USR-009 POLÍTICA DE TRANSACCIONES NO AUTORIZADAS Y RESOLUCIÓN DE ERRORES
UNAUTHORIZED TRANSACTIONS & ERROR RESOLUTION POLICY
PUBLICATION FINAL CLEAN
- ID / Category
- USR-009 / USR
- Entity / Entidad
- BLIIM GLOBAL LLC — Delaware, United States
- Version / Versión
- V1.1 Effective Date / Fecha de Vigencia 6 October 2026 / 6 de octubre de 2026 Master Register Item 91 Execution Sequence 090 Priority / Gate P0 — BLOCKER (document publication does not equal Product GO)
AVISO DE ALCANCE / SCOPE NOTICE Esta Política establece cómo Bliim recibe y gestiona reportes de transacciones no reconocidas, potencialmente no autorizadas y errores. Los derechos, plazos, reembolsos, créditos provisionales, reversos y entidades responsables dependen del producto, país, partner, entidad jurídica y régimen aplicable. La publicación de esta Política no significa que una funcionalidad esté disponible en todas las jurisdicciones ni que Bliim sea banco, emisor, PSP, money transmitter, custodio o participante PIX.
This Policy explains how Bliim receives and handles reports of unrecognized or potentially unauthorized transactions and errors. Rights, time limits, reimbursements, provisional credits, reversals and responsible entities depend on the product, country, partner, legal entity and applicable regime. Publication of this Policy does not mean that a feature is available in every jurisdiction or that Bliim is a bank, issuer, PSP, money transmitter, custodian or Pix participant.
1. Purpose
This Policy sets out Bliim’s public framework for receiving, classifying, preserving, investigating, routing and resolving reports of unrecognized or potentially unauthorized transactions and errors relating to enabled features. Its purpose is to protect user rights, preserve evidence and applicable time limits, and ensure that each case is handled by the correct entity and procedure.
2. Scope
It may apply, where the relevant feature is enabled, to transfers, payments, virtual or local account details, cards, wallet, stablecoins, conversions, BliimPay/P2P, deposits, withdrawals, fees, FX and other movements of value. Not every product, country or partner is available to every user and not every case creates the same rights or remedies.
3. Relationship with other documents
USR-008 governs general complaint intake and claims. USR-009 governs unauthorized transactions and error resolution.
USR-010 governs refunds, reversals and chargebacks where applicable. The General Terms, product-specific terms, partner terms, privacy notices, disclosures and applicable mandatory law form part of the relevant framework.
4. Product, country and partner determination
Each case is assessed according to the product, country, customer type, partner, legal entity, rail or network, transaction type and applicable regime. The commercial name of a feature or the fact that Bliim initially receives a report does not by itself determine which entity bears the ultimate legal or financial obligation.
5. Basic definitions
An “unrecognized transaction” is a transaction the user states they do not recognize and that requires investigation. An “unauthorized transaction” is one that, under the applicable regime and contract, was not authorized by the person with legal authority. An “error” may include, where applicable, duplication, omission, incorrect amount, wrong recipient, incorrect fee or FX, inconsistent recording, non-delivery or processing error. A scam or induced fraud may require a classification different from a legally unauthorized transaction.
6. How to report a problem
The user should report the issue as soon as reasonably possible through the support channels available in the app or by emailing [email protected]. The report should identify, where possible, the transaction, date, amount, currency or asset, recipient or merchant, nature of the issue and available evidence. Initial missing information does not necessarily prevent opening a case where there is enough information to reasonably identify the transaction and issue.
7. Preservation of report date
Bliim will seek to preserve the date and time of the first reasonably sufficient notice. If the case must later be reclassified or routed to a partner, subsequent routing should not artificially change the original receipt time where that time is legally relevant.
8. Protective measures
Where there is a reasonable risk of further loss or security compromise, Bliim or the authorized actor may, as applicable, block a card, temporarily restrict a feature, revoke sessions, require step-up authentication, reset credentials or apply other protective measures. A preventive measure does not by itself constitute a conclusion regarding fraud, fault, liability or reimbursement.
