Complaints Procedure

Introduction

1. Clearcrest Inc. UAB (“LoonieBit” or “we,” “us,” “our”) is a licensed crypto-asset service provider with registration number 306094970, and registered address at Lviv st. 21A, LT-09313, Vilnius, Lithuania. We provide high-quality crypto-asset exchange services focusing on crypto-asset wallets, enabling the exchange between fiat currency and crypto-assets and among different crypto-assets (“Services”).
2. We give top priority to your experience and are committed to paying due regard to the interests and needs of each and all of you, including fair, clear, and not misleading communication.
3. As part of these arrangements, we employed complaints handling procedures to ensure that any complaints are resolved as quickly as possible and, where necessary, trigger an internal review into the quality of Service being provided and whether or not it can be improved.
4. Below, you will find a procedure that indicates the main principles and guidance to be followed in the event you are not satisfied with our Services and would like to file a complaint with us.

Initiation of Complaint

1. We consider a complaint as an expression of dissatisfaction with our Services, regardless of whether it is justified or not, related to our products / Services or the complaints handling process, where a response or resolution is explicitly or implicitly expected. 
2. An eligible complaint may be made by any person directly affected by how we have provided our Services and who can make a complaint concerning it. Therefore, you may file the complaint respectively to us if you are: 

• individual client (natural person) that uses our Services or
• a legal representative of any individual client of ours.

1. Our employees are always conscious that, although an ineligible complaint may be made, the issue raised may still impact the quality of our Services; therefore, on such a complaint, our respective employees will still seek to review and respond to all of such complaints on a case-by-case basis.

Complaints Handling Procedure

File a Complaint

1. If such a situation occurs under which you find yourself dissatisfied with our Services, at all times, you can express your complaints via the following means:

• Via email: As a first instance of simple daily and/or operational questions/issues, contact us at support@looniebit.com. Our Customer Support Team Lead addresses the complaints received in this instance. If the Customer Support Team Lead cannot assist you with a variety of issues quickly and efficiently or, on the rare occasions they are not able to assist directly, the complaint you filed will be able to escalate to our Chief Compliance Officer;
• Via the Customer service portal on the web https://looniebit.com/support-center;
• Via post, send the complaint to our address at Lviv st. 21A, LT-09313, Vilnius, Lithuania.

1. To help us investigate and resolve complaints effectively, competently, diligently, and impartially, you will be instructed to provide the following information:

• your full name, address, e-mail address, and contact phone number(s);
• a description of the complaint (i.e., a description of the issue, the date and time that the issue occurred, your willingness on how it would consider the complaint would have to be resolved, etc.);
• any additional documentation or information that may support the complaint.

1. Aiming for the most efficient complaint-handling procedure, we recommend submitting your complaint using the complaint form, which can be accessed here (download the form). However, we may also accept another form for complaints as it may be convenient for you. In such a case, please make sure that you indicate all circumstances in detail for you to understand the subject matter and other key details, as well as the main problem(s) of the complaint, aiming to provide feedback to you.
2. Your complaint will be communicated to our Customer Support Team Lead and the Chief Compliance Officer (if needed) immediately or as soon as practicable upon receipt of the complaint. 
3. You may file the complaint in English, or any official language of the European Union, which is also an official language of the Member State of the European Union where our Services are provided.
4. Filing of the Complaint is free of charge. Should you require assistance making/filing the complaint, reasonable assistance may be provided from our side free of charge and promptly by our Customer Support Team.

Send Acknowledgment to the Complaint

1. Upon receipt of any complaint, our respective department will be responsible for acknowledging your complaint within 48 hours.
2. You will receive a written acknowledgment of the complaint received. Such acknowledgment will include estimated timeframes for our response to your complaint.

Reviewing/Assessment of Complaint

1. We will carefully evaluate the complaint and other related departments, if any, to ensure a high-quality response within an appropriate time, which will include the consideration of the complaint and whether this can be resolved immediately or whether an investigation is required.
2. When reviewing your complaint, we will pay due regard to the interests of yours and treat you fairly, assessing the following matters:

• whether the complaint is clear and contains all relevant information necessary for the handling;
• subject of the complaint;  
• whether the complaint should be upheld;  
• that remedial action and/or redress may be appropriate for you;  
• the root cause, and
• whether the complaint could have been prevented.

