Refund & Cancellation Policy

Overview

This Refund & Cancellation Policy explains how Centili Group Ltd. (trading as Centili, “we”, “us”, “our”) approaches refunds, billing errors, chargebacks and cancellations in connection with the services we provide. Centili operates a direct carrier-billing, mobile-payments and content-monetisation platform that connects merchants and digital content providers to mobile network operators (“operators”) across more than 280 carrier integrations.

Because of the role we play, it is important to understand the distinction between the business-to-business (“B2B”) services we supply directly to our merchant and operator customers, and the consumer-facing purchases that an end-user (a mobile subscriber) makes from a merchant and that we help facilitate. The two are governed differently, and this policy sets out which applies in each case.

This policy should be read together with our Terms of Service, Privacy Policy and Complaints & Dispute Resolution policy. Where there is a conflict between this policy and a signed commercial agreement with a customer, the signed agreement prevails for that customer.

Who this applies to

This policy addresses two distinct audiences:

• Business customers — merchants, content providers, aggregators and operators who contract with us for access to our platform, integrations and payment-facilitation services. Their refund and cancellation entitlements are primarily governed by their commercial agreement with us.
• End-users — individual mobile subscribers who purchase digital goods, content or services from a merchant where payment is collected through carrier billing or another payment method we facilitate. End-user refunds are, in most cases, governed by the policy of the merchant of record and/or the relevant operator, not by us directly.

If you are an end-user trying to obtain a refund for a charge that appeared on your mobile bill or prepaid balance, please read How end-users request refunds below.

Platform fees vs end-user purchases

There are two categories of payment in our ecosystem, and refunds work differently for each.

1. Platform fees and charges we invoice to business customers

These are amounts we charge our merchant, content-provider or operator customers directly — for example integration and onboarding fees, recurring platform or subscription fees, transaction or processing fees, and professional-services charges. Entitlement to a refund or credit for these amounts is governed by the customer's commercial agreement and order form with us. Unless that agreement states otherwise:

• Recurring platform and subscription fees are generally non-refundable once the relevant billing period has begun.
• One-off setup, integration and onboarding fees are non-refundable once work has commenced.
• Usage-based and per-transaction fees are charged in arrears for transactions actually processed and are not refundable except where they were charged in error (see Billing errors & duplicate charges).
• Where we are at fault for a service failure, the customer's remedies (including any service credits) are those set out in the applicable agreement and any service-level addendum.

2. End-user purchases we facilitate

When an end-user buys digital content or a service from a merchant and pays via carrier billing or another facilitated method, Centili typically acts as a payment facilitator and technical intermediary. In the great majority of cases:

• The merchant is the merchant of record and the seller of the digital goods or service.
• The operator collects the charge from the end-user (via the mobile bill or prepaid balance).
• Centili routes, authorises and settles the payment between those parties but is generally not the seller and does not hold the customer relationship for the underlying purchase.

As a result, the refund policy of the merchant of record and/or the operator governs end-user refunds, alongside the end-user's non-excludable statutory rights (see Your statutory rights). We will support a valid refund operationally — for example by reversing a settled transaction once the merchant or operator authorises it — but we do not unilaterally decide the merits of an end-user refund for goods or services we did not sell.

How end-users request refunds

If you are an end-user and you want a refund for a charge made through carrier billing or another method we facilitated, the fastest and correct route is almost always to contact the merchant you purchased from, or your mobile operator. They hold the seller relationship and the billing relationship respectively, and they are best placed to assess and action a refund.

Step 1 — Identify the merchant

Check the confirmation message, receipt, app or website where you made the purchase. The merchant's name usually also appears on the descriptor associated with the charge, in the service's help or support section, or in the message you received confirming the purchase or subscription.

Step 2 — Contact the merchant or operator

• Merchant: use the support, “help” or “contact us” channel on the merchant's service. Quote the date, amount and a description of what you bought.
• Operator: for queries about how the charge appeared on your bill or prepaid balance, or to block future charges, contact your mobile network operator's customer service.

Step 3 — If you cannot reach the merchant or operator

If you have tried the merchant and operator and cannot resolve the matter, you may contact us at support@centili.co.uk. While we are generally not the seller, we can help identify the merchant, confirm transaction details we hold, and pass the matter to the correct party. To help us locate the transaction, please provide:

• your mobile number (or a partial/masked version) and country;
• the approximate date and time of the charge;
• the amount charged and the currency;
• the name of the service, app or content as it appeared; and
• any transaction or reference number shown to you at the time.

Please do not include full payment-card details. We will only ask for information necessary to locate and investigate the transaction, and we handle it in line with our Privacy Policy.

Billing errors & duplicate charges

A billing error is a charge that should not have occurred or was for the wrong amount — for example a duplicate charge for a single purchase, a charge after a confirmed cancellation, a technical fault that resulted in an undelivered service still being billed, or an incorrect amount or currency.

We take genuine billing errors seriously. Where a billing error is confirmed, the affected charge will be refunded or credited in full to the party who bore it, without that party needing to rely on a discretionary refund. Our approach is:

• For end-users: raise the error with the merchant or operator first (see How end-users request refunds). If they confirm the error, the refund is actioned through the operator's billing system. We will support the reversal of the underlying transaction once authorised.
• For business customers: if you believe an invoice, platform fee or settlement amount is incorrect, contact us promptly (and in any event within the period specified in your agreement) so we can investigate. Confirmed errors are corrected by refund, credit note or adjustment to the next settlement, as appropriate.

