EU-Customer Complaints Handling Policy
Last updated: March 27, 2026
Last update: March 2027
1. General Provisions
1.1 Purpose
The purpose of this Regulation is to govern the internal rules and functioning of the Customer Service Department of CROSSMINT EUROPE, S.L. (hereinafter, Crossmint or the Entity), as well as the procedure for handling complaints and claims submitted by clients in relation to their legally recognized rights and interests.
This Regulation complies with:
Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (MiCA)
Commission Delegated Regulation (EU) 2025/294 of 1 October 2024, supplementing Regulation (EU) 2023/1114 as regards regulatory technical standards specifying requirements, templates, and procedures for handling complaints by crypto-asset service providers
Order EHA/2899/2011 of 28 October on transparency and protection of banking services customers
Law 7/2017, of 2 November, incorporating into Spanish law Directive 2013/11/EU of the European Parliament and of the Council of 21 May 2013 on alternative dispute resolution for consumer disputes
Order ECO/734/2004, of 11 March, on customer service departments and the customer ombudsman of financial institutions
1.2 Scope of Application
The Customer Service Department shall, in accordance with the powers and procedures established in this Regulation, be responsible for handling and resolving complaints and claims from customers, whether natural or legal persons, spanish or foreign, provided that such complaints and claims relate to their legally recognized interests and rights, whether arising from contractual relationships, applicable transparency and customer protection regulations, or from financial best practices and principles of fairness.
The Customer Service Department shall not be competent to handle complaints and claims that do not fall within the scope described above, and in particular those arising from:
Relationships between the entities and their shareholders or employees in their capacity as such.
Relationships between the entities subject to this Regulation and their suppliers in matters relating to their commercial relationship.
Services or products provided by other Crossmint entities that are not subject to this Regulation, and complaints or claims submitted by persons who do not qualify as customers or representatives of customers.
Complaints relating exclusively to products or services provided by third parties, where the customer’s relationship is directly established with such third party under its own terms and conditions.
Complaints or claims that fall within the jurisdiction of administrative, arbitral, or judicial bodies, or that are pending resolution or litigation.
Complaints or claims involving disputes over facts that can only be evidenced through judicial proceedings or whose resolution necessarily requires the assessment of experts with specialized knowledge in technical matters unrelated to customer protection regulations or financial best practices.
Complaints or claims relating to discretionary commercial decisions of the entities, such as whether or not to enter into transactions, contracts, or services with a particular person, or the terms and conditions thereof.
1.3 Definitions
The following terms shall have the meanings set out below for the purposes of this Regulation:
Customers or users: Natural or legal persons, whether Spanish or foreign, who qualify as users of any of the services provided by Crossmint under this Regulation, provided that such services are considered financial or crypto-asset services.
Services: The services subject to this Regulation are those provided by Crossmint that are of a financial or crypto-asset nature.
Complaint (Queja): Any expression of dissatisfaction submitted by customers to an internal department other than the Customer Service Department (SAC). All internal departments are responsible for proactively addressing and resolving customer dissatisfaction so that a formal claim before the SAC is not required. Complaints shall also include those submitted by users of financial services in relation to delays, lack of attention, or any other deficient performance observed in the operation of the Entity.
Claim (Reclamación): An expression of dissatisfaction submitted to the SAC in relation to regulated services, in which the customer alleges harm to their interests or legally recognized rights arising from alleged breaches by the Entity, applicable regulations, or principles of fairness.
Technical support: The service responsible for receiving customer contacts and acting to resolve queries, requests, incidents, and complaints, with the support of internal departments, so that the customer does not need to submit a formal claim.
SAC (Customer Service Department): The Customer Service Department, an independent unit from business and commercial areas, responsible for resolving claims and managing and promoting the continuous improvement of all complaints and claims.
Supervisory Complaints Services: Refers to the complaints services attached to the Spanish National Securities Market Commission (CNMV), which, within the scope of its competence, handles complaints and claims submitted by users of the services.
1.4 Approval and Adherence to the Regulation
This Regulation has been approved by resolution of the Board of Directors of CROSSMINT EUROPE, S.L. and submitted for verification by the CNMV.
Other Crossmint entities may adhere to this Regulation provided that they fall within one of the following categories:
a) Investment firms; and
b) Any other entity providing financial or other services to end customers, provided that no legal provision prevents such adherence.
