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Effective Date: 1 July 2026Last Updated: 1 July 2026

This Complaints, Disputes & Mediation Policy (the “Policy”) forms part of the contractual framework governing the use of the OXLY platform (the “Platform”) operated by IN SPOT SLU, a company organized under the laws of the Principality of Andorra, with registered office at Carretera d’Engolasters 27A 2-1, Andorra, tax / registration number L-919089-T (“OXLY,” “Company,” “we,” “us,” or “our”).

This Policy applies to complaints, booking-related disputes, refund-related disputes, payment-related issues, provider-customer disagreements, moderation-related complaints, trust and safety complaints, and other disputes arising out of or connected with the use of the Platform.

This Policy supplements the Terms of Platform Use, the Booking, Cancellation & Refund Policy, the Payments & Payout Terms, the Provider Terms, the Messaging, Reviews & Ratings Policy, the Verification & Trust Policy, the Community Standards, and any other applicable Platform policies. If there is a conflict between this Policy and a more specific dispute rule in another Platform policy, the more specific rule will control for that subject matter to the extent permitted by law.

By submitting a complaint, participating in a dispute review, requesting a refund, contesting an enforcement action, or otherwise invoking a dispute-related process on the Platform, you agree to this Policy.

1. Purpose of This Policy

The purpose of this Policy is to explain:

• how a complaint may be submitted;
• what types of disputes may be reviewed through the Platform;
• what evidence may be required;
• what role the Platform may play;
• what the Platform does not do;
• when refunds or payment-protective measures may be considered;
• how informal resolution and mediation may work;
• how matters may escalate if not resolved.

OXLY is a technology intermediary and not the provider of the underlying third-party services offered by Providers unless expressly stated otherwise. Complaint and dispute handling through the Platform is intended to support fair and efficient operational review, not to replace courts, regulators, or mandatory rights under applicable law.

2. Scope of Complaints and Disputes Covered

This Policy may apply to complaints or disputes involving, without limitation:

• booking confirmations;
• cancellations;
• no-show situations;
• rescheduling disputes;
• service not as described;
• partial performance;
• refund requests;
• hidden charges or pricing discrepancies;
• payout-related issues;
• messaging abuse;
• fake reviews or review extortion;
• trust and safety concerns;
• verification-related restrictions or badge disputes;
• account restrictions, content removal, or other enforcement actions;
• promotional disputes, where applicable;
• conduct connected to a Platform relationship even if part of the conduct occurred off-platform.

This Policy does not require the Company to review every disagreement between users, and some issues may instead be governed by a more specific policy or by direct legal processes outside the Platform.

3. Platform Role

OXLY may, in its discretion and subject to applicable law, act in one or more of the following capacities:

• a support channel;
• an operational reviewer;
• a trust and safety reviewer;
• a payment-protection operator where payment functionality is enabled;
• a neutral intermediary for gathering information;
• a facilitator of informal resolution;
• a facilitator of voluntary mediation where offered.

OXLY does not, by reason of operating the Platform or handling a complaint:

• become the provider of the underlying third-party service;
• become a guarantor of the service outcome;
• become the legal representative of either party;
• act as a court, arbitrator, public authority, or expert tribunal;
• guarantee that a complaint will result in refund, removal, compensation, or account action;
• assume responsibility for losses except to the extent required by law or expressly accepted in applicable Platform terms.

4. What the Platform May Review

The Company may review, where relevant:

• booking data;
• profile and listing information;
• prices and disclosed fees;
• in-platform messages;
• reviews and ratings;
• uploaded evidence;
• payment and payout metadata;
• cancellation timestamps;
• verification and trust signals;
• complaint history;
• prior warnings or related conduct;
• logs, security data, and platform records;
• other reasonably relevant materials.

The Company may, but is not required to, review events or communications that occurred outside the Platform if they are sufficiently connected to a Platform relationship, Booking, payment issue, review issue, or trust and safety concern.

5. What the Platform Does Not Do

Unless mandatory law requires otherwise, OXLY is not obligated to:

• resolve every dispute;
• determine every factual issue conclusively;
• reimburse all claimed losses;
• compensate for indirect, consequential, reputational, or emotional damages;
• provide legal advice to users;
• conduct a formal forensic investigation;
• preserve all evidence indefinitely;
• participate in external proceedings unless legally required;
• force one user to settle on another user’s preferred terms;
• guarantee recovery of off-platform payments.

6. How to Submit a Complaint

A complaint may be submitted through Platform tools where available or via the official support channels:

• help@oxly.eu for operational complaints; and/or
• a.samoylov@inspot.ad for legal notices and formal escalation.

