1. Scope of Refunds

This Refund Policy applies to:

• Subscription fees paid by Traders and Dealers on Tradoly.
• Service fees charged for platform usage, payment processing, or logistics integrations when applicable.
• Transaction-related charges where Tradoly is a technical intermediary.

Refunds apply only to digital platform services and not to the sale or transport of vehicles, as Tradoly is not the seller, buyer, or logistics provider.

Marketplace Role Clarification:

Tradoly operates as a technical intermediary platform facilitating interactions between buyers (Dealers) and sellers (Traders).

Depending on the transaction type:

• Tradoly may act only as a technical service provider (e.g., listings, subscriptions)
• Payments may be processed via third-party providers or directly between users

Payments are processed through a third-party escrow arrangement provided by PayProff for transaction-based vehicle deals, whereby funds are held and released in accordance with applicable transaction instructions and platform rules. In addition, recurring subscription fees and platform service charges may be processed via Stripe, acting as a payment service provider for automated billing and subscription management. Users are onboarded through a combined internal and third-party (PayProff) KYC/KYB verification process prior to account activation. All refund requests are subject to internal verification by Tradoly based on submitted evidence and transaction records and are processed in accordance with the applicable PayProff escrow release procedures or Stripe billing and refund mechanisms, as well as the standard Tradoly refund workflow.

This distinction affects refund eligibility and responsibility.

2. No Refund Rule

2.1 No Refund for Fees

Subscription fees are non-refundable once paid and activated, even if the user:

• Discontinues use immediately
• Fails to use the platform
• Terminates the account voluntarily

Service Fees and Transaction Charges are non-refundable once processed, including but not limited to:

• Platform usage fees
• Payment processing fees
• Logistics integration fees

2.2 No Refund for Completed Services

Tradoly does not provide refunds for:

• successfully activated subscriptions,
• completed listing services,
• Exclusive car listing
• Listing extension service
• fees already consumed through platform usage,
• promotional or sponsored placements once displayed,
• third-party costs (e.g. Stripe, PayProff, ASG service, TransConnect logistics service).

2.3 Justification of No-Refund Policy:

Certain services provided by Tradoly are classified as immediately performed digital services, including but not limited to listing activation, promotional placement, and subscription access. Upon activation or delivery of such services, they are deemed fully performed and are not subject to refund, except where required by applicable mandatory law.

Where applicable under EU consumer law (Directive 2011/83/EU), users expressly acknowledge and agree that performance of digital services may begin immediately upon activation, and that they thereby lose any applicable withdrawal right once the service has been fully performed.

This includes instant listing publication, real-time exclusive listing placement, vehicle listing data services, and immediate visibility across search and matching systems upon activation.

This provision does not affect statutory rights in cases of service non-performance, technical failure, or other mandatory legal protections under applicable law.

3. Subscription Refund Conditions

Subscription benefits may include:

• Access to listing tools
• Priority placement or promotional features
• Communication tools with other users

Included subscription features may consist of exclusive product access, third-party ASG based services (including vehicle damage reports, registration tax estimates, and market price data retrieval), standard support (email and SMS), basic analytics dashboard, standard listing visibility, access to a verified trader network, unlimited car purchase capability, platform service fee handling, car reservation functionality, extended reservation periods, and other plan-specific benefits and promotional or priority placement features depending on the selected subscription. Use of any of these features may be considered partial or full consumption of the service.

3.1 Initial Billing Period

Subscription fees are non-refundable once activated, except in cases of:

• duplicate billing caused by a technical error;
• an incorrectly applied plan tier;
• legally mandated refunds under Spanish contract law.

3.2 Auto-Renewal

Users are responsible for cancelling their subscription before renewal.

Users can cancel subscriptions through their Account Setting.

Cancellation takes effect at the end of the current billing cycle. No partial refunds apply for ongoing periods.

Refunds for auto-renewed payments are only considered if:

• the user contacts support within 48 hours of being charged.

4. Refunds for Platform Errors

4.1 Definition of Technical Failure:

A technical failure includes:

• Inability to publish or access paid listings
• System errors preventing subscription activation
• Incorrect billing due to system malfunction
• API integration failures
• Third-party service disruptions (including ASG data services, PayProff escrow processing, Stripe payment processing)
• Payment gateway timeouts or processing delays beyond Tradoly's control

It does not include:

• User errors (incorrect data entry)
• Poor listing performance or lack of buyer interest
• API integration failures, third-party service disruptions, including ASG data services, PayProff escrow processing, Stripe payment processing, and any payment gateway timeouts or latency issues beyond Tradoly's control.

