Contact

Complaint Handling Policy

1. INTRODUCTION

This Complaint Handling Policy (hereinafter – “Policy”) sets out the process for receiving, reviewing, escalating and responding to complaints submitted in connection with the Website, onboarding, communications, Services, transactions, payments, payouts, settlement or other interactions with Frapex Inc. (hereinafter – “Company”, “We”, “Us” or “Our”).

The Company is registered with the Financial Transactions and Reports Analysis Centre of Canada (hereinafter – “FINTRAC”) as a money services business under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Certain payment-related Services may be subject to the Retail Payment Activities Act and the related requirements applicable to payment service providers in Canada. The Company does not represent that any Service requiring registration with the Bank of Canada is available unless and until the applicable registration, legal, regulatory and operational requirements have been satisfied.

The Company is committed to handling complaints in a fair, transparent, consistent and timely manner, in accordance with this Policy, Applicable Law and the Company’s internal procedures.

2. TERMS AND DEFINITIONS

For the purposes of this Policy, unless the context requires otherwise, the following terms have the meanings set out below.

Applicable Law means any law, regulation, rule, regulatory requirement, order, directive, guidance or other legal or regulatory requirement applicable to the Company, the Website, the Services, the Customer, the complaint or the relevant transaction.

Complaint means an expression of dissatisfaction submitted to the Company by a User, prospective Customer, Customer or other relevant person concerning the Website, onboarding, communications, Services, transaction processing, payment processing, payout, settlement, customer support, compliance request or another interaction with the Company, where a response or resolution is reasonably expected.

Company means Frapex Inc., a company incorporated under the laws of Alberta, Canada under company registration number 2027786017, with its registered office at 700-602 12 Ave SW, Calgary, Alberta, T2R 1J3, Canada.

Customer means a person or entity that has been accepted by the Company for onboarding, transaction discussions, provision of Services or another customer relationship, as applicable.

Electronic Funds Transfer means an electronic transfer of funds, where applicable to the relevant Service or transaction flow.

Money Transfer Services means transaction-specific fiat transfer services made on a Customer’s instruction to an identified payee, recipient or beneficiary, subject to the Company’s approval, compliance procedures and operational requirements.

OTC Virtual Currency Exchange and Settlement Services means over-the-counter virtual currency exchange and related settlement services that may include fiat-to-virtual currency, virtual currency-to-fiat or virtual currency-to-virtual currency transactions, where supported by the Company.

Payroll Payment Services means services involving transaction-specific payment or payout instructions related to payroll or similar payment flows, subject to the Company’s approval, compliance procedures and operational requirements.

Services means the services that may be provided by the Company from time to time, including Money Transfer Services, OTC Virtual Currency Exchange and Settlement Services, Payroll Payment Services and other related services, in each case to the extent legally permitted, registered, authorized or otherwise available to the Company.

User means any person who accesses, browses or uses the Website, submits an inquiry, sends a communication, uses a contact form or otherwise interacts with the Website before being accepted by the Company as a Customer.

Virtual Currency means a digital representation of value that may be used for payment or investment purposes and that is not fiat currency, including crypto-assets where they fall within the meaning of virtual currency under applicable Canadian AML/ATF requirements.

Website means the website available at https://frapex.exchange/ and any pages, content, communication tools, forms or functionality made available through that website.

You means the User, prospective Customer, Customer or other person submitting a Complaint, as applicable. Your has a corresponding meaning.

3. SCOPE OF THIS POLICY

This Policy applies to Complaints concerning:

  • access to or use of the Website;
  • inquiries, communications or customer support interactions with the Company;
  • onboarding, identification, verification, screening or eligibility assessment;
  • requests for, assessment of, or use of the Services;
  • Money Transfer Services, OTC Virtual Currency Exchange and Settlement Services, Payroll Payment Services or other related Services;
  • transaction processing, payment processing, payout, settlement, return, rejection, delay or cancellation;
  • Payment Instructions, wallet details, account details, payee, recipient or beneficiary information;
  • fees, charges, transaction confirmations, quotes or settlement instructions;
  • compliance requests, service restrictions or account/relationship-related decisions; and
  • any other matter relating to the Company’s Website, Services or customer-facing processes.

This Policy does not prevent the Company from applying any legal, regulatory, AML/ATF, sanctions, fraud-prevention, security, risk-management or operational measures required or permitted under Applicable Law or the Company’s internal procedures.

