Cancellation & Refund Policy
ARCBDS CANCELLATION & REFUND POLICY
Document No.: 10 of 14
Version: 1.0
Effective Date: [●]
Last Updated: [●]
Policy Owner: Operations / Finance / Compliance
Approved By: [●]
IMPORTANT NOTICE
This Policy explains when an ARCBDS Founding Circle application may be:
cancelled;
rejected;
withdrawn;
refunded;
partially refunded;
reversed where legally and technically possible; or
treated as final.
Sending a blockchain payment does not automatically mean that a Founding Circle participation has been accepted.
Likewise, the fact that a blockchain transaction is irreversible does not automatically eliminate any refund, cancellation, consumer or statutory right that may apply under Applicable Law.
The rights available to a Participant depend on the stage of the transaction.
In general:
BEFORE PAYMENT
A participation request may normally be abandoned without charge.
AFTER PAYMENT BUT BEFORE FINAL ACCEPTANCE
A cancellation request may be considered, subject to transaction verification, KYC/AML, sanctions requirements, blockchain conditions and this Policy.
AFTER FINAL ACCEPTANCE AND ARCBDS ALLOCATION
Participation is generally treated as binding and is not ordinarily cancellable merely because the Participant changes their mind, subject always to mandatory legal rights.
AFTER ARCBDS HAS BEEN RELEASED OR TRANSFERRED
A normal cancellation or refund is generally not available. The Participant may instead use available market mechanisms or, where all conditions are satisfied, the Participant Protection Reserve framework.
Nothing in this Policy removes a legal right that cannot lawfully be waived.
1. PURPOSE
The purpose of this Policy is to establish fair and transparent rules concerning:
a. cancellation of participation applications;
b. withdrawal before acceptance;
c. rejected applications;
d. failed KYC/KYB;
e. rejected Contributions;
f. oversubscription;
g. duplicate payments;
h. overpayments;
i. underpayments;
j. incorrect transactions;
k. refunds;
l. partial refunds;
m. refund valuation;
n. blockchain fees;
o. stablecoin valuation;
p. return-to-source controls;
q. AML and sanctions restrictions;
r. token surrender following an exceptional post-allocation refund;
s. regulatory cancellation;
t. Company errors;
u. cooling-off rights where legally applicable;
v. complaints; and
w. refund records.
2. SCOPE
This Policy applies to:
a. prospective Founding Circle Participants;
b. Founding Circle Applicants;
c. accepted Founding Circle Participants;
d. individual Participants;
e. corporate and institutional Participants;
f. Contributions made through approved ARCBDS payment methods;
g. refunds arising from rejected applications;
h. refunds arising from transaction errors; and
i. other transactions expressly stated to be governed by this Policy.
3. RELATIONSHIP WITH OTHER DOCUMENTS
This Policy must be read together with:
ARCBDS Founding Circle Participation Agreement;
ARCBDS Founding Circle Terms & Conditions;
ARCBDS Risk Disclosure Statement;
ARCBDS Participant Protection Reserve Terms;
ARCBDS Website Terms of Use;
ARCBDS Privacy Policy;
ARCBDS Cookie Policy;
ARCBDS KYC, AML & Sanctions Policy;
ARCBDS Payment, Allocation & Blockchain Transaction Policy;
this Cancellation & Refund Policy;
ARCBDS Eligibility & Restricted Jurisdiction Policy;
ARCBDS Electronic Communications & E-Sign Consent; and
other applicable ARCBDS documentation.
If this Policy conflicts with an express provision of the Founding Circle Participation Agreement, the Participation Agreement shall prevail.
Mandatory Applicable Law shall prevail where required.
4. DEFINITIONS
For purposes of this Policy:
4.1 “Accepted Contribution”
means a Contribution formally accepted by ARCBDS following completion of applicable transaction, compliance and participation checks.
4.2 “Acceptance Event”
means the point at which ARCBDS formally accepts a Founding Circle participation and issues a Participation Confirmation or otherwise creates a binding participation under the applicable agreement.
4.3 “Applicant”
means a person who has commenced but has not yet completed final Founding Circle participation.
4.4 “Cancellation”
means termination or withdrawal of a participation request before or, in exceptional circumstances, after the Acceptance Event.
4.5 “Contribution”
means the amount transmitted in connection with a Founding Circle participation application.
4.6 “Mandatory Refund Right”
means a refund, withdrawal, cooling-off, cancellation or rescission right that Applicable Law does not permit ARCBDS to exclude.
4.7 “Participation Confirmation”
means the official record confirming acceptance of a Founding Circle participation.
4.8 “Refund”
means a return of all or part of a Contribution or another amount determined under this Policy.
4.9 “Refund Amount”
means the amount approved for return after applying any lawful adjustments expressly permitted under this Policy.
4.10 “Refund Request”
means a formal request submitted by an Applicant or Participant asking for a refund.
4.11 “Released ARCBDS”
means ARCBDS that has completed applicable release restrictions.
4.12 “Return-to-Source”
means the principle that refunded funds should ordinarily be returned to the same verified source from which they were originally received.
4.13 “Unreleased ARCBDS”
means ARCBDS that remains subject to a Cliff, release schedule or other applicable restriction.
5. FUNDAMENTAL PRINCIPLES
ARCBDS shall administer cancellation and refunds according to the following principles:
5.1 Fairness
Refund and cancellation rules should be fair, clear and consistently applied.
5.2 Transparency
Material refund conditions should be disclosed before participation.
5.3 Compliance
No refund shall be processed in violation of AML, sanctions, court, regulatory or other legal requirements.
5.4 Return-to-Source
Refunds should ordinarily return to the verified source of the original Contribution.
5.5 No Double Recovery
A Participant should not retain both:
a. a refunded Contribution; and
b. the ARCBDS allocation obtained from that Contribution,
unless expressly required by Applicable Law.
5.6 Mandatory Rights Preserved
Nothing in this Policy removes consumer or other legal rights that cannot legally be excluded.
5.7 Blockchain Reality
ARCBDS cannot technically reverse a blockchain transaction merely by deleting or changing an internal record.
Where a refund is approved, it will ordinarily be processed through a new transaction.
6. FOUR TRANSACTION STAGES
Cancellation rights differ according to the following stages:
STAGE A — BEFORE CONTRIBUTION
No blockchain payment has been transmitted.
STAGE B — CONTRIBUTION RECEIVED BUT PARTICIPATION NOT YET ACCEPTED
Funds have been received or detected, but the Acceptance Event has not occurred.
STAGE C — PARTICIPATION ACCEPTED AND ARCBDS ALLOCATED
The Acceptance Event has occurred and contractual ARCBDS entitlement has been established.
