Dispute Resolution Policy

ZIMMA SOLUTIONS (PRIVATE) LIMITED

DISPUTE RESOLUTION POLICY

Effective Date: 07 April 2026

Last Updated: 07 April 2026

Version: 1.0

SECP Incorporation No: 0331469 | NTN: I782094

House 1123, Street 10, G-14/4, Islamabad Urban, ICT 42600, Pakistan

hello@zimma.com.pk | www.zimma.com.pk

IMPORTANT NOTICE

This Dispute Resolution Policy ("Policy") governs the procedures by which disputes between Buyers and Sellers on the Zimma platform are raised, reviewed, and resolved, and by which platform-level complaints against Zimma are handled. This Policy is incorporated by reference into Zimma's Terms of Service and forms part of the binding agreement between each User and Zimma Solutions (Private) Limited.

By using the Zimma platform and creating or participating in any escrow transaction, you agree to be bound by this Policy.

1. PURPOSE AND SCOPE

1.1 Purpose

The purpose of this Policy is to establish a clear, fair, and time-bound mechanism for resolving disputes that arise in connection with escrow transactions conducted through the Zimma platform, and for handling complaints raised by users against Zimma itself. Zimma is committed to providing a structured resolution process that protects both Buyers and Sellers while maintaining its role as a neutral Escrow Agent.

1.2 Scope — What This Policy Covers

This Policy covers two distinct categories of matters:

Escrow Transaction Disputes: Disputes between a Buyer and a Seller arising from the performance, non-performance, or partial performance of an escrow transaction, including disputes about the delivery, quality, condition, or description of goods or services;
Platform Complaints: Complaints raised by a User against Zimma itself in relation to platform errors, fee disputes, KYC issues, account-level matters, or the conduct of Zimma's staff or systems.

1.3 What This Policy Does Not Cover

This Policy does not cover:

Disputes arising from transactions conducted entirely outside the Zimma platform, even if the parties are registered Zimma users;
Disputes between users who did not complete the KYC verification process required to create or participate in an escrow transaction;
Criminal matters, which Zimma will refer to the relevant law enforcement authorities;
Civil claims between Buyers and Sellers that exceed the scope of Zimma's escrow function — such claims must be pursued through the courts of competent jurisdiction in Islamabad, Pakistan.

2. DEFINITIONS

Capitalized terms used in this Policy carry the meanings assigned to them in Zimma's Terms of Service. The following additional terms apply for the purposes of this Policy:

"Business Day" means a day on which commercial banks in Pakistan are open for business, excluding Saturdays, Sundays, and public holidays declared by the Government of Pakistan.

"Claimant" means the User who initiates a Dispute or Platform Complaint through the Zimma platform.

"Complaint" means a formal grievance raised by a User against Zimma in relation to Zimma's own conduct, systems, or platform, as distinct from a Dispute between a Buyer and a Seller.

"Decision" means Zimma's written determination of the outcome of an Escrow Transaction Dispute, specifying whether the Escrow Funds will be released to the Seller or returned to the Buyer.

"Dispute" means a formal disagreement raised by a Buyer or Seller through the Zimma platform in relation to the performance of an Escrow Transaction.

"Dispute Window" means the period within which a Buyer must raise a Dispute following the Seller's notification of delivery or performance, as specified in Section 6.

"Evidence" means any documentation, media, communication, or other material submitted by either party in support of their position in a Dispute.

"Respondent" means the User against whom a Dispute or Complaint has been raised.

"Resolution Notice" means the written notification from Zimma communicating its Decision on an Escrow Transaction Dispute to both parties.

"Ticket Number" means the unique reference number assigned by Zimma to each Dispute or Complaint upon registration, used for all subsequent correspondence.

