AML & KYC Summary

General

In order to ensure the compliance with international trade standards we operate exclusively in accordance with the legislation on combating illicit money laundering and countering terrorism financing. To monitor the accordance with legal requirements and recommendations of FATF, we have established a Compliance department developing Anti-money laundering and Know your customer (AML / KYC) procedures, obligatory for all employees and customers and determining the policy of engagement with any person who intend to become out customer. The Compliance Department ensures that all the operations of the Company are consistent with the international standards to combat money laundering and all the documents provided by the Customer are up-to-date and comply with relevant legal requirements.

AML / KYC rules

As our client you irrevocably agree with the following rules and undertake to observe them:

  • You are obliged to follow our AML and KYC requirements while you are our client. Upon the request of the Company the additional documents and information should be provided by you. Filling of the respective KYC questionnaire may also be an obligatory requirement under Company’s sole decision. You agree with such requirements of the Company and undertake to follow them;
  • The withdrawal of any assets is carried out only to the account that belongs to you. The withdrawal of Assets to third parties is prohibited. Internal transfers between the Company’s customers are also forbidden;
  • The Company is obliged and has the right without obtaining prior consent to share with financial institutions and law enforcement agencies any information about you, as required by applicable law, and you give the Company you consent to these actions. In order to comply with this paragraph, the Company holds a records about your transactions for the last five years at least;
  • You undertake to follow the legislation, including international ones, aiming to combat illicit trafficking, financial fraud, money laundering and legalization of funds obtained by illegal means. You should use your best efforts to avoid direct or indirect participation in illegal financial activities and any illegal transactions using the Company’s Website and Services;
  • You guarantee the legal origin, legal ownership and the right to use the assets transferred to your account. In case of the evidence of suspicious transactions in your account, cash replenishments from untrusted sources (for example, the data of assets’ sender and Traders Room’s owner is different) and / or any actions with attributes of fraud (including any refunds or cancellation of payments), the Company reserves the right to conduct an internal investigation, to block or close your Traders Room or any account, cancel any payment or trading order and to suspend operations on the accounts before the end of the official investigation. When making the decision the Company is guided by the provisions of the applicable law, FATF recommendations or by common practice;
  • The Company has the right to request additional information about you if the method of withdrawal is different from the depositing method. The Company also reserves the right to block your Traders Room or any account during the investigation if you refused to provide the additional information requested by the Company;
  • In the course of investigation, the Company has the right to request additional copies of documents confirming your identity or identity of other individuals in corporate structure, as well documents confirming place of living and lawful possession and legal origin of funds. The Company also has the right to demand the provision of original documents for review in case of any doubts from Company’s side;
  • The Company does not provide Services to the persons and legal entities who located at the jurisdictions that are “blacklisted” by FATF. Also the Company does not provide services to citizens and residents of U.S.A;
  • The Сompany refuses to perform the operations that from Company’s point of view are considered to be a suspicious. The use of preventive measures (such as blocking or closing of a customer’s Traders Room or any account) is not the reason for civil liability of the Company for failure to fulfill obligations to you;
  • The Company is not obliged to inform you or other persons about the measures taken to fulfil the AML/CFT legislation. Also the Company is not obliged to inform you or other persons about any suspicions, about the reasons for refusal of execution of your trading order, refusal to open the account, need for providing any documents, etc;
  • This document is just a summary, which goal is to clarify our rights and our intention to contribute in worldwide AML initiative. However, each Company has its own internal AML&KYC procedures and rules, that may supplement rules specified in this summary. Nothing in this summary should be understood as an immutable rule that cannot be supplemented by a local AML policy of respective Company;
  • This anti-money laundering and know your customer policy is an integral part of the any agreement concluded between you and the Company. Non-compliance with this policy can be a ground for termination of the agreement at the Company’s sole discretion.