STAGE D — ARCBDS RELEASED, TRANSFERRED OR OTHERWISE USED
Some or all relevant ARCBDS has become Released ARCBDS and may have been transferred, sold or used.
The applicable rules are described below.
7. STAGE A — CANCELLATION BEFORE CONTRIBUTION
7.1 An Applicant may ordinarily abandon or cancel an uncompleted participation application before transmitting a Contribution.
7.2 No refund is required because no Contribution has been received.
7.3 ARCBDS may close an incomplete application after:
a. expiry of the payment request;
b. inactivity;
c. failure to complete KYC;
d. eligibility failure; or
e. programme closure.
7.4 Creating an Account or selecting Access, Growth or Legacy does not by itself create an obligation to contribute.
8. NO CANCELLATION FEE BEFORE PAYMENT
ARCBDS shall not charge a cancellation fee merely because an Applicant:
a. created an Account;
b. completed KYC;
c. selected a package; or
d. decided not to proceed
before sending a Contribution, unless an independent separately disclosed service legitimately generated a charge permitted by Applicable Law.
9. STAGE B — PAYMENT RECEIVED BEFORE ACCEPTANCE
9.1 Where ARCBDS receives a Contribution but the Acceptance Event has not yet occurred, the Contribution may remain:
a. pending blockchain confirmation;
b. pending reconciliation;
c. pending KYC;
d. pending source-of-funds review;
e. pending sanctions review;
f. pending transaction monitoring;
g. pending eligibility review;
h. pending capacity verification; or
i. otherwise pending.
9.2 A pending blockchain payment is not automatically an Accepted Contribution.
10. VOLUNTARY CANCELLATION BEFORE ACCEPTANCE
An Applicant may submit a Cancellation Request before the Acceptance Event.
ARCBDS shall review the request taking into account:
a. whether the participation has already been accepted;
b. whether allocation has already been finalised;
c. compliance status;
d. blockchain status;
e. legal requirements;
f. sanctions restrictions;
g. fraud concerns;
h. technical feasibility; and
i. applicable consumer rights.
11. CANCELLATION REQUEST TIMING
A pre-acceptance cancellation request should be submitted as soon as possible.
The request must be made through:
Official Cancellation Channel: [●]
or through the participant dashboard where available.
A message sent to:
a. an unofficial Telegram administrator;
b. community leader;
c. referral partner;
d. promoter;
e. social-media page; or
f. unauthorised person
does not constitute formal cancellation unless ARCBDS expressly accepts it.
12. CANCELLATION REQUEST INFORMATION
The Applicant may be required to provide:
a. full legal name;
b. Participant ID;
c. registered email;
d. transaction hash;
e. Contribution amount;
f. payment asset;
g. blockchain network;
h. funding wallet;
i. reason for cancellation;
j. proof of wallet ownership where required; and
k. other information reasonably required.
13. PRE-ACCEPTANCE REFUND
Where:
a. the Contribution has been successfully received;
b. participation has not been finally accepted;
c. no sanctions or legal freeze prevents return;
d. ownership and payment source are verified; and
e. the Cancellation Request is approved,
ARCBDS may return the eligible Contribution according to this Policy.
14. STAGE C — AFTER ACCEPTANCE
14.1 Once an Acceptance Event occurs, the Participant has entered a binding Founding Circle participation.
14.2 An Acceptance Event generally occurs when:
a. required KYC/KYB has been completed;
b. transaction verification has been completed;
c. the Contribution has been accepted;
d. applicable Allocation Price has been applied;
e. ARCBDS entitlement has been calculated; and
f. a Participation Confirmation has been issued.
14.3 After the Acceptance Event, participation is generally not cancellable merely because:
a. the Participant changes their mind;
b. ARCBDS market conditions change;
c. another Founding Circle category later appears more attractive;
d. ARCBDS market price decreases;
e. the Participant needs liquidity;
f. the Participant no longer wishes to wait through the applicable release period;
g. another investment opportunity becomes available;
h. the Participant disagrees with market sentiment; or
i. the Participant expected a faster return.
14.4 This section remains subject to Mandatory Refund Rights.
15. NO GENERAL POST-ACCEPTANCE COOLING-OFF PROMISE
Unless Applicable Law expressly provides otherwise, ARCBDS does not create a voluntary universal cooling-off period after the Acceptance Event merely by publishing this Policy.
If a mandatory cooling-off period applies to a particular Participant or transaction, ARCBDS shall comply with it.
16. MANDATORY COOLING-OFF RIGHTS
Where Applicable Law gives a Participant a legally non-waivable cooling-off or cancellation right:
a. the right shall be honoured;
b. the relevant deadline shall apply;
c. required disclosures shall be provided;
d. any permitted deductions shall comply with law; and
e. this Policy shall be interpreted consistently with that legal right.
17. STAGE D — AFTER RELEASE OR TRANSFER
17.1 Once ARCBDS has become Released ARCBDS, ordinary Founding Circle cancellation becomes substantially more difficult because the Participant may have obtained transferable digital assets.
17.2 A Participant generally cannot demand a refund while simultaneously retaining:
a. Released ARCBDS;
b. Unreleased ARCBDS;
c. Alignment Reward ARCBDS; or
d. another related economic benefit
arising from the same Contribution.
17.3 Market losses after release do not automatically create a refund entitlement.
18. CANCELLATION IS NOT A MARKET EXIT MECHANISM
The Cancellation & Refund Policy is not intended to operate as:
a. a guaranteed redemption programme;
b. a guaranteed token buyback;
c. a substitute for secondary-market trading;
d. a price-protection mechanism;
e. a guaranteed liquidity facility; or
f. a Protection Reserve Claim process.
19. CANCELLATION VS. PROTECTION RESERVE
A Refund Request and a Participant Protection Reserve Claim are different.
Refund
relates principally to cancellation, rejection, operational error or another qualifying refund circumstance.
Protection Reserve Claim
relates to qualifying inability to liquidate eligible Released ARCBDS under the Participant Protection Reserve Terms.
A Participant may not obtain duplicate recovery through both mechanisms for the same economic loss.
20. CANCELLATION VS. TOKEN SALE
Selling ARCBDS in a market is not a refund.
A market sale:
a. depends on available buyers;
b. occurs at the available market price;
c. may involve trading fees;
d. may create tax consequences; and
e. does not reverse the original Founding Circle participation.
21. COMPANY REJECTION BEFORE ACCEPTANCE
ARCBDS may reject an application before the Acceptance Event because of:
a. KYC failure;
b. KYB failure;
c. sanctions concerns;
d. AML concerns;
e. source-of-funds failure;
f. source-of-wealth concerns;
g. jurisdiction restrictions;
h. capacity exhaustion;
i. insufficient Contribution;
j. unsupported transaction;
k. regulatory restrictions;
l. suspected fraud;
m. inability to verify beneficial ownership;
n. programme closure; or
o. other lawful reason.
