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ARVIA TECH ENTERPRISE REFUND POLICY

(Applicable to All Network Transactions, SaaS Subscriptions, and Marketplace Originations Processed Through the Arvia Platform)

Effective Date: 28/04/2026 | Last Updated: 28/04/2026 | Version: 1.0

Customer Support: [email protected]

1. Overview and Purpose

This Refund Policy sets out the terms and conditions governing refunds within the Arvia Tech Enterprise ecosystem ("Arvia", "we", "us", or "our"). Arvia operates as the transaction spine of Malaysia's B2B economy, functioning as a networked Accounts Receivable (AR) and Accounts Payable (AP) pipeline.

Because Arvia facilitates B2B trade but is not a party to the underlying commercial transactions between Suppliers and Buyers, this Policy governs strictly the fees charged by Arvia for network access and transaction processing. A Buyer's entitlement to a refund of the principal purchase price for goods or services is governed entirely by the relevant Supplier's own refund and returns policy.

2. SaaS Subscription Fees

Arvia provides network access, automated reconciliation, and live cash flow analytics via tiered Software-as-a-Service (SaaS) subscriptions (e.g., Basic, Growth at RM 79/Month, and Elite at RM 100/Month).

2.1 General Cancellation and Refund Eligibility

• Active Billing Cycles: Subscription fees for the active billing month are strictly non-refundable. You may cancel your subscription at any time, with the cancellation taking effect at the end of your current billing cycle.
• Tier Upgrades: If you upgrade your tier mid-cycle (e.g., moving from Growth to Elite), the remaining balance of your previous tier will be prorated and applied as credit toward your new invoice. No cash refunds are issued for upgrades or downgrades.

2.2 Exceptions for Arvia Platform Errors

Arvia will consider a SaaS fee refund solely in the event that:

• An incorrect fee amount was charged due to a verified billing error on Arvia's part.
• The business was charged for a service tier or feature that was not activated or accessible due to a documented technical failure on Arvia's platform infrastructure.

3. Transaction Processing Fees

Arvia charges a Processing Fee for every B2B invoice settled through our integrated third-party payment gateways. The fee depends on the active subscription tier (Basic: 1.20%, Growth: 0.80%, Elite: 0.50%).

3.1 Non-Refundability of Settled Transactions

Once a payment is successfully reconciled and settled between the Buyer and Supplier, the associated transaction processing fee is entirely non-refundable. This strict non-refundability exists because:

• The fee covers the immediate, irrevocable execution costs levied by the third-party payment gateways.
• The transaction initiates the permanent timestamping of a verified data point on the Arvia network, which actively contributes to the business's accumulated behavioural credit profile. The value of this network action is delivered instantaneously upon settlement.

4. Disputed Transactions and Commercial Reversals

4.1 Commercial Disputes Between Buyer and Supplier

If a Buyer requests a refund for goods or services purchased, they must direct this request to the Supplier. Arvia has no authority to compel a Supplier to issue a commercial refund. If the Supplier approves the refund, they must execute it directly or instruct the reversal through their own gateway merchant portal. Arvia does not refund the transaction processing fees associated with the original payment, even if the principal amount is returned to the Buyer by the Supplier.

4.2 Erroneous Debits by Arvia's Systems

If an automated payment or settlement was executed without authorisation, in error, or in excess of an agreed invoice amount due to an Arvia system fault, the affected party must report the dispute to [email protected] within fourteen (14) calendar days. Following an investigation, if Arvia or our payment gateway confirms the error, a full reversal of the incorrect principal amount and any associated processing fees will be arranged within five (5) to ten (10) working days.

5. How to Submit an Arvia Fee Refund Request

All requests regarding SaaS billing errors or Arvia system faults must be submitted in writing to [email protected] within thirty (30) calendar days of the disputed charge. Verbal requests will not be accepted. The request must include:

• Full business name and SSM number;
• Arvia account email address and relevant invoice reference number;
• A clear description of the billing error or technical fault; and
• Supporting documentation (e.g., bank statement showing the disputed debit).

6. Escalation and Disputes

If you are dissatisfied with Arvia's decision on a fee refund request, you may escalate the matter by writing to the Compliance Team at [email protected]. Arvia will provide a final written determination within fourteen (14) working days. If you remain dissatisfied following escalation, complaints relating to integrated payment services may be directed to Bank Negara Malaysia's BNMTELELINK helpline or the Ombudsman for Financial Services (OFS), where applicable.