Privacy Policy

General

This Privacy Policy governs collection, processing and use by us of your Personal Information that you provide us when accessing or using a website www.efimarkets.com (hereinafter – the “Website”) and any products or services offered by us (hereinafter – “Services”). “Personal Information” refers to information that identifies an individual, such as name, address, e-mail address, financial information, and banking details. “Personal Information” does not include anonymized and/or aggregated data that does not identify a specific user. We are committed to protecting and respecting your privacy. The purpose of this Privacy policy is to describe:

  • The types of Personal Information we collect and how it may be used;
  • How and why we may disclose your Personal Information to third parties;
  • The transfer of your Personal Information;
  • Your right to access, correct, update, and delete your Personal Information;
  • The security measures we use to protect and prevent the loss, misuse, or alteration of Personal Information;
  • Our retention of your Personal Information;
  • This Privacy policy also covers some basics of our use of cookies, however, for more details please see also our Cookie policy.

We control the ways of collecting your Personal Information, and determine goals for which We use Personal Information. We are a “data controller” within the meaning of the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”) and other applicable European laws pertaining to data protection.

Collection and use of personal information.

A. Personal information we collect

We collect the following personal Information:

  • Contact information, such as name, home address, and e-mail address;
  • Account information, such as username and password;
  • Financial information, such as bank account numbers, bank statement, trading activity and history, commissions charged, etc;
  • Identity verification information, such as images of your government issued ID, passport, national ID card, driving license or other documents requested by our compliance department;
  • Residence verification information, such as Utility bill details or similar information;
  • Other information, obtained during our KYC procedures, such as information about your financial state and source of funds.

We also automatically collect certain computer, device, and browsing information when you access the Website or use of Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:

  • The information about the computer or mobile device you use to access our Website, including the hardware model, operating system and version, the web browser you use, IP addresses and other device identifiers;
  • Website usage information, the server log information, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at our Website and the websites you visit just before and just after our Website;
  • The bandwidth upload and download speeds, the amount of free and used storage space on your device and other statistics about your device;
  • We may automatically capture, store and otherwise process information about you even if you abandon the completion of an online application or registration form.

We may automatically capture, store and otherwise process information about you even if you abandon the completion of an online application or registration form.

B. Use of cookies and similar technology

The Website uses Cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are typically stored on your computer’s hard drive

Our Website uses Cookies to enable you to use the Website, the Services we offer and the materials on the Website. Cookies are also used to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.

For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

C. How we use your personal information

We may use your Personal Information to:

  • Process your transactions. We will process your Personal Information only for the purpose(s) for which it has been provided to us;
  • Fulfill our legal or regulatory requirements;
  • Verify your identity in accordance with the applicable legislation and the our Anti Money Laundering policy, as well as address other law enforcement needs. We also may share your information with other financial institutions and with tax authorities if such actions are required from us due to any applicable legislation;
  • Detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
  • Protect of our rights and property;
  • Personalize your Services experience;
  • Analyze Website usage, and improve our Website and Website offerings. Analyzing and tracking data to determine the usefulness or popularity of certain content and to better understand the online activity of our Website users;
  • Help us respond to your customer service requests and support needs, answer your inquiries or respond to a communication from you;
  • Contact you about Services. The email address you provide may be used to communicate information and updates related to your use of the Services. We may also occasionally communicate technical notices, support or administrative notifications, company news, updates, promotions, and related information relating to similar products and Services provided by us;
  • Administer a contest, promotion, survey or other features as will be more explained on the Website;
  • Link, connect or combine Personal Information we collect from or about you with other Personal Information;
  • Carry out any other purpose or reason for which the Information was collected.

We do not perform behavioral tracking of a customer’s activities on our Website or across different Websites, nor do we allow third-party data collection through our services. If you wish to stop receiving marketing communications from us, please contact us at info@efimarkets.com to opt-out.

Disclosing and transferring personal information

We may disclose your Personal Information to third parties and legal and regulatory authorities, and transfer your Personal Information as described below:

A. Disclosures to third parties

In processing your transactions, we may share some of your Personal Information with our third party service providers who help with our business operations. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide Services or as required by law. By using Website or Services you consent to the disclosure of your Personal Information as described in this Privacy policy. Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses. Our third party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms no less protective those described in this Privacy policy, or those we are subject to under applicable data protection laws.

