Rules on Investigation of Complaints
I. General provisions
1. These Rules on Investigation of Complaints (the “Rules“) set out the procedure under which Satchelpay, UAB (the “Company“) investigates complaints from its clients or potential clients (the “Applicant“) regarding financial services provided by the Company or agreements concluded with it (the “Complaint“). These Rules apply equally to Complaints submitted by natural persons and legal persons.
2. These Rules are prepared in accordance with the Law on Payments of the Republic of Lithuania, the Law on Electronic Money and Electronic Money Institutions of the Republic of Lithuania, Resolution No. 03-105 of the Board of the Bank of Lithuania of 6 June 2013 “On the Approval of the Rules on the Examination of Complaints Received by Financial Market Participants”, and other applicable legal acts.
II. Scope of Complaint
3. Any expression of dissatisfaction with the Company’s actions or omissions submitted to the Company shall be treated as a Complaint, regardless of the form of submission, communication channel or terminology used by the Applicant.
4. The following are not treated as Complaints: (a) requests for identification of a payment, payment remitter or person depositing funds; (b) requests for assistance with payment returns or recipient identification; (c) requests for copies of payment documents; (d) suggestions for service improvement or product modification; (e) matters concerning activities not regulated by financial market laws and not supervised by the Bank of Lithuania.
For the avoidance of doubt, where the content of a message indicates dissatisfaction with the Company’s actions or omissions, such message shall be treated as a Complaint.
5. Where the Company is not responsible for the activity referred to in the Complaint, the Company shall notify the Applicant, give reasons and, where possible, indicate the appropriate person or institution.
III. Submitting a Complaint
6. The Applicant shall submit the Complaint to the Company without undue delay, and in any event within 3 (three) months from the date when the Applicant became aware or should have become aware of the matter giving rise to the Complaint. This deadline does not apply to Complaints concerning unauthorised or improperly executed payment operations, for which the 13-month notification period set out in Article 36(1) of the Law on Payments and the Company’s General Terms and Conditions applies.
7. The Complaint shall include: (a) for natural persons – name, surname, date of birth, contact details (e-mail and/or phone number); (b) for legal persons – name, registration code, registered address, contact details; (c) the date and circumstances of the matter complained about; (d) a clear description of the issue and the actions of the Company that the Applicant disagrees with; (e) the Applicant’s expectations regarding the outcome.
8. The Complaint shall be submitted in Lithuanian or English and shall be signed by the Applicant or the Applicant’s authorised representative. Where the Complaint is submitted by a representative, the representative shall provide a copy of an identity document and a power of attorney or other document evidencing the right to act on behalf of the Applicant.
9. The Applicant is responsible for the accuracy of the contact details provided. The Company will use the contact details given in the Complaint to communicate during the Complaint handling process. Where the Applicant has provided an e-mail address, the Company may communicate by e-mail.
10. The Complaint may be submitted free of charge through the following channels: (a) by registered mail to: SatchelPay, UAB, Geležinio vilko g. 18A, LT-08104, Vilnius, Lithuania; (b) by e-mail to info@satchel.eu; (c) through the online complaint form at https://satchel.eu/customer-complaint-form/.
Complaints submitted verbally or through other communication channels shall also be treated as Complaints where the content indicates dissatisfaction with the Company’s actions or omissions, provided that the Complaint is recorded by the Company.
11. Where the Complaint does not contain the information needed for the investigation, the Company may request the Applicant to provide additional information or documents within a reasonable time, which shall not be shorter than 7 (seven) calendar days. If the shortcomings are remedied within the deadline, the Complaint is considered submitted on the date of remedying. If the Applicant does not remedy the shortcomings, the Company may decline to investigate the Complaint and shall inform the Applicant accordingly.
12. The Company may decline to investigate a Complaint that concerns the same matter and is based on the same grounds as a Complaint already investigated and resolved for the same Applicant. The Company shall inform the Applicant of such decision.
IV. Investigation of the Complaint
13. The Company investigates Complaints following the principles of fairness, objectivity, impartiality, reasonableness and respect for the rights of the Applicant. All relevant circumstances and evidence available to the Company are taken into account.
14. The Company keeps Complaint-related information confidential and discloses it only to persons necessary for investigation and resolution. Personal data is processed only to the extent necessary for handling the Complaint.
V. Response and decision
15. The Complaint is investigated, and a written response is provided to the Applicant as soon as possible and in any event no later than within 14 (fourteen) calendar days from the date of receipt of the Complaint. The same deadline applies to all Applicants, whether natural or legal persons, consumers or non-consumers.
16. Where, in exceptional cases due to reasons beyond the Company’s control, the Complaint cannot be fully investigated within 14 calendar days, the Company shall inform the Applicant in writing before the initial deadline expires, specify the reasons for the delay and indicate the new deadline. In any event, the maximum complaint handling period shall not exceed 35 (thirty-five) business days from the date of receipt of the Complaint.
17. Following the investigation, the Company makes one of the following decisions: (a) to satisfy the Complaint; (b) to partially satisfy the Complaint; (c) to reject the Complaint.
Where the Complaint is satisfied or partially satisfied, the Company shall implement the corrective measures without undue delay.
18. Where the Complaint is rejected or only partially satisfied, the Company’s response shall be reasoned and based on factual findings, applicable legal acts and contractual provisions. The response shall additionally inform the Applicant of: (a) for consumers – the right to apply to the Bank of Lithuania as the consumer dispute resolution body, including its contact details; (b) for non-consumers – the right to refer the dispute to the courts of the Republic of Lithuania.
19. The Company’s decision is communicated to the Applicant by registered mail, e-mail or any other channel agreed between the Company and the Applicant.
VI. Final provisions
20. The Company stores Complaints and related documents for at least 3 (three) years from the date of the final response, in accordance with applicable law.
21. The Company submits aggregated information about Complaints to the Bank of Lithuania in accordance with applicable supervisory requirements.
22. These Rules are governed by the laws of the Republic of Lithuania.
23. The Company may amend these Rules at any time. The amended Rules take effect on the date of their publication on the Company’s website, except where the Law on Payments or other mandatory law requires prior notice to clients.