Refund Policy

This Refund Policy is the canonical English version. Any other language version is provided for convenience only; the English version shall prevail in case of discrepancy.

Aligned with the T&C v5.0 | Publication Date: 26 August 2026

This Policy supersedes all prior versions of the refund policy published by Neom Triple A Information Technology LLC under the brand NEOM Funded.

Publisher: Neom Triple A Information Technology LLC Brand: NEOM Funded Address: The Binary by Omniyat, Office 2114, Business Bay, Dubai, UAE Refund enquiries: support@neomfunded.com Legal enquiries: legal@neomfunded.com Data-protection enquiries: privacy@neomfunded.com

Introduction

This Refund Policy (the “Policy”, also referenced on the Company’s website as the “Programme Fees & Refund Policy”) sets out the rights and obligations of Participants and Neom Triple A Information Technology LLC (the “Company” or “NEOM Funded”) with respect to (i) the categories of fees payable by Participants for access to NEOM Funded services (Evaluation Fees, Reset Fees, and Add-on Fees, as defined in §3 below), and (ii) requests for refund of such fees.

This Policy forms part of the complete contractual documentation of NEOM Funded, which includes the Terms and Conditions (the “T&C”) and the Privacy Policy (“PP”). In the event of any conflict between this Policy and the T&C, the T&C shall prevail, except where applicable mandatory consumer law grants the Participant broader rights, in which case the mandatory law applies.

This Policy covers exclusively the refund of fees paid by Participants for the Company’s products. It does not govern payments under the Benefit Program / Performance Rewards, which constitute a separate mechanism described in §16 of the T&C and in §12 of this Policy.

§1 Scope and Definitions

1.1 Scope

This Policy applies to all Participants who have purchased, or intend to purchase, the following products on neomfunded.com:

• Funded Evaluation Account pursuant to §1.5(j) of the T&C;
• Express Evaluation Account pursuant to §1.5(q) of the T&C;
• any other products in the Prop Accounts category pursuant to §1.5(o) of the T&C;
• Reset (account parameter reset), Add-on (additional features), and other related paid services offered on neomfunded.com.

This Policy applies regardless of the Participant’s country of residence; the separate provisions of §§5–9 contain specific carve-outs for particular jurisdictions in which mandatory consumer legislation grants the Participant broader rights.

1.2 Definitions

For the purposes of this Policy, the following terms have the meanings set out below (unless otherwise defined in the T&C):

• Evaluation Fee — the monetary amount paid by the Participant to gain access to a Funded Evaluation Account or Express Evaluation Account. The Evaluation Fee comprises the Account Price (as defined in §1.5(aa) of the T&C) and any subsequent Reset Fees. Throughout this Policy, “Evaluation Fee” and “Account Price” are used interchangeably to designate the initial monetary amount paid for access to the account, save that “Account Price” is used where the T&C so specifies (in particular in §14.4 and §6.4.1 of the T&C).
• Reset Fee — the fee for re-launching an evaluation account following a breach of trading parameters or a voluntary reset by the Participant.
• Add-on Fee — the fee for optional paid additions to an account, offered at the point of purchase or subsequently.
• Refund Period — the period during which the Participant may submit a refund request pursuant to applicable law or this Policy.
• Withdrawal Period — the fourteen (14) calendar-day period during which consumers under applicable consumer-rights legislation are entitled to withdraw from a distance contract without giving a reason (see §§5–6 below).
• Performance Reward / Benefit Program — payments made by the Company pursuant to §16 of the T&C in recognition of the Participant’s simulated-trading results. These payments are NOT refunds and are governed by §12 of this Policy.
• Clawback — the Company’s right to demand repayment of a Crystallised Benefit Program Amount paid to the Participant where violations are subsequently discovered, pursuant to §16.9 of the T&C. This mechanism operates in the direction opposite to a refund and applies exclusively to Benefit Program payments, not to Evaluation Fees.
• Set-off — the Company’s right to offset amounts owed to it by the Participant, including recovered Account Prices reversed through chargebacks, against the Crystallised Benefit Program Amount pursuant to §16.10 of the T&C.
• Delivery of Credentials — the transmission to the Participant of the login, password, and access parameters for a Funded Evaluation Account or Express Evaluation Account by email or through the personal account dashboard.

§2 Nature of the Product

2.1 Character of NEOM Funded Services

NEOM Funded provides exclusively simulated trading-skill assessment services and educational products. Understanding the legal nature of the products purchased is essential to the assessment of refund rights.

Funded Evaluation Account (§1.5(j) of the T&C) is a simulated-performance account with a virtual balance allocated to a Participant who has successfully completed the Evaluation Phase. A Funded Evaluation Account:

• is not a real brokerage account;
• does not involve the deposit of real trading capital by the Company or the Participant;
• does not grant the Participant any proprietary rights or control rights over real funds;
• does not constitute access to regulated investment or brokerage services.

