Complaints Procedure

Coinbar s. r. o. ("Coinbar") is a crypto-asset service provider. Its competent authority is Národná banka Slovenska (NBS). Coinbar maintains an effective and transparent procedure for handling complaints promptly, fairly and consistently.

Any client or potential client (for example, an applicant whose request to open an account was refused) may make a complaint. Making a complaint and having it handled is free of charge.

You may complain in particular about:

• custody and administration of your crypto-assets (for example balances, statements of positions, crediting of crypto-asset deposits)
• exchanges with Coinbar Direct (quote, price, commission, completion of the exchange)
• transfers of crypto-assets (withdrawals, network fees, held or rejected transfers)
• EUR deposits by SEPA transfer and their automatic exchange into EURC
• account opening and identity verification (KYC/KYB), including a decision to refuse or restrict an account
• the protection of your personal data (you may also contact the Slovak data protection authority, see section 7)
• the conduct of our staff or the quality of customer support

By "complaint" we mean any statement of dissatisfaction with Coinbar’s services that you address to us. If you are not sure whether your message is a complaint or an ordinary request, mark it as a complaint and we will handle it under this procedure.

Please make your complaint in writing through one of the channels below.

Never send us your password, two-factor authentication codes or other login credentials. Coinbar will never ask you for them.

We acknowledge receipt of your complaint in writing (usually by e-mail) without undue delay. The acknowledgement states:

• the contact point you can reach about your complaint
• the indicative timeframe within which we will handle it

If it is not clear who is making the complaint, or if we need to verify your identity before sharing information about your account, we will ask you to confirm it.

Your complaint is investigated by Coinbar’s complaints-management function. This function is independent of the business unit whose activity the complaint concerns, and a complaint is never investigated by the person whose conduct it is about. Any conflicts of interest are managed under Coinbar’s conflicts-of-interest policy (Article 72 of the MiCA Regulation).

During the investigation we:

• examine all relevant facts and records (for example records of trades and transfers, blockchain data and our correspondence with you)
• may ask you for additional information or documents where needed
• compare your complaint with our decisions on similar complaints, so that we act consistently

We investigate every complaint fairly and in a timely manner, with due regard to your legitimate interests.

We decide on your complaint without undue delay and at the latest within two months of receiving it. We send you the decision in writing (by e-mail or on another durable medium) in the language of your complaint.

The decision:

• addresses every point raised in your complaint
• states the reasons on which it is based
• is consistent with our decisions on similar complaints
• if your complaint is upheld, states the measures we will take
• if your complaint is rejected or only partly upheld, tells you about the remedies available outside Coinbar (section 7)

If, exceptionally, we cannot decide within that period, we will tell you the reasons for the delay and the date by which we will decide.

The decision cannot contain information that Coinbar is prohibited by law from disclosing — for example information on a report of an unusual transaction under the anti-money-laundering rules (zákon č. 297/2008 Z. z. o ochrane pred legalizáciou príjmov z trestnej činnosti a o ochrane pred financovaním terorizmu).

Coinbar keeps a register of all complaints received and of the measures taken in response (Article 71 of the MiCA Regulation).

• We analyse complaints regularly to identify recurring problems and their causes, and to remedy them.
• The complaints-management function regularly reports to Coinbar’s management on complaints and the measures taken.
• We make the register available to the competent authority (NBS) on request.

We keep complaint records for the periods required by the MiCA Regulation and the anti-money-laundering rules. Details on how we process personal data are in the following document: Privacy Policy

If you are not satisfied with the decision on your complaint, or if we have not decided within the timeframe, you have the options below. Using this procedure does not limit these rights.

When you make a complaint, you have the following rights:

• Making a complaint is free of charge; Coinbar charges no fee for handling it.
• The fact that you have complained is never a reason to restrict, block or close your account or to worsen the terms on which we provide our services to you.
• You may be represented by a person of your choice; the representative must prove their authority with a written power of attorney.
• You may withdraw your complaint at any time.
• This procedure does not limit your right to turn to the supervisory authority (NBS), an ADR body or a court.
• We process the personal data in your complaint only to handle it and to meet our legal obligations.

Send complaints and questions about this procedure to:

Company name

Coinbar s. r. o.

Registered office

Krajná 17137/7C, 821 04 Bratislava-Ružinov, Slovakia

Complaints e-mail

[email protected]

Customer support e-mail

[email protected]

Data protection e-mail

[email protected]

Competent authority

Národná banka Slovenska (NBS), Imricha Karvaša 1, 813 25 Bratislava