3. APPLICABLE LAWS

This Policy is designed and operated in compliance with the following laws and regulatory frameworks of Pakistan:

a. Payment Systems and Electronic Fund Transfers Act, 2007 ("PS&EFT Act 2007")

Section 36: Error notification obligations and investigation requirements;
Section 37: Obligation to correct errors within one Business Day of determination;
Section 38: Obligations where no error is found;
Section 39: Liability for triple damages where an institution acts in bad faith;
Section 71: Consumer right to refer complaints to the State Bank of Pakistan.

b. SBP Electronic Fund Transfer Regulations, Section 12

Dispute and error resolution process requirements, including a maximum resolution period of ten (10) Business Days and obligations to notify consumers of investigation outcomes.

c. SBP Rules for Payment System Operators and Payment Service Providers, Section 10

Requirement for a defined dispute resolution mechanism with turnaround times and a comprehensive Complaint Redressal Mechanism for consumer protection.

d. Consumer Protection Act, 2019

Section 10: Prohibition on misleading or deceptive conduct in connection with goods or services;
Section 11: Right of consumers to information about dispute resolution mechanisms.

e. Anti-Money Laundering Act, 2010, Section 7

Record-keeping obligations applicable to dispute and transaction records.

f. Electronic Transactions Ordinance, 2002, Section 6

Legal validity and retention of electronic records of disputes and their resolution.

g. SECP AML/CFT Regulations, 2018

Obligations to report suspicious transactions identified in the course of dispute review.

4. TYPES OF DISPUTES AND COMPLAINTS

4.1 Escrow Transaction Disputes

The following categories of dispute may arise between a Buyer and a Seller in connection with an Escrow Transaction:

Non-Delivery: The Seller has wholly failed to deliver the goods or perform the services described in the Transaction Terms within the agreed timeline, and the Buyer has not received anything.
Partial Delivery: The Seller has delivered only a portion of the agreed goods or performed only part of the agreed services, and the Buyer has not received the full benefit bargained for.
Goods Not As Described: The goods delivered by the Seller are materially different from the description provided in the Transaction Terms — including differences in type, model, specification, brand, or condition.
Damaged Goods: The goods received by the Buyer are physically damaged, defective, or non-functional in a manner that was not disclosed in the Transaction Terms.
Service Deficiency: The services rendered by the Seller are materially below the standard or scope described in the Transaction Terms.
Seller Cancellation: The Seller has cancelled or refused to perform the Escrow Transaction after the Buyer has deposited Escrow Funds into the Escrow Account.
Buyer Non-Confirmation: The Seller contends that goods or services have been properly delivered but the Buyer is unreasonably withholding confirmation of satisfaction.

4.2 Platform Complaints Against Zimma

The following categories of complaint may be raised by a User against Zimma:

Fee Dispute: A User contends that the escrow service fee deducted by Zimma was incorrect, unauthorized, or inconsistent with the published Schedule of Charges.
KYC Rejection: A User contends that their KYC verification was rejected incorrectly or that the AWS Rekognition biometric matching result was erroneous.
Account Suspension: A User contends that their account was suspended without lawful basis or proper notice.
Platform Error: A User reports a technical error on the Zimma platform that resulted in a financial discrepancy — for example, a duplicate deduction, an incorrect transaction amount, or a failure to credit a release or return.
Delayed Fund Release or Return: A User contends that funds were not released or returned within the applicable timeframe following the occurrence of a Release Trigger or Return Trigger.
OTP Delivery Failure: A User reports that they did not receive an OTP via SMS (sender ID: ZIMMA) and were thereby unable to access their account or authorize a transaction, resulting in loss.
Privacy Complaint: A User contends that Zimma has processed their personal data in a manner inconsistent with the Privacy Policy.
Staff Conduct: A User reports unprofessional, discriminatory, or abusive conduct by a member of Zimma's customer support team.

5. WHO MAY RAISE A DISPUTE

5.1 KYC Verification Required

Only Users who have completed the full KYC verification process — including biometric verification via AWS Rekognition and OTP confirmation via Veevo Tech (sender ID: ZIMMA) — may raise an Escrow Transaction Dispute through the Zimma platform.

5.2 Buyer's Right to Dispute

A Buyer may raise a Dispute against a Seller in respect of any of the Escrow Transaction Dispute categories described in Section 4.1, sub-clauses (a) through (f): Non-Delivery, Partial Delivery, Goods Not As Described, Damaged Goods, Service Deficiency, and Seller Cancellation.

5.3 Seller's Right to Dispute

A Seller may raise a Dispute against a Buyer only in respect of the category described in Section 4.1, sub-clause (g) — where the Seller contends that goods or services have been duly delivered and the Buyer is unreasonably or in bad faith withholding confirmation of satisfaction.

5.4 Platform Complaints

Either a Buyer or a Seller may raise a Platform Complaint against Zimma in respect of any of the categories described in Section 4.2.