22. REFUND AFTER COMPANY REJECTION
Where an application is rejected and ARCBDS lawfully holds funds that may be returned:
a. no ARCBDS allocation shall be confirmed;
b. any provisional allocation shall be cancelled;
c. the eligible amount shall ordinarily be returned to the verified original funding source;
d. applicable lawful network or recovery costs may apply; and
e. a transaction record shall be maintained.
23. KYC FAILURE
If KYC/KYB cannot be completed:
23.1 ARCBDS may reject participation.
23.2 A refund may be processed where legally permitted.
23.3 Refund processing may require identity sufficient to establish:
a. the person entitled to the funds;
b. the original funding source; and
c. the absence of sanctions restrictions.
23.4 A Participant cannot refuse all identity verification and simultaneously require ARCBDS to send funds to an unrelated anonymous wallet.
24. SANCTIONS OR ASSET-FREEZE CASES
Where funds or a Participant are subject to a legally binding sanctions freeze:
a. ARCBDS may be prohibited from processing a refund;
b. funds may be required to remain frozen;
c. disclosure to the Participant may be legally restricted;
d. ARCBDS may be required to notify competent authorities; and
e. ordinary refund timelines shall not apply.
No refund shall be processed in violation of sanctions law.
25. SUSPICIOUS ACTIVITY REVIEW
Where a Contribution is subject to an AML/CFT/CPF review:
a. refund processing may be delayed;
b. additional documents may be requested;
c. Return-to-Source controls may be strengthened;
d. ARCBDS may be legally prohibited from explaining the full reason for the delay; and
e. regulatory reporting obligations may apply.
26. NO REFUND AS A MONEY-MOVEMENT SERVICE
ARCBDS shall not knowingly allow the refund process to be used to:
a. redirect funds;
b. obscure source of funds;
c. launder assets;
d. change beneficial ownership;
e. bypass exchange controls;
f. evade sanctions; or
g. transfer funds to an unrelated third party.
27. RETURN-TO-SOURCE PRINCIPLE
Approved refunds shall ordinarily be returned:
to the same verified wallet
from which the original digital-asset Contribution was received,
or:
to the same verified payment source
where another payment channel was used.
28. ALTERNATIVE REFUND DESTINATION
A refund to a different destination may be considered only where:
a. return to the original source is technically impossible;
b. the original service provider no longer supports the wallet;
c. the original wallet has been compromised;
d. a court or regulator requires another destination;
e. the Participant can prove ownership and legitimate reason; or
f. another exceptional circumstance exists.
Such refunds require enhanced verification and Compliance approval.
29. THIRD-PARTY FUNDING
Where the original Contribution came from a third party, ARCBDS may require verification of:
a. the original payer;
b. Participant;
c. relationship between them;
d. beneficial ownership;
e. source of funds; and
f. refund entitlement.
ARCBDS shall not automatically refund third-party funds to the Participant if doing so would create financial-crime risk.
30. DECEASED PARTICIPANTS
Where a Participant dies before a refund is processed, ARCBDS may require:
a. death certificate;
b. probate documentation;
c. executor or administrator authority;
d. beneficiary information;
e. identity verification; and
f. other legally required estate documentation.
Funds shall not be transferred solely on the instruction of an unverified relative.
31. CORPORATE PARTICIPANTS
Refund requests for corporate Participants must be submitted by an authorised representative.
ARCBDS may require:
a. board resolution;
b. authorised-signatory confirmation;
c. corporate bank/wallet verification;
d. KYB refresh; or
e. other authority evidence.
32. OVERSUBSCRIPTION
If Stage 1 reaches its maximum allocation capacity before a valid pending Contribution can be fully accepted, ARCBDS may:
a. reject the Contribution;
b. partially accept the Contribution; or
c. apply another previously disclosed allocation methodology.
33. REFUND OF OVERSUBSCRIPTION
Where only part of a Contribution can be accepted because of capacity:
a. the accepted part shall generate the applicable ARCBDS entitlement;
b. the unaccepted excess shall be returned where legally permitted; and
c. the Participation Confirmation shall clearly identify the accepted amount.
34. DUPLICATE CONTRIBUTIONS
Where an Applicant accidentally sends substantially identical duplicate Contributions, ARCBDS may:
a. accept both where permitted and intended;
b. contact the Applicant for instructions;
c. accept one and refund the duplicate; or
d. apply another fair resolution.
KYC and allocation-capacity requirements continue to apply.
35. OVERPAYMENT
Where more than the intended amount is received, ARCBDS may:
a. accept the full amount if permitted;
b. accept the requested amount and refund the excess;
c. request confirmation; or
d. partially accept according to remaining capacity.
The Participant shall be informed of the treatment.
36. UNDERPAYMENT
Where less than the required or selected amount is received, ARCBDS may:
a. request the shortfall;
b. adjust participation to the amount actually received where permitted;
c. reject and refund the Contribution; or
d. apply another disclosed method.
If the amount is below the minimum participation threshold, acceptance is not guaranteed.
37. UNSUPPORTED ASSET
If an Applicant sends an unsupported digital asset, the transfer does not automatically create a refund right if ARCBDS cannot technically access the asset.
Where recovery is possible, the matter shall be handled under the Payment, Allocation & Blockchain Transaction Policy.
38. WRONG NETWORK
A transfer through an unsupported network may be:
a. recoverable;
b. unrecoverable;
c. recoverable only through specialised technical intervention; or
d. inaccessible because ARCBDS does not control the necessary keys.
Recovery is not guaranteed.
39. INCORRECT ADDRESS
ARCBDS cannot refund assets that were never received or controlled by ARCBDS because the Participant sent them to an unrelated incorrect blockchain address.
The Participant bears responsibility for verifying the receiving address before transmission, subject to any legally attributable ARCBDS error.
40. ARCBDS PAYMENT-INSTRUCTION ERROR
Where ARCBDS itself provided materially incorrect official payment instructions and that error directly caused a Participant's loss, ARCBDS shall investigate and provide an appropriate remedy to the extent required by:
a. Applicable Law;
b. the Participation Agreement; and
c. the circumstances.
ARCBDS shall not rely on the general irreversibility of blockchain transactions to avoid responsibility for its own legally established error.
41. SYSTEM ALLOCATION ERROR
If ARCBDS incorrectly allocates ARCBDS because of a proven system error, the preferred remedy shall generally be correction of the allocation.
Where correction is impossible or legally inappropriate, another remedy including refund may be considered.
