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Complaints and Resolution Procedures

Note:The English version of this agreement is the governing version and shall prevail whenever there is any discrepancy between the English version and the other versions.

Introduction

This procedure describes how the Company handles any Complaint or grievance (”Complaint”) received. The Company has appointed a member of the Compliance team (Compliance Officer”) to oversee the handling of any Complaint. This allows the Company to ensure no Conflicts of Interest will occur in the handling of any Complaint and ensures that all measures internally and regulatory are followed efficiently fairly and promptly. It is the aim of the Company to resolve any Complaint at the earliest possible stage.

Receiving and Investigation of a Complaint

Complaints can be received by various means including letter, telephone, email, Live chat or in person. All Complaints will be initially handled by a member of the Back Office/Account Opening Department.

In order to process your Complaint you should include the following details:

  1. Your user ID/email address.
  2. The service provided by the Company related to your Complaint.
  3. The date/time of the service provided by the Company related to your Complaint.
  4. The capital and the value of the financial instruments related to your Complaint.
  5. Your proposed resolution.

The Person responsible shall examine, assess and verify the events leading to the Complaint based on the information you have provided.

Should the Complaint include any offensive language or uncontrolled vocabulary then the company reserves the right to refuse the Complaint.

Responding to Complaints

Once a Complaint has been submitted to the company, a written acknowledgement will be sent to you within 2 business days.

Within 4 weeks of receiving the Complaint the Company will send you either a final response or a “holding response” which indicates why the Company cannot yet resolve the Complaint and when the Company will be in touch again.

At the end of an 8 week period, the Company will send you either;

  1. A final response offering redress.
  2. A rejection of the Complaint together with reasons.
  3. A response which indicates why the Company is still not in a position to provide a final response together with an indication of when the Company will be able to.

If the Company does not receive a reply from you within 8 weeks then the Complaint will be considered as closed when either:

  1. The Company has sent you a final response.
  2. You have accepted an earlier response in writing.
  3. You have not responded within 8 weeks of the Company sending its response.

In addition, by the end of the 8 week period, should you remain dissatisfied with the Company’s final response then you may refer the Complaint with a copy of the Company’s final response to the Cyprus Securities and Exchange Commission, which is the relevant regulatory authority, for further investigation.

Compensation

Where the company decides that redress is appropriate, compensation will be fair and compensate for any acts of omission on the Company’s part for which the Company is reasonably responsible. Redress need not be financial, and can take the form of an apology. The company reserves the right to choose the method of resolution at its sole discretion.

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