Express Evaluation Account (§1.5(q) of the T&C) is a single-phase Funded Evaluation Account product by which the Participant gains access to the funded-account stage upon completing a single set of evaluation tasks, without a separate preceding verification phase. The Express Evaluation Account is a variant of the Funded Evaluation Account and is subject to the same rules regarding simulated character, the same Benefit Program rules (§16 of the T&C), and the same provisions on termination, suspension, and Clawback. Any references in prior marketing materials to “Instant Funded” or “Instant Funded Account” shall be construed as references to the Express Evaluation Account.

2.2 Absence of Financial-Instrument Status

The services of NEOM Funded:

• do not constitute an investment product and do not include investment services within the meaning of Directive 2014/65/EU (MiFID II) (eur-lex.europa.eu), Art. 4(1)(15);
• do not constitute a financial instrument within the meaning of Annex I Section C of MiFID II;
• do not constitute a deposit or guaranteed investment product;
• do not constitute a regulated investment service in any jurisdiction of the Participant’s residence.

The purchase of an Evaluation Fee represents payment for access to an educational and simulation platform for skills assessment — not for a financial service or investment product. This characterisation is material to the classification of the product under applicable law, including the Spanish Real Decreto Legislativo 1/2007, de 16 de noviembre (TRLGDCU) (boe.es) and Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights (‘CRD’).

2.3 Cross-Reference to the T&C

A full description of the legal nature of the services is contained in §3.7 of the T&C, and capitalised terms used in this Policy are defined in §1.5 of the T&C. The Participant confirms that they have read those provisions before purchasing.

§3 Pre-Purchase Opportunity to Assess the Product (Try Before You Buy)

3.1 Demo Account

The Company provides Participants with a free demo account (Demo Account), accessible before any purchase is made on neomfunded.com. The Demo Account enables the Participant to familiarise themselves with:

• the trading platform interface (MetaTrader 5 or TradeLocker in the Approved Build version pursuant to §1.5(w) of the T&C);
• the trading conditions and simulation parameters;
• the risk-management rules applied during assessment;
• the structure of the Evaluation Phase and its target metrics.

3.2 Differences Between Demo Conditions and Paid Evaluation

The Company discloses the following material circumstance: the trading conditions of the Demo Account may differ from those of the paid Funded Evaluation Account or Express Evaluation Account in the following respects: spreads, margin levels, available instruments, maximum drawdown rules, and other parameters published by the Company on neomfunded.com as at the date of the relevant purchase. Current trading conditions for the paid evaluation are published on the product page at neomfunded.com and, where applicable, in the Plan Specification, which prevails in the event of any inconsistency with informational content.

3.3 Significance of Demo Account Availability

The availability of a free Demo Account is provided by the Company as a transparency and consumer-information measure to enable Participants to assess the product before purchase. The Demo Account is independent of, and does not form part of, the legal test for the digital-content withdrawal exemption under Article 16(m) of Directive 2011/83/EU, which is governed exclusively by the cumulative conditions set out in §5.2 of this Policy (performance commencement, prior express consent, and acknowledgement of loss of the right of withdrawal under Article 8(7) of Directive 2011/83/EU).

For the avoidance of doubt:

1. the availability of a Demo Account does not, of itself, trigger or extinguish any withdrawal right;
2. the unavailability or malfunction of a Demo Account does not, of itself, suspend or invalidate the Article 16(m) exemption where the Article 8(7) conditions are independently satisfied; and
3. the Demo Account is offered as a pre-purchase information tool consistent with the Company’s obligations under Article 6 of Directive 2011/83/EU (information requirements for distance and off-premises contracts) and Articles 97–98 of the Spanish Texto Refundido de la Ley General para la Defensa de los Consumidores y Usuarios.

Nevertheless, the availability of a Demo Account does not limit the mandatory consumer rights applicable pursuant to §§5–9 of this Policy.

§4 Standard Refund Position

4.1 General Rule

The Evaluation Fee, Reset Fee, and Add-on Fee are non-refundable from the moment of Delivery of Credentials for the relevant account to the Participant, since the Company commences performance of the digital service from that point. This general rule is based on the following: (i) the product is digital and immediately usable upon Delivery of Credentials; (ii) from the moment of Delivery of Credentials the Company incurs operational costs for infrastructure maintenance, platform operation, account monitoring, and support; (iii) the Participant had the opportunity to assess the product via a free Demo Account before making a purchase, this opportunity being offered as a pre-purchase information measure under Article 6 of Directive 2011/83/EU and not forming part of the Article 16(m) digital-content exemption test set out in §5.2.

