Complaints Handling Policy

Last review: 2025.03.05

1. INTRODUCTION

1.1. The objective of this Complaints Handling Policy (the “Policy”) is to establish Client’s Complaints handling procedure of Cryptonis UAB (the “Company”, also referred to as “we”, “us” or “our”) including rules for filing, registering, examining, and providing answers to Complaints submitted to the Company by its Clients.
1.2. The Complaints handling procedures shall be understood as procedures conducted on the basis of Complaints filed by the Company’s existing and (or) potential clients claiming violations of their rights and (or) legitimate interests in the Company’s activities and (or) provision of services.
1.3. This Policy is prepared in accordance with the requirements of European Union regulations, the laws of the Republic of Lithuania, and other applicable laws, rules, guidelines, or internal documents of the Company governing this activity. It applies to the extent that the Company is providing payment and/or other licensed services to its Clients.
1.4. This Policy applies to all bodies and employees of the Company, who organize or are involved in the Complaints handling procedure, or whose work is otherwise related to the implementation of the complaints handling function (including any outsourced service providers).

2. GLOSSARY

2.1. Complaint – a written request or statement of the Client addressed to the Company, stating that in the Client’s rights and (or) legitimate interests have been violated in relation to the services provided by the Company or agreements concluded with the Company and asking for satisfaction of the expressed claims.
2.2. Client – a legal entity or individual to whom the Company provides payment services or with whom the Company has entered into an agreement, and who has submitted a Complaint to the Company. For the purposes of this Policy, “Client” also includes any other party that has filed a Complaint concerning the Company’s services or agreements, such as a client of another financial market participant, a prospective client, etc.
2.3. Complaints Register – the complaints registration log of the Company maintained in electronic form.
2.4. Response to the Complaint – a written answer to a Client’s complaint.
2.5. Responsible Person – an employee or officer of the Company assigned as responsible for handling a Complaint with the Client.
2.6. Supervisory Authority – the Bank of Lithuania (www.lb.lt).

3. APPLICABILITY

3.1. The Company recognizes its responsibility to address all Client Complaints promptly, clearly, transparently, and constructively, ensuring a fair and effective process for Clients’ Complaints handling process.
3.2. This Policy applies exclusively to Complaints from Clients regarding the provision of the Company’s licensed products and services. The following instances are not deemed Complaints, and this Policy does not apply to them:
3.2.1.Complaints about the Company’s activities that are not governed by specific laws or are outside the Supervisory Authority’s oversight (i.e., unrelated to licensed services);
3.2.2.Complaints related to activities for which the Company holds no responsibility.
3.3. In case the Company is not responsible for the performance of the activity indicated in the Complaint (as provide in clause 3.2.2., the Company shall reply to the Client by indicating reasons for a refusal to accept and examine the Complaint, as well as, if possible, specifying the responsible person or institution for dealing with such Complaint.

4. SUBMISSION AND ACCEPTANCE OF COMPLAINTS

4.1. A Client who believes that the Company has infringed upon their contractual rights or legitimate interests related to licensed services must contact the Company and submit a Complaint, detailing the circumstances of the dispute, presenting their claim, and including any relevant supporting documents that validate the claim, if available.
4.2. Filing a Complaint and the subsequent handling process at the Company are free of charge.
4.3. Complaints may be submitted to the Company in either Lithuanian or English. The Client may also submit a Complaint via a duly authorized representative.
4.4. Clients can submit a Complaint in writing, using any of the following methods:
4.4.1.By postal mail to the Company’s office at Gaižiūnų g. 4, LT-50126, Kaunas, Republic of Lithuania; or
4.5. By email to: legal@cryptonix.com.
4.6. Only Complaints meeting the following criteria will be registered and considered for review:
4.6.1.The Complaint must be legible.
4.6.2.The Complaint must contain:

The full name of the Client, along with the name and surname of the individual acting on behalf of the Client (if applicable), and their authority to act on the Client’s behalf (if applicable). When a Complaint is submitted by an authorized representative, it must be accompanied by a document verifying this authorization, such as a power of attorney.
The Client’s contact information (email address, mailing address, and phone number).
The date the Complaint was submitted.
The preferred method for receiving a response, if different from the submission method (e.g., via postal mail or email).
A clear description of the Complaint, including details of the actions taken by the Company, its employees, or representatives, specific claims made by the Client, and any supporting documents (e.g., payment orders, account statements) that establish the facts related to any alleged damages, if applicable.
Any other relevant circumstances surrounding the Complaint.

