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Coinhold Wallet P2P Dispute Resolution Rules

These Dispute Resolution Rules set out the procedure for reviewing user requests related to P2P orders placed on the Platform.

These Rules constitute additional rules, guidelines, and procedures that apply to the review of user requests under the P2P Transaction Support Services provided by EMCD Fintech, and they apply together with the Quensa.io P2P Terms of Use, the EMCD Terms of Service, the Privacy Policy, and any other applicable rules, guidelines, and notices available on the Platform.

Capitalized terms used but not defined in these Rules have the meanings given to them in the Quensa.io P2P Terms of Use and/or the EMCD Terms of Service, as the context requires.

In the event of any conflict between these Rules and the Quensa.io P2P Terms of Use, the Quensa.io P2P Terms of Use will prevail with respect to the P2P Bulletin Board Services and the P2P Transaction Support Services, unless the EMCD Terms of Service expressly provide otherwise. In the event of any conflict between these Rules and the EMCD Terms of Service with respect to the P2P Transaction Support Services, the EMCD Terms of Service will apply to the extent they expressly govern the matter in question.

Quensa.io provides a bulletin board-style P2P technology platform that allows users to post and browse listings and to interact with one another in connection with potential P2P orders. Quensa.io is not a party to any P2P order, does not participate in the performance of obligations between users, and does not provide custody of Digital Assets, escrow, the release, return, or transfer of Digital Assets, fiat payment processing, P2P order execution, financial intermediation, counterparty matching, clearing, settlement, or any other activity related to the execution of transactions between users.

EMCD Fintech provides the P2P Transaction Support Services if and when users use such services. These services may include, among other things, custodial wallet functionality, escrow of Digital Assets, the release, return, or continued holding of Digital Assets, compliance checks under applicable rules, review of proof of payment, dispute resolution support, and other related P2P transaction support functions provided for in the Quensa.io P2P Terms of Use, the EMCD Terms of Service, these Rules, and the applicable guidelines available on the Platform.

Posting a listing, creating a P2P order, or using the Platform's shared interface does not make Quensa.io a party to any transaction between users, nor does it mean that Quensa.io provides the P2P Transaction Support Services. Likewise, EMCD Fintech's provision of the P2P Transaction Support Services does not make EMCD Fintech a party to any fiat settlement between users or make EMCD Fintech a payment service provider.

As part of the P2P Transaction Support Services, EMCD Fintech Support may review requests and disputes related to P2P orders, request any necessary documents and information, review submitted materials, set deadlines for providing information, and make decisions regarding Digital Assets held in escrow, including releasing them to the buyer, returning them to the seller, continuing to hold them, restricting them, or otherwise administering them, in accordance with the Quensa.io P2P Terms of Use, the EMCD Terms of Service, these Rules, the applicable guidelines on the Platform, and Applicable Law.

All P2P transactions take place directly between users. Users independently set the terms of each transaction, settle fiat payments directly with each other or through third-party banks and payment services, and are responsible for fulfilling their own obligations.

The dispute resolution procedure is intended solely to help users resolve disagreements and does not guarantee the fulfillment of obligations under a P2P order, a refund, the transfer of Digital Assets, or compensation for losses.

1. General Dispute Resolution Procedure

1.1 If a disagreement arises, a dispute may be opened through the Platform interface in the cases and in the manner set out in these Rules.

1.2 When reviewing a dispute, EMCD Fintech Support may request from the parties any documents, information, explanations, and other materials necessary to establish the facts of the dispute and may set a deadline for providing them.

1.3 When reviewing a dispute, EMCD Fintech Support may take into account any documents, information, and materials that EMCD Fintech Support considers relevant to the dispute, including, without limitation:

  • documents and materials submitted by the parties;

  • proof of payment;

  • communications between the parties on the Platform;

  • any other documents, information, and circumstances relevant to the dispute.

1.4 Users must promptly provide accurate documents, information, and explanations needed to review the dispute. Failure to provide requested information, refusal to cooperate, or providing inaccurate information may be taken into account by EMCD Fintech Support when making a decision.