42. FAILURE TO PROVIDE ACCEPTED PARTICIPATION
Where:
a. an Accepted Contribution was received;
b. ARCBDS formally accepted participation;
c. ARCBDS subsequently cannot provide the agreed ARCBDS entitlement because of a cause legally attributable to ARCBDS; and
d. no lawful alternative performance is available,
the Participant may be entitled to an appropriate remedy under the Participation Agreement and Applicable Law.
Such remedy may include refund where legally appropriate.
43. COMPANY CANCELLATION BEFORE ACCEPTANCE
ARCBDS may cancel a pending application because of:
a. programme closure;
b. regulatory change;
c. technical failure;
d. legal restriction;
e. allocation exhaustion;
f. compliance requirements;
g. service discontinuation; or
h. another legitimate reason.
Where funds were received but not accepted, eligible funds shall ordinarily be returned subject to this Policy.
44. REGULATORY CHANGE AFTER ACCEPTANCE
Where a regulatory change makes continued participation unlawful after acceptance:
a. ARCBDS shall comply with the applicable legal requirement;
b. existing contractual rights shall be considered;
c. tokens may need to be restricted, transferred, surrendered, cancelled or otherwise treated according to law;
d. refund or other remedy may apply where legally required; and
e. Participants shall be notified where legally permitted.
45. VOLUNTARY COMPANY TERMINATION IS NOT AUTOMATIC FORFEITURE
ARCBDS shall not simply cancel an accepted Participant's lawful contractual rights without appropriate legal basis.
Termination rights and consequences must follow:
a. the Participation Agreement;
b. Applicable Law;
c. applicable refund provisions; and
d. the reason for termination.
46. PARTICIPANT BREACH
Where a Participant materially breaches the Participation Agreement, ARCBDS may exercise contractual remedies.
The treatment of:
a. Contribution;
b. ARCBDS entitlement;
c. Released ARCBDS;
d. Unreleased ARCBDS; and
e. any refund
shall depend on the nature of the breach and Applicable Law.
47. FRAUD
A Participant who obtained participation through fraud does not automatically acquire a right to use the refund process to retain the proceeds of that fraud.
ARCBDS may:
a. freeze activity;
b. cancel fraudulent records;
c. preserve assets;
d. report the matter;
e. seek recovery; and
f. comply with court or regulatory directions.
48. POST-ALLOCATION EXCEPTIONAL REFUND
A refund after allocation may be approved only where:
a. Applicable Law requires it;
b. ARCBDS materially breached the applicable agreement;
c. a proven Company error makes correction impossible;
d. the Participation Agreement expressly provides for it;
e. a regulator or court orders it; or
f. ARCBDS voluntarily approves an exceptional remedy permitted by law.
49. TOKEN SURRENDER
Where a post-allocation refund is approved, ARCBDS may require surrender or cancellation of:
a. base ARCBDS;
b. Alignment Reward ARCBDS;
c. Released ARCBDS;
d. Unreleased ARCBDS; and
e. other benefits directly arising from the refunded participation,
to the extent legally and technically possible.
50. NO REFUND WHILE RETAINING TOKENS
Except where required by Applicable Law, a Participant cannot receive a full rescission refund while retaining all ARCBDS allocated from the same Contribution.
This prevents double recovery.
51. TOKENS ALREADY SOLD
If ARCBDS allocated under a participation has already been sold or transferred to a bona fide third party, full contractual reversal may be impossible.
Any legally required remedy shall therefore be calculated according to:
a. Applicable Law;
b. transaction history;
c. value already realised;
d. remaining ARCBDS;
e. contractual rights; and
f. other relevant circumstances.
52. PARTIAL TOKEN RETURN
Where only part of the relevant allocation can be surrendered, ARCBDS may approve:
a. partial refund;
b. adjusted refund;
c. another lawful remedy; or
d. rejection of a voluntary exceptional refund request,
depending on the circumstances.
53. ALIGNMENT REWARD ON CANCELLATION
Where participation is lawfully reversed, associated Alignment Reward ARCBDS may also be:
a. cancelled;
b. surrendered;
c. deducted from remaining entitlement; or
d. otherwise reversed
because the Alignment Reward arose from the original participation.
54. ECOSYSTEM BENEFITS
Where a Participant has already received a non-token Founding Circle benefit, cancellation may require consideration of:
a. whether the benefit can be reversed;
b. whether the benefit had independently disclosed value;
c. Applicable Law; and
d. fairness.
No arbitrary penalty shall be imposed.
55. REFUND ASSET
Where possible, a pre-acceptance refund should ordinarily be made using the same asset originally received.
For example:
USDT received → USDT refunded
subject to:
a. network compatibility;
b. legal restrictions;
c. technical feasibility;
d. stablecoin status; and
e. other requirements.
56. SAME-ASSET PRINCIPLE
If a Participant contributed:
1,000 USDT
and the full Contribution is eligible for refund before acceptance, the starting refund amount will ordinarily be:
1,000 USDT
before applicable lawful adjustments.
The Participant does not automatically receive a guaranteed US$1,000 fiat payment if USDT subsequently trades below US$1.00.
57. STABLECOIN PRICE CHANGES
The Participant bears the ordinary market risk of the settlement asset unless:
a. Applicable Law requires otherwise;
b. ARCBDS agreed to a different valuation; or
c. ARCBDS caused an unlawful delay or other legally compensable event.
A USDT refund returns USDT; it does not guarantee US-dollar market parity.
58. STABLECOIN FAILURE
If the original settlement asset becomes:
a. frozen;
b. technically unavailable;
c. materially impaired;
d. prohibited;
e. unsupported; or
f. impossible to transfer,
ARCBDS may use another lawful settlement method after appropriate disclosure and valuation.
59. REFUND AMOUNT BEFORE ACCEPTANCE
Subject to Mandatory Refund Rights, the standard pre-acceptance calculation is:
Eligible Contribution Received
minus:
lawfully applicable non-recoverable charges
=
Refund Amount
No arbitrary cancellation penalty should be imposed.
60. NETWORK FEES
The blockchain network may charge fees to process a refund.
Treatment of refund network fees shall be disclosed.
Default policy:
ordinary blockchain network fees directly required to transmit the refund may be deducted from or borne in connection with the refund where lawful and properly disclosed.
ARCBDS shall not add an undisclosed profit margin to a network fee.
61. REFUND ADMINISTRATION FEE
ARCBDS shall not charge a general refund administration fee unless:
a. such fee is lawful;
b. disclosed before participation where required;
c. proportionate;
d. related to genuine cost; and
e. not inconsistent with mandatory consumer rights.
Current Refund Administration Fee: None, unless expressly disclosed otherwise.
62. TECHNICAL RECOVERY FEE
A technical asset-recovery fee may apply where an Applicant caused a wrong-network or unsupported-asset transfer requiring exceptional intervention.