6. THE DISPUTE WINDOW

6.1 Standard Dispute Window

A Buyer must raise a Dispute within seven (7) calendar days of the Seller's notification through the Zimma platform that the goods have been dispatched or the services have been performed ("Dispute Window").

6.2 Commencement of Dispute Window

The Dispute Window commences on the date and time on which Zimma sends the Buyer an in-app notification confirming that the Seller has marked the transaction as delivered or performed. The Dispute Window runs continuously — it is not suspended by weekends or public holidays.

6.3 Extended Dispute Window for Long-Timeline Deliveries

Where the agreed Transaction Terms specify a delivery or performance timeline longer than seven (7) calendar days from the date the Escrow Funds are deposited, the Dispute Window shall commence only upon expiry of that agreed delivery timeline, or upon the Seller's notification of delivery, whichever occurs first.

6.4 Consequence of Failure to Raise a Dispute in Time

If a Buyer fails to raise a Dispute within the Dispute Window and also fails to confirm satisfaction, Zimma will:

Send a reminder notification to the Buyer via in-app notification and SMS (sender ID: ZIMMA);
Allow a further forty-eight (48) hours from the delivery of that reminder notification for the Buyer to take action;
If no action is taken within that forty-eight (48) hour period, automatically close the Escrow Transaction in the Seller's favor and release the Escrow Funds to the Seller, less Zimma's applicable escrow service fee.

6.5 No Dispute After Confirmation of Satisfaction

Once a Buyer has confirmed satisfaction through the Zimma platform and the Escrow Funds have been released to the Seller, no Dispute may be raised in relation to that transaction. The Release Trigger, once acted upon, is final and irrevocable.

7. HOW TO RAISE AN ESCROW TRANSACTION DISPUTE

7.1 Dispute Must Be Raised Through the Platform

All Escrow Transaction Disputes must be raised through the designated Dispute function within the Zimma mobile application. Disputes raised by email, telephone, or WhatsApp alone will not be accepted as formal Disputes — however, they may be acknowledged and the User directed to raise the Dispute through the application.

7.2 Dispute Submission — Required Steps

When raising a Dispute, the Claimant must:

Select the relevant Escrow Transaction from their transaction history;
Select the applicable Dispute category from the list provided in Section 4.1;
Provide a written description of the basis for the Dispute, including the specific Transaction Term(s) alleged to have been breached;
Upload all available Evidence in support of the Dispute (see Section 8);
Confirm that the submission is accurate and made in good faith.

7.3 Dispute Ticket Assignment

Upon submission of a Dispute, Zimma will:

Assign a unique Ticket Number to the Dispute within two (2) Business Days of receipt;
Notify both the Claimant and the Respondent via in-app notification and SMS that a Dispute has been registered;
Immediately place the Escrow Funds on hold in the Escrow Account, preventing release or return pending the outcome of the Dispute.

7.4 Respondent's Right to Reply

Upon receipt of a Dispute notification, the Respondent will have five (5) calendar days to submit their response and Evidence through the Zimma platform. Where the Respondent fails to submit any response within this period, Zimma will proceed to review the Dispute based solely on the Claimant's submission.

8. EVIDENCE REQUIREMENTS

8.1 General Principle

The burden of establishing the basis for a Dispute rests on the Claimant. Each party is responsible for submitting clear, relevant, and verifiable Evidence in support of their position. Zimma will review all Evidence submitted but cannot independently verify facts that are outside the Zimma platform's records.

8.2 Types of Acceptable Evidence

The following types of Evidence will be considered by Zimma in the review of an Escrow Transaction Dispute:

Photographs or video recordings of goods received, showing their condition, description, or any damage;
Screenshots of conversations between the Buyer and Seller conducted through any messaging platform;
Screenshots or copies of the agreed Transaction Terms as entered on the Zimma platform;
Delivery tracking information, courier receipts, or proof of dispatch provided by the Seller;
Receipts, invoices, or order confirmations;
Proof of the service having been rendered — for example, completed work product, access credentials, or delivery confirmations for digital services;
Any other documentation that a reasonable person would consider relevant to establishing the facts in dispute.

8.3 Evidence Integrity

Evidence must not be altered, fabricated, or misleadingly cropped or edited. The submission of fabricated or materially altered Evidence constitutes a serious breach of Zimma's Terms of Service and may result in the immediate suspension of the submitting party's account, resolution of the Dispute against them, and, where appropriate, referral to law enforcement authorities under PECA 2016.