Adherence must be effected by resolution of the governing body of the relevant entity. Such resolution must include the explicit and specific acceptance of the Head of the Customer Service Department (SAC) appointed by the Board of Directors of Crossmint.
Any changes to the Head of the Customer Service Department (removals and new appointments) shall be approved by resolution of the Board of Directors of Crossmint, in accordance with this Regulation, and shall be binding on the adhering entities. Such changes shall be notified to the supervisory complaints services, the CNMV, and any other competent supervisory authorities, depending on the activities carried out by Crossmint and the adhering entities. In addition, the Boards of Directors of the adhering entities shall individually approve any such changes.
Any amendments to this Regulation shall be approved by resolution of the Board of Directors of Crossmint and shall be binding on the adhering entities, which must approve them through their respective governing bodies. Such amendments shall be submitted for verification by the CNMV.
Failure to adopt the resolutions referred to in the preceding paragraphs shall result in the affected entity ceasing to be bound by the regime established under this Regulation, and it shall be entitled to establish its own Customer Service Department in accordance with the applicable regulations in force at any given time.
An updated list of adhering entities, if any, shall be attached as Annex II to this Regulation.
1.5 Disclosure
In accordance with Article 9 of Order ECO/734/2004, the Entity shall make the following information available to its customers at all times, in each of its offices open to the public (if any), as well as on its website in the case of contracts entered into by electronic means:
The existence of a Customer Service Department and, where applicable, a Customer Ombudsman, including their postal and email addresses, as set out in Annex I of this Regulation.
Crossmint’s obligation to handle and resolve complaints and claims submitted by its customers within a period of fifteen (15) business days from their submission at any of the Entity’s offices, to the Customer Service Department or, where applicable, the Customer Ombudsman, by post or via the designated email address. In exceptional circumstances, where a response cannot be provided within fifteen (15) business days for reasons beyond the Entity’s control, a provisional response must be sent clearly stating the reasons for the delay and specifying the timeframe within which the customer will receive a final response. In any case, the deadline for the final response shall not exceed one (1) month.
A reference to the complaints services of the supervisory authorities, including their postal and email addresses, for cases where customers consider it necessary to escalate their complaint, together with an express indication that the Customer Service Department or Customer Ombudsman procedure must first be exhausted before submitting complaints to such authorities.
This Regulation governing the operation of the Customer Service Department, or any documents replacing it.
References to the regulations on transparency and protection of customers of financial services.
For these purposes, it is expressly stated that the activity of the Customer Service Department governed by this Regulation is subject to Order ECO/734/2004 and to the applicable regulations in force at any given time concerning transparency and customer protection, as well as to the regulations referred to above in this Regulation.
2. CUSTOMER SERVICE DEPARTMENT
2.1 Structure
The Customer Service Department is an internal body and department of Crossmint, separate from commercial and operational functions, whose role is to resolve, independently and avoiding any conflict of interest, the complaints within its remit, in accordance with this Regulation, as well as to promote continuous improvement in relation to complaints and claims.
Crossmint shall provide the Department with adequate human, material, technical, and organizational resources to perform its functions. In particular, it shall take the necessary measures to ensure that staff assigned to the Department have an adequate understanding of the regulations on transparency and customer protection in financial services.
Crossmint shall adopt appropriate measures to ensure that procedures for the transmission of information required by the Customer Service Department from other departments of the organization comply with the principles of promptness, security, effectiveness, and coordination.
2.2 Head of the Customer Service Department
Crossmint shall appoint a Head of the Customer Service Department (the “Head of the Customer Service Department” or the “Head”) to ensure the proper handling of complaints and claims in accordance with Order ECO/734/2004 and the regulations applicable to this Regulation. Entities adhering to this Regulation shall appoint the same Head through their respective Boards of Directors.
The Head must possess commercial and professional integrity, as well as appropriate knowledge and experience. A person may not be appointed if they have a criminal record or are under investigation for offences relating to property, money laundering, socio-economic order, public finances, or social security.
The Head of the Customer Service Department shall participate in the approval, monitoring, and control processes for new products, contributing their experience regarding complaints and their knowledge of supervisory criteria.
Decisions of the Customer Service Department shall be binding on Crossmint, but not on the complainant.
2.3 Incompatibility and Ineligibility
The following persons may not be appointed as Head of the Department:
Undischarged bankrupts or insolvent persons not rehabilitated.