END OF REFUND POLICY

Arvia Tech Enterprise | Jalan PUJ 2/6, Taman Puncak Jalil, 43300 Seri Kembangan, Selangor | [email protected]

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ARVIA TECH ENTERPRISE TERMS AND CONDITIONS

Effective Date: 28th April 2026 | Version: 1.0

These Terms and Conditions ("Terms") govern your access to and use of the Arvia Tech Enterprise B2B transaction network, including the website and all related applications, features, APIs, and services (collectively, the "Platform") provided by Arvia ("Arvia", "we", "us", or "our"). By accessing or using the Platform, creating an account, or transacting through the Platform, you confirm that you have read, understood, and agreed to be bound by these Terms and any additional policies referenced herein.

1. DEFINITIONS

• "Arvia Network" refers to the networked Accounts Receivable (AR) and Accounts Payable (AP) pipeline serving as the transaction infrastructure for Malaysian businesses.
• "User", "Buyer", or "Supplier" refers to any verified business entity registered on the Platform to manage invoices, reconcile payments, and build a behavioural credit profile.
• "Payment Gateway" refers to licensed third-party payment processors integrated into the Platform to facilitate direct fund transfers.

2. NATURE OF ARVIA'S SERVICES

2.1 Platform as a B2B Transaction Spine

Arvia provides infrastructure to automate reconciliation and invoice matching. Every transaction processed through the Platform becomes a verified, timestamped data point, systematically accumulating into a behavioural credit profile for the User.

2.2 Arvia Is Not a Payment Processor or Financial Institution

Arvia does not process, hold, receive, transmit, or settle any funds. All fund transfers are executed exclusively by our integrated Payment Gateways. Furthermore, Arvia is not a bank or a lender.

3. ELIGIBILITY AND ACCOUNT REGISTRATION

To register as a User, you must be a legally incorporated business entity or registered sole proprietor in Malaysia. Arvia is strictly a B2B platform; consumer accounts are not permitted. Users must provide accurate business registration details (SSM) to establish a verified financial identity on the network.

4. FEES AND BILLING

4.1 SaaS Subscriptions

Users are billed a monthly Software-as-a-Service (SaaS) subscription fee for network access, data analytics, and automation features, corresponding to their selected tier (e.g., Growth, Elite).

4.2 Transaction Processing Fees

A processing fee (ranging from 0.50% to 1.20%, depending on the active subscription tier) is applied to each invoice settled through the integrated Payment Gateway. This fee covers gateway execution costs and network data timestamping.

5. DATA USAGE AND CREDIT PROFILES

By transacting on the Arvia Network, you explicitly agree that your payment behaviour, settlement times, and reconciliation data will be utilized to generate a behavioural credit profile. This profile acts as your business's financial reputation on the network and may be shared with our licensed financing partners via API to facilitate credit access, as further detailed in our Privacy Policy.

6. DISCLAIMER OF WARRANTIES

Arvia provides the Platform on an "as is" and "as available" basis. Arvia does not guarantee that participation in the network will result in guaranteed financing or credit approvals from third-party financiers. Arvia expressly disclaims all implied warranties of merchantability and fitness for a particular purpose.

7. LIMITATION OF LIABILITY

To the fullest extent permitted by applicable Malaysian law, Arvia shall not be liable for any indirect, consequential, or special damages, including loss of profits, data, or business reputation arising from your use of the Platform or the Financing Marketplace. Arvia bears no liability for any acts, omissions, or errors committed by the integrated Payment Gateways.

8. GOVERNING LAW AND DISPUTE RESOLUTION

These Terms shall be governed by and construed in accordance with the laws of Malaysia. Any disputes arising from these Terms or your use of the Platform shall be subject to the exclusive jurisdiction of the courts of Malaysia.

END OF TERMS AND CONDITIONS

Arvia Tech Enterprise | [email protected]

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ARVIA TECH ENTERPRISE PRIVACY POLICY

(Pursuant to the Personal Data Protection Act 2010, as amended 2024)

Effective Date: 28/04/2026 | Last Updated: 28/04/2026 | Version: 1.0

Data Protection Officer: [email protected]

1. Identity and Contact Details of the Data Controller

Arvia Tech Enterprise (Company Registration No. 202603071201 (JR0188604-K)) ("Arvia", "we", "us", or "our") is a financial technology and software platform company incorporated and registered in Malaysia, with its registered office at Jalan PUJ 2/6, Taman Puncak Jalil, 43300 Seri Kembangan, Selangor, Malaysia.

Arvia operates a business-to-business (B2B) network acting as the transaction spine of Malaysia's B2B economy. Our platform serves as a networked Accounts Receivable (AR) and Accounts Payable (AP) pipeline, automating reconciliation and generating verified financial identities and credit profiles for Malaysian SMEs.

