User Complaint Procedure

Last Updated: September 1, 2026

1. Introduction

This User Complaint Procedure (this "Procedure") is incorporated by reference into, and forms an integral part of, the Ethena Pay Terms of Use (the "Terms of Use"). This Procedure supplements but does not replace the Terms of Use. Except as otherwise expressly defined herein, all capitalized terms used herein shall have the meanings given to them in the Terms of Use.

This Procedure sets out how you may submit, escalate, and resolve complaints relating to your use of the Ethena Pay Platform and the Services. Ethena Pay Ltd. ("Ethena Pay," "we," "us," or "our") is committed to handling complaints fairly, transparently, and in accordance with applicable law.

Submitting a complaint under this Procedure is free of charge. Use of this Procedure does not affect your right to pursue any other legal remedies available to you under applicable law, including any mandatory rights afforded to you as a consumer in your country of residence.

2. Scope of This Procedure

This Procedure applies to complaints about:

  • The Platform, the Services, or any feature, functionality, or content provided by us;
  • The conduct of Ethena Pay personnel or our authorized agents;
  • Our handling of your personal data (without prejudice to your statutory rights under applicable data protection law, including your right to lodge a complaint directly with a supervisory authority as described in Section 7);
  • Suspected violations of the Acceptable Use Policy by other users; and
  • Services provided by Third-Party Providers (including Sumsub, Privy, Iron/Moonpay, and the Issuer of the Ethena Pay Spend Card), to the extent we are able to assist.

Complaints relating exclusively to your Ethena Pay Spend Card account, card issuance, card transactions, chargebacks, or your relationship with the card Issuer are handled in the first instance under the Ethena Pay Spend Card Terms (Exhibit H) and the procedures described in Section 6 below.

3. How to Submit a Complaint

You may submit a complaint to us through any of the following channels:

  • Email: complaints@ethenapay.co
  • In-app: through the "Help" or "Support" section of the Ethena Pay App or website (look for "Submit a Complaint").
  • Mail: Ethena Pay Ltd., Attn: User Complaints, 30/1 Kenilworth, Triq Sir Augustus Bartolo, Ta' Xbiex, XBX 1093, Malta.

To help us investigate and respond promptly, please include the following information in your complaint:

  • Your full name and the email address associated with your Ethena Pay account or profile;
  • A clear description of the issue, including dates, times, and the Services or features affected;
  • Any relevant transaction references, card transaction identifiers, or wallet addresses;
  • The outcome or remedy you are seeking; and
  • Any supporting documents, screenshots, or correspondence.

If you need assistance preparing or submitting your complaint, including by reason of disability or language difficulty, please contact User Support and we will help you to the extent reasonably practicable.

4. How We Handle Your Complaint

4.1 Acknowledgment

We will acknowledge receipt of your complaint without undue delay and, in any event, no later than five (5) business days after we receive it. Our acknowledgment will include a unique complaint reference number and the name or team handling your complaint.

4.2 Investigation

We will investigate your complaint promptly, fairly, and impartially. We may contact you for additional information or documentation. We will use our best efforts to maintain the confidentiality of your complaint, subject to legal and regulatory requirements and the need to share information with relevant Third-Party Providers as necessary to investigate.

4.3 Resolution Timeframe

We aim to provide a final response to your complaint within fifteen (15) business days of receipt. Where this is not possible due to the complexity of the matter, the need to obtain information from Third-Party Providers, or other circumstances beyond our reasonable control, we will:

  • Notify you of the delay and the reasons for it before the initial fifteen-business-day deadline expires;
  • Provide an indicative date by which you can expect a final response; and
  • In any event, provide a final response no later than thirty-five (35) business days from the date we received your complaint, except where applicable law permits a longer period.

4.4 Final Response

Our final response will be provided to you in writing (including by email) and will:

  • Summarize your complaint and the outcome of our investigation;
  • Explain whether we accept, partially accept, or reject your complaint, and the reasons for our determination;
  • Describe any corrective action we have taken or will take, or any remedy or compensation we are offering, where applicable; and
  • Inform you of your right to escalate the matter under Section 7 if you are dissatisfied with our response.

5. Internal Escalation

If you are dissatisfied with the response from the team handling your complaint, you may request internal escalation by replying to the final response email with the subject line "Request for Escalation," or by writing to escalations@ethenapay.co and referencing your complaint reference number.

An internal review will be conducted by a member of our Compliance or Legal team who was not involved in the original investigation. We will provide a written escalation response within ten (10) business days of receiving your escalation request, unless the complexity of the matter requires additional time, in which case we will keep you informed.

6.1 Disputes With Merchants and Chargebacks

Disputes about charges, refunds, undelivered goods or services, or unauthorized transactions on your Ethena Pay Spend Card are governed by the Ethena Pay Spend Card Terms (Exhibit H) and the rules of the applicable card network. Under the Spend Card Terms, you must:

  • First attempt to resolve any merchant dispute directly with the merchant; and
  • Initiate a chargeback through your Ethena Pay account within sixty (60) days after the disputed charge is posted on your Periodic Statement.