4.2 Exceptions to the General Rule

The general non-refund rule does not apply in the following circumstances:

1. Mandatory consumer rights. To the extent that applicable mandatory consumer law (§§5–9 below) grants the Participant a right to a refund or a right to withdraw from the contract, the Company shall honour such rights in full. Nothing in this Policy limits or excludes any rights that cannot be limited under applicable mandatory consumer legislation.
2. Technical failure on the Company’s side. Where, as a result of a technical failure or other disruption attributable to the Company, the Participant is denied access to the paid account for seven (7) or more consecutive business days without the Company providing a resolution or equivalent replacement, the Participant may submit a reasoned refund or account-replacement request. The Company shall review such a request in accordance with the procedure in §10 of this Policy.
3. Billing error. Where a documented error in the billing process has occurred — including duplicate charges, incorrect-amount charges, or an unauthorised transaction not initiated by the Participant — the Company shall refund the excess or erroneously charged amount in full.
4. Material discrepancy between offer and product. Where the product actually provided materially differs from the public offer in force on the date of purchase, as evidenced by objective evidence, the Participant may submit a refund or product-replacement request. Minor discrepancies in trading-platform parameters that do not affect the ability to complete the evaluation are not considered material within the meaning of this sub-clause.
5. KYC verification. Where the Company determines, after purchase, that the Participant cannot complete verification for reasons not attributable to fraud, misrepresentation, or material breach by the Participant, and the Participant has not materially used the services within the meaning of §14.8(b) of the T&C, the Company shall refund the Account Price within thirty (30) days of the Company’s determination, in accordance with §6.4.1 of the T&C.
6. Company termination for convenience. Where the Company terminates the Participant's Account for convenience under §14.4 of the T&C (that is, for a reason other than a Participant breach falling under §14.3 of the T&C), the Company shall refund the Account Price paid for the affected Account as follows: (i) one hundred per cent (100%) where the Account is at the Evaluation Phase stage, or is an Express Evaluation Account before completion of the single-stage objectives published in the applicable Plan Specification, at the effective date of termination; (ii) fifty per cent (50%) where the Account is at the funded stage of a Funded Evaluation Account at the effective date of termination and no Reward Cycle has yet been crystallised under §16.1 of the T&C on that Account; (iii) no Account Price refund is due where at least one Reward Cycle has crystallised under §16.1 of the T&C on the affected Account, without prejudice to payment of any earned but unpaid Performance Rewards. The Company shall pay the refund within thirty (30) days of the effective date of termination. This entitlement is additional to, and does not derogate from, any statutory refund right of the Participant under §§5–9 of this Policy or under mandatory consumer-protection law of the Participant's country of habitual residence.

4.3 Promotions

The terms of Promotions pursuant to §10 of the T&C may establish specific refund conditions, including a “refund-on-success” mechanism (refund of the fee upon successful completion of the evaluation). Such terms apply exclusively to accounts purchased under the relevant Promotion and do not modify the general refund position established by this §4.

§5 Consumer Rights — European Union, United Kingdom, and EEA

5.1 Right of Withdrawal under Directive 2011/83/EU, the UK CCRs 2013, and EEA transpositions

Where the Participant is a Consumer within the meaning of §1.5(dd) of the T&C and is a resident of a Member State of the European Union, the United Kingdom, or an EEA EFTA State (Iceland, Liechtenstein, or Norway), the Participant has the right to withdraw from a distance contract without giving any reason within fourteen (14) calendar days from the date on which the contract is concluded, pursuant to Article 9(1) of Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights (‘CRD’), the equivalent provisions of the United Kingdom Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, or the national law of the relevant EEA EFTA State transposing Directive 2011/83/EU pursuant to Annex XIX to the Agreement on the European Economic Area.

To exercise the right of withdrawal, the Participant must notify the Company by means of an unequivocal statement sent to legal@neomfunded.com before the expiry of the Withdrawal Period. The Participant may use the Model Withdrawal Form (Annex A to the T&C) but is not obliged to do so.

5.2 Digital-Content Exemption — Article 16(m)

Pursuant to Article 16(m) of Directive 2011/83/EU, read together with Article 8(7) of that Directive (see also Directive (EU) 2019/770 on digital content and digital services), the right of withdrawal does not apply to the supply of digital content not provided on a tangible medium if: (i) performance has begun with the consumer’s prior express consent; and (ii) the consumer has acknowledged that they thereby lose the right of withdrawal; and (iii) the Company has provided confirmation of the contract in accordance with Article 7(2) and Article 8(7) of Directive 2011/83/EU.

COMPANY POSITION: upon checkout for any paid Funded Evaluation Account or Express Evaluation Account, the Participant is presented with a Checkout Consent Architecture consisting of four (4) mandatory acknowledgement checkboxes (in accordance with §14.8(c) of the T&C), each separate, unticked by default, and displayed in plain language:

(A) Legal Documents: “I agree to the Terms & Conditions and Privacy Policy.”

