Complaints Procedure

Last Updated: 10.10.2025
Effective Date: 17.10.2025

At the Odin Pay s.r.o., a company registered in the Czech Republic, registration number 223 56 312 and having its official registered address at Olšanská 54/3 Prague 3 Žižkov 130 00, Czech Republic (the “Company”), our goal is to provide you with fast, efficient, and friendly services that meet your needs and leave you satisfied. We value your feedback, including complaints, and take them seriously. Our commitment is to address any concerns you may have promptly and effectively.

The Company maintains effective and transparent procedures for the prompt, fair and consistent handling of complaints received from clients. The Company has a properly developed complaint-handling internal process, in line with the MICA regulation.

This Procedure applies equally to all individuals involved in complaint reception, communication, documentation, or resolution, including external professionals engaged under outsourcing or outstaffing agreements (the “Engaged Individuals”). All such individuals operate under the authority and responsibility of the Management (CEO and CBO) and must comply with the standards and procedures set out in this document.

1. What is a complaint?

1.1 The “Complaint” means a statement of dissatisfaction addressed to the Company by one of its clients relating to the provision of one or more crypto-asset services.

2. How to initiate a formal complaint?

2.1 If you have any complaints about our services, please reach out to us at our website, using the form or via email: [email protected]. You can also send a complaint by post to the registered address of the Company visible at our website.

2.2 We encourage you to raise any issues or complaints with a member of our staff as soon as possible. When filing a complaint, please provide a clear and detailed explanation of the nature of your problem.

2.3 Attached please find below a template for filing complaints. We encourage the use of this template to ensure all necessary information is provided, however, its use is not mandatory for a complaint to be admissible. Please note that complaints are filed and handled free of charge.

3. Conditions for admissibility of complaints.

3.1 The complainant must provide valid identification details to verify their identity and eligibility to file a complaint;

3.2 Complaint must be submitted within a reasonable timeframe from the occurrence of the incident giving rise to the complaint;

3.3 The complaint must contain all relevant details, including a clear description of the issue, supporting evidence;

3.4 Complaints must not contain any abusive language;

3.5 Complaints must be submitted in English or Czech, being the primary languages used by the Company to market its services or communicate with clients. The final response will be provided in English or Czech, matching the language of the complaint.

3.6 The Company acknowledges a receipt of a complaint and informs the complainant about whether the complaint is admissible within 1 day after its receipt.

3.7 Where a complaint does not fulfil the conditions of admissibility, we will provide you with a clear explanation of the reasons for rejecting the complaint as inadmissible.

4. Acknowledgement of a complaint receipt.

4.1 The acknowledgement of receipt of a complaint, which you receive, will contain all the following:

4.1.1 the identity and contact details, including email address and telephone number, of the Support Team (Chief Operating Officer (COO)) to which, complainants can address any query related to their complaint;
4.1.2 a reference to the timeline applicable to complaint handling, including for acknowledging receipt of the complaint, requesting additional information, investigating a complaint and providing a response, specifying the maximum date by which you shall receive the final decision (i.e., not later than 35 business days from the date of receipt of the complaint, unless an extension is necessary).
4.1.3 a copy of the completed template filed by the client, clearly mentioning the date of its receipt.

5. Transparency in Investigation.

5.1 We are committed to keeping you informed about the progress of your complaint. We will provide you with at least one substantive update on the progress of the investigation every 15 business days, unless the final decision is issued sooner. Additionally, we will reply to any reasonable requests for information from you without undue delay.

6. What is the timeframe for resolving a complaint?

6.1 At the Company, we understand the importance of promptly resolving any complaints you may have. For simpler issues, our team members will work to address them immediately. However, for more complex issues, we have a formal Complaints procedure in place. We will document all the details of your complaint and arrange for you to be contacted by a member of our team who is best equipped to handle your specific issue.

6.2 Our goal is to send you a final response to your complaint within 15 business days from the date of receipt of the complaint, except for cases where additional time is needed for appropriate checks. In any case, the deadline for submitting the final answer cannot be longer than 35 business days from the date of receipt of the complaint.

6.3 We communicate our decision on a complaint to the complainant as soon as possible, within the timeline set forth in an acknowledgement of receipt of a complaint.

6.4 Where, in exceptional situations, the decision on a complaint cannot be provided within the timeline referred to above, we will inform you about the reasons for that delay and specify the date of the decision.

7. What is our process for addressing and resolving complaints?

7.1 Our support team members, managed by the COO, have got proper skills, knowledge, and expertise necessary for the professional complaints handling.

7.2 At our company, we are committed to efficiently processing and resolving all customer complaints. Our team members prioritize addressing complaints in a timely and equitable manner while maintaining integrity and objectivity.

7.3 All complaints are investigated impartially and objectively by dedicated personnel (primarily the COO as Support Team Lead). Cases involving complex legal, compliance, or financial risks must be escalated to the Head of Legal, Compliance Officer, and/or Risk Manager for objective assessment.

7.4 When you initiate the formal complaint process, we will send you a written acknowledgement that includes a reference number for your complaint and the name of the staff member who will handle your case.

7.5 If we are able to provide a final response immediately or within one day, we will do so. However, if we require additional information or more time to investigate the issue, we will request that you provide us with any necessary information and explain the reason for the delay. We will then provide you with an estimated timeframe for when we expect to reach a final decision. Our ultimate goal is to provide a satisfactory resolution to your complaint.

8. Further escalation.

8.1 If you are not satisfied with the final response to your complaint, you may first request a secondary review by the Management (CEO and CBO) or a designated Function Holder from the 3rd Line of Defence (e.g., Internal Business Auditor) by contacting us through the same email address provided earlier.

8.2 If the matter remains unresolved or if you are not satisfied with the final outcome, you have the right to refer your complaint to the Czech National Bank (ČNB), as the competent authority for out-of-court dispute resolution in the Czech Republic. You may refer the matter to the ČNB within the time limits and under the conditions specified by the relevant legislation. Information on the procedure for addressing the ČNB is available on its official website.

9. Document Control.

9.1 This Procedure may from time to time be updated or amended upon approval by the Management (CEO and CBO). We will post any such updates on the Website and an alert notification will be sent to you. Such updated Procedure as posted will take effect immediately, unless otherwise indicated.