Complaints Handling Policy

1. Purpose and Scope

At Unramp OOD ("Unramp", "we", "us", "our") we aim to provide high‑quality services in connection with crypto‑asset transactions. If you believe that we have not met your expectations, or that you have suffered a loss, inconvenience or other detriment as a result of our services, you have the right to submit a complaint.

This Complaints Handling Policy explains:

• what a complaint is;
• who can submit a complaint;
• how to submit a complaint and what information to provide;
• how we will handle your complaint and within which timeframes;
• your options if you remain dissatisfied.

This Policy applies to all services provided by Unramp as a crypto‑asset service provider (CASP) in the process of authorisation under MiCA, the Bulgarian Act implementing it and other applicable Bulgarian laws.

This Complaints Handling Policy is a simplified summary of our internal complaints management procedures and does not describe every internal control or step in detail; it is provided solely to help clients understand, in a clear and accessible way, how they can raise concerns and how we will handle them.

2. What Is a Complaint

A complaint is any expression of dissatisfaction, submitted in a written form, from or on behalf of a client about our services, behaviour or handling of your crypto‑asset transaction that requires a formal review and response.

Complaints may relate in particular (but not exclusively) to:

• execution or processing of a crypto‑asset transaction (e.g. delay, non‑execution, incorrect amount);
• fees, charges, commissions or pricing;
• quality, clarity or timeliness of the communication or customer service;
• technical issues affecting the use of the Platform;
• alleged breach of the Terms and Conditions, policies or applicable law;
• handling of your personal data in the context of the Services.

Requests for information, clarifications or technical service issues which can be resolved as part of normal customer support may not be treated as formal complaints unless the client explicitly requests this or the matter cannot be resolved promptly.

3. Who Can Submit a Complaint

The following persons may submit a complaint under this Policy:

• individual users of Unramp services;
• (if applicable in future) legal entities that are direct clients of Unramp;
• duly authorised representatives acting on behalf of a user (e.g. legal representative, attorney‑at‑law, guardian).

If you submit a complaint on behalf of another person, please include a valid written authorisation or power of attorney. We may request additional documents to verify your authority.

4. How to Submit a Complaint

You may submit a complaint using one of the following channels:

4.1. By Email (preferred)

Email: [email protected]

Please include "Complaint" in the subject line so that we can prioritise your message.

4.2. By Postal Mail

Unramp OOD
Attn: Complaints Department
22 San Stefano Str., San Stefano Plaza
entr. B, 5th floor, Office 16
City of Sofia 1504
Bulgaria

4.3. Other Channels

Complaints submitted by telephone, live chat or other channels will be logged; however, we may ask you to confirm your complaint in writing (email or letter) to ensure that we have all necessary information to conduct a thorough investigation.

Submitting a complaint and participating in the complaint‑handling process is free of charge.

4.4. Template

Clients may use the Complaint template, available here. The usage of the template is recommended, but not a required prerequisite for the complaint handling.

5. What Information to Include

To help us process your complaint quickly and accurately, please provide, wherever possible:

• your full name and contact details (email address and, optionally, telephone number);
• the date and approximate time of the event or issue you are complaining about;
• a clear description of the problem and why you consider it unsatisfactory;
• what outcome or resolution you are seeking;
• relevant transaction identifiers (e.g. order number, wallet address, transaction hash);
• copies of any supporting documents (e.g. screenshots, receipts, statements, correspondence).

If essential information is missing or unclear, we may contact you to request additional details.

6. Complaint Handling Procedure

We handle complaints promptly, fairly and consistently, in line with MiCA expectations for CASPs and applicable Bulgarian and EU consumer‑protection principles.

Step 1 – Acknowledgement

We will acknowledge receipt of your complaint within 3 business days of receiving it. The acknowledgement will usually be sent by email and will include:

• confirmation that we have received your complaint;
• a reference number or identifier for your complaint;
• the name or function of the person or team handling your case;
• information about the next steps and expected timelines.

