Complaints handling policy
Note:
“PRYPCO Mint” is hereby referred to as “PRYPCO FZE”
To submit suspicious activity:
PRYPCO FZE defines and categorises customer communications to ensure clarity, effective handling, and compliance with regulatory standards. This section outlines key terms related to complaints and feedback.
Complaint: Any expression of dissatisfaction, whether oral or written, related to PRYPCO FZE’s products, services, or employee behaviour that necessitates a response. This includes, but is not limited to:
Issues with service quality.
Delays or errors in service delivery.
Other factors impacting the client experience.
Business Unit: A distinct product or service group within PRYPCO FZE or an affiliated entity operating under a service-level agreement with PRYPCO FZE.
Business Senior Management: Refers to members of PRYPCO FZE’s Board of Directors or the Director of the relevant Business Unit. Responsible for reviewing and resolving escalated complaints to ensure fair outcomes and alignment with company standards.
Exclusions: The following do not qualify as complaints under this policy:
Expressions of social or political views.
Complaints exceeding reasonable customer expectations.
Market performance issues related to crypto assets.
Feedback: Written communications from customers that do not meet the criteria for a complaint but provide insights into customer sentiment. Feedback is documented and shared internally as part of a separate information flow to improve services and customer experience.
Management Information: Includes data on customer complaints collected from:
The Complaints Register.
Customer service interactions.
Compliance investigations.
Management Information supports decision-making and continuous improvement initiatives by identifying trends and gaps in customer service.
This Complaints Handling policy sets out the policies and procedures that PRYPCO FZE (“the Firm” or “PRYPCO Mint”) must follow in order to comply with principles, rules and regulations of the Dubai Virtual Assets Regulatory Authority (“VARA”) to maintain the highest standards of market integrity, transparency, ethical conduct, and fair treatment of customers in all its operations.
PRYPCO FZE is dedicated to delivering an extraordinary customer experience and ensuring satisfaction with our products and services as a PRYPCO FZE customer. This Complaints Handling Policy outlines our approach to effectively handling complaints and feedback from current, former and potential customers. PRYPCO FZE ensures that we adequately manage complaints, which enables us to continuously improve our offerings and maintain high levels of customer satisfaction.
Customers have the right to submit complaints and expect timely responses and resolutions. The following policy and procedures detail our process for handling complaints.
SECTION 1:
Customer Awareness
Customer Awareness of the Complaints Policy
To ensure customers are well-informed, PRYPCO FZE publishes a summary of its internal complaints handling process on its website. This summary includes:
Submission Guidelines: How to lodge a complaint and the available submission channels.
Required Information: Details about the information that complainants need to provide for processing.
Handling Timescales: Estimated timelines for resolving complaints.
Handling Procedures: An overview of PRYPCO FZE’s policies and processes for addressing complaints.
Redress Options: Information on additional redress mechanisms, including out-of-court procedures where applicable.
Complaint Submission Channels
PRYPCO FZE provides multiple channels to ensure customers can easily submit complaints in their preferred manner.
Dedicated Email Address:
Complaints can be submitted via a designated email: groupcompliance@prypco.com .
Monitoring:
The dedicated inbox is actively monitored by the Customer Support team during business hours to ensure timely responses.
Website Form
Online Complaint Form:
Customers can submit complaints through a secure online form available on PRYPCO FZE’s website.
Monitoring:
Submissions are logged in real-time and reviewed by the Customer Support team.
In-Person
Office Visits:
Customers may visit PRYPCO FZE’s office to lodge complaints directly with staff.
Documentation:
Attending staff document in-person complaints and forward them to the Customer Support team for follow-up.
Postal Mail
Mailing Address:
Complaints can be sent via postal mail to PRYPCO FZE’s registered office. Mailing details are available on the website.
Documentation:
Complaints received by mail are recorded and managed by the Customer Support team upon receipt.
Complaint Recognition and Monitoring
Official Lodgement:
A complaint is officially recognised once it is received through one of the designated channels and meets the minimum information requirements.
Monitoring Procedures:
PRYPCO FZE has robust systems to monitor and document all complaints submitted through these channels to ensure accountability and timely resolution.
SECTION 2:
PRYPCO FZE is committed to ensuring customers are fully informed about its complaints handling process and can easily access multiple channels to submit their concerns.
