NAVIGATION

COMPLAINTS POLICY

1. DISPUTES RESOLUTION FACILITIES

1.1. Apasati Markets Limited (hereinafter referred to as “Apasati”) has in place formal procedures to deal with complaints or disputes relating to operation of the Trading Account (issues concerning trading, deposit and/or withdrawal of funds and similar – collectively “Complaints”).

1.2. You can lodge complaints by emailing to Apasati on email: compliance@apasati.org using the procedure described below.

1.3. When Apasati receives a complaint, we will attempt to resolve it promptly. This will stop any unnecessary and inappropriate escalation of minor complaints.

2. PROCEDURE FOR RECEIPT AND HANDLING OF CLIENT COMPLAINTS

2.1. Any complaints or disputes relating to operation of the Trading Account (issues concerning trading, deposit and/or withdrawal of funds and similar – collectively “Complaints”) must be made via electronic mail to the following address: compliance@apasati.org

2.2. For authentication reasons all Complaints must be sent from the same e-mail address of the Client as the one indicated by the Client to the Apasati during the account opening process (or as later modified in accordance with the Apasati applicable terms and conditions).

2.3. All Complaints must be made within 1 (one) Business Day following occurrence of the event, to which the respective Complaint relates. If a Complaint is made beyond the indicated deadline it will be in the Apasati sole and absolute discretion to react to such complaint or to disregard it.

2.4. All Complaints must be made in a legible and comprehensive manner, and must contain at least the following:

a). Full name of the Client;

b). Client’s login;

c). Number(s) of the Order(s) or Transaction(s) in question;

d). Details of the matter in question;

e). Description of the situation that the complaint refers to supported by screenshots.

2.5. A Complaint must be executed in a courteous manner, may not contain any inappropriate language and/or other indecent content and may not be otherwise made in a manner abusive to the Apasati and its Staff.

2.6. Each qualifying Complaint will be assigned a unique identification number in the Apasati complaint handling system (“Ticket ID”), which will be communicated to the Client following the initial assessment of the Complaint. The Client shall refer to the Ticket ID in the “Subject” field of each subsequent communication to the Apasati related to the respective Complaint.

2.7. The Client shall promptly respond to the Apasati request for any information or materials necessary to review the respective Complaint and shall provide such information and/or materials in a timely and accurate fashion.

2.8. All Complaints will be reviewed in accordance with the provisions of the Customer Agreement between Apasati and the Client and the Terms of Business thereto.

2.9. Without derogating from the provisions of Clause (f) above, it is expressly stipulated that no complaints may be made in respect of:

a). a transaction or a pending order or any modification to the foregoing not accepted, rejected, deleted or reverted in accordance with the provisions of the Customer Agreement

b). any trading or account management issue arising due to error in communications either on the side of the Client or Apasati or both

c). any issues arising due to unavailability of the trading facilities for maintenance and/or other technical works conducted in accordance with the Terms of use

d). any transactions made with funds generated by the Client as profit from transactions that were subsequently cancelled by Apasati

e). any issues arising out the failure of the Trading Platform software/hardware in case no records on the Server Log‐File exist to prove the Client sent instructions

f). any differences in the prices and/or quotes provided by Apasati for the respective financial instrument and any of the foregoing provided for any other financial instrument (including, without limitation, the underlying asset) and/or provided for the same and/or similar financial instrument by any other company (whether Apasati’s affiliate or otherwise)

g). an erroneous price quote and/or a spike in the Apasati price feed

h). any lost and/or unrealized profits or any non-financial losses

2.10. Apasati records of Apasati trading system regarding the Client’s Trading Account, including, without limitation, the server log files, shall be the absolute and indisputable proof in respect of any Complaint. Without limiting generality of the foregoing, in case of a discrepancy between the trading logs on the server side and trading logs on the Client’s side, the log files on the server side shall take precedence. If the Server Log‐File has not recorded the relevant information to which the Client refers, the complaint based on this reference may not be considered.

2.11. Apasati shall communicate to the Client regarding the Complaint, including providing notice of Apasati final decision on its resolution via e-mail notification to the Client’s e-mail address referred to in Clause (b) above and Trading Platform internal mail. The Client is considered to be duly informed immediately upon sending of the notification by Apasati. Apasati Trading Platform Server log files and/or outgoing e-mail server logs shall be the sufficient and indisputable evidence of notification send. Apasati reserves the right but will in no case be obliged to provide respective notifications to the Client via other means of communication as per contact details provided by the Client to Apasati.

2.12. The Client acknowledges that Apasati may, at its sole discretion, prevent the Client from making any changes to the Order(s) in question during the time the respective Complaint is being reviewed.

2.13. If a decision to address the issue referred to in the Client’s Complaint has been made by the Apasati, the Company may, at its sole and absolute discretion, choose either of the following methods:

a). Credit and/or debit the Client’s Trading Account for the amount of the respective actual direct financial loss sustained by the Client

b). Open and/or close a transaction and/or pending order in question

c). Satisfy (fully or partially) Client’s request as stated in the Complaint.

d). Otherwise address the issue using methods, generally excepted in common market practice.

2.14. Unless expressly set forth otherwise by an applicable law and/or regulation, Apasati decision with respect to a Complaint shall be final and binding and shall not be subject to any appeal.

NAHORU ^

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