Complaints policy & procedure

Sezvo is the trading name of UAB Aušra Pay, a licensed electronic money institution authorised and supervised by the Bank of Lithuania and passporting its services across the European Economic Area. We hold money for hundreds of thousands of everyday payments, transfers, card purchases, savings vaults, investments and crypto interactions, and we know that when one of those interactions goes wrong it can be stressful and disruptive. Treating customers fairly when things go wrong is just as important to us as building features that work in the first place.

We treat every complaint as a signal. A complaint is not a nuisance to be deflected; it is the clearest evidence we have that a product, a process or a piece of communication has fallen short of what you were entitled to expect. Our promise to you is simple and we hold ourselves to it:

• We will listen properly, without making you repeat yourself across multiple channels.
• We will investigate fairly, looking at the facts and the records rather than defending a position.
• We will respond clearly, in plain language, within the timelines set out below.
• We will put things right where we have got them wrong, including correcting errors, returning charges that should not have been applied, and compensating you for direct loss we have caused where it is fair to do so.
• We will learn, feeding the root cause back into our product and operations so the same issue does not recur for you or anyone else.

Raising a complaint is always free. You will never be charged a fee for using this process, and escalating to the independent bodies described later is also free of charge. You are entitled to ask a friend, family member, solicitor or other representative to complain on your behalf; we may ask for your authority before we discuss your account with a third party.

A complaint is any expression of dissatisfaction, whether spoken or written, and whether justified or not, about the products or services we provide. You do not need to use the word "complaint", quote a regulation, or frame your concern in any particular way. If you tell us that something is wrong and you want it fixed, we will treat that as a complaint and handle it under this procedure.

Common subjects of complaint include, but are not limited to:

• A payment, SEPA Instant transfer, SWIFT transfer or internal transfer that did not arrive, arrived late, went to the wrong place, or was for the wrong amount.
• A card transaction you did not recognise, a declined payment, a card you could not freeze, or a limit you could not change.
• A fee, charge or foreign-exchange rate you believe was applied incorrectly or not clearly disclosed.
• Interest on a savings vault or goal — for example the AER, the daily payment, or how accrual was calculated.
• Difficulty opening, verifying, freezing or closing an account, including delays in identity or source-of-funds checks.
• The quality, tone or speed of our customer service, including our 24/7 in-app support.
• An investing order, fractional purchase, dividend, corporate action, or the information we showed about a stock or ETF.
• Something to do with the self-custodial crypto wallet — for example the in-app experience, fee estimates or network selection across the supported chains.
• How we have handled your personal data, marketing preferences, or accessibility needs.

Some interactions are requests rather than complaints — for example asking us to raise a transaction limit, dispute a card payment through the scheme rules, or provide a copy of a statement. We will always action a valid request, and if you are unhappy with how a request was handled that dissatisfaction becomes a complaint. Where the right remedy is a formal card chargeback or a payment indemnity claim, we will tell you and run that process alongside your complaint rather than instead of it.

You can raise a complaint through whichever channel suits you. You do not need to use more than one, and using several at once will not speed things up — it can actually slow us down by splitting your case. Choose the channel that is easiest for you:

• In the app — open the Sezvo app, go to Help & support and start a chat with our team. This is the fastest route because we already have your account context, and our support is available 24 hours a day, every day. You can attach screenshots and documents directly in chat.
• By email — write to complaints@sezvo.com. Please send from the email address registered to your account where possible, as it helps us verify you quickly and securely.
• By phone — call our support line on +370 5 214 0022. Lines are open 24/7. If we cannot resolve your complaint on the call, we will log it and confirm the details to you in writing.
• By post — write to Complaints, UAB Aušra Pay, Konstitucijos pr. 21A, LT-08130 Vilnius, Lithuania. Postal complaints take longer to reach the right team, so we recommend the app or email if your matter is urgent.

Please do not send full card numbers, your passcode, recovery phrases for your self-custodial crypto wallet, or other security credentials by email or post. We will never ask you for these, and you do not need them for us to investigate. If you believe your account has been compromised, freeze your cards in the app and contact us immediately so we can secure the account before we begin the complaint itself.