Step 2 – Investigation

We will investigate your complaint in a fair and impartial manner. This may include:

• reviewing relevant transaction data, system logs and internal records;
• checking applicable contractual terms, policies and regulatory requirements;
• consulting with relevant internal teams (e.g. operations, technical, compliance, AML);
• requesting further information or documentation from you, if needed.

We may contact you during the investigation to clarify certain points or to request additional evidence. Your timely cooperation will help us resolve the matter more quickly.

Step 3 – Response

We will provide you with our final written response without undue delay and in any case within 2 calendar months from the date we receive your complaint, unless a shorter timeframe applies under specific regulations.

If we are unable to provide a final response within 2 months, we will send you a response explaining:

• why we need more time;
• what further steps we are taking;
• when you can expect a final response.

7. Outcome of the Complaint

Our final response will include:

• a summary of your complaint and the main facts as we understand them;
• the outcome of our investigation;
• whether your complaint is upheld, partially upheld or rejected;
• any corrective actions or remedies we propose (if applicable), such as:
  • explanations or clarifications;
  • correction of records or technical issues;
  • refunds or adjustments, where justified and permitted by law and our policies;
• information on your options if you remain dissatisfied, including external escalation and legal remedies.

Our decision will be reasoned and based on the information available, applicable terms and conditions, internal policies and relevant laws and regulations.

8. No Additional Cost

Filing a complaint and participating in the complaint‑handling process with Unramp is free of charge. We will not charge you any fee for receiving, investigating or responding to complaints.

You may, however, incur costs for legal advice, postage or translation services if you choose to use them, which are your responsibility.

9. Alternative Dispute Resolution and External Remedies

If you are not satisfied with our final response, or if you have not received a final response within the indicated timeframe, you may seek redress through:

9.1. Bulgarian Financial Supervision Commission (FSC)

As Unramp is supervised as a CASP by the Bulgarian Financial Supervision Commission, you may contact the FSC with a complaint regarding our conduct, in accordance with the FSC’s procedures.

Financial Supervision Commission
16 Budapeshta Str.
1000 Sofia
Bulgaria
Website (complaints information): https://www.fsc.bg/en/for-the-consumers/complaints/

The FSC will assess whether we have complied with applicable legal and regulatory requirements and may take supervisory or administrative measures where appropriate.

9.2. European Online Dispute Resolution (ODR) Platform

If you are a consumer resident in the EU/EEA, you may also use the European Online Dispute Resolution (ODR) platform to submit a complaint and seek an out‑of‑court settlement:

ODR platform: https://ec.europa.eu/consumers/odr

9.3. Other National ADR Bodies

Depending on your country of residence and the nature of the dispute, you may have access to other national alternative dispute resolution (ADR) bodies or consumer protection authorities. Information on competent ADR entities in your Member State is available on the European Commission’s website.

9.4. Judicial Remedies

This Policy does not affect your right to bring legal proceedings before the competent courts under applicable law. You may decide to pursue court action at any time, whether or not you have used the internal complaints procedure or ADR options.

10. Language of Complaints

We handle complaints in English and Bulgarian. Complaints submitted in these languages will generally allow for faster processing.

Where possible, we may accept complaints in other languages; however, translation may be required, which could prolong the time needed to investigate and respond. In such cases, we will inform you if we expect a delay due to translation needs.

11. Privacy and Personal Data

Any personal data you provide in connection with a complaint will be processed in accordance with our Privacy and Cookie Policy and applicable data‑protection laws (including the GDPR and the Bulgarian Personal Data Protection Act).

We will use your information solely for:

• receiving, recording and managing your complaint;
• communicating with you about the complaint;
• complying with our legal, regulatory and reporting obligations.

We will retain complaint‑related data for as long as necessary to manage your complaint and to comply with legal and regulatory requirements, after which it will be deleted or anonymised in line with our data‑retention policy.

For more details, please refer to our Privacy Policy available on our website.

12. Review of This Policy

We may update this Complaints Handling Policy from time to time to reflect:

• changes in law or regulation (including MiCA‑related technical standards on complaint handling);
• guidance or expectations of regulators and supervisory authorities;
• changes in our internal processes or services.

The latest version of this Policy will always be available on our website and will indicate the date of last update.