Conduct Complaint Policy

Last Updated: April 13, 2026

Discover our comprehensive approach to handling complaints and concerns.

Our Commitment

At Cirqul, we believe everyone deserves to be treated with fairness, respect, and transparency — especially when it comes to their finances. We take all complaints seriously and are committed to resolving them promptly, equitably, and in accordance with applicable federal and state consumer protection laws.

This policy explains how to submit a complaint, what to expect from us in response, and your rights throughout the process.

What Is a Complaint?

A complaint is any expression of dissatisfaction — whether written or verbal — about Cirqul's products, services, employees, agents, or third-party partners acting on our behalf. This includes, but is not limited to:

• Concerns about billing, subscription charges, or fees

• Questions related to services we offer

• Issues with CIRQUL AI (CARA) outputs, chats, or account actions

• Complaints about the conduct of a Cirqul representative or third-party agent

• Any matter you believe was handled unfairly, incorrectly, or in violation of your rights

How to Submit a Complaint

You may submit a complaint to Cirqul using any of the following methods:

Email (preferred): support@cirqul.com

Mail: Cirqul Ventures Inc. Attn: Customer Relations 40 S. Stephanie Street #101, Henderson, NV 89012

Legal / Formal Disputes: legal@cirqul.com

When submitting a complaint, please include the following information to help us investigate and respond as quickly as possible:

• Your full name and the email address or phone number associated with your Cirqul account

• A clear description of the issue, including relevant dates and any account numbers or reference numbers

• The outcome you are requesting (e.g., refund, correction, explanation, account action)

• Any supporting documentation, if applicable

What Happens After You Submit a Complaint

Acknowledgment: We will acknowledge receipt of your complaint within 3 business days.

Investigation: A dedicated member of our Customer Relations team will review your complaint, gather relevant information, and — where necessary — consult with the relevant department, service provider, or third-party partner.

Resolution: We aim to provide a full written response and resolution within 30 calendar days of receiving your complaint. In cases requiring additional investigation, we will notify you of the delay and provide an estimated resolution date.

Escalation: If your complaint involves a third-party partner, we will coordinate with that partner on your behalf and keep you informed of progress.

Debt Collection Complaints

If your complaint relates to Cirqul's role as a debt collector, you have specific rights under the Fair Debt Collection Practices Act (FDCPA), including the right to:

• Request debt validation within 30 days of our initial contact. We will cease collection activity until we provide verification of the debt.

• Dispute the debt if you believe the amount, creditor, or other details are inaccurate. Send your written dispute to legal@cirqul.com or visit cirqul.com/dispute

• Request cessation of contact. If you request in writing that Cirqul stop contacting you, we will honor that request subject to the limited exceptions permitted under the FDCPA.

We are prohibited from engaging in harassment, the use of false or misleading representations, or unfair practices in connection with the collection of any debt. If you believe a Cirqul representative has engaged in any such conduct, please report it immediately using the contact information above.

Credit Reporting Complaints

If you believe that information Cirqul has furnished to a consumer reporting agency is inaccurate or incomplete, you have the right to dispute that information directly with the relevant credit bureau(s):

• Experian: experian.com/disputes | 1-888-397-3742

You may also submit a complaint to Cirqul at legal@cirqul.com, and we will investigate and respond as required by the Fair Credit Reporting Act (FCRA).

Non-Retaliation

Cirqul does not retaliate against any customer who submits a complaint in good faith. Filing a complaint will not affect your ability to access Cirqul's Services, and we are committed to treating all complainants with professionalism and respect throughout the process.

Updates to This Policy

We may update this Conduct Complaint Policy from time to time to reflect changes in our practices, services, or applicable law. The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this policy periodically.

Contact Us

For any questions about this policy or to submit a complaint:

• Email: support@cirqul.com

• Legal / Disputes: legal@cirqul.com

• Mail: Cirqul Ventures Inc., 40 S. Stephanie Street #101, Henderson, NV 89012