„Digital Assist" Ltd.
| Approved by: The management body of the Company | Version 1.0 | Date February 20, 2026. |
The present Policy („Policy“) governs the procedure, deadlines, and responsibilities for receiving, registering, reviewing, and resolving Customer Complaints of „Digital Assist“ Ltd. , EIK: 206079266 („Company“) in connection with the crypto-asset services provided through the website and through a network of crypto-ATMs located on the territory of the Republic of Bulgaria.
The policy is developed in accordance with the requirements of Article 71 of Regulation (EU) 2023/1114 (MiCA) and Commission Delegated Regulation (EU) 2025/294, as well as the Law on Crypto-Asset Markets.
The policy applies to any Complaint submitted by a current or potential customer, regardless of channel, including website, email, postal mail, telephone.
The Company handles complaints conscientiously, impartially, and in a timely manner, free of charge to the client. The Company strives to use clear and accessible language and follows effective, publicly disclosed procedures that comply with data protection and ensure the prevention of conflicts of interest. Complaints are handled consistently, with traceability of processing, and with an emphasis on corrective and preventive measures.
„Complaint“ means any expressed dissatisfaction, claim of violation, or request for correction by a customer regarding provided or offered services/products, including technical, pricing, contractual, informational, ethical, and operational aspects.
„Client“ is a natural or legal person who uses or intends to use the company's crypto-asset purchase and sale services.
Complaints are accepted in Bulgarian and English. Customers can submit complaints by:
For the Complaint to be effectively considered, it shall contain:
When the complaint is incomplete, the Company shall, without undue delay, inform you that the complaint needs to be clarified/supplemented in order to be considered.
Customers owe no fees or expenses for filing or processing complaints.
Complaints can be filed using the template provided in Annex 1 to this Policy, which is also available on the Company's website. This template is recommended but not mandatory. The template is intended to provide maximum ease for Clients when filing Complaints. The Company guarantees that the use of such a template is not mandatory, but is intended solely for the convenience of clients.
The complaint is inadmissible and will therefore not be considered on its merits when:
Every complaint is registered immediately in a register with a unique number and date.
The client receives written confirmation of receipt of the Complaint with a unique number and information on the next steps.
Confirmation period: The Company confirms receipt of your Complaint without undue delay and no later than 5 business days.
When your Complaint does not meet the eligibility conditions set forth in this Policy, the Company will provide you with a clear explanation of the reasons for rejecting the Complaint as inadmissible within 10 business days of receiving the Complaint.
Upon receipt of a valid complaint, the Company conducts an objective investigation, including a review of logs, video recordings from the cryptomat (if processed for security purposes and in compliance with the law), event records, cash receipts, account movements, compliance with limits and security procedures, KYC/AML flags, incident notifications, etc.
Complaints are handled by employees who are not directly involved in the process or transaction that led to the complaint. In case of a potential conflict, responsibility is transferred to another competent employee of the Company or escalated to a Company Manager.
The Company considers a complaint filed with it without undue delay, but no later than 2 months from its receipt.
In complex cases where a resolution within this timeframe is not possible, the Client will receive an interim message explaining the reasons for the delay and an expected date for a final response, with resolution to be provided as soon as possible.
In its decision on the Complaint, the Company will consider all issues raised therein and will state the reasons for the outcome of its review. This decision must be consistent with any previous decision made by the Company regarding similar Complaints, unless the Company can justify why a different conclusion has been reached.
The response/resolution to the complaint is in written form on a durable medium (email or letter), contains facts, analysis, resolution/proposed compensation, instructions for follow-up actions, and information on out-of-court dispute resolution options and referral to the competent supervisory authority.
If the decision does not satisfy the applicant's request or only partially satisfies it, the Company will clearly state the reasons and include information about available remedies so that the Client can take further action if they disagree with the reasons for rejection.
For every justified Complaint, a corrective measure is determined (e.g., information update and/or technological correction). A root cause analysis is performed, and preventive measures are implemented: process changes, staff training, website/cryptomat interface updates, review of limits and controls.
The Company maintains a register of received Complaints, as well as all measures taken in response to the complaints, in a Complaints Register. This register helps the Company ensure fair treatment of complainants.
To ensure consistent complaint processing and identify trends, recurring issues, and opportunities for service improvement, the Company will continuously analyze complaint processing data. This data will include the number and average processing time of complaints, the subject categories to which the complaints relate, and the outcomes of the reviews conducted.
Periodically, but no less often than once a year, a report shall be prepared for the Governor on trends, systemic issues, and improvement measures.
All employees undergo initial and periodic training regarding this Policy, the requirements of MiCA, and Bulgarian legislation concerning crypto-asset markets, good customer service practices, and data protection.
The policy is reviewed at least once annually or upon regulatory changes, technological updates, or identified system discrepancies. Changes are approved by the Administrator/Governing Body and published in a timely manner.
Data processing in connection with complaints is carried out in accordance with Regulation (EU) 2016/679 (GDPR) and Bulgarian legislation on personal data.
The company provides a privacy notice that explains the purposes, legal bases, retention periods, data subject rights, and contact information for exercising rights. Only authorized persons have access to the data.
Retention period for complaint records: 5 years from the conclusion of the complaint review, unless the law requires a longer retention period.
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(sent by the client to the crypto asset service provider)
Last name/Legal entity name:
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EIC or, if none, national registration or identification number:
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Legal Entity Identifier (if applicable):
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Customer data (if any):
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Address (street, number, floor) (for legal entities - registered office):
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Postal code
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City
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Phone
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Email address:
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Last name/Legal entity name:
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Address (street, number, floor) (for legal entities - registered office):
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Email address:
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(power of attorney or other official document proving the appointment of a representative, to be provided as an attachment to this form)
Last name/Legal entity name:
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Registration number and IKPS (if any):
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Address (street, number, floor) (for legal entities - registered office):
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Phone
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Email address:
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Last name/Legal entity name:
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Address: street, number, floor (for legal entities - seat):
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3.a. Full details of the crypto-asset service to which the complaint relates (i.e., name of the crypto-asset service provider, crypto-asset service reference number or other data for the relevant transactions...)
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3.b. Description of the subject of the complaint
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Please provide any documentation to support the stated facts.
3.b. Date(s) of the facts on which the complaint is based
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3.g. Description of damage, loss, or harm suffered (where applicable)
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3.d. Other notes or relevant information (where applicable)
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In _______________ (place) on _______________ (date)
SIGNATURE
COMPLAINANT/LEGAL REPRESENTATIVE OF THE COMPLAINANT
Attached documents (please tick the appropriate box):
Power of attorney or other official document proving the representative's appointment ☐
Copy of the contractual documents for the investments to which the complaint relates ☐
Other documents in support of the appeal: ☐
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