Complaints Procedure

1. INTRODUCTION

Clearcrest Inc. UAB (“Clearcrest” or “we”, “us”, “our”) is a licensed crypto-asset service provider in Lithuania. We provide high-quality crypto-assets exchange services focusing on crypto-asset wallets, enabling the exchange between fiat currency and crypto-assets, as well as among different crypto-assets (“Services”). We give top priority to your experience, and we are committed to paying due regard to the interests and needs of each and all of you, including fair, clear and not misleading communication.

As part of these arrangements, we employed complaints handling procedures to ensure that any complaints are resolved as quickly as possible and, where necessary, trigger an internal review into the quality of Service being provided and whether or not it can be improved.

Below you will find a procedure, that indicates main principles and guidance to be followed in the event you are not satisfied with our Services and would like to file a complaint to us.

2. INITIATION OF COMPLAINT

We consider a complaint as an expression of dissatisfaction of our Services, irrespective of whether it is justified or not, related to our products / Services or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected. 

An eligible complaint may be made by any person who is directly affected by the way we have provided our Services and who can make a complaint in respect thereof. Therefore, you may file the complaint respectively to us, if you are: 

• individual client (natural person) that uses our Services, or
• a legal representative of any individual client of ours.

Our employees are always conscious that, although an ineligible complaint may be made, the issue raised may still have an impact on the quality of our Services, therefore on such a complaint and, our respective employees will still seek to review and to respond to all of such complaints on a case-by-case basis.

3. COMPLAINTS HANDLING PROCEDURE

1. File a complaint
   1. If such situation would occur under which you find yourself dissatisfied with our Services, at all times you are able to express your complaints via the following means:

      1. Via E-mail: as a first instance for simple daily and / or operational questions / issues via e-mail: complaints@coinsdrom.com. The complaints received in this instance are addressed by our Customer Support Team Lead. If the Customer Support Team Lead cannot assist you with a variety of issues quickly and efficiently or, on the rare occasions they are not able to assist directly, the complaint you filed will be able to escalated to our Chief Compliance Officer;
      2. Via the Customer service portal on the web https://ticket.coinsdrom.com/en/knowledgebase/article/filing-a-formal-complaint ticketing system;
      3. Via post by sending the complaint by post to our address at: Lvivo g. 21A, LT-09313, Vilnius, Lithuania.

   2. To help us investigate and resolve complaints effectively, competently, diligently and impartially, you will be instructed to provide the following information:

      1.  your full name, address, e-mail address and contact phone number(s);
      2. a description of the complaint (i.e., a description of the issue, the date and time that the issue occurred, your willingness on how it would consider the complaint would have to be resolved, etc.);
      3. any additional documentation or information that may support the complaint.

   3. Aiming for the most efficient complaint handling procedure, we recommend submitting your complaint using the complaint form, which can be accessed here (download the form) However, we may also accept other form for complaints purposes as it may be deemed convenient for you. In such case, please make sure that you indicate all circumstance in detail for you to understand the subject matter and other key details as well as the main problem(s) of the complaint, aiming to provide feedback to you.

   4. Your complaint will be communicated to our Customer Support Team Lead and the Chief Compliance Officer (if needed) immediately or as soon as practicable, upon receipt of the complaint. 

   5. You may file the complaint in Lithuanian, English or in any official language of the European Union, which is also an official language of the Member State of the European Union where our Services are provided.
   6. Filing of the Complaint is free of charge. Should you require assistance in making / filing the complaint, reasonable assistance may be provided from our side free of charge and in a timely manner by our Customer Support Team.

