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Client Complaint Process

The Commission de Surveillance du Secteur Financier (“CSSF”) has adopted Regulation N° 16-07, followed by specifications by the CSSF Circular 17/671 related to the out-of-court resolution of complaints (this regulation is available on the CSSF website https://www.cssf.lu/fr/reclamations-ClientClientele/).  

 

As part of the obligations laid out in Regulation N° 16-07, COMO DL S.A. (“COMO Digital Life”), as a payment institution regulated by the CSSF, seeks to provide a high-quality service to its Clients, and in particular it hereby informs them that all potential concerns and complaints will be treated in a careful, effective, and prompt manner in compliance with the below procedure.  

 

In addition, COMO DL S.A. aims to take all the necessary measures to ensure that the processing of personal data for the purposes of Clients ́complaints analysis and solving complies with the applicable rules on the protection of personal data.  

 

  1. A complaint can be submitted by certified mail against return receipt, by electronic mail, or via telephone to the following addresses:  


    COMO DL S.A.  

    Atrium Business Park

    33, Rue du Puits Romain

    L-8070 Bertrange

    Luxembourg  

    Email: complaints@como-dl.com

    Telephone: (+352) 26 20 2877  

     

    Complaints can be made in the Luxembourgish, German, English, or French language.  

     

  2. The complainant (“Complainant”) shall include in his/her complaint his/her first and last name (and/or that of his/her legal representative), address, and other contact details (telephone number, mobile number, electronic mail).  

     

  3. The Complainant shall include a detailed description of the circumstances underlying his/her complaint. All complaints submitted by Complainants must contain all relevant information as well as copies of all relevant documents in the Complainant’s possession. 

      

  4. A written acknowledgement of receipt will be provided to the complainant within ten (10) business days as of the receipt of the complaint unless the answer itself is provided to the complainant within this period.  

     

  5. Once the complaint has been received by COMO Digital Life, it shall deal with it within the terms indicated within COMO Digital Life Complaints Procedure. COMO Digital Life designates and coordinates the responsible persons in charge of the treatment of the complaint, who has management level ranking (“Person Responsible for Complaints Handling”). The Person Responsible for Complaints Handling will gather all relevant evidence and ensure that a thorough and impartial investigation is carried out within the mandatory timeframe after receipt of a complaint.  

     

  6. Following an assessment, COMO Digital Life provides the Complainant with its position by registered letter, by courier, or by certified email within maximum 1 (one) month from the date of receipt of the complaint. If, for any reason, COMO Digital Life considers that it shall exceed this period, it commits to advising the Complainant about the reason for the delay and indicates the date by which its examination will be finished.  

     

  7. Where the complaint handling does not result in a satisfactory answer within a reasonable timeframe, the Complainant may notify the CSSF within 1 (one) year of filing the initial complaint and make use of the out-of-court procedure.  

     

    Any complaint submitted to the CSSF, should be drafted in the English, Luxembourgish, German, or French language can be submitted to the CSSF by mail, fax or email:  

     

    Commission de Surveillance du Secteur Financier  

    Département Juridique CC  

    283, route d’Arlon  

    L-1150 Luxembourg  

    Fax: +352 26251 – 601  

    Email: reclamation@cssf.lu  

     

  8. Within 3 (three) weeks from the receipt of the request and in case of an unfounded complaint, the CSSF will send in writing to the Complainant and to COMO Digital Life a detailed explanation of the reasons for which it does or does not accept to deal with the dispute.  

     

  9. In the event the CSSF considers the request of the Complainant justified and complete, it will also send a written confirmation to COMO Digital Life asking for its position within a reasonable period which should not exceed 1 (one) month.  

     

  10. The CSSF then provides a motivated decision within 90 (ninety) days addressed to the Complainant and to COMO Digital Life inviting them, in case the request is well-founded, to resolve their differences, in consequence of which the parties shall attempt to reach an amicable agreement and inform the CSSF.  

CSSF CLIENT COMPLAINTS  

https://www.cssf.lu/en/2019/02/complaints-about-infringements-of-the-law-of-10-november-2009-on-payment-services/  

CSSF CIRCULAR 16-07 RELATING TO OUT-OF-COURT COMPLAINT RESOLUTION  

https://www.cssf.lu/wp-content/uploads/RCSSF_No16-07eng.pdf (English version) 

  

https://www.cssf.lu/wp-content/uploads/RCSSF_No16-07.pdf (French version) 

The submission of our complaints table and report to the CSSF happens before the 1st March deadline each year within our client complaint process in compliance with the section 3 of CSSF circular 17/671 as amended.The analysis of data relating to complaint handling within our client complaint process is in compliance with the article 15 (6) of CSSF Regulation n°16-07.

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