Persons disqualified or suspended, criminally or administratively, from holding public office or management positions.
Persons with criminal records for offences relating to property, money laundering, socio-economic order, public finances, or social security.
Persons sanctioned for serious or very serious administrative infringements relating to banking, insurance, securities markets, crypto-assets, anti-money laundering, counter-terrorist financing, consumer protection, or any other serious administrative offence.
Persons performing functions directly related to Crossmint’s commercial or operational services.
Persons holding political office or carrying out activities that may have public relevance or affect the public image or independence of the Customer Service Department.
2.4 Appointment and Removal
The Head shall be appointed by resolution of the Board of Directors of Crossmint. The term of office shall be four years, automatically renewable for equal periods, unless the Entity notifies the supervisory authorities of the replacement of the appointed Head.
The Head may be removed by a reasoned decision of the same body on the basis of the following grounds:
Loss of the eligibility requirements;
Suspension or termination of the employment relationship with Crossmint;
Being subject to criminal investigation for offences relating to property, money laundering, socio-economic order, public finances, or social security;
Manifestly negligent performance of duties or any other serious cause;
Death or supervening incapacity;
Express resignation;
At any time, by reasoned decision of the Board of Directors of Crossmint, provided that such decision is based exclusively on serious and justified grounds;
Incurring any of the causes of ineligibility or incompatibility set out in this Regulation.
The appointment and removal of the Head shall be notified by Crossmint to the supervisory complaints services and to the Spanish National Securities Market Commission (CNMV).
In the event that the position becomes vacant for any reason, a replacement shall be appointed in accordance with the applicable legal and/or statutory provisions.
The removal and subsequent appointment of a new Head shall not suspend the deadline for resolving any complaint or claim.
2.5 Conflicts of Interest
In any complaint or claim in which the Head has a personal interest that gives rise, or may give rise, to a conflict of interest, the Head shall abstain from participating in its handling and resolution. In such cases, responsibility shall fall to the most senior person within the Customer Service Department after the Head.
Similarly, any member of the Customer Service Department with a personal interest that may give rise to a conflict of interest shall abstain from participating in the handling or proposing the resolution of the matter.
For these purposes, a personal interest shall be deemed to exist where the complaint or claim, or a related matter, directly affects the individual, their relatives up to the third degree of consanguinity or affinity, or persons with whom they maintain or have maintained a close personal or emotional relationship.
A personal interest shall also be deemed to exist where the Head or any member of the Customer Service Department was providing professional services in the department affected by the complaint or claim at the time the relevant events occurred or produced their effects.
2.6 Departmental Obligations
Although the Customer Service Department, as well as its Head, shall remain separate from the other commercial and operational functions of the organization, all Crossmint departments must cooperate with the Customer Service Department whenever requested, in all matters that facilitate the proper performance of its functions. In particular, they must provide all information requested in matters within its competence and in relation to issues submitted for its consideration.
To this end, all Crossmint employees and management are required to cooperate with the Customer Service Department, providing the data, reports, opinions, and evidence requested by it.
3. PROCEDURE FOR HANDLING COMPLAINTS AND CLAIMS
3.1 Scope of the procedure
Operational, sales, and technical support departments are responsible for resolving customer queries, incidents, and complaints so that they do not escalate into a formal claim.
The procedure set out in this section shall apply to the handling of claims falling within the competence of the Customer Service Department.
3.2 Time limit for submitting claims
Customers may submit claims at any time from the moment they become aware of the facts giving rise to the claim, within a period of two (2) years from such knowledge.
3.3 Submission of claims
Where a complaint or incident is not resolved by the responsible department, or where the customer is not satisfied with the outcome, the customer may immediately submit a formal claim to the Customer Service Department.
All customers shall have the right to submit claims to the Customer Service Department free of charge in relation to the products and services offered by the Entity.
Claims may be submitted in the languages used by the crypto-asset service provider to market its services or communicate with customers, as well as in the official languages of the home Member State and host Member States that are also official languages of the European Union.
Claims may be submitted in person or through a representative, in paper form or via electronic or telematic means, provided that such means allow for the reading, printing, and storage of documents. The use of electronic means must comply with the requirements set out in Law 59/2003 of 19 December on electronic signatures.
In all cases, acknowledgment of receipt must be provided in writing, including the following:
The department responsible for handling the claim and the contact email address for any related inquiries;
The date of receipt of the claim and a reference to the resolution timeline;
A copy of the claim submitted by the customer.