(B) Product Nature: “I acknowledge the Risk Disclosure and understand this is a simulated-account service.”

(C) Eligibility: “I am of legal age and not resident in a Restricted Country listed in the Terms.”

(D) Digital Content Acknowledgement (displayed in a visually distinct block): “I expressly request immediate access and acknowledge that I will lose my right of withdrawal under Article 16(m) of Directive 2011/83/EU when performance begins — the earlier of (i) my first simulated trade, or (ii) substantive content consumption per §14.8(g).”

The payment button on the checkout interface remains disabled and non-clickable until all four mandatory checkboxes above have been affirmatively ticked by the Participant. Optional consents that are not necessary for the conclusion or performance of this Agreement (including consent to receive marketing communications) may be presented separately in the checkout flow, unticked by default, clearly labelled as optional, and shall not condition the payment button, in accordance with Article 7(4) of Regulation (EU) 2016/679 (GDPR) as interpreted in Case C-673/17 Planet49 and Article 22 of Directive 2011/83/EU. Full checkout logging, prohibited-practices rules (including no pre-ticking and no bundling of the Digital Content Acknowledgement with other consents), and record-retention obligations are set out in §14.8(c)(iv)–(v) of the T&C and apply in full to this Policy. If a court of competent jurisdiction, a competent regulator, a payment service provider, or any other competent authority nevertheless determines, in respect of a specific transaction, that the acknowledgement under checkbox (D) was not effectively obtained, the defensive savings clause under §14.8(d) of the T&C applies: the Consumer's right of withdrawal remains exercisable for the full 14-day Withdrawal Period under Article 9(1) of Directive 2011/83/EU regardless of the commencement of performance, and refunds are processed under §5.4(b)(ii) of this Policy.

5.3 Exemption for Fully Performed Services — Article 16(a)

Pursuant to Article 16(a) of Directive 2011/83/EU, the right of withdrawal does not apply to service contracts where the service has been fully performed before the expiry of the withdrawal period and performance commenced with the consumer’s prior express consent, and the consumer acknowledged that they would lose their right of withdrawal once the contract had been fully performed. Delivery of Credentials constitutes commencement of performance of the service for the purposes of Article 16(a).

5.4 Refund Calculation Upon Valid Withdrawal

(a) No performance trigger — 100% refund. Where the Consumer exercises the right of withdrawal within the Withdrawal Period and neither performance trigger in §14.8(b) of the T&C has occurred at the moment of the withdrawal notice (that is, no simulated trade has been executed on any Account associated with the Participant, and no substantive consumption of educational content within the meaning of §14.8(g) of the T&C has occurred), the Company shall refund one hundred per cent (100%) of amounts paid by the Consumer within fourteen (14) days of receipt of the withdrawal notice, using the same payment method as the original transaction, save where the Consumer expressly agrees otherwise. For the avoidance of doubt, mere availability of, login to, or navigation through the Services interface does not constitute services ‘provided’ within the meaning of Article 14(3) of Directive 2011/83/EU and Case C-641/19 PE Digital.

(b) Partial performance — three scenarios.

(b)(i) Fallback pro-rata — service-contract requalification only. This sub-paragraph applies exclusively in the alternative scenario where a court of competent jurisdiction, a competent regulator, a payment service provider, or any other competent authority determines that the Services do not qualify as digital content or digital services within the meaning of Article 16(m) of Directive 2011/83/EU, but instead qualify as a service contract within the meaning of Article 14(3) of that Directive. In such alternative scenario, and only in such alternative scenario, where the Consumer has validly exercised the right of withdrawal within the Withdrawal Period, the acknowledgement under §14.8(b) and §14.8(c) of the T&C is otherwise valid, and a performance trigger under §14.8(b) of the T&C has occurred such that the Services have been only partially performed at the moment of withdrawal, the Consumer shall pay the Company an amount which is in proportion to what has actually been provided until the moment of withdrawal, in accordance with the principles set out by the Court of Justice of the European Union in Case C-641/19 PE Digital and Article 14(3) of Directive 2011/83/EU. The amount shall be calculated by reference to the actual services rendered (not on a flat-rate or ‘fair value’ basis). The Company shall refund the remaining amount within fourteen (14) days using the same payment method as the original transaction, save where the Consumer expressly agrees otherwise. This sub-paragraph mirrors §14.8(e)(i) of the T&C. For the avoidance of doubt, in the primary qualification of the Services as digital content or digital services under Article 16(m), pro-rata refund does not apply — see sub-paragraph (b)(iii) below.

