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COMPLAINTS HANDLING PROCEDURE

  1. Purpose
    2. This document summarises the complaints handling procedure (the “Procedure”) applied by Cloverum Finance (CY) Limited (the “Company”, “Cloverum”, “we”, “us” or “our”). The Procedure is designed to ensure that complaints are handled fairly, consistently, and promptly, and in accordance with applicable regulatory requirements, including Regulation (EU) 2023/1114 (“MiCAR”) and relevant CySEC expectations.
    This is a public-facing summary. It does not reproduce internal controls and recordkeeping in full. If there is any inconsistency between this Procedure and the Company’s internal complaints handling policy, the internal policy will prevail.
  2. Who we are
    3. Cloverum Finance (CY) Limited is a company registered in Cyprus under registration number HE 474703.
    Registered address: Kypranoros 13, Evi Building, 2nd Floor, Office 201, 1061 Nicosia, Cyprus.
    Regulatory status: Cloverum has applied to the Cyprus Securities and Exchange Commission (“CySEC”) for authorisation as a Crypto-Asset Service Provider (“CASP”) under Regulation (EU) 2023/1114 on Markets in Crypto-assets (“MiCA”).
  3. What is a complaint?
    4. A complaint is an expression of dissatisfaction by a client (or an authorised representative) regarding the provision of our services, a product, an action or omission, or the way a matter has been handled, where a response or resolution is expected.
  4. How to submit a complaint
    5. All complaints are handled free of charge. Complaints must be submitted in writing through the channels below:You may submit a complaint in any language that we use to market our services and/or communicate with our clients. Where needed, we may respond in a language agreed with you to ensure effective handling.
  5. What to include in your complaint
    • Complainant details: Full name (or legal entity name), identification/registration number, and (for legal entities) LEI (if available).
    • Client reference: Account number and/or client ID, and any relevant transaction references.
    • Contact details: Email, phone number, and address.
    • If submitted by a representative: Representative details and evidence of authority (e.g., a power of attorney), if requested.
    • A clear description of the issue: What happened, when it happened, and who was involved (including, where relevant, the Company’s employees or departments).
    • Supporting documents and evidence: Screenshots, correspondence, transaction records, or other relevant materials.
    • The impact: Details of any loss, damage, or detriment suffered (where relevant).
    • The outcome you are seeking: For example, correction, explanation, remedial action, or compensation.
  6. How we handle your complaint
    1. Acknowledgement
      2. We will acknowledge receipt of your complaint by email no later than the end of the next business day and provide a complaint reference number. Please use that reference number in any follow-up communications.
    2. Investigation and assessment
      3. We investigate complaints competently, diligently, and impartially. We may request additional information where necessary. We will assess the complaint fairly and consistently, including (as relevant):
      • The subject matter and factual circumstances;
      • Whether the complaint should be upheld;
      • What remedial action and/or compensation may be appropriate; and
      • Whether a third party may be solely or jointly responsible.
    3. Outcome and final response
      4. Our final response will clearly state whether we accept or reject the complaint, provide reasons, and (where applicable) describe any proposed redress or remedial action, including the method of calculation for any compensation offered.
  7. Timelines
    8. We aim to resolve complaints as quickly as possible. The following timelines apply:
    • Acknowledgement: by the end of the next business day after receipt.
    • Best-efforts early resolution: where possible, within 3 business days.
    • Standard deadline for a final response: within 15 business days from receipt.
    • If a final response cannot be provided within 15 business days: we will send a holding response explaining the reasons for delay and indicating an expected date for the final response.
    • Extended deadline: up to 35 business days. In any event, the complaint handling period will not exceed three (3) calendar months.
  8. Complaints attributed to third parties
    9. Where we have reasonable grounds to believe that another party may be solely or jointly responsible for the matter alleged, we may forward the complaint to that party. If we do so, we will inform you promptly in writing and provide the relevant party’s contact details.
  9. Further escalation (if you are dissatisfied)
    10. If you are not satisfied with our final response, you may consider escalating your complaint as follows (where applicable):
    1. Financial Ombudsman of the Republic of Cyprus
      2. You may submit a complaint to the Financial Ombudsman of the Republic of Cyprus (subject to eligibility criteria and applicable rules):
      • Website: http://www.financialombudsman.gov.cy
      • Email: [email protected]
      • Postal address: P.O. BOX 25735, 1311 Nicosia, Cyprus
      • Telephone: +357 22 848900
      • Fax: +357 22 660584 / +357 22 660118
    2. Cyprus Securities and Exchange Commission (CySEC)
      3. You may also submit a complaint to CySEC. Please note that CySEC does not have restitution powers and may not investigate individual complaints for compensation purposes.
      • Website: https://www.cysec.gov.cy/en-GB/complaints/how-to-complain/
      • General email: [email protected]
      • Postal address: P.O. BOX 24996, 1306 Nicosia, Cyprus
      • Telephone: +357 22 506600
      • Fax: +357 22 506700
  10. Data protection
    11. We process personal data for the purposes of receiving, investigating, responding to, and resolving complaints, including regulatory reporting where required. Please see our Privacy Policy for information on how we process personal data, retention periods, and your rights.
  11. Record keeping
    12. We maintain records of complaints and related correspondence for a period of five (5) years from the date of receipt of the complaint, in accordance with applicable requirements.
  12. Contact
    13. For complaints, please contact us at: [email protected].
    For general support queries (non-complaints), please contact: [email protected].