01Introduction
PAYPILOT CY LTD (“PayPilot”, “Company”, “we”, “us” or “our”) is committed to handling complaints relating to its public website and communications fairly, promptly, transparently and without charge.
This Complaints Handling Policy (“Policy”) explains how visitors may submit a complaint, how complaints are reviewed and how PayPilot communicates the outcome.
PayPilot is a company incorporated in the Republic of Cyprus under registration number HE 497184, with its registered address at Agiou Andreou 296, 3035 Limassol, Cyprus.
02Regulatory Status and Scope
PayPilot intends to seek authorisation as a crypto-asset service provider under Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCA”).
PayPilot has not been granted CASP authorisation by the Cyprus Securities and Exchange Commission (“CySEC”).
The regulated crypto-asset services described on the Website are proposed services and are not currently available.
This Policy applies to complaints concerning:
- Information published on the Website;
- Website accessibility or functionality;
- Communications with PayPilot;
- The handling of enquiries submitted through the Website;
- The handling of personal information in connection with Website communications; and
- Other concerns relating to the public informational Website.
This Policy is not a client complaints procedure for the provision of regulated crypto-asset services. A separate or revised procedure will apply if and when PayPilot becomes authorised and begins providing such services, in accordance with the applicable regulatory requirements.
03What Constitutes a Complaint?
For the purposes of this Policy, a complaint is an expression of dissatisfaction relating to the Website, PayPilot's communications or the handling of an enquiry, where the sender seeks a response, explanation or corrective action.
General requests for information, business proposals and routine correspondence are not necessarily complaints, although PayPilot may treat a communication as a complaint where its substance indicates dissatisfaction requiring review.
A complaint does not need to use the word “complaint” to be considered under this Policy.
04How to Submit a Complaint
Complaints may be submitted free of charge through the following channels:
- [email protected]
- Website
- The complaint submission form available through https://paypilot.cy
- Post
Complaints may be submitted in English.
Visitors who experience difficulty using the Website form may submit their complaint by email or post.
05Information to Include
To help us review a complaint effectively, the complainant should provide, where reasonably available:
- Full name;
- Email address or other preferred contact details;
- A clear description of the issue;
- The date or approximate period of the relevant event;
- Relevant correspondence or supporting information; and
- The outcome or resolution sought.
We may request additional information where necessary to understand or investigate the complaint.
Complainants should not send passwords, private cryptographic keys, wallet recovery phrases or unrelated sensitive documents.
Failure to provide information that is not reasonably necessary will not, by itself, prevent a complaint from being considered.
06Acknowledgement of Receipt
PayPilot aims to acknowledge receipt of a complaint within three business days after receiving it.
The acknowledgement will confirm that the complaint has been received and may identify any additional information reasonably required for its review.
For this Policy, a business day means a day other than a Saturday, Sunday or public holiday in the Republic of Cyprus.
07Complaint Review and Investigation
Complaints are handled under the oversight of the Company's Compliance Officer or an appropriately designated person acting under the Company's internal arrangements.
The review may involve:
- Examining the information submitted by the complainant;
- Reviewing relevant Website content or correspondence;
- Consulting personnel responsible for the relevant issue;
- Assessing whether an error, omission or inappropriate action occurred; and
- Identifying proportionate corrective measures where appropriate.
PayPilot seeks to handle complaints impartially and to manage potential conflicts of interest appropriately.
Only persons who require access for the handling of a complaint will be given access to the relevant information.
08Response Timeframes
PayPilot aims to conduct an initial review within 10 business days of receipt of a complaint.
We aim to provide a final substantive response within 30 calendar days of receipt.
Where a complaint cannot reasonably be resolved within that period, we will inform the complainant of the reason for the delay and provide an updated expected response date.
These are the Company's service standards for Website-related complaints. They do not replace any shorter or otherwise mandatory time limit that may apply under relevant law.
09Outcome and Resolution
Following its review, PayPilot will communicate its findings and, where appropriate, explain the action taken or proposed.
Possible outcomes may include:
- Providing an explanation or clarification;
- Correcting inaccurate Website information;
- Addressing a technical or communication issue;
- Improving an internal process;
- Referring a privacy-related issue to the appropriate person within the Company; or
- Explaining why no further action is considered appropriate.
Where a complaint is not upheld, PayPilot will seek to explain its decision in a clear and understandable manner.
The outcome will be communicated using an appropriate contact channel, ordinarily the channel through which the complaint was received or the complainant's stated preferred channel.
10Further Review and External Rights
If a complainant is dissatisfied with the response, they may request a further review by writing to [email protected] and explaining the reasons for their disagreement.
PayPilot will arrange for the matter to be reconsidered where appropriate, with attention to impartiality and any potential conflicts of interest.
Nothing in this Policy restricts a person's right to seek independent legal advice, pursue an available judicial remedy or contact a competent public authority where permitted by law.
Complaints concerning the processing of personal data may be submitted to the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus, or another competent supervisory authority where applicable.
This Policy does not represent that PayPilot is already subject to an external dispute-resolution scheme applicable to authorised CASPs.
11Confidentiality and Data Protection
Personal data submitted in connection with a complaint is processed for the purpose of receiving, investigating, resolving and documenting the complaint and, where necessary, complying with legal obligations or protecting legal rights.
Complaint information is handled confidentially, subject to lawful disclosure requirements and the need to obtain appropriate professional advice.
Further details are provided in PayPilot's Privacy Policy.
12Recordkeeping
PayPilot maintains records of Website-related complaints sufficient to document:
- The date of receipt;
- The nature of the complaint;
- Relevant correspondence;
- The steps taken to review the matter;
- The response and outcome; and
- The date the complaint was closed.
As a standard practice, complaint records are retained for three years after closure, unless a longer period is necessary under applicable law or for the establishment, exercise or defence of legal claims.
Access to complaint records is limited to authorised personnel and advisers with a legitimate need to review them.
13Continuous Improvement
PayPilot may review complaints collectively to identify recurring issues, improve Website information and communications, and strengthen its internal procedures.
The Company may revise this Policy to reflect operational developments, changes in law or the commencement of authorised activities.
14Changes to This Policy
The current version of this Policy will be available on the Website.
Any revised version will state its effective date. Changes will not restrict rights or remedies that cannot lawfully be excluded.