Effective Date: 31-07-2025
Introduction
1.1. Overview
This Policy is developed in alignment with the Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) and other related regulations and Czech regulatory requirements. This Policy is submitted as part of Canis’s CASP licensing file pursuant to Article 62(2) of MiCA.
1.2. Purpose
To ensure client trust and full regulatory compliance, Canis has established this Complaint Handling Policy. This Policy sets out our commitment to a transparent, fair, and timely process for addressing client concerns. It details the procedures for submitting, investigating, and resolving complaints, ensuring we meet our legal obligations and our clients' expectations.
This Policy applies to all complaints received from clients concerning the crypto-asset services provided by Canis, including issues related to transparency, consumer rights, pricing, execution and security.
An up-to-date version of this Policy will be published on Canis website, so that the clients can familiarize themselves with the procedure of complaint handling.
1.3. Scope
This Complaint Handling Policy has been developed to ensure full adherence to the applicable legal and regulatory framework. Canis commits to maintaining and applying these procedures in strict accordance with the requirements set forth in the following regulations:
Regulation (EU) 2023/1114 on markets in crypto-assets ("MiCA"), in particular its Article 71.
Commission Delegated Regulation (EU) 2025/294, which specifies the regulatory technical standards (RTS) for the requirements, templates, and procedures for handling complaints by crypto-asset service providers.
Commission Delegated Regulation (EU) 2025/305, specifying the information to be included in an application for authorisation as a crypto-asset service provider (“CASP”).
Relevant provisions of the Czech legal framework, including consumer protection and financial services regulations.
1.4. Approval
This Policy has been reviewed and approved by the Management Board of Canis. Any amendments to this Policy must be formally approved by the Management Board and documented to ensure transparency and regulatory compliance. This Policy will be reviewed at least annually, or at any time in case of material changes.
1.5. Definitions
Client: A natural or legal person who has entered into an agreement with Canis for the provision of crypto-asset services.
Complaint: A statement of dissatisfaction addressed to Canis by a Client relating to the provision of one or more crypto-asset services.
Complainant: A Client that submits a complaint to Canis.
Information on the Human and Technical Resources
The Risk Manager is responsible for the complaint-handling process. Risk Manager is responsible for
maintaining the Complaints Register
analyzing complaint data to identify trends
preparing semi-annual reports for the Management Board
ensuring all relevant staff receive appropriate training
The Risk Manager may collaborate with the Compliance Officer as needed.
Guiding Principles
Canis is committed to handling all complaints based on the following principles:
Fairness: We will investigate every complaint impartially and assess it based on facts and evidence.
Transparency: We will provide clients with clear, concise, and accessible information about our complaint-handling process.
Timelines: We will adhere to the timelines set out in this Policy and communicate promptly with complainants.
Consistency: We will apply this Policy consistently to ensure equitable outcomes for similar complaints.
Confidentiality: We will handle all complaints and personal data in accordance with the GDPR and Canis’s Data Protection & Record Keeping Policy.
Accessibility: The entire complaint-handling process is provided free of charge to all clients.
Complaint Information
4.1. General Statement
Clients and potential clients are informed that they may file a complaint, which is free of charge, on Canis’ website.
The informative statement sample template:
“All clients and potential clients have the possibility to file a complaint. The process of complaint-handling is free of charge. Complaints can be submitted through the dashboard, sent via email or mail. When filing a complaint please follow the rules on admissibility that are specified in the Complaint Handling Policy. A Standard Complaint Template can be found here”
4.2. How to File a Complaint
Clients may submit complaints through the following dedicated channels:
Email: feedback@canis.xyz;
Written Post: sent to Canis Life s.r.o., Václavské nám. 2132/47, 110 00 Nové Město, Praha.
4.3. Conditions for the Admissibility
To ensure a prompt investigation, complaints should include the following details:
the Client's full legal name and contact details;
a clear description of the issue;
the date on which the issue occurred;
any supporting documentation (e.g., transaction IDs, correspondence).
Canis encourages the use of the dashboard form available on their website or the official Standard Complaint Template (which forms the Annex I to this Policy and is available on our website). The use of the dashboard or the Template is not mandatory.