Customer Awareness of the Complaints Policy
PRYPCO FZE publishes a comprehensive summary of its internal complaints handling process on its website, ensuring transparency and accessibility for all customers. This summary provides the following information:
Submission Guidelines: Clear instructions on how to lodge a complaint and the available submission channels.
Required Information: A list of the essential details that complainants need to provide to facilitate prompt processing.
Handling Timescales: Expected timeframes for reviewing and resolving complaints.
Handling Procedures: A detailed outline of PRYPCO FZE’s internal procedures and commitments for addressing complaints.
Redress Options: Guidance on additional redress mechanisms, including access to out-of-court solutions when necessary.
Complaint Submission Channels
To cater to customer preferences and convenience, PRYPCO FZE offers multiple complaint submission channels, each designed for seamless interaction and efficient handling.
Dedicated Email Address: Customers can email complaints to PRYPCO FZE’s designated address, groupcompliance@prypco.com .
Monitoring: The email inbox is actively monitored during business hours by the Customer Support team to ensure timely acknowledgement and response.
Telephone
Customers may submit complaints to PRYPCO FZE via phone number 800-779726. The number is available and operational from Monday to Friday and from 10:00 to 18:00.
When submitting complaints via telephone, these must at a minimum include the following information:
Name and customer number of the complainant;
Telephone number and email address of the complainant;
A description of the Complaint;
Copies of supporting documentation(s); and
Date and time of the event from which the Complaint arose.
Website Form
Online Complaint Form: Complaints can be submitted through a secure online form available on PRYPCO FZE’s official website.
Monitoring: All submissions are logged automatically and reviewed in real-time by the Customer Support team to prioritise action.
In-Person Submissions
Office Visits: Customers may visit PRYPCO FZE’s offices to lodge complaints directly with trained staff members.
Documentation: In-person complaints are documented in detail by the attending staff and forwarded to the Customer Support team for prompt follow-up and resolution.
Postal Mail
Mailing Address: Customers can submit complaints via postal mail to PRYPCO FZE’s registered office address, which is provided on PRYPCO FZE’s website.
Processing: All postal submissions are logged upon receipt and reviewed by the Customer Support team to ensure appropriate action is taken.
PRYPCO FZE will ensure that its complaints-handling procedures are clearly disclosed on its website and other relevant platforms. These procedures will be easy to understand and accessible to all clients.
SECTION 3:
PRYPCO FZE is committed to a fair, transparent, and efficient approach to handling customer complaints. The company’s procedures ensure that all complaints are acknowledged, investigated, and resolved within clear timelines, while keeping customers informed throughout the process. These guidelines also outline the roles, responsibilities, and documentation standards for maintaining accountability and continuous improvement.
Acknowledgement of Complaints
PRYPCO FZE ensures that all complaints are promptly acknowledged and that customers are supported if they require assistance in submitting a complaint. There are no fees or charges imposed for lodging or handling complaints.
Procedures Implemented by PRYPCO FZE:
Acknowledgement Timeline: Acknowledge all complaints within one (1) week of receipt. This acknowledgement can be provided via automated email at a minimum.
Customer Assistance: If a customer requires help in making a complaint, provide reasonable and timely assistance to ensure their concerns are submitted accurately and promptly.
Actions Taken by PRYPCO FZE:
Acknowledgement Content: The acknowledgement to the complainant must:
Confirm receipt of the complaint.
Indicate that a response or update will be provided within four (4) weeks.
Provide the name, title, and contact details of the agent handling the complaint.
Extraordinary Circumstances: If a complaint cannot be resolved within four (4) weeks, provide an update explaining the delay and resolve the complaint no later than eight (8) weeks from the original submission date.
Complaints Log: Complete a Complaints Log (as per the Appendix) within four (4) weeks of receipt and record it in the Complaints Register held by PRYPCO FZE.
Investigation Procedures
PRYPCO FZE’s investigation procedures ensure a structured, comprehensive, and timely approach to resolving complaints. Clear timelines, defined roles, and thorough documentation support transparency, fairness, and regulatory compliance.
Timelines for Each Stage of the Investigation:
Receipt of Complaint: Complaint received by email or Support chat. Acknowledge within 1 week.
Acknowledgement: Send an acknowledgement email to the complainant within 1 week of receipt, providing confirmation of receipt, contact details of the responsible agent, and a 4-week response timeframe.
Initial Review: The Independent Customer Service Complaints Officer reviews the complaint within 1 week of acknowledgement.
Detailed Investigation: Complete a comprehensive investigation, including interviews and document reviews, within 4 weeks of receiving the complaint.