You can complain with as little or as much detail as you have. We will always work with what you give us and ask for anything further we need. That said, the more of the following you can share at the outset, the faster we can investigate and the fewer times we will need to come back to you:

• Your name and enough information for us to identify your account securely — we will never ask for your passcode or full security credentials.
• A clear description of what happened, in your own words, and what you expected to happen instead.
• Relevant dates, times and amounts, and any transaction or reference numbers shown in the app.
• Any evidence that helps — screenshots, emails, statements or correspondence.
• How the issue has affected you, including any costs or losses you believe you have incurred.
• What outcome you are looking for — for example a refund, a correction, an apology, or simply an explanation.
• Your preferred contact method and any accessibility needs we should accommodate.

If you are complaining on behalf of someone else, please tell us your relationship to the account holder and be ready to provide their authority. We take the security of customer information seriously and will not disclose account details to a third party without proper consent.

We work to clear, published timelines so you always know where you stand. These reflect our regulatory obligations as a Lithuanian electronic money institution and, in many cases, we beat them comfortably.

• Acknowledgement — within one business day. As soon as we receive your complaint we confirm that we have it, tell you who is handling it, and explain what happens next. If you complain in the app outside business hours, you will still see an acknowledgement, and a human reviews it the next working day.
• Quick resolution — within three business days. Many complaints are straightforward and we aim to resolve them within three business days of receipt. Where we do, we send you a short written summary of the resolution and confirm your right to escalate if you remain unhappy.
• Full investigation — final response within 15 business days. For complaints about payment services that need investigation, we will send our final response within 15 business days of receipt. In exceptional cases beyond our control, this may extend to a maximum of 35 business days, and we will write to you before the 15th day to explain the delay, the reason for it, and when you can expect our answer.
• Other complaints — within eight weeks. For complaints that fall outside the payment-services rules, we will issue a final response no later than eight weeks from the date we received the complaint, and usually much sooner.

"Business days" means Monday to Friday excluding public holidays in Lithuania. If we need more time, we will always tell you in writing rather than letting a deadline pass silently. The clock starts on the day we receive your complaint, regardless of the channel you used.

Every complaint is handled by someone empowered to put things right, and complaints are kept separate from the team or individual whose work is being questioned, so the review is genuinely impartial. Our process is consistent whatever the subject matter:

• We gather the facts. We pull the relevant account records, transaction logs, support transcripts, system events and any documents you have provided, and we build an accurate timeline of what actually happened.
• We assess fairly. We measure what happened against what should have happened — our terms, our published service levels, applicable law and regulation, and the standard of care you are entitled to expect.
• We identify the cause. We distinguish between a one-off error, a process gap, a third-party issue (for example a correspondent bank, a card scheme, an investing venue or a blockchain network), and a genuine misunderstanding.
• We decide the remedy. Where we are at fault we correct it, refund charges that should not have applied, and compensate direct loss we have caused where it is fair. Where we are not at fault we explain clearly why, with reference to the evidence.
• We keep you updated. If an investigation is taking time, we tell you what we are waiting on and when we expect to have an answer, rather than leaving you in silence.

Some matters depend on parties outside our control. A SWIFT transfer may sit with a correspondent or beneficiary bank; an investing corporate action follows the timetable of the issuer and the venue; an on-chain crypto transaction is final once confirmed by the network and cannot be reversed by us. In those cases we will be straight with you about what we can and cannot influence, and we will chase the relevant party on your behalf where we are able to.

When we have finished investigating we send you a final response in writing. This is a clear, self-contained letter or message that tells you everything you need to know to decide whether you are satisfied. It will:

• Summarise your complaint as we understood it, so you can see we addressed the right issue.
• Set out our findings and the evidence we relied on.
• State our decision — whether we uphold the complaint in whole, in part, or not at all — and the reasons for it.
• Explain any remedy or redress we are offering, such as a refund, correction, goodwill payment or apology, and how and when you will receive it.
• Tell you about your right to escalate to the independent bodies described below if you remain dissatisfied, including the relevant time limits.

If we cannot send a final response within the applicable timeframe, we will instead send a holding response that explains why, tells you when we expect to reach a conclusion, and confirms that you can already refer your complaint to the relevant ombudsman if you wish. We would always rather you waited for our considered answer, but the choice is yours.

If you are not satisfied with our final response, or if the relevant timeframe has passed without one, you have the right to refer your complaint to an independent body. This is free of charge and does not affect any other legal rights you may have.