The claim shall be submitted only once by the customer, and the customer shall not be required to resubmit it to different internal bodies.
Upon receipt of the claim by the Customer Service Department, a case file shall be opened.
3.4 Form and content of claims
The procedure shall be initiated by submitting a written claim including:
The name, surname, and address of the claimant, and, where applicable, proof thereof; identification number or passport number for natural persons, and public registry details for legal persons. Where submitted through a representative, such representation must be duly evidenced.
The reason for the claim, clearly specifying the issues on which a decision is requested and, where applicable, the amount claimed.
The office(s), department, or service where the events giving rise to the complaint or claim occurred.
A statement confirming that the claimant is not aware of any administrative, arbitral, or judicial proceedings relating to the same matter.
Place, date, and acceptance of personal data processing in accordance with applicable data protection laws.
Any documentary evidence available to the claimant supporting the claim.
The claimant must submit, together with the written claim, any documentary evidence available. The claim may be submitted using the form provided in Annex III.
3.5 Time limit for resolving claims
The Customer Service Department must issue a decision within a maximum period of two (2) months.
Exceptionally, this period may be extended where it is impossible to provide a response within the established timeframe for reasons beyond the control of the Department, provided that the customer is informed of the reasons for the delay and the expected timeframe for the final response.
Time limits shall be calculated from the date the claim is submitted to the Customer Service Department in the case of electronic channels, and from the date of receipt in the case of postal submissions.
3.6 Rectification
Where the identity of the claimant is not sufficiently verified or the facts of the claim cannot be clearly established, the claimant shall be requested to complete the documentation within ten (10) calendar days, with the warning that failure to do so will result in the claim being closed without further action.
Failure to remedy deficiencies within the prescribed timeframe shall not be interpreted as a waiver of the claimant’s right to submit the claim again.
The time taken by the claimant to remedy deficiencies shall not be included in the calculation of the resolution deadline.
3.7 Inadmissibility
Claims may only be rejected as inadmissible in the following cases:
Where essential data required for processing is missing and cannot be remedied, including where the reason for the claim is not specified;
Where the matter falls within the jurisdiction of administrative, arbitral, or judicial bodies, is pending resolution, or has already been resolved by such bodies;
Where the facts, reasons, and requests do not relate to specific transactions or fall outside the scope of this Regulation;
Where the claim is manifestly intended to obstruct, hinder, or delay the exercise of Crossmint’s rights;
Where the claim repeats a previous claim already resolved concerning the same facts;
Where the time limit for submission of claims has expired;
Where the content of the claim is abusive or offensive;
Where there is simultaneous processing of the same matter through administrative, arbitral, or judicial proceedings.
Where a claim is deemed inadmissible, the claimant shall be notified through a reasoned decision and granted ten (10) calendar days to submit observations. If the grounds for inadmissibility remain, the final decision shall be communicated.
3.8 Processing
During the processing of claims, the Customer Service Department may request from the claimant and from the relevant departments any data, clarifications, reports, or evidence deemed necessary to reach a decision. Departments must act diligently to ensure that a decision can be reached within the established timeframes.
Crossmint shall adopt appropriate measures to ensure that internal information flows requested by the Customer Service Department comply with principles of promptness, security, effectiveness, and coordination. Departments must respond within a non-extendable period of five (5) days.
3.9 Settlement and withdrawal
Prior to issuing a decision, the Customer Service Department may take all necessary steps to seek an amicable settlement between the parties, which, if reached, shall be binding on both parties.
Where Crossmint rectifies its position to the satisfaction of the claimant, this shall be documented and the claim may be closed without further processing.
Claimants may withdraw their claims at any time. Withdrawal shall result in the immediate termination of the procedure in relation to the claimant. However, the Customer Service Department may decide to continue the process in the context of its role in promoting compliance with transparency and customer protection regulations and financial best practices.
3.10 Completion and notification
The case must be concluded within a maximum period of two (2) months from the date the complaint or claim was submitted.
The decision shall always be reasoned and shall include clear conclusions regarding the issues raised, based on contractual terms, applicable transparency and customer protection regulations, and financial best practices.
Where the decision departs from criteria applied in previous similar cases, the reasons for such departure must be provided.