Such a fee must be:
a. disclosed before recovery;
b. reasonable;
c. accepted by the Applicant; and
d. permitted by Applicable Law.
This is different from an ordinary refund fee.
63. NO MARKET LOSS DEDUCTION BEFORE ACCEPTANCE
ARCBDS shall not reduce a same-asset pre-acceptance refund merely because the US-dollar market value of the returned asset changed, unless a different valuation rule was validly disclosed and applies.
64. POST-ALLOCATION REFUND VALUATION
Where an exceptional refund after allocation is legally required, the appropriate calculation shall depend on:
a. whether ARCBDS can be fully surrendered;
b. whether some ARCBDS was transferred or sold;
c. whether the Participant realised value;
d. whether Alignment Rewards were received;
e. Applicable Law;
f. the nature of the breach or cancellation;
g. court or regulatory instructions; and
h. the goal of avoiding unjustified double recovery.
No single formula shall override mandatory legal remedies.
65. PARTIAL REFUND
A partial Refund may occur where:
a. only part of a Contribution was accepted;
b. there was an overpayment;
c. Stage 1 was partially oversubscribed;
d. only part of an exceptional post-allocation claim qualifies;
e. part of the payment is subject to legal restriction;
f. part has already been returned; or
g. Applicable Law provides for partial reimbursement.
66. REFUND CURRENCY CONVERSION
If a Refund must be made in an asset or currency different from the original Contribution, ARCBDS shall disclose the valuation method.
The method may use:
a. agreed market price;
b. recognised exchange rate;
c. stablecoin reference rate;
d. fiat conversion rate; or
e. another reasonable source.
The valuation time and source should be documented.
67. REFUND PROCESSING TARGET
Once:
a. a Refund is approved;
b. all required verification is complete;
c. Return-to-Source information is confirmed; and
d. no legal hold applies,
ARCBDS should ordinarily aim to initiate the Refund within:
10 Business Days
unless:
a. Applicable Law requires a shorter period;
b. blockchain or banking conditions prevent it;
c. additional compliance review is required;
d. a regulatory restriction applies; or
e. another exceptional circumstance exists.
68. PROCESSING TARGET IS NOT BLOCKCHAIN CONFIRMATION TIME
The processing period concerns ARCBDS initiating the Refund.
Actual receipt may depend on:
a. blockchain confirmation;
b. wallet provider;
c. exchange processing;
d. bank processing;
e. network congestion; or
f. third-party service availability.
69. REFUND STATUS
Refund status may be displayed as:
REQUESTED
Request received.
UNDER REVIEW
Eligibility being assessed.
INFORMATION REQUIRED
Additional information needed.
COMPLIANCE REVIEW
AML/sanctions review in progress.
APPROVED
Refund approved.
PROCESSING
Refund transaction being prepared.
SUBMITTED
Refund transaction submitted.
COMPLETED
Refund confirmed.
PARTIALLY APPROVED
Only part of the request qualifies.
REJECTED
Refund not approved.
FROZEN / LEGAL HOLD
Processing prohibited or restricted by Applicable Law.
70. REFUND RECEIPT
Upon completion, ARCBDS should provide a receipt showing:
a. Refund ID;
b. Participant ID;
c. original Transaction Hash;
d. original Contribution;
e. Refund Amount;
f. Refund asset;
g. blockchain network;
h. destination wallet;
i. applicable fees;
j. refund Transaction Hash;
k. initiation date; and
l. status.
71. REFUND RECORDKEEPING
ARCBDS shall retain appropriate records concerning:
a. request;
b. reason;
c. eligibility assessment;
d. KYC status;
e. AML review;
f. approval;
g. rejection;
h. amount;
i. fees;
j. wallet;
k. transaction hash;
l. token surrender where relevant;
m. communications; and
n. complaints.
72. FRAUDULENT REFUND REQUESTS
ARCBDS may reject and investigate requests involving:
a. forged wallet evidence;
b. false transaction hashes;
c. false identity;
d. duplicate refund requests;
e. false claims that tokens were not received;
f. stolen Account access;
g. altered screenshots;
h. fabricated KYC information; or
i. other fraud.
73. DUPLICATE REFUNDS
A Participant is not entitled to receive the same Refund twice.
Where a duplicate refund is accidentally processed, ARCBDS may seek lawful recovery of the duplicate amount.
74. CHARGEBACKS AND PAYMENT REVERSALS
Where future payment methods permit chargebacks or reversals, Participants must not improperly use a chargeback to obtain both:
a. repayment of the Contribution; and
b. continued ARCBDS entitlement.
Fraudulent chargebacks may result in:
a. allocation suspension;
b. Account restriction;
c. token recovery action;
d. legal recovery; and
e. compliance review.
75. DIGITAL-ASSET PAYMENTS GENERALLY HAVE NO CHARGEBACK
USDT blockchain transactions generally do not contain a card-style chargeback mechanism.
A Refund therefore requires a separate transaction from the appropriate ARCBDS-controlled wallet or payment infrastructure.
76. VOLUNTARY WITHDRAWAL FROM ACCOUNT
Closing an ARCBDS Account is not automatically equivalent to cancelling a Founding Circle participation.
A Participant may close or request closure of an Account while contractual or regulatory records remain.
Existing ARCBDS rights and obligations shall be treated according to applicable agreements.
77. ACCOUNT CLOSURE AFTER PARTICIPATION
Where an Account is closed after an accepted participation:
a. ARCBDS allocations do not automatically disappear;
b. legal and compliance records may be retained;
c. unreleased entitlements may remain subject to contractual terms;
d. alternative access or distribution arrangements may be required; and
e. Account closure does not create a refund right.
78. PRIVACY DELETION REQUESTS DO NOT CREATE REFUNDS
A request to delete Personal Data under privacy law does not automatically cancel an economic transaction.
ARCBDS may also be legally required to retain:
a. KYC;
b. transaction;
c. agreement;
d. AML; and
e. tax records
after a relationship ends.
79. TAX CONSEQUENCES
Cancellation, token surrender or refund may have tax consequences.
ARCBDS does not provide personal tax advice.
Participants are responsible for determining applicable:
a. income tax;
b. capital-gains tax;
c. corporate tax;
d. reporting; or
e. other tax treatment.
80. REFERRAL REWARDS
Where a participation is cancelled or refunded, any referral or other reward arising from that participation may be:
a. cancelled;
b. reversed;
c. deducted from pending rewards; or
d. recovered where already improperly paid,
subject to the ARCBDS Referral & Rewards Terms and Applicable Law.