B. Disclosures to legal authorities

We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:

  • Compelled by subpoena, court order, or other legal procedure;
  • We believe that the disclosure is necessary to prevent physical harm or financial loss;
  • Disclosure is necessary to report suspected illegal activity;
  • Detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
  • Disclosure is necessary to investigate violations of this Privacy policy or any our agreement with you.

C. International transfers of personal informations

We store and process your Personal Information in data centers around the world, wherever our facilities or service providers are located. As such, we may transfer your Personal Information between such data centers. Such transfers are undertaken in accordance with our legal and regulatory obligations and are performed only via protected channels.

D. Other circumstancer for disclosure of personal information

We also can disclose your Personal Information in the following circumstances:

  • With your consent or at your instruction. Certain information you may choose to share may be displayed publicly, such as your username and any content you post when you use interactive areas of our Website like our online forums;
  • With our current or future parent companies, affiliates, subsidiaries and with other companies under common control or ownership with us or our offices internationally. We ensure that listed parties will be bound by terms not less protective those described in this Privacy policy, or those we are subject to under applicable data protection laws;
  • If the sharing of Personal Information is necessary for protection of our rights and property, or rights and property of the above listed current or future parent companies, affiliates, subsidiaries and with other companies under common control or ownership with us or our offices;
  • Detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
  • Disclosure is necessary to investigate violations of this Privacy policy or any our agreement with you.

External websites

Occasionally, the Website may provide references or links to other websites (“External websites”). We do not control these External websites third party sites or any of the content contained therein. You agree that we are in no way responsible or liable for External websites referenced or linked from our Website, including, but not limited to, website content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to, or arising from those sites. External websites have separate and independent privacy policies. We encourage you to review the policies, rules, terms, and regulations of each site that you visit. We seek to protect the integrity of our site and welcome any feedback about External website information provided on our Website.

Your rights regarding your personal information

You are able to exercise all the rights foreseen by legislation, if this does not contradict the legal requirements in relation to the prevention of money laundering and terrorist financing laws, our record keeping obligations, etc.

You have the following rights:

  • the right to be informed about the fact that we’re processing your Personal Information and which data exactly we are processing;
  • the right to data portability. In certain circumstances, you have the right to obtain all your Personal Information we store in a machine readable format;
  • the right to object the processing of your Personal Information;
  • the right not to be subject to automated decision-making including profiling if it doesn’t intervene in performing the contract between you and us;
  • the right to access your Personal Information, to correct, update, and block inaccurate and/or incorrect data;
  • the right to withdraw your consent of Personal Information processing;
  • the right to erase your Personal Information from our servers upon your justified request (a right to be forgotten).

To exercise these rights, contact us at info@efimarkets.com

Within 40 days of receipt of your written request we will provide you with your Personal Information, including the purposes for which it was used and to whom it was disclosed to in accordance with applicable legislation. We reserve the right to request additional information from you, that may be necessary in order to provide the duly respond to your request in accordance with applicable legislation and you agree with such our right. Also, if you wish to correct, update, and block inaccurate and/or incorrect data, we have a right to request a confirmation of correct data from you, for example, official documents containing such data. Please note that if we are unable to verify your identity by e-mail messages or at your application to the call center, or in the case of reasonable doubts concerning your identity, we may ask you to provide a proof of identity, including by personal appearance in our office. This is the only way we can avoid disclosing your Personal Information to a person who can perpetrate your identity.

In some cases, we will not be able to change your Personal Information. In particular, such a case can include the event when your personal information has already been used during the execution of any agreement or transaction, or is specified in any official document, etc. You have the right of withdrawal of consent to personal data processing. You may also exercise your right to be forgotten and erase your Personal information from our servers. In cases stipulated in Article 17 of GDPR, we will delete your Personal Information we process, except for those Personal Information which we are obliged to store in accordance with the requirements set forth by the applicable legislation. Please be advised, that in case of realization of your right of withdrawal of consent to personal data processing or right to be forgotten, we will not be able to provide you our products or services, and we have a special right to terminate all our current agreements with you with the application of legal consequences of such termination, and you irrevocably acknowledge such our right.

