Complaint Handling Policy

Table of Contents

• 1. Purpose
• 2. Scope
• 3. What is a complaint
• 4. How to make a complaint
• 5. Information to include
• 6. How we handle complaints
  • Stage 1 - Acknowledgement
  • Stage 2 - Investigation and resolution
  • Stage 3 - Escalation and final response
• 7. Alternative dispute resolution
• 8. Data protection complaints
• 9. Vulnerable customers
• 10. Records, monitoring and improvement
• 11. Review

1. Purpose

This policy explains how Gamban Ltd (“Gamban”, “we”, “us”) receives, handles and resolves complaints about our site, our software and our services. It is the policy referred to in the “Complaints and dispute resolution” sections of our Terms of Use and End User Licence Agreement.

Gamban supports people experiencing gambling harm. We recognise that many of the people who contact us may be in a vulnerable position, and this policy is written to ensure complaints are handled fairly, promptly and with appropriate care.

2. Scope

This policy covers complaints from consumers and business users about:

• the Gamban website and any content on it;

• the Gamban desktop and mobile software and its documentation;

• our subscription, billing, renewal and cancellation processes; and

• the conduct of our support function.

Complaints that relate to how we handle personal data are dealt with under the separate route in section 8 (Data protection complaints).

3. What is a complaint

A complaint is any expression of dissatisfaction, whether justified or not, about Gamban’s products, services or conduct, where a response or resolution is expected. A complaint is different from a routine support query or feature request, which is handled through normal support.

Any ticket identified as a complaint or escalation is categorised in Zammad using the "User Complaint" tag and escalated directly to the Customer Operations Manager (Emil Jankowski) for review and resolution.

Application of the tag has been inconsistent: complaints received during 2026 were escalated to and resolved by the Customer Operations Manager as intended, but were not consistently tagged, so no tagged complaint records exist for the period. Consistent use of the tag was reinforced with the support team in July 2026 so that complaint volumes and themes can be reported at management review.

4. How to make a complaint

You can make a complaint using the following channels:

Customers may submit complaints through any of Gamban’s active support channels. This includes email, the contact form available on the Gamban website, and direct messages received through X and Instagram. Complaints received through any of these channels are handled through the same internal complaint management process.

5. Information to include

To help us resolve your complaint quickly, please tell us:

1. your name and the email address associated with your account;

2. what the complaint is about and what has gone wrong;

3. when it happened and any relevant order, transaction or ticket reference; and

4. what outcome you are looking for.

6. How we handle complaints

We aim to resolve complaints fairly and at the earliest possible stage. Our process has the following stages.

Stage 1 - Acknowledgement

We will acknowledge your complaint and confirm who is dealing with it.

Gamban aims to acknowledge and respond to all complaints within 24 hours. In circumstances where further investigation or input from the technical team is required, response times may extend to up to 48 hours.

Stage 2 - Investigation and resolution

The complaint is investigated by the support team. Where it concerns a service failure, it is recorded and progressed in line with our internal Control of Nonconforming Service procedure, including root cause review and an appropriate remedy (which may include a correction, a replacement service or a refund). We will provide a substantive response setting out our findings and any resolution offered.

Stage 2 complaint handling is carried out by the Customer Operations Manager. Customers can generally expect a response within 24 hours, or within 48 hours where technical investigation is required.

Where a refund or other remedy is deemed appropriate, the Customer Operations Manager is authorised to approve and process the refund. Refunds are issued immediately upon approval, although it may take up to 14 days for the funds to appear on the customer’s bank statement, depending on the payment provider and banking institution.

Stage 3 - Escalation and final response

If you are not satisfied with the Stage 2 outcome, you can ask for the complaint to be reviewed. The review is carried out by someone not involved in the original handling. Once the review is complete we will issue a final response. If we cannot resolve the complaint, we will write to you to confirm this (a final or “deadlock” position) so that you can pursue other options, including those in section 7.

If a customer remains dissatisfied following Stage 2, the complaint may be escalated to the Chief Executive Officer or Chief Operating Officer for final review and resolution. Gamban aims to provide a final response as promptly as possible following escalation.

7. Alternative dispute resolution

If you are a consumer and we are unable to resolve your complaint to your satisfaction, you may be able to refer the matter to an alternative dispute resolution (ADR) body. Gamban is not currently a member of a specific ADR scheme. We will provide information about a competent ADR body, such as the Chartered Trading Standards Institute, on request, and will confirm whether or not we agree to use ADR in your case.

This does not affect your legal rights, including any right to bring a claim through the courts of your country of residence.

8. Data protection complaints

Complaints about how Gamban collects, uses or protects personal data are handled separately from general service complaints, because Gamban processes special category data relating to gambling harm.

Please use the following routes if you have a data protection concern:

9. Vulnerable customers

We recognise that people contacting Gamban may be experiencing gambling harm or financial difficulty. Staff handling complaints should respond with care, avoid unnecessary delay, and take individual circumstances into account when agreeing a resolution. Where a complaint indicates a person may be at risk, it should be escalated promptly.

10. Records, monitoring and improvement

All complaints are recorded in our support system and retained in line with our Data Deletion Procedure. Complaint outcomes and trends are reviewed as part of the Corrective Action process and reported to senior management at Management Review, so that recurring issues are addressed and the service improved over time.

All complaints are recorded in Zammad using the “User Complaint” tag to ensure they can be tracked and reviewed for quality management purposes. Complaint records may be reviewed during management meetings and internal audits to identify trends, recurring issues, and opportunities for improvement.

Where complaint histories are reviewed internally, any personal information is removed or anonymised to protect customer privacy.

11. Review

This policy is reviewed at least annually by the document owner, and earlier if there is a material change to the support process, the Terms of Use, the EULA, or applicable law (including the consumer subscription provisions of the Digital Markets, Competition and Consumers Act 2024 expected in 2027).

End of policy.