REFUND POLICY

Last Updated: August 18, 2026

1. INTRODUCTION

This Refund Policy (the "Policy") governs all refund-related terms for purchases of the Finestro Service available at finestro.io. The Finestro Service is offered by VELRIO LIMITED, a company incorporated in the Republic of Cyprus, with its registered address at Prodromou, 75, ONEWORLD PARKVIEW HOUSE, Floor 4, Nicosia, Republic of Cyprus 2063.

Findmy LLC, a Delaware limited liability company located at 501 E Las Olas Blvd, Suite 300, Fort Lauderdale, FL 33301, USA, acts as the authorized web distributor and merchant of record for certain payment transactions processed in connection with the Service. Payment processing may be facilitated through Stripe, Braintree, SolidGate, PayPal, or other payment providers.

This Policy forms part of the Finestro Terms of Service and should be read together with the Subscription Terms. In the event of any conflict between this Policy and the Terms of Service or Subscription Terms, the provisions of this Policy shall govern with respect to refund matters. Capitalized terms not defined herein have the meanings assigned to them in the Terms of Service or the Definitions section below.

2. DEFINITIONS

The following capitalized terms, when used in this Policy, have the meanings set forth below. Terms not defined here have the meanings assigned to them in the Terms of Service or the Subscription Terms.

"Consumer" means a natural person acting for purposes outside that person's trade, business, craft, or profession.

"EEA" means the European Economic Area, comprising the member states of the European Union plus Iceland, Liechtenstein, and Norway.

"Policy" means this Finestro Refund Policy, as amended from time to time.

"Service" means the Finestro AI education platform accessible at finestro.io.

"Service Content" means all educational materials, tools, data, and other content made available through the Service.

"Subscription" means a recurring plan granting access to the Service.

"Trial Period" means the introductory 1-week trial period offered for certain Subscription plans.

"Withdrawal Period" means the 14-day period during which eligible Consumers in the EEA, UK, or Switzerland may exercise their statutory right of withdrawal.

3. GENERAL REFUND POLICY

3.1 All purchases and payments made in connection with the Service are generally non-refundable once processed. This applies to Subscription fees, Trial Period fees, one-time purchases, and any unused Service Content.

3.2 Without limiting the foregoing, refunds will not typically be issued for any of the following reasons:

1. The Consumer changed their mind or was dissatisfied with the Service after purchase;
2. The Consumer forgot to cancel during the Trial Period or before a renewal date;
3. The Consumer was unaware that the Subscription would automatically renew;
4. The Consumer did not realize the Service required payment.

3.3 VELRIO LIMITED reserves the right to update or modify the categories of non-eligible refund reasons at any time by revising this Policy in accordance with Section 11.

3.4 If you believe exceptional circumstances warrant a refund outside the conditions described in this Policy, you may contact customer support at [email protected] for individual review. Any refund granted under this provision is at the sole discretion of VELRIO LIMITED.

4. SPECIFIC REFUND CONDITIONS

Notwithstanding the general non-refund policy set forth in Section 3, refunds or account credits may be issued under the following specific conditions:

5. Billing Errors: If you are charged in error (including duplicate charges, incorrect amounts, or charges processed after proper cancellation in accordance with the Subscription Terms), we will investigate and, where confirmed, correct the error by issuing a refund or account credit.
6. Non-Delivery of Service: If paid Service Content was not delivered or was inaccessible due to an error attributable to us, we will either deliver the applicable content or issue a refund at our election.
7. Significant Technical Issues: Prolonged or material technical outages affecting your access to the Service may, at our sole discretion, warrant a Subscription extension or partial refund. Minor, temporary, or intermittent disruptions do not qualify.
8. Company-Initiated Termination or Material Downgrade: If we discontinue the Service or materially reduce its scope without cause during a prepaid Subscription period, you will receive a pro-rata refund of the unused prepaid portion.
9. Termination for User Violation: No refund will be issued if your access to the Service is terminated due to your breach of the Terms of Service.