A complaint should include, where reasonably possible:

• the complainant’s name and account identifier;
• the relevant Booking, order, profile, listing, message thread, review, payment, or feature involved;
• the date and time of the relevant events;
• a clear description of the issue;
• the outcome requested;
• relevant supporting evidence.

The Company may request additional information before reviewing the complaint.

7. Complaint Windows

Users should submit complaints as soon as reasonably possible.

Unless a more specific rule applies under another policy or is shown in the product flow:

• Provider no-show complaints should be submitted within 24 hours of the scheduled start time;
• service-not-as-described, partial-performance, or quality-related complaints should be submitted within 24 hours after the service was completed or should reasonably have been completed;
• pricing, hidden-fee, or undisclosed-charge complaints should be submitted as soon as the issue is discovered;
• messaging abuse, review abuse, fraud, trust and safety, or moderation-related complaints should be submitted without undue delay after discovery;
• payment, payout, refund, or promotional disputes should be submitted as soon as reasonably practicable after the relevant event.

Late complaints may still be reviewed in the Company’s discretion, but delay may affect evidence quality and outcome.

8. Evidence Requirements

To evaluate a complaint or dispute, the Company may request evidence including, without limitation:

• screenshots;
• messages;
• photos or videos;
• timestamps;
• service deliverables;
• invoices or receipts;
• booking records;
• refund or charge records;
• account details;
• verification or compliance records where relevant;
• travel or attendance evidence;
• written explanations from the parties;
• any other reasonably relevant materials.

The Company may weigh evidence in its reasonable discretion and is not required to accept every submission as accurate or complete.

9. Duty to Cooperate

Users involved in a complaint or dispute are expected to cooperate in good faith.

Good-faith cooperation may include:

• responding within a reasonable time;
• providing truthful information;
• not withholding material facts in bad faith;
• not fabricating or altering evidence;
• complying with reasonable requests for clarification;
• not harassing the other party during the review.

Failure to cooperate may affect the review outcome.

10. Types of Outcomes the Platform May Reach

Depending on the issue and the applicable policy, the Company may determine, in its reasonable discretion, that one or more of the following outcomes is appropriate:

• no action;
• warning to a user;
• content removal or correction;
• review or rating removal;
• listing or profile restriction;
• booking closure;
• cancellation recognition;
• no refund;
• partial refund;
• full refund;
• platform credit or goodwill credit, where available;
• payout delay, hold, reserve, offset, or withholding;
• badge removal or downgrade;
• feature restriction;
• account suspension;
• account termination;
• referral to legal or regulatory channels where appropriate.

The Company is not required to apply any specific outcome merely because it is requested by a user.

11. Refund Review

Where payment functionality is enabled, refund review may be available for issues including, without limitation:

• provider cancellation;
• provider no-show;
• service not as described;
• material partial performance;
• hidden or undisclosed mandatory charges;
• duplicate payment;
• technical error;
• unauthorized or suspicious transaction;
• other circumstances recognized by the relevant policy.

Refund decisions remain subject to the Booking, Cancellation & Refund Policy, the Payments & Payout Terms, and any applicable campaign-specific or feature-specific rules.

If the relevant payment did not occur through the Platform, OXLY may still review conduct-related issues but is generally not responsible for issuing or enforcing a refund for off-platform payment.

12. Payment-Protective Measures During a Dispute

Where payment functionality is enabled, the Company may, to the maximum extent permitted by law and applicable payment-provider rules, take protective measures during a complaint or dispute review, including:

• delaying payout;
• withholding payout;
• placing funds on reserve;
• offsetting amounts;
• reversing provisional settlement;
• canceling or freezing a payment-enabled feature;
• issuing a full or partial refund to the Customer;
• holding a promotional benefit or reward pending review.

The Company may take such steps where reasonably necessary to protect users, payment systems, app-store compliance, fraud controls, or the integrity of the Platform. Airbnb’s own legal stack similarly separates general terms from payment and resolution flows and describes a dedicated Resolution Center layer for money-related disputes.

13. Informal Resolution Stage

Before the Company reaches a final operational outcome, the Company may, where appropriate:

• invite one or both parties to clarify their position;
• request supporting evidence;
• encourage direct resolution through the Platform;
• suggest a proposed compromise;
• allow a short period for voluntary settlement.

The Company is not required to conduct an informal resolution stage in every matter, especially where fraud, abuse, safety issues, urgent payment risk, or prohibited conduct is involved.

14. Voluntary Mediation Through or Near the Platform

Where appropriate, the Company may offer or suggest voluntary mediation as a means of helping the parties reach a practical resolution.

Any mediation arranged or facilitated by the Company is voluntary unless mandatory law provides otherwise. Participation in mediation does not oblige either party to settle.

