Complaints Handling Policy and Procedure

This Complaints Handling Policy and Procedure is published pursuant to Rule III of the VARA Market Conduct Rulebook, Rule II.B.1(b) of the VARA Exchange Services Rulebook, and Rule I.B.1(b) of the VARA Broker-Dealer Services Rulebook.

1. Introduction

Rain MENA FZE (the "Company") is committed to ensuring that all complaints are acknowledged, addressed, escalated where applicable, and resolved. This document sets out the Company's procedures for the receipt, acknowledgment, investigation, and resolution of complaints from clients and other affected persons.

This document is published on the Company's website in a prominent place in accordance with the Company's obligations under the VARA Market Conduct Rulebook, the VARA Exchange Services Rulebook, and the VARA Broker-Dealer Services Rulebook.

2. What Is a Complaint?

A complaint is an expression of dissatisfaction made to the Company, related to its products, services, or employees, where a response or resolution is explicitly or implicitly expected.

A complaint may be filed by anyone (the "Complainant") who is not satisfied with the services, products, employees, management, or performance of the Company.

A complaint is considered to have been formally made from the moment it is submitted through any of the channels listed in Section 3 below, provided it identifies the Complainant and describes the nature of the dissatisfaction. The Company monitors all channels set out in Section 3 for incoming complaints on an ongoing basis. You are not required to use any particular channel or form for your submission to be recognized as a complaint by the Company.

3. How to Make a Complaint

You may submit a complaint via email to support-ae@rain.com with the subject line "Official Complaint", providing your full name, email address, phone number, account number, any supporting documents, and the outcome or expected rectification you are seeking.

Alternatively, you may submit a complaint using the Company's Official Complaint Form, which is available here:Official Complaint Form. The Official Complaint Form is designed to be straightforward and easy to use. It asks you to provide your contact details (including your full name and email address), your Unique Identification Number, a description of the nature of the relevant incident, your desired outcome, and any supporting documents you wish to attach. There are clear instructions accompanying the form to guide you through the submission process.

The mode of communication used by the Complainant when submitting their complaint will remain the channel through which the Company provides updates and may request additional information.

4. Complaint Timelines

The Company will acknowledge receipt of your complaint in writing within one (1) week from the date of the complaint, confirming that it has been received and is being reviewed. At the time of acknowledgment, the Company will also provide a unique reference number to the Complainant.

The Company will resolve all complaints within four (4) weeks from the date of the complaint, including details of its assessment and any remedial action taken.

If, due to exceptional circumstances, the complaint cannot be resolved within four (4) weeks, the Company will inform the Complainant of the delay, provide an update on progress, outline the reasons for the extended timeline, and ensure the matter is concluded no later than eight (8) weeks from the date the complaint was submitted.

5. No Fees

The Company does not impose any fees or charges on the Complainant for submitting or handling complaints

6. Independence in Complaint Handling

Complaints will be handled and investigated by members of Staff who are not directly involved in the subject matter of the complaint, ensuring that all investigations are conducted impartially and with appropriate remedial action taken where required.

7. Complaints Involving Third Parties

If a complaint relates to a third party linked to the provision of the Company's virtual asset services or products, the Company will liaise directly with such third party to address the complaint and will be responsible for ensuring the complaint is resolved within the timelines set out in Section 4 above.

The Company will reach out to the Complainant within one (1) week from the date of the complaint to outline the nature of the complaint and request written confirmation that the Complainant consents to the complaint being shared with the relevant third party. Where the complaint includes personal data, the Company will ensure that the Complainant is made aware of this and that the complaint is forwarded in compliance with applicable data protection laws.

Once consent is granted, the Company will forward the complaint to the third party as soon as reasonably practicable.

The Company will update the Complainant that the complaint has been forwarded to the relevant third party, together with the contact details of the individual dealing with the complaint at that third party.

In the event of complaints involving third parties, the Company will still record the complaint and issue a unique reference number to the Complainant. Once resolved, all associated documentation will be stored for a minimum period of eight (8) years.

8. Investigation and Systemic Review

In the course of investigating any complaint, the Company will take reasonable steps to identify and remedy any recurring or systemic problems, including: analyzing the causes of complaints to identify common root causes; considering whether such root causes may affect other processes, services (including VA Activities), or products not directly the subject of the complaint; correcting such root causes as soon as reasonably practicable; and documenting and recording all steps taken, including the outcomes.

9. Data and Privacy

All information collected by the Company in connection with a complaint shall be subject to the Company's Records Retention and Records Management Policy and Data Privacy Policy, available here.

10. Record Retention

All complaints and related correspondence will be documented and retained by the Company for a minimum of eight (8) years. This includes all communications and documentation related to the investigation of client complaints, transaction error resolution, and any facts giving rise to a potential violation of applicable laws or regulatory requirements, in accordance with the requirements of the VARA Compliance and Risk Management Rulebook.

The records maintained shall include at minimum: all complaints received from Complainants; all measures the Company has taken in relation to such complaints (including remedial steps, communications with third parties, and investigation records); and the outcome or resolution provided in respect of each complaint.

11. If You Are Not Satisfied

If you are not satisfied with the resolution provided, you may request the Company to review its decision, provided that you are able to supply new material information or evidence in support of that request, or alternatively refer the matter to the relevant regulators or authorities.

You may also request the Company's support team to internally escalate the matter to the Compliance Officer for further review.

In the event that a complaint cannot be resolved through the procedure set out in this document, the dispute resolution method shall be via the Dubai International Arbitration Centre ("DIAC"), whose rules are incorporated by reference. The number of arbitrators shall be three; the seat of arbitration shall be Dubai, UAE; the language of the arbitration shall be English. The decision and award of the arbitral tribunal shall be final, binding, and conclusive on all parties, who waive any right of appeal to the fullest extent permitted by applicable law.

You may also refer your complaint to the Virtual Assets Regulatory Authority (VARA) here: https://www.vara.ae/en/register-a-complaint/. 

12. Regulatory Framework

This Complaints Handling Policy and Procedure has been established and is maintained in accordance with:

• Rule III of the VARA Market Conduct Rulebook;
• Rule I.B.1(b) of the VARA Broker-Dealer Services Rulebook, which requires VASPs providing Broker-Dealer Services to publish on their website in a prominent place their policies and procedures relating to the handling of client complaints;
• Rule II.B.1(b) of the VARA Exchange Services Rulebook; and
• The VARA Compliance and Risk Management Rulebook, which requires VASPs to establish, maintain, and enforce clear and detailed compliance policies and procedures to enable all Staff and the Board to ensure that client complaints are handled properly with appropriate remedial action.

The disclosures set out in this document are in addition to all disclosures required under the VARA Market Conduct Rulebook and to all notifications to VARA required under the VARA Compliance and Risk Management Rulebook.

This document is reviewed on an annual basis and updated as required.