Complaints & Dispute Resolution Policy

01Purpose and Scope

This Complaints & Dispute Resolution Policy (“Policy”) establishes the procedures through which complaints, disputes and requests for formal review concerning Famepify may be submitted, investigated, resolved and escalated.

Famepify is operated under Famepify Media.

This Policy is intended to provide an accessible, fair, transparent and proportionate mechanism for addressing dissatisfaction relating to Famepify Services, Accounts, Orders, Wallets, Payments, refunds, customer support, enforcement actions, privacy matters and other interactions with the Platform.

This Policy applies to complaints made by:

• registered Famepify Users;
• customers;
• persons who have made Payments to Famepify;
• API users;
• resellers;
• agencies;
• persons affected by a Famepify transaction;
• Data Subjects exercising applicable privacy rights; and
• other persons with a legitimate complaint concerning Famepify.

This Policy shall be read together with the:

• Terms of Service;
• Refund Policy;
• Billing, Wallet & Payment Policy;
• Privacy Policy;
• Data Rights & Privacy Requests Policy;
• Acceptable Use Policy;
• Intellectual Property & Copyright Policy; and
• API & Reseller Terms.

Nothing in this Policy shall operate to exclude, waive, postpone or restrict any statutory complaint, regulatory, judicial or consumer remedy that cannot lawfully be excluded.

02Definitions

Complaint

“Complaint” means an expression of dissatisfaction concerning an act, omission, Service, transaction, decision, process, communication or other matter relating to Famepify where the complainant seeks an explanation, correction, remedy, review or other response.

A Complaint may exist whether or not the complainant expressly uses the word “complaint”.

Complainant

“Complainant” means the person or organisation submitting a Complaint or on whose behalf an authorised Complaint is submitted.

Dispute

“Dispute” means a material disagreement between Famepify and a User or other affected person concerning facts, contractual rights, payments, Services, refunds, Account actions, enforcement or another matter that has not been resolved through ordinary support interaction.

Final Response

“Final Response” means Famepify’s formal conclusion of an internal Complaint after available information has been reviewed and the Complaint has been upheld, partially upheld, rejected, otherwise resolved or referred to another applicable process.

Internal Review

“Internal Review” means a further review of a Complaint decision where the complainant presents a reasonable basis for reconsideration.

Platform

“Platform” means Famepify’s websites, applications, dashboard, Wallet, payment systems, APIs, support systems and other digital infrastructure.

Remedy

“Remedy” means any corrective action reasonably available in response to a Complaint, including explanation, correction, re-performance, replacement, Wallet adjustment, refund, partial refund, restoration of access, reversal of an enforcement action or another appropriate form of redress.

Famepify

“Famepify”, “we”, “us” or “our” means the Famepify platform operated under Famepify Media.

03Principles Governing Complaints

Fair Complaint Handling

Complaints shall be handled according to the nature of the matter, available evidence, applicable legal obligations, contractual terms and the rights of affected persons.

Famepify’s complaint-handling process is intended to reflect the following principles:

• accessibility;
• fair treatment;
• good-faith investigation;
• reasonable opportunity to provide relevant information;
• proportionate decision-making;
• appropriate confidentiality;
• timely handling;
• consistency;
• accurate recordkeeping;
• non-retaliation;
• availability of escalation; and
• preservation of applicable consumer and statutory rights.

No Complaint shall be rejected merely because its determination may be commercially unfavourable to Famepify.

Substance Over Labels

A communication shall be handled according to its substance rather than solely according to the category selected by the complainant.

Accordingly, a communication submitted as a support request may be treated as a Complaint where it clearly alleges unresolved wrongdoing or seeks formal review.

Likewise, a Complaint seeking repayment of money may be referred into the Refund Request process where the requested remedy is principally a refund.

04Complaints and Ordinary Customer Support

Support Requests Are Not Necessarily Formal Complaints

An ordinary customer-support request shall not automatically constitute a formal Complaint.

