Complaints Handling Policy

1. Our commitment

Circlworld is committed to providing a high-quality service to all members. We take complaints seriously and treat them as an opportunity to improve our platform and our relationships.

This Complaints Handling Policy explains:

What constitutes a complaint
How to raise a complaint with Circlworld
How we handle and investigate complaints
The timelines you can expect
Your rights to escalate if our response does not satisfy you

This Policy applies to all members of the Circlworld platform, treasurer partners enrolled in the Community Growth Program, and (where relevant) third parties who interact with us.

2. The Circlworld entity handling your complaint

The Circlworld entity that handles your complaint depends on your country of residence:

Jamaican residents and members in countries other than the United Kingdom: Circlworld Technology Limited (Jamaica) handles your complaint. Address: [to be inserted at incorporation]
United Kingdom residents: Circlworld Technology Ltd (England and Wales) handles your complaint. Address: [to be inserted at incorporation]

3. What is a complaint?

A complaint is any expression of dissatisfaction about a Circlworld product, service, or staff member that requires a response. This includes (but is not limited to):

Concerns about service quality or availability
Disputes about fees, charges, or earnings calculations
Concerns about how we have handled your personal data
Disagreement with a decision we have made (account suspension, KYC rejection, Programme decisions)
Concerns about how we have handled a previous complaint
Concerns about the conduct of a member or treasurer (where Circlworld's intervention is appropriate)

A complaint is distinct from a general enquiry (a question about how something works), which we handle through our support channels.

A complaint is also distinct from a circle-internal dispute (a disagreement between members of a circle, such as a contested contribution), which we handle through our dispute resolution mechanism within the platform.

4. How to raise a complaint

You can raise a complaint through any of the following channels.

4.1 Online (preferred)

Submit a complaint at circlworld.com/complaints — a structured form that collects the information we need to investigate efficiently.

The form asks for:

Your name and account email
The nature of your complaint
When the issue occurred
Any supporting evidence
What outcome you are seeking

4.2 By email

Email complaints@circlworld.com.

Please include:

Your name and account email
A clear description of the issue
Any reference numbers, dates, or supporting evidence

4.3 By post

Send written complaints to the relevant Circlworld entity:

Circlworld Technology Limited (Jamaica) [Address to be inserted at incorporation]

Circlworld Technology Ltd (England and Wales) [Address to be inserted at incorporation]

4.4 Through your dashboard

Logged-in members can raise complaints through Settings → Support → Raise a Complaint.

5. What happens when you raise a complaint

5.1 Acknowledgment

We acknowledge every complaint within 5 business days of receipt. The acknowledgment will:

Confirm we have received your complaint
Provide a reference number for tracking
Identify the complaints handler responsible for your case
Estimate when you can expect a substantive response

If we need any clarification or additional information before we can investigate, we will ask for it in the acknowledgment.

5.2 Investigation

A trained complaints handler investigates your complaint. The investigation may include:

Reviewing your account activity and audit log
Reviewing relevant policies and decisions
Speaking with relevant Circlworld staff
Reviewing supporting evidence you have provided
(Where applicable) speaking with other parties involved

We investigate fairly and impartially. The complaints handler is not the same person who made the original decision you are complaining about.

5.3 Substantive response

We aim to provide a substantive response to your complaint within 20 business days of receipt.

The response will:

Set out our understanding of your complaint
Describe the investigation we conducted
Explain our findings
Explain the outcome and any actions we will take
Inform you of your rights to escalate if you remain dissatisfied

5.4 Complex cases

Some complaints require more time to investigate (for example, where multiple parties are involved, or where regulatory considerations apply). In these cases:

We will tell you within 20 business days that we need additional time
We will explain why
We will give you a revised estimated response date
We will not exceed 40 business days without a final response, except in genuinely exceptional circumstances

6. Possible outcomes

Following our investigation, possible outcomes include:

Upheld — we agree with your complaint and will take corrective action
Partially upheld — we agree with part of your complaint and will take corrective action on that part
Not upheld — we have considered your complaint but do not agree with it; we will explain why
Outside our remit — your complaint relates to something Circlworld cannot address; we will explain why and refer you to the appropriate venue

Where a complaint is upheld, corrective action may include:

Refunds or fee adjustments
Reversal of decisions (account restoration, Programme reinstatement, etc.)
Apology and explanation
Process improvements to prevent recurrence
(Where applicable) compensation for direct loss caused by our error

7. Your right to escalate

If our response does not satisfy you, you have rights to escalate.

