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Haavarot Mehirot Ltd.
Complaint Policy

  1. COMPLAINT SUBMISSION
  2. The Complaint shall include the following information:
    1.1. For natural persons – name, surname, birth date, contact details (e-mail and / or telephone number).
    1.2. For legal persons – name of the entity, registered code, registered address, contact details (e-mail and telephone number);
    1.3. Dispute matter – Clear description of the circumstances which led to the Complaint, including dates and times.
  3. The Applicant is responsible for certainty (i.e. correctness) of the personal and contact data provided in the Complaint and agrees that the Company will present all the information related to the Complaint handling process by using contact details provided in the Complaint. For the sake of clarity, if the Applicant specifies his email address, the Company has the right to provide information and further communication by e-mail.
  4. The Complaint shall be submitted in Hebrew or English and shall be duly signed by the Applicant or authorized representative.
  5. When a Complaint is submitted by a representative, the Complaint must provide identity and authorisation documentation for said representative.
  6. The Complaint shall be submitted via: registered mail, sent to: Ehad Haam 9, Tel Aviv, Israel; or email: support@fastpay.co.il.
  7. The filling of and processing of all Complaints shall be free of charge.
  8. The Company may refuse to investigate:
    7.1. A complaint that fails to comply with the procedures and rules set herein.
    7.2. A complaint regarding the same circumstances or grounds as a Complaint that was previously submitted by the same Applicant and was resolved by the Company
    7.3. The client will be informed of any such refusal within 7 business days after receipt thereof by the Company.
  9. RECEIPT AND REGISTRATION
    1.1. All Complaints, which are received in the manner set out in these Rules, shall be recorded in the Complaints registration journal of the Company. The Complaints shall be registered on their receipt date or the first following business day if the complaint was submitted on a non-business day/after working hours.
    1.2. Initial registration of the Complaint shall be made by the employee of the Company who has received/accepted the complaint. Afterwards the complaints log shall be supplemented by the employee assigned responsible for handling the complaint and preparation of the reply to the client.
    1.3. The Complaints journal shall include the following:
    1.3.1. Complaint number;
    1.3.2. Category of Complaint;
    1.3.3. Date Received;
    1.3.4. Received From;
    1.3.5. Client;
    1.3.6. Receipt Acknowledged (Yes/No + Date);
    1.3.7. Name of Investigator;
    1.3.8. Justified/Upheld (Yes/No)
    1.3.9. Outcome Advised (Date)
    1.3.10. Process time
    1.3.11. Compensation (Yes/No + Amount)
    1.3.12. Actions Completed (Yes/No)
    1.3.13. Closed Out Date
    1.4. Within 24 hours of registration, the Company shall confirm receipt of the Complaint to the Applicant and advise the Applicant when they can expect a response.
  10. INVESTIGATION AND DECISION
  11. Each step of the investigation process of Complaint shall be duly documented.
  12. The Complaints shall be investigated by the Customer Support Department of the Company. A Customer Support Department representative may ask for co-operation of other structural units of the Company as needed. The Customer Support Department is entitled to take a final decision at its own discretion. The Customer Support Department shall ask for management confirmation of the decision regarding Complaint only in case the Complaint:
    2.1. contains a claim of over €1000 (or equivalent);
    2.2. alleges fraud, AML/CFT gross negligence by the Company;
    2.3. poses a material reputational risk to the Company;
    2.4. alleges breach of information security or privacy laws.
  13. In case the submitted Complaint lacks information needed for the investigation, the Company has the right to ask the Applicant to specify further details relating to the essence of the Complaint or provide additional documents or data. In such cases the Company shall sets a reasonable time limit, no shorter than 7 calendar days, for provision of requested information or documentation. If the Applicant provides such information or documentation within the set deadline, the Complaint is deemed to have been received on the date when the specified information or documentation were provided to the Company.
  14. The Complaint shall be investigated and a response is provided as soon as possible, but not later than within 15 calendar days from the date of receipt of the Complaint from the Applicant. Exceptionally, when the Complaint cannot be investigated within the term set in this provision, the Company must so inform the Applicant and specify the circumstances and the new term within which the Complaint will be investigated and a response provided, not to exceed 35 days.
  15. The Company shall investigate the Complaint in accordance with the relevant laws and makes one of the following decisions:
    5.1. to accept the Complaint and satisfy the request of the Applicant;
    5.2. to fully or partially satisfy the request of the Applicant without accepting the Complaint;
    5.3. to reject the Complaint.
  16. The decision of the Company regarding the Complaint shall be recorded in the Complaints registration journal and sent to the Applicant via registered mail and/or e-mail.
  17. When the Complaint is rejected or only partially satisfied, the Company in its response to the Applicant shall specify reasons for the rejection or failure to fully satisfy the Complaint and, if the Applicant is a natural person and shall be considered as a consumer, the right of the Applicant to file a complaint to the Israeli regulatory authorities.
  18. FINAL PROVISIONS
  19. The Policy must be reviewed at least annually. Any modifications and amendments to the Policy shall be made in writing and become effective once approved by a management resolution.
  20. The Customer Support Department shall prepare and submit quarterly reports to the management of the Company, describing the main issues in the process of handling the Complaints and proposing any recommended measures for enhancement.
  21. The Company in order to determine shortcomings of its activities and potential legal or operational risk constantly assesses the Complaints’ investigation results. By performing this assessment the Company:
    3.1. collects information on similar Complaints related to certain services or products, performs an analysis of this information in order to identify the main reasons of these Complaints, also to determine priorities for the elimination of these reasons;
    3.2. assesses whether essential reasons of certain Complaints might lead to new Complaints regarding other services or products;
    3.3. assesses whether essential reasons of certain Complaints might be eliminated and determines methods of their elimination;
    3.4. eliminates main determined reasons of Complaints, if needed;
    3.5. assures that the repetitive or systemic reasons of Complaints would be regularly communicated to the Managing Director of the Company and that the Managing Director could effectively perform its functions and ensure that similar Complaints would not occur.
  22. The Company’s Customer Support Department is responsible for the proper implementation of this Policy. The representative of this Department shall monitor and ensure that the Company‘s complaints handling process is efficient and, if necessary, update it, also ensure that any shortcomings shall be remedied. Breaches of the Policy must be reported to the Managing Director as soon as possible.
  23. The Rules, including its amendments, comes into force from the day of their approval. The employees of the Company must comply with the Rules from the moment the employee is introduced to the Rules. Employees are introduced to the Rules in writing and must follow their requirements properly.
  24. The Company must submit to the Regulatory body of Israel within by electronic means, information regarding complaints received during the year as prescribed by law.
  25. Representative of Customer Support Department is responsible for reporting to the Regulatory body of Israel.
  26. The Company must store information about the number of complaints received, classified by the reasons of complaint and examination results (number of the complaints received, examined, satisfied, and partially satisfied) and submit such information as proscribed by law upon request.
  27. The Company stores the Complaints, data related to the investigation, documents which provide a particular result of the investigation and response provided to the Applicant at least 7 years from the date of providing the final response to the Applicant. All information and documents are stored in the manner set by the Israeli law.
  28. The Company shall publish information regarding these Complaint procedures and information about the Financial Ombudsman Service on its website.