8.4 Evidence in Urdu

Where Evidence is submitted in Urdu or another language, Zimma reserves the right to request a translation. Zimma will use reasonable efforts to accommodate Evidence in Urdu without requiring a formal translation.

8.5 Evidence File Formats

Evidence must be submitted in commonly supported digital formats including JPG, PNG, PDF, or MP4. Each file must not exceed the size limit specified on the Zimma platform at the time of submission.

9. ZIMMA'S REVIEW PROCESS

9.1 Neutral Review

Zimma will review all Escrow Transaction Disputes as a neutral Escrow Agent. Zimma has no financial interest in the outcome of a Dispute beyond its applicable escrow service fee, which is deducted regardless of outcome. Zimma's review process is not adversarial — it is designed to identify the most reasonable outcome based on the available Evidence and the Transaction Terms.

9.2 Steps in the Review Process

Upon receiving a Dispute and the Respondent's reply (or upon expiry of the reply window), Zimma's Dispute Review Team will proceed through the following steps:

Step 1 — Verification: Confirm that the Dispute has been raised within the Dispute Window and that both parties have completed KYC verification.

Step 2 — Platform Record Review: Review all records of the Escrow Transaction held on the Zimma platform, including the Transaction Terms as entered, all status changes, timestamps of each event, and any in-platform communications.

Step 3 — Evidence Review: Review all Evidence submitted by both the Claimant and the Respondent.

Step 4 — Analysis: Apply the applicable Dispute category criteria to the available Evidence and platform records to determine whether the Release Trigger or Return Trigger conditions have been met.

Step 5 — Decision: Issue a written Resolution Notice to both parties specifying the outcome, the reasoning, and the action that will be taken in respect of the Escrow Funds.

9.3 Right to Request Additional Information

Zimma reserves the right, at any stage of the review process, to request additional Evidence or information from either or both parties. A failure to respond to such a request within three (3) calendar days will be treated as an absence of further Evidence from that party.

9.4 Circumstances Where Zimma May Decline to Decide

Where Zimma determines that:

The Dispute involves a matter of criminal conduct (for example, fraud or identity theft);
The available Evidence is so materially conflicting that Zimma cannot determine the outcome without judicial or investigative powers it does not possess; or
The Dispute raises legal questions that require determination by a court of competent jurisdiction;

Zimma will freeze the Escrow Funds and issue a written notification to both parties advising them to seek resolution through appropriate legal channels. In such cases, Zimma may file a Suspicious Transaction Report with the Financial Monitoring Unit (FMU) where required under the AML Act 2010.

10. TURNAROUND TIMES

The following turnaround times apply to all Escrow Transaction Disputes and Platform Complaints, measured in Business Days from the date of receipt by Zimma.

Dispute / Complaint Type | Brief Description | Acknowledgement | Resolution
ESCROW TRANSACTION DISPUTES
Non-Delivery (complete) | Seller has wholly failed to deliver goods or services within agreed timeline. | 2 Business Days | 7 Business Days
Goods Not As Described | Goods received are materially different from Transaction Terms. | 2 Business Days | 10 Business Days
Partial Delivery | Only part of the agreed goods or services delivered. | 2 Business Days | 10 Business Days
Damaged Goods | Goods received in damaged, defective, or non-functional condition. | 2 Business Days | 10 Business Days
Service Deficiency | Services rendered below the standard or scope in Transaction Terms. | 2 Business Days | 10 Business Days
Seller Cancellation | Seller cancelled or refused to perform after Buyer deposited funds. | 2 Business Days | 5 Business Days
Buyer Non-Confirmation (Seller-initiated) | Seller contends Buyer is unreasonably withholding confirmation. | 2 Business Days | 7 Business Days
PLATFORM COMPLAINTS AGAINST ZIMMA
Fee Dispute | Incorrect, unauthorized, or unexplained fee deduction. | 2 Business Days | 7 Business Days
KYC Rejection | KYC rejected incorrectly or biometric match result erroneous. | 1 Business Day | 5 Business Days
Account Suspension | Account suspended without lawful basis or proper notice. | 1 Business Day | 5 Business Days
Platform Error (financial) | Duplicate deduction, wrong amount, failure to credit. | 1 Business Day | 3 Business Days
Delayed Fund Release / Return | Funds not released or returned within applicable timeframe. | 1 Business Day | 3 Business Days
OTP Delivery Failure | OTP not received via SMS (sender ID: ZIMMA), causing access loss. | 1 Business Day | 2 Business Days
Privacy Complaint | Personal data processed inconsistently with Privacy Policy. | 2 Business Days | 14 Business Days
Staff Conduct | Unprofessional, discriminatory, or abusive conduct by Zimma staff. | 2 Business Days | 10 Business Days
Note: Saturdays, Sundays, and public holidays declared by the Government of Pakistan are not Business Days and are not counted toward the above turnaround times.