Interim Update: If the investigation extends beyond 4 weeks, provide an update to the complainant by the end of the 4th week explaining the delay.
Final Response: Send a written response outlining findings and resolution no later than 8 weeks from the complaint’s receipt.
Roles and Responsibilities:
Compliance Officer:
Oversees the entire complaints process.
Ensures compliance with regulatory requirements.
Reviews and approves final investigation reports.
Customer Service Complaints Officer:
Performs the initial review and conducts the detailed investigation.
Prepares investigation reports and drafts responses to complainants.
Business Unit Director:
Assists in complex cases.
Provides necessary information for investigations.
Reviews and concurs with complaint closures.
Board of Directors:
Oversees overall effectiveness of the complaints handling process.
Reviews quarterly Management Information reports on complaints.
Documentation and Reporting:
Investigation File: Created by the Compliance Officer for each complaint, containing all related details and documents.
Complaints Register: Maintained by the Customer Service Complaints Officer, noting all actions taken and the final resolution for each complaint.
Final Report: Prepared by the Customer Service Complaints Officer and approved by the Compliance Officer, summarising the findings and resolution.
Management Information Report: Provided quarterly to the Board of Directors, including the number, type, and outcomes of complaints, and identifying any recurring issues that may require systemic changes.
Independent Review and Investigation of Complaints
PRYPCO FZE ensures that complaints are handled impartially, effectively, and with full consideration of their nature and potential impact. By designating an independent Customer Service Officer who is not involved in the matter at hand, PRYPCO FZE safeguards the integrity and fairness of the complaint resolution process. This officer collaborates with the relevant Business Unit representative, if applicable, to communicate with the complainant, review the complaint thoroughly, and determine whether it can be resolved immediately or requires escalation.
Procedures Implemented by PRYPCO FZE:
Independent Assignment: Appoint a Customer Service Officer who has not participated in the events leading to the complaint.
Cross-Functional Review: Involve other departments as needed to ensure a comprehensive response.
Timely, High-Quality Response: Evaluate each complaint promptly to decide on immediate resolution or further escalation.
Actions Taken by PRYPCO FZE:
Fair and Impartial Investigations: All complaints are investigated diligently, ensuring responses are unbiased, timely, and clearly explain whether the complaint is upheld, along with any remedial or corrective actions.
Systemic Analysis: Compare the complaint with past similar issues and redress measures to identify patterns, remedy recurring problems, and enhance processes.
Complex Cases and Specialist Involvement
The Business Unit Director or Compliance Officer may designate certain complaints as complex, requiring more extensive research and possibly the involvement of subject matter experts. Complex cases may be reviewed by a senior specialist or Department Leader to ensure comprehensive fact-finding and informed decision-making.
Procedures Implemented by PRYPCO FZE:
Complex Case Designation: The Business Unit Director or Compliance Officer classifies a complaint as complex when it involves intricate issues, extensive documentation, or multiple departments.
Thorough Review: Complex cases involve gathering all pertinent information for an in-depth analysis and are managed by experienced personnel.
Actions Taken by PRYPCO FZE:
Specialist Consultation: Engage senior specialists and Department Leaders for guidance and support.
Enhanced Due Diligence: Collect and review all relevant data to facilitate a well-founded resolution.
GDPR and Data Privacy Complaints
For complaints involving the General Data Protection Regulation (GDPR), the commencement date is the date the email or letter is received. PRYPCO FZE must respond within four (4) weeks of receipt. Such complaints are explicitly marked in the Complaints Log, including start and response dates. All data privacy complaints must be immediately directed to the Data Protection Officer and reported to VARA.
Procedures Implemented by PRYPCO FZE:
GDPR-Specific Tracking: Identify and record GDPR-related complaints distinctly in the Complaints Log.
Timely Response: Ensure a four (4)-week response timeframe for GDPR complaints.
Regulatory Reporting: Notify the Data Protection Officer promptly and report to VARA as required.
Actions Taken by PRYPCO FZE:
Special Handling: Fast-track GDPR complaints to meet stringent response deadlines and regulatory expectations.
Data Protection Oversight: The Data Protection Officer oversees these complaints, ensuring compliance and appropriate redress.
Criteria for Complaint Assessment
PRYPCO FZE evaluates complaints based on their nature, severity, impact on the customer, frequency of similar issues, and the appropriate escalation thresholds. This structured approach ensures that each complaint receives the level of attention and resources it warrants.