5. EEA, UK, AND SWISS CONSUMER RIGHT OF WITHDRAWAL

5.1 Statutory Right. Consumers in the EEA, United Kingdom, or Switzerland have a statutory 14-day right of withdrawal from distance contracts. For ongoing Subscription services, you expressly request and consent to the immediate commencement of service supply upon purchase. If you exercise withdrawal within the Withdrawal Period, we will deduct a proportional amount for the Service already provided. This consent does not constitute a full waiver of your withdrawal right.

5.2 Exercising Your Right. You may exercise your right of withdrawal by sending an unequivocal written statement by email to [email protected] or completing and submitting the Model Withdrawal Form below. The Withdrawal Period expires 14 days after the day you enter into the contract.

5.3 Model Withdrawal Form (EEA/UK/Swiss Consumers):

To: VELRIO LIMITED, Prodromou, 75, ONEWORLD PARKVIEW HOUSE, Floor 4, Nicosia, Republic of Cyprus 2063. Email: [email protected]

I hereby give notice that I withdraw from my contract for the following service: [Name of Service/Subscription Plan]. Ordered on / Received on: [Date]. Name of consumer: []. Address of consumer: []. Signature of consumer (only if notified on paper): []. Date: [].

5.4 Effects of Withdrawal. If withdrawal is valid, we will reimburse all payments received, minus any proportional deduction for Service already provided. Reimbursement will be made using the same payment method used for the initial transaction, unless expressly agreed otherwise, and will be processed without undue delay and no later than 14 days from the day we are informed of your withdrawal decision.

6. QUEBEC CONSUMER CANCELLATION RIGHTS

6.1 Statutory Right. Consumers residing in the Province of Quebec may cancel a contract for services involving sequential performance at any time, in accordance with the Quebec Consumer Protection Act (Loi sur la protection du consommateur). Cancellation takes effect upon receipt by VELRIO LIMITED of written notice from the Consumer.

6.2 Cancellation Procedure. To cancel, you must send a written cancellation notice to VELRIO LIMITED by email at [email protected] or by mail to the address below. Upon receipt of a valid cancellation notice, we will cease billing for subsequent periods. Any amounts prepaid for periods following the effective date of cancellation will be refunded on a pro-rata basis.

6.3 Model Cancellation Form (Quebec Consumers):

To: VELRIO LIMITED, Prodromou, 75, ONEWORLD PARKVIEW HOUSE, Floor 4, Nicosia, Republic of Cyprus 2063. Email: [email protected].

I hereby give notice that I cancel my contract for the following service: [Name of Service/Subscription Plan]. Contract date: [Date]. Name of consumer: [Name]. Address of consumer: [Address]. Date: [Date].

7. RESIDENTS OUTSIDE THE EU, UK, AND QUEBEC

7.1 This Section applies to users who reside outside the European Economic Area, the United Kingdom, Switzerland, and the Province of Quebec, Canada.

7.2 Consumer protection laws vary by jurisdiction. In the United States and most other jurisdictions, there is generally no automatic statutory cooling-off period or right of withdrawal applicable to online digital subscription services. Accordingly, the general no-refund policy set out in Section 3 of this Policy applies in full to such users.

7.3 Where applicable local consumer protection statutes mandate cancellation rights, refund rights, or other remedies that cannot be excluded or limited by contract, VELRIO LIMITED will honor those mandatory rights to the extent required by law. Nothing in this Policy is intended to limit or exclude any right or remedy that applicable mandatory law grants to Consumers and that cannot be waived by agreement.

7.4 If you believe you are entitled to a refund or cancellation right under your local consumer laws, please contact us at [email protected] with details of the applicable statute or regulation, and we will review your request in accordance with the relevant legal requirements.

8. APP STORE PURCHASES

8.1 If you purchase a Subscription to the Service through a third-party application store, including the Apple App Store or Google Play (each, an "App Store"), your purchase is subject to the refund policies and terms of that App Store.

8.2 VELRIO LIMITED does not control and cannot process refunds for purchases made through an App Store. Any refund request for an App Store purchase must be directed to the applicable App Store provider in accordance with its policies and procedures.

8.3 To the extent of any conflict between this Policy and the terms of an App Store with respect to a Subscription purchased through that App Store, the App Store's terms shall govern the refund process for that transaction.

