Complaints-Handling Procedure – BITX, S.L.

1. Purpose

1.1 BITX, S.L. ("BITX") has established this procedure so that its Clients can lodge complaints about the crypto-asset service it provides and have them handled promptly, fairly and consistently. The procedure is approved by BITX's management body, which monitors its implementation, and it is operated by BITX's Customer Service function (Servicio de Atención al Cliente), which is independent from the operational and commercial functions and reports to the management body.

1.2 Complaints are lodged and handled free of charge.

2. Who may complain and about what

2.1 Any Client, prospective Client or duly authorised representative of a Client may lodge a complaint concerning the exchange service provided by BITX, including the onboarding process, the quotation, conclusion or settlement of a transaction, the information provided by BITX, the fees applied or the treatment received from BITX's staff.

2.2 A complaint is admissible where it: (a) relates to a crypto-asset service provided, or requested from, BITX; (b) identifies the complainant and, where applicable, the representative, with the information needed to reply; (c) describes the facts complained of and what the complainant asks for; and (d) is submitted through one of the channels in section 3. These conditions are applied fairly and reasonably. Use of the complaint form in the Annex is recommended but not required.

3. How to lodge a complaint

3.1 Complaints may be lodged in English or in Spanish, in writing, by any of the following means:

• by e-mail to legal@bitx.es, indicating "Complaint" in the subject line;
• by post to BITX, S.L., Customer Service, Passeig de Gràcia 53, Ático, 08007 Barcelona, Spain;
• by completing the complaint form in the Annex to this procedure, which can be downloaded from this website and sent by either of the above means.

3.2 The complaint should include: the complainant's name or legal entity name and contact details; where applicable, the representative's details and the document evidencing the representation; the reference of the transaction or service concerned; a description of the facts and the dates on which they occurred; the damage or loss claimed, if any; any supporting documents; and the complainant's preferred means of communication.

3.3 Complaints are addressed to BITX's Customer Service function, which is responsible for their handling. Where a complaint concerns the Customer Service function itself, it is handled under the supervision of BITX's compliance function.

4. How complaints are handled

4.1 Acknowledgement. BITX acknowledges receipt of every complaint without undue delay and in any event within five (5) business days, by the means indicated by the complainant. The acknowledgement states whether the complaint is admissible, the contact details of the person or department handling it, the date of receipt, the applicable timeframe and, where the complaint was lodged electronically, a copy of it. Where a complaint is rejected as inadmissible, BITX explains the reasons clearly.

4.2 Additional information. Where BITX needs further information or documents to assess the complaint, it requests them from the complainant without undue delay, indicating a reasonable period for reply.

4.3 Investigation. BITX examines the complaint impartially, gathering the relevant records, communications and evidence held by BITX and, where necessary, the views of the staff involved.

4.4 Decision. BITX communicates its reasoned decision to the complainant in writing, in plain language, within two (2) months of the date of receipt of the complaint. Where, exceptionally, a decision cannot be reached within that period, BITX informs the complainant of the reasons for the delay and of the date by which the decision is expected. The decision states whether the complaint is upheld, in whole or in part, the measures that BITX will take and the complainant's right to pursue the matter further.

4.5 Where the complainant does not accept the decision, or does not receive a decision within the period above, the complainant may refer the matter to the Comisión Nacional del Mercado de Valores (CNMV), Calle Edison 4, 28006 Madrid, www.cnmv.es, which is the authority competent for crypto-asset service providers in Spain, without prejudice to any other administrative or judicial remedy available to the complainant and, where the complainant is a consumer, to the alternative dispute resolution mechanisms provided for by law.

5. Records and analysis

5.1 BITX records every complaint received and the measures taken in response in a secure electronic register, which includes the date of receipt, the complainant, the subject-matter, the stages of handling, the decision and the date of communication. Records are kept for at least five (5) years and are available to the CNMV on request.

5.2 BITX analyses complaints on an ongoing basis to identify recurring issues and the root causes of deficiencies, and reports to its management body at least annually on the complaints received and the measures adopted.

6. Personal data

6.1 Personal data provided with a complaint are processed by BITX as data controller for the purpose of handling the complaint and complying with its legal obligations, in accordance with the Privacy Policy published on this website. Data subjects may exercise their rights by writing to legal@bitx.es.

7. Availability of this procedure

7.1 This procedure and the complaint form are published on this website and are provided to any Client on request and together with the acknowledgement of receipt of a complaint.

Annex – Complaint form

This form reproduces the template set out in the Annex to Commission Delegated Regulation (EU) 2025/294. Please complete it and send it to legal@bitx.es or by post to BITX, S.L., Customer Service, Passeig de Gràcia 53, Ático, 08007 Barcelona, Spain. Fields marked "if available" or "if applicable" may be left blank.

1. FILING OF A COMPLAINT (to be sent by the client to the crypto-asset service provider)

1.a. Information about the complainant

1.b. Contact details (if different from 1.a)

2. LEGAL REPRESENTATIVE OF THE COMPLAINANT

2.a. Information about the legal representative (if applicable) (a power of attorney or other official document as proof of the appointment of the representative is to be provided as an attachment to this form)

2.b. Contact details (if different from 2.a)

3. INFORMATION ABOUT THE COMPLAINT

Documentation provided (tick as appropriate)

In ____________________________ (place), on ____________________ (date)

Signature of the complainant / legal representative of the complainant: ____________________________________