The Company may:

• facilitate a structured exchange between the parties;
• appoint or suggest an internal reviewer or external neutral facilitator;
• pause certain operational steps while mediation is attempted;
• end the mediation attempt if it appears abusive, unproductive, unsafe, or legally inappropriate.

In Andorra, the Government also publicly describes mediation as a voluntary process and maintains an official mediation/orientation service.

15. Pre-Court Complaint Stage

Before starting court proceedings against the Company in relation to Platform operation, users are expected to first submit a written complaint through the channels listed in this Policy.

Unless urgent relief is required or mandatory law provides otherwise, the parties should make a good-faith effort to resolve the matter for at least 30 calendar days after receipt of the written complaint before initiating court proceedings against the Company.

This pre-court stage does not limit any non-waivable consumer rights under applicable law.

16. External Consumer and Public Complaint Routes

Nothing in this Policy limits a user’s right, where applicable, to use public consumer complaint channels or to seek relief from competent authorities or courts.

For consumer matters in Andorra, the Government provides an official Servei d’Atenció al Consumidor and official consumer complaint forms.

The Company may, in its discretion, refer users to such public complaint mechanisms where appropriate.

17. False, Abusive, or Bad-Faith Complaints

Users must not misuse complaint or dispute procedures.

Prohibited conduct includes, without limitation:

• knowingly false complaints;
• fabricated evidence;
• retaliatory complaints;
• coordinated complaint abuse;
• abusive refund claims;
• weaponizing support or safety processes against another user;
• repeated bad-faith escalation designed to harass, intimidate, or gain leverage rather than resolve a genuine issue.

The Company may take enforcement action in response to such conduct.

18. Account, Content, and Feature Disputes

A user may also submit a complaint or appeal regarding:

• content removal;
• listing delisting;
• badge removal;
• messaging restriction;
• review removal;
• payment restriction;
• payout hold;
• role restriction;
• account suspension or termination.

Such disputes may be reviewed under this Policy together with the more specific policy that applies to the underlying action. The Company may uphold, modify, or reverse its prior action in its discretion, subject to applicable law.

19. Escalation and Final Platform Position

After reviewing the available information, the Company may communicate a final platform-level operational position.

That final position may include:

• closure of the complaint;
• denial of the complaint;
• one or more operational or financial measures;
• referral to another Platform process;
• suggestion of voluntary mediation;
• suggestion to use external legal or public complaint channels.

A final platform-level decision does not prevent a user from exercising rights available under mandatory law, but it does conclude the Company’s internal review unless the Company decides to reopen the matter.

20. Preservation of Evidence and Records

The Company may preserve complaint-related records, logs, communications, moderation records, payment metadata, or other materials for as long as reasonably necessary for:

• dispute review;
• fraud prevention;
• trust and safety review;
• legal compliance;
• defense of rights;
• audit and recordkeeping;
• cooperation with competent authorities.

The Company is not your evidence archive, and users remain responsible for keeping their own records where appropriate.

21. No Warranty as to Complaint Outcomes

To the maximum extent permitted by law, the Company does not warrant or guarantee that:

• every complaint will be accepted for review;
• every dispute will be resolved within a specific time;
• every valid complaint will result in refund or compensation;
• every mediation attempt will succeed;
• every enforcement request will be granted;
• every final platform-level outcome will satisfy the complaining user.

Nothing in this Policy makes the Company the guarantor of the underlying third-party service or the final legal resolution of any dispute.

22. Interaction With Other Policies

This Policy operates together with the rest of the OXLY legal stack.

Without limitation:

• booking-specific issues remain subject to the Booking, Cancellation & Refund Policy;
• payment measures remain subject to the Payments & Payout Terms;
• provider duties remain subject to the Provider Terms;
• review and messaging issues remain subject to the Messaging, Reviews & Ratings Policy;
• trust, badge, and document issues remain subject to the Verification & Trust Policy;
• content disputes remain subject to the Content, Images & Intellectual Property Policy.

23. Changes to This Policy

The Company may update this Policy from time to time.

If material changes are made, the Company may notify users by:

• posting the updated version on the Platform;
• updating the Effective Date or Last Updated date;
• email notice;
• in-app notice;
• account notice; or
• another reasonable communication method.

Continued use of the Platform after the effective date of the revised Policy constitutes acceptance of the updated version.

24. Governing Law and Jurisdiction

This Policy is governed by and shall be interpreted in accordance with the laws of the Principality of Andorra, without regard to conflict-of-law principles.

Any dispute arising out of or in connection with this Policy shall be submitted to the competent courts of Andorra, unless mandatory consumer protection law requires otherwise.

25. Contact

IN SPOT SLU

Carretera d’Engolasters 27A 2-1, Andorra

Tax / Registration No.: L-919089-T

Operational complaints: help@oxly.eu

Legal notices: a.samoylov@inspot.ad