Complaints handling policy

1. INTRODUCTION

1.1. Piastra Pay Inc., a corporation incorporated under the laws of Canada (the “Canadian Entity”), and 3-102-941161 S.R.L., a company incorporated under the laws of Costa Rica (the “Costa Rican Entity”) (collectively, the “Entities”), are committed to providing services in a professional, transparent and compliant manner.

1.2. This Complaints Handling Policy (the “Policy”) sets out the procedure for the submission, investigation and resolution of complaints submitted by Clients in relation to cryptocurrency processing, crypto-to-fiat settlement and related services provided under the applicable Cryptocurrency Processing and Settlement Agreement (the “Agreement”).

1.3. The Canadian Entity and the Costa Rican Entity are independent legal entities. Each Entity is responsible solely for the services it provides. Nothing in this Policy shall be interpreted as creating joint liability between the Entities.

2. DEFINITIONS OF COMPLAINT

2.1. For the purposes of this Policy, a Complaint shall mean a written request, claim or statement submitted by a Client to the relevant Entity alleging that the Client’s rights and/or legitimate interests have been adversely affected in connection with the Services provided by that Entity or under an agreement concluded with that Entity, and requesting resolution of the matter or satisfaction of the claims expressed therein.

2.2. A Client shall mean a legal entity to whom either the Canadian Entity or the Costa Rican Entity provides cryptocurrency processing, settlement or related services, or with whom such Entity has entered into an agreement, and who has submitted a Complaint. For the purposes of this Policy, the term Client may also include any other legal entity that submits a Complaint concerning the Services or agreements of the relevant Entity, including a prospective client or other contractual counterparty, where applicable.

2.3. The Complaints Register shall mean the internal electronic register maintained by the relevant Entity for the purpose of recording, tracking and managing Complaints in accordance with this Policy and applicable laws of Canada or Costa Rica, as relevant.

2.4. A Response to the Complaint shall mean a written reply issued by the relevant Entity to the Client addressing the subject matter of the Complaint and setting out the outcome of the review.

2.5. A Responsible Person shall mean an employee, officer or authorised representative of the relevant Entity designated to review, investigate and respond to a Complaint in accordance with this Policy.

2.6. Competent Authority shall mean any governmental, regulatory or supervisory authority having jurisdiction over the relevant Entity in connection with the Services, including, where applicable, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) in relation to the Canadian Entity, and the competent authorities of Costa Rica in relation to the Costa Rican Entity.

3. APPLICABILITY

3.1. Each relevant Entity recognizes its responsibility to address all Client Complaints promptly, clearly, transparently and constructively, ensuring a fair, objective and effective Complaint handling process in accordance with applicable laws governing the Entity providing the Services.

3.2. This Policy applies exclusively to Complaints submitted by Clients in connection with the provision of cryptocurrency processing, settlement and related Services provided by:

• 3-102-941161 S.R.L. (Costa Rica), acting as Crypto Processor; and/or
• Piastra Pay Inc. (Canada), acting as Settlement Agent.

The following shall not be considered Complaints under this Policy:

3.2.1. Complaints concerning activities that are not regulated under applicable law or that fall outside the jurisdiction of the competent authority supervising the relevant Entity;

3.2.2. Complaints relating to activities for which neither the Canadian Entity nor the Costa Rican Entity bears contractual or legal responsibility.

3.3. If a Complaint concerns activities for which the relevant Entity is not responsible, that Entity shall inform the Client in writing of the reasons for refusing to accept or examine the Complaint and, where reasonably possible, shall indicate the appropriate person, entity or authority responsible for addressing such matter.

4. SUBMISSION AND ACCEPTANCE OF COMPLAINTS

4.1. A Client who believes that its contractual rights or legitimate interests have been infringed in connection with the Services must submit a written Complaint to the relevant Entity, describing the circumstances of the dispute, clearly stating the claim and enclosing any available supporting documentation.