Duplicate charges

Where a single purchase results in two or more identical charges due to a technical fault or repeated submission, the duplicate charge(s) will be refunded once verified against our transaction records. To investigate a suspected duplicate we will compare the transaction identifiers, timestamps and amounts in our logs against those reported.

Chargebacks & dispute handling

A chargeback (or its carrier-billing equivalent, such as an operator-initiated reversal or a regulator-mandated refund) occurs when an end-user disputes a charge directly with their bank, card scheme or operator rather than seeking a refund from the merchant. Because carrier-billed transactions are collected by operators, the dispute and reversal mechanisms are typically operated by the operator and are subject to the operator's and any applicable national regulator's rules.

How we handle disputes

• We cooperate with operators, merchants and, where relevant, payment schemes and regulators to investigate disputed transactions and provide the transaction evidence we hold (such as authorisation records and delivery confirmations).
• Where a dispute is upheld, the relevant amount is reversed through the operator or scheme, and any associated settlement adjustment is reflected in the responsible merchant's account in accordance with their agreement with us.
• Merchants are responsible for the legitimacy of their offers and for delivering what end-users pay for. Excessive chargeback, refund or dispute rates may trigger additional monitoring, reserves, holdbacks or suspension under the merchant's agreement and our Acceptable Use Policy.

We encourage end-users to seek a refund from the merchant or operator first, as this is usually faster than a formal dispute and avoids the costs and reversal fees that disputes can attract.

Subscription cancellations & renewals

Many services billed through our platform are recurring subscriptions that renew automatically until cancelled. The terms of a particular subscription — its price, billing frequency, free-trial conditions and renewal behaviour — are set by the merchant offering it and are disclosed to the end-user at the point of sign-up.

End-user subscriptions

• How to cancel: end-users can normally cancel a carrier-billed subscription through the merchant's service, or by following the operator's instructions (which often include sending a stop keyword by SMS or managing subscriptions in the operator's account portal).
• Effect of cancellation: cancellation stops future renewals. Unless the merchant's terms or applicable law provide otherwise, cancelling part-way through a paid period does not automatically refund the remainder of that period; access typically continues until the end of the period already paid for.
• Charges after cancellation: if you are charged after a confirmed cancellation, that is a billing error — see Billing errors & duplicate charges.

Business customer subscriptions

Platform and service subscriptions we provide to business customers may be cancelled in accordance with the notice periods and terms in the relevant agreement or order form. Unless that agreement states otherwise, fees for a period that has already begun are not refunded on cancellation, and cancellation takes effect at the end of the then-current term.

Your statutory rights

Nothing in this policy limits or excludes any rights you have under applicable law that cannot lawfully be limited or excluded. In particular, where an end-user is a consumer in the United Kingdom, this policy does not affect rights under the Consumer Rights Act 2015 and the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, including, where applicable:

• the right to digital content that is of satisfactory quality, fit for purpose and as described, and to a remedy (such as a repair, replacement or refund) where it is not;
• the right, where it applies, to cancel certain distance contracts within the statutory cancellation period — subject to the rules on digital content supplied with the consumer's consent before the end of that period; and
• the right not to be charged for goods or services not requested or not received.

These statutory rights are generally exercised against the seller (the merchant of record). Where you are a consumer and the relevant law gives you a remedy, that remedy is available regardless of anything in this policy. For business customers, statutory rights applicable to business contracts are likewise unaffected to the extent they cannot lawfully be excluded.

Processing times

Once a refund or reversal has been approved by the party responsible for it, the time it takes to reach the end-user or customer depends on the payment method and the systems involved, several of which are operated by third parties (operators, banks and schemes) and are outside our direct control.

These timeframes are indicative. We will action the parts of a refund within our control promptly once authorised; the final step of crediting the end-user is completed by the operator, issuer or provider on their own timescales.

How to contact us

For refund, billing or cancellation queries that you have been unable to resolve with the relevant merchant or operator, contact our support team at support@centili.co.uk. To help us respond quickly, please include the details listed in How end-users request refunds (for end-user charges) or your account and invoice references (for business customers).

If you are unhappy with how a refund or billing matter has been handled and wish to escalate it, you can raise a formal complaint under our Complaints & Dispute Resolution policy or write to us at complaints@centili.co.uk.

Changes to this policy

We may update this Refund & Cancellation Policy from time to time to reflect changes in our services, operator and merchant arrangements, or legal and regulatory requirements. The “Last updated” date at the top of this page shows when the latest version took effect. Material changes will be reflected here, and for business customers any change is also subject to the variation terms of the relevant agreement. Your statutory rights as a consumer are not affected by changes to this policy.

Contact

For questions about refunds, billing errors or cancellations, contact our support team at support@centili.co.uk. For complaints, contact complaints@centili.co.uk.

Centili Group Ltd. is registered in England and Wales. This policy is governed by the laws of England and Wales, and any disputes are subject to the exclusive jurisdiction of the courts of England and Wales.

Centili Group Ltd.
[Registered office address — to be confirmed], United Kingdom
Company number: [Company number — to be confirmed]
VAT number: [VAT number — to be confirmed]