1. Introduction and Scope

Digital Lamp sp. z o.o. (“Digital Lamp”, “we”, “us”, or “the Company”) is committed to the fair, transparent, and timely handling of any concerns or dissatisfaction expressed by our Clients (“Complaints”).

This Policy summarises the rules and procedures applied by Digital Lamp when receiving, examining, and responding to Complaints. It is published on our website for transparency and to inform Clients and counterparties of the standards we apply. The full internal Complaints-Handling Procedure (Version 3.0, dated 16 January 2026) is maintained as an internal document and is made available to competent authorities upon request.

A “Complaint” means any expression of dissatisfaction submitted by a Client of the Company in respect of the services provided by the Company. Complaints are received and examined free of charge.

2. Regulatory Framework

This Policy and the underlying Procedure have been adopted in line with applicable European Union and Polish requirements, including:

• Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), in particular Article 71(1) and Article 62(2)(l);
• relevant guidelines and technical standards issued by the European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA);
• applicable Polish law, including consumer-protection legislation and the rules issued by the Polish Financial Supervision Authority (KNF);
• general principles of good market conduct, fairness, and consumer protection.

3. Who Can File a Complaint

A Complaint may be submitted by any natural person or legal entity that is a Client of Digital Lamp, or by an authorised representative acting on the Client’s behalf. If the Complaint is submitted by a representative, a power-of-attorney document must be attached as proof of authorisation.

4. How to File a Complaint

Clients may file a Complaint through any of the following channels:

• Email: complaints@digitallamp.co
• Postal mail: Digital Lamp sp. z o.o., Koneser Building M, Plac Konesera 12, 03-736 Warsaw, Poland
• In person: at any unit of the Company that serves Clients, during regular business hours
• Electronic delivery: via the electronic delivery address of the Company, where available, in accordance with applicable Polish law

A standard Complaint template is available upon request and may also be published on our website. The use of the template is recommended but not mandatory.

5. Information to Include in a Complaint

To allow us to handle your Complaint efficiently, please include the following information:

• Client identification details (full name or business name, address, and any Client/account identifier known to you);
• contact details for our response (email and/or postal address; phone number if you would like us to call you);
• if filed by a representative — full identification of the representative and a power of attorney;
• the crypto-asset service to which the Complaint relates;
• a detailed description of the subject of the Complaint and the date(s) on which the relevant facts occurred;
• your specific request (what you would like the Company to do);
• any supporting evidence or documents (e.g. correspondence, transaction references, screenshots);
• the date and place of the Complaint, and your signature (where the Complaint is filed in writing).

6. Languages

Complaints may be filed in English, Polish, and in any other language that the Company uses to provide its crypto-asset services or to communicate with Clients. Our response will be issued in the language in which the Complaint was filed, in clear, plain, and easily understandable terms.

7. Acknowledgement of Receipt

Upon receipt of a Complaint, the Company acknowledges receipt without undue delay. The acknowledgement contains:

• a unique reference number assigned to the Complaint;
• the date of receipt;
• the contact details of the person or department handling the Complaint;
• an indication of when the Client will be notified of the decision;
• where the Complaint was submitted via an electronic form, a copy of the Complaint as recorded by the Company.

8. Investigation

Complaints are examined fairly, thoroughly, objectively, and in a timely manner, applying the relevant law and good-conduct standards. The Company seeks to gather and examine all relevant information and evidence, and may request additional information from the Client where the Complaint is unclear or incomplete. The Client has 14 calendar days to provide such additional information; otherwise, the Complaint will be examined on the basis of the information already in the Company’s possession.

The Company will keep the Client duly informed of any additional steps taken and will reply to reasonable information requests from the Client without undue delay.

9. Response Timelines

The Company will respond to the Complaint without undue delay, and within the following maximum timelines:

Where a Complaint is filed by an individual Client (consumer) and the Company fails to provide a response within the applicable deadline, the Complaint is deemed to have been resolved in accordance with the Client’s requests, in line with applicable Polish law.

10. Content of the Response

The response to a Complaint will be addressed only to the Client who filed it (or to the authorised representative, where applicable) and will contain:

• a unique Complaint reference number and the date of the response;
• the Company’s position on each issue raised, with reference to the relevant sections of the contract or terms of service;
• detailed factual and legal justification, unless the Complaint has been fully resolved in line with the Client’s requests;
• the date by which any agreed remedial action will be implemented;
• information on out-of-court dispute-resolution and judicial remedies available to the Client (see Section 12).

11. Implementation of Accepted Requests

Where a Complaint is resolved in line with the Client’s requests, the agreed remedial action will be implemented without undue delay and in any case within the timelines required by applicable law or the contract with the Client. For individual Clients, this period shall not exceed 30 calendar days from the date of the response, unless a longer period is required by law or agreed with the Client.

12. If You Are Not Satisfied with the Response

If we are unable to fully accept your requests, the response will set out your further options, which may include:

• requesting further review by the Company;
• referring the matter to a competent out-of-court dispute-resolution body, where available under applicable law;
• contacting the relevant supervisory authority — including, where applicable, the Polish Financial Supervision Authority (KNF) or the consumer-protection body of your jurisdiction;
• initiating proceedings before a competent court of law.

The specific options available to you will depend on your status (consumer or professional Client), your country of residence, and the nature of the dispute. The applicable options will be set out in the response to your Complaint.

13. Record Keeping

All Complaints, related correspondence, evidence, and responses are recorded in our internal Complaints Register and retained in accordance with applicable law (currently a minimum of five years from the closure of the Complaint), in a secure and retrievable format.

14. Personal Data

Personal data submitted as part of a Complaint is processed in accordance with applicable data-protection law (including the EU General Data Protection Regulation, “GDPR”) and our Privacy Notice. Data is processed solely for the purposes of examining and responding to the Complaint, complying with our legal obligations, and defending or pursuing legal claims where necessary.

15. Free of Charge

Filing and handling of Complaints is free of charge. The Company does not impose any fees on Clients in connection with the submission or examination of a Complaint.

16. Updates to this Policy

This Policy is reviewed regularly and updated to reflect changes in applicable law, regulatory expectations, and our internal procedures. The current version is always available at https://digitallamp.co.

17. Contact

For Complaints and any related queries, please contact:

This document is published for transparency and information purposes. It is a summary of our internal Complaints-Handling Procedure and does not disclose confidential operational detail. The full Procedure is maintained internally and made available to competent authorities upon request.