2. Send acknowledgement to the complaint
   1. Upon receipt of any complaint, our respective department will be responsible for acknowledging your complaint within 48 (forty-eight) hours. You will receive a written acknowledgment of the complaint received. Such acknowledgment will include information about estimated timeframes for our response to your complaint.
3. Reviewing / Assessment of complaint
   1. We will carefully evaluate the complaint and other related departments, if any, to ensure a high-quality response within an appropriate time, which will include the consideration of the complaint and whether this can be resolved immediately or whether an investigation is required.
   2. When reviewing your complaint, we will pay due regard to the interests of yours and treat you fairly, assessing the following matters:
      1. whether complaint is clear and contains all relevant information necessary for the handling;
      2. subject of the complaint;  
      3. whether the complaint should be upheld;  
      4. that remedial action and / or redress may be appropriate for you;  
      5. the root cause of the complaint; and
      6. whether the complaint could have been prevented.
   3. If the investigation results shows that the root cause of the complaint is because of our system or operational flaws, this should be identified and acknowledged and, where appropriate, a restitution may be offered to you.
   4. If the investigation concludes that the subject matter of the complaint was not caused by any negligence, willful misconduct or default of ours or it was caused by inevitable and unpredictable factors, we will explain this to you by providing you with the relevant information or facts on which the investigation conclusion has based.
4. Prioritization of complaints
   1. To ensure a structured and effective complaint handling process, we prioritize complaints based on their potential impact on our Services, you and our regulatory obligations. Complaints that pose a higher risk, such as legal violations, data breaches, or significant financial losses, are handled with urgency, while lower-risk complaints follow our standard complaint resolution process.
5. Communication with you
   1. After assessing the complaint and / or conduction of an investigation against the complaint, we will issue a final response with its findings and the proposed solutions (if any) to you via the same communication channel that you used to submit the complaint, unless you will request us to use a different method (form) of response. 
   2. Notably, you will always be answered in writing. We aim to provide a response to your complaint within 14 business days starting from the date of receiving the complaint. However, if your complaint relates to a potential fraud case, it will be prioritized, and a response will be provided within 10 calendar days from the date of receipt. In exceptional cases, where the complaint cannot be resolved within the standard timeframes as indicated earlier, we will notify you thereof and indicate the circumstances of the delay in submitting the complaint, as well as the term by which the complaint will be examined and provided to you. In any event, the total resolution period will not exceed 35 business days from the date of submission your complaint.
   3. In case when the resolution provided and your complaint is rejected or partially satisfied, we oblige to state the reasons for the refusal to satisfy the complaint, indicate other means of protection of the interests of your, if possible, including but not limited to possible means of dispute settlement and courts.
6. Additional investigations
   1. In the event you are not satisfied with the response provided by us, additional investigations and / or remedies may occur. Additional investigations and questions related to it may be referred to the board or other responsible body of the company for further decision. 
   2. If you are still not satisfied with our response, you may be entitled to report complaint to the local governmental authority, which acts as a supervisory authority of ours, i.e., the Bank of Lithuania. You may submit a complaint to the Bank of Lithuania within 1 (one) year period from the date of the final response of ours, in Lithuanian or English language, by filling in the application form as specified in the website of the Bank of Lithuania and sending it in writing or by electronic means to the Bank of Lithuania to this address: Totorių g. 4, LT-01121 Vilnius, Lithuania, or via email: info@lb.lt. 
   3. However, you should be aware that depending on the background of the complaint, different governmental authorities may be responsible for handling such complaints (i.e., the State Consumer Rights Protection Authority).
7. Closing the Complaint & Record keeping
   1. We will consider a complaint as resolved, when:
      1. we have sent a final response; or
      2. you have accepted any redress offered, in writing.
   2. We keep and maintain a complaint registry each complaint received. The information kept on record includes:
      1. your name;
      2. date and description of the complaint;
      3. email address associated with you and your user profile;
      4. in certain cases, your user profile ID number and phone number associated with your user’s profile;
      5. when applicable, personal data of your legal representative;
      6. date and method of receipt of the complaint;
      7. date of the reply to you;
      8. ongoing status report;
      9. general information about the complaint, with short content;
      10. Service or products addressed in the complaint;
      11. any redress offered by us;
      12. final decision; and
      13. the copies of documentation(s) and all relevant communication with you.
   3. We will resolve the complaint and will ensure to keep copies of relevant electronic correspondence in our record keeping system, the material related to the complaint and its examination, the document indicating the specific result of the examination of the complaint and the answer provided to you. Such records shall be kept within our date base for at least 5 (five) years from the date of submission of the final answer to you.
8. Learning from experience
   1. Any specific findings from complaints which can be directly addressed and used to increase your satisfaction will be considered. Root cause analysis, correction and enhancement will be put into system products and / or operational procedures to prevent future errors and increase your satisfaction.

4. REDRESS AND COMPENSATION

In cases where complaint is upheld, we acknowledge our responsibility and we may issue an apology as an appropriate redress.

5. OTHER

In case any questions arise, you can always contact us via email support@coinsdrom.com,   or on our web https://coinsdrom.com/.