Complaint Policy
Complaints Policy
Version 1.0 – Effective Date: October 15, 2025
1. Purpose
This policy establishes a corporate system for the structured and efficient management of complaints, enabling users, employees, suppliers, and third parties to submit concerns or grievances in a simple, secure, free, and retaliation-free manner; receive fair, transparent responses; and reduce reputational, regulatory, and financial risks.
2. Scope
This policy applies to all persons or entities interacting with Seacrets who wish to submit a formal complaint related to services, content, internal processes, or staff conduct.
Covered Groups
- External users: Creators, Fans, affiliates, advertisers, and any registered account holder.
- Internal collaborators: Employees, contractors, moderators, trainees, volunteers.
- Third parties: Service providers, regulatory bodies, accreditation entities, civil society organizations.
Covered Topics
- Transactions and payments
- Content and moderation
- Privacy and data protection
- Information security
- Customer support and service
- Fraud or suspected illegal conduct
- Violations of internal policies
- Improper conduct by Seacrets personnel
3. Key Definitions
| Term | Description |
|---|---|
| Complaint | A formal expression of dissatisfaction requiring an official response. |
| Financial claim | Complaint linked to chargebacks, refunds, or economic disputes. |
| Compliance report | Communication about potential violations of law or policy. |
| Appeal | A request for review when not satisfied with the initial resolution. |
4. Guiding Principles
| No. | Principle | Application |
|---|---|---|
| 1 | Accessibility | 24/7 complaint submission through Support Center. |
| 2 | Transparency | Automatic confirmation and case tracking. |
| 3 | Impartiality | Objective investigation by independent analysts. |
| 4 | Confidentiality | All complaints treated as confidential. |
| 5 | Effectiveness | Compliance with SLAs and KPIs. |
Complaint Submission Channels and Response Timeframes
Users may submit complaints or report content through any of the following channels:
1. The in-platform reporting tools, including the “Report” button available on content, profiles, or messages; or
2. By contacting our support center via email at [email protected].
All complaints received through any channel are logged, assigned a case ID, and incorporated into the operational handling flow defined in Section 6.
The Platform commits to acknowledging, reviewing, and resolving complaints within a maximum timeframe of five (5) business days from receipt, unless extended due to legal, regulatory, or card network obligations, or as required in collaboration with law enforcement or government authorities.
5. Roles and Responsibilities (RACI)
| Activity | Customer Care | Trust & Safety | Fraud & Disputes | Legal & Compliance | MLRO | Board |
|---|---|---|---|---|---|---|
| Reception & registration | A/R | I | I | I | I | I |
| Classification & priority | R | A | C | C | I | I |
| Investigation (content) | I | A/R | I | C | I | I |
| Investigation (financial) | I | I | A/R | C | C | I |
| Initial resolution | A/R | C | C | C | I | I |
| Appeals | C | A | C | A/R | C | I |
| Quarterly reporting | R | C | C | A/R | I | A |
6. Operational Flow (PDCA – ISO 37301)
- Plan: Define category matrix and escalation flows.
- Do: Automatic registration and acknowledgment (≤ 48h).
- Check: Investigation (≤ 2 business days).
- Act: Resolution (≤ 5 business days).
- Appeal: Independent review (≤ 5 business days).
- Closure: Satisfaction survey and lessons learned.
7. Severity Classification
| Level | Criteria | Example | Max Resolution Time |
|---|---|---|---|
| Critical (Red) | High legal risk, CSAM, minors, legal threats | CSAM report | 48 hours |
| High (Amber) | Loss > USD 1,000, confidential data breach, PEP | Withheld funds | 2 days |
| Medium (Green) | Payment disputes, offensive content | Friendly fraud | 5 days |
| Low (Blue) | Minor UX issues | Page layout error | 15 days |
8. Integration with Other Policies
| Topic | Linked Policy | Associated Action |
|---|---|---|
| Chargebacks | Chargeback Policy | Referral to Fraud & Disputes |
| CSAM | KYC & Safety Policy | Escalation to Trust & Safety |
| Non-consensual content | CNC Policy | Evidence handling |
| AML/CFT | AML/CFT Policy | Escalation to MLRO |
| Privacy | Privacy Policy | DPO handling |
9. Confidential Whistleblowing Channels
Secure and confidential reporting via the online portal without retaliation.
10. Recordkeeping, Retention, and Traceability
- Minimum retention: 5 years
- Critical cases: 7 years under legal hold
- All records auditable
11. Refunds
Refunds may be granted in specific situations such as duplicate charges, unauthorized transactions, or documented technical issues affecting the service.
12. Performance Indicators (KPIs / KRIs)
| Metric | Target | Alert Threshold |
|---|---|---|
| Resolution within SLA | ≥ 90% | < 80% |
| Post-complaint CSAT | ≥ 4/5 | < 3.5 |
| Case reopen rate | ≤ 5% | > 10% |
| Complaints per 1,000 transactions | Decreasing trend | > 15% increase |
| DSA Article 17 breaches | 0 | > 0 |
13. Training and Awareness
Training programs ensure compliance and standard performance.
14. Audit and Continuous Improvement
Internal and external audits ensure compliance with international standards.
15. Sanctions for Non-Compliance
| Actor | Violation | Consequence |
|---|---|---|
| Employee | Failure to register complaint | Disciplinary measures |
| User | System abuse | Warning or permanent ban |
| Supplier | Delay providing evidence | Contractual penalty |
16. Version History
| Version | Description | Date | Approved By |
|---|---|---|---|
| 0.9 – Draft | Internal circulation | 01-01-2025 | Legal Office |
| 1.0 – Initial Publication | Public release | 10-15-2025 | Board of Directors |
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