1. Purpose
This Complaints Handling Policy sets out how Unlshd Ltd, trading as NeptunePay ("Unlshd", "we"), receives, investigates, resolves, and learns from complaints made by merchants, partner acquirers, end-customers (where they reach us directly), and any other person.
Although Unlshd is not a regulated payment-services provider and is not subject to consumer-financial-services complaints rules in its own right, we treat complaints handling as a core operational and reputational discipline. Acquirer relationships, scheme inquiries, and merchant retention all depend on it.
2. Scope
This Policy applies to all complaints received by Unlshd, regardless of channel (email, telephone, written letter, message via partner acquirer, social media, etc.). It applies to all employees, contractors, and agents of Unlshd.
3. Definition of a Complaint
A complaint is any expression of dissatisfaction (whether justified or not) about Unlshd's services, conduct, employees, or representatives. Routine support enquiries, change requests, and general feedback are not complaints unless they are accompanied by an expression of dissatisfaction.
4. How to Make a Complaint
Complaints may be submitted by any of the following channels:
• Email: complaints@neptunepay.io
• Postal address: Complaints, Unlshd Ltd, 24 Ischyron, 4151 Kato Polemidia, Cyprus.
• Through the partner acquirer (where the complaint relates to the acquirer-merchant relationship), with the acquirer forwarding to Unlshd as appropriate.
To assist us in handling the complaint efficiently, we ask complainants to include: their name and contact details; the merchant or matter to which the complaint relates; a description of the issue; the outcome they are seeking; and any relevant supporting documents.
5. Acknowledgement and Initial Triage
We acknowledge complaints in writing within five (5) business days of receipt. The acknowledgement identifies a case reference, the person handling the complaint, and an indicative timeline for substantive response.
On receipt, the complaint is triaged by category and severity:
• Category A — Critical (regulatory, financial-crime, sanctions, scheme, or law-enforcement implications): escalated immediately to the MLRO/Compliance Officer and, where appropriate, to the Board.
• Category B — Material (significant operational, financial, or reputational impact): handled by the Compliance Function in coordination with the relevant business owner.
• Category C — Routine (operational issues, service quality, billing): handled by the relevant business owner with Compliance oversight as needed.
6. Investigation and Response
We investigate complaints fairly, promptly, and impartially. Investigations are conducted by a person not directly involved in the matter complained of, where reasonably practicable. Where the complaint involves a partner acquirer, a merchant, or a third party, we coordinate with them as appropriate, subject to confidentiality and data-protection obligations.
We will provide a substantive response in writing within 15 business days of receipt for Category C complaints, within 20 business days for Category B complaints, and as soon as reasonably practicable for Category A complaints (with interim updates at least every 10 business days). Where the complexity of the complaint requires a longer period, we will inform the complainant of the delay, the reason for it, and the expected response date.
The substantive response will: explain the outcome of the investigation; address the substance of the complaint; identify any remedial action taken or proposed; and inform the complainant of any further options available, including, where relevant, escalation to a partner acquirer or to a competent authority.
7. Records and Reporting
All complaints are recorded in a Complaints Register that captures: case reference; date received and channel; complainant identity (subject to data-protection rules); category and severity; subject matter; investigation findings; outcome; remediation; and time to acknowledgement and response. The Register is reviewed periodically by the Compliance Function for trends, root causes, and remediation themes. Material findings are reported to the Board.
8. Escalation and External Routes
Where a complaint cannot be resolved to the complainant's satisfaction internally, the complainant may, depending on the subject-matter:
• escalate to the partner acquirer in respect of the underlying merchant relationship;
• contact the relevant data-protection supervisory authority in respect of personal-data complaints (in Cyprus, the Office of the Commissioner for Personal Data Protection at commissioner@dataprotection.gov.cy);
• seek independent legal advice and pursue remedies in the competent courts under the governing-law and jurisdiction provisions of the underlying agreement.
Unlshd is not subject to a payment-services ombudsman scheme, because Unlshd is not a regulated payment-services provider.
9. Continuous Improvement
Complaints are a key source of operational and conduct feedback. Root-cause analysis is conducted on Category A and Category B complaints, and on patterns identified across Category C complaints. Findings feed into policy review, staff training, partner-acquirer dialogue, and changes to merchant onboarding criteria.
10. Confidentiality and Data Protection
Complaint information is processed in accordance with our Privacy Policy (NP-POL-005) and the Data Protection Laws. Information is shared internally only on a need-to-know basis and is shared externally (with partner acquirers, regulators, or other parties) only where lawful and necessary for handling the complaint.
11. Governance
This Policy is owned by the Compliance Function and approved by the Board of Directors of Unlshd Ltd. It is reviewed at least annually and on the occurrence of any material change.
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