4.2. The submission and examination of a Complaint under this Policy shall be free of charge.

4.3. Complaints may be submitted in English. A Client may submit a Complaint through a duly authorised representative, provided that appropriate documentary evidence of such authorisation (including, but not limited to, a power of attorney or corporate authorisation document) is provided.

4.4. Complaints may be submitted in writing by any of the following methods:

4.4.1. By postal mail to the registered office address of the relevant Entity as specified in the applicable Agreement; or

4.4.2. By email to: [email protected].

4.5. Only Complaints meeting the following criteria shall be registered and reviewed:

4.5.1. The Complaint must be legible and sufficiently clear.

4.5.2. The Complaint must contain:

a) The full legal name of the Client, and where applicable, the name, position and authority of the individual acting on behalf of the Client. If submitted by an authorised representative, documentary proof of authorisation must be attached;
b) The Client’s contact details, including email address and, where applicable, mailing address and telephone number;
c) The date of submission;
d) The preferred method of receiving a response, if different from the submission method;
e) A clear and detailed description of the Complaint, including relevant transactions, Services involved, dates, amounts, actions taken by the relevant Entity, specific claims and any supporting documents (such as payment confirmations, account statements or correspondence);
f) Any other relevant circumstances related to the Complaint.

4.6. Where necessary for the proper handling of a Complaint, the relevant Entity may verify the identity of the Client or its representative and may request additional information. The review period may be suspended until the requested information is received.

4.7. Information transmitted by email or other electronic communication methods capable of evidencing transmission shall satisfy the written form requirement under this Policy.

4.8. If a Complaint does not comply with the requirements of this Policy, is incomplete, unclear, submitted in a language other than English, or does not allow proper identification of the Client, the relevant Entity may request clarification or additional information. If the deficiencies cannot be remedied, the relevant Entity may decline to examine the Complaint and shall notify the Client in writing within a reasonable timeframe. Anonymous Complaints or Complaints lacking sufficient identification of the Client shall not be accepted.

5. REGISTRATION

5.1. All Complaints submitted in accordance with this Policy shall be recorded in the internal Complaints Register maintained by the Compliance function of the relevant Entity (either the Canadian Entity or the Costa Rican Entity, as applicable).

5.2. The following information shall be recorded in the Complaints Register:

a) The full legal name of the Client;
b) The contact details provided by the Client;
c) The date and method of submission of the Complaint;
d) A summary description of the Complaint;
e) The specific Services involved, including whether the matter relates to cryptocurrency processing or settlement activities;
f) The name of the Responsible Person assigned;
g) The date of the Response;
h) The outcome of the Complaint (upheld, partially upheld, rejected);
i) Any corrective or remedial action taken.

5.3. The Complaints Register shall be maintained in electronic form and shall be made available to competent authorities upon lawful request.

6. EXAMINATION OF COMPLAINTS

6.1. Throughout the Complaint handling process, all employees and officers of the relevant Entity shall maintain confidentiality and adhere to the principles of fairness, reasonableness, objectivity and impartiality.

6.2. Each Complaint shall be handled by a suitably qualified employee designated as the Responsible Person, who was not directly involved in the matter giving rise to the Complaint, where reasonably practicable.

6.3. For the purpose of investigating the Complaint, the Responsible Person shall be entitled to:

a) Obtain and review all relevant internal records, transaction data and documentation;
b) Examine historical transactional and contractual data relating to the Client;
c) Request additional information or clarification from the Client;
d) Consult other employees, officers or departments of the relevant Entity where necessary.

6.4. The Responsible Person shall ensure that the investigation process is adequately documented to demonstrate the scope and basis of the review.

6.5. Where a Complaint concerns both cryptocurrency processing services provided by the Costa Rican Entity and settlement services provided by the Canadian Entity, the Entities may cooperate in reviewing the matter. However, each Entity shall remain responsible only for its respective scope of Services.