Examples of ordinary support matters may include:

• asking how a feature works;
• requesting an Order status;
• requesting a refill;
• asking how to fund a Wallet;
• seeking clarification about a Service;
• reporting a technical issue; or
• requesting general Account assistance.

Where ordinary support resolves the issue satisfactorily, no separate Complaint process may be required.

When a Support Matter Becomes a Complaint

A support matter may become a Complaint where the User expresses material dissatisfaction concerning:

• failure to resolve an issue;
• repeated Service failure;
• treatment by Famepify;
• a disputed decision;
• disputed payment handling;
• an allegedly unfair Account restriction;
• refusal of a requested remedy;
• alleged breach of policy;
• alleged violation of consumer rights; or
• another matter requiring formal review.

A User shall not be required to repeat the entire factual history merely because a support issue has been escalated into a Complaint where Famepify already possesses the relevant records.

05Matters Covered by This Policy

Service Delivery Complaints

This Policy may apply to complaints concerning:

• non-delivery;
• partial delivery;
• material delay;
• incorrect delivery;
• Service quality;
• alleged material misdescription;
• refill handling;
• Service substitution;
• supplier-related issues;
• Order cancellation; or
• another dispute concerning performance of a Service.

Billing and Wallet Complaints

This Policy may apply to complaints concerning:

• missing Wallet credits;
• incorrect Wallet deductions;
• duplicate Payments;
• duplicate Wallet credits;
• disputed balances;
• incorrect transaction records;
• Payment reconciliation;
• negative balances;
• Promotional Credits;
• Wallet restrictions; or
• another billing issue.

Refund Complaints

This Policy may apply where a complainant disputes:

• refusal of a refund;
• amount of a partial refund;
• refund method;
• refund destination;
• classification of Wallet value;
• duplicate-recovery determination;
• refund delay;
• refund investigation; or
• another decision made under the Refund Policy.

The underlying request for a refund shall ordinarily be made through the dedicated Refund Request process.

Account Complaints

This Policy may apply to complaints concerning:

• Account suspension;
• Account termination;
• verification requirements;
• alleged Account compromise;
• access restrictions;
• enforcement decisions;
• suspected fraud restrictions;
• API restrictions;
• payment restrictions; or
• another Account-management decision.

Customer Service Complaints

This Policy may apply where the complainant alleges:

• unreasonable failure to respond;
• materially inaccurate information;
• inappropriate staff conduct;
• repeated unresolved support;
• unfair complaint handling;
• failure to follow an applicable process; or
• another issue concerning Famepify customer support.

Acceptable Use Enforcement Complaints

A User affected by enforcement under the Acceptable Use Policy may complain that an enforcement decision was:

• factually incorrect;
• disproportionate;
• based upon mistaken identity;
• based upon inaccurate payment information;
• imposed without consideration of relevant evidence; or
• otherwise inconsistent with the applicable Policy.

Privacy Complaints

A Complaint concerning personal data may involve:

• unlawful processing;
• alleged failure to honour a privacy right;
• improper disclosure;
• Cookie consent;
• marketing after objection;
• inadequate security;
• international transfers;
• Data Rights Request handling; or
• another privacy matter.

Privacy matters shall also be handled under the Privacy Policy and Data Rights & Privacy Requests Policy.

06Matters Governed Primarily by Other Procedures

Formal Refund Requests

A request principally seeking the return of money shall ordinarily be submitted through the official Famepify Refund Request process:

The Refund Policy governs refund eligibility.

A Complaint may subsequently challenge the handling or outcome of that refund request.

Privacy Rights Requests

Requests for:

• access;
• rectification;
• erasure;
• restriction;
• portability;
• objection;
• consent withdrawal; or
• other statutory privacy rights

shall ordinarily be submitted through the Data Rights & Privacy Requests Policy.

A Complaint may be made where the Data Subject disputes how that request was handled.

Chargebacks and Bank Disputes

A chargeback or bank dispute is governed principally by the rules of the relevant bank, Payment Provider or payment network.

The existence of a chargeback does not prevent a Complaint from being submitted to Famepify.

