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. |
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
Non-refundable unless exceptions apply: duplicate charges, unauthorized transactions, or technical issues.
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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