7.1 Internal escalation

You may request an internal review by a senior member of Circlworld. The request should be made within 30 days of receiving our substantive response and explain why our response did not satisfy you.

Internal review:

Is conducted by a different, more senior person than the original complaints handler
Provides a written response within 20 business days
Is the final stage of our internal process

7.2 External escalation

If you remain dissatisfied after internal review (or if you wish to skip internal review), you may escalate to the relevant external authority.

Jamaica:

Consumer Affairs Commission (CAC) — for consumer protection matters. Website: www.cac.gov.jm
Office of the Information Commissioner (OIC) — for data protection complaints. Website: www.oic.gov.jm
Fair Trading Commission (FTC) — for matters of unfair competition. Website: www.jftc.gov.jm

United Kingdom:

Information Commissioner's Office (ICO) — for data protection complaints. Website: www.ico.org.uk
Trading Standards — for consumer protection matters; contact via your local council
Competition and Markets Authority (CMA) — for matters of unfair competition. Website: www.gov.uk/cma
Citizens Advice — free guidance on consumer rights. Website: www.citizensadvice.org.uk

Other jurisdictions: We will identify the appropriate authority for your country in our final response.

External escalation is your right. Pursuing internal complaint resolution does not waive your right to external escalation, and we do not require you to exhaust internal options before escalating externally — though we encourage internal resolution first as the fastest path to a meaningful response.

8. Treasurer-specific complaints

Treasurer Partners enrolled in the Community Growth Program may have additional types of complaint, including:

Disputes about Activation Bonus qualification
Disputes about Residual calculations
Disputes about Identity Level assignment
Disputes about Community Health metric scoring
Disputes about Programme suspension or termination

These complaints follow the same process as other complaints but with the following additional considerations:

The Treasurer Partner Agreement (Clause 12) governs the substantive terms
Audit log evidence is consulted alongside other evidence
Disputed amounts may be held in abeyance pending resolution
Complainants may request review by a senior Circlworld staff member familiar with the Programme

9. Complaints about how a complaint was handled

If you believe we have not handled your original complaint properly, you may raise a complaint about the handling itself. This is a separate complaint that we will investigate independently.

The handling complaint follows the same process described above, but will not be investigated by anyone involved in the original complaint.

10. Confidentiality

We treat complaints confidentially:

Information you share with us in your complaint is shared only with those who need it to investigate
We do not publish complaint details
If we need to share information with other parties (for example, to investigate), we will tell you what will be shared and why
Complaint outcomes are recorded in our internal systems and used to improve our service, but identifying details are not published

11. Data protection

When you raise a complaint, we process personal data about you to investigate and respond. Our Privacy Notice explains how we handle this data. In summary:

We process the data on the basis of legitimate interests (responding to your complaint)
We retain complaint records for 6 years from resolution (UK) or 7 years (Jamaica), or longer where required by law
You retain your rights under the relevant data protection law

12. Complaints monitoring

We monitor complaints data to improve our service:

Categorisation by type, severity, and outcome
Root cause analysis for recurring issues
Reporting to senior management
(When applicable) reporting to regulators in our annual statements

We do not retaliate against complainants. Raising a complaint will not adversely affect your access to the Circlworld platform or your standing within the Community Growth Program.

13. Vulnerable complainants

Some complainants may need additional support to participate in the complaints process effectively — for example, due to disability, language barriers, age, or distressing life circumstances. We will:

Provide reasonable adjustments to make the process accessible
Accept complaints in other formats where the standard channels are difficult
Refer you to advocacy or support services where appropriate
Treat all complainants with respect and dignity

If you need additional support, please tell us when you raise your complaint.

14. Updates to this Policy

We update this Policy from time to time. Material changes are notified through our usual channels (email, in-app notification, and updates to this page). The current version is always available at circlworld.com/legal/complaints, with the date of last update shown at the top.

15. Contact

For any questions about this Policy or the complaints process:

Email: complaints@circlworld.com
Through the platform: Settings → Support → Raise a Complaint
Post: To the relevant Circlworld entity (see Section 2 above)

This Complaints Handling Policy is read together with our Terms of Service, Privacy Notice, and (for treasurer partners) the Treasurer Partner Agreement. Where there is any inconsistency, the substantive provisions of the relevant agreement govern.