(b)(ii) Acknowledgement invalidated — statutory zero-cost outcome under Article 14(4)(b). Where the acknowledgement under §14.8(b) and §14.8(c) of the T&C is determined by a court of competent jurisdiction, a competent regulator, a payment service provider, or any other competent authority not to have been effectively obtained (that is, the trigger under §14.8(d) of the T&C applies in respect of the specific transaction), and the Consumer exercises the right of withdrawal within the Withdrawal Period, the Consumer shall bear no cost for the supply of digital content or digital services performed prior to the exercise of withdrawal, in accordance with Article 14(4)(b) of Directive 2011/83/EU. The Company shall refund one hundred per cent (100%) of all payments received from the Consumer within fourteen (14) days of receipt of the withdrawal notice, using the same payment method as the original transaction, save where the Consumer expressly agrees otherwise. Pro-rata calculation under Case C-641/19 PE Digital does not apply where the acknowledgement itself has been invalidated, because the conditions under Article 14(4)(b)(i) to (iii) of Directive 2011/83/EU are alternative and any one failed condition triggers the zero-cost outcome.

(b)(iii) Primary scenario — Art 16(m) withdrawal extinguished. Where the acknowledgement under §14.8(b) and §14.8(c) of the T&C is valid and enforceable, and a performance trigger under §14.8(b) of the T&C has occurred (that is, the earlier of (i) the execution of any simulated trade on any Account associated with the Participant, or (ii) substantive consumption of educational content within the meaning of §14.8(g) of the T&C), the Consumer's right of withdrawal under §14.8(a) of the T&C is extinguished at the moment performance began, pursuant to Article 16(m) of Directive 2011/83/EU, read together with Article 8(7) of that Directive. In this primary scenario, no refund is payable under this §5.4, and any withdrawal notice submitted after the performance trigger shall be rejected as inadmissible under §14.8(h) of the T&C, subject only to sub-paragraphs (b)(i) (requalification fallback) and (b)(ii) (acknowledgement invalidated) above. This sub-paragraph mirrors §14.8(b), the chapeau of §14.8(e)(i), and §14.8(h) of the T&C.

(c) UK residents — Regulation 36 UK CCRs. For Consumers resident in the United Kingdom, Regulation 36 of the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (the ‘UK CCRs’) applies to sub-paragraph (b)(i) above in respect of the calculation of any proportionate amount payable to the Company; proportionality is calculated in accordance with Regulation 36(4). Where sub-paragraph (b)(ii) applies (acknowledgement invalidated), Regulation 36 of the UK CCRs likewise operates to relieve the Consumer of any cost obligation for services performed prior to withdrawal, consistently with Regulation 36(1) and Regulation 37 of the UK CCRs.

5.5 Spain — TRLGDCU

For Participants resident in Spain, Article 103(m) of Real Decreto Legislativo 1/2007, de 16 de noviembre (TRLGDCU) (the Spanish transposition of Article 16(m) of the CRD — digital-content exemption) and Article 98.7 of TRLGDCU (the Spanish transposition of Article 8(7) of the CRD — durable-medium confirmation) apply, providing the same 14-day withdrawal period and the same exemptions for digital content as Articles 9 and 16(a)+(m) of Directive 2011/83/EU as transposed into Spanish law. The express-consent checkout flow described in §5.2 satisfies the requirements of Spanish law when correctly implemented. The simulated educational product falls within the digital-service exemption under TRLGDCU upon correct acknowledgement by the Participant.

For resolution of consumer disputes, Spanish Participants may contact the Junta Arbitral de Consumo (Consumer Arbitration Committee) or the Organización de Consumidores y Usuarios (OCU — www.ocu.org) as primary recourse. Recourse to the Comisión Nacional del Mercado de Valores (CNMV — www.cnmv.es) applies only if the dispute establishes that the product falls within CNMV regulatory scope, which the Company contests given the educational and simulation nature of its services.

5.6 Procedure for Submitting a Withdrawal Request (EU)

To exercise the right of withdrawal under Directive 2011/83/EU, the Participant shall send an unequivocal written statement to legal@neomfunded.com before the expiry of the 14-day Withdrawal Period. The Company shall acknowledge receipt and process the refund within fourteen (14) days using the same payment method as the original transaction.

§6 Consumer Rights — United Kingdom

6.1 Applicable Law

For Participants resident in the United Kingdom, The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (SI 2013/3134) (‘UK CCRs’) apply, granting consumers in respect of distance contracts the right to cancel within fourteen (14) calendar days (Regulations 29–31 of the UK CCRs).

6.2 Digital-Content Exemption (Regulation 37 of the UK CCRs)

Pursuant to Regulation 37 of the UK CCRs, the right to cancel does not apply to digital content not provided on a tangible medium where: (i) performance has begun with the consumer’s prior express consent; and (ii) the consumer has acknowledged that they thereby lose the right to cancel.

The express-consent checkout flow described in §5.2 of this Policy applies equally to UK-resident Participants.