81. NO REFERRAL PERSON MAY APPROVE A REFUND
Community leaders, referrers, promoters and independent marketing representatives may not bind ARCBDS by promising:
a. guaranteed refunds;
b. guaranteed cancellation;
c. special refund periods;
d. refund exemptions; or
e. accelerated refunds
unless formally authorised.
82. UNAUTHORISED PROMISES
Statements such as:
“You can refund anytime.”
“Your USDT is always refundable.”
“You can cancel after the lock period.”
“ARCBDS will always buy your tokens back.”
or equivalent claims
must not be made unless factually and legally correct under official documentation.
83. PROTECTION RESERVE MARKETING
The Protection Reserve must not be described as a refund policy.
A Protection Reserve settlement is subject to separate eligibility requirements and does not reverse the original Founding Circle purchase.
84. COMPLAINTS ABOUT REFUNDS
A Participant who disagrees with a Refund decision may submit a complaint to:
Complaints Email: [●]
Participant Support: [●]
Portal: [●]
The complaint should identify:
a. Refund ID;
b. Participant ID;
c. disputed decision;
d. reasons for disagreement; and
e. supporting evidence.
85. INTERNAL REVIEW
A disputed Refund decision may be reviewed by personnel not solely responsible for the original decision where reasonably practical.
The review may consider:
a. applicable agreement;
b. transaction records;
c. blockchain data;
d. KYC;
e. applicable law;
f. system records;
g. token status; and
h. previous communications.
86. REFUND APPEAL PERIOD
A Participant should normally submit an internal Refund appeal within:
30 calendar days
after receiving the relevant Refund decision.
A late appeal may still be considered where:
a. required by Applicable Law;
b. exceptional circumstances exist; or
c. ARCBDS reasonably agrees to review it.
87. REGULATORY COMPLAINT RIGHTS
Nothing in this Policy prevents a Participant from contacting a competent consumer-protection, regulatory or judicial authority where they possess a lawful right to do so.
88. NO RETALIATION
ARCBDS shall not retaliate against a Participant merely because the Participant makes a legitimate complaint or exercises a statutory right.
This does not prevent ARCBDS from acting against fraud or abuse.
89. CONSUMER RIGHTS
Where UAE consumer-protection legislation or another applicable consumer law applies, this Policy shall not exclude rights that the supplier is legally required to provide.
Any contractual provision inconsistent with a mandatory consumer right shall be interpreted or adjusted to comply with Applicable Law.
90. PROFESSIONAL AND INSTITUTIONAL PARTICIPANTS
Consumer-law rights may differ for:
a. corporations;
b. professional investors;
c. institutional Participants;
d. businesses; and
e. other non-consumer persons.
This Policy does not create consumer status where the law does not provide it.
91. JURISDICTIONAL DIFFERENCES
Cancellation and refund rights may vary depending on:
a. Participant residence;
b. Participant legal status;
c. location of transaction;
d. applicable regulatory framework;
e. service classification; and
f. mandatory local law.
ARCBDS may apply jurisdiction-specific supplementary terms.
92. CROSS-BORDER PARTICIPANTS
A cross-border Participant may have mandatory rights under their local law where that law legally applies to ARCBDS.
The Eligibility & Restricted Jurisdiction Policy may restrict access where ARCBDS cannot legally provide the relevant participation.
93. SERVICE UNAVAILABILITY
Temporary Website or Platform downtime does not automatically create a refund right.
Where material service failure prevents ARCBDS from fulfilling a contractual obligation, the appropriate remedy shall depend on:
a. duration;
b. cause;
c. effect on Participant rights;
d. available corrective action; and
e. Applicable Law.
94. BLOCKCHAIN OUTAGE
A blockchain outage may delay:
a. Contributions;
b. refunds;
c. token releases; or
d. withdrawals.
ARCBDS shall use reasonable efforts to resume processing.
A temporary blockchain delay does not automatically cancel a valid participation.
95. FORCE MAJEURE
Refund or cancellation processing may be delayed by circumstances beyond reasonable control, including:
a. war;
b. terrorism;
c. civil unrest;
d. natural disaster;
e. widespread cyberattack;
f. blockchain failure;
g. stablecoin disruption;
h. exchange failure;
i. banking disruption;
j. government action;
k. sanctions;
l. infrastructure failure; or
m. other comparable events.
Nothing in this section removes non-excludable legal rights.
96. COMPANY INSOLVENCY
If the relevant ARCBDS entity becomes insolvent, the treatment of:
a. pending Contributions;
b. Client Virtual Assets;
c. Accepted Contributions;
d. ARCBDS allocations; and
e. Refund claims
will depend on:
a. legal ownership;
b. segregation arrangements;
c. custody structure;
d. applicable insolvency law;
e. regulatory requirements; and
f. contractual rights.
This Policy does not guarantee that every creditor or Participant will recover all amounts in insolvency.
97. PENDING CONTRIBUTION OWNERSHIP
The final legal structure must determine the status of funds received before Acceptance.
Where such funds constitute Client Virtual Assets under Applicable Law, they shall be handled according to applicable client-asset rules.
Where they have become legally due to ARCBDS as contractual consideration, different treatment may apply.
98. REFUND FROM CLIENT-ASSET ARRANGEMENT
If a refund concerns assets held on behalf of a Participant rather than Company assets, ARCBDS shall comply with applicable segregation, reconciliation and transfer requirements.
99. DOCUMENTATION OF REFUND DECISIONS
Material Refund decisions should document:
a. legal basis;
b. contractual basis;
c. transaction evidence;
d. compliance assessment;
e. amount;
f. fees;
g. approval personnel;
h. settlement method; and
i. completion status.
100. APPROVAL AUTHORITY
ARCBDS should maintain an internal Refund approval matrix.
Higher-value or exceptional refunds should require enhanced approval.
No single salesperson or community leader should have unilateral authority to approve material Refunds.
101. REFUND APPROVAL MATRIX
An internal matrix should distinguish:
a. ordinary pre-acceptance refunds;
b. rejected applications;
c. overpayments;
d. duplicate payments;
e. technical recovery;
f. high-value refunds;
g. post-allocation exceptional refunds;
h. sanctions-restricted refunds; and
i. legally ordered refunds.
102. CONFLICTS OF INTEREST
A person with a material personal interest in a Refund should not be the sole decision-maker.
This includes cases involving:
a. related parties;
b. referral commissions;
c. personal relationships; or
d. other material conflicts.
103. INTERNAL AUDIT
Refund records may be reviewed through:
a. finance reconciliation;
b. compliance review;
c. internal audit;
d. external audit; or
e. regulatory review.
104. POLICY CHANGES
ARCBDS may amend this Policy because of:
a. changes in law;
b. regulatory requirements;
c. payment-method changes;
d. new blockchain networks;
e. operational improvements;
f. consumer-protection requirements;
g. risk-management changes; or
h. technical developments.