4.7. If necessary for handling the Complaint or providing a response, the Company will verify the identity of the Client (or their representative) and may request additional information to confirm their identity.
4.8. Information provided by email, fax, or any other telecommunication method capable of verifying transmission will meet the requirement to provide written information as per this Policy.
4.9. If a Complaint does not meet the requirements of this Policy, is written in a language other than Lithuanian or English, is disorganized, unreadable, or lacks clear Client identification, the Representative should, if feasible, take proactive steps to assist the Client. This may include reaching out to the Client to clarify the necessary details or advising on corrective actions to submit a compliant Complaint. If these issues cannot be resolved, the Company may decline to review the Complaint and will inform the Client in writing within five (5) business days of receipt. Anonymous Complaints, or those missing the Client’s name and surname, will not be accepted or returned to the Client.

5. REGISTRATION

5.1. All Complaints submitted in compliance with the procedures outlined in this Policy shall be recorded in the Company’s Complaints Register by the Compliance Department delegated employee.
5.2. The following details must be documented in the Complaints Register at all times:

The Client’s full name;
The address provided by the Client in the Complaint;
The date and method of the Complaint submission;
A brief summary of the Complaint;
The specific services or products of the Company involved in the Complaint, including their types;
The date the Company issued its response to the Complaint;
The final outcome (decision) of the Complaint investigation.

5.3. The Company’s Complaints Register is included as Annex 1 to this Policy.

6. EXAMINATION OF COMPLAINTS

6.1. Throughout the Complaint handling process, all Company employees shall maintain confidentiality and adhere to the principles of fairness, reasonableness, objectivity, and impartiality.
6.2. Complaints shall be managed by a suitably qualified employee from the Compliance Department, who is assigned to handle the specific Complaint and was not previously involved in the matter being complained about, in accordance with the timelines set forth in this Policy.
6.3. To investigate the Complaint, the Responsible Person shall have the following authority:

Gather and assess all necessary documents and information;
Review historical data related to the Client;
Communicate with the Client to request additional information, if needed;
Consult other Company employees or seek assistance from other departments within the Company, as necessary.

6.4. The Responsible Person shall adequately document the Complaint investigation process to demonstrate the extent and details of the investigation, if required.
6.5. If a Complaint is found to involve other areas or departments of the Company, the assigned Responsible Person shall retain full responsibility for the Complaint. They must collaborate with the relevant departments to prepare a response.
6.6. If, during the investigation, it is determined that additional explanations or documentation are required from the Client, the Company shall request these from the Client in writing, specifying a deadline for submission. During this period, the response timeline set forth in this Policy will be suspended until the requested information is received. Should the Client fail to provide the required information within the specified timeframe, the Company will proceed to respond to the Complaint based on the information available, following the timeline established in Clause 7.1 of this Policy.

7. PROVIDING RESPONSES TO COMPLAINTS

7.1. The Company must review and investigate the Client’s Complaint and, within a maximum of 15 business days from the date of receipt, provide a detailed, reasoned, and documented written Response. In exceptional cases where circumstances beyond the Company’s control delay the Response beyond 15 business days, the Responsible Person shall send an interim written notice to the Client, explaining the reason for the delay and indicating the anticipated date of the final Response. In any event, the Complaint must be fully addressed, and a Response provided to the Client no later than 35 business days from its receipt.

7.2. At any stage during the Complaint review, the Client retains the right to withdraw their claim and cancel the Complaint. If the Client chooses to do so, the Company will terminate its investigation.
7.3. The Responsible Person shall make a decision on the Response to the Complaint, including whether the Complaint will be upheld or dismissed, except in cases specified in clause 7.4.
7.4. If, upon investigation, the Complaint is found to meet any of the following criteria: (i) involves a claim exceeding EUR 1 500 (one thousand five hundred euros) or equivalent, (ii) contains allegations of fraud or gross negligence by the Company, (iii) poses a significant reputational risk to the Company, or (iv) alleges a breach of information security or privacy laws – the Responsible Person must notify the CEO and transfer all relevant materials and information regarding the Complaint. In such cases, the CEO will review the Complaint, prepare a written recommendation, and forward it, along with all supporting documentation, to the Management Board for a final decision.
7.5. Based on a comprehensive review of the Complaint’s circumstances and in line with applicable Lithuanian laws and this Policy, the Responsible Person or Management Board shall make one of the following determinations:

Fully uphold the Complaint;
Partially uphold the Complaint;
Reject the Complaint.

