Customer Protection Regulation

Preamble

One of the YOiD Group's main strategic objectives is to build a lasting, mutually satisfactory relationship with its users. Achieving this requires, among other things, a high level of service quality that meets customers' expectations.

The process for handling complaints and claims is a core element in improving service quality, providing a simple channel to resolve quickly and with guarantees the cases in which a user believes they have not received the service they expected, and a source of learning to correct errors going forward.

The YOiD Group has a Customer Service Department (SAC) that guarantees proper protection of users' rights, and a Customer Protection Regulation adapted to the requirements of Order ECO/734/2004, of 11 March, on the customer service departments and customer ombudsman of financial institutions.

Title I. General provisions

Article 1. Purpose and scope

This Regulation governs the activity and operation of the Customer Service Department (hereinafter, the SAC) of the YOiD Group (hereinafter, YOiD). Through the SAC, YOiD undertakes to address and resolve complaints and claims submitted to it, directly or through representation, by individuals or legal entities, Spanish or foreign, who qualify as users of YOiD's services, provided they concern their legally recognized interests and rights, whether arising from contracts, transparency and customer protection regulations, or good financial practices and customs and, in particular, the principle of fairness.

Article 2. Approval

Approval of the Regulation and its subsequent updates falls to the governing body of YOiD Identidad Digital, S.L. The Regulation and its amendments are submitted to verification by the Bank of Spain and, thereafter, published on YOiD's website for the information of customers and the public in general.

Title II. SAC requirements and duties

Article 3. Appointment

The head of the SAC shall be appointed by YOiD's governing body. The appointment shall be communicated to the Bank of Spain's Complaints Service and to the relevant supervisory authority or authorities.

Article 4. Suitability

The head of the SAC must possess commercial and professional good standing, as well as suitable knowledge and experience to perform their duties.

Article 5. Term of office

The head of the SAC shall hold the position for an indefinite term.

Article 6. Grounds for incompatibility and ineligibility

The following may not act as head of the SAC: persons who have been declared bankrupt or subject to insolvency proceedings and not rehabilitated; those disqualified or suspended, criminally or administratively, from holding public office or management or administrative positions in entities; those with criminal records for offenses of forgery, tax offenses, culpable insolvency, breach of custody of documents, disclosure of secrets, money laundering, misappropriation of public funds, or property offenses; and those who hold operational or commercial responsibilities within YOiD.

Article 7. Removal. Conflicts of interest

The head of the SAC shall be removed upon death, incapacity, resignation, termination of their employment relationship, retirement or early retirement, upon falling under any of the circumstances of Article 6, or by reasoned decision of the governing body based on serious and justified cause. Anyone with a personal interest in a complaint or claim must disclose it and refrain from taking part in its processing and resolution.

Article 8. Functions and reporting line

The SAC's functions are to address and resolve users' complaints or claims relating to their legally recognized interests and rights, and to submit to YOiD's management recommendations and suggestions that strengthen the relationship with customers. To ensure its independence, the SAC reports directly to the governing body and is functionally and hierarchically independent from the commercial, operations, internal audit and legal advisory areas.

Article 9. Exclusions

The following are excluded: complaints relating to YOiD's employment relationships with its staff; matters that fall within YOiD's discretionary powers; matters pending or already resolved through judicial or arbitration proceedings; complaints aimed at preventing YOiD from exercising its rights against the customer; and complaints filed after the maximum period set out in Article 13.

Article 10. Duty of cooperation

YOiD shall adopt the measures necessary for the SAC to perform its functions as effectively as possible, ensuring that all its departments provide whatever information the SAC requests in connection with its duties.

Article 11. Duty to inform

YOiD shall provide customers with information about the existence and functions of the SAC, its postal and electronic address, the content of this Regulation, the existence of the financial supervisors' Complaints Services (and the need to first exhaust the SAC channel), and references to customer transparency and protection regulations.

Title III. Procedural aspects

Article 12. Filing complaints or claims

Every customer or user has the right to file complaints or claims with the SAC. Filing and processing are free of charge. They may be filed, in person or through accredited representation, on paper or by electronic means allowing for their reading, printing and retention, at any office, at the email address, or via the form enabled for this purpose in the app.

Article 13. Filing deadline

The deadline for filing complaints or claims shall be up to five years from the customer's becoming aware of the events giving rise to them. Complaints filed after this deadline shall not be admitted.

Article 14. Resolution deadline

The SAC shall generally have two months to issue a decision (one month in the case of consumers). Claims relating to payment services shall be dealt with within fifteen business days at the latest; in exceptional situations a provisional response shall be sent, and the final response shall not exceed one month. If the deadline elapses without a decision, or in the event of disagreement, the claimant may turn to the Complaints Services of the competent financial supervisor.

Article 15. Content of the submission

The submission shall state: the identifying details of the interested party and, where applicable, their representative; the grounds for the complaint or claim, with the relevant documents and evidence; the service where the events took place; a declaration that the matter is not being processed through administrative, arbitration or judicial channels; and the place, date and signature.

Article 16. Admission for processing

Upon receipt of the complaint or claim, the SAC shall open a file and acknowledge receipt in writing, recording the filing date for the purposes of computing the deadline.

Article 17. Request for additional information

If the claimant's identity is not sufficiently evidenced or the facts cannot be clearly established, the claimant shall be required to complete the documentation within ten calendar days, with the complaint being filed away if not remedied. The period for remediation does not count toward the deadline in Article 14.

Article 18. Inadmissibility

Admission may only be refused due to the omission of essential, non-remediable information; because the matter falls within the competence of administrative, arbitration or judicial bodies, whether pending or already resolved; because it does not concern specific transactions or does not meet the requirements of Article 1; because it repeats claims from the same customer already resolved; because the deadline in Article 13 has elapsed; or because it is excluded under Article 9. Inadmissibility shall be reasoned and the interested party shall be given ten calendar days to submit observations.

Article 19. Processing

The SAC may request from the claimant and from YOiD's departments any data, clarifications, reports or evidence it considers relevant; the departments must respond within a maximum of ten days.

Article 20. Agreement or acquiescence

The SAC may carry out actions to reach an amicable settlement between the parties. Any agreement reached shall be binding and shall conclude the process. The same applies if YOiD acquiesces to the customer's request.

Article 21. Withdrawal

Interested parties may withdraw their complaints or claims at any time, immediately ending the procedure.

Article 22. Decision and notification

Decisions shall always be reasoned and shall contain clear conclusions, based on the contractual clauses, customer transparency and protection regulations, good financial practices and customs, and the principle of fairness. They shall be binding on YOiD, but not on the customer, who retains all subsequent avenues of recourse. They shall be notified within ten calendar days of their date.

Article 23. Acceptance of the Regulation

Filing a claim implies acceptance of this Regulation.

Title IV. Other aspects

Article 24. Annual report

Within the first quarter of each year, the SAC shall submit to the governing body a report on the performance of its function during the preceding year, including a statistical summary of the complaints and claims handled, a summary of the decisions issued, the general criteria applied, and the recommendations or suggestions arising from its experience.

Final provision

For anything not provided for in this Regulation, Order ECO/734/2004, of 11 March, on the Customer Service Departments and Customer Ombudsman of financial institutions, shall apply.

Annex I. Address of the Customer Service Department

Customer Service Department (SAC) · YOiD Group · c/ Sollube 22, 48993 Getxo (Vizcaya), Spain. SAC email: info@yoid.es.

Annex II. Entities affiliated with the Customer Service Department

• YOiD Identidad Digital, S.L.
• YOiD Tech, S.L.