105. EXISTING PARTICIPANTS
A policy amendment shall not retroactively remove a Mandatory Refund Right or an accrued contractual right.
Material changes shall be handled according to the Participation Agreement and Applicable Law.
106. NOTICE OF MATERIAL CHANGES
Where legally required or appropriate, material changes may be notified through:
a. email;
b. Account notice;
c. Website notice;
d. dashboard notification; or
e. another approved electronic method.
107. VERSION CONTROL
ARCBDS shall maintain:
a. current Policy;
b. previous versions;
c. effective dates;
d. change records;
e. Participant acceptance records where applicable; and
f. relevant legal-review records.
108. GOVERNING LAW
This Policy shall be governed by the same governing law as the ARCBDS Founding Circle Participation Agreement.
Final Governing Law: [●]
Mandatory consumer and other legal protections shall apply where required.
109. DISPUTE RESOLUTION
Disputes arising under this Policy shall be handled according to the dispute-resolution mechanism in the Founding Circle Participation Agreement, without preventing access to mandatory consumer, regulatory or judicial remedies.
110. CONTACT
ARCBDS CANCELLATION & REFUND SUPPORT
Official Website:
www.arcbds.com
Legal Entity:
[●]
Participant Support:
[●]
Refund Requests:
[●]
Compliance:
[●]
Complaints:
[●]
Registered Address:
[●]
SCHEDULE 1
REFUND ELIGIBILITY MATRIX
Scenario
Normal Treatment
Application abandoned before payment
No payment / no refund required
Payment sent but not yet received
Wait for blockchain confirmation
Payment received, participation not accepted, Applicant cancels
Refund may be considered
KYC fails before acceptance
Refund where legally permitted
Sanctions freeze
Refund prohibited while freeze applies
AML review
Refund may be delayed
Application rejected for jurisdiction
Refund where legally permitted
Stage 1 capacity exhausted
Refund or partial acceptance
Duplicate Contribution
Refund or additional participation after verification
Overpayment
Refund excess or accept additional amount
Underpayment
Top-up, adjust, or refund
Wrong network
Technical recovery rules
Unsupported asset
Technical recovery rules
Wrong external address
Usually not recoverable by ARCBDS
ARCBDS official payment instruction error
Investigate and provide lawful remedy
Participation accepted, Participant changes mind
Normally no refund
Market price falls after acceptance
No ordinary refund
Token is illiquid
Not an ordinary refund; Protection Reserve may apply if eligible
ARCBDS released and sold
No ordinary cancellation
Mandatory statutory cancellation right
Apply legal right
Proven material ARCBDS breach
Appropriate legal/contractual remedy
Regulator/court orders refund
Refund according to order
SCHEDULE 2
REFUND CALCULATION — PRE-ACCEPTANCE
Standard Same-Asset Refund
Contribution actually received
minus
lawfully applicable disclosed network/recovery costs
=
Refund Amount
Example:
Contribution Received:
1,000 USDT
Refund Network Cost:
5 USDT
Indicative Refund:
995 USDT
This example is illustrative only. Actual blockchain fees may differ.
Where ARCBDS elects to bear the network fee:
Refund = 1,000 USDT
SCHEDULE 3
REFUND CALCULATION — OVERPAYMENT
Participation requested:
1,000 USDT
Amount received:
1,200 USDT
Amount accepted:
1,000 USDT
Eligible excess:
200 USDT
minus any lawfully applicable disclosed refund network fee.
Alternatively, where the Participant agrees and programme capacity permits, the full 1,200 USDT may be accepted and allocated according to the selected Participation Category.
SCHEDULE 4
PARTIAL ACCEPTANCE
Contribution:
10,000 USDT
Remaining programme capacity permits acceptance of:
6,000 USDT
Accepted Contribution:
6,000 USDT
Unaccepted amount:
4,000 USDT
ARCBDS allocation is calculated only on:
6,000 USDT
The remaining 4,000 USDT shall be refunded subject to applicable transaction and compliance requirements.
SCHEDULE 5
REFUND REQUEST FORM
PARTICIPANT
Full Legal Name: [●]
Participant ID: [●]
Registered Email: [●]
KYC Reference: [●]
ORIGINAL TRANSACTION
Transaction Hash: [●]
Contribution Amount: [●]
Asset: [●]
Network: [●]
Funding Wallet: [●]
Date: [●]
PARTICIPATION STATUS
☐ Application Pending
☐ KYC Pending
☐ Compliance Review
☐ Participation Accepted
☐ ARCBDS Allocated
☐ ARCBDS Partially Released
☐ ARCBDS Fully Released
REASON
☐ Cancellation Before Acceptance
☐ KYC Rejection
☐ Jurisdiction Rejection
☐ Duplicate Payment
☐ Overpayment
☐ Programme Capacity
☐ Technical Error
☐ Company Error
☐ Mandatory Legal Right
☐ Other: [●]
REQUESTED REFUND
[●]
REFUND WALLET
[●]
DECLARATION
☐ I confirm that the information supplied is accurate.
☐ I understand that Refund approval is subject to this Policy and Applicable Law.
☐ I understand that ARCBDS may require Return-to-Source.
☐ I understand that post-allocation Refund may require surrender of ARCBDS.
☐ I authorise applicable KYC, AML, sanctions and transaction verification.
Electronic Signature: [●]
Date: [●]
SCHEDULE 6
REFUND DECISION RECORD
Refund ID: [●]
Participant ID: [●]
Original Contribution: [●]
Original Transaction Hash: [●]
Status at Request
[●]
Eligibility
☐ Eligible
☐ Partially Eligible
☐ Not Eligible
☐ Legal Hold
Reason
[●]
Eligible Refund
[●]
Fees / Adjustments
[●]
Final Refund Amount
[●]
Refund Asset
[●]
Destination
[●]
Return-to-Source Verified
Yes / No
Compliance Approval
[●]
Finance Approval
[●]
Transaction Hash
[●]
Completion Date
[●]
SCHEDULE 7
POST-ALLOCATION CANCELLATION CHECKLIST
Where a post-allocation cancellation is legally or exceptionally approved:
☐ Legal basis confirmed
☐ Participation Confirmation reviewed
☐ Base allocation identified
☐ Alignment Reward identified
☐ Released ARCBDS identified
☐ Unreleased ARCBDS identified
☐ Transfers reviewed
☐ Sales reviewed
☐ ARCBDS surrender possible
☐ ARCBDS surrendered
☐ Referral rewards reviewed
☐ Ecosystem benefits reviewed
☐ AML review completed
☐ Tax implications disclosed as Participant responsibility
☐ Refund calculation approved
☐ Dual approval completed
☐ Participant informed
SCHEDULE 8
REFUND APPROVAL MATRIX
Refund Type
Operational Approval
Compliance
Senior Approval
Standard pre-acceptance cancellation
Operations
Required screening
According to threshold
KYC rejection
Operations
Required
According to threshold
Duplicate payment
Operations / Finance
Required
According to threshold
Overpayment
Finance
Required
According to threshold
Oversubscription
Finance / Operations
Required
Programme approval
Technical recovery
Technology / Finance
Required
According to threshold
High-value refund
Finance
Required
Yes
Post-allocation exceptional refund
Legal / Finance
Required
Yes
Sanctions-related
No action without Compliance
Mandatory
MLRO / legal
Regulator/court ordered
Legal / Finance
Mandatory
Senior Management
Value Thresholds: [●]
SCHEDULE 9
WEBSITE REFUND NOTICE
Before Contribution, the Website should display substantially the following:
CANCELLATION & REFUND NOTICE
You may abandon your Founding Circle application before sending a Contribution.