6.3 Rights After the Withdrawal Period

After the expiry of the 14-day cancellation period, refund rights of UK-resident Participants are governed by §4 of this Policy. Nothing in this Policy excludes rights provided by mandatory consumer legislation of the United Kingdom, including the Consumer Rights Act 2015 (legislation.gov.uk).

6.4 Escalation Routes (UK)

UK-resident Participants may seek advice and assistance from:

• Citizens Advice (www.citizensadvice.org.uk);
• Trading Standards (via local authorities);
• the Information Commissioner’s Office (ICO — ico.org.uk) for personal-data matters.

§7 Consumer Rights — UAE

7.1 Applicable Law

For Participants qualifying as consumers under UAE law, UAE Federal Law No. (15) of 2020 on Consumer Protection (‘UAE Consumer Protection Law’) and Cabinet Decision No. 66 of 2023 on the Implementing Regulation of Federal Law No. (15) of 2020 apply.

7.2 Refund Rights under UAE Law

UAE Federal Law No. (15) of 2020 on Consumer Protection establishes consumer rights to safe, quality goods and services. In respect of digital services where performance has commenced with the consumer’s consent, the UAE Consumer Protection Law does not provide for an automatic right to a refund analogous to the European 14-day Withdrawal Period; however:

1. where the service provided materially differs from that described, the consumer may seek redress pursuant to applicable UAE law;
2. billing errors, documented technical failures, and instances of inability to use a purchased service for reasons outside the consumer’s control are to be addressed in accordance with §4.2 of this Policy.

7.3 Escalation Routes (UAE)

UAE-resident Participants may contact the UAE Ministry of Economy via the consumerrights.ae portal in the event of unresolved disputes with a service provider. The Company cooperates with competent authorities within the framework of applicable UAE law.

§8 Consumer Rights — United States

8.1 Absence of a Federal Cooling-Off Period

Unlike the EU and the United Kingdom, the United States does not have a single federal law establishing a universal cooling-off period for online purchases. Refund rules for online purchases are regulated at the state level.

8.2 State-Level Rights

Where the law of a particular state grants consumers a cooling-off period or refund rights in respect of digital services, the Company shall comply with such rights. Participants resident in the following states (among others) should note potentially applicable provisions:

• California: California Business and Professions Code §17538 and the Consumer Legal Remedies Act;
• New York: New York Arts & Cultural Affairs Law §11.01 and general consumer-protection provisions;
• Illinois: Illinois Consumer Fraud and Deceptive Business Practices Act.

Participants from other states who believe that the law of their state grants them a refund right should send a request to legal@neomfunded.com specifying the applicable provision.

8.3 Regulatory Bodies (USA)

US-resident Participants may contact:

• the Federal Trade Commission (FTC — ftc.gov) regarding unfair or deceptive trade practices;
• the State Attorney General of their state;
• the Better Business Bureau (BBB — bbb.org) for out-of-court resolution.

§9 Other Jurisdictions

9.1 Principle of Mandatory-Law Priority

Where the Participant is resident in a jurisdiction not covered by §§5–8 of this Policy and mandatory consumer or other mandatory law of that jurisdiction grants the Participant broader rights in respect of refunds or withdrawal from contracts than those established by this Policy, the mandatory-law provisions shall apply to the extent that they exceed the provisions of this Policy.

9.2 Mechanism of Application

This Policy does not limit or exclude any rights of the Participant that cannot be limited under the mandatory law of their country of habitual residence. Where the Participant considers that the mandatory legislation of their jurisdiction grants them rights beyond the scope of this Policy, the Participant shall notify the Company at legal@neomfunded.com specifying the applicable provision, and the Company shall review such request on an individual basis.

9.3 Liability in Other Jurisdictions

Nothing in §16.13 of the T&C is modified by this §9. The mandatory consumer-law carve-outs provided by §16.13 of the T&C (mandatory consumer carve-out), together with §16.6(c) of the T&C (consumer carve-out on the minimum Performance Reward threshold) and §16.3(d) of the T&C (thirty (30) calendar-day maximum payment delay for consumer Participants), remain in full force.

§10 Refund Request Procedure

Scope and priority of statutory timelines. This §10 sets out the standard procedure and timelines for refund requests submitted under §4.2(b), §4.2(c), §4.2(d), §4.2(e), and §4.2(f) of this Policy. Where a refund request arises from the exercise of a statutory right of withdrawal, cancellation, or refund under §5 (European Union), §6 (United Kingdom), §7 (Switzerland), §8 (United States), or §9 (Other Jurisdictions), the substantive and procedural timelines set out in those sections prevail over the timelines in this §10 to the extent of any inconsistency. In particular, for Consumers resident in the European Union exercising the right of withdrawal under §5, the Company shall refund all sums paid within fourteen (14) calendar days of receipt of the withdrawal notice, in accordance with Article 13(1) of Directive 2011/83/EU. The steps in §10.1 (Steps 1–3) apply to statutory refunds as the operational contact channel; the decision timeline in §10.1 (Step 4) and the payout timeline in §10.2 do not apply where they would extend a statutory refund period. Alternatively, a Consumer exercising withdrawal under §5 may submit the notice directly to legal@neomfunded.com in accordance with §5.6.