1.5 Based on the outcome of the dispute review, EMCD Fintech Support may make a decision regarding the Digital Assets held in escrow, including releasing them to the buyer, returning them to the seller, continuing to hold them, restricting them, or otherwise administering them, in accordance with these Rules, the Quensa.io P2P Terms of Use, the EMCD Terms of Service, the applicable guidelines on the Platform, and Applicable Law. Such a decision is based on the available materials and does not constitute a judicial, arbitral, or governmental resolution of the dispute between users.

1.6 When reviewing a dispute, EMCD Fintech Support may take into account circumstances related to chargebacks, canceled or blocked bank transfers, actions of banks and payment systems, requirements of Applicable Law, and any other circumstances that may affect the security of the transaction or the ability to complete the P2P order.

1.7 Refusal to cooperate or bad-faith conduct includes, without limitation:

  • participating in fraudulent schemes intended to harm another user, Quensa.io, EMCD Fintech, or third parties;

  • a buyer's failure to pay after confirming payment or creating the appearance of payment;

  • a seller's unjustified refusal to complete a P2P order after receiving payment;

  • abusing the dispute procedure by submitting knowingly false claims, accusations, documents, or proof of payment;

  • failing to respond, causing unjustified delays, or engaging in hostile, abusive, or unconstructive communication;

  • charging hidden commissions or fees not provided for in the terms of the listing or order;

  • attempting to change the terms of a transaction after the order has been created;

  • pressuring other users to communicate, pay, share payment details, or complete a transaction outside the Platform's official channels;

  • using third-party payment accounts where this is prohibited by the Platform rules or applicable guidelines;

  • providing inaccurate, forged, incomplete, or misleading documents, information, or proof of payment.

2. Buyer Disputes

2.1 Order Canceled After Payment

If an order was canceled after payment was made (because the payment window expired or the buyer canceled it by mistake), EMCD Fintech Support may contact the seller to help resolve the situation and, where possible, facilitate a voluntary refund.

If the seller confirms receipt of the funds and agrees to refund them, the parties will process the refund between themselves.

If the seller refuses to issue a refund:

  • EMCD Fintech Support does not process fiat payments and is not liable for any losses arising from users' performance or non-performance of their refund obligations;

  • compensation to the buyer is not guaranteed;

  • EMCD Fintech Support may restrict the user's access to P2P trading if the user refuses to cooperate.

2.2 Payment Amount Does Not Match the Order Amount

If the buyer transferred more than the amount specified in the order, EMCD Fintech Support may contact the seller to help resolve the situation and, where possible, arrange a refund of the overpayment.

If the seller refuses to refund the overpayment:

  • the buyer bears responsibility for any resulting losses;

  • EMCD Fintech does not compensate for losses resulting from such a transaction;

  • EMCD Fintech Support may restrict or block P2P trading access for users who refuse to cooperate in resolving the dispute.

EMCD Fintech does not process, control, execute, cancel, reverse, verify, or facilitate fiat transfers between users, and it does not guarantee that such transfers will be successful, timely, or refunded. Fiat payments are made directly between users or through third-party banks, payment systems, or other payment channels. Disputes related to fiat payments are outside the Platform's control. EMCD Fintech's review of proof of payment, bank documents, communications, or other materials as part of the P2P Transaction Support Services does not constitute fiat payment processing, a payment service, or financial intermediation, nor does it guarantee that any such payment will be successful, timely, or refunded.

2.3 Seller Delays Sending Cryptocurrency

Instant Payment Methods

If the buyer claims to have paid using an instant payment method and the seller does not confirm receipt of payment or complete the order within 30 minutes, EMCD Fintech Support may contact the seller to confirm the payment status and address the release of the Digital Assets held in escrow.

If the seller does not respond or provide the requested materials within the set deadline, EMCD Fintech may manually make a decision based on the available materials, including releasing the Digital Assets to the buyer, returning the Digital Assets to the seller, continuing to hold them, or canceling the order, depending on the circumstances, the evidence provided, fraud risk, chargeback risk, bank account freeze risk, compliance with applicable rules, and other relevant factors.

Non-Instant Payment Methods

If a non-instant payment method is used or the seller cannot promptly confirm receipt of the funds, EMCD Fintech Support may contact the seller to check the payment status and may allow additional time to complete the order.