10.2 Complex Disputes

Where a Dispute is exceptionally complex or involves third-party verification requirements that fall outside the standard process, Zimma may extend the resolution period by a further five (5) Business Days. Zimma will notify both parties of any such extension before the original resolution deadline expires.

10.3 Platform Errors Under PS&EFT Act 2007

Where a Dispute involves what would constitute an "error" within the meaning of Section 36 of the PS&EFT Act 2007 — including a computational or platform error by Zimma — Zimma will investigate and report the outcome to the affected User in writing within ten (10) Business Days of notification, in accordance with Section 36(2). Where an error is confirmed, Zimma will correct it within one (1) Business Day of determination, consistent with Section 37.

11. POSSIBLE OUTCOMES

11.1 Outcome in Favor of the Buyer — Return of Escrow Funds

Where Zimma's review determines that the Return Trigger conditions have been satisfied, Zimma will:

Issue a Resolution Notice to both parties specifying the outcome and the basis for it;
Return the Escrow Funds to the Buyer, less Zimma's applicable escrow service fee, within three (3) to five (5) Business Days of the Resolution Notice;
Update the Escrow Transaction status to "Refunded" on the Zimma platform.

11.2 Outcome in Favor of the Seller — Release of Escrow Funds

Where Zimma's review determines that the Release Trigger conditions have been satisfied, Zimma will:

Issue a Resolution Notice to both parties specifying the outcome and the basis for it;
Release the Escrow Funds to the Seller, less Zimma's applicable escrow service fee, within three (3) to five (5) Business Days of the Resolution Notice;
Update the Escrow Transaction status to "Completed" on the Zimma platform.

11.3 Partial Resolution — Split Outcome

Where the Evidence establishes that the Seller delivered part but not all of the agreed goods or services, Zimma may — where both parties agree in writing through the platform — facilitate a proportionate split of the Escrow Funds, releasing a share to the Seller and returning the balance to the Buyer, after deducting Zimma's applicable fee. Such a partial resolution requires the affirmative written agreement of both parties before it can be implemented.

11.4 Unresolved Disputes

Where Zimma is unable to determine the outcome of a Dispute as described in Section 9.4, Zimma will freeze the Escrow Funds and notify both parties that they must seek resolution through alternative means. The Escrow Funds will remain frozen until:

A court of competent jurisdiction issues an order directing the release or return of funds;
Both parties reach an agreement and submit a joint instruction through the platform;
The matter is resolved through a regulatory determination; or
Applicable law otherwise provides for the disposition of the frozen funds.

12. AUTOMATIC CLOSURE AFTER DISPUTE WINDOW

12.1 Where No Dispute Is Raised

Where the Buyer neither confirms satisfaction nor raises a Dispute within the Dispute Window, Zimma will follow the procedure described in Section 6.4, culminating in the automatic release of the Escrow Funds to the Seller upon expiry of the forty-eight (48) hour reminder period.

12.2 Notification Obligation

Zimma will send all notifications required under Section 6.4 to the Buyer via in-app notification and by SMS to their registered mobile number (sender ID: ZIMMA). The timestamp of each notification will be recorded by Zimma. Zimma's notification obligation is fulfilled upon dispatch to the Buyer's registered contact details; Zimma is not responsible for notifications that are unread or undelivered due to the Buyer's failure to maintain access to their registered mobile number or Zimma account.

13. FUND HANDLING DURING A DISPUTE

13.1 Immediate Hold

Upon registration of a Dispute by either party, Zimma will immediately place the Escrow Funds on hold in the Escrow Account. No release or return of the Escrow Funds will occur while a Dispute is active, except by operation of the outcomes described in Section 11 or by court order.

