AND TRANSPARENCY

DAlphaPay will publish or display applicable fees and material transaction limits through the relevant customer channel. Customers should be informed of applicable charges before a transaction is completed where practicable and legally required.

A fee schedule should be maintained separately from this Policy so that product-specific pricing can change without rewriting the entire customer-protection document, subject to notice requirements.

15. ACCOUNT LIMITATIONS AND SECURITY HOLDS

DAlphaPay may temporarily restrict an account or transaction where reasonably necessary to protect the customer, DAlphaPay, a partner or the payment system. Reasons may include suspected fraud, account takeover, sanctions screening, AML/CFT review, legal requirements, court orders, technical reconciliation

or a significant security incident.

Where legally permitted, DAlphaPay will communicate what the customer needs to do to resolve the restriction. We may withhold sensitive fraud-detection or law-enforcement information where disclosure would compromise an investigation or legal obligation.

16. DATA AND PRIVACY PROTECTION

Customer protection includes protection of personal data. DAlphaPay will handle personal information under its Privacy Policy and applicable law. Security incidents involving customer information will be managed through DAlphaPay's incident-response process, including regulatory, partner and customer notification where required or appropriate.

17. THIRD-PARTY AND PARTNER RESPONSIBILITY

DAlphaPay may depend on banks, mobile money operators, payment service providers, switches, card networks, processors, identity providers, cloud providers and other vendors. DAlphaPay will establish appropriate contracts and escalation arrangements.

Where a third party is responsible for a transaction stage, DAlphaPay will coordinate with that provider rather than falsely representing that DAlphaPay controls the third party's system. Where DAlphaPay remains legally responsible for an outsourced function, it will maintain appropriate oversight.

18. FRAUD PREVENTION

DAlphaPay may monitor transactions and account activity for unusual patterns.

We may request additional verification before allowing a transaction.

We may temporarily delay or reject a transaction where necessary to manage risk.

We may cooperate with banks, MNOs, regulators, law enforcement and other authorised parties in fraud investigations.

Customers should report scams, phishing, impersonation and suspicious communications immediately.

19. CUSTOMER EDUCATION

DAlphaPay will provide practical security guidance, including warnings about phishing, OTP theft, SIM-swap risks, fake support agents, social engineering and fraudulent payment requests. DAlphaPay may also conduct financial-literacy and digital-safety initiatives as the platform grows.

20. RECORDS AND AUDITABILITY

DAlphaPay will maintain appropriate transaction, complaint, fraud, security and service-disruption records. For regulated services, the retention programme will follow applicable legal and regulatory requirements. BSL's Financial Consumer Protection Guidelines state that covered financial service providers maintain transaction, fraud and service-disruption records for at least 10 years.

21. SERVICE DISRUPTIONS

DAlphaPay will maintain procedures for planned and unplanned service disruptions. Where a disruption materially affects customers, DAlphaPay should communicate the incident and provide updates where reasonably practicable.

DAlphaPay will investigate material service failures and maintain records of service disruptions for operational, compliance and risk-management purposes.

22. VULNERABLE CUSTOMERS

DAlphaPay should design customer support and communications so that customers who may be particularly vulnerable to financial harm can receive appropriate assistance. This may include clear explanations, reasonable support during complaints and escalation of suspected exploitation or fraud where appropriate and lawful.

23. NO FALSE PROMISES

This Policy does not create an unconditional promise that every disputed transaction will be refunded. Protection depends on the transaction type, applicable law, evidence, customer conduct, partner rules and DAlphaPay's responsibility for the event.

DAlphaPay will not market a protection programme that it does not have the operational or financial capacity to administer.

24. POLICY CHANGES

DAlphaPay may update this Policy to reflect changes in law, regulation, products, partners, risk controls or operating procedures. Material changes will be communicated as required. The effective date will appear at the beginning of the updated Policy.

25. CONTACT AND EMERGENCY REPORTING

Official customer-support channel: support@dalphacompany.com

Fraud/security reporting: management@dalphacompany.com

Complaints: info@dalphacompany.com