Complaints policy

1. Purpose and scope

This policy applies to complaints about Nomos Pay, our services, our staff, and the way we have handled your account or your money. It applies to individuals and to business customers.

Complaints are handled separately from ordinary support requests, are recorded centrally, and are reviewed by someone with the authority to put things right.

2. What is a complaint, and what is not

A complaint is an expression of dissatisfaction about our services, our conduct or our decisions, where you want us to investigate and respond. Examples include a transaction that was not executed as you instructed, a restriction on your account you believe was wrong, a fee you consider incorrect, poor service, or the way we have handled your personal information.

A support request is not a complaint. Asking how to complete verification, requesting a statement, resetting a credential or asking a product question is support, and is usually resolved faster through the support channel.

If you contact support and are not satisfied with the outcome, you can escalate the matter into a formal complaint at any time, and we will treat it as one.

3. Who can complain

You can complain if you are a customer, an applicant whose application was declined, an authorised user of a business account, or someone who has been directly affected by our services. A representative may complain on your behalf if you authorise them to do so in writing, and we may need to verify that authority before we can share information with them.

4. How to make a complaint

Please mark your message clearly as a complaint, so that it is routed correctly rather than treated as a support request.

5. What to include

• Your name, and the email address or account identifier registered with us.
• What happened, with dates and, where relevant, transaction references or amounts.
• Why you think it was wrong, or what impact it has had on you.
• What you would like us to do to put it right.
• Any documents or screenshots that support your complaint.

Never send us your password, a two-factor code or a recovery phrase, in a complaint or in any other message. We will never ask you for them.

6. What happens next

We will aim to provide a substantive response as soon as reasonably practicable. Where a statutory or partner-mandated deadline applies to your complaint, we will comply with it, and it will be stated here: [INSERT APPLICABLE REGULATORY COMPLAINT DEADLINE].

1. Acknowledgement. We will acknowledge your complaint and confirm who is handling it. We aim to do this promptly and within a reasonable period of receiving it.
2. Investigation. We review the account records, transaction data, communications and system logs relevant to your complaint, and speak to the people involved. Where a partner is involved, we raise it with them.
3. Contact. If we need more information from you, we will ask. If the investigation is taking longer than expected, we will tell you why and give you an updated timeframe.
4. Resolution. We reach a decision, explain the reasoning, and set out what we will do. Where we have made a mistake, we say so and put it right.
5. Final response. We confirm our conclusion in writing, together with any redress and, where it applies to you, information about escalating the matter further.

7. If you are not satisfied

If you are unhappy with our final response, tell us and we will escalate the complaint to a senior reviewer who was not involved in the original decision.

Depending on where you live and the nature of your complaint, you may also have the right to refer the matter to an external dispute resolution body, an industry ombudsman, a privacy regulator or another authority. Where such a right applies to you, we will tell you which body, and by when you must refer the matter, in our final response.

Nothing in this policy limits any legal right you have to take a matter to court.

8. Particular types of complaint

9. Records, confidentiality and review

We record every complaint, the investigation and the outcome, and retain those records for the period required by applicable law. Complaints data is reviewed periodically by management to identify recurring issues and improve the service.

We handle complaints confidentially. Information is shared internally only with those who need it, and externally only with a partner, a regulator, an authority or a professional adviser where necessary or required by law.

This policy is reviewed at least annually and whenever our regulatory obligations change.

Entity and contact details

These details will be completed and confirmed by counsel before publication. Where a placeholder appears below, the information has not yet been confirmed and must not be relied upon.