1. Introduction
This Factual Correction Policy describes how Maven Pay Inc. and the MavenPay group handle a factual statement we have published that turns out to be inaccurate, misleading, or out of date. It supplements our Corrections Policy. The Corrections Policy covers operational corrections to records, transactions, and content. This Policy covers the specific case of a published factual statement that may have misled the public.
We publish factual statements on the MavenPay marketing site, in the MavenPay product, in our help centre, in our blog, in our developer documentation, in our press releases, in our investor and partnership materials, in our regulatory filings made publicly available, and in any other surface that members of the public can read.
2. Our Commitment
When a factual statement on a MavenPay surface is wrong, we correct it. We label the correction clearly, we date the correction, we explain what was wrong, we explain what is now correct, and we leave the correction note visible for the life of the page. We do not silently rewrite a published statement.
If the factual statement appeared in material we provided to a regulator, an auditor, a journalist, an analyst, or any other party who may have relied on it, we tell that party about the correction at the same time we publish it.
3. What Qualifies As A Factual Statement For This Policy
A factual statement is a claim that can be objectively verified as true or false. Examples include a regulatory status, a registration number, the existence of a feature or partnership, a price or fee level, a date, an aggregate metric, a security certification, or a published commitment.
This Policy applies to a factual statement we made on a MavenPay surface. It does not apply to opinions, to predictions, to forward-looking statements, to marketing language that uses figurative wording, or to factual statements made by third parties that we did not endorse.
4. When A Correction Is Required
A correction is required when a factual statement on a MavenPay surface is inaccurate, when it is technically accurate but reasonably misleading in context, when it is out of date in a way that may mislead a reader who relies on it today, or when it omits a material fact whose absence makes the statement misleading.
A correction is not required when a statement was accurate at the time it was made and remained accurate until the underlying fact changed, provided that the page makes clear when the statement was made and that we apply our routine refresh process when the underlying fact changes.
5. How To Report A Factual Statement That May Be Wrong
Write to corrections@mavenpay.com. Tell us the page or surface where the statement appears, the specific statement that is wrong, the reason you believe it is wrong, and any evidence you have. A clear plain-language message is enough.
We acknowledge the report within two business days.
We investigate and respond within ten business days. If the investigation takes longer, we tell you the reason and a revised timeline. We do not delay an investigation as a tactic.
6. What We Publish When We Make A Correction
When we agree the statement was wrong, we publish a correction on the same surface where the statement appeared. The correction includes the following elements.
A clear label that the page has been corrected.
The date the correction was made.
A plain-language description of what the original statement said and what was wrong with it.
A plain-language description of what the corrected statement says now.
A brief description of how the error came to be, where the description is not itself sensitive or subject to a confidentiality obligation that the law respects.
We do not edit the surface to make it appear that the original statement never existed. We do not remove the correction note without disclosure.
7. Proactive Corrections
We also correct factual statements that we discover ourselves through internal review, audit, monitoring, or routine refresh. When we do, we apply the same standard. We label the correction, we date it, we explain what was wrong, we explain what is now correct, and we leave the note visible.
8. Corrections That Affect Regulatory Filings
Where the corrected statement was contained in a regulatory filing or a regulatory disclosure that we made public, we file the appropriate amendment or supplementary disclosure with the competent authority at the same time as the public correction. We do not wait to be asked.
9. Corrections That Affect Third Parties Who Published Our Statement
Where a journalist, an analyst, a research firm, a partner, or any other third party published our factual statement and we later correct it, we notify that third party at the same time as the public correction. We provide a plain-language explanation of the change so they can update their own publication if they choose to.
10. Escalation
If you reported a factual statement and you disagree with our response, you can ask us to escalate the matter. We escalate to our Compliance Officer. The Compliance Officer reviews the original report, our response, and the underlying evidence, and provides a written decision within ten further business days.
Where the matter relates to a regulatory disclosure, the Compliance Officer's review is documented and is available to the relevant competent authority on request.
11. Record Keeping
We keep a record of every factual-correction report we receive, the decision we took, the correction we made or did not make, and the date of each step. We retain those records for the period required by the law that applies to the underlying record. The records are available to the relevant competent authority on request.
We publish an annual summary of factual-correction volumes and themes on the same surface as this policy. The summary does not name reporters and does not identify individual cases in a way that would breach confidentiality.
12. Fairness
We do not treat a reporter differently because the reporter raised a correction request. We do not refuse to engage on the substance of a report because of the identity of the reporter. We do not require a reporter to identify themselves. We do not require a reporter to accept a confidentiality undertaking that goes beyond what the law allows.
13. Contact
For a factual-correction report, write to corrections@mavenpay.com.
For an escalation, write to compliance@mavenpay.com and ask for a factual-correction escalation.
14. Changes To This Policy
We may update this policy from time to time. When we make a material change, we will tell you in the MavenPay product or by email at least thirty days before the change takes effect. The current version of this policy and its effective date are shown at the top of this page.
