Complaints Procedure

What is a formal complaint?

A formal complaint is a written report by which the customer informs THE REAL MONEY of a specific problem related to the services received through the Platform, requesting a specific intervention to resolve it.

How to file a complaint

2.1 · Reception channels

The customer can file a formal complaint through one of the following channels, all available 24 hours a day:

2.2 · Content of the complaint

In order for the complaint to be processed effectively, it must contain:

• a) Name and surname (or company name) and tax identification number / VAT number.
• b) E-mail address and contact telephone number.
• c) THE REAL MONEY Client Number / Account ID (if available).
• d) Clear and detailed description of the fault in dispute.
• e) Reference to the disputed transaction (date, amount, type of transaction, transaction number if available).
• f) Desired outcome (e.g., reimbursement, rectification, reasoned explanation).
• g) Supporting documentation: account statements, screenshots, previous communications, contracts.

Structured complaints management procedure

Each complaint received is processed through a 6-step process, each with defined deadlines and assigned responsibilities.

Priority and response times

THE REAL MONEY prioritizes complaints and adheres to the following deadlines, beginning on the date of receipt of the completed complaint:

4.1 · Corrective action in case of acceptance

If the complaint is fully or partially accepted, THE REAL MONEY will implement corrective measures within the following timeframes:

• Financial refunds: paid within 5 business days of sending the final response.
• Accounting corrections: correction within 3 business days.
• Unblocking transactions: immediate (same business day).
• Contractual modifications: within 15 working days.
• Changes to internal procedures: within 30 business days.

Content of the final answer

Any final response to a complaint must include the following elements:

• a) Identification data: protocol number, date of receipt.
• b) Summary of the complaint submitted: clear reformulation of the dispute.
• c) Chronological reconstruction of the facts in dispute.
• d) Result of the investigation, clearly communicated: ACCEPTED (recognition of the problem and indication of the corrective measures taken), PARTIALLY ACCEPTED (recognition of the validity of some aspects and explanation of others) or REJECTED (detailed and reasoned explanation of the reasons).
• e) Detailed reasons with specific contractual and regulatory references (MiFID II, GDPR, CBI regulation).
• f) Corrective measures taken or to be taken, with their respective time frames, if accepted or partially accepted.
• g) Full information on available remedies: mandatory in each response (see Section 6).
• h) For any clarification, please contact: claim@therealmoney.com.

5.1 · Format and traceability

• Written in English or in the language used by the customer to submit the complaint, in PDF format and signed by the Compliance Officer.
• Sent through the same channel used by the customer.
• Stored in the Complaints Register in a non-editable format with automatic backup.
• Available for inspection by the Central Bank of Ireland upon request.
• Kept for a minimum period of 6 years in accordance with MiFID II and the Central Bank of Ireland (CBI) regulations, and for 10 years for profiles relevant to the prevention of money laundering.

5.2 · Automated processing

The complaint management process may use technological tools for the initial classification and review phase. The final decision on the complaint is always made by an official of THE REAL MONEY.

Available remedies

If the customer is not satisfied with THE REAL MONEY's response or has not received a response within the indicated period, they can contact the following bodies. These appeals are free, alternative, and can be initiated independently of the internal procedure.

6.1 · Financial Services and Pensions Ombudsman (FSPO) — Ireland

The FSPO is the independent body established by the Financial Services and Pensions Ombudsman Act 2017 for the out-of-court settlement of disputes between clients and authorised financial institutions, and is competent for institutions authorised by the Central Bank of Ireland under the MiFID II Directive.

6.2 · Reporting to the Central Bank of Ireland (CBI)

Clients have the right to report any suspected non-compliance with the MiFID II Directive or the terms of the licence granted by REAL MONEY EUROPE LIMITED directly to the Central Bank of Ireland.

6.3 · ODR Platform — European Commission

For consumers residing in the European Union, the European online dispute resolution platform is available:

• Website: https://ec.europa.eu/consumers/odr
• Free access; the platform allows a procedure to be initiated with accredited alternative dispute resolution bodies.

6.4 · Ordinary Judicial Authority

The customer always has the right to appeal to the competent judicial authority, independently of any other procedure. The competent court for disputes with THE REAL MONEY is the Court of Dublin, without prejudice to the consumer's right to appeal to the court of their place of residence, in accordance with Regulation (EU) No 1215/2012.

6.5 · Comparative summary of remedies

Supervision, governance and control

7.1 · Multi-level supervision system

7.2 · Monitored key performance indicators (KPIs)

• Average complaint processing time (target: < 30 days for ordinary complaints).
• Percentage of compliance with regulatory deadlines (target: 100%).
• Percentage of accepted vs. rejected complaints.
• Percentage of complaints referred to external bodies for resolution.
• Customer satisfaction after resolution (optional survey).

7.3 · Periodic review

• Quarterly review: analysis of statistics, trends, and recurring critical issues.
• Annual review: assessment of the effectiveness of the procedure, policy update.
• Corrective measures: identify the root causes of recurring complaints; implement preventive measures.

Processing of personal data

The personal data provided in the context of a complaint is processed by the platform owner as Data Controller in accordance with Regulation (EU) 2016/679 (GDPR) and the Data Protection Act 2018 (Ireland), exclusively for the following purposes:

• Management and investigation of complaints.
• Compliance with regulatory obligations (MiFID II, CBI regulation, GDPR).
• Preparation of internal reports and trend analysis for the continuous improvement of the service.
• Possible transmission to the Central Bank of Ireland, the FSPO, or another authority, upon request.

Complaint data is kept for a minimum period of 6 years, in accordance with MiFID II regulations, and for 10 years in the case of profiles related to the fight against money laundering. For more information, please consult the «Privacy» section of the platform.

Summary of contacts and references