6.6. If additional documentation or clarification is required from the Client, the relevant Entity shall request such information in writing, specifying a reasonable deadline. The response timeframe may be suspended until the requested information is received. If the Client fails to provide the requested information within the specified period, the relevant Entity may proceed with the review based on the information available.

7. PROVIDING RESPONSES TO COMPLAINTS

7.1. The relevant Entity shall review and investigate the Complaint and provide a detailed written Response within thirty (30) calendar days from the date of receipt.

7.2. In exceptional cases where the matter is complex or requires additional time for investigation, the Client shall be informed of the delay and provided with an expected timeframe for the final Response.

7.3. The Responsible Person shall determine whether the Complaint is upheld, partially upheld or rejected.

7.4. Where a Complaint:

(i) involves a financial claim exceeding USD 10,000 (or equivalent),
(ii) contains allegations of fraud, wilful misconduct or gross negligence,
(iii) presents material regulatory, compliance or reputational risk, or
(iv) alleges a breach of information security, AML obligations or data protection laws,

the Responsible Person shall escalate the matter to the Chief Executive Officer (CEO) of the relevant Entity. The CEO shall review the matter and make the final determination.

7.5. The written Response shall include:

a) The decision (upheld, partially upheld or rejected);
b) The reasoning supporting the decision;
c) Any corrective or remedial action to be taken, where applicable;
d) Information regarding available legal remedies.

7.6. The Client may withdraw the Complaint at any time prior to issuance of the final Response, in which case the investigation may be discontinued.

7.7. The Response shall be delivered in writing via the same communication channel used for submission of the Complaint, unless otherwise requested by the Client.

7.8. Each Response shall be recorded in the Complaints Register.

8. COMPLAINT CONTROL AND ARCHIVING

8.1. The Compliance function of the relevant Entity shall oversee the monitoring of Complaints and response timelines on an ongoing basis.

8.2. The Compliance function shall periodically analyse Complaints in order to identify recurring issues, systemic risks, compliance deficiencies or operational weaknesses.

8.3. The Chief Executive Officer of the relevant Entity shall be informed of material, high-risk or systemic Complaints and may require corrective or preventive measures.

8.4. Records relating to Complaints, including investigation materials, correspondence and Responses, shall be retained for a minimum of five (5) years from the date of final resolution, or longer if required under applicable AML, record-keeping or regulatory obligations.

8.5. Complaint-related information may be provided to competent authorities, including FINTRAC or other relevant authorities in Canada or Costa Rica, where required by law.

9. PUBLISHING INFORMATION ON THE COMPLAINTS HANDLING PROCEDURE

9.1. The Entities shall ensure that this Policy, together with relevant information regarding the Complaint submission process, is made publicly available on the website operated under the Cryptonix brand at www.cryptonix.com and is provided to Clients upon request.

9.2. The information made available to Clients shall include:

9.2.1. The required details that must be included in a Complaint;
9.2.2. The contact information and communication channels through which a Complaint may be submitted;
9.2.3. The timeframe within which the relevant Entity will review and respond to a Complaint;
9.2.4. Information regarding the Client’s right to seek review by a competent authority, where applicable;
9.2.5. A statement confirming that the Complaint handling process is free of charge.

9.3. The relevant Entity shall compile and maintain internal records regarding the number of Complaints received, their categorisation, outcomes (including received, investigated, upheld, partially upheld or rejected), and any corrective actions taken. Such information may be provided to competent authorities in Canada or Costa Rica upon lawful request.

10. FINAL PROVISIONS

10.1. This Policy, including any amendments thereto, shall enter into force on the date of its approval by the Chief Executive Officer (CEO) of the relevant Entity.

10.2. The Policy shall be reviewed at least annually by the Compliance function of the relevant Entity. Any proposed amendments shall be documented in writing and shall become effective only upon formal approval by the CEO of the relevant Entity.