However, where the same monetary amount is simultaneously subject to a chargeback and refund claim, Famepify may coordinate or pause duplicate monetary resolution to prevent double recovery.

Intellectual Property Notices

Copyright, trademark and related intellectual-property complaints shall be handled primarily under the Intellectual Property & Copyright Policy.

Security Reports

A suspected vulnerability, Account compromise or security incident may require immediate technical handling rather than ordinary Complaint processing.

Where a dedicated Responsible Disclosure or Security Policy exists, qualifying reports shall be handled under that procedure.

07Who May Submit a Complaint

Account Holders

A registered User may submit a Complaint concerning the User’s Account, transactions, Orders, Wallet, Services or other interactions with Famepify.

Payers

A person who made a Payment connected to a Famepify Account may submit a Complaint concerning that Payment where the person can establish a legitimate connection to the transaction.

Payment ownership and Account ownership may require separate verification.

Authorised Representatives

A person may submit a Complaint through an authorised representative.

Famepify may require reasonable evidence establishing:

• the identity of the complainant;
• the identity of the representative;
• authority to act;
• scope of the authority; and
• other information necessary to prevent unauthorised disclosure.

Businesses, Agencies and Resellers

A business, agency or reseller may submit a Complaint concerning its own contractual relationship with Famepify.

Where the Complaint concerns the personal information or independent rights of the reseller’s customer, additional authority may be required.

08How to Submit a Complaint

Official Complaint Channels

A Complaint may be submitted through an official Famepify support or complaint channel made available for that purpose.

Where a dedicated Complaint form is provided on the Complaints page, that form should be used for formal Complaint submissions.

Complaints may also be submitted by email to:

Failure to use the suggested subject line shall not invalidate an otherwise identifiable Complaint.

Information to Include

A Complaint should contain sufficient information to identify and investigate the matter.

Relevant information may include:

• complainant’s name;
• registered email address;
• Account username or identifier;
• Order ID;
• Payment reference;
• refund reference;
• support ticket reference;
• date of relevant event;
• description of the issue;
• remedy requested;
• relevant screenshots;
• relevant correspondence; and
• other evidence reasonably necessary to investigate the matter.

The complainant shall not be required to provide information unrelated to the Complaint.

09Complaint Acknowledgement

Acknowledgement Standard

Famepify shall ordinarily aim to acknowledge a properly submitted formal Complaint within five Business Days.

Acknowledgement may include:

• confirmation that the Complaint has been received;
• Complaint reference where available;
• indication of the category assigned;
• request for missing information; or
• information concerning the next stage of review.

Acknowledgement does not constitute acceptance of the complainant’s allegations.

Automatic Acknowledgements

An automated acknowledgement may confirm receipt but shall not constitute substantive resolution of the Complaint.

10Complaint Classification

Initial Triage

After receipt, a Complaint may be classified according to its primary subject matter.

Classification may include:

• ordinary Service complaint;
• refund dispute;
• payment dispute;
• Wallet dispute;
• Account enforcement review;
• privacy matter;
• security matter;
• intellectual-property matter;
• API or reseller matter;
• suspected fraud;
• legal claim; or
• another relevant category.

Multiple Issues in One Complaint

A Complaint may involve more than one category.

Where practicable, related issues should be considered together to avoid unnecessary duplication.

Where materially different procedures or legal deadlines apply, the Complaint may be divided into separate workstreams.

For example, one communication may contain both:

• a refund dispute; and
• a statutory privacy access request.

The refund component shall be governed by the Refund Policy while the privacy-rights component shall remain subject to the Data Rights Policy and applicable statutory response periods.

11Priority and Urgent Complaints

Immediate Risk Matters

Certain Complaints may require urgent handling where they concern:

• suspected unauthorised Account access;
• active payment fraud;
• stolen payment instruments;
• security compromise;
• active disclosure of personal data;
• credible threats;
• active malicious access;
• child-safety concerns;
• serious ongoing financial loss; or
• another material and immediate risk.

Urgent handling does not mean that Famepify shall determine the underlying legal merits before sufficient evidence is available.