If payment has not been received within the set timeframe, the seller must promptly contact EMCD Fintech Support directly and provide supporting materials within the set deadline. Failure to respond or provide the requested materials may be taken into account by EMCD Fintech when making a decision based on the available materials and may result in a decision against the non-responding party, including the release of the Digital Assets to the buyer, if EMCD Fintech considers such a decision justified under the circumstances.

2.4 Seller Refuses to Send Cryptocurrency

If the buyer transferred the correct amount from an account whose holder name matches the verified name on the user's EMCD Fintech account, and the seller refuses to complete the order, refuses to confirm receipt of payment, or attempts to change the order terms after the order was created, EMCD Fintech Support may step in to help resolve the matter and make a decision regarding the Digital Assets held in escrow.

  • For orders of up to $1,000, if the difference between the order price and the market price does not exceed 10%, EMCD Fintech Support may decide to release the Digital Assets held in escrow to the buyer, provided there are no signs of fraud, sanctions risk, chargeback risk, bank account freeze risk, third-party payment, conflicting evidence, or other circumstances that, in EMCD Fintech's judgment, require returning the Digital Assets to the seller, continuing to hold them, restricting transactions, or conducting an additional review.

  • For orders over $1,000, the acceptable price deviation is 5%. If this threshold is not exceeded and the buyer has provided sufficient proof of payment, EMCD Fintech Support may decide to release the Digital Assets held in escrow to the buyer. In that case, the seller is solely responsible to the buyer for any obligation to refund the funds received if such a refund is required under the order terms, these Rules, the Quensa.io P2P Terms of Use, the EMCD Terms of Service, or Applicable Law.

Important: The seller is responsible for making sure the listing price is correct. EMCD Fintech recommends carefully checking the price before creating an order. A pricing error alone is not grounds for canceling the order, issuing a refund, or granting claims related to a change in the order price, unless EMCD Fintech determines otherwise, taking into account all circumstances, fraud risk, compliance with applicable rules, or Applicable Law.

2.5 Buyer Added a Payment Note and Seller Did Not Send Cryptocurrency

If, when transferring funds, the buyer included in the payment note any words or phrases related to cryptocurrency, P2P trading, the EMCD or Quensa.io name, digital assets (BTC, ETH, etc.), or other confidential information, and the seller refuses to complete the order for that reason, EMCD Fintech Support may contact the parties and request additional materials.

The purpose of EMCD Fintech Support's involvement is to help resolve the situation and make a decision regarding the Digital Assets held in escrow. EMCD Fintech may decide to release, return, or continue holding the Digital Assets held in escrow, taking into account the evidence provided, payment risk, bank account freeze risk, chargeback risk, fraud risk, compliance with applicable rules, and other circumstances.

Important: If any funds are refunded, all related fees are paid by the buyer.

2.6 Offensive Language

If either party uses offensive, threatening, discriminatory, misleading, fraudulent, or otherwise inappropriate language on the Platform, including in the order chat, support chat, reviews, order comments, or other official communication channels, Quensa.io and/or EMCD Fintech, depending on the applicable function and role, may partially or fully restrict that user's access to the P2P Services, Platform functionality, and/or the P2P Transaction Support Services, and may take any other measures provided for in the Quensa.io P2P Terms of Use, the EMCD Terms of Service, the applicable guidelines, and Applicable Law.

3. Seller Disputes

3.1 Buyer Did Not Pay but Clicked Paid

If the buyer has not made the payment or has not provided proof of payment from a banking app, bank website, or payment service, or any other requested materials, within the set deadline, EMCD Fintech Support may make a decision based on the available materials, including canceling the order, returning the Digital Assets to the seller, continuing to hold the Digital Assets, or restricting transactions.

If the same conduct occurs three or more times, Quensa.io and/or EMCD Fintech, depending on the applicable function and role, may partially or fully restrict the user's access to the P2P Services, Platform functionality, and/or the P2P Transaction Support Services.

If the buyer claims that payment was made from a verified account but the seller does not confirm receipt of the funds, EMCD Fintech Support may contact the seller to review the materials provided. Based on its assessment of the available evidence, EMCD Fintech may decide to release the Digital Assets to the buyer and complete the transfer within three business days, or may decide to return the Digital Assets, continue holding them, or restrict transactions. If EMCD Fintech decides to release the Digital Assets to the buyer, EMCD Fintech will take commercially reasonable steps to carry out that action within a reasonable time, subject to technical, legal, operational, and compliance constraints.