A Complaint submitted under this Policy will not automatically suspend, reverse or modify any transaction, payment, payout, settlement, compliance request, legal obligation or risk-management measure.

4. SUBMISSION CHANNELS

If You are dissatisfied with the Website, onboarding process, communications, Services, transaction, payment, payout, settlement or another interaction with the Company, You may submit a Complaint by email to: officialfrapexinc@gmail.com. 

Complaints should be submitted in writing to allow the Company to review the matter properly and maintain appropriate records.

Submitting and handling a Complaint is free of charge.

Complaints should preferably be submitted in English to facilitate efficient review and communication. Where reasonably practicable, the Company may consider Complaints submitted in another language.

5. INFORMATION TO INCLUDE IN A COMPLAINT

To help the Company register, assess and respond to Your Complaint efficiently, please provide the following information:

  • Your full name or company name;
  • email address and telephone number, where available;
  • Your role or relationship with the Company, for example User, prospective Customer, Customer, authorized representative, payer, payee, recipient, beneficiary or other relevant person;
  • the Service, transaction, payment, payout, settlement, inquiry or communication to which the Complaint relates;
  • the date of the relevant event, issue or incident;
  • any relevant transaction, payment, wallet, account, quote, reference, order, case or communication identifier, where available;
  • a short title identifying the issue;
  • a description of the Complaint, including the relevant facts in chronological order;
  • the outcome or resolution You are seeking; and
  • any supporting documents or materials that You consider relevant.

Supporting documents may include screenshots, transaction confirmations, payment instructions, settlement instructions, correspondence, notices, receipts, bank confirmations, blockchain transaction identifiers or other materials reasonably necessary to support Your Complaint.

You may submit a Complaint in any reasonable format, provided that it contains sufficient information to allow the Company to identify and assess the matter.

If the information provided is incomplete, unclear, inconsistent or insufficient to assess the Complaint, the Company may request additional information or documentation from You.

Failure to provide requested information may delay the review of the Complaint or prevent the Company from providing a complete response.

6. COMPLAINT REVIEW PROCESS AND TIMELINES

Upon receipt of a Complaint, the Company will register it and review whether it contains sufficient information to identify and assess the matter.

The Company will acknowledge receipt of Your Complaint within two (2) business days and, where applicable, assign a reference or tracking number for future correspondence.

The Company aims to provide a final substantive response within fifteen (15) business days from receipt of the Complaint.

If additional information or documentation is reasonably required from You in order to assess the Complaint, the Company will notify You promptly. The time required for You to provide the requested information may affect the overall review period.

In exceptional or complex cases, where the Complaint cannot reasonably be resolved within fifteen (15) business days, the review period may be extended up to thirty-five (35) business days.

Where an extension is necessary, the Company will provide an interim response explaining the reason for the delay and, where reasonably possible, indicating when the final response is expected.

Substantive responses will normally be provided in writing by email using the contact details provided by You.

The Company may be unable to disclose certain information where disclosure is prohibited, restricted or inappropriate under Applicable Law, regulatory requirements, AML/ATF obligations, sanctions requirements, confidentiality obligations, security requirements, internal investigation procedures or the Company’s compliance framework.

7. POSSIBLE OUTCOMES

Following review of a Complaint, the Company may, as appropriate:

  • provide an explanation of the relevant facts, decision, process or transaction status;
  • request additional information or documentation;
  • confirm that no further action is required;
  • correct an error, where an error is identified and correction is possible;
  • take operational, technical, compliance or customer support measures to address the issue;
  • escalate the matter for further internal review;
  • maintain, modify or reverse a previous operational or customer-facing decision, where permitted by Applicable Law and the relevant transaction documentation; or
  • take any other action that the Company considers appropriate in the circumstances.

The Company does not guarantee that every Complaint will result in the outcome requested by the complainant.

Any resolution will be subject to Applicable Law, compliance requirements, sanctions restrictions, payment or settlement limitations, blockchain network conditions, third-party provider requirements, transaction documentation and the Company’s internal procedures.

8. ESCALATION

If You are not satisfied with the Company’s initial response to Your Complaint, You may request that the matter be escalated for further review.

Escalation requests should explain why You disagree with the initial response and provide any additional information or supporting materials that You want the Company to consider.

The escalated review may be conducted by the Company’s Compliance Officer or other appropriately authorized personnel who were not directly responsible for the initial response, where reasonably practicable.

