Pravidlá vyšetrovania sťažností Neoalex

I. GENERAL PROVISIONS

1. These complaint investigation rules (Rules) establish the rules and procedures by which Neoalex (Platform) is governed when investigating complaints from clients or potential clients (Applicant) regarding financial services provided by the Company and/or concluded contracts (Complaint).

2. The rules are drawn up in accordance with the Act on Electronic Money and Electronic Money Institutions.

II. SCOPE OF THE COMPLAINT

3. The Rules apply to all Complaints received by the Company (its representatives) through the communication channels listed in Part III „COMPLAINING PROCEDURE“ of the Rules.

4. The following types of messages are not considered Complaints:

4.1. complaints regarding the activity of the Company, which is not regulated by special laws and is not supervised by a supervisory authority;

4.2. complaints regarding activities for which the Company is not responsible;

4.3. requests for payment identification or payment orderer / entity depositing funds into the client’s account;

4.4. requests for the mediation of a refund or for the identification of the recipient of the payment;

4.5. requests for a copy of a proof of payment or transaction;

4.6. requests for data on the payer or payment specification;

4.7. proposals to modify or improve the Company’s services;

4.8. proposals for the modification of documents issued and (or) proposed by the Company in connection with the provision of the service.

5 In the event that the Company is not responsible for the performance of the activity specified in the complaint, the company will respond to the client stating the reasons for refusing to accept and review the complaint, and if possible, also indicate the responsible person. to address such complaints.

III. COMPLAINT SUBMISSION PROCEDURE

6. The complaint will be provided to the Company within 3 months from the day the Applicant learned or should have learned about the violation of his rights.

7. The complaint must contain the following information:

7.1. for natural persons – name, surname, date of birth, contact details (e-mail and/or telephone number). For legal entities – entity name, ID number, registered office, contact details (e-mail and telephone number);

7.2. the moment of violation of the Applicant’s rights (the moment when the Applicant believes that his rights have been violated);

7.3. a disputed matter. A clear description of the Company’s activities that led to the Complaint;

7.4. a description of the circumstances that led to the filing of the complaint.

8. The complaint must be submitted in Lithuanian or English and must be duly signed by the Applicant or his authorized representative.

9. The applicant is responsible for the correctness (ie correcting) of the personal and contact data specified in the Complaint and agrees that the Company will present all information related to the process of processing the Complaint through the contact data provided in the Complaint. For the sake of clarity, if the Interested Party provides his email address, the Company has the right to provide information and further communication via email.

10. The claim must be filed by the Applicant in person or his representative. The Applicant’s representative, together with the submitted Complaint, must submit documents proving identity and authorization: a copy of the identity card/passport of the authorized person and a written copy of the power of attorney proving the authority to represent the Applicant or another document proving the authority to act. on behalf of the Applicant.

11. The company may refuse to investigate a complaint if it was not filed in accordance with the procedures and rules set forth in this document. The client will be informed of such a refusal within 7 working days of the receipt of the complaint by the Company.

12. Processing claims and handling complaints in the company is free of charge.

13. In the event that the Applicant files a complaint due to the same circumstances or reasons as the Company previously presented and resolved to the same Applicant, the Company has the right to refuse to investigate this type of Complaint and inform the Applicant thereof.

14. Complaints are submitted through:

14.1. Registered mail sent to Štefánikova 13, Piešťany;

14.2. E-mail info@neoalex.org; .

IV. REGISTRATION OF CLAIMS

15. All Complaints received in the manner specified in these rules are recorded in the Company’s Complaint Log. Complaints are registered on the day they are received or the first following business day if the complaint was filed outside of business hours/after business hours.

16. The initial registration of the complaint is carried out by the employee of the Company who accepted the complaint. Subsequently, the complaint protocol will be completed by the employee entrusted with processing the complaint and preparing the response to the client.

17. The following information shall be recorded in the complaints log:

17.1. information specified in point 7.1 of the Rules;

17.2. representative data (if applicable);

17.3. date and method of receiving the Complaint;

17.4. a brief description of the Complaint;

17.5. services and/or activities of the Company that are the subject of the appeal;

17.6. the date of the Company’s response to the Applicant;

17.7. the Company’s decision and further procedure.

V. COMPLAINT INVESTIGATION AND DECISION

18. Complaints will be investigated in accordance with the principles of justice, fairness, adequacy, objectivity, impartiality and with regard to human rights. The Complaint investigation process must be properly documented.

