COMPLAINT HANDLING

About Spays

Spays is a commercial brand operated by 3-102-966866 Sociedad de Responsabilidad Limitada, a company registered under the laws of Costa Rica under corporate identification number 3-102-966866.

Spays does not issue or distribute its own crypto-assets. Instead, Spays provides commercial services relating to access to and exchange of third-party crypto-assets, wallet functionality, blockchain consulting and, where available, on-ramp and off-ramp services provided or facilitated through relevant third-party partners.

The availability and scope of particular services may depend on the applicable jurisdiction, regulatory requirements, technical capabilities, and partner arrangements.

Submitting a Complaint

Clients of Spays may submit complaints free of charge.

Complaints should be submitted using the following contact details:

  • Email for complaints: hello@spays.io
  • Recommended email subject: Complaint
  • Language of submission: English
  • Complaint form: An optional complaint form is available on the Spays website.

Use of the complaint form is encouraged but is not mandatory. Complaints submitted in another written format will also be reviewed, provided that they contain sufficient information for Spays to understand and investigate the matter.

Spays will acknowledge and handle complaints in a fair, objective, transparent, and timely manner.

Each complaint will be assessed impartially, and appropriate actions will be taken based on the circumstances of the complaint, the contractual relationship with the complainant, and applicable legal or regulatory requirements.

Records relating to complaints, investigations, communications, decisions, and remedial actions will be retained for legal, compliance, audit, and operational purposes.

Information Required to Process a Complaint

To allow Spays to properly investigate and process a complaint, the complainant should provide the following information:

  1. Full name and contact details of the complainant.
  2. Account number, client reference, transaction reference, wallet address, or other relevant identifying information, where applicable.
  3. Where the complaint is submitted by a legal representative:
    • the representative’s full name and contact details; and
    • a power of attorney or another official document confirming the representative’s authority to act on behalf of the complainant.
  4. A clear description of the complaint and the circumstances giving rise to it.
  5. Copies of documents, correspondence, transaction records, screenshots, receipts, or other evidence supporting the complaint.
  6. The date or dates on which the relevant event or events occurred.
  7. A description of any damage, loss, inconvenience, or other detriment allegedly suffered, where relevant.
  8. The resolution or remedial action requested by the complainant.
  9. Any other comments or information that may assist Spays in investigating the complaint.
  10. The place and date of submission and, where the complaint is submitted as a signed document, the complainant’s signature.

Failure to provide all of the information listed above will not automatically prevent a complaint from being considered. However, Spays may request additional information or documentation where this is reasonably necessary to investigate and resolve the complaint.

Acknowledgment and Assessment

Spays will acknowledge receipt of a complaint as soon as reasonably practicable.

The acknowledgment may include:

  • the date on which the complaint was received;
  • a complaint reference number;
  • the contact details of the person or department handling the complaint;
  • an indication of the expected processing period; and
  • a request for further information or documentation, where necessary.

Spays may contact the complainant during the investigation to request clarification, additional evidence, or further information.

The complainant should provide the requested information within a reasonable period. A delay in providing necessary information may affect the time required to complete the investigation.

Decision on the Complaint

Spays will communicate its decision to the complainant as soon as possible and, in any event, within 15 calendar days following acknowledgment of receipt of the complaint.

The decision will be communicated in English using the complainant’s provided contact details.

The response will, where appropriate, include:

  • a summary of the complaint;
  • the outcome of the investigation;
  • the reasons for the decision;
  • any corrective or remedial action taken or proposed;
  • any offer of compensation or reimbursement, where applicable; and
  • information about any further steps available to the complainant.

Where, due to exceptional circumstances, Spays cannot issue a final decision within the stated period, Spays will inform the complainant of:

  • the reasons for the delay;
  • the status of the investigation; and
  • the date by which a final decision is expected.
Complaints Concerning Third-Party Services

Certain services offered or facilitated through Spays may involve third-party providers, including payment service providers, banks, crypto-asset service providers, wallet infrastructure providers, liquidity providers, identity-verification providers, or other technology partners.

Where a complaint concerns a service provided by a third party, Spays may:

  • investigate the aspects of the complaint relating to Spays;
  • share relevant information with the third-party provider where necessary and legally permitted;
  • refer the complaint or the relevant part of it to the appropriate third-party provider; or
  • provide the complainant with information on how to contact the relevant provider directly.

Spays will remain responsible for handling the aspects of the complaint that relate to its own acts, omissions, contractual obligations, or services.

Confidentiality and Personal Data

Personal data provided in connection with a complaint will be processed in accordance with the Spays Privacy Policy and applicable data-protection laws.

Complaint information will be accessible only to authorised persons who require access for the purposes of investigation, resolution, compliance, legal advice, audit, risk management, or regulatory reporting.

Information may be disclosed to competent authorities, professional advisers, service providers, or business partners where this is necessary and legally permitted.

Contact Details

Commercial brand: Spays
Operator: 3-102-966866 Sociedad de Responsabilidad Limitada
Corporate identification number: 3-102-966866
Country of registration: Costa Rica
Complaints email: hello@spays.io