9. Authentication does not automatically equal authorization
The existence of a password, OTP, MFA, biometric check, device binding, wallet signature or successful login does not by itself prove legal authorization. The investigation may consider account takeover, malware, SIM swap, social engineering, coercion, compromised credentials, delegated or revoked authority and other relevant facts.
10. Investigation and evidence
The investigation may consider transaction records, authorization events, authentication, device and session data, logs, partner, issuer, bank, network or custodian information, blockchain data, applicable terms and disclosures, fee/FX quotes, communications and evidence provided by the user. Bliim may request additional information where reasonably necessary and legally permitted.
11. Additional information or documents
The need for additional information depends on the case and applicable regime. Bliim will not use unnecessary documentary requirements as a barrier to receiving a report. Where applicable law does not permit an investigation to be conditioned on a written statement, affidavit, police report or other document, the process will be handled in accordance with that rule.
12. Routing to partners and other entities
Where a transaction depends on an issuer, bank, processor, card network, account provider, custodian, blockchain provider, liquidity provider, Bridge, Rain or another partner, Bliim may refer or coordinate the case with the relevant entity. This does not eliminate Bliim’s own obligations and does not automatically make Bliim the regulated entity responsible for the transaction.
13. Time limits and legal clocks
Investigation, response, correction, reimbursement, provisional credit, cancellation or appeal time limits depend on the product, country, responsible entity and applicable regime. Bliim does not apply one global time limit where applicable law or the relevant partner establishes different rules. Where a mandatory legal time limit exists, it will apply to the covered case.
14. Provisional credits and temporary measures
A provisional credit, temporary reimbursement, hold release or other interim measure will be applied only where required by law, authorized by the responsible entity or approved under applicable internal authority. A provisional measure is not a final decision and may be adjusted in accordance with the applicable regime.
15. Decision and remedies
The outcome may include, as applicable, correction of records, reversal, reimbursement, fee or FX adjustment, reprocessing, restoration of access, card replacement or block, partner remediation or another mandatory or authorized remedy. Bliim will communicate the outcome to the extent required and permitted, including additional review or complaint routes where applicable.
16. Cards
Card-related reports are processed according to the card type, issuer, program manager, processor/network, applicable Card Terms and law. A merchant dispute, unauthorized use, billing error and chargeback are not necessarily the same procedure.
Where the partner or issuer is the responsible entity, the case will be coordinated with that entity.
17. Virtual or local account details
Errors involving incoming or outgoing payments, posting, returns, duplicate credits/debits, unidentified funds, incorrect beneficiary or account details or delayed posting may require reconciliation against the provider ledger, bank/rail reference and final transaction status. A webhook or technical confirmation does not necessarily equal final availability of funds.
18. Domestic and cross-border transfers
Rights applying to a transfer may depend on its nature, origin and destination countries, provider and rail. Certain regimes may provide specific cancellation, error-resolution or refund rights. Those rights apply only where the transaction and responsible entity fall within the relevant scope.
19. Wallet, stablecoins and on-chain transactions
A blockchain transfer that has been signed or transmitted may be technically irreversible or difficult to recover. The investigation will distinguish, where relevant, custody, key or signing control, compromised credentials, selected network, address, smart-contract behavior and partner involvement. Technical irreversibility does not eliminate mandatory rights that may exist against a responsible entity.
20. BliimPay/P2P, fraud and scams
For P2P features, Bliim will distinguish among an unrecognized transaction, account takeover, recipient-selection error, impersonation, scam or induced fraud and a commercial dispute. The fact that a user pressed “send” does not by itself resolve every issue of fraud or coercion; at the same time, an instruction induced through deception is not always legally classified as an unauthorized transaction. The remedy depends on the applicable regime.
21. Fees, FX and conversions
A claim involving a fee, spread, exchange rate, quote or converted amount may require reconstruction of the quote, timestamp, pricing configuration, user confirmation and actual settlement. A difference between expectation and the applied rate is not necessarily an error; equally, Bliim will not defend a figure that cannot be reconciled with the applicable configuration and disclosure.