6.2 Complaints Against the Card Issuer

The Ethena Pay Spend Card is issued by the applicable card issuer under a license from the applicable card network. For complaints relating to the issuance, servicing, statement accuracy, fees, interest, account closure, or arbitration of disputes by the Issuer, you may contact the Issuer at:

Card-related disputes with the Issuer are subject to the dispute resolution and binding arbitration provisions in Section 16 of the Spend Card Terms, including the requirement to provide written notice of the dispute and to attempt informal resolution before initiating arbitration. The Issuer's arbitration is administered by the American Arbitration Association under its Consumer Arbitration Rules.

6.3 Complaints About Ethena Pay's Role in Card Services

To the extent your complaint concerns services provided by Ethena Pay under the Terms of Use (for example, the operation of the Platform, your wallet, or the cashback Rewards program) rather than services provided by the Issuer, the complaint will be handled under this Procedure and governed by the Terms of Use and the laws of Malta.

7. External Escalation

If you remain dissatisfied with our final response, or if we have failed to provide a final response within the timeframes set out in Section 4.3, you may have the right to escalate your complaint to an external authority. The available routes depend on your country of residence and the nature of your complaint.

7.1 Financial Services Complaints (Malta)

Ethena Pay Ltd. is incorporated in Malta. To the extent the Office of the Arbiter for Financial Services has jurisdiction over the matter, eligible complainants may refer unresolved complaints to:

A complaint to the Office of the Arbiter for Financial Services must generally be lodged within two (2) years from the date on which the complainant first knew, or reasonably should have known, of the matters complained of, and only after our internal complaints process has been exhausted or has failed to resolve the matter within the prescribed timeframe.

7.2 EU Online Dispute Resolution (ODR) Platform

If you are a consumer resident in the European Union and your complaint relates to a service provided online, you may use the European Commission's ODR Platform to submit your complaint:

Please note that we are not obliged to participate in ODR proceedings unless required by applicable law.

7.3 Data Protection Complaints

If your complaint relates to our handling of your personal data, you have the right to lodge a complaint directly with the competent data protection supervisory authority, in addition to or instead of complaining to us. For users in Malta, the competent authority is:

For users in other EEA member states, a list of national supervisory authorities is available at edpb.europa.eu/about-edpb/about-edpb/members_en. For users in the United Kingdom, the competent authority is the Information Commissioner's Office (ICO) at www.ico.org.uk.

7.4 Country-Specific Authorities

Depending on your country of residence, additional or alternative external escalation routes may be available to you under local law, including financial ombudsmen, consumer protection authorities, or regulatory complaints bodies. Please refer to the Country-Specific Terms in Appendix 1 of the Terms of Use for details applicable to your jurisdiction.

7.5 Card Network Dispute Procedures

For unresolved card transaction disputes, you may also have rights under the rules of the applicable card network. The Issuer can provide information about these procedures on request.

8. Reports of Acceptable Use Policy Violations

Reports that another user, account, or transaction may be in violation of the Acceptable Use Policy (Exhibit A), including suspected fraud, sanctions evasion, money laundering, or other prohibited activity, are not "complaints" against us but are reports we take seriously. You may submit such reports to:

You may report anonymously where permitted by applicable law. We will investigate credible reports and take appropriate action consistent with the Acceptable Use Policy, the Terms of Use, and applicable law. For confidentiality and legal reasons, we may not be able to share the outcome of our investigation with you.

9. Records and Confidentiality

We maintain records of complaints, our investigations, and our responses in accordance with the retention periods set out in the Ethena Pay Privacy Policy. Records of complaints and supporting correspondence are typically retained for three (3) years from the date of the communication, and complaints involving suspected fraud or financial crime are retained for five (5) years.

We treat complaint information confidentially, subject to applicable law, our regulatory obligations, and the need to share information with Third-Party Providers, professional advisers, regulators, law enforcement, or arbitral or judicial bodies as necessary or appropriate to investigate, resolve, or comply with legal requirements.

10. Non-Retaliation

We will not retaliate against any user who, in good faith, submits a complaint or report under this Procedure. Submitting a complaint will not, in and of itself, result in suspension, restriction, or termination of your account. Nothing in this Section limits our right to take enforcement actions under the Terms of Use or the Acceptable Use Policy where we determine, in good faith, that such action is warranted by your conduct independent of the complaint.

11. Updates to This Procedure

We may update, modify, or amend this Procedure from time to time in accordance with Section 1.8 (Changes; your access to these Terms) of the Terms of Use. Updates will be effective upon posting to the Platform or as otherwise communicated to you, except that material changes will be notified to you at least thirty (30) days in advance where required by applicable law. Your continued use of the Services following any update constitutes your acceptance of the updated Procedure.

12. Contact Summary

The following table summarizes the contact channels referenced in this Procedure:

PurposeContactReference
Submit a complaintcomplaints@ethenapay.coSection 3
Internal escalationescalations@ethenapay.coSection 5
Card-related (Issuer)support@ethenapay.co / 1-844-ETHA-PAYSection 6.2
Privacy / data protectionprivacy@ethenapay.coSection 7.3
AUP violations / compliancecompliance@ethenapay.coSection 8
General user supportVia the in-app Help sectionTerms § 11.1