13.2 Funds Remain Segregated

Escrow Funds held during a Dispute remain in the Escrow Account maintained with United Bank Limited (UBL), IBAN: PK17UNIL0109000358906012, and are not commingled with Zimma's operating funds. The existence of a Dispute does not affect the segregated nature of the Escrow Funds.

13.3 No Interest Accrual

Escrow Funds held during a Dispute do not accrue interest, and neither the Buyer nor the Seller is entitled to any mark-up or return on held funds, regardless of the duration of the Dispute.

13.4 AML/CFT Hold

Where Zimma places an additional hold on Escrow Funds for AML/CFT reasons, that hold operates independently of the Dispute hold and may continue even after the Dispute is resolved. Zimma may be legally prohibited from disclosing the existence or basis of an AML/CFT hold to the affected User (tipping-off prohibition under the AML Act 2010).

14. BAD FAITH DISPUTES AND ABUSE OF PROCESS

14.1 What Constitutes a Bad Faith Dispute

A Dispute will be treated as made in bad faith where it is:

Raised on false, fabricated, or materially altered Evidence;
Raised for the primary purpose of delaying the release of Escrow Funds to a Seller without a genuine basis for the claim;
Duplicative — that is, raising the same Dispute a second time after a Resolution Notice has been issued, without new Evidence or a change in circumstances;
Raised by a Buyer who has, in fact, received the goods or services in the condition agreed in the Transaction Terms but is withholding confirmation to extract a discount or additional benefit from the Seller;
Raised in circumstances where the Buyer has already agreed outside the platform to accept the delivery.

14.2 Consequences of Bad Faith Disputes

Where Zimma determines that a Dispute has been raised in bad faith, Zimma may:

Dismiss the Dispute and proceed to release the Escrow Funds to the Seller;
Suspend the Claimant's account pending investigation;
Permanently close the Claimant's account where the bad faith conduct involves fraud or fabrication of Evidence;
Report the matter to law enforcement authorities under PECA 2016 where the conduct involves the submission of false documents or electronic fraud.

14.3 AML Implications

Where a Dispute reveals that the underlying Escrow Transaction was structured to facilitate money laundering or any other financial crime, Zimma will freeze the Escrow Funds and file a Suspicious Transaction Report (STR) with the Financial Monitoring Unit (FMU) in accordance with the AML Act 2010 and the SECP AML/CFT Regulations 2018, regardless of which party raised the Dispute.

15. PLATFORM COMPLAINTS AGAINST ZIMMA

15.1 How to Submit a Platform Complaint

Users who wish to raise a Platform Complaint against Zimma must submit their complaint through:

The in-app support function within the Zimma application; or
Email to hello@zimma.com.pk with subject line: "Platform Complaint — [Brief Description]".

All Platform Complaints should include:

The User's full name and registered mobile number;
The Ticket Number of any related Escrow Transaction, if applicable;
A clear description of the complaint, including dates, amounts, and screenshots where relevant;
The outcome the User is seeking.

15.2 Acknowledgement

Zimma will acknowledge receipt of all Platform Complaints within the acknowledgement timelines specified in Section 10 and will assign a Ticket Number for each complaint.

15.3 Fee Dispute Resolution

Where a Platform Complaint involves a contention that Zimma has incorrectly charged its escrow service fee:

Zimma will review the transaction record and the Schedule of Charges applicable at the time of the transaction;
Where the overcharge is confirmed, Zimma will refund the excess amount to the affected User within three (3) Business Days of confirmation;
Where the charge is confirmed to be correct, Zimma will provide the User with a written explanation referencing the applicable Schedule of Charges.

15.4 Platform Error Resolution

Where a Platform Complaint reveals a technical error on Zimma's part that resulted in a financial discrepancy, Zimma will:

Investigate the error within three (3) Business Days;
Correct the error within one (1) Business Day of its determination, consistent with Section 37 of the PS&EFT Act 2007;
Notify the affected User in writing of the correction and the amount restored.

16. ESCALATION TO REGULATORY AUTHORITIES

16.1 Internal Process First

Users are required to raise their Dispute or Complaint with Zimma in the first instance and allow Zimma's internal resolution process to run before escalating to a regulatory authority.