10.1 Steps for Submitting a Request

To have a refund request considered, the Participant must complete the following steps:

Step 1. Submit a request by email. The Participant shall send an email to support@neomfunded.com with the subject line: “Refund Request — [Account ID]”.

Step 2. Provide the required information. The request must include:

• the Account ID or order number;
• the date of purchase and the payment method used;
• the ground for the refund from among those set out in §4.2 or §§5–9 of this Policy;
• documentary evidence, where the ground relates to a technical failure, billing error, or material discrepancy between the product and its description;
• the Participant’s jurisdiction of residence — where relying on rights under §§5–9.

Step 3. Receive acknowledgement. The Company shall send an acknowledgement of receipt of the request within five (5) business days of receiving it.

Step 4. Review and decision. The Company shall issue a decision on the request within fourteen (14) business days from the date of receipt of the confirmed complete request. This period may be extended to thirty (30) business days in cases requiring further investigation (for example, where technical failures require infrastructure logging, or where legal matters require analysis of applicable law). The Company shall notify the Participant of any extension before the expiry of the initial 14-business-day period.

10.2 Method of Refund and Currency

Where a decision is made to grant the request, the refund shall be made:

• to the original payment instrument used at the time of purchase;
• in the original currency of the transaction;
• within seven (7) to fourteen (14) business days from the date of approval of the request.

In exceptional circumstances where a refund to the original payment method is technically impossible (for example, where a card has expired or a payment account has been closed), the Company shall agree an alternative method of refund with the Participant.

10.3 Status of Demo Accounts and Unpaid Accounts

This §10 applies exclusively to paid products. Free Demo Accounts are not subject to refund as no fee was paid for them.

10.4 Partial Refunds

Where the Participant has used a portion of the paid service prior to submitting a refund request, the Company may make a proportionate (partial) refund corresponding to the unused portion of the service, except where applicable mandatory law requires a full refund.

§11 Chargeback

11.1 Recommendation to Contact the Company First

Before initiating a chargeback procedure through their bank or payment operator, the Participant must notify the Company in accordance with §10 of this Policy and give the Company the opportunity to resolve the dispute directly. This requirement is based on the following: direct contact with the Company generally resolves the issue more quickly than a chargeback procedure through a payment operator, which may take up to 90 days. This provision is formulated in accordance with the requirements of Council Directive 93/13/EEC on unfair terms in consumer contracts and does not prevent the consumer from using legitimate payment-operator protection mechanisms.

11.2 Consequences of Initiating a Chargeback Without Prior Notification

Where the Participant initiates a chargeback procedure without prior notification to the Company in accordance with §10, the Company may suspend access to all of the Participant’s accounts for the duration of the payment operator’s review of the dispute. Such suspension is temporary pending resolution of the dispute and does not constitute final account closure.

11.3 Unwarranted Chargebacks

Where the payment operator’s review establishes that a chargeback was unwarranted (in particular, constituted fraud or was submitted in breach of contractual terms, where the service was in fact used and no ground for refund existed under §4.2 or §§5–9), the Company may:

1. apply to the Participant an administrative fee in a reasonable amount reflecting the Company’s documented costs of addressing the unwarranted chargeback (excluding legal representation fees for court proceedings unrelated to the administrative review);
2. close all of the Participant’s accounts and deny further access to the services.

The formulation of this §11.3 deliberately does not include a provision for “all legal fees”, as such formulation may be characterised as an unfair contractual term within the meaning of Article 3 of Council Directive 93/13/EEC. Any costs recovered by the Company must be reasonable, proportionate, and documented.

11.4 Interaction with §16.10 of the T&C (Set-off)

Where, at the time of initiation or resolution of a chargeback, a Crystallised Benefit Program Amount exists, the Company may apply Set-off in accordance with §16.10 of the T&C. Set-off under §16.10 constitutes a separate mechanism from a refund and does not give rise to any obligation on the Company’s part to refund an Evaluation Fee.

§12 Benefit Program Payments (Distinction from Refunds)

12.1 Fundamental Distinction

Performance Rewards and Benefit Program payments pursuant to §16 of the T&C are not refunds in any legal sense. This fundamental distinction has the following significance:

• Refund — the return of an Evaluation Fee or other charge paid by the Participant to the Company for access to a product. Refunds are the subject of this Policy.
• Performance Reward / Benefit Program — a payment by the Company to the Participant in recognition of the Participant’s results in a simulated trading environment. This payment is governed by §16 of the T&C and constitutes consideration under a separate mechanism.

