Complaint Management Policy

1. Purpose of the Policy

This policy sets out the principles and procedures through which Globe Monnaie S.R.L. (“the Company”) receives, reviews, and resolves complaints submitted by clients of the TOKERO platform, ensuring a transparent, fair, and efficient process for all clients, in line with EU and national legislation on alternative consumer dispute resolution.

2. Legal Basis

  • Directive 2013/11/EU on Alternative Dispute Resolution (ADR) – establishes standards for ADR entities, including the general target of completing procedures within 90 calendar days from receipt of the complete file.
  • Government Ordinance no. 38/2015 (RO) – transposes the ADR Directive and regulates ADR between consumers and traders; ANPC coordinates the competent ADR entities.

3. Definitions

  • Complaint – any written communication by which a client expresses dissatisfaction regarding the services or products provided by the company, including in relation to transactions, custody, support, fees, or security.
  • Notification – information regarding potential irregularities without explicitly requesting a solution.
  • Consumer dispute – conflict between a consumer and a trader regarding contractual obligations related to the sale of goods or the provision of services, eligible for ADR.
  • ADR (Alternative Dispute Resolution) – the European Union term for mechanisms that allow consumer–trader conflicts to be resolved outside the courts, e.g., through mediation, conciliation, or arbitration.
  • ADR/SAL in Romania – the Romanian transposition of ADR through Government Ordinance no. 38/2015. ANPC (National Authority for Consumer Protection) coordinates and authorizes ADR entities in Romania.

4. Scope

This policy applies to all complaints submitted by individual or legal entity clients who use the services of the TOKERO platform, regardless of the communication channel used (email, online form, phone, or written correspondence).

5. General Principles

  • Transparency: clients are informed about how they can submit a complaint and the steps for resolution.
  • Impartiality: all complaints are reviewed objectively, without discrimination or preferential treatment.
  • Confidentiality: client data and the content of complaints are protected in accordance with data protection legislation.
  • Timeliness: complaints are resolved within a reasonable timeframe, in line with internal procedures.

6. Complaint Submission Channels

Complaints may be submitted as follows:

For complaints submitted in writing, through any of the above channels, please provide at least the following information:

  • Client’s full name;
  • Contact details (email, phone);
  • Transaction ID (if applicable);
  • Detailed description of the complaint;
  • Impact on the client;
  • Supporting evidence/documents attached;
  • The client’s requested resolution.

7. Complaint Resolution Procedure

  • Registration: all complaints received are recorded in the Complaints Register maintained by the Compliance Department.
  • Acknowledgement: the client receives confirmation of receipt of the complaint within a maximum of 5 business days.
  • Review: the complaint is reviewed by designated staff, under the coordination of the Compliance Department.
  • Resolution: the company formulates a reasoned response and, if applicable, proposes corrective measures.
  • Communication: the response is sent to the client within a maximum of 30 business days from receipt of the complaint.
  • Escalation: high-risk cases are reported to Management and activate incident procedures.
  • Closure: the solution and lessons learned are documented.

8. External Resolution Channels (ADR)

If the internal solution does not satisfy the client, they may contact:

  • ADR entities in Romania – accredited under GO 38/2015 and coordinated by ANPC; procedures are generally resolved within 90 days from receipt of the complete file.
  • The EU list of dispute resolution bodies available here.
  • The European Consumer Centres Network (ECC-Net) – for cross-border disputes.
  • The European Small Claims Procedure – a simplified judicial route.

9. Data Protection and Confidentiality

  • Data is processed strictly for the purpose of complaint management.
  • Access is restricted to staff involved in the process.
  • Data is anonymised for statistical reporting.
  • Retention periods are set out in the Company’s data retention policy.

10. Policy Review

This policy is reviewed annually or whenever necessary to ensure alignment with applicable legislation and best practices.

11. Miscellaneous

TOKERO continuously monitors all complaints to identify opportunities to improve services. Client feedback helps TOKERO build a better experience for all users.

If the client is not satisfied with the proposed solution, they may contact the competent authorities, in accordance with applicable European and national legislation.