16.2 Right to Escalate

Where a User is not satisfied with Zimma's Decision or with Zimma's handling of a Platform Complaint, they retain the right to:

File a complaint with the Securities and Exchange Commission of Pakistan (SECP), which exercises regulatory oversight over Zimma as a SECP-registered private limited company:

Securities and Exchange Commission of Pakistan (SECP)

SECP Building, Constitution Avenue, Islamabad

Website: www.secp.gov.pk

Refer a transaction-level complaint to the State Bank of Pakistan (SBP) under Section 71 of the PS&EFT Act 2007, where the complaint relates to an electronic fund transfer matter within the SBP's jurisdiction;
Pursue the matter through the courts of competent jurisdiction in Islamabad, Pakistan.

16.3 Zimma's Cooperation

Zimma will cooperate fully with any regulatory investigation, inquiry, or direction arising from a user complaint escalated to the SECP or SBP. Zimma will provide all requested records, documentation, and information within the timeframes specified by the relevant regulatory authority.

17. NON-BINDING NATURE OF ZIMMA'S DECISION

17.1 Administrative Nature

Zimma's Decision on any Escrow Transaction Dispute is an administrative determination made by Zimma in its capacity as Escrow Agent. It is not a judicial decision, an arbitral award, or a legally binding determination of the parties' rights and obligations under the laws of Pakistan.

17.2 Right to Legal Remedy

Either party remains entitled, regardless of Zimma's Decision, to pursue their legal rights against the other party through the courts of competent jurisdiction in Islamabad, Pakistan. Zimma's Decision does not constitute res judicata, issue estoppel, or any other bar to legal proceedings between the Buyer and the Seller.

17.3 Zimma Not a Party

Zimma is not a party to any legal proceedings between the Buyer and the Seller arising from an Escrow Transaction, except where Zimma is independently named as a defendant in relation to its own conduct as Escrow Agent.

17.4 Records Available for Legal Proceedings

Upon written request by either party or by order of a court of competent jurisdiction, Zimma will make available the transaction records, Dispute submissions, Evidence, and Resolution Notice associated with a particular Escrow Transaction. Such records constitute electronic records admissible in evidence under Section 5 and Section 6 of the Electronic Transactions Ordinance, 2002, and constitute prima facie evidence of the transaction under Section 34 of the PS&EFT Act 2007.

18. RECORD RETENTION

18.1 Dispute Records

Zimma will maintain complete records of all Escrow Transaction Disputes and Platform Complaints — including all submissions, Evidence, correspondence, Decisions, and outcomes — for a minimum of five (5) years from the date of resolution, in accordance with Section 15 of the SBP Electronic Fund Transfer Regulations and the SECP AML/CFT Regulations 2018.

18.2 Extended Retention for Legal Proceedings

Where a Dispute record is subject to ongoing legal proceedings, a regulatory investigation, or a court order, Zimma will retain the relevant records until the matter is finally resolved, regardless of whether the standard five (5) year retention period has expired.

18.3 Escrow Transaction Records

All underlying escrow transaction records — independent of whether a Dispute was raised — are retained for a minimum of ten (10) years from the date of the transaction, in accordance with Section 12 of the SBP Rules for Payment System Operators and Payment Service Providers and Section 7 of the PS&EFT Act 2007.

18.4 User Access to Records

Users may request a copy of their own Dispute records by submitting a written request to hello@zimma.com.pk, subject to the identity verification requirements described in Zimma's Privacy Policy. Zimma will respond to such requests within thirty (30) calendar days.

19. AMENDMENTS TO THIS POLICY

Zimma reserves the right to amend this Dispute Resolution Policy at any time to reflect changes in its operational processes, Applicable Laws, or regulatory requirements. Any material amendment will be notified to registered Users via in-app notification and by SMS to their registered mobile number at least twenty-one (21) days before the amendment takes effect, consistent with the requirements of Section 31(1) of the PS&EFT Act 2007. An amendment will not affect any Dispute that has been formally registered and is in active review at the time the amendment takes effect.

20. CONTACT

For Dispute submissions, Platform Complaints, or any queries regarding this Policy, please contact us:

Zimma Solutions (Private) Limited

House 1123, Street 10, G-14/4

Islamabad Urban, ICT 42600, Pakistan

Email: hello@zimma.com.pk

Website: www.zimma.com.pk

This Dispute Resolution Policy is published in English and constitutes the legally binding version. In the event of any conflict between this Policy and any translated or summarized version, the English version shall prevail.

Governing Law: Islamic Republic of Pakistan | Jurisdiction: Courts of Islamabad, Pakistan