19. Complaints will be investigated by the Company’s customer support department. The representative of the customer support department can, if necessary, request the cooperation of other structural components of the Company. Customer Support reserves the right to make the final decision at its sole discretion. The customer support department will request confirmation of the decision on the Complaint only if the Complaint:

19.1. contains a claim over EUR 1,000 (or equivalent);

19.2. alleges fraud, AML/CFT gross negligence on the part of the Company;

19.3. represents a significant reputational risk for the Company;

19.4. claims that information security or privacy laws have been violated.

20. The Company does not investigate Complaints that do not meet the requirements set forth in the Rules, are written in a language other than Lithuanian or English, are unorganized and illegible, the identity of the Applicant is not clear.

21. In the event that the submitted Complaint lacks information necessary for investigation, the Company has the right to call on the Applicant to eliminate the deficiencies of the Complaint by clarifying the essence of the Complaint or providing additional documents or data necessary for the investigation of the Complaint. In such a case, the Company sets a reasonable deadline, which cannot be shorter than 7 calendar days, to eliminate the deficiencies of the Complaint. If the Applicant removes the deficiencies within the specified period, the Complaint is deemed to have been completed on the day the deficiencies were eliminated, i.e. the day the Company was provided with the said Complaint or the necessary documents.

22. If the Complaint does not meet the requirements stated in this document, the Company will not investigate the Complaint and will return it to the Applicant or his representative.

VI. SUBMISSION OF THE RESPONSE TO THE APPLICANT

23. The complaint is investigated and an answer is provided as soon as possible, but no later than: (i) 16 calendar days from the date of receipt of the Complaint from the Applicant – consumer; and (ii) 30 calendar days from the date of receipt of the Complaint from other Applicants who are not considered consumers. The period begins to run from the day the Complaint is received. Exceptionally, when it is not possible to investigate the Complaint within the period specified in this provision, the Company must inform the Applicant and specify the circumstances and a new period within which the Complaint will be investigated and an answer provided.

24. The Company will investigate the Complaint in accordance with applicable laws and will make one of the following decisions:

24.1. comply with the Interested Party’s request;

24.2. partially comply with the Applicant’s request;

24.3. to reject the Complaint.

25. In the case of rejection of the Complaint or only partial satisfaction, the Company will state the reasons for the rejection in its response to the Applicant in order to fully comply with the Complaint and if the Applicant is a natural person and will be considered a consumer – the Applicant’s right to file a complaint with the Bank of Lithuania.

26. The Company’s decision on the Complaint is recorded in the Complaint Log and sent to the Applicant by registered mail and/or e-mail specified by the Applicant.

VII. FINAL PROVISIONS

27. The policy must be reviewed at least once a year by March 1. Any amendments to the Policy must be made in writing and will take effect upon approval by resolution of the relevant governing body.

28. The Customer Support Department will prepare and submit quarterly reports to the Company’s management, describe the main problems in the Complaints handling process and propose measures for improvement.

29. In order to determine the shortcomings of its activity and possible legal or operational risk, the Company continuously assesses the results of the investigation of Complaints. By carrying out this assessment, the company:

29.1. collects information about similar Complaints related to certain services or products, performs analysis of this information in order to identify the main reasons for these Complaints, as well as to determine priorities for eliminating these reasons;

29.2. assesses whether the substantive reasons for certain Complaints may lead to new Complaints regarding other services or products;

29.3. assess whether it is possible to remove the essential reasons for some Complaints and determine the methods of their removal;

29.4. if necessary, removes the main identified reasons for Complaints;

29.5. ensures that repeated or systemic reasons for Complaints are regularly reported to the Company’s executive and that the executive can effectively perform his functions and ensure that similar Complaints do not occur.

30. The Company’s customer support department is responsible for the proper implementation of these Policies. The representative of this department will monitor and ensure that the Company’s complaint handling process is effective and, if necessary, update it and also ensure that any deficiencies are corrected. Violations of the Policy must be reported to the Executive Director as soon as possible.

31. The rules, including their changes, enter into force on the day of their approval. Employees of the Company must comply with the Rules from the moment the employee is familiar with the Rules. Employees are familiar with the Rules in writing and must properly follow their requirements.

32. The Company keeps Complaints, data related to the investigation, documents that provide a specific result of the investigation and the answer provided to the Applicant for at least 3 years from the date of providing the final answer to the Applicant. All information and documents are stored in the manner