8.4 For Subscriptions purchased directly through the Service at finestro.io, this Policy applies in full, and refund requests should be submitted to [email protected].

9. CHARGEBACKS

9.1 Prior Contact Required. Before initiating a chargeback, dispute, or payment reversal with your bank, credit card company, or payment provider, you must first contact us at [email protected] to attempt to resolve the billing issue. We commit to investigating and responding to billing inquiries promptly.

9.2 Account Suspension. We reserve the right to suspend your account and access to the Service immediately upon receiving notice of a chargeback or payment dispute, pending resolution of the matter.

9.3 Chargeback Abuse. Filing a chargeback without first contacting us, or filing chargebacks that are fraudulent, frivolous, or otherwise abusive, constitutes a violation of the Terms of Service and may result in permanent account termination.

9.4 Granted Chargebacks. If a chargeback is granted by your bank or payment provider, your account will be terminated immediately, and you will lose access to all Service Content associated with that account.

9.5 Recovery of Costs. We reserve the right to pursue recovery of any amounts owed, including chargeback fees and administrative costs, through lawful means where a chargeback is determined to have been filed improperly.

10. REFUND PROCESSING

10.1 Payment Method. Where a refund is approved under this Policy, the refund will be credited to the original payment method used for the transaction. If the original payment method is no longer available or valid, we may, upon mutual written agreement, issue the refund to an alternative payment method designated by the Consumer.

10.2 Processing Timeframe. We will initiate approved refunds without undue delay. Depending on the payment processor and the Consumer's financial institution, refunds may take several business days to appear on the Consumer's account statement after initiation.

10.3 Termination of Access. If a refund is issued for the current billing period, premium access to the Service may be terminated immediately upon issuance of the refund. Any Service Content accessed or downloaded prior to termination remains subject to the Terms of Service.

10.4 Currency and Fees. Refunds will be issued in the same currency as the original transaction. We are not responsible for any exchange rate differences or fees imposed by the Consumer's bank or payment provider.

11. AMENDMENTS

11.1 VELRIO LIMITED reserves the right to update, amend, or modify this Refund Policy at any time, in its sole discretion. Any revised version will be identified by an updated "Last Updated" date at the top of this Policy.

11.2 We will notify users of material changes to this Policy by reasonable means, which may include: (a) posting the revised Policy on finestro.io with a prominent notice; (b) sending an email notification to the address associated with your account; or (c) providing an in-Service notification prior to the effective date of the changes.

11.3 Your continued use of the Service after the effective date of any amended version of this Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you must discontinue use of the Service and cancel your Subscription before the changes take effect.

11.4 Amendments to this Policy will not reduce any mandatory Consumer rights that apply under Sections 5 or 6 of this Policy, or under any other applicable mandatory consumer protection law.

12. GOVERNING LAW

12.1 This Refund Policy, and any dispute or claim arising out of or in connection with it (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of the Republic of Cyprus, consistent with the governing law provisions set forth in the Terms of Service.

12.2 Nothing in this Section 12 shall deprive any Consumer of the protection afforded by mandatory consumer protection provisions of the law of the jurisdiction in which that Consumer is habitually resident. Where mandatory local consumer protection statutes (including, without limitation, those of any EEA Member State, the United Kingdom, Switzerland, or the Province of Quebec) grant rights that cannot be overridden by contractual choice-of-law provisions, those mandatory rights shall prevail to the extent of any inconsistency with this Policy.

12.3 The application of the United Nations Convention on Contracts for the International Sale of Goods is expressly excluded.

13. CONTACT INFORMATION

13.1 For all refund requests, billing inquiries, withdrawal notices, and cancellation notices, please contact:

VELRIO LIMITED

Prodromou, 75, ONEWORLD PARKVIEW HOUSE, Floor 4Nicosia, Republic of Cyprus 2063

Email: [email protected]

13.2 When submitting a refund or withdrawal request, please include your full name, the email address associated with your account, the relevant Subscription plan, and a description of the reason for your request. Providing this information will allow us to process your inquiry promptly.