Clapp Complaints Policy

Last Revised: 25.08.2026

1. Purpose and Scope

1.1 This Policy explains how to make a complaint about any service offered through the Clapp website and the Clapp app, how we handle it, how long it takes, and what you can do if you are not satisfied with the outcome.

1.2 It applies to all services provided by the companies of the Clapp group. Your complaint is handled by the group company that provides the service concerned, as identified in the Clapp app and in the Terms of Service. Where a service is provided by a partner institution, such as the card issuer or the institution providing euro accounts, we will pass your complaint to that partner where its procedures apply and will keep you informed.

1.3 Complaints are handled free of charge. Making a complaint does not affect your right to use the services, except where the complaint relates to conduct that leads to suspension or closure under the Terms of Service.

2. How to File a Complaint

2.1 You can submit a complaint through the support chat in the Clapp app, or by email to [email protected] with the subject line “Complaint”.

2.2 To help us resolve your complaint quickly, please include: the email address linked to your Clapp account; the date and details of the issue, including transaction identifiers, amounts, currencies and screenshots where relevant; a clear description of what went wrong in your view; and the outcome you are seeking.

2.3 If you make a complaint through a channel other than those above, for example through social media, we may ask you to resubmit it through the app or by email so that we can verify your identity and protect your account information.

3. Timelines

3.1 We will acknowledge your complaint within 2 business days of receipt and give you a reference number.

3.2 We aim to give you a final response within 15 business days of receipt.

3.3 In exceptional cases, where a full answer is not possible within that period for reasons outside our control, for example where we are waiting for information from a card network, a partner institution or a blockchain analytics provider, we will inform you of the delay, its reasons and the date by which you will receive our final response, which will be no later than 35 business days after receipt.

3.4 Business days are days other than Saturdays, Sundays and public holidays in England and Wales.

4. How We Handle Complaints

4.1 We investigate every complaint fairly and on its merits. Wherever possible, complaints are reviewed by staff who were not directly involved in the matter complained about.

4.2 Our final response will explain our findings and the reasons for them, state whether we uphold the complaint in whole or in part, describe any remedy we offer, and tell you what you can do if you are not satisfied.

4.3 Where we uphold a complaint, remedies may include correcting an error, reversing a fee, restoring assets or balances, or paying compensation for a direct loss we caused. Remedies are subject to the liability provisions of the Terms of Service and the applicable product terms.

4.4 We record all complaints and their outcomes, and we use them to improve our services and controls.

5. Card Complaints and Transaction Disputes

5.1 Complaints about the Clapp Card are handled by Clapp Limited (Hong Kong) as program distributor and servicer, in coordination with the card issuer and the card network where needed.

5.2 Disputed card transactions and suspected errors must be reported no later than 60 days after the transaction date, as set out in the Card Terms. We will submit eligible disputes into the chargeback process. The outcome of a chargeback is decided by the card network and the card issuer, not by Clapp, and the timelines of the network rules apply in addition to this Policy.

5.3 The card issuer may operate its own complaint procedure under its cardholder terms. Where it does, we will tell you how to access it.

6. If You Are Not Satisfied

6.1 If you do not accept our final response, or if you have not received a final response within the period stated in Section 3, you may pursue the dispute resolution route set out in the terms applicable to the service concerned.

6.2 For services governed by the Terms of Service, the Savings Terms and the Credit Line Terms: before starting formal proceedings, you agree to contact us and engage in good faith negotiations for at least 30 days. Any dispute arising out of or in connection with those terms shall be referred to and finally resolved by arbitration under the LCIA Rules. The number of arbitrators shall be one. The seat of arbitration shall be London, England. The language of the arbitration shall be English.

6.3 For the Clapp Card, disputes with Clapp Limited are resolved as set out in the Card Terms, by arbitration administered by the Hong Kong International Arbitration Centre seated in Hong Kong. Disputes with the card issuer are governed by the issuer’s cardholder terms.

6.4 Nothing in this Policy deprives you of the protection of mandatory consumer protection rules of the country where you reside, prevents you from bringing proceedings before the courts of your country of residence where applicable law gives you that right, or restricts your right to complain to a competent supervisory or consumer protection authority at any time.

7. Complaints to Authorities

7.1 You may refer a complaint to a competent authority at any time, before or after using our internal process. Depending on the service and your country, the following may be relevant: for services of Clapp S.A. de C.V., the Superintendence of the Financial System of El Salvador; for card matters, the regulator of the card issuer, whose details are available on request; and the consumer protection body of your country of residence.

7.2 We cooperate with authorities that examine complaints about our services and will provide the information they lawfully request.

8. Data Protection Complaints

8.1 For complaints about the processing of your personal data, write to [email protected]. Such complaints are handled under our Privacy Policy, and we respond within one month, extendable by two further months for complex requests.

8.2 You have the right to lodge a complaint with a supervisory authority. In the EU, you may complain to the supervisory authority of your habitual residence or place of work, or to the Czech Office for Personal Data Protection (ÚOOÚ), which is the authority of the group’s EU establishment. In Canada, you may complain to the Office of the Privacy Commissioner of Canada. In Hong Kong, you may complain to the Privacy Commissioner for Personal Data.

9. Time Limit for Claims

9.1 Any claim arising out of or relating to the services must be filed within one year after the date on which you became aware, or reasonably should have become aware, of the facts giving rise to the claim, unless a longer period is required by applicable law. Making a complaint under this Policy does not extend this period unless we agree otherwise in writing.

10. Language, Changes and Contact

10.1 Complaints are handled in English. We may accept complaints in other languages where we are able to, but our final response is issued in English, and the English version prevails.

10.2 We may update this Policy from time to time. The “Last Revised” date shows the current version. Complaints already in progress are handled under the version in force when they were submitted.

10.3 Support and complaints: [email protected]. Data protection: [email protected].