Temporary protective action may be taken while investigation continues.

12Complaint Investigation

Good-Faith Review

Famepify shall review a Complaint in good faith having regard to the available information and applicable contractual and legal requirements.

The investigation may consider:

• Account records;
• Order history;
• Service descriptions;
• supplier records;
• API records;
• Wallet ledger;
• Payment Provider records;
• bank reconciliation information;
• refund history;
• chargeback status;
• support correspondence;
• Complaint correspondence;
• technical logs;
• security records;
• screenshots;
• uploaded documents;
• relevant Policies; and
• other information reasonably connected to the Complaint.

Relevant Evidence

The weight given to evidence shall depend upon:

• reliability;
• source;
• consistency;
• contemporaneous records;
• technical integrity;
• independent confirmation;
• relationship to the disputed event; and
• any indication of alteration or incompleteness.

A customer screenshot shall not automatically override reliable transaction or technical records.

Equally, an internal Famepify record shall not automatically be treated as infallible where credible contrary evidence exists.

13Opportunity to Provide Information

Additional Information Requests

Where additional information is reasonably necessary, Famepify may request clarification or supporting evidence from the complainant.

The request shall be proportionate to the matter under investigation.

Examples may include:

• Payment reference;
• Order ID;
• transaction date;
• relevant URL;
• screenshot;
• Account information;
• correspondence;
• proof of ownership;
• relevant timing information; or
• another material fact.

No Unnecessary Burden

A complainant shall not be required to provide evidence that Famepify already possesses where the information can reasonably be identified internally.

Famepify shall not intentionally create unnecessary procedural barriers for the purpose of discouraging Complaints.

14Identity Verification

When Verification May Be Required

Reasonable identity or ownership verification may be required where a Complaint seeks:

• disclosure of confidential Account information;
• Account restoration;
• payment redirection;
• External Refund;
• Account ownership transfer;
• sensitive privacy information;
• credential changes; or
• another action carrying material fraud or security risk.

Proportionate Verification

Verification shall be proportionate to the risk.

Famepify shall not require disclosure of:

• banking PINs;
• card PINs;
• OTPs;
• full online-banking passwords;
• cryptocurrency private keys;
• seed phrases; or
• unrelated authentication secrets.

15Supplier and Third-Party Information

External Service Providers

Certain Complaints may require information from:

• payment processors;
• banks;
• social media Service suppliers;
• hosting providers;
• API providers;
• telecommunications providers; or
• other relevant third parties.

A third party’s response may form part of Famepify’s investigation.

Third-Party Decisions Are Not Automatically Conclusive

Famepify may rely upon credible third-party records but shall not treat an upstream supplier’s position as automatically determinative where:

• credible contradictory evidence exists;
• Famepify has independent contractual obligations;
• applicable consumer law provides a remedy; or
• the dispute concerns Famepify’s own conduct.

For example, an upstream supplier’s refusal to refund Famepify does not automatically eliminate a refund right that Famepify is legally required to provide to the customer.

16Complaint Handling Timeframes

Ordinary Complaints

Famepify shall aim to investigate and provide a substantive response to an ordinary Complaint within ten Business Days after the Complaint contains sufficient information for meaningful review.

This is an internal service standard and does not replace a shorter period required by applicable law.

Complex Complaints

A Complaint may require additional time where it involves:

• multiple transactions;
• multiple Orders;
• supplier investigation;
• Payment Provider investigation;
• fraud;
• security analysis;
• chargebacks;
• Account ownership disputes;
• substantial technical records;
• privacy issues;
• regulatory involvement;
• legal advice; or
• another materially complex issue.

Where a Complaint cannot reasonably be concluded within the ordinary timeframe, Famepify should provide an update where practicable.

The update may identify:

• the reason further review is required;
• information still outstanding;
• current status; and
• an indicative next step.

No Artificial Delay

A Complaint shall not remain unresolved merely because an internal status remains marked as “pending”, “under review” or another non-final designation.

Reasonable progress shall be made toward a substantive outcome.

