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Complaints Handling Policy

Introduction

This Policy regulates effective, clear and fast handling of complaints submitted to the Company in relation to the performance and procedures of the Company. The Company maintains records of complaints and measures taken for expedient complaint resolution, in line with applicable Legislation, Rules and/or Regulations.

Within this Policy, the Complaint is understood as any objection provided by the client related to the performance, services or products as these are offered by the Company.

Match2Pay Ltd (hereinafter the “Company”) aims to provide superior services to all of its Clients and for this purpose, the Company has appointed a Compliance Officer to efficiently ensure the proper handling of any complaints from the Clients. This is to allow the Company to resolve and apply mandatory measures to avoid any recurring issues.

Definition

The Company classifies a complaint as any objection and/or dissatisfaction that the Client may have with regards to the provision of the services provided by the Company. A complaint form is enclosed at the end of this policy.

Company’s Internal Escalation Procedure

The Compliance Officer shall be responsible to ensure the proper handling of Client complaints, except in the case where the complaint involves the Compliance Officer, whereby the complaint shall be handled by a Management member.

The Client may register a complaint by completing the complaint form, using any of the following options:

  • Email: compliance@match2pay.com
  • Postal Address: Match2pay Ltd
    9A CT House, Providence, Mahe,
    Seychelles
  1. When the Company receives the Client’s complaint then a written acknowledgement will be sent to the Client within 24 hours from the date the Complaint was received (within business days);
  2. The Company will attempt a final response within 30 business days, however in case we are still not in a position to resolve the issue then the Company will notify you in writing stating the reasons for the delay and indicate an estimated time to resolve the issue;
  3. A final response should be provided to the Client within 14 business days (45 business days in particularly complicated cases) the latest from the date he submitted his complaint;
  4. In the case where the complainant is still not satisfied with the Company’s final response, then the complainant can refer his complaint with a copy of the Company’s final response to the Financial Services Authority (FSA) in Seychelles for further examination.
Escalation to FSA
Prior lodging the complaint to the FSA
  1. In order for the Client to be able to contact the FSA for further examination it is required to demonstrate to the FSA that all possible options have been exhausted to resolve the matter directly with the Company. For this purpose, the Client should follow the Company’s escalation procedure as indicated above for the investigation of the complaint by the Company before lodging a complaint to the FSA.
  2. It is further noted, that the FSA shall not attend to any complaint, unless that it is satisfied that the matter has been brought to the attention of the Company and both the Client and the Company have failed to reach a mutually agreeable solution on the matter.
Lodging the complaint to the FSA
The contact details for the Financial Services Authority (FSA) in Seychelles are set out below:

Address: PO Box 991 Bois de Rose Avenue Roche Caiman Victoria, Mahe, Republic of Seychelles
Phone: (+248) 438 08 00
Fax: (+248) 438 08 88
Website: https://fsaseychelles.sc/complaint-handling

Client Records

The Client should provide all relevant documentations as well as any additional information requested by the Company in order to ensure all records are collected and the complaint is properly resolved on time. The Company shall be entitled to prepare statistics and reports about complaints, which will be aimed to improve the efficiency of administering Complaints.

All records will be kept safe as per local requirements and for a period of seven (7) years.


COMPLAINT FORM

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    CT House, Office No. 9A, Providence, Mahe, Seychelles.

    Business address: Office 13(b), Third Floor, Vairam Building,
    Providence, Mahe, Seychelles.

    contact@match2pay.com

    Match2Pay Ltd is regulated by the Seychelles Financial
    Services Authority as a Virtual Asset Exchange. Match2Pay is
    registered in U.S. Patent and Trademark Office, the European
    Union Intellectual Property Office and Office of the Controller
    General of Patents, Designs and Trade Marks in India. Unauthorized
    use of the above trademark without the consent of the company
    is prohibited. Match-Trade Technologies is a strategic IT partner of
    Match2Pay Ltd. and an independent company.

    B2B Only Notice

    Match2Pay services are provided exclusively on a B2B basis to businesses, merchants and regulated financial institutions. Match2Pay does not onboard retail users, does not provide services to private individuals and does not solicit or accept consumer business. Match2Pay provides virtual asset custody services exclusively to business and institutional clients, including merchants, brokers and regulated financial institutions. Custody services are provided in connection with Match2Pay’s payment, exchange and settlement infrastructure and are subject to applicable regulatory, security and compliance requirements. Match2Pay does not provide standalone wallet or custody services to private individuals.

    AML / CFT & Travel Rule Compliance

    Match2Pay maintains an AML/CFT compliance framework aligned with applicable laws, regulatory requirements and FATF recommendations. Match2Pay applies a risk-based approach to customer due diligence, transaction monitoring and sanctions screening. Where applicable, Match2Pay implements Travel Rule measures in connection with virtual asset transfers and cooperates with relevant counterparties and authorities in accordance with applicable regulations.

    Custody & Safeguarding

    Virtual assets held in custody by Match2Pay are recorded and safeguarded in accordance with applicable laws, regulatory requirements and internal control procedures. Virtual asset custody involves operational, technological and counterparty risks. Clients should ensure that custody services are appropriate for their business model and regulatory obligations. Client virtual assets held in custody are segregated and recorded in accordance with applicable laws and internal safeguarding procedures.

    Restricted Jurisdictions

    Match2Pay does not establish relationships with, and does not provide services to, clients incorporated, registered or operating in jurisdictions subject to comprehensive sanctions, high-risk AML classifications or other material regulatory restrictions. Without limitation, Match2Pay services are not available to clients incorporated or operating in the following jurisdictions: the United States of America, Canada, Australia, Cuba, Russia, the Islamic Republic of Iran, North Korea, Myanmar, South Sudan and Syria, or in any other jurisdiction where the provision of virtual asset exchange, payment, custody, on-ramp or off-ramp services would be restricted or prohibited by applicable laws, sanctions or regulatory requirements. Availability of services is subject to jurisdictional assessment and successful completion of Match2Pay’s institutional onboarding and due diligence processes.

    Trademarks & Group Relationship

    Match2Pay is the registered owner of the Match2Pay trademark in the United States, the European Union and India. Unauthorized use of the trademark without prior consent is prohibited. Match-Trade Technologies is a strategic IT partner of Match2Pay Ltd. and an independent technology provider.

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