Customer Complaint Policy

1. Purpose

This policy outlines Crypto Mart’s approach to handling customer complaints, ensuring transparency, accountability, and compliance with relevant regulations.

2. Scope

The policy applies to all customer complaints received through various communication channels. Specific actions that do not qualify as official complaints are stated.

3. Customer Complaints

Customer complaints are characterized by a written or verbal expression of dissatisfaction or concern expressed by a customer regarding Crypto Mart’s services, products, or interactions with staff, whether received through direct communication channels, email, social media, or any other communication platform. Only complaints submitted by a customer, or an authorized representative of a customer will be considered official complaints.

4. Exclusions

The following do not constitute official complaints:

  • General negative comments about Crypto Mart
  • Routine inquiries or service requests
  • Queries related to transaction processing
  • Questions regarding Crypto Mart’s policies and procedures
  • Refund requests
  • Law enforcement requests
  • Contact initiated by consumer protection groups

5. Standard Resolution

All official customer complaints will be subject to management and compliance reviews. A member of senior management and/or designee will investigate the complaint and gather pertinent data, to be presented for management appraisal. The nature of such complaints will determine who carries the responsibility of communicating the resolution to the customer. Irrespective of the outcome or communication channel, all official complaints will be documented in a Customer Complaint Log (see “Customer Complaint Log”).

6. Immediate Resolution

In some cases, customer complaints can be resolved by a member of senior management and/or designee without involving the BSA Compliance Officer. Where escalation is deemed unnecessary, the resolution shall be recorded in the Customer Complaint Log. The BSA Compliance Officer shall periodically review the Customer Complaint Log, addressing non-escalated complaints as needed.

7. Customer Complaint Log

The Customer Complaint Log is used to document all official customer complaints received by Crypto Mart and monitor their resolutions. The log helps Crypto Mart keep track of customer feedback, identify patterns of complaints, and make improvements to their products or services.

Each log entry should include:

  • Date of the complaint
  • Complainant’s name and contact information
  • Compliant description
  • Provided resolution
  • Responsible person’s name
  • Date of resolution
  • Subsequent actions taken

8. Investigation

During investigations of customer complaints, it is necessary to collect all relevant information, including emails, screenshots, contact information, and a detailed account of the complaint. Interviews with the customer may also be conducted to gather further information. Complaints necessitating compliance review should be escalated within 24 hours of receipt.

When a complaint is received, the investigation should be conducted by a member of senior management and/or designee, and should include the following steps:

  • Enter the case in the Customer Complaint Log and create a digital file folder for storing investigation materials.
  • Review the information gathered and investigate the issue to determine its cause and potential solutions.
  • Determine whether the complaint requires escalation to the BSA Compliance Officer.
  • If escalation is deemed unnecessary, offer the customer a resolution that addresses their concerns, such as an explanation, promo code, or refund of fees.
  • Follow-up with the customer to ensure their satisfaction and confirm that the issue has been fully resolved.

9. Standard Escalation

After completing the investigation, certain complaints may require escalation to the BSA Compliance Officer. The member of senior management and/or designee who investigated the complaint should communicate the matter to the BSA Compliance Officer if the complaint involves:

  • Fraud or suspected fraudulent activity
  • Alleged account takeover
  • Money laundering or other illegal activities
  • Suspected terrorist financing or sanctions evasion
  • Bribery or corruption
  • Cybercrime or hacking
  • Miscommunication or lack of information provided to the customer

The complaint may be reviewed during a weekly or biweekly compliance meeting, as deemed appropriate by the BSA Compliance Officer. Additionally, legal counsel and/or senior management may be involved by the BSA Compliance Officer during the investigation.

10. Immediate Escalation

Certain official or unofficial complaints by nature or fact pattern shall require immediate escalation to the BSA Compliance Officer without prior investigation by the member of senior management and/or designee in receipt of the complaint. The circumstances that warrant immediate escalation include:

  • Threats to Crypto Mart
  • Contact initiated by regulators or law enforcement
  • Contact initiated by a third-party on behalf of the customer, including lawyers or consumer protection groups

11. Timeframe

Customer complaints must be acknowledged within three business days and resolved within seven business days unless otherwise indicated by the BSA Compliance Officer. The acknowledgment of the complaint to the customer must include confirmation of its receipt and notification to the relevant party that a written response and/or corrective action will be provided after a thorough review of the facts and circumstances. Any delay in resolving the complaint must be communicated with the complainant and documented in the Customer Complaint Log.

12. Records

Crypto Mart will retain the aforementioned records relating to its Customer Complaint Policy including but not limited to logs, records, supporting documentation, investigative notes, analyses, trainings, reports to management, and all other pertinent information. Crypto Mart will retain these records for at least five years after the date of each customer complaint. These records will be filed or stored in such a way as to be accessible within a reasonable period of time.