Statutory Deadlines

Where a particular matter is subject to a statutory deadline, the applicable legal deadline shall prevail.

For example, qualifying Data Rights Requests remain subject to the response rules stated in the Data Rights & Privacy Requests Policy and any applicable privacy law.

17Resolution Options

Available Remedies

Where a Complaint is upheld wholly or partly, an appropriate remedy may include:

• explanation;
• correction of inaccurate information;
• correction of an Account record;
• completion of an outstanding Service;
• re-performance;
• replacement;
• refill;
• Wallet adjustment;
• refund;
• partial refund;
• Payment reconciliation;
• reversal of an erroneous charge;
• restoration of Account access;
• removal of an inappropriate restriction;
• reconsideration of an enforcement decision;
• correction of support information;
• apology where appropriate;
• procedural improvement; or
• another remedy reasonably suited to the circumstances.

The appropriate Remedy shall depend upon the underlying legal and factual position.

No Automatic Monetary Compensation

The existence of a valid Complaint shall not automatically create an entitlement to monetary compensation beyond:

• the amount properly refundable;
• loss for which Famepify is legally liable;
• compensation expressly agreed; or
• another remedy required by applicable law.

A service failure may be capable of correction, completion, replacement or partial refund rather than full monetary reimbursement depending upon the circumstances.

18Complaint Outcomes

Complaint Upheld

A Complaint may be upheld where the available evidence establishes that Famepify:

• made an error;
• failed to perform an applicable obligation;
• handled the matter incorrectly;
• provided materially inaccurate information;
• failed to apply an applicable Policy correctly; or
• otherwise owes the complainant an appropriate Remedy.

Complaint Partially Upheld

A Complaint may be partially upheld where:

• some allegations are established and others are not;
• only part of a Service failed;
• only part of the amount claimed is recoverable;
• Famepify and the complainant each contributed materially to the outcome; or
• another circumstance justifies partial redress.

Complaint Not Upheld

A Complaint may be rejected where the available evidence establishes that:

• Famepify complied with the applicable agreement;
• the requested outcome is not contractually or legally available;
• the Service was properly performed;
• the issue was caused by the complainant;
• no Famepify transaction can be verified;
• the allegation is materially unsupported; or
• another valid reason applies.

A rejection shall not be based solely upon a desire to avoid cost.

Unable to Determine

In limited circumstances, available evidence may be insufficient to establish the disputed facts reliably.

Where a Complaint cannot reasonably be determined, Famepify may explain:

• what evidence was available;
• what material information remains unavailable;
• why a definitive conclusion could not be reached; and
• any further options available.

19The Final Response

Contents of a Final Response

A Final Response should contain sufficient information to communicate the outcome of the Complaint.

Where appropriate, the response may state:

• Complaint issue;
• material findings;
• decision;
• Remedy offered;
• reason for the decision;
• steps required from the complainant;
• applicable internal review procedure; and
• external rights where relevant.

The level of detail may be limited where fuller disclosure would compromise:

• security;
• another person’s privacy;
• fraud detection;
• legal privilege;
• confidential supplier information;
• law-enforcement activity; or
• another protected interest.

No Requirement for Legalistic Language

A Final Response may be written in plain language.

The fact that this Policy is a formal legal document does not require Famepify to communicate routine Complaint outcomes in unnecessarily technical language.

20Internal Review

Grounds for Further Review

A complainant dissatisfied with a Final Response may request Internal Review where there is a reasonable basis for reconsideration.

Relevant grounds may include:

• new material evidence;
• factual error;
• mistaken identity;
• incorrect transaction attribution;
• failure to consider material evidence;
• incorrect application of a Famepify Policy;
• inconsistent treatment of materially identical records;
• disproportionate enforcement action; or
• another material procedural or substantive error.

Review Requests Based Solely on Disagreement

A complainant may disagree with a decision.

However, repeated submission of the same information without identifying a material reason for reconsideration shall not necessarily require unlimited successive reviews.

Famepify may treat a reasoned Internal Review as the final internal stage unless additional material evidence later becomes available.