12.2 Conditions for Benefit Program Payment

Benefit Program payments are subject to the framework of §16 of the T&C. In particular:

1. Crystallisation. A Benefit Program Amount crystallises upon satisfaction of the objective conditions in §16.1(a)–(d) and (f)–(g) of the T&C, including Good Standing (§16.1(a) of the T&C), exclusive use of Approved Builds (§16.1(b), §1.5(w) of the T&C), and completion of the Pre-Crystallisation Review (§16.4 of the T&C).
2. Payment timing. Payment of a Crystallised Benefit Program Amount is conditional on Operational Budget Availability (§16.3, §1.5(x) of the T&C), which affects only the timing of payment and does not affect crystallisation. Maximum-delay limits apply: thirty (30) calendar days for consumer Participants (§16.3(d) of the T&C) and one hundred twenty (120) calendar days for non-consumer Participants (§16.3(c) of the T&C).

Following payment, each Crystallised Benefit Program Amount remains subject to the post-crystallisation compliance review window in §16.2 of the T&C, which commences only after payment and does not delay or condition payment.

A Benefit Program payment is not conditional upon, and does not affect, the Participant’s right to a refund of the Evaluation Fee.

12.3 Clawback and Set-off — Not Refunds

The Clawback mechanism (§16.9 of the T&C) constitutes the Company’s right to demand repayment of a previously paid Crystallised Benefit Program Amount upon subsequent discovery of Participant violations. This is a mechanism operating in the Company’s favour and applicable exclusively to Benefit Program payments. Clawback is not related to any refund of the Evaluation Fee.

The Set-off mechanism (§16.10 of the T&C) enables the Company to offset amounts owed by the Participant, including Account Prices recovered through chargebacks, against the Crystallised Benefit Program Amount. Set-off is likewise not a refund.

12.4 “Refund-on-Success” Mechanism via Promotions

Certain Company Promotions provide for refund of the Evaluation Fee upon the Participant’s second successful Performance Reward request on the funded stage (“refund-on-success”). The refund is processed as a separate transfer, distinct from the second Performance Reward payout, and is triggered only upon explicit request by the Participant at or after the second-payout milestone (not auto-credited, not added to the second Performance Reward payout amount). This mechanism is not a Performance Reward within the meaning of §16 of the T&C and constitutes a separate contractual obligation of the Company arising exclusively under the specific Promotion. The terms of each such Promotion are published on neomfunded.com and are fixed for the account purchased under it, in accordance with §10 of the T&C. For the corresponding per-product parameter, see the Plan Specification (“Refund Policy” row for the relevant product).

§13 Amendments to this Policy and Contact Details

13.1 Notice of Amendments

The Company may amend this Policy in accordance with the amendments regime established by §1.3 of the T&C. In respect of material amendments to the Policy, the following rules apply:

1. The Company shall notify Participants of material amendments to the Policy by:
   • sending an email notification to the address provided by the Participant upon registration; and
   • posting a notice of the amendments on neomfunded.com,
   no less than thirty (30) days before the amendments take effect.
2. Amendments apply to purchases made on and from the Publication Date of the amendments. Purchases made before that date are subject to the version of the Policy in force at the time of the relevant purchase.
3. Continued use of the services after the amendments take effect constitutes acceptance of the updated Policy in respect of future purchases.

13.2 Immediately Effective Amendments

Amendments falling within §1.3(a) of the T&C (in particular, amendments for the purpose of preventing fraud, ensuring information security, complying with regulatory requirements, or satisfying AML/CTF obligations) take effect immediately without 30-day prior notice.

13.3 Contact Details

For all enquiries relating to this Policy:

Postal address for formal notices: Neom Triple A Information Technology LLC, The Binary by Omniyat, Office 2114, Business Bay, Dubai, UAE.

13.4 Version Archive

All previous versions of the Refund Policy are retained by the Company and are available on request at legal@neomfunded.com for the purpose of ensuring contractual certainty in respect of purchases made during the period of the relevant version.

Governing Law and Dispute Resolution

This Policy is governed by the law of the Emirate of Dubai and UAE federal law pursuant to §18.1 of the T&C, without prejudice to the mandatory consumer-law provisions of the Participant’s country of habitual residence applicable by virtue of Article 6 of Regulation (EC) No 593/2008 (Rome I). Disputes are resolved in accordance with §18 of the T&C (DIAC arbitration, Dubai), except where the mandatory consumer law of the applicable jurisdiction grants the Participant the right to bring proceedings before a court in their place of residence.

Refund Policy v5.0 | Neom Triple A Information Technology LLC (NEOM Funded) | Publication Date: 26 August 2026