7.6. If the Company decides to partially uphold or reject the Client’s Complaint:
7.6.1. The Company’s response will provide a reasoned explanation based on applicable legal provisions, supported by relevant documentation (e.g., copies of contracts with the Client, documents received from the Client, etc.), as applicable. The response will also include information on other available remedies for the Client, such as the option to pursue court action in accordance with applicable laws.
7.6.2. The response will inform the Client that, if dissatisfied with the Company’s decision, they may escalate the Complaint to the Bank of Lithuania or appeal directly to the court.
7.6.3. The response will additionally advise the Client that any Complaint submitted to the Bank of Lithuania must be filed within one year of submitting the Complaint to the Company. The Complaint may be submitted to the Bank of Lithuania via:

The electronic dispute settlement platform (epaslaugos.lt);
By mail to Totorių g. 4, Vilnius, Lithuania;
Via email at prieziura@lb.lt.
Further information on the dispute resolution process at the Bank of Lithuania can be found at https://www.lb.lt/en/dbc-settle-a-dispute-with-a-financial-service-provider.

7.7. The Company’s decision will be submitted to the Client in writing and in the language in which the Complaint was submitted by the Client.
7.8. The Company shall register each Response to the Complaint in the Complaints Register.
7.9. The original of Company’s Response to the Complaint (including any attachments) shall be delivered to the Client in the same manner as the Complaint was submitted unless otherwise requested by the Client in the Complaint.

8. COMPLAINT CONTROL AND ARCHIVING

8.1. The Compliance Department of the Company shall oversee ongoing control of Complaints and responses, conducting the following actions by the 7th day of each calendar month:
8.1.1. Review entries and data in the Complaints Register, and
8.1.2. Monitor the progress of Complaint processing and deadlines for responses.
8.2. The CEO will gather information from the Compliance Department on Complaints received during the reporting period, analyze this data to identify root causes, prioritize solutions, and prepare a periodic report for the Board of Directors containing:

Number of Complaints received;
Root causes of Complaints;
Products related to Complaints;
Details on recurring or systemic issues linked to specific services or products;
Other affected processes or products;
Priorities for corrective actions;
Proposals for corrective actions to address root causes.

8.3. The Management Board will review Complaint data quarterly to ensure root causes are identified, insights are gained, and operational adjustments are made. To support this, the CEO shall submit a quarterly report on Complaint handling, as outlined in 8.2, to the Management Board.
8.4. Upon receiving and reviewing the report (referenced in clause 8.2), the Management Board shall:
8.4.1.Collect information on similar Complaints related to specific services or products and analyze it to identify root causes and prioritize remedies;
8.4.2.Assess whether root causes of certain Complaints might impact other services or products;
8.4.3.Determine the feasibility of eliminating root causes and decide on methods to address them;
8.4.4.Initiate corrective actions, if necessary, to eliminate identified root causes.
8.5. The CEO will maintain records of Complaint numbers, categorized by reasons and outcomes (received, examined, upheld, partially upheld), and provide this information to the Bank of Lithuania upon request.
8.6. Records of the Management Board’s analysis and decisions on corrective actions for operational deficiencies in the Complaint handling process will be retained for at least three years.
8.7. All Client Complaints, related investigation details, responses, and/or response copies indicating the outcome of the Complaint handling process will be archived for a minimum of three years from the date of the final response to the Client.

9. PUBLISHING INFORMATION ON THE COMPLAINTS HANDLING PROCEDURE

9.1. The Company ensures that this Policy, along with relevant details about the Complaint submission process, is publicly accessible on the Company’s website www.cryptonix.com and can be provided in writing to any Client upon request. The information available to Clients will include:
9.1.1. Required details that the Client must include in the Complaint;
9.1.2. Contact information for the individual or department to which the Complaint should be directed;
9.1.3. The time frame within which the Company will review the Complaint;
9.1.4. Information on the Client’s option to approach a competent authority to review the Complaint;
9.1.5. A statement that the Complaint handling process is free of charge.
9.2. The Company is responsible for compiling data on the number of received Complaints, categorized by reasons for rejection and outcomes of the Complaint handling process (e.g., received, investigated, upheld, partially upheld), and must submit this data to the Bank of Lithuania upon request.

10. FINAL PROVISIONS

10.1.This Policy, along with any amendments to its provisions, will take effect on the date it is approved by the Company’s Management Board.

10.2.The Policy must undergo an annual review by the Compliance Department, who will submit any proposed amendments to the Management Board. All modifications to the Policy must be documented in writing and will only become effective once they receive formal approval from the Management Board.

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