Complaints Handling Policy
Walleexer s.r.o.
Website: www.walleexer.com • Email: welcome@walleexer.com
1. Purpose and Scope
This policy ensures all client complaints concerning Walleexer's crypto-asset services are handled effectively, transparently, and fairly in strict compliance with:
- MiCA (Regulation (EU) 2023/1114 & Delegated Regulation (EU) 2025/294)
- GDPR (Regulation (EU) 2016/679)
- AMLD5 & AMLD6 (Directive (EU) 2018/843 and Directive (EU) 2023/XXXX)
- Czech AML Act (Act No. 253/2008 Coll.)
- Czech National Bank guidelines and all relevant Czech/EU regulations
Scope: Applies to all complaints from clients ("Complainants") regarding any crypto-asset service provided by Walleexer.
2. Policy & Procedures
Accessibility:
The full complaints policy, procedures, and template form are published on our website in Czech and English, using clear language and free of charge.
Submission Channels:
Language Options:
Clients may submit complaints in Czech or English at no additional cost.
Assistance:
Reasonable support is available to clients with disabilities or special needs upon request.
3. Resources & Responsibilities
| Role | Responsibilities |
|---|
| Complaint Officer | Named, qualified, and experienced. Oversees logging, admissibility, investigation, and communication. |
| Investigating Team | Staff from relevant business units responsible for fact-finding and evidence gathering. |
| MLRO | Reviews AML/CTF-related complaints and files Suspicious Transaction Reports as needed. |
| DPO | Advises on GDPR and personal data issues during the process. |
| Technical Resources | Secure e-complaints register and case-management system with full audit trail and reporting. |
Independence:
The Complaint Officer and Investigating Team act independently from the business unit involved in the complaint.
4. Reasonable Deadlines
| Stage | Deadline |
|---|
| Acknowledgement of receipt | Within 2 business days of submission |
| Completion of admissibility check | Within 5 business days |
| Request for further info/notice | Within 5 business days |
| Thorough investigation | Within 20 business days of admissibility |
| Interim update | At day 10 if unresolved |
| Final decision and response | Within 60 calendar days of receipt |
Extensions: If deadlines cannot be met, the complainant is notified of the reasons and new timeframe.
5. Complaints Record & Documentation
- Unique ID: Each complaint is assigned a unique identifier and recorded in a secure register.
- Details Recorded: Original complaint, communication logs, investigation notes, evidence, decisions, and follow-up actions.
- Retention:
- Standard complaints: at least 5 years post-closure
- AML-related records: at least 10 years (per AML Act)
6. Handling & Investigation
- Admissibility Check: Verify completeness and relevance; request missing information if necessary.
- Investigation: Collect internal data, interview staff, review transactions, and consult MLRO/DPO as needed.
- Interim Updates: Inform complainant of progress at reasonable intervals or upon request.
- Impartiality: Ensure no conflicts of interest in the investigation process.
7. Decision & Communication
- Decision Content: Address each complaint point, provide rationale, reference relevant policies/regulations, and specify remedial actions.
- Communication: Written response (email or paper upon request) in the complaint's language.
- Remedies: May include refunds, corrections, or other fair solutions as appropriate.
- Transparency: Clearly explain the decision-making process and criteria used.
8. Informing Clients of Outcomes & Recourse
Outcome Notification:
Clear statement of the final decision, remedial measures, and reasons.
Further Options:
- Internal appeal to Senior Management (within 14 days)
- Referral to the Czech Financial Arbitrator (free) or Czech National Bank's supervisory complaints mechanism
- Other ADR or judicial recourse
Guidance: Provide contact details and procedural information for escalation.
9. Monitoring & Continuous Improvement
- Metrics & Reporting: Track complaint volumes, response times, outcomes, and client satisfaction.
- Reviews:
- Quarterly review by Compliance
- Annual policy review and update
- Management Reporting: KPI report to Management Body, including systemic issues and improvement actions.
- Feedback Loop: Use complaint trends to improve products, services, and processes.
10. Data Protection & Confidentiality
- GDPR Compliance: Process personal data under lawful bases (legal obligation, legitimate interest).
- Client Privacy: Inform clients of their data rights (access, rectification, erasure, etc.) and provide DPO contact.
- Security: Confidential handling and secure storage of all complaint records.
- Access Control: Limit access to complaint data to authorized personnel only.