Bank of Lithuania. As our supervisory authority, the Bank of Lithuania operates an out-of-court dispute resolution procedure for consumers of financial services. You can refer your complaint to the Bank of Lithuania, generally within one year of submitting it to us, through its consumer dispute resolution service. Its contact details are:

• Lietuvos bankas (Bank of Lithuania), Totorių g. 4, LT-01121 Vilnius, Lithuania.
• Online and by post via its financial-market consumer dispute resolution service at www.lb.lt.

Relevant ombudsman in your country. Because we passport across the EEA, you may also be able to use the financial ombudsman or alternative dispute resolution (ADR) scheme in your own country of residence. If you are unsure which scheme applies to you, ask us in your complaint and we will point you to the right one in our final response.

Online Dispute Resolution. If you opened your account online, the European Commission's Online Dispute Resolution platform can also help direct you to an approved ADR body. We will include any links you need in our final response so you do not have to hunt for them.

Referring to an ombudsman or ADR body is voluntary and free. You do not need a lawyer, although you are welcome to use one. These bodies look at the matter independently and reach a fair outcome based on the facts, and we cooperate fully with their requests.

If your complaint is specifically about how we have handled your personal data — for example access, accuracy, erasure, marketing preferences, or a suspected breach — we will handle it under this procedure and, where relevant, alongside your rights under the General Data Protection Regulation (GDPR). You can also raise data protection concerns directly with our Data Protection Officer.

In addition to our internal process, you have the right to lodge a complaint with the supervisory authority for data protection in Lithuania, the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija):

• Valstybinė duomenų apsaugos inspekcija, L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania.
• Online at vdai.lrv.lt.

If you live in another EEA country, you may instead complain to your local data protection authority. Using the data protection authority does not stop you from also using the financial dispute resolution routes above, and the two can run in parallel where your complaint touches both money and data.

We want the complaints process to be open to everyone, regardless of disability, language or circumstances. We will make reasonable adjustments so you can raise and follow a complaint in the way that works best for you. For example, we can:

• Take a complaint by phone and write it up for you if typing or writing is difficult.
• Communicate by your preferred channel — in-app chat, email, phone or post.
• Allow a trusted friend, family member, carer or representative to complain on your behalf with your authority.
• Provide information in plain language and explain anything that is unclear, with no jargon and no assumptions.
• Give you extra time where a deadline would otherwise disadvantage you because of your circumstances.

If you have an accessibility need that affects how you would like to complain, just tell us at any point and we will adapt. We would always rather make an adjustment than have a customer feel unable to be heard.

A complaint that we resolve for one customer but never learn from is only half-handled. We treat complaints as one of our most valuable sources of feedback about where Sezvo can be better.

• We record the root cause of every complaint, not just the resolution, so we can tell the difference between isolated errors and patterns.
• We review complaint themes regularly with the product, operations and engineering teams, and feed fixes into the roadmap.
• We monitor our own performance against the timelines on this page, and we report complaints data to senior management and, where required, to the Bank of Lithuania.
• Where a complaint reveals an issue that could affect other customers, we act proactively to correct it for everyone, not only for the person who raised it.

None of this changes the safeguards around your money. As an electronic money institution, customer funds are safeguarded in line with EMI rules — held separately from our own funds so they remain yours even in the unlikely event of our insolvency. Where eligible deposits are covered by the applicable deposit guarantee scheme, that protection extends up to €100,000. Sezvo is an e-money institution rather than a traditional bank, so we are always accurate about the distinction between safeguarding and deposit guarantee. Please remember that investing puts your capital at risk, and that crypto assets are unregulated and volatile; complaints about market movements or the value of assets are outside what this process can change, although we will always help with anything about the service itself.

To raise a complaint, or to ask anything about this procedure, use whichever of the following is easiest:

• In the app: Help & support → chat to our team, available 24/7.
• Email: complaints@sezvo.com
• Phone: +370 5 214 0022 (24/7)
• Post: Complaints, UAB Aušra Pay, Konstitucijos pr. 21A, LT-08130 Vilnius, Lithuania

Sezvo is a trading name of UAB Aušra Pay, an electronic money institution authorised and supervised by the Bank of Lithuania, passporting across the EEA. BIC/SWIFT: OCENLT22. Accounts use Lithuanian (LT) IBANs. This complaints policy is reviewed regularly and may be updated; the effective date above shows the most recent revision.