If the seller claims that the payment was not received, the seller must promptly contact EMCD Fintech Support and provide supporting materials. Failure to contact Support, respond, or provide the requested materials may be taken into account by EMCD Fintech when making a decision based on the available materials and may result in a decision against the seller.

3.2 Payment Details or Amount Paid Do Not Match

3.2.1 Transfer to Incorrect Payment Details or a Third-Party Account

If the buyer transferred funds to payment details other than those specified in the order, or to a third-party account, EMCD Fintech is not liable for any resulting losses and does not guarantee a refund.

Any third-party payments, including transfers from accounts that do not belong to the buyer, may be considered a violation of the Platform rules and/or grounds for refusing to complete the order, returning the Digital Assets to the seller, continuing to hold the Digital Assets, restricting transactions, canceling the order, or taking other measures provided for in the Quensa.io P2P Terms of Use, the EMCD Terms of Service, these Rules, the applicable guidelines, and Applicable Law.

EMCD Fintech does not process, initiate, execute, cancel, or guarantee such payments and has no control over third-party banks, payment systems, payment accounts, or the actions of third parties. All risks, including the risk of losing funds, are borne entirely by the user who used incorrect payment details or involved third parties, except where Applicable Law does not permit such an allocation of risk.

3.2.2 Buyer's Payment Account Name Mismatch

If the payment account holder's name does not match the verified name on the EMCD Fintech account, the order cannot be completed.

In this case, EMCD Fintech Support may ask the seller to refund the full transferred amount to the buyer. Once the refund is confirmed and the buyer has received the funds, the order may be canceled.

All fees related to the refund are paid by the buyer.

3.2.3 Partial Payment by the Buyer

If the buyer transferred less than the amount specified in the order, EMCD Fintech Support may ask the buyer to pay the remaining balance within the set deadline. All fees and other costs related to the additional payment are paid by the buyer, unless EMCD Fintech determines otherwise or Applicable Law requires otherwise.

If the buyer does not respond or refuses to pay the remaining balance, the seller will be asked to refund the funds received, and/or a decision will be made regarding the Digital Assets held in escrow, including returning them to the seller, continuing to hold them, restricting transactions, or canceling the order. EMCD Fintech is not liable for losses arising from such orders, and Quensa.io and/or EMCD Fintech, depending on the applicable function and role, reserve the right to restrict or block access for users who refuse to cooperate.

EMCD Fintech does not process, initiate, execute, cancel, control, verify, or facilitate fiat payments between users and does not guarantee that they will be successful, timely, or refunded. Any disputes related to fiat transfers are beyond EMCD Fintech's control. Reviewing proof of payment or other materials as part of the P2P Transaction Support Services does not constitute fiat payment processing, a payment service, or financial intermediation.

3.2.4 Seller Sent Cryptocurrency Before Receiving Full Payment

If the seller confirmed receipt of payment, agreed to release the Digital Assets, transferred the Digital Assets outside the Platform, or otherwise completed the transaction before receiving full payment from the buyer, the seller bears the risk of those actions. EMCD Fintech may contact the buyer to help settle the remaining payment but does not guarantee receipt of the additional payment, a refund, or compensation for losses.

If the buyer refuses to pay the remaining balance after the order has been completed or the Digital Assets have been released, all risks are borne by the seller, except where Applicable Law requires otherwise. Quensa.io and/or EMCD Fintech, depending on the applicable function and role, reserve the right to restrict or block bad-faith users' access to the P2P Services, Platform functionality, and/or the P2P Transaction Support Services.

3.3 Seller Did Not Verify Payment but Sent Cryptocurrency

If the seller confirmed receipt of payment, agreed to release the Digital Assets, transferred the Digital Assets outside the Platform, or otherwise completed the transaction without first verifying that the payment had actually arrived in their account, the seller must immediately contact EMCD Fintech Support and report the situation. EMCD Fintech Support may request additional materials from the parties and attempt to help resolve the matter; however, EMCD Fintech does not guarantee a refund, receipt of payment, compensation for losses, or restoration of the position that existed before the transaction was completed.

If the buyer does not respond or refuses to cooperate in resolving the dispute, the seller may contact law enforcement.

