CLIENT COMPLAINTS AND DISPUTE RESOLUTION POLICY
CLIENT COMPLAINTS AND DISPUTE RESOLUTION POLICY
(Complaint Handling and Dispute Management Framework)
Geloro Pay Ltd
Trading as Octapex
Registered Headquarters: 2100-1055 West Georgia St, Vancouver, British Columbia, Canada, V6E 3P3
Octapex provides crypto-asset services in accordance with applicable regulatory frameworks, including requirements of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), where relevant.
This Policy establishes a fair, transparent, and efficient framework for the handling of client complaints and the resolution of disputes.
1. Purpose and Principles
This Policy is designed to ensure:
• Fair and equal treatment of all clients
• Prompt and impartial complaint handling
• Clear and transparent communication
• Proper documentation and regulatory accountability
Octapex is committed to resolving complaints in a consistent, objective, and professional manner.
2. Scope of Application
This Policy applies to:
• All retail and professional clients
• Complaints related to services provided by Octapex
• Disputes involving transactions, account access, fees, or operational decisions
This Policy applies globally, subject to applicable mandatory consumer protection laws.
3. Definition of a Complaint
A complaint is any expression of dissatisfaction, whether oral or written, relating to:
• Provision of services
• Execution or non-execution of transactions
• Financial loss or perceived disadvantage
• Conduct of the Company or its representatives
• Alleged breach of contractual obligations
General inquiries or support requests are not considered complaints unless dissatisfaction is clearly expressed.
4. Initial Support and Informal Resolution
4.1 First Contact
Clients should initially contact:
• support@octapex.com
Submissions should include:
• Full name and account details
• Relevant transaction references
• Clear description of the issue
• Supporting documentation
• Desired resolution
Incomplete submissions may result in processing delays.
4.2 Preliminary Assessment
Upon receipt, Octapex will:
• Acknowledge the request promptly
• Conduct an initial review
• Request additional information if required
• Attempt to resolve the matter informally
Clients are expected to cooperate in good faith during this process.
5. Formal Complaint Procedure
5.1 Submission Requirements
If the issue remains unresolved, a formal complaint may be submitted to:
• support@octapex.com
The complaint must include:
• Nature of the dispute
• Timeline of events
• Supporting evidence
• Financial impact (if applicable)
• Requested resolution
5.2 Complaint Handling Standards
Octapex ensures that:
• Complaints are handled fairly and consistently
• The process is free of charge
• Conflicts of interest are identified and managed
• Complaint handling is independent from operational functions
5.3 Investigation Process
Octapex will:
• Conduct a structured internal investigation
• Review transaction records and blockchain data
• Consult Compliance, Risk, Legal, and IT teams
• Document findings and outcomes
Additional documentation may be requested where necessary.
5.4 Response Timeframes
Octapex will:
• Acknowledge complaints without undue delay
• Provide a response within a reasonable timeframe
If additional time is required, the client will be informed of:
• The reason for the delay
• The expected timeframe for resolution
5.5 Final Determination
Upon completion, the client will receive:
• A written decision
• Clear reasoning
• Any corrective actions (if applicable)
• Information on further escalation options
6. Protective Measures During Disputes
To mitigate risk, Octapex may apply temporary measures, including:
• Account restrictions
• Suspension of transactions
• Freezing of disputed funds
• Additional verification requirements
These measures are precautionary and do not imply fault.
7. External Escalation Rights
If the client remains dissatisfied, they may:
• Seek independent legal advice
• Refer the dispute to arbitration
• Submit a complaint to a relevant competent regulatory authority
This Policy does not limit statutory consumer protection rights.
8. Alternative Dispute Resolution (ADR)
Where applicable, clients may access alternative dispute resolution mechanisms:
• Participation is voluntary unless required by law
• Proceedings are conducted in good faith
• Confidentiality is maintained
9. Arbitration Framework
9.1 Initiation
Disputes may be referred to arbitration by mutual agreement following the final response.
Notice must be submitted within fourteen (14) days of the final decision.
9.2 Arbitration Process
Arbitration shall:
• Be conducted in Vancouver, Canada
• Follow applicable arbitration rules
• Be conducted in English unless otherwise agreed
The decision of the arbitrator shall be final and binding.
9.3 Cost Allocation
• Each party shall bear its own legal costs
• Arbitration fees shall be shared equally unless otherwise determined
10. Record Management
Octapex maintains:
• A complaints register
• Investigation records and outcomes
• Documentation of corrective actions
Records are retained for a minimum of five (5) years, or longer where required by law.
11. Governance and Oversight
The Compliance Function is responsible for:
• Monitoring complaint handling processes
• Reporting complaint metrics to senior management
• Identifying recurring issues
• Recommending operational improvements
Senior management and the Board review complaint trends periodically.
12. Individual Dispute Resolution
Disputes shall be resolved on an individual basis, to the extent permitted by law.
This does not affect mandatory consumer protection rights.
13. Policy Updates
Octapex reserves the right to amend this Policy at any time.
Material changes will be communicated to users. Continued use of the platform constitutes acceptance of the updated Policy.