If a Contribution has been sent but your participation has not yet been accepted, cancellation and refund may be available subject to transaction verification, KYC/AML, sanctions requirements and this Policy.
Once your participation has been formally accepted and your ARCBDS entitlement has been confirmed, participation is generally binding and is not ordinarily refundable merely because you change your mind or market conditions change, except where Applicable Law or your agreement provides otherwise.
The Participant Protection Reserve is not a general refund programme.
Please review the full ARCBDS Cancellation & Refund Policy before participating.
SCHEDULE 10
PAYMENT-SCREEN ACKNOWLEDGEMENT
Before sending a Contribution:
☐ I understand that blockchain transactions may be irreversible.
☐ I understand that sending USDT does not itself mean my participation has been accepted.
☐ I understand that I may request cancellation before final acceptance subject to the Cancellation & Refund Policy.
☐ I understand that once my participation is accepted and my ARCBDS entitlement is confirmed, the participation is generally binding except where Applicable Law provides otherwise.
☐ I understand that market-price changes do not create an automatic refund right.
☐ I understand that illiquidity does not create an ordinary refund right and is addressed separately under the Protection Reserve Terms where applicable.
☐ I understand that approved refunds will ordinarily be returned to the verified original funding source.
☐ I understand that sanctions or AML requirements may delay or prevent refund processing.
☐ I have read and agree to the ARCBDS Cancellation & Refund Policy.
SCHEDULE 11
REFUND PROCESS FLOW
1. Refund Request
Participant submits formal request.
↓
2. Transaction Identification
Original Contribution verified.
↓
3. Participation Status
Determine whether Acceptance Event occurred.
↓
4. Token Status
Determine whether ARCBDS was allocated/released/transferred.
↓
5. Legal Eligibility
Determine contractual/statutory cancellation rights.
↓
6. KYC / AML / Sanctions
Complete applicable verification.
↓
7. Return-to-Source Verification
Confirm lawful destination.
↓
8. Refund Calculation
Determine eligible amount and disclosed costs.
↓
9. Approval
Operational / Finance / Compliance / Legal as applicable.
↓
10. Settlement
Execute refund.
↓
11. Confirmation
Issue Refund Receipt.
↓
12. Reconciliation
Reconcile blockchain and finance records.
SCHEDULE 12
REASONS A REFUND MAY BE DELAYED
A Refund may take longer where:
Participant identity requires additional verification;
original funding wallet cannot be verified;
sanctions screening identifies a possible match;
suspicious activity review is ongoing;
source of funds requires verification;
third-party funding is involved;
a blockchain network is unavailable;
the original stablecoin is unavailable;
transaction records are incomplete;
a wallet has been compromised;
a court or regulator has issued a restriction;
token surrender is required;
an estate or legal representative is involved;
the Refund is unusually complex; or
another legal or technical issue prevents safe processing.
SCHEDULE 13
REFUND FRAUD RED FLAGS
ARCBDS should investigate circumstances including:
Participant requests refund to unrelated wallet;
refund destination changes repeatedly;
refund is requested immediately after third-party funding;
KYC identity differs from funding source;
multiple Participants request refunds to same wallet;
wallet is linked to sanctions or illicit activity;
transaction screenshots are altered;
Participant denies receiving ARCBDS despite verified delivery;
Participant sold ARCBDS and then requests full refund;
duplicate refund request;
Account credentials appear compromised;
refund request follows suspicious referral activity;
source of funds becomes inconsistent;
Participant refuses Return-to-Source; or
another money-laundering indicator exists.
SCHEDULE 14
REFUND RECORD RETENTION
ARCBDS should retain, for the applicable legal period:
☐ Refund Request
☐ KYC/KYB records
☐ Original transaction
☐ Funding wallet
☐ Return destination
☐ Wallet verification
☐ AML screening
☐ Sanctions screening
☐ Refund decision
☐ Calculation
☐ Approval record
☐ Fees
☐ Token surrender
☐ Refund Transaction Hash
☐ Participant communications
☐ Complaint or appeal
☐ Final reconciliation
Where an eight-year regulatory recordkeeping requirement applies, relevant records shall be retained for at least eight years or longer where legally required.
SCHEDULE 15
KEY REFUND PRINCIPLES
Before Payment
Cancel freely.
After Payment, Before Acceptance
Refund may be available subject to verification.
After Acceptance
Participation is generally binding.
After Token Release
Market exit is not the same as refund.
If ARCBDS Rejects You
Eligible funds should ordinarily be returned, unless law prevents it.
If Sanctions Apply
ARCBDS may be legally prohibited from returning funds.
If You Change Your Mind
That does not automatically create a post-acceptance refund right.
If Price Falls
That is market risk, not ordinarily a refund event.
If Tokens Cannot Be Sold
Review the Protection Reserve Terms, not this Refund Policy.
If ARCBDS Makes a Material Error
ARCBDS must investigate and provide an appropriate remedy where required.
If the Law Gives You a Mandatory Right
That legal right prevails.
FINAL REFUND NOTICE
ARCBDS seeks to administer cancellations and refunds fairly while recognising the technical and legal characteristics of blockchain transactions.
A BLOCKCHAIN PAYMENT MAY BE IRREVERSIBLE ON-CHAIN.
That does not mean ARCBDS may ignore mandatory legal rights.
At the same time:
A FOUNDING CIRCLE PARTICIPATION IS NOT INTENDED TO FUNCTION AS A RETURN-ANYTIME PRODUCT.
Once a participation has been accepted and ARCBDS entitlement has been established, a Participant should not assume that the Contribution can be refunded simply because market conditions change.
Participants should therefore understand the Founding Circle terms, release schedule and risks before submitting a Contribution.
END OF ARCBDS CANCELLATION & REFUND POLICY