4.2 Refund issue conditions

A refund may be issued where Tradoly confirms that:

• a technical failure prevented the delivery of the subscribed service,
• the user was charged for a service that was not provided,
• there was a system miscalculation of fees.

Refunds cannot be granted for user mistakes/errors, incorrect vehicle details, or VAT misclassification caused by the user.

5. Physical Order Return & Refund Workflow (Vehicle Transactions)

5.1 Transaction Role and Responsibility:

In vehicle transactions:

• The Trader (seller) is responsible for the product, pricing, and acceptance of returns
• The Dealer (buyer) is responsible for initiating return requests within the allowed period
• Tradoly facilitates the workflow but does not take ownership of goods

Where applicable, payments are processed through a third-party escrow system (PayProff), under which funds are temporarily held and released based on transaction completion, return validation, or dispute resolution outcomes. Tradoly does not at any time take custody, ownership, or direct control of funds, except for facilitating instructions within the escrow workflow.

5.2 Return Eligibility Conditions:

Returns are only permitted where supported by verifiable proof, including but not limited to material misrepresentation, undisclosed damage, condition mismatch, transport damage, or confirmed transaction fraud. Return eligibility is subject to review and validation through platform records, inspection reports, and supporting documentation provided by either party.

5.3 Vehicle Condition Verification:

Vehicle condition is assessed based on inspection reports, dealer-submitted documentation, logistics partner records (including TransConnect or other API-integrated providers), and any ASG-based damage reports where applicable. Vehicle condition and delivery verification may also include transport and legal documentation such as CMR (Consignment Note), delivery confirmation records, and vehicle registration or export/import documents where applicable. Tradoly does not independently verify physical vehicle condition and relies on third-party and user-submitted data.

5.4 Escrow Release and Dispute Handling:

In escrow-based transactions, funds remain held by PayProff until successful completion of delivery or resolution of an active dispute. In case of disputes, release or reversal of funds is determined based on internal review of submitted evidence, transaction records, and third-party verification inputs. Tradoly acts solely as a facilitation layer and does not adjudicate legal ownership or physical possession of vehicles.

5.5 Return Workflow:

This section governs the return of physical goods and the financial settlement between Dealers (Buyers), Traders (Sellers), and Tradoly.

Return Request & Approval:

Dealers have 14 days from delivery to submit a return request. After the return request window closes, a 5-day approval period applies during which the Trader may approve or reject the request. If no response is provided within this period, the return request shall be deemed approved for further processing in accordance with platform rules.

Upon approval, the system initiates return processing and logistics coordination. Return shipments may be grouped by consignment location for operational efficiency through integrated logistics providers, including TransConnect or other API-based logistics partners.

Return validation and processing may involve supporting documentation and evidence, including CMR (Consignment Note), delivery confirmation records, vehicle registration or export/import documents where applicable, photographic evidence, and other logistics or transport records provided by the parties or third-party service providers.

Return shipments are delivered back to the Trader. Any applicable return shipping or handling costs may be deducted in accordance with platform rules and the specific transaction terms.

Upon confirmed delivery and validation of returned goods, the refund process is initiated against the original transaction. Where applicable under the escrow system (PayProff), funds are released in accordance with the final verified return outcome.

System callbacks update return and refund status across the platform in real time.

5.6 Data Processing in Return Workflow:

Processing of return requests involves:

• Sharing relevant transaction, vehicle, and user data between buyer and seller
• Updating order, return, escrow, and logistics status across internal systems
• Communicating with third-party logistics providers (including TransConnect or other API-integrated providers)
• Processing and exchanging relevant transport and verification documentation, including CMR (Consignment Note), delivery confirmations, ASG reports, and other supporting evidence where applicable
• Coordinating with payment and escrow providers (including PayProff) for settlement, refund, or release instructions

This processing is necessary for the performance of the contract between the parties (Article 6(1)(b) GDPR), as well as for the operation of the return, logistics, and dispute resolution workflow.

6. Chargebacks and Disputes

Users agree not to initiate chargebacks for valid transactions and authorized transactions.

In case of a chargeback, Tradoly may freeze the user's account and withhold payouts pending investigation.

Fraudulent, abusive, or repeated chargebacks may result in:

• account termination,
• legal recovery of fees and damages,
• reporting to payment processors and relevant authorities.

For unresolved issues, users may contact the Centro Europeo del Consumidor en España or file a complaint through the Online Dispute Resolution (ODR) platform: https://ec.europa.eu/consumers/odr/

7. Refund Processing Procedure

7.1 Submission

Refund requests must be submitted through:

• support@tradoly.com, or
• the in-platform support module.

Requests must include:

• account email,
• invoice number,
• reason for the refund,
• supporting documents (if any).