In order to withdraw the consent to personal data processing and/or exercise your rights to be forgotten please contact us at info@efimarkets.com. Furthermore, in this case, for the purposes of safety, we may request that you present your ID document, directly at our office.

Security of personal information

We use a variety of security measures to ensure the confidentiality of your Personal Information, and to protect your Personal Information from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to: Password protected directories and databases.

Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely.

Limited access to hosting servers using 2FA and traffic encryption.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized personnel are permitted access to your Personal Information, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.

Retention of personal information

We retain Personal Information for as long as necessary to fulfil purposes described in this Privacy policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain account and other Personal Information for at least five years after termination of respective agreement.

Updates to this privacy policy

This Privacy policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at our sole discretion. When we make changes to this Privacy policy, we will notify all users on our Website, and make the amended Privacy policy available on our Website.

Data protection officer

To exercise all relevant rights, queries or complaints to any data protection matter between you and us, please in the first instance contact our Data Protection Officer at info@efimarkets.com.

Fraud prevention policy

General

This fraud and whistleblower policy is established to outline the controls in place to educate, prevent, detect, and report any form of fraudulent behavior.

By definition, “Fraud is any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain.” We (hereinafter – “We” or the “Company”) have a strong commitment to fraud risk management. Examples of fraud can include but are not limited to these three categories.

Financial misstatement

  • Forgery or alteration of any financial document;
  • Improper revenue recognition;
  • Misappropriation of funds, securities, supplies, or other assets;
  • Understatement of liabilities;
  • Management override;
  • Deviation from full and fair reporting of the financial condition.

Misappropriation of assets

  • Misappropriation of funds, supplies or other assets;
  • Impropriety in the handling or reporting of money or financial transactions;
  • Use Сompany-owned assets for personal use;
  • Loss or misuse of Company’s resources by not following system controls.

Misconduct

  • Theft of a payment or other financial asset;
  • Profiting as a result of insider knowledge;
  • Impropriety in the handling or reporting of money or financial;
  • Confidential information used in the conduct of outside business;
  • Disclosing information that should be secure;
  • Non-compliance with internal controls.

Staff awareness

Each employee shall have a basic understanding of fraud and be aware of the red flags and know their role within the internal control framework. Fraud involves not just monetary issues, but also is significant to an organization’s financial reporting, operations, reputation, legal, and regulatory compliance. Staff have an awareness of how their job procedures are designed to help mitigate fraud risks and when noncompliance may open up the opportunity for fraud to occur. Each member of the management team will be familiar with the types of improprieties that might occur within their area of responsibility and will be alert for any indication of possible irregularity.

Fraud RED FLAGS and mitigation options

Frequent "red flags" indicating fraud opportunities include:

  • Poorly written or poorly enforced internal controls, procedures, policies or security;
  • Irregular or unexplained variances in financial reporting;
  • Failure to take action on audit findings;
  • Unusually high expenses or purchases;
  • Frequent complaints from customers;
  • Missing or incomplete files, records, and documentation;
  • Employee comments concerning possible fraud;
  • Complex business arrangements not widely understood and appear to serve little or no purpose;
  • Financial results that seem “too good to be true”;
  • A consistently close match between reported results and planned results;
  • Changes to employee’s behavior.

Prior to employment, background checks are used in employment screening with the specific objective of assuring that persons with inappropriate records or inconsistency are identified and eliminated from the hiring process. Every employee is required to read and understand policies and procedures upon employment with the Company.

Ongoing monitoring procedures are built into normal recurring operating activities. Certifications and self-assessments create strong controls that help prevent occurrences of fraud. Segregation of duties exists and is tested routinely. The annual fraud risk assessment, which is a part of the annual Company’s risk assessment process, helps to identify potential schemes and events.

