Complaints Handling Policy

Last modified: Twenty fourth of September 2013 (24/09/2013 – UK date format)

CH1 Introduction

This module sets out the procedure for handling complaints about the Service.

The Provider (“we”, “us” or “our”) will follow the procedure set out in this module in dealing with your complaints. We will only follow the time limits set out here if you are a Consumer or a Micro-Enterprise and your complaint is about a Payment Transaction. In all other cases we will try to deal with your complaint within a time period appropriate to the relevant factors and complexity of your complaint.

Terms not expressly defined in the complaints handling procedure are defined in the main Agreement between the provider and yourself (in particular within the Basic Access module).

 

CH2 Our Approach

We will:

  • investigate your complaint competently, diligently and impartially;
  • assess fairly, consistently and promptly:
    • the subject matter of the complaint;
    • whether the complaint should be upheld; and
    • what remedial action or redress (or both) may be appropriate.

We will (taking into account all relevant factors):

  • offer redress or remedial action if we decide this is appropriate;
  • explain to you promptly and, in a way that is fair, clear and not misleading, our assessment of the complaint, our decision on it, and any offer of remedial action or redress; and
  • comply promptly with any offer of remedial action or redress accepted by you.

 

CH2 How to Complain to Us

If you have a complaint or are unhappy about the Service, you should, in the first instance, contact us and we will endeavour to resolve any problems as quickly as possible.

We recommend that if you have a complaint that you do so by e-mail to the E-mail Address: support@business.entropay.com. Alternatively you may submit your complaint to us by post) to the Address: Ixaris Systems, 22 Long Acre, London WC2E 9LY You must provide us with your name, address, e-mail address, the details of the Payment Transaction in question and a summary of your complaint.

We recommend that you use e-mail to contact us with your complaint as this is the fastest way for us to resolve the matter.

 

CH3 Initial Response

We will respond to your complaint by the end of the next Business Day after the day we receive your complaint by email or by post.  In this response we will acknowledge our receipt of your complaint and we will confirm that we are dealing with the matter.

If after four weeks of our receipt of your complaint, we have not responded in accordance with CH4 below we will send you an e-mail or a letter, setting out the progress of your complaint and what measures we are taking to resolve the complaint.

A complaint sent by you to us by e-mail will be deemed to have been received on the day it is sent except if it is sent on a non-Business Day or after 17:30 (London time) on a Business Day in which case we will be deemed to have received the reply the next Business Day.

A complaint sent by you to us by post will be deemed to be received by us on the day that we receive it.

 

CH4 Written Response

We will send within four weeks of receiving your complaint a written response by email or via post. In this response we will:

  • either (i) offer redress or remedial action (whether or not we accept the complaint), or (ii) reject the complaint and give our reasons for doing so;
  • inform you that if you are dissatisfied with our response that you may escalate your complaint with us so that we must consider the complaint again; or
  • inform you that you may now refer your complaint to the card issuer, if having exhausted the IDT Financial Services Limited complaints procedure you remain unhappy; and
  • refer you to the availability of the Financial Ombudsman Service (“FOS”) and additional complaints escalation routes including the Financial Service Commission (“FSC”)in Gibraltar when relevant  dependent on the issuer of your card if you remain dissatisfied with our response and you are a Consumer or a Micro-Enterprise; and
  • inform you that we will regard the matter closed if we do not receive a reply from you within eight weeks of you receiving our written response.

You will be deemed to have received our written response if by email on the day sent and if by post on the day that we receive it.

You may reply to us by e-mail sent to the E-mail Address: support@business.entropay.com  or by post sent to the Address: Ixaris Systems, 22 Long Acre, London WC2E 9LY. We will be deemed to have received a reply sent by e-mail on the day it is sent except if it is sent on a non-Business Day or after 17:30 (London time) on a Business Day in which case we will be deemed to have received the reply the next Business Day. We will be deemed to have received a reply sent by post on the day that we receive it.

If you do not reply to our written response within the time period specified above, we will send you a final response by email or by post, repeating our written response and that we regard the matter as closed.

If you do reply to our written response as above and you chose to escalate your complaint, we will reconsider your complaint along with any additional information you provide. We will respond in writing by email or via recorded delivery post, within the time span specified above, with:

  • a final response setting out our final offer of redress or remedial action (whether or not we accept the complaint), or our rejection the complaint and the reasons for doing so; or
  • a second written response in which we:
    • explain why it is not possible for us to give a final response and gives an indication of when we expect to be able to do so;
    • inform you that you may now refer your complaint to the card issuer, If having exhausted the IDT Financial Services Limited complaints procedure you remain unhappy, you may complain to the FOS or the FSC in Gibraltar,  depending on the complaints escalation route provided by the issuer of your card if you are a Consumer or a Micro-Enterprise; and
    • enclose a copy of the FOS standard explanatory leaflet (if relevant).

In our final response we will also inform you that you have a six-month period in which to complain to the FOS should you want to, after which the FOS will exclude you from consideration.

 

CH5 FOS

If you are unhappy with how we have handled your complaint, you can additionally contact them stating the nature of your complaint at IDT Financial Services Limited, Customer Services, PO Box 1374, Gibraltar. Once your complaint has been received by IDT, a complaints officer will investigate it and respond.

If having exhausted the IDT Financial Services Limited complaints procedure you remain unhappy, you may complain to the Financial Services Commission (“FSC”), PO Box 940, Suite 3, Ground Floor, Atlantic Suites, Europort Avenue, Gibraltar. Tel +350 200 40283, Fax +350 200 40282, e-mail psdcomplaints@fsc.gi, web www.fsc.gi or you may refer your complaint to the FOS which can be contacted by post at Financial Ombudsman Service (“FOS”), South Quay Plaza, 183 Marsh Wall, London E14 9SR, by telephone on 0845 0800 1800, and by email at enquiries@financial-ombudsman.org.uk.

We will cooperate fully with the FSC and FOS and comply promptly with any settlements or awards made by them.

For the avoidance of doubt, if your card is a physical card it will state on the back who the card issuer is. If it is a virtual card you will have to contact us to confirm the issuer.

 

CH6 Time Limit

If we receive a complaint that is outside the time period for a referral to the FOS, we will in a written final response inform you that the complaint is outside the time period for consideration by the FOS and that in accordance with financial regulations we have rejected the complaint.

The time period for a referral to the FOS is:

  • less than six years after the event you are complaining about; or
  • if later, less than three years from the date you became aware, or ought reasonably to have been aware, that you had cause to complain.