Withdrawals, Complaints & Client Communications Policy

1. Purpose and Legal Status

This Withdrawals, Complaints & Client Communications Policy (the "Policy") sets out the principles and procedures governing:

  • client withdrawal requests;
  • handling of complaints and disputes; and
  • official client communications.

This Policy forms part of the group's consumer-protection and regulatory compliance framework and must be read together with the applicable customer agreements, Terms of Use, and Risk Disclosure Statement.

2. Scope and Applicable Entities

This Policy applies to services provided by:

  • Polar Tensor™ US LLC – U.S. and non-EU international clients
  • Polar Tensor™ Europe SP ZOO – EU-resident clients

Payment-related withdrawals may involve:

  • Polar MSB Inc. – fiat on- and off-ramp services

Execution technology providers do not process withdrawals or handle client funds.

3. Withdrawal Principles

3.1 Client Ownership and Control

  • Clients retain legal and economic ownership of their assets at all times.
  • Withdrawal authority rests exclusively with the licensed custodial entity applicable to the client's jurisdiction.

3.2 Execution-Layer Transfers

Where assets are temporarily transferred to an execution layer for technical trade execution:

  • such transfers do not affect client ownership;
  • assets remain withdrawable subject to completion of in-flight execution processes; and
  • no entity other than the licensed custodian may approve or deny withdrawals.

4. Withdrawal Requests

4.1 Initiation

Withdrawal requests must be submitted through the official platform or interface provided by the applicable licensed entity.

4.2 Processing

Withdrawals are processed in accordance with:

  • applicable customer agreements;
  • regulatory requirements;
  • AML/CFT and sanctions obligations; and
  • operational security controls.

Processing times may vary depending on:

  • blockchain network conditions;
  • payment rails;
  • verification or compliance checks; and
  • operational constraints.

No guarantee is provided as to processing speed.

5. Temporary Restrictions

Withdrawals may be temporarily delayed or restricted where required to:

  • comply with legal or regulatory obligations;
  • complete mandatory security or compliance checks;
  • prevent fraud or unauthorised access; or
  • address technical issues affecting execution or settlement.

Any such restriction is applied only to the extent reasonably necessary and lifted once the relevant issue is resolved.

6. Fees and Charges

Any fees applicable to withdrawals or payment processing are:

  • disclosed in advance through applicable fee schedules; and
  • applied in accordance with contractual terms.

Network or third-party fees may apply and are outside the control of the group.

7. Complaints Handling

7.1 Right to Complain

Clients may submit complaints relating to services, execution, custody, payments, or communications.

7.2 Submission

Complaints must be submitted via the official contact channels published on the relevant website or within the client portal.

7.3 Handling Process

Complaints are:

  • acknowledged within a reasonable timeframe;
  • reviewed impartially and diligently; and
  • addressed in accordance with applicable law and regulatory expectations.

8. Resolution and Escalation

Where a complaint cannot be resolved immediately:

  • further investigation may be conducted;
  • additional information may be requested; and
  • the client will be informed of the outcome once available.

EU clients retain the right to escalate complaints to competent supervisory or consumer-protection authorities in accordance with applicable law.

9. Client Communications

Official communications relating to:

  • withdrawals;
  • complaints;
  • compliance matters; or
  • service updates

are issued through authorised channels only.

The group does not accept responsibility for communications transmitted through unofficial or unauthorised channels.

10. No Waiver of Legal Rights

Nothing in this Policy limits or excludes rights afforded to clients under mandatory consumer-protection or financial-services laws.

11. Amendments

This Policy may be updated from time to time to reflect changes in law, regulation, or operational practices.

The most current version will be made available on the relevant websites.