7.2 Assessment

All refund requests undergo:

• verification of account activity,
• assessment of whether the service was consumed,
• compliance checks (VAT accuracy, identity verification, payment legitimacy).

Tradoly may request identity verification before processing any refund to comply with AML and financial crime regulations.

Refund requests may also involve automated and manual fraud checks, including:

• Transaction validation
• Identity verification
• Detection of suspicious activity
• Fraud detection systems and automated risk scoring tools, including behavioral analytics and anomaly detection mechanisms integrated into the platform and payment/escrow flows (including PayProff and Stripe-related validation where applicable)

This processing is necessary to prevent fraud and ensure platform integrity (Art. 6(1)(f) GDPR).

7.3 Refund Timeline

Approved refunds are processed within 14 business days through the original or customer preferenced payment method.

Delays caused by banks, payment processors (including Stripe or PayProff), or external financial institutions are outside Tradoly's control.

8. No Refunds for Third-Party Services

Payments facilitated through third-party providers (including Stripe, PayProff, ASG services, and logistics providers) are subject to the respective terms, conditions, and refund policies of those third parties.

Tradoly cannot refund or assume liability for:

• transport fees,
• VAT charges,
• payment processor fees,
• costs incurred through external service providers, including logistics, inspection, or data services.

Any refund or reimbursement relating to such third-party services is governed exclusively by the applicable third-party provider's policies and contractual terms.

8.1 Third-Party Data Processing:

When payments, verification, analytics, or logistics services are handled by third parties, personal data may be shared strictly to the extent necessary to execute, process, or complete the transaction or related services.

These third-party providers may act either as independent data controllers or as data processors depending on the nature of the service and contractual relationship.

Such providers include Stripe, PayProff, ASG service providers, and logistics partners (including TransConnect and other API-integrated logistics providers used by Tradoly from time to time).

Tradoly is not responsible for the data retention practices, refund policies, or internal processing decisions of such third-party providers, which are governed by their own privacy policies and contractual obligations.

All data sharing is carried out in accordance with applicable data protection laws, including GDPR, and is limited to what is necessary for contract performance, legal compliance, and fraud prevention.

9. Personal Data & Refund Processing (GDPR Alignment)

To process refunds and manage disputes, Tradoly processes personal data including:

• Billing and transaction details
• Account and identity information
• Communication and support logs
• Technical and audit logs

Processing is based on:

• Art. 6(1)(b) GDPR – contractual necessity
• Art. 6(1)(c) GDPR – legal obligations (tax, AML, accounting)
• Art. 6(1)(f) GDPR – fraud prevention and platform security

Marketplace Context: Certain data (e.g. transaction details, communication history) may be shared with other users involved in the transaction.

Once shared, such data may be retained independently by those users.

Invoice sharing between transaction parties, downloadable/exportable transaction and refund reports, and system-generated audit logs or summaries for accounting, dispute resolution, tax, or regulatory compliance purposes.

10. Abuse, Fraud & Misuse Prevention

Tradoly reserves the right to refuse refunds where:

• misuse of the platform is detected,
• suspicious activity suggests money laundering or VAT fraud,
• the account shows repeated refund or chargeback attempts.

Tradoly may suspend accounts pending further investigation.

Tradoly may do platform monitoring for fraud prevention:

• Repeated refund requests
• Abnormal transaction patterns
• Listing manipulation or misuse

Such monitoring may involve automated systems and manual review.

Account risk scoring systems, and fraud risk flags generated through automated monitoring tools and transaction analysis across platform activity, including integration-based signals from payment and escrow providers (such as Stripe and PayProff where applicable).

11. Amendments

Tradoly may update this Refund Policy to reflect legal, regulatory, or operational changes.

Users will be notified where legally required.

12. User-to-User Disputes

For transactions conducted between users:

• Refund decisions related to the underlying product (vehicle) are the responsibility of the seller (Trader)
• Tradoly may assist in dispute handling but does not guarantee resolution outcomes

Users are encouraged to resolve disputes directly where possible.

The platform provides structured dispute resolution tools, including in-platform dispute submission forms, evidence upload functionality, messaging between parties, case tracking dashboards, and optional email based escalation workflows for internal review and escrow-related coordination (where applicable via PayProff).

13. Transparency and User Expectations

Tradoly aims to provide clear information regarding:

• When fees are charged
• Which services are refundable or non-refundable
• How refunds are processed

Users are responsible for reviewing service details before making payments.

This information is disclosed through in-platform interfaces, including pricing pages, checkout screens, subscription selection pages, listing creation flows, and transactional confirmation screens where applicable. Users acknowledge that all applicable fees, refund conditions, and service terms are displayed prior to final confirmation of payment.