Independence of Review

Where reasonably practicable, an Internal Review should be conducted by:

• a different support representative;
• a more senior decision-maker;
• another authorised reviewer; or
• another person capable of independently reconsidering the original decision.

This shall not require a separate corporate department where Famepify’s organisational size does not make such separation reasonably practicable.

Internal Review Outcome

An Internal Review may:

• uphold the original decision;
• vary the decision;
• reverse the decision;
• increase or reduce a Remedy where legally appropriate;
• require additional investigation; or
• refer the matter to another specialised process.

21Complaint Escalation and Exhaustion

Internal Resolution Is Encouraged

Famepify encourages complainants to permit a reasonable opportunity for direct resolution where practical.

Direct engagement can often resolve:

• payment errors;
• Service disputes;
• Wallet discrepancies;
• refund issues;
• Account restrictions; or
• customer-support misunderstandings

without the need for external proceedings.

Internal Process Is Not an Unlawful Barrier

Nothing in this Policy shall be interpreted as requiring a consumer to surrender or waive an external legal remedy.

Where applicable law permits a consumer to:

• complain to a regulator;
• approach an industry-sector regulator;
• file a complaint with the FCCPC; or
• commence proceedings before a court,
• this Policy shall not remove that right.

22Federal Competition and Consumer Protection Commission

Consumer Complaints to the FCCPC

Consumers may have rights under the Federal Competition and Consumer Protection Act 2018 (“FCCPA”) to seek redress through the Federal Competition and Consumer Protection Commission (“FCCPC”).

Where applicable, a consumer may submit a Complaint to the FCCPC concerning alleged conduct inconsistent with consumer-protection law.

Famepify’s internal complaint process shall not operate as a waiver of that right.

Direct Engagement Before FCCPC Escalation

FCCPC complaint guidance generally encourages consumers to first engage the provider of the relevant product or Service.

Accordingly, use of Famepify’s internal Complaint process may assist by creating a documented opportunity for direct resolution.

However, the legal rights available under the FCCPA shall ultimately be determined by applicable law rather than solely by this Policy.

FCCPC Complaint Information

A complainant escalating a matter externally may be required by the FCCPC to provide information such as:

• identity of the undertaking complained against;
• transaction information;
• amount involved where relevant;
• requested redress;
• receipts;
• agreements;
• correspondence; and
• other supporting documents.

Famepify recommends retaining material transaction and complaint records for this purpose.

23Sector Regulators

Applicable Industry Regulators

Certain matters may fall within the jurisdiction of another regulator.

Where applicable law permits or requires referral to an industry-sector regulator, the complainant may exercise that right.

Examples may include matters relating to:

• financial institutions;
• Payment Providers;
• telecommunications;
• data protection; or
• another regulated industry.

The relevant regulator shall depend upon the subject matter of the Complaint and legal jurisdiction.

Separate Responsibility of Payment Providers

Where a Complaint concerns conduct independently attributable to a bank, card issuer, Payment Provider or another regulated financial institution, the complainant may also have rights under that provider’s complaint process and applicable financial regulation.

Famepify shall not represent that it can determine every dispute concerning an independent financial institution.

24Nigeria Data Protection Commission

Privacy Complaints

A Complaint alleging violation of applicable Nigerian data-protection law may be submitted to the Nigeria Data Protection Commission (“NDPC”) where the applicable statutory requirements are satisfied.

The internal Famepify Privacy Request or Complaint process shall not eliminate that right.

Privacy complaints are governed further by the Data Rights & Privacy Requests Policy.

25Courts and Judicial Remedies

Right to Seek Judicial Redress

Nothing in this Policy shall prevent a person from approaching a court of competent jurisdiction where applicable law permits such proceedings.

The use of Famepify’s Complaint process shall not constitute a waiver of a right to seek judicial redress.

Likewise, failure to complete every internal stage shall not create a contractual bar to court proceedings where applicable law provides a direct right of action.

26Alternative Dispute Resolution

Negotiated Resolution

Famepify and a complainant may attempt to resolve a dispute through good-faith negotiation.