Nature of the Complaint:
Service Issues: Dissatisfaction with service quality, delays, or errors.
Behavioural Issues: Inappropriate staff conduct or breaches of company policies.
Legal/Regulatory Issues: Potential violations of laws, regulations, or contracts.
Severity of the Complaint:
Minor: Easily resolved with minimal impact.
Moderate: Requires more extensive investigation and could cause inconvenience or dissatisfaction.
Severe: Involves significant service failures, possible legal breaches, or substantial harm.
Impact on the Customer:
Financial Impact: Monetary loss or damage.
Reputational Impact: Harm to the customer’s reputation, especially if made public.
Operational Impact: Disruption to the customer’s operations or services.
Frequency of Similar Complaints:
Isolated Incident: One-time occurrence, not indicating a broader problem.
Recurring Issues: Multiple similar complaints, suggesting systemic issues needing prompt corrective action.
Thresholds for Escalation:
Immediate Escalation: Legal/regulatory breaches, litigation risks, or involvement of senior management/Board members.
After Initial Review: Complaints requiring input from multiple departments or third parties.
Periodic Review: Recurring issues that indicate persistent underlying problems.
Complaints Involving Third-Party Entities
When a complaint involves a third-party entity, PRYPCO FZE logs it clearly, notifies the third party within fourteen (14) business days, and establishes a communication channel for cooperation. A joint investigation may be conducted, but PRYPCO FZE maintains ultimate responsibility for ensuring a satisfactory resolution for the client.
Procedures Implemented by PRYPCO FZE:
Clear Documentation: Mark complaints involving third parties distinctly in the Complaints Log.
Timely Notification: Inform the third party promptly and initiate a collaborative resolution process.
Actions Taken by PRYPCO FZE:
Joint Investigation: Work with the third party to identify the root cause and remedies.
Accountability: PRYPCO FZE remains accountable for final resolution and client satisfaction.
In handling complaints, PRYPCO FZE will take reasonable steps to identify and address any recurring or systemic issues. This includes analysing the causes of complaints to identify common root causes, considering whether these root causes may affect other processes, services, or products, and implementing corrective measures as needed.
The Head of Operation will provide quarterly Management Information reports to the Board of Directors, detailing complaint levels and types. The Board will monitor and allocate resources to ensure the complaints handling process is effective and continuously improved.
SECTION 4:
All records related to each complaint, including details of actions taken and investigations conducted, are stored in the Complaints Register for at least eight (8) years. This serves as the primary record for audit and regulatory review, ensuring transparency and accountability.
Procedures Implemented by PRYPCO FZE:
Comprehensive Record Storage: Maintain a detailed Complaints Register with all supporting documentation.
Audit Readiness: Ensure records are easily accessible for audit purposes and long-term reference.
Actions Taken by PRYPCO FZE:
Resolution Documentation: Record all resolutions and supporting evidence.
Long-Term Retention: Keep records for a minimum of eight (8) years to demonstrate due diligence and compliance.
Policy Review and Amendments
PRYPCO FZE’s Board of Directors, assisted by the Head of Compliance/Compliance Officer, is committed to ensuring that the Complaints Policy remains effective, relevant, and compliant with all applicable regulations. Regular evaluations, conducted at least annually, help maintain the policy’s alignment with evolving business operations and the changing regulatory landscape. Prompt action is taken to adjust the policy whenever new facts or circumstances necessitate amendments.
Procedures Implemented by PRYPCO FZE’s:
Annual Review: The Board of Directors, with support from the Compliance team, reviews the Complaints Policy at least once a year to confirm its ongoing effectiveness and suitability.
Proactive Adjustments: If indications arise that changes are needed due to altered conditions or emerging issues, the Board promptly reassesses the policy and implements the necessary revisions.
Additional Review Triggers:
Significant Operational Changes: Should the Board of Directors determine that a substantial change in PRYPCO FZE’s operations has occurred, the Complaints Policy will be reviewed to ensure it continues to address the company’s current needs and risk profile.
Regulatory Developments: Any amendments in applicable laws, regulations, guidance from VARA, or industry best practices will prompt an immediate review of the Complaints Policy. Changes will be made as required to ensure ongoing compliance and adherence to the highest standards of conduct.
By periodically reassessing the Complaints Policy and updating it in response to organisational shifts and regulatory developments, PRYPCO demonstrates its commitment to maintaining a robust and adaptive framework for managing customer complaints.