22. Systemic errors
If a case reveals duplication, a ledger mismatch, webhook replay, stale configuration, software defect or another potentially systemic issue, Bliim may broaden the investigation, identify affected users and undertake additional remediation. Closing an individual case does not prevent review of a wider issue.
23. United States
Where a transaction is covered by the Electronic Fund Transfer Act and Regulation E, or by remittance-transfer rules, the legally obligated entity will apply the corresponding rights and procedures, including those relating to unauthorized electronic fund transfers and error resolution. For credit cards, TILA/Regulation Z and issuer rules may apply differently. Bliim does not presume that it is the responsible “financial institution, ” remittance transfer provider or creditor unless the facts and legal structure establish that role.
24. Spain and European Economic Area
Where PSD2 and applicable national transposition rules apply to the responsible payment service provider, authorization, proof of consent, liability for unauthorized transactions, refund/restoration and other rights will be governed by that framework. Bliim will not promise in its own name a remedy that legally belongs to an independent PSP unless Bliim bears that obligation.
25. Colombia
In Colombia, the applicable route depends on the feature and on whether a supervised entity, payment system or other provider subject to specific rules is involved. Where a supervised entity is responsible, its relevant channels and rights will apply, including the Financial Consumer Ombudsman route where applicable. Integration with a supervised entity does not automatically make Bliim an entity supervised by the Superintendencia Financiera.
26. Mexico
In Mexico, applicable procedures and rights depend on whether the transaction involves a financial institution, an ITF, payment rail or another provider subject to unrecognized-charge, complaint or security rules. CONDUSEF, Banco de México or other authority rules apply only to the entity and product within their legal scope.
27. Brazil and Pix
Where a BRL or Pix feature is enabled, Bliim will identify the partner and participating or responsible institution before attributing rights or obligations. Pix includes specific mechanisms for certain fraud and operational-failure situations, including the Mecanismo Especial de Devolução (MED), subject to the current requirements and procedures of the Banco Central do Brasil and participating institutions. MED is not a general guarantee of recovery, does not apply to every commercial dispute and does not make Bliim a Pix participant merely because Bliim technically integrates a feature. Errors, fraud, returns and complaints will be routed to the legally competent actor based on the actual flow.
28. Privacy and security
Cases may require processing personal data, financial data, device identifiers, logs, geolocation or other evidence. Bliim will process this information under its Global Privacy Policy, security controls and applicable law, limiting access and disclosure to what is reasonably necessary.
29. Disclosure restrictions
Bliim will not disclose information where disclosure is restricted by AML, sanctions, security, privacy, secrecy, privilege or other obligations. These restrictions will not be used to avoid explaining an outcome where applicable law requires specific information to be provided to the user.
30. Retention and traceability
Bliim will retain the case ID, timestamps, classification, transaction IDs, evidence, communications, decisions and remedies for the period required by law, contracts, recordkeeping, defence of claims or legal hold. There is no single global retention period for every case.
31. Additional complaints and authorities
Where applicable, the user may have the right to approach a partner, issuer, bank, ombudsman, consumer authority, financial authority, data-protection authority, court or other competent body. The relevant route will be identified where material to the product and jurisdiction.
32. Changes to this Policy
Bliim may update this Policy to reflect legal, regulatory, product, partner, issuer, rail, network, technology or error-resolution changes. The version number and effective date identify the applicable text. Changes requiring notice, reacceptance or other action will be handled in accordance with applicable law.
33. Contact
To report an unrecognized transaction, potential error or operational issue: [email protected] or the support channels available in the app. For legal matters relating to this Policy: [email protected]. Where a product has an urgent or partner-specific channel, it will be shown in the relevant flow.
34. Effective Date
This Policy is effective from 6 October 2026 and remains in force until replaced by a later version published by Bliim.
Document Control / Control del Documento Document ID USR-009 Version V1.1 Status PUBLICATION FINAL CLEAN Effective Date 6 October 2026 Languages Spanish / English — structural and semantic mirror Product GO Separate Product × Country × Partner approval required