1. Suppose the investigation results show that the root cause of the complaint is our system or operational flaws. In that case, this should be identified and acknowledged, and restitution may be offered to you where appropriate.
2. Suppose the investigation concludes that the subject matter of the complaint was not caused by negligence, willful misconduct, default of ours, or inevitable and unpredictable factors. In that case, we will explain this to you by providing the relevant information or facts on which the investigation conclusion is based.

Prioritization of Complaints

1. To ensure a structured and effective complaint-handling process, we prioritize complaints based on their potential impact on our Services, you, and our regulatory obligations.
2. Complaints that pose a higher risk, such as legal violations, data breaches, or significant financial losses, are handled urgently, while lower-risk complaints follow our standard complaint resolution process.

Communication With You

1. After assessing the complaint and/or conducting an investigation against the complaint, we will issue a final response with its findings and the proposed solutions (if any) to you via the same communication channel that you used to submit the complaint unless you request us to use a different method (form) of response. 
2. Notably, you will always be answered in writing. We aim to respond to your complaint within 14 business days, starting from the date of receiving the complaint. However, if your complaint relates to a potential fraud case, it will be prioritized, and a response will be provided within 10 calendar days from the date of receipt.
3. In exceptional cases, where the complaint cannot be resolved within the standard timeframes as indicated earlier, we will notify you thereof and indicate the circumstances of the delay in submitting the complaint and the term by which the complaint will be examined and provided to you. In any event, the total resolution period will not exceed 35 business days from submitting your complaint.
4. In case when the resolution is provided, and your complaint is rejected or partially satisfied, we are obliged to state the reasons for the refusal to satisfy the complaint and indicate other means of protection of your interests, if possible, including but not limited to possible means of dispute settlement and courts.

Additional Investigations

1. If you are dissatisfied with our response, additional investigations and/or remedies may occur. Additional investigations and related questions may be referred to the board or other responsible company body for further decision. 
2. Suppose you are still not satisfied with our response. In that case, you may be entitled to report the complaint to the local governmental authority, which acts as our supervisory authority, i.e., the Bank of Lithuania.
3. You may submit a complaint to the Bank of Lithuania within 1 (one) year period from the date of the final response, in English language, by filling in the application form as specified on the website of the Bank of Lithuania. 
4. However, you should be aware that depending on the background of the complaint, different governmental authorities may be responsible for handling such complaints (i.e., the State Consumer Rights Protection Authority).

Closing the Complaint & Record Keeping

1. We will consider a complaint as resolved when:

• we have sent a final response, or
• you have accepted any written redress.

1. We keep and maintain a complaint registry for each complaint received. The information kept on record includes:

• your name;
• date and description of the complaint;
• the email address associated with you and your user profile;
• in certain cases, your user profile ID number and phone number associated with your user’s profile;
• when applicable, personal data of your legal representative;
• date and method of receipt of the complaint;
• date of the reply to you;
• ongoing status report;
• general information about the complaint, with short content;
• service or products addressed in the complaint;
• any redress offered by us;
• final decision, copies of documentation(s), and all relevant communication with you.

1. We will resolve the complaint and ensure that copies of relevant electronic correspondence are kept in our record-keeping system, the material related to the complaint and its examination, the document indicating the specific result of the examination of the complaint, and the answer provided to you. Such records shall be kept within our database for at least 5 years from submitting the final answer to you.

Learning From Experience

1. Any specific findings from complaints that can be directly addressed and used to increase your satisfaction will be considered.
2. Root cause analysis, correction, and enhancement will be included in system products and/or operational procedures to prevent future errors and increase your satisfaction.

Redress and Compensation

1. In cases where a complaint is upheld, we acknowledge our responsibility and may issue an apology as appropriate redress.

How to Contact Us

If you have any questions or need assistance, our team at LoonieBit is here to help. You’ll be able to reach us through the following channels:

1. Via email at support@looniebit.com;
2. Via phone number +14378869702 or +37052144957;
3. Or through the contact form provided on the website: www.looniebit.com/contacts.