REFUND POLICY – SUNIO

Effective Date: 01st of September 2026

This Refund Policy sets out the conditions under which refunds may be provided for services purchased through a Sunio website, the Sunio Client Portal or otherwise directly from Sunio.

By purchasing a service, you acknowledge and agree to this Refund Policy.

This Policy should be read together with the applicable Sunio Terms & Conditions and the description of the purchased service.

1. General Refund Conditions

1.1. No Refund After Service Commencement

Once provision of a service has commenced, or the service has been used, the payment is generally non-refundable.

A service may be considered commenced when Sunio has begun any material activity required for providing it, including:

• onboarding;

• reviewing the order or submitted information;

• compliance or eligibility checks;

• preparing applications or documents;

• preparing an accounting, tax, registration or other service;

• communicating with authorities or third parties in connection with the service;

• incurring third-party costs; or

• otherwise beginning execution of the ordered service.

For services ordered through the Client Portal, placing the order alone does not necessarily determine whether the service has commenced. The actual work performed and costs incurred will be taken into account.

1.2. Refunds Where the Client Cannot Be Onboarded

If you purchase a service but Sunio determines during onboarding or compliance review that the service cannot be provided because the Client, business activity, jurisdiction or other relevant circumstances fall outside Sunio’s accepted criteria, Sunio will refund 95% of the amount paid.

The remaining 5% is retained as an administrative and processing charge for the onboarding, payment-processing and compliance work already undertaken.

This may apply, for example, to:

• unsupported business models;

• unsupported countries or jurisdictions;

• regulatory restrictions;

• compliance restrictions;

• sanctions or anti-money laundering concerns; or

• other eligibility conditions published or otherwise communicated by Sunio.

1.3. Unsupported Business Models, Countries or Other Conditions

The same refund rule in section 1.2 applies where a service cannot be provided because the Client’s business model, country or other relevant circumstances are not supported by Sunio.

Where Sunio has already incurred non-refundable external charges or public fees, those amounts may also be deducted in accordance with section 4.3.

1.4. Client Responsibility for Eligibility Information

Clients are responsible for providing complete and accurate information before and during onboarding.

Sunio’s preliminary website information or automated eligibility indications do not constitute final compliance approval.

Final eligibility may depend on the information and documents obtained during onboarding, KYC or KYB review.

2. Special Conditions for Company Registration Services

2.1. Failure to Complete the Registration Process

If you purchase assistance with registering an Estonian private limited company (OÜ) or non-profit organisation (MTÜ) but fail to:

• provide required information;

• provide required documents;

• complete identification or compliance requirements;

• sign required documentation; or

• otherwise complete steps required from you,

you are not entitled to a refund after Sunio has commenced providing the registration service.

The Client remains bound by the applicable service agreement until the company is registered or the service relationship is otherwise terminated in accordance with the Terms & Conditions.

2.2. State and Third-Party Fees

State fees, notary fees, registry fees, apostille fees, courier fees and other third-party charges already incurred in connection with the registration process are non-refundable unless the relevant third party refunds them to Sunio.

3. Services Ordered Through the Client Portal

3.1. Additional Services

The Client Portal may allow the Client to order additional services and pay for them through Stripe or another payment provider.

The price, scope, included service time and other material terms displayed when the order is placed apply to that order.

3.2. Cancellation Before Work Begins

If the Client requests cancellation before Sunio has commenced the service and before Sunio has incurred any non-refundable third-party costs, Sunio may approve a full refund.

Where payment-processing or other unavoidable third-party costs have already been incurred, these may be deducted where applicable.

3.3. Cancellation After Work Begins

Once Sunio has started onboarding, processing or otherwise providing the ordered service, the payment is non-refundable except where this Refund Policy or mandatory law provides otherwise.

4. Subscription-Based Services

4.1. Cancellation

Recurring services may be cancelled at any time by contacting support@sunio.ee or, where the functionality is made available, through the Client Portal or associated billing environment.

Unless otherwise stated for a particular service, cancellation becomes effective from the beginning of the next applicable billing period.

Amounts already charged for the current billing period are not refunded merely because the Client chooses not to use the service for the remainder of that period.

4.2. Discontinued Services

If Sunio discontinues a service plan and the Client does not accept the closest available replacement plan, the Client may request a proportionate refund of any prepaid unused service period where applicable.

If the Client continues using the replacement service after the applicable notification period, this will be considered acceptance of the replacement plan and no refund will be due solely because of the plan change.

5. Processing Refunds

5.1. Refund Request Timeframe

Refund requests should be submitted as soon as reasonably possible and, in any event, within 30 days of the original purchase, unless mandatory law requires otherwise.

Submitting a refund request does not itself create an entitlement to a refund. Eligibility is determined under this Refund Policy.

5.2. Refund Method and Processing Time

Approved refunds will normally be returned using the original payment method.

Where the original payment method cannot reasonably be used, Sunio may agree another refund method with the Client.

After Sunio has initiated an approved refund, it may take approximately 7–14 business days for the refund to appear, depending on the payment provider and financial institution.

5.3. Non-Refundable Costs

Unless otherwise agreed or required by law, the following amounts are non-refundable once incurred:

• state fees;

• registry fees;

• notary fees;

• apostille fees;

• government charges;

• courier or delivery costs;

• third-party service fees; and

• other external costs incurred specifically for the purchased service.

6. How to Request a Refund

To request a refund, contact:

support@sunio.ee

Please provide:

1. your name and contact details;

2. the company name, where applicable;

3. the service purchased;

4. the date of purchase;

5. the reason for requesting the refund; and

6. any relevant supporting documents.

Sunio normally reviews refund requests and responds within 5 business days.

Additional information may be requested where necessary to assess the request.

7. Changes to This Refund Policy

Sunio may amend this Refund Policy from time to time.

The current version will be published on a Sunio website and may also be made available through the Client Portal.

Material changes affecting existing services may be communicated by email or through the Client Portal.

The version applicable to a specific one-time service order is generally the version in force when that order was placed, unless mandatory law or an expressly agreed amendment provides otherwise.

Contact

Questions regarding this Refund Policy may be sent to:

support@sunio.ee