Any settlement reached shall be governed by its agreed terms.

Mediation or Conciliation

Where appropriate, the parties may mutually agree to mediation, conciliation or another recognised alternative dispute-resolution procedure.

Participation shall be subject to:

• mutual agreement;
• applicable law;
• the rules of the chosen mediator or institution; and
• any written terms governing the process.

No Automatic Mandatory Arbitration

This Policy does not impose mandatory private arbitration upon every Famepify consumer dispute.

No User shall be treated as having waived a statutory right to regulatory or judicial redress merely by accepting this Policy where such waiver would be unlawful.

If Famepify and another party separately agree to arbitration for a particular commercial dispute, the legal effect of that agreement shall depend upon its terms and applicable law.

27Informal Settlement Communications

Settlement Offers

Famepify may propose a commercial settlement to resolve a Complaint without admitting legal liability.

Likewise, a complainant may propose a compromise.

A settlement proposal shall not automatically constitute:

• admission of wrongdoing;
• admission of liability;
• waiver of legal rights;
• acceptance of every allegation; or
• precedent governing another Complaint.

Where a settlement is accepted, its terms may become binding to the extent permitted by law.

28Complaints Involving Refunds

Refund Eligibility Remains Governed by the Refund Policy

A Complaint concerning money shall not alter the underlying principles governing refund eligibility.

Where the complainant seeks a refund, relevant matters may include:

• extent of Service delivery;
• Order status;
• Customer-Funded Balance;
• Promotional Credit;
• duplicate recovery;
• Payment reversals;
• chargebacks;
• customer-caused issues; and
• applicable consumer rights.

The complete refund framework is contained in the Refund Policy.

Refund Complaint Versus Refund Request

A Refund Request asks whether money should be returned.

A Refund Complaint challenges:

• the way the Refund Request was handled;
• the amount approved;
• refusal of the refund;
• unreasonable delay;
• refund destination;
• calculation; or
• another refund-related decision.

The two processes may therefore involve the same transaction but perform different functions.

29Complaints Involving Service Delivery

Service Evidence

A Service Complaint may require review of:

• original Service description;
• destination submitted;
• start count;
• completion count;
• supplier status;
• estimated delivery information;
• applicable refill terms;
• Order history;
• username changes;
• destination availability;
• overlapping Orders; and
• other material circumstances.

Service Delay

The fact that an estimated delivery period has passed does not automatically establish failure.

However, a materially unresolved Order shall not be left open indefinitely without reasonable investigation.

Where continued performance is no longer reasonable, an appropriate Remedy shall be considered under the Terms of Service and Refund Policy.

30Complaints Involving Payments

Payment Reconciliation

A Payment Complaint may require reconciliation against:

• Payment Provider records;
• bank information;
• transaction references;
• Wallet credits;
• reversals;
• refunds;
• chargebacks; and
• related Orders.

A bank debit alone does not necessarily establish that Famepify received settled funds.

Conversely, a technical failure to credit a Wallet does not extinguish a Payment that can be verified as received.

31Complaints Involving Chargebacks

Chargebacks and Internal Complaints May Coexist

Opening a chargeback does not automatically prohibit a Complaint.

However, where a chargeback may result in recovery of the same monetary amount sought through Famepify, monetary resolution may be coordinated to prevent duplicate reimbursement.

No Retaliation for Genuine Chargebacks

A User shall not be penalised merely because a genuine payment dispute was raised in good faith.

Separate action may nevertheless be taken where credible evidence establishes fraudulent chargeback abuse.

32Complaints Involving Account Enforcement

Review of Suspension or Termination

A User may challenge an Account restriction, suspension or termination by presenting information indicating that the decision may have been incorrect or disproportionate.

Relevant information may include:

• explanation of the disputed activity;
• proof of Account ownership;
• evidence concerning the Payment;
• security information;
• evidence of mistaken identity;
• evidence concerning API activity; or
• another fact relevant to the enforcement decision.

Security-Sensitive Decisions

Famepify may decline to disclose specific anti-fraud or security techniques where disclosure could enable circumvention.