4.4. Languages
Complaints and communications may be submitted in English, Czech, or any other official language of an EU Member State where Canis provides services.
4.5. Communication
All communication between Canis and the complainant will be made electronically, unless the complainant requests communication in a paper form.
The Complaint-Handling Procedure
5.1. Receipt and Acknowledgement
Upon receipt of a complaint, Canis will log it in its secure electronic Complaints Register and send an acknowledgement of receipt to the complainant within 48 hours The acknowledgment will contain:
The name and contact details, including e-mail address and telephone number of the department handling the complaint, to which the complainant can address any query related to their complaint
The date the complaint was received.
Standard cases: 15 days
Complex cases: 35 days
Exceptional cases: Never exceeding 2 months
A copy of the complaint filed, if submitted electronically.
If a complaint is inadmissible (e.g. does not relate to a service provided by Canis) Canis will inform the complainant providing a clear explanation for the rejection.
5.2. Request for Additional Information
Canis will assess whether the complaint contains all necessary information for a proper investigation. If a complaint is incomplete or additional information is required, Canis will inform the complainant and ask for the additional information necessary within 5 days of receiving the complaint.
5.3. Investigation
Where Canis has received a complete and admissible complaint with all necessary information provided, Canis will conduct a thorough and impartial investigation into the complaint. This includes gathering and reviewing all relevant information and documentation.
Canis will not request information from the complainant that is already in its possession.
Upon request, the complainant will be kept reasonably informed of the progress of the investigation.
5.4. Decision
A complaint shall be resolved within 15 days (35 days for complex cases) from the date the complaint was received. The final decision will be communicated in clear and plain language and will:
Address all points raised in the complaint.
Provide a clear explanation of the investigation's findings and the reasons for the decision.
State what remedial action, if any, Canis will take.
In the exceptional circumstance that a decision cannot be provided within 35 days, Canis will inform the complainant of the reasons for the delay and specify a new expected date for the decision.
A decision must be provided to the complainant in any case within 2 months from the date the complaint was received.
If the decision does not fully satisfy the complainant's demand, it will include information on the available alternative dispute resolution mechanisms and how the complainant may access them.
6. Client Rights and Alternative Dispute Resolution
If a complainant is dissatisfied with the final decision provided by Canis, they may pursue alternative dispute resolution. This includes, but is not limited to, referring the matter to:
The Czech Financial Arbitrator (Finanční arbitr České republiky).
A competent court of law in the Czech republic.
The final decision letter will include information on how to contact these bodies.
Record-keeping, Analysis and Reporting
Canis will maintain a secure electronic Complaints Register to record all details of complaints received and the measures taken for their resolution. All records related to a complaint will be retained for a minimum period of 5 years from the date of the final decision.
The Risk Manager will regularly analyze complaint-handling data to identify root causes, systemic issues, and recurring trends. This analysis will include, at a minimum:
the average processing time for each stage of the complaint procedure;
the number of complaints received within a set period of time and their distribution across the complaint-handling procedure.
the number of complaints where maximum time limits were not met;
the categories of issues to which complaints relate;
the outcomes of complaint investigations.
The Risk Manager will provide a comprehensive report on its analysis to the Management Board every 6 months. This report will highlight key trends, risks, and recommendations for improving Canis's services and operational processes.
The Risk Manager is responsible for ensuring that all relevant staff receive appropriate training on the complaint-handling process
These measures ensure a robust framework for monitoring, evaluating, and improving Canis’s complaint-handling process.
Approved by: The Management Board of Canis Life s.r.o.
Approval Date: 31/07/2025
Next Review: by 31/07/2026 or sooner if needed
This Commercial Policy (“Policy”) is issued by Canis s.r.o. (“Canis” or “the Company”) in compliance with Article 77 of Regulation (EU) 2023/1114 (Markets in Crypto-Assets Regulation, MiCA). It sets out the terms and conditions under which Canis provides exchange services between fiat currency and crypto-assets, as well as between different crypto-assets.