The Company will re-evaluate the Complaint, taking into account the information previously provided, any additional supporting materials and the outcome of the initial review.

Where reasonably necessary, the Company may request additional information or documentation from You as part of the escalation process.

The escalation review will be conducted within the timelines set out in this Policy, unless a different or shorter period is required under Applicable Law or regulatory requirements.

Nothing in this Policy limits any right You may have under Applicable Law to contact a competent authority, regulator, court or other dispute-resolution body.

9. COMPLAINTS INVOLVING COMPLIANCE, SANCTIONS OR AML/ATF MATTERS

Some Complaints may involve onboarding decisions, due diligence requests, service restrictions, transaction delays, transaction refusals, payment returns, wallet screening, sanctions screening, AML/ATF review, fraud-prevention measures, Travel Rule requirements, regulatory reporting or other compliance-related matters.

The Company may be legally restricted from disclosing specific details of internal reviews, monitoring alerts, risk assessments, suspicious transaction analysis, regulatory reporting decisions or communications with competent authorities.

The Company may also be unable to confirm whether a report has been filed with FINTRAC or another competent authority, or whether a particular transaction, wallet, payment flow or person is subject to internal review.

Where a Complaint involves a compliance-related matter, the Company will review the Complaint in accordance with this Policy while continuing to comply with Applicable Law, AML/ATF obligations, sanctions requirements, confidentiality obligations and internal compliance procedures.

10. COMPLAINT RECORD KEEPING

The Company maintains appropriate records of Complaints submitted under this Policy.

Complaint records may include, where applicable:

  • the original Complaint;
  • supporting documentation or files;
  • correspondence with the complainant;
  • internal review or investigation records;
  • information requests and responses;
  • escalation records;
  • decisions and final responses; and
  • records of any remedial or follow-up actions taken.

Complaint records are maintained in a manner designed to preserve their confidentiality, integrity and accessibility and to support complaint management, internal controls, audit, regulatory compliance, dispute resolution and the establishment, exercise or defence of legal claims.

As an internal record-keeping standard, complaint records may generally be retained for a period of five (5) years from the date on which the Complaint is finally resolved or closed, unless a different retention period is required or permitted under Applicable Law or the Company’s internal record-keeping framework.

Records may be retained for a longer period where reasonably necessary in connection with an ongoing investigation, dispute, litigation, regulatory inquiry, legal hold, audit or other legal or compliance requirement.

Personal Information submitted in connection with a Complaint will be processed and retained in accordance with the Company’s Privacy Policy and Applicable Law.

11. PERSONAL INFORMATION AND PRIVACY

The Company may collect, use, disclose, transfer, retain and otherwise process Personal Information in connection with receiving, registering, reviewing, investigating, escalating and responding to Complaints.

Such Personal Information may be processed for purposes including complaint investigation and resolution, customer support, compliance review, record keeping, fraud prevention, security, regulatory compliance, dispute resolution, legal claims and protection of the Company’s rights and interests.

The Company may share Personal Information relating to a Complaint with Third-Party Service Providers, professional advisers, banks, payment service providers, exchanges, custodians, settlement providers, regulators, law enforcement agencies, courts or other competent persons where necessary or permitted under Applicable Law.

Further information about how the Company handles Personal Information is provided in the Company’s Privacy Policy.

12. CHANGES TO THIS POLICY

The Company may update, amend, supplement or replace this Policy from time to time to reflect changes in Applicable Law, regulatory guidance, the Website, the Services, complaint-handling procedures, payment or settlement arrangements, technologies used, third-party providers, business activities or the Company’s compliance practices.

Any updated version of this Policy will be made available through the Website and will indicate the date on which it was last updated.

Where required by Applicable Law, the Company may provide additional notice of material changes.

The Company encourages You to review this Policy periodically to remain informed about the Company’s complaint-handling procedures.

13. CONTACT INFORMATION

Complaints, questions, notices, requests and other communications relating to this Policy may be submitted to the Company using the contact details below:

Company name: Frapex Inc.

Registered address: 700-602 12 Ave SW, Calgary, Alberta, T2R 1J3, Canada.

Website: https://frapex.exchange/ 

Email: officialfrapexinc@gmail.com 

Where a Complaint or communication relates to a specific Customer relationship, onboarding process, Service, transaction, payment, payout, settlement, wallet, account, payee, recipient, beneficiary or compliance request, the communication should include sufficient information to allow the Company to identify the relevant matter.