Beschwerdeverfahren

Complaints procedure of Innovation Service Group s.r.o.

(valid from 1. 5. 2025)

I. General provisions

1. This Complaints Procedure regulates the procedure for submitting and handling client complaints and claims with Innovation Service Group sro (hereinafter referred to as the „Company“) in accordance with:

o with Act No. 634/1992 Coll., on Consumer Protection,

o with Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 (MiCA Markets in Crypto-Assets Regulation),

o ESMA’s rules on complaints in the field of crypto assets ,

o other valid and effective legal regulations that regulate the company’s activities, e.g. Act No. 253/2008 Coll. on certain measures against the legalization of proceeds from crime and the fight against terrorism.

2. The company’s services are provided through verified external P2P platforms (e.g. Binance, Bybit, OKX). The company’s website (https://is-group.cz/) is used only for communication with clients, for providing information, for filing claims or complaints, and not for directly providing crypto-asset exchange services.

II. Basic rules for filing complaints and claims

1. Charging for complaints and claims

1.1 All complaints and claims are handled free of charge. You may only be charged for the cost of sending the postal item if you decide to communicate with our company by post.

2. Language of communication

2.1 The complaint and claim can be filed in Czech, Slovak or English, at your choice, and subsequent communication for the purpose of investigating the complaint and/or claim can take place in Czech or English, at your choice.

2.2 If the company has used another language to market its services or communicate with clients, you are guaranteed the right to receive and handle complaints or claims in this other language as well.

2.3 We will try to conduct any communication with you using simple and easy-to-understand language so that our message can be understood by every average consumer.

III. Filing a complaint and claim

1. When to file a complaint or claim?

1.1. Use complaints and claims when our services have not met your expectations. A complaint is when we can no longer remedy the situation in your favor because it has already happened and cannot be undone (e.g. you feel that we have not been polite to you), while with a claim you expect that we can still remedy the situation and thus exercise your rights (e.g. a refund).

2. Methods of administration

2.1. You can file a complaint or claim:

● By email:[email protected],

● In writing: Záhřebská 562/41, 120 00 Prague 2,

● Online form, which is available on our website:

https://is-group.cz/feedback/ .

2.2. If you express your dissatisfaction to us by phone or otherwise (e.g. during mutual communication in the chat), unfortunately this is not a complaint or claim, because we must have the content of your submission properly registered and must therefore accept it in one of the above-mentioned ways.

3. Complaint/claim details

3.1. The complaint/claim must contain:

● Your full name and surname,

● Your contact details of your choice, depending on how you wish to be notified of the result: if in writing, then your full address, if by email, your full email address and if by phone, your phone number,

● if the complaint/claim is filed through a legal representative, then also the business name (name) and contact details,

● date of the problem,

● a clear description of the violation of your rights or interests,

● in the case of a complaint, a specific request for redress,

● all relevant documents (e.g. transaction receipts, screenshots of communication).

3.2. A submission that does not contain the above information and/or supporting documents cannot be accepted as a complaint or claim, especially if it is not possible to identify the client who filed the complaint or claim and/or if the content of the complaint or claim is incomprehensible.

3.3. If possible, the company will nevertheless ask the client to complete the missing information in accordance with the rules set out in Article IV. Paragraph 2.

3.4. We do not accept a complaint and/or claim if the matter involved:

● proceedings have been initiated before a court, financial arbitrator or other out-of-court dispute resolution body;

● the matter has already been finally decided by the competent authority;

● the limitation period under generally binding legal regulations has already expired.

IV. Complaint handling

1. Confirmation of receipt

1.1 All clients are informed immediately of the receipt of their complaint or claim, but no later than 5 working days from its delivery, in the manner they choose or, if applicable, in the form they used to submit the complaint or claim (by email, in writing, or otherwise – e.g. by data mailbox).

1.2 The acknowledgement of receipt of the complaint or claim must contain:

● identification and contact details (including email address and telephone number) of the person responsible for handling the complaint or claim; you can contact this person with any questions you may have;

● date of receipt of the complaint or claim; if the complaint or claim was sent on a holiday (i.e. not a working day), the first following working day may be considered the date of receipt;

● a reference to the time frame (deadline) for handling complaints and claims specified in these Complaints Procedures (see paragraph 3 of this provision);

● in the case of electronic submission of a complaint or claim, a copy of it (i.e. usually a copy of your email or electronic form using which the complaint or claim was submitted).

2. Request for additional information or documents

2.1 If necessary to resolve the complaint or claim, we may ask you for additional information and supporting documents. In such a case, the deadline for resolving the complaint or claim is extended by the period during which the company did not have this necessary information or supporting documents available, which we will always inform you of in the request for supplementation.

2.2 We may ask you to supplement your complaint or claim, in particular if:

● your (client) or legal representative’s identification data is not complete (especially if a power of attorney authorizing them to act on your behalf as a client is not documented);

● some essential facts and circumstances relating to the subject of the complaint or claim are not clear (e.g. key documents relating to, for example, previous communication with the company are not provided).