Other internal controls help prevent fraud as follows:

  • Adherence to documentation and authorization limits;
  • Physical security and restricted access;
  • Independent review;
  • Clear lines of authority;
  • Enforcement of conflict of interest;
  • Internal control walkthroughs;
  • Regular vacation breaks;d;
  • Board oversight;
  • Anonymous reporting “Whistleblower” procedures.

These controls help to create an environment where employees, vendors, and other parties believe that dishonest acts will be detected, reported, and dealt with appropriately.

Reporting and complaint "Whistle Blower" procedures

Employees, vendors or other parties with concerns of fraud or suspected fraud may report the responsible employee. Any fraud that is detected or suspected must be reported immediately. Upon receipt of a complaint, the responsible employee will take appropriate action for investigation, tracking and confidentiality.

Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the Company. It is important to provide as much information regarding the facts and circumstances surrounding the complaint as possible in order to facilitate a full and complete investigation.

Upon receipt of a complaint, the responsible employee will determine whether the complaint actually pertains to accounting or auditing matters and, as possible, acknowledge receipt of the complaint to the sender. Complaints relating to accounting or auditing matters will be forwarded for investigation to such person or persons as responsible employee determines to be appropriate. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review.

The Company is committed to achieving compliance with all applicable securities laws, regulations, accounting standards, accounting controls, and audit practices.

Any employee, vendor, or other party may file a good faith complaint without the fear of dismissal or retaliation of any kind. The Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against anyone because of any lawful actions in providing information or other assistance in investigation of fraud or the commission. This will be true even in the event that it is concluded from the investigation that no violation occurred.

Fraud prevention mechanisms

Here is the list of prevention mechanisms which the Company is using to mitigate fraud:

  • Establish clear and easy to understand standards from the top-down. Maintain employee manual that clearly outlines these standards and keeps the rules from becoming arbitrary;
  • Always check references and perform background checks that include employment, credit, licensing and criminal history for all new hires;
  • Secure physical assets, access to data, and money at all levels including monitoring and using pre-numbered checks. Keep checks locked up, have a “voided check” procedure and never sign blank checks. Review all disbursements regularly;
  • Segregation of duties for employees. Divide activities so one employee doesn’t have too much control over an area or duty. Separate important accounting and account payable functions. Small business owners and managers should review every payroll check personally. The person who has custody of the checks should never have check signing authority. The person opening the mail should not record the receivables and reconcile the accounts;
  • Proper authorisation of transactions, ensuring that employees aren’t exceeding their authority;
  • Independent checks on performance by using audits, surprise check-ups, inventory counts or other procedures to verify compliance with policies and procedures, as well as accuracy;
  • Instilled anonymous reporting mechanism such as an employee fraud hotline;
  • Small-business owners should control who first receives the bank statements and other sensitive documents. Consider a separate post office box for the purpose of receiving bank statements, customer receipts or any other sensitive documents;
  • All account reconciliations and general ledger balances should have an independent review by a person outside the responsibility area such as an outside accountant. This allows for reviews, better ensuring nothing is amiss and providing a deterrent for fraudulent activities;
  • Conduct annual audits to motivate all bookkeeping-related staff to keep things honest because they can never be sure what questions an auditor is going to ask or what documents an auditor may request to review.

Possible threats

Check / measures

Fictitious vendors

Run checks to uncover post office boxes used as addresses and to find any matches between vendor and employee addresses and/or phone numbers

Be alert for vendors with similar sounding names or more than one vendor with the same address and phone number

Search for duplicates

Check for invoice amounts not matching contracts or purchase order amounts

Fixed bidding

Summarize contract amount by vendor and compare vendor summaries for several years to determine if a single vendor is winning most bids

Calculate days between close for bids and contract submission date by vendor to see if the last bidder consistently wins the contract Goods not received

Search for purchase quantities that do not agree with contract quantities

Check if inventory levels are changing appropriate to supposed delivery of goods

Duplicate invoices

Review for duplicate invoice numbers, duplicate date, and invoice amounts

Inflated prices

Compare pricesacross vendors to see if prices from a particular vendor are unreasonably high

Excess quantities purchased

Review for unexplained increasesin inventory

Determine if purchase quantities of raw materials are appropriate for production level

