Holyheld Complaints Handling Policy

Last Update: 27.11.2025

This Summary provides a clear and comprehensive overview of the Complaints Handling framework of UAB Holyheld Financial (the “Company”). The Company is dedicated to delivering services and products of exceptional quality. Company’s goal is to ensure that every Client receives value, reliability, and a consistently positive experience. Continuous improvement is central to the operations, and Clients’ feedback plays an essential role in helping the Company achieve this.

Should the Clients feel dissatisfied or believe that something has not met their expectations, the Company encourages Clients to submit a complaint. Every complaint is taken seriously, handled with care, and addressed as promptly and fairly as possible.

1. Purpose and Regulatory Alignment

1.1. The Company ensures that all Complaints are handled fairly, promptly, diligently, transparently, impartially, and in accordance with EU and Lithuanian law. The Complaints Handling framework aims to:

  • 1.1.1. protect Client rights;
  • 1.1.2. identify and remediate service, process, or control deficiencies;
  • 1.1.3. ensure consistent and high‑quality service standards;
  • 1.1.4. comply with all supervisory and regulatory obligations;
  • 1.1.5. contribute to continuous operational and governance improvement.

1.2. The Complaints Handling framework applies to all Complaints received from eligible Complainants as set out below.

2. Eligible Complaints

2.1. A Complaint may be submitted by:

  • 2.1.1. any natural or legal person directly affected by the Company services;
  • 2.1.2. any Client or potential Client;
  • 2.1.3. any person to whom the Company owes a duty of care;
  • 2.1.4. any duly authorised legal representative acting on behalf of a Complainant.

2.2. Complaints from non‑clients are accepted, acknowledged, and responded to, even if the matter lies outside the Company’s direct control.

3. How to Submit a Complaint

3.1. Complaints may be submitted free of charge via:

  • 3.1.1. Email: support@holyheld.com;
  • 3.1.2. In‑app submission;
  • 3.1.3. Postal mail to the Company’s registered office, available up-to-date on the Company’s website;
  • 3.1.4. Other communication channels (e.g., social media, chat) — these will be formalised internally by the Company.

3.2. Complaints may be submitted in:

  • 3.2.1. English or Lithuanian (i.e. languages used by the Company to market or communicate its services);
  • 3.2.2. any official EU language.

3.3. All the communication with the Complainant will be conducted in English or Lithuanian languages (i.e. languages used by the Company for marketing and communication, list of which may be amended from time to time upon discretion of the Company). Company will communicate with Complainants in clear and plain language that is easily understandable, in writing by electronic means or, upon the Complainant’s request, in paper form.

3.4. Use of the standard Complaint Form, available here is encouraged but optional.

3.5. For the Company to be able to address the Complaint efficiently, to raise the Complaint the Company asks to provide at least the following details:

  • 3.5.1. full name and surname or legal entity details of Complainant (or representative of the Complainant), Client reference (if available);
  • 3.5.2. contact information (phone number and email address);
  • 3.5.3. description of the issue;
  • 3.5.4. relevant dates;
  • 3.5.5. supporting evidence (optional);
  • 3.5.6. service or transaction affected;
  • 3.5.7. other important circumstances related to the Complaint.

4. Acknowledgement of Receipt

4.1. The Company acknowledges all Complaints within 2 business days, providing:

  • 4.1.1. a unique Complaint ID;
  • 4.1.2. contact details of the responsible case handler;
  • 4.1.3. the date the Complaint was received;
  • 4.1.4. applicable Complaint‑handling timelines;
  • 4.1.5. confirmation that handling is free of charge;
  • 4.1.6. a copy of the Complaint if submitted electronically;
  • 4.1.7. reference to the location on Company’s website of summary details of Company’s Complaints Handling framework.

4.2. If a Complaint is inadmissible, the Company communicates clear reasons for the decision.

5. Complaint Investigation

5.1. Investigations follow a structured and transparent process:

  • 5.1.1. classification of the Complaint into defined categories;
  • 5.1.2. request for additional information where necessary;
  • 5.1.3. factual analysis and review of relevant evidence;
  • 5.1.4. cross‑departmental cooperation if the Complaint relates to AML, ICT, data protection, or conduct matters;
  • 5.1.5. escalation based on severity, risk, or regulatory implications.

6. Complaint Resolution and Timelines

6.1. The Company provides a final written response within:

  • 6.1.1. 15 business days;
  • 6.1.2. If delayed due to exceptional circumstances, an interim reply will be issued, specifying the reasons for the delay and indicating that final response will be provided within 35 business days.

6.2. Final responses:

  • 6.2.1. The final response will address all points raised in the Complaint and will provide a clear explanation supported by evidence, outline any corrective action or redress measures. The Company will aim to ensure consistency with previous determinations unless deviation is justified. The response will also explain escalation options to supervisory authorities.

6.3. Outcomes of the Complaint resolution may include:

  • 6.3.1. Upheld;
  • 6.3.2. Partially upheld;
  • 6.3.3. Rejected.

6.4. Examples of redress may include issue remediation, technical assistance, fee corrections, or other appropriate measures.

7. Escalation to Supervisory Authorities

7.1. Complainants dissatisfied with the Company’s final response may escalate their Complaint to:

7.2. Bank of Lithuania

  • 7.2.1. Must be submitted within 1 year of receiving the Company’s final response;
  • 7.2.2. in Lithuanian or English language;
  • 7.2.3. via Electronic Government Gateway (applicable for citizens and residents of Republic of Lithuania) or by filling in the application form as specified in the website of the Bank of Lithuania and sending it in writing or by reaching out to Legal and Licensing Department at the Bank of Lithuania at Totorių g. 4, LT-01121 Vilnius, Lithuania, or via email: info@lb.lt.

7.3. State Consumer Rights Protection Authority (SCRPA)

  • 7.3.1. For consumer‑related matters;
  • 7.3.2. in Lithuanian or English language;
  • 7.3.3. electronically via the VTIS system (www.vtis.lt) by logging in via the e-Government Gateway. Alternatively, complaints can be submitted by completing and sending signed request form (available at https://vvtat.lrv.lt/en/how-to-submit-a-request/) together with supporting documents to the SCRPA by post (A. Goštauto str. 12, 01108 Vilnius, Lithuania) or by email (tarnyba@vvtat.lt).

7.4. The Company’s final response includes detailed instructions, links, and contact details required to file escalations.

7.5. Escalation does not prejudice the Complainant’s right to pursue other legal remedies.

8. Complaints Register & Record‑Keeping

8.1. The Company maintains a secure, auditable Complaints Register that includes:

  • 8.1.1. Complainant’s name and contact details;
  • 8.1.2. method and date of receipt;
  • 8.1.3. description and classification of the Complaint;
  • 8.1.4. product or service involved;
  • 8.1.5. investigation timeline and actions taken;
  • 8.1.6. final decision and redress provided (if any);
  • 8.1.7. date of final response;
  • 8.1.8. retention of supporting documents.

8.2. Records are retained for at least 5 years from the date of submission of the final answer to the Complainant.

9. Monitoring, Analysis, and Continuous Improvement

9.1. The Company continuously analyses Complaint-handling data by monitoring processing times, timeline breaches, Complaint volumes and trends, systemic or recurring issues, root causes, and the consistency of outcomes. Correction and enhancement will be put into system, products and / or operational procedures aiming to prevent future errors and increase Clients’ satisfaction with Company’s services.

10. Other

10.1. In case any questions arise, the Complainants can always contact the Company via email: support@holyheld.com or by raising the support ticket in-app.