Complaints Handling Policy EU

This document is reviewed at least once every 12 months under the Compliance Monitoring Program.

Complaints Handling Policy EU

LA ORANGE CY LIMITED

Complaints Handling Policy

October 2025

Table of Contents
Document Review and Version Control 1
1. Introduction 3
2. Definition of a Complaint and Complainant 3
3. Submitting a Complaint or Inquiry 3
4. Complaints Handling Procedures 3
4.1. Investigation and Response 3
4.2. Client Cooperation 4
5. Final Outcome 4
5.1. Contact Details of the Financial Ombudsman of the Republic of Cyprus: 4
6. Complaint Form 4
7. Record Keeping 4
8. Confidentiality 5
APPENDIX 1 6
COMPLAINT FORM 6


Introduction

La Orange CY Limited operates under the tradename and domain ‘JETON’ (jeton.com). La Orange CY Limited is incorporated and registered under the laws of the Republic of Cyprus with registration number HE424897 and is authorized and regulated by Cyprus Central Bank (CBC) with license number 115.1.3.66. (hereafter the ‘Company’)

The purpose of this Complaints Policy (hereafter the “Policy”) is to establish and maintain effective, transparent, and fair procedures for the prompt handling of complaints received from clients, in accordance with the applicable Cyprus and EU regulatory framework.

This Policy has been developed in line with:

The Electronic Money Laws of 2012 to 2023;

The Payment Services Laws of 2018 to 2023 (transposing Directive (EU) 2015/2366 – PSD2); and

The relevant Directives and Guidelines issued by the Central Bank of Cyprus regarding the handling of customer complaints by Electronic Money and Payment Institutions.

The Company is committed to providing the highest level of service to its clients. However, it acknowledges that complaints may occasionally arise. This Policy ensures that any complaint is handled fairly, efficiently, and in a timely manner, with the aim of resolving issues and improving the quality of our services.

The Company maintains clear internal procedures for the receipt, investigation, and resolution of complaints, and keeps appropriate records of all complaints and actions taken.

Definition of a Complaint and Complainant

A complaint is a statement of dissatisfaction addressed to the Company by the complainant relating to the provision of the investment services provided by the Company. A complainant is a natural or legal person who is presumed to be eligible to have a complaint considered by the Company and who has already lodged a complaint.

Submitting a Complaint or Inquiry

If, after consulting with a member of the Company’s support team, you (the “client”) are unable to obtain a satisfactory response and explanation to your inquiry, we welcome you to escalate it by contacting our Compliance team at: complaintscy @ jeton . com

To formally submit a complaint, please include all relevant details and any supporting documentation using the attached Complaint Form (Appendix 1), and send it to complaintscy@jeton.com

For clarification purposes, the Company may not be able to accept your complaint via any other means/channels.

Complaints Handling Procedures

The Company is required to establish, implement, and maintain effective and transparent procedures for the prompt and reasonable handling of complaints or grievances received from its clients.

Upon receipt of a complaint the Company will acknowledge receipt within fifteen (15) business days.

Investigation and Response

Once a complaint is received, the Company will conduct a thorough investigation to determine the outcome. The Company aims to provide a final response within two (2) months of receipt. In certain circumstances, if additional time is required, the Company may contact to update the complainant on the status of the investigation and provide a revised timeframe for the final decision.

The final decision will include an explanation of the Company’s position and any remedial measures deemed necessary, where applicable. If the Company is unable to reach the complainant or if the complainant fails to provide required information in a timely manner, the complaint may be considered closed within three (3) months from the date of submission.

Client Cooperation

To ensure efficient processing, clients are requested to provide all relevant supporting documentation, such as emails, chat transcripts, and statements, as soon as possible. In some cases, a Company representative may contact the client by phone to clarify information or obtain additional details.

Final Outcome

If you are not satisfied with the Company’s final response, or if the Company has not replied to you within a reasonable timeframe, you may refer your complaint to the Financial Ombudsman of the Republic of Cyprus to seek mediation or possible compensation. Please note that you must first submit your complaint to the Company before contacting the Financial Ombudsman.

Your complaint to the Financial Ombudsman must be submitted within twelve (12) months from the date you initially submitted your complaint to the Company.