The decision shall be notified to the claimant within ten (10) calendar days from its issuance, in writing or via electronic or telematic means that allow for reading, printing, and storage, in accordance with Law 59/2003 on electronic signatures, using the channel designated by the claimant or, in the absence of such designation, the same channel used to submit the claim.
The decision must expressly inform the claimant of their right to escalate the matter to the relevant supervisory complaints service.
The decision shall be issued in the language in which the claim was submitted, provided it is one of the languages referred to in section 3.3.
Where the claimant qualifies as a consumer (in accordance with Law 7/2017), they shall have a period of one (1) year from the submission of the complaint or claim to escalate it to the relevant financial supervisory authority, provided that:
Two (2) months have elapsed without resolution; or
The claimant is not satisfied with the decision issued.
The customer shall have a maximum period of one (1) year from the date the Customer Service Department issued its decision, or from the date it should have issued it, to submit a complaint to the CNMV Complaints Service.
3.11 Effects of the decision
For the customer: The claimant is not required to accept the decision and may initiate administrative or judicial proceedings.
For Crossmint: A decision favorable to the claimant shall be binding on Crossmint.
Once accepted, Crossmint shall implement the decision within the timeframe specified in the response. The execution period shall begin from the date Crossmint is notified of the claimant’s acceptance.
3.12 Confidentiality and record retention
Claimants shall have the right to be informed of the status of their case, to recover original documents submitted, and to obtain copies of such documents and of communications issued by the Customer Service Department.
Information relating to case files shall not be disclosed to third parties without the consent of the claimant, except where required by judicial or administrative authorities. Statistical data and decision criteria may be published, provided that confidentiality of the parties is preserved.
Complaint files, including all documentation and communications, shall be retained on a durable medium for a minimum period of five (5) years from the date of closure, in accordance with applicable regulations.
4. OTHER PROVISIONS
4.1 Annual Report
Within the first quarter of each year, the Customer Service Department shall submit to the Board of Directors of Crossmint and of the entities adhering to this Regulation a report explaining the performance of its functions during the previous financial year. This report shall include, at a minimum, the following:
A statistical summary of the complaints handled, including information on their number, admissibility and reasons for inadmissibility, the issues and matters raised, and the amounts involved;
A summary of the decisions issued, indicating whether they were favorable or unfavorable to the claimant;
The general criteria applied in the decisions;
Recommendations or suggestions derived from its experience, aimed at improving the achievement of its objectives.
At least a summary of this report shall be included in the annual report of Crossmint and of each of the entities adhering to this Regulation.
4.2 Relationship with Supervisory Complaints Services
The Customer Service Department shall, through a designated person, respond to any requests made by the supervisory authorities in the exercise of their functions, within the timeframes established by such authorities.
The supervisory authorities shall adopt the necessary measures and carry out appropriate actions to facilitate the transmission of the data and documents required for the performance of their functions by electronic means, including the use of electronic signatures, in accordance with Law 6/2020 of 11 November on certain aspects of electronic trust services.
ANNEX I – Contact Details
In particular, any submissions containing complaints and claims, as well as any documents to be submitted in the course of procedures initiated in connection with them, shall be addressed to the Customer Service Department (SAC) at the following contact details:
Email: support@crossmint.com
Postal address: Calle Villalar 7, Bajo Izq, 28001, Madrid
ANNEX II – Adhering Entities
In accordance with Article 3, there are currently no entities adhering to this Regulation.
ANNEX III – Complaint Submission Form to the SAC
1.a. Information relating to the complainant
1.b. Contact details (if different from those provided in section 1.a)
2.a Information relating to the legal representative (if applicable)
(A power of attorney or other official document evidencing the appointment of the representative must be attached to this form)
2.b. Contact details (if different from those provided in section 2.a)
3. Information relating to the complaint
3.a. Provide a complete reference to the product, service, or agreement to which the complaint relates, including transactions carried out, currency type, quotation, reference number, etc.
3.b Description of the reason for the complaint (include supporting documents evidencing the facts described)
3.c. Date(s) of the events giving rise to the complaint
3.d Description of damages, losses, or harm caused (if applicable)
3.e Other relevant comments or information (if applicable)
I declare that I am not aware that this matter is currently being processed through an administrative or judicial proceeding (mandatory).
At (place) on (date)
Signature
COMPLAINANT / LEGAL REPRESENTATIVE OF THE COMPLAINANT
Supporting documentation (tick as applicable):