1.1 Privacy Compliance Contact

If you have any questions about this Policy or wish to exercise your data rights, please contact our privacy team at:

• Name: Arvia Privacy team
• Designation: Privacy Compliance Administrator
• Email: [email protected]
• Response time: Within twenty-one (21) working days of receipt of a verifiable written request

2. Scope and Application of This Policy

This Privacy Policy applies to all personal and business data collected, used, disclosed, stored, and processed by Arvia in connection with the following activities:

• Arvia's web platform, mobile application, and API services;
• All AR/AP file uploads, invoice matching, and reconciliation activities;
• All payments, auto-debits, and fund transfers facilitated through our integrated payment gateways;
• The generation of behavioural credit profiles and data sharing under our credit marketplace; and
• All communications and automated profiling carried out by Arvia's platform systems.

This policy applies to businesses transacting on the network, including Suppliers (Sellers), Buyers, and their authorised representatives.

3. Categories of Personal Data Collected

3.1 Data Collected from Network Participants (Buyers and Suppliers)

Upon registration or onboarding on the Arvia platform, the following categories of data are collected:

• Full legal name and NRIC or passport number of the authorised account holder/director;
• Business name and Company Registration Number (SSM);
• Business registered address, principal operating address, email, and telephone number;
• Bank account details (bank name, account number, account holder name) for direct fund transfers and mandate execution;
• Transaction and Invoice Data: Accounts Receivable and Accounts Payable files, including invoice amounts, counterparty details, and payment terms; and
• Payment Behaviour Data: Timestamps of payment clearing, settlement frequency, mandate status, and live cash flow analytics.

3.2 Data Collected Automatically

When you visit our platform, Arvia automatically collects technical and usage data: browser type, device type, operating system, IP address, approximate geographic location, and session cookies required for platform functionality and fraud prevention.

4. Purposes of Processing

Arvia processes data to transition dormant spreadsheets into live financial intelligence. Purposes include:

• Platform Operations & Reconciliation: To automate invoice matching, verify identities, manage accounts, and serve as the single source of truth for B2B transactions;
• Payment Execution: To instruct our integrated payment gateway partners (such as Airwallex or Curlec) to execute scheduled debits or direct fund transfers;
• Credit Profile Generation: To systematically accumulate payment behaviour into a verifiable credit profile that replaces collateral-based lending with behaviour-based creditworthiness;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions and abuse of the Arvia network;
• Legal Compliance: To fulfil obligations under the PDPA 2010, AMLA 2001, and tax legislation.

5. Lawful Basis for Processing

Arvia processes data on the following lawful bases:

• Consent: For the collection of bank account details, execution of payment mandates, and the explicit sharing of credit profiles with third-party financiers.
• Contractual necessity: For processing required to fulfil SaaS subscriptions, reconciliation services, and payment settlements on the network.
• Legal obligation: For compliance with Malaysian statutory obligations, including AMLA and tax record-keeping.
• Legitimate interests: For network security, fraud prevention, and system improvements.

6. Disclosure of Personal Data

Arvia operates as an integrated ecosystem and discloses data only to the minimum extent necessary:

• Payment Gateways: Licensed processors (e.g., Airwallex, Curlec) receive bank account details and payment instructions solely to execute fund transfers securely.
• Financial Institutions & Financiers: Through our credit and data API licensing model, we share anonymised or consent-based behavioural credit profiles with banks, insurers, and trade financiers to facilitate loan origination and invoice factoring on our financing marketplace.
• Network Counterparties: Invoice status and reconciliation updates are visible to verified buyers and suppliers involved in a specific transaction.
• Regulatory & Legal Authorities: Bank Negara Malaysia (BNM), the Personal Data Protection Commissioner, or law enforcement, as required by law.

7. Security Measures

Arvia ensures transaction data remains immutable and protected:

• Data in transit is encrypted using TLS 1.2 or higher. Sensitive data at rest is encrypted using AES-256 or equivalent standards.
• Arvia does not store full bank account credentials on its own servers; details are transmitted directly to our partners' PCI-DSS compliant infrastructure.
• Strict role-based access controls and independent security audits are routinely enforced.

8. Retention of Personal Data

Arvia retains data to preserve accumulated credit behavioural histories and meet legal requirements:

• Identity and transaction data: Seven (7) years from the last transaction, per tax and AMLA requirements.
• Payment behaviour data: Retained as long as the business remains active on the network to maintain its credit profile.
• Closed accounts: Deleted or anonymised ninety (90) days from closure, barring legal retention mandates.

9. Your Rights as a Data Subject

Under the PDPA (as amended 2024), you have the right to access, correct, limit processing, request data portability, and withdraw consent. Requests can be made to [email protected]. Please note that withdrawing consent for payment processing or data sharing may restrict access to network financing or automated reconciliation capabilities.

END OF PRIVACY POLICY

Arvia Tech Enterprise | Jalan PUJ 2/6, Taman Puncak Jalil, 43300 Seri Kembangan | [email protected]