Further information as to the procedure a client needs to follow, can be found on https://financialombudsman.org.cy/en/. It should be noted that the Cyprus Securities and Exchange Commission has no restitution powers. Any disputes for which damages are claimed, should be submitted to the Financial Ombudsman of the Republic of Cyprus.

Contact Details of the Financial Ombudsman of the Republic of Cyprus:

Website: https://financialombudsman.org.cy/

Email: complaints@financialombudsman.gov.cy

Telephone: +35722848900

Fax: +35722660584, +35722660118

Complaint Form

In order to ensure the correct complaint details were collated the information found in the Complaint Form must be provided.

Template of the Complaint Form can be found herein as Appendix 1.

The Complaint form must include:

  1. Full name;
  2. Address;
  3. Contact details (telephone number and email);
  4. Payment account number and/or Card Account and Card number;
  5. Detailed description of the complaint (including date the incident occurred, if applicable information on affected transactions, and desired outcome); and
  6. Supporting evidence (e.g. screenshots, communication etc.).

Any complaint must be submitted as specified above, in writing, in English in a clear and comprehensible manner. No oral or handwritten complaints will be accepted.

Record Keeping

The Company shall maintain comprehensive records of all complaints or grievances received from clients, along with all related correspondence, documentation, and actions taken for their investigation and resolution.

Such records shall be retained for a minimum period of five (5) years, or for a longer period of up to seven (7) years, where requested by the Central Bank of Cyprus or another competent authority.

The Compliance Function is responsible for maintaining and safeguarding all complaint-related records and ensuring they are readily available for inspection by the competent authorities upon request.

The Management Body shall review, on a regular basis, the nature and frequency of complaints to identify potential recurring issues and ensure that appropriate corrective and preventive measures are implemented to mitigate the likelihood of recurrence.

Confidentiality

The Company shall ensure that all information relating to a complaint, including any personal data, documentation, or correspondence, is treated with the utmost confidentiality and handled in accordance with the applicable data protection legislation, including the EU General Data Protection Regulation (GDPR) and the Cyprus Data Protection Law.

Both the Company and the complainant are required to maintain strict confidentiality throughout the handling and investigation process. Information obtained during the investigation shall be used solely for the purpose of resolving the complaint.


APPENDIX 1
COMPLAINT FORM
A. Customer Information:


Name: Account Number:
Address: Telephone Number:


B. Brief Summary of the Complaint:

Please describe the product or service you are complaining about (description, evidence, amount, and suggested way to be solved):

● Please enclose any other relevant documentation that may help us to handle the complaint.
● Possible documentation to be provided (customer statement, correspondence with the Company as well as any other supporting documentation to be requested by the Compliance Officer which is relevant to the Customer’s complaint)




Date and place Customer Signature


For internal use only:
Complaint Received By: Date:
Acknowledgement sent to Customer: □ Yes - □ No
Informed Customer of initial action: □ Yes - □ No
Final response provided to Customer: □ Yes - □ No
Holding response provided to Customer: □ Yes - □ No - □ N/A
Signature of MLRO:
Date:

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© 2025 | www.jeton.com is owned and operated by LA Orange CY Limited (Gladstonos, 116 M. Kyprianou House, 3&4th Floor, 3032, Limassol, Cyprus.) LA Orange CY Limited trading as Jeton, is authorised by the Central Bank of Cyprus under the Electronic Money Law of 2012 and 2018 (Law 81(I)/2012) for distributing or redeeming electronic money (e-money), with Licence No: 115.1.3.66. LA Orange CY Limited has been incorporated in the Republic of Cyprus under the provisions of the Companies Law (Cap 113) with registration number HE 424807, with its registered office address at Gladstonos, 116 M. Kyprianou House, 3&4th Floor, 3032, Limassol, Cyprus. LA Orange Limited, trading as Jeton, is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 for distributing or redeeming electronic money (e-money) and providing certain payment services on behalf of an e-money institution, with FCA registration number 902088. Company Name: LA ORANGE LIMITED, LEI code: 8945009645M8PD0AD211, BIC Value: ORAGGB22 (Swift Code). LA Orange Limited is registered in England and Wales, Company Number 11535714, with its registered office address at The Shard Floor 24/25, 32 London Bridge Street, London, SE1 9SG, United Kingdom. The Jeton Card Account and Card are issued by Financial House Limited, which is authorised and regulated by the Financial Conduct Authority as an Electronic Money Institution under Firm Reference Number 902039.

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