Purpose
Recognize, securely register and acknowledge every complaint within approved timeframes, as mandated by sections 1 (Purpose and Scope), 2 (Definitions), 5 (Complaint Submission Channels), 6 (Acknowledgment of Complaints) and 7 (Complaints Register and Recordkeeping) of the approved Client Complaints Handling Manual.
Definitions
- Complaint: Any expression of dissatisfaction, whether justified or not, about Bitkaya’s products, services, staff, or representatives. Examples include service delays, product malfunctions, regulatory or contractual concerns, staff misconduct, or allegations of unfair treatment. The use of the word “complaint” by the client is not required for an issue to be treated as a complaint.
- Complainant: Any natural or legal person, including clients, partners, investors, or stakeholders, submitting a complaint through the designated channels. The complainant has the right to acknowledgment, a fair investigation, and timely resolution.
Scope of Intake
The scope applies to all complaints received from clients, business partners, investors, or other stakeholders concerning Bitkaya’s products and services, staff conduct/professionalism/behavior, regulatory compliance and contractual obligations, and ethical standards or fairness in dealing. Complaints may be submitted orally, in writing, or electronically. All complaints, regardless of form, must be logged and addressed in line with the procedures described herein.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Accept complaints through approved channels | Orally, in writing, or electronically via Email: complaints@bitkaya.com, Online Form: www.bitkaya.com/complaints, Postal Mail: Bitkaya Board of Directors, Julianaplein 36, Willemstad, Curaçao. | Channel intake log |
| 2 | Treat any expression of dissatisfaction as a complaint | Even if the complainant does not use the word “complaint” — whether justified or not. | Complaint register entry |
| 3 | Request complainant information to enable efficient handling | Full name and contact details, a clear description of the complaint, and relevant dates, documentation, or evidence. | Intake request record |
| 4 | Record complaint in the centralized, secure electronic register | Complainant details, date of receipt, description and potential impact, status (open, under investigation, resolved), and resolution details and final response date. | Complaints register entry |
| 5 | Assign a unique complaint reference and initial status | Reference and status recorded against the complaint entry. | Register reference assignment |
| 6 | Confirm receipt in writing | Within 5 business days. | Written acknowledgment |
| 7 | Provide registration communication | Within 2 weeks: confirmation of complaint registration, contact details of the assigned Complaints Officer, and an indicative timeframe for investigation and resolution. | Two-week registration communication |
| 8 | Inform complainant of their rights | Including escalation options if dissatisfied. | Rights notification record |
| 9 | Secure personal and sensitive information | Limit register access to authorized roles. | Access-control record |
| 10 | Preserve original communications and attachments | Stored in the complaint record. | Original evidence file |
| 11 | Retain complaints data | At least 10 years after resolution. | Retention confirmation |
Records
- Original complaint and attachments
- Centralized electronic complaint-register entry with unique reference, including: complainant details, date of receipt, description and potential impact, status (open, under investigation, resolved), and resolution details and final response date
- Written acknowledgment delivered within 5 business days
- Two-week registration communication (registration confirmation, assigned officer contact, indicative timeframe, escalation rights)
- Registration information and deadline tracking
- Retention confirmation (minimum 10 years after resolution)
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMP-002 Ensure Complaints Are Registered and Acknowledged on Time
History
- 2026-07-28: Enriched with full operational details from PDF sections 1, 2, 5, 6, 7 (definitions, scope, channels, acknowledgment timelines, register fields, retention).
- 2026-07-26: Created from sections 1-2 and 5-7 of the approved COMP Manual.