Complaints Policy

Introduction & Company Commitment

BCASH S.A., as a crypto-asset service provider, is fully committed to its clients to provide high-level services with transparency, integrity, and respect. We recognize that, in any business activity, there may be circumstances where our clients or partners wish to express complaints, comments, or requests for improvement. This Complaints Policy aims to ensure that every complaint is handled with seriousness, objectivity, and impartiality.

Our company's Complaints Policy is based on a clear legal framework defined in accordance with Regulation (EU) 2023/1114 (MiCA) and Greek legislation (Law 4557/2018 on AML/CTF, Law 4624/2019 & GDPR). Compliance with these rules ensures that every report or complaint is treated with due respect, transparency, and responsibility. Complaints are accepted in writing, including electronically, in Greek (and in English, where feasible).

Purpose and Importance of the Complaints Policy

A “complaint” is any expression of dissatisfaction related to a service/behavior, which requires examination/response. A “query/request” does not constitute a complaint but is handled under a separate customer service procedure.
The purpose of this policy is to ensure that every complaint is reviewed in a fair, transparent, and efficient manner. The existence of a clear complaints procedure contributes not only to the protection of clients’ rights but also to the company’s continuous improvement. BCASH S.A. considers every complaint an opportunity for self-improvement, as client feedback is a valuable source of information regarding the quality of our services.

Who the Policy Concerns

The complaints policy is addressed to all of our company's clients, partners, employees, and any third party with a legitimate interest in the operation of BCASH S.A. Every individual has the right to express their concerns, whether they relate to the services provided, the behavior of executives, or issues of compliance, security, and personal data protection.

Complaint Submission Procedure

Clients may submit their complaint via email, through the dedicated form on our website, or by letter to the company’s headquarters. All reports and complaints are taken seriously and are immediately recorded in a special complaints register. The company has appointed a responsible person for managing complaints, who examines the case and ensures its proper and fair resolution.

Each complaint submitted is recorded in a special complaints log, in which the client’s details, the nature of the complaint, the submission date, and the progress of the review are registered. Subsequently, a preliminary assessment follows by the Customer Service Department, which may lead to further review by the Compliance Officer (AML/Compliance Officer) and/or Internal Audit, depending on the seriousness of the issue. "Complaint handling is carried out independently of the department involved; the four-eyes principle is applied and escalation to the Compliance Officer/Internal Audit is made where required.
Complaints are categorized (e.g., operational, regulatory compliance, technical in nature) and forwarded to the competent departments for immediate and effective action. In cases where serious regulatory compliance issues arise, there is a commitment to notify the Hellenic Capital Market Commission.

Timelines and Complaint Management

BCASH S.A. is committed to responding to every complaint within 15 business days from its receipt. In cases where more time is required due to complexity, we inform the client in writing about the progress of the process and the estimated timeframe for completion. Our goal is the complete and fair resolution of every complaint without delays.

Rights and Protection of Complainants

Every client has the right to express their complaint without fear of suffering any form of retaliation or discrimination. The company protects complainants and ensures that their voice is heard and evaluated objectively. Transparency and impartiality are fundamental principles of our process.

Confidentiality, Anonymity, and Data Security

BCASH S.A. maintains a strict confidentiality policy. All information received through complaints is handled with absolute confidentiality. There is a possibility to submit complaints anonymously, although in such cases, the ability to communicate and clarify may be limited.
The personal data of complainants are fully protected in accordance with the GDPR and Greek legislation.

Our company fully complies with the provisions of Law 4990/2022, which transposed into Greek law Directive (EU) 2019/1937 on the protection of persons reporting breaches of Union law (whistleblowing). Complainants have the right to submit anonymous or named reports without facing the risk of retaliation or discriminatory treatment.

All information received through complaints or reports is considered strictly confidential and used solely for investigative purposes. The personal data of the parties involved are maintained in accordance with GDPR, while technical and organizational security measures are applied to prevent unauthorized access. The principle of data minimization is observed; legal bases are applied according to GDPR/Law 4624/2019; in case of a data breach, notification to the Hellenic Data Protection Authority (HDPA) is made within 72 hours where required.

Record Keeping and Transparency

Every complaint is systematically recorded and archived. Data related to complaints are kept for a period of at least five years, so that they are available for inspections by the competent authorities or for the company’s internal audits. Record keeping contributes to monitoring the effectiveness of our procedures and to strengthening transparency.

All complaints are recorded and archived in an electronic database, which is accessible to the Compliance Officer. This data is incorporated into periodic compliance reports and feeds the annual risk assessment. The Complaints Register is kept for at least five (5) years, as stipulated by the regulatory framework, and is available in the event of an inspection by the Hellenic Capital Market Commission or other competent authorities. This record keeping contributes to transparency and the possibility of retrospective examination of systemic issues.

Commitment to Continuous Improvement

BCASH S.A. treats every complaint as an opportunity for improvement. We regularly analyze the complaints we receive in order to identify any recurring issues and take corrective actions.
Management monitors the effectiveness of the complaints policy and ensures its adaptation to developments in the regulatory framework and the needs of our clients.

The company systematically monitors key performance indicators (KPIs) related to complaint handling, such as average response time, complaint resolution rate, and recurrence frequency. The findings are evaluated annually by the Board of Directors and lead to adjustments in procedures, training, and policies.

In this way, the complaints policy is not a static document but a dynamic tool for the continuous improvement of corporate operations and for strengthening the trust of our clients.

Final Provisions

This Complaints Policy is available to all clients and published on the company’s official website. It is regularly updated to reflect changes in legislation and market needs. By implementing it, we confirm our commitment to transparency, accountability, and respect for our clients’ rights. If the client is not satisfied, they may appeal to the Hellenic Capital Market Commission (HCMC), in accordance with Art. 108 MiCA (see the complaint procedures of the competent authority).