Managing complaints from clients




1. Scope

The purpose of this document is to establish the manner in which SEEDBLINK SA handles client complaints. This document is publicly available on the SeedBlink website and can also be provided, upon request, free of charge, in a printed or electronic format.

2. Scope of Application

This document is mandatory within SEEDBLINK SA for all departments involved in client relations.

3.Reference documents

  • REGULATION (EU) 2020/1503 OF THE EUROPEAN PARLIAMENT AND COUNCIL from October 7, 2020, regarding European providers of crowdfunding services for businesses and amending Regulation (EU) 2017/1129 and Directive (EU) 2019/1937

  • Commission Delegated Regulation (EU) 2022/2117 of July 13, 2022, supplementing Regulation (EU) 2020/1503 of the European Parliament and Council with regard to regulatory technical standards specifying the requirements, standard formats and procedures for handling complaints.

  • Regulatory technical standards according to EU Regulation 2020/1503 - Guide on complaint handling in the securities sector (ESMA);

  • Government Ordinance no. 27/2002, with subsequent amendments and additions, regarding the regulation of petition handling activity;

  • ISO 10002 Customer complaint management system.

4. Definitions and abbreviations

4.1.Definitions of terms

Term Definition and/or, if applicable, the act defining the term
Crowdfunding Service the connection of investors interested in providing financing for businesses with project owners through the use of a crowdfunding platform, a service consisting of any of the following activities: (i) facilitating the granting of loans; (ii) placement, without a firm commitment, as provided in Annex I section A point 7 of Directive 2014/65/EU, of securities and instruments admitted for the purpose of crowdfunding issued by project owner or an investment vehicle, as well as the receipt and transmission of customer orders, as mentioned in point 1 of the aforementioned section, regarding these securities and instruments admitted for the purpose of crowdfunding; (Regulation (EU) 2020/1503)
Complaint A statement of dissatisfaction addressed to the crowdfunding service provider by one of the clients regarding the crowdfunding services as defined in point 1. (Regulatory technical standards according to EU Regulation 2020/1503). In the context of this document, a complaint is understood as a statement made by any natural or legal person addressed to SeedBlink in relation to the provision of crowdfunding services mentioned in point 1.

5. Description of the complaint filing process

5.1. GENERALITIES – Prerequisites for addressing complaints received from end customers

SEEDBLINK SA, as a crowdfunding service provider, has organized and conducts activities regarding the resolution (handling and management) of complaints received from customers, by establishing an internal system for collecting, recording, analyzing, determining measures, and resolving customer complaints regarding violations of their rights, ensuring the correct application of legal provisions, including written communication to them, within the legal deadlines, of the conclusion resulting from the analysis of the complaint.

For carrying out this activity, SEEDBLINK SA uses Romanian as its official language, and for handling complaints and petitions received from foreign complainants, English will be used or any language used in the key investment information sheet, mentioned in Articles 23 and 24 of Regulation (EU) 2020/1503 or advertising communications mentioned in Article 27 paragraph (1) of the respective regulation.

5.2. Filing complaints

Any natural or legal person, customer of SEEDBLINK SA or their legal representatives, who believe that their rights and interests (mentioned in the law or in the Investment Facilitation Agreement) have been violated in any way, can address the company for clarification of the cause leading to such a petition.

Petitions can be filed in Romanian or English or in any language used in the key investment information sheet, mentioned in Articles 23 and 24 of Regulation (EU) 2020/1503 or advertising communications mentioned in Article 27 paragraph (1) of the respective regulation, using the standard form (according to Annex 1). To be accepted, complaints must meet the acceptance criteria.

Methods of filing complaints:

  1. On the website www.seedblink.com

  2. Email address: investors@seedblink.com;

  3. At the company’s headquarters;

  4. Registered letter sent by mail or courier.

5.4. Structure of complaints

The complaints filed must contain at least the following elements to be taken into consideration and analyzed:

• First and last name;

• Complainant's contact details (address, phone number, email);

• The subject of the complaint, including full reference to the investment and/or agreement to which the complaint refers (e.g. project owner/company and/or crowdfunding project, other relevant transaction references)

• Documentation supporting the mentioned facts.

• Date of the event generating the complaint.

• Description of the damage or loss caused (if relevant).

Other comments or relevant information (if applicable).

If the complaint is not formulated by the complainant, it must additionally contain the following information about the person making the petition:

• First and last name;

• Contact details (address, phone number, email);

• Status and interest in the case;

Anonymous complaints or those where the complainant's identification data (name, surname, address, contact details) or relevant data regarding the subject of the petition are not specified will not be taken into consideration and will be classified as lacking object.

Complaints sent are signed by hand or electronically, and in the case of electronically sent complaints that cannot be signed, SeedBlink may request confirmation of the correctness of the data transmitted electronically.

5.4. Recording complaints

Complaints sent by mail or submitted in person as well as complaints sent via email are assigned a registration number and date, and these will be highlighted in the Electronic Register.

5.5. Criteria for accepting complaints

For a complaint to be considered valid, it must contain all the necessary elements from section 4.3.

Also, when filing complaints, it is mandatory to specify in detail the subject of these, the steps taken by the complainant at the level of SeedBlink, if applicable, the information available to support the statements, as well as the attachment of conclusive evidence, to the extent they hold it.

In the situation where the complaint does not meet the admissibility conditions, the complainant will receive a clear explanation of the reasons for rejecting the complaint as inadmissible.

5.6. Handling complaints

After accepting complaints, the process of handling them will consider the following stages:

  • recording the complaint and confirming receipt - within 10 working days from its receipt, including the mention of the contact details of the person or department to which the complainant can address questions related to the complaint.

  • in the situation where additional information is needed or the complaint is unclear or incomplete, additional information will be requested from the complainant.

  • in the situation where the complaint does not meet the admissibility conditions, the complainant will receive a clear explanation of the reasons for rejecting the complaint as inadmissible within 10 days from its receipt.

  • the deadline for communicating a decision regarding the complaint to the complainant is 30 days from the date of its registration.

In the situation where the aspects noted by the complaint require a more detailed investigation, the complainant will be informed about the causes of the delay and about the extension of the deadline in which the decision regarding the complaint will be communicated to him. The communicated term cannot exceed by more than 15 days the term of 30 days from the registration of the petition.

5.7. Response to complaints

The transmission of responses to complainants will be carried out within the deadlines established above, from the date of registration of the complaint, regardless of whether these are favorable or unfavorable. In the case of rejected complaints (unfavorable), the reason for the complaint's rejection will be included in the response.

In the event that a decision is issued that does not satisfy or partially satisfies the complainant's request, the decision will include an explanation of the reasons underlying this outcome, as well as information regarding the possibility of contesting the decision, namely filing a complaint with ASF (Financial Supervisory Authority) / legal action.

SeedBlink will use the same language in communications as the one used by the customer in the complaint.

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SeedBlink S.A. is registered in the Register of the Romanian Financial Supervisory Authority (ASF), under number PJR28FSFPR/400001, as of 03.11.2022 with an EU passport as per European Securities and Market Authority (ESMA) register of crowdfunding services providers.

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