The seller bears full responsibility for confirming receipt of payment or transferring Digital Assets without verifying that the funds have actually been received, except where Applicable Law requires otherwise.

3.4 Offensive Language

If either party uses offensive, threatening, discriminatory, misleading, fraudulent, or otherwise inappropriate language on the Platform, including in the order chat, support chat, reviews, order comments, or other official communication channels, Quensa.io and/or EMCD Fintech, depending on the applicable function and role, may partially or fully restrict that user's access to the P2P Services, Platform functionality, and/or the P2P Transaction Support Services, and may take any other measures provided for in the Quensa.io P2P Terms of Use, the EMCD Terms of Service, the applicable guidelines, and Applicable Law.

4. General Provisions

4.1 The dispute procedure is a support mechanism for reviewing disputes and helping resolve disagreements between users, but it does not guarantee a refund, the release of Digital Assets, the return of Digital Assets, the completion of a P2P order, compensation for losses, or the fulfillment of one party's obligations to another. Decisions are made based on the available evidence, applicable rules, and compliance and risk-based considerations, and within the Platform's technical capabilities.

4.2 Quensa.io does not act as a party to any P2P order, a guarantor of obligations between users, an escrow provider, a payment service provider, a financial intermediary, an exchange, a broker, a dealer, or a custodian. As part of the P2P Transaction Support Services, EMCD Fintech may administer escrow of Digital Assets; the release, return, continued holding, or restriction of Digital Assets; compliance checks under applicable rules; review of proof of payment; and dispute support. However, EMCD Fintech does not act as a guarantor of obligations between users, does not assume counterparty risk, and does not compensate for losses arising from the use of the P2P Services. Users are responsible for assessing their own risks, including the risks of fraud, errors, third-party payments, chargebacks, bank account freezes, payment cancellations or reversals, and actions of financial institutions and other third parties. By using the Platform, users fully and unconditionally accept these risks to the maximum extent permitted by Applicable Law.

5. Governing Law and Dispute Resolution

Disputes and claims arising out of or in connection with the P2P Bulletin Board Services provided by Quensa.io are governed by the Quensa.io P2P Terms of Use, including the governing law and dispute resolution provisions applicable to Quensa.io.

Disputes and claims arising out of or in connection with the P2P Transaction Support Services provided by EMCD Fintech, including escrow of Digital Assets; the release, return, continued holding, or restriction of Digital Assets; compliance checks under applicable rules; review of proof of payment; and dispute support, are governed by the Quensa.io P2P Terms of Use, the EMCD Terms of Service, and/or the applicable Platform terms, including the governing law and dispute resolution provisions applicable to EMCD Fintech, unless Applicable Law requires otherwise.

Nothing in these Rules shall be construed as requiring Quensa.io, EMCD Fintech, the Platform Hosting Provider, the App Store Publisher, a Partner, or any other service provider to submit to the governing law or forum established for the services or functions of another party, unless that party has expressly agreed to do so.

Disclaimer:

Quensa.io and/or EMCD Fintech, depending on the applicable function and role, reserve the right to suspend, restrict, or terminate a user's access to the P2P Services, Platform functionality, and/or the P2P Transaction Support Services if the user refuses to cooperate, provides false information, abuses the dispute procedure, or acts in bad faith.

If a payment is blocked, reversed, canceled, or charged back, a bank account is frozen, or banks, payment systems, payment services, or third parties otherwise intervene after the user has confirmed the payment, Quensa.io and EMCD Fintech are not liable for the consequences of such actions, except where Applicable Law does not permit such a limitation. Users understand and accept the risks of dealing with the fiat financial system.

These Rules do not constitute, and should not be considered, a recommendation to use any products, investment advice, financial advice, legal advice, tax advice, or an endorsement of the reliability of any user, listing, digital asset, or payment method. Digital assets, including stablecoins, are subject to volatility and carry high risks, up to and including a complete loss of value. Quensa.io and EMCD Fintech do not provide investment, financial, legal, or tax advice.

Before carrying out transactions with digital assets, users are advised to independently assess their financial situation, the risks of the transaction, the reliability of the counterparty, the legality of the chosen payment method, and applicable legal requirements, and, if necessary, to seek advice from legal, tax, financial, or other professional advisors.

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