2.3 The company does not request additional information or documents that it has or should have available.

2.4 If the client has been asked to supplement their complaint or claim and does not respond within 90 days, the case is closed due to the client’s lack of cooperation.

3. Response to your complaint or claim

3.1 You will receive a final response to your complaint or claim in the manner chosen by you or in the manner in which the complaint or claim was received (e.g. by email) without undue delay, usually within 30 calendar days of receipt of the complaint or claim. The time limit does not inсlude the time during which the company waited for the delivery of the necessary information or documents within the meaning of paragraph 2 of this provision.

3.2 If it is not possible to provide a final written response within the above-mentioned period, we will inform you as soon as possible, including the reason for the delay and the expected date of resolution of the complaint or claim. We will also inform you of any further steps and answer any questions you may have in this regard. However, we consider any internal corrective measures taken in response to your complaint or claim to be internal know-how and cannot inform you of them unless we decide otherwise in the given case.

3.3 The answer must inсlude:

● date of receipt of the complaint or claim;

● the results of the investigation, including a clear decision that responds to all factual objections raised in the complaint or claim and the reasons for the outcome of this decision, i.e. an explanation of whether the company confirms the complaint or claim in full, in part or, conversely, rejects it,

● in the event of a complaint, information about the corrective measure taken against you (the client), i.e., for example, recognition of withdrawal from the contract with a refund, discount on the services provided, etc.

3.4 In the event that the complaint has been rejected in whole or in part, the response also contains information about the possibility of contacting the court or the Financial Arbitrator.

3.5 Given that the company is obliged to comply with the legislation on the prevention of money laundering and the fight against terrorism, the company may, following the investigation of a complaint or claim, take appropriate measures in accordance with this legislation, without informing you (e.g. report a suspicious transaction to the Financial Analytical Office).

V. What to do if you were not satisfied with the handling of your complaint or claim

1. If you were not satisfied with the handling of a claim or complaint, please first of all keep in mind that only with a claim can you seek redress, while a complaint serves to point out an irregularity that cannot be remedied retroactively and can only be addressed internally for the future. Whether we take the appropriate remedial action is therefore primarily our internal matter.

2. However, if you are dissatisfied with the handling of your complaint, you can contact the following entities:

● Financial Arbiter (Legerova 69/1581, 110 00 Prague 1, finarbitr.cz), which, since February 15, 2025, is competent to resolve disputes otherwise falling within the jurisdiction of Czech courts between a consumer and a person providing services related to crypto-assets;

● the competent court, which is also competent to decide on the matter of the dispute;

● platform for resolving consumer disputes – resolving disputes arising from contracts concluded online (ec.europa.eu/consumers/odr) – only until 19. 7. 2025 (after which the platform will be closed);

● Czech National Bank (Na Příkopě 28, 115 03 Prague 1,www.cnb.cz), which is a public law supervisory authority and, in the event of a finding of misconduct on the part of the company, is entitled to impose a public law sanction on the company (however, it cannot decide on your private law claim).

VI. Rules for handling complaints and claims through P2P platforms

1. P2P platform complaints process

1.1 The company also offers the sale and purchase of cryptocurrencies to its clients through selected P2P platforms (e.g.: BINANCE, OKX, BYBIT), where you as a client had to register. These platforms inсlude user ratings and tools that allow you to file a complaint or claim and communicate with free support. If you decide to file a claim in this way, you must follow the rules of the individual P2P platforms, for whose operation the company is not responsible.

1.2 Because theThe complaint process on P2P platforms is governed by their own rules, this section serves as an informative overview of the typical procedures used to resolve complaints or other cases of client dissatisfaction. However, when investigating client complaints and claims, the company must base its investigation on information and documents relating to the course of investigation of the complaint or claim on the P2P platform (if it was filed there).

2. The most commonly used methods of redress within the complaints process of P2P platforms

2.1 Buyer complaints:

2.2 Seller complaints

3. Rules and procedures for the complaints process of P2P platforms

3.1 To resolve your requests, it is usually necessary to provide screenshots of communication, payment confirmations, and other documents related to the transaction.

3.2 You can usually expect confirmation of receipt of your complaint or claim within 24 hours and a response within 5 working days, or in complex cases within 14 calendar days.

3.3 All requests are handled free of charge and the costs of any return are borne by the party that committed the error.

3.4 Please note that your account may also be blocked, for example in the event of inappropriate behavior or reasonable suspicion of fraud on your part.

VII. Final provisions

1. This Complaints Procedure isas amendedpermanently posted on https://is-group.cz/feedback-order

2. The Company is entitled to updаte the Complaints Procedure, in particular with regard to changes in legal regulations. Clients will be notified of the changes by e-mail at least 2 months in advance.

Approved by:

Rafael Nersesian, executive

Innovation Service Group sro

Date: 28. 4. 2025

[1] Draft regulatory technical standards on procedures for handling complaints by crypto-asset service providers pursuant to Article 71(5) of Regulation (EU) 2023/1114 (MiCA) – following the adoption of this Draft, the final approved text of these technical standards.