Check to see if increases in quantities ordered compare similarly to previous contracts or years or when compared to other plants

Duplicate payments

Search for identical invoice numbers and payments amounts

Check for repeated requests for refunds for invoices paid twice

Carbon copies

Search for duplicates within all company checks cashed; conduct a second search for gaps in check numbers

Duplicate serial numbers

Determine if high value equipment a company already owns is being repurchased by checking serial numbers for duplicates and involvement of same personnel in purchasing and shipping processes

Payroll fraud

Find out if a terminated employee is still on payroll by comparing the date of termination with the pay period covered by the pay check and extract all pay transactions for departure date less than date of current pay period.

Accounts payable

Reveal transactions not matching contract amounts by linking accounts payable files to contract and inventory files and examining contract date, price, ordered quantity, inventory receipt quantity, invoice quantity, and payment amount by contract.

Card Fraud Prevention Mechanisms

The Company will be using third party card issuing vendor. This means it will not be able to implement custom solutions. The vendor who will be working with us should have at least:

  • 3D secure transactions;
  • Fraud prevention system;
  • Fraud prevention checks:

Possible threats

Check / measures

Fraudsters try to find out the expiry date and possibly also the CVV for the card number known to them

Reduction of the maximum number of authorisation interrogations per card number and a free choice of time period (0-1440 mins.).

Fraudsters try, through series testing of various card numbers, to check their validity

Damage to the merchant through high-value improper purchases.

Repeated improper use of a card number.

Blacklist – exclusion of individual card numbers or whole card number fields (BIN). Once card numbers are reported as blocked, they are filed on our blacklist. Before each transaction is transmitted to the finance company, it is matched to our blacklist. If the system finds a corresponding entry, the transaction is immediately rejected.

Improper use of fraud-susceptible BIN ranges (card number fields).

White list with selection of countries (on the basis of the BIN). Via the Web interface from Data trans the merchant can include or exclude countries. Customers from regions at risk – from experience, orders from crisis regions have an increased risk. Data trans Allows you to reduce this risk by not accepting orders from customers from such regions (IP addresses, card number). Use of stolen or self-generated card numbers, whose actual country of origin is not known to the fraudster.

Validation of the country of origin of the card on the basis of the ISO Country Code. The customer also states the country of origin of the card. The transaction is the only authorised if the country was correctly stated. For Visa, Mastercard and American Express.

Complaints policy

General

We are committed to providing a high standard of service to all our customers on every occasion. We do recognize however, that occasionally there may be circumstances where you are dissatisfied with the service you may have received

How to file a complaint

A. Where should I send my complaint

If you have a complaint about any aspect of our service, then we would like to hear from you. You can contact us by e-mail info@efimarkets.com

Please send your message from the e-mail which was used by you for registration of your Trading Room. If you send message from another e-mail we reserve the right not to provide you any advice in case if such our action, on our opinion, will lead to disclosure of client’s confidential information.

B. Required documentation

  • Your name and e-mail which was used during registration of your Trading Room;
  • A clear description of your concern or complaint;
  • Details of what you would like us to do to put it right;
  • Copies of any relevant correspondence, such as e-mails.

C. Details on settling your complaint

We will try to resolve your complaint as quickly as possible and with minimum inconvenience to you. However, you irrevocably agree with the following:

  • You have to complain as soon as possible, but not later than within one day after the grievance has arisen. If you delay, it can lead to a situation when the time necessary for resolve has passed. In such a case, we are not responsible for the inability to satisfy your request;
  • We will reply on the complaint during 2 weeks. For avoidance of doubt, we have a right to ignore any complaints or messages from the customers who behave incorrectly, impolite, engaged in trolling, or repeatedly apply to us with the same question, etc;
  • You are liable for all charges/costs/expenses/fees incurred by us regarding your requests, claims or complaints if such requests could not be comprehensively satisfied without involving of third parties. We will inform you in advance if such involvement of third parties is needed;
  • We keep records of all your messages for compliance and training purposes;