Complaints & Dispute Resolution

Overview & our commitment

Centili Group Ltd. (trading as Centili, “we”, “us” or “our”) is committed to delivering reliable mobile-payment, carrier-billing, content-monetisation and SIM-security services to our customers, partners and the consumers who use them. We recognise that, from time to time, things may go wrong, or you may be unhappy with an aspect of our service.

We treat complaints as a valuable source of feedback. Handling them fairly, promptly and transparently helps us put things right for you and improve our services for everyone. This policy sets out how we receive, acknowledge, investigate and resolve complaints, and the rights you have if you are not satisfied with our response.

We are committed to:

• making it easy to raise a complaint through clearly published channels;
• treating every complainant courteously, fairly and without discrimination;
• acknowledging complaints promptly and keeping you informed of progress;
• investigating thoroughly, impartially and proportionately to the issue raised;
• providing a clear, written explanation of our findings and any remedial action;
• offering a route of escalation, both internally and to an independent third party where appropriate; and
• using the lessons learned to improve our processes, controls and customer experience.

There is no charge for using this complaints procedure, and raising a complaint will not adversely affect how we treat you.

What this covers

A complaint is any expression of dissatisfaction, whether justified or not, about our products, services, conduct, staff or the way we have handled a previous matter, where you expect a response or resolution. This policy applies to complaints from:

• business customers and integration partners who use our platforms and APIs;
• merchants, content providers and aggregators monetising through our services;
• mobile-network operators and other carriers connected to our billing and SIM-security infrastructure; and
• end-user consumers affected by a transaction, charge or service delivered through our platforms, where we are the appropriate party to address the issue.

What this policy does not cover

The following are handled through other channels and are outside the scope of this policy:

• routine technical support requests and “how do I” questions — please contact support@centili.co.uk;
• requests to exercise data-protection rights (such as access, erasure or objection), which are handled under our Privacy Policy via privacy@centili.co.uk;
• requests for refunds, chargebacks or cancellations, which are governed by our Refund & Cancellation Policy (although a refusal of a refund may itself become the subject of a complaint);
• reports of suspected security vulnerabilities, which should be submitted under our Responsible Disclosure Policy; and
• contractual disputes that the relevant master agreement directs to a specific dispute-resolution mechanism, in which case the terms of that agreement prevail.

Where a consumer’s complaint relates primarily to a charge applied by their mobile-network operator, or to content supplied by a third-party merchant, we may need to liaise with, or signpost you to, that operator or merchant in order to resolve the matter fully. We will tell you when this is the case.

How to make a complaint

The quickest way to raise a complaint is by email to our dedicated complaints mailbox:

complaints@centili.co.uk

You may also write to us by post at [Registered office address — to be confirmed], United Kingdom, marking your correspondence for the attention of the Complaints Team. If you have a disability or any other requirement that makes a particular channel difficult to use, please tell us and we will make reasonable adjustments to accommodate you, consistent with our obligations under the Equality Act 2010 and our Accessibility Statement.

What to include

To help us investigate quickly and thoroughly, please give us as much of the following information as you can:

• your name and the best way to contact you (email, phone or postal address);
• if you are writing on behalf of a business or another person, the name of that organisation or individual and your authority to act;
• relevant identifiers such as your account name, merchant or partner ID, transaction or reference numbers, the mobile number involved, and the date and time of the issue;
• a clear description of what went wrong and how it has affected you;
• copies of any supporting evidence, such as screenshots, messages, receipts or prior correspondence; and
• what you would like us to do to put things right.

We will only ask for and use the personal data we need to investigate and respond to your complaint, and we will handle that data in accordance with our Privacy Policy.

Our process & timescales

We aim to resolve complaints as quickly as possible and, wherever we can, at the first point of contact. The timescales below are indicative targets; where a matter is complex or depends on a third party, it may take longer, and we will keep you informed throughout.

Acknowledgement

We will promptly acknowledge your complaint, usually within two business days, and provide you with a reference number to quote in any further correspondence. If we can resolve your concern immediately, we will do so and confirm the outcome to you.

Investigation

A member of our team will investigate your complaint impartially and proportionately to the issues raised. This may involve reviewing transaction records, system and billing logs, internal communications and any relevant policies, and liaising with merchants, carriers or our sub-processors where the matter involves them. We may contact you to clarify points or request additional information; responding promptly will help us reach a fair outcome more quickly.

Written response

We aim to send you a full written response within 15 business days. Our response will explain what we found, the decision we have reached and our reasons for it, any action we have taken or will take to put things right, and how to escalate the matter if you remain dissatisfied. Where the complaint is particularly complex and we cannot respond fully within 15 business days, we will tell you why and give you a revised timescale, aiming in all cases to provide a final response within eight weeks of receiving your complaint.

Escalation to a senior reviewer

If you are not satisfied with our response, you may ask us to escalate the matter. A senior reviewer who was not involved in the original investigation will re-examine your complaint, our handling of it and the outcome, and will issue a further written response, normally within 15 business days of your escalation request. This is our final internal stage.

If you remain dissatisfied

We hope to resolve your complaint to your satisfaction through our internal process. If we cannot, there are several further options available depending on the nature of your complaint.

Alternative dispute resolution & mediation

Where a dispute has not been resolved through our complaints procedure, we are open to resolving it through alternative dispute resolution, such as independent mediation, as a constructive alternative to litigation. Either party may propose mediation in writing, and we will consider any reasonable proposal in good faith. Participation in mediation does not affect your right to pursue the matter through the courts, and the terms of any applicable contract between us may set out a specific escalation or dispute-resolution procedure that applies in addition to this policy.

Data-protection complaints

If your complaint concerns how we have handled your personal data and you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection, at ico.org.uk or by calling its helpline. We would, however, appreciate the opportunity to address your concerns first, so please consider contacting our Data Protection Officer at dpo@centili.co.uk before approaching the ICO. More information about your data-protection rights is set out in our Privacy Policy.

Consumers & relevant ombudsman schemes

If you are a consumer, you may, depending on the nature of the charge or service, be able to refer your complaint to the relevant ombudsman or alternative dispute resolution scheme once you have received our final response or eight weeks have passed since you first complained. Many mobile charges are billed by your mobile-network operator, whose own complaints procedure and ombudsman scheme (for example, a communications ombudsman) may apply; we will signpost you to the appropriate body where relevant. If your complaint relates to content or services regulated by an industry code, the relevant regulator’s complaints route may also be available.

Your legal rights

Nothing in this policy affects your statutory rights or your right to take legal action. The options above are intended to help resolve disputes efficiently and fairly without the need for court proceedings wherever possible.

Governing law & jurisdiction

This policy, and any complaint or dispute arising out of or in connection with it (including non-contractual disputes or claims), is governed by and construed in accordance with the laws of England and Wales. Subject to any different dispute-resolution provisions agreed in a specific contract between us, and to any mandatory rights you have as a consumer, the courts of the courts of England and Wales shall have exclusive jurisdiction to settle any such dispute. Where you are a consumer, you may also benefit from the mandatory protections and jurisdictional rights available under the law of your country of residence.

Contact

To raise a complaint, or for any question about this policy, please contact our Complaints Team at complaints@centili.co.uk. You can also write to us at:

Centili Group Ltd.
[Registered office address — to be confirmed], United Kingdom

Centili Group Ltd. is registered in England and Wales (company number [Company number — to be confirmed]). For data-protection matters you may also contact our Data Protection Officer at dpo@centili.co.uk, and for general legal queries our legal team at legal@centili.co.uk.