The purpose of this document is to establish the manner in which SEEDBLINK SA handles client complaints. This document is publicly available on the SeedBlink website and can also be provided, upon request, free of charge, in a printed or electronic format.
This document is mandatory within SEEDBLINK SA for all departments involved in client relations.
4.1.Definitions of terms
Term
Definition and/or, if applicable, the act defining the term
Crowdfunding Service
the connection of investors interested in providing financing for businesses with project owners through the use of a crowdfunding platform, a service consisting of any of the following activities: (i) facilitating the granting of loans; (ii) placement, without a firm commitment, as provided in Annex I section A point 7 of Directive 2014/65/EU, of securities and instruments admitted for the purpose of crowdfunding issued by project owner or an investment vehicle, as well as the receipt and transmission of customer orders, as mentioned in point 1 of the aforementioned section, regarding these securities and instruments admitted for the purpose of crowdfunding; (Regulation (EU) 2020/1503)
Complaint
A statement of dissatisfaction addressed to the crowdfunding service provider by one of the clients regarding the crowdfunding services as defined in point 1. (Regulatory technical standards according to EU Regulation 2020/1503). In the context of this document, a complaint is understood as a statement made by any natural or legal person addressed to SeedBlink in relation to the provision of crowdfunding services mentioned in point 1.
5.1. GENERALITIES – Prerequisites for addressing complaints received from end customers
SEEDBLINK SA, as a crowdfunding service provider, has organized and conducts activities regarding the resolution (handling and management) of complaints received from customers, by establishing an internal system for collecting, recording, analyzing, determining measures, and resolving customer complaints regarding violations of their rights, ensuring the correct application of legal provisions, including written communication to them, within the legal deadlines, of the conclusion resulting from the analysis of the complaint.
For carrying out this activity, SEEDBLINK SA uses Romanian as its official language, and for handling complaints and petitions received from foreign complainants, English will be used or any language used in the key investment information sheet, mentioned in Articles 23 and 24 of Regulation (EU) 2020/1503 or advertising communications mentioned in Article 27 paragraph (1) of the respective regulation.
5.2. Filing complaints
Any natural or legal person, customer of SEEDBLINK SA or their legal representatives, who believe that their rights and interests (mentioned in the law or in the Investment Facilitation Agreement) have been violated in any way, can address the company for clarification of the cause leading to such a petition.
Petitions can be filed in Romanian or English or in any language used in the key investment information sheet, mentioned in Articles 23 and 24 of Regulation (EU) 2020/1503or advertising communications mentioned in Article 27 paragraph (1) of the respective regulation, using the standard form (according to Annex 1). To be accepted, complaints must meet the acceptance criteria.
Methods of filing complaints:
5.3. Structure of complaints
The complaints filed must contain at least the following elements to be taken into consideration and analyzed:
• First and last name;
• Complainant's contact details (address, phone number, email);
• The subject of the complaint, including full reference to the investment and/or agreement to which the complaint refers (e.g. project owner/company and/or crowdfunding project, other relevant transaction references)
• Documentation supporting the mentioned facts.
• Date of the event generating the complaint.
• Description of the damage or loss caused (if relevant).
Other comments or relevant information (if applicable).
If the complaint is not formulated by the complainant, it must additionally contain the following information about the person making the petition:
• First and last name;
• Contact details (address, phone number, email);
• Status and interest in the case;
Anonymous complaints or those where the complainant's identification data (name, surname, address, contact details) or relevant data regarding the subject of the petition are not specified will not be taken into consideration and will be classified as lacking object.
Complaints sent are signed by hand or electronically, and in the case of electronically sent complaints that cannot be signed, SeedBlink may request confirmation of the correctness of the data transmitted electronically.
5.4. Recording complaints
Complaints sent by mail or submitted in person as well as complaints sent via email are assigned a registration number and date, and these will be highlighted in the Electronic Register.
5.5. Criteria for accepting complaints
For a complaint to be considered valid, it must contain all the necessary elements from section 4.3.
Also, when filing complaints, it is mandatory to specify in detail the subject of these, the steps taken by the complainant at the level of SeedBlink, if applicable, the information available to support the statements, as well as the attachment of conclusive evidence, to the extent they hold it.
In the situation where the complaint does not meet the admissibility conditions, the complainant will receive a clear explanation of the reasons for rejecting the complaint as inadmissible.
5.6. Handling complaints
After accepting complaints, the process of handling them will consider the following stages:
In the situation where the aspects noted by the complaint require a more detailed investigation, the complainant will be informed about the causes of the delay and about the extension of the deadline in which the decision regarding the complaint will be communicated to him. The communicated term cannot exceed by more than 15 days the term of 30 days from the registration of the petition.
5.7. Response to complaints
The transmission of responses to complainants will be carried out within the deadlines established above, from the date of registration of the complaint, regardless of whether these are favorable or unfavorable. In the case of rejected complaints (unfavorable), the reason for the complaint's rejection will be included in the response.
In the event that a decision is issued that does not satisfy or partially satisfies the complainant's request, the decision will include an explanation of the reasons underlying this outcome, as well as information regarding the possibility of contesting the decision, namely filing a complaint with ASF (Financial Supervisory Authority) / legal action.
SeedBlink will use the same language in communications as the one used by the customer in the complaint.
SeedBlink S.A. is registered in the Register of the Romanian Financial Supervisory Authority (ASF), under number PJR28FSFPR/400001, as of 03.11.2022 with an EU passport as per European Securities and Market Authority (ESMA) register of crowdfunding services providers.
Investing in start-ups involves risks, including loss of capital, illiquidity, dilution, lack of dividends. It is suitable only for investors capable of evaluating and bearing those risks. In any event, it should be done only as part of a diversified portfolio (meaning a portfolio in which investment in start-ups represents only a fraction of the total investments or assets). Before investing please read the risk warnings available at https://seedblink.com/generalterms as well as the risks related provisions of the investment facilitation agreement that will be provided to you for the relevant round.SeedBlink is not responsible for any information provided by the start-ups, even if distributed through or by SeedBlink. SeedBlink does not endorse any start-up for investment nor does it advise you on the merits of your investment. Seedblink does not provide to you any other advisory services. The decision to invest is yours only. If you require help in evaluating a decision to invest, you should consult a professional adviser.The messages and documentation you receive from SeedBlink or the start-ups have been neither verified nor approved by the Romanian or the European authorities. Nothing in this message shall be considered an offer to sell, or a solicitation of an offer to buy, any security to any person in any jurisdiction to whom or in which such offer, solicitation or sale is unlawful.
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