A security-sensitive explanation may therefore describe the general basis of the decision without disclosing:

• detection thresholds;
• fraud scoring;
• security architecture;
• confidential provider information; or
• another detail whose disclosure would create material risk.

33Complaints Concerning Staff Conduct

Professional Conduct

Complaints concerning support or staff conduct shall be assessed separately from the merits of the underlying transaction where appropriate.

A complainant may raise concerns regarding:

• abusive communication;
• discriminatory treatment;
• improper refusal to assist;
• deliberate misinformation;
• disclosure of confidential information;
• retaliation; or
• other material misconduct.

Customer Conduct Does Not Automatically Defeat a Valid Complaint

The fact that a complainant communicated angrily or critically shall not automatically invalidate an otherwise legitimate Complaint.

Serious threats, harassment or other prohibited conduct may nevertheless be addressed under the Acceptable Use Policy independently from the merits of the underlying Complaint.

34Complaints Concerning Privacy

Privacy Complaint Handling

Where a Complaint alleges unlawful processing of personal data, Famepify shall consider:

• applicable privacy law;
• lawful basis;
• purpose of processing;
• Data Subject rights;
• consent where relevant;
• disclosure;
• retention;
• security;
• international transfers; and
• applicable regulator rights.

Where the communication also constitutes a Data Rights Request, the applicable statutory process shall run independently as required.

35Complaints Concerning Third-Party Platforms

Independent Platform Decisions

Famepify does not control independent actions taken by third-party social media platforms.

Accordingly, a Complaint shall distinguish between:

• Famepify’s own Service performance; and
• independent action taken by a third-party platform.

Examples of third-party actions may include:

• Account suspension;
• content removal;
• engagement adjustment;
• algorithm changes;
• metric recounting;
• monetisation decisions;
• recommendation changes; or
• platform-wide technical outages.

Famepify shall remain responsible for its own contractual obligations notwithstanding reliance upon third parties.

36Complaints Made Through Public Channels

Social Media and Public Reviews

A customer may express dissatisfaction publicly.

A public review, social media post or public comment shall not automatically constitute a formal Complaint submitted through this Policy.

Where Famepify becomes aware of a public Complaint, it may invite the complainant to provide transaction-specific information through a private official channel.

Protection of Personal Information

Famepify should avoid requesting sensitive transaction or identity information publicly.

Complaint handling involving:

• Payment references;
• Account details;
• personal information;
• bank information; or
• other confidential material

should be moved to an appropriate private channel.

37Anonymous Complaints

Anonymous Information

Famepify may consider anonymous reports where sufficient information exists to investigate a matter.

However, anonymous reporting may limit the ability to:

• verify the complainant’s connection to the issue;
• disclose confidential findings;
• provide Account-specific remedies;
• process refunds;
• change an Account;
• verify ownership; or
• seek clarification.

A Complaint seeking a personal Remedy will ordinarily require sufficient identity verification.

38Complaints From Vulnerable Consumers

Reasonable Accessibility

Where Famepify is reasonably aware that a complainant requires assistance because of disability, communication difficulty or another material vulnerability, reasonable efforts should be made to facilitate access to the Complaint process where practicable.

This may include allowing:

• an authorised representative;
• alternative written communication;
• simplified explanation; or
• another reasonable adjustment.

No additional fee shall be imposed merely because reasonable complaint accessibility is required.

39Complaint Costs

No Complaint Submission Fee

Famepify shall not charge a fee merely for submitting an ordinary Complaint.

This does not require Famepify to bear:

• the complainant’s independent legal costs;
• third-party professional fees;
• bank charges imposed independently;
• internet or telecommunications costs; or
• other costs not caused or assumed by Famepify.

Any award of recoverable legal or regulatory costs shall remain subject to applicable law or a competent decision-maker.

40Complaint Records

Recordkeeping

Famepify may maintain records of Complaints for purposes including:

• investigation;
• customer support;
• quality control;
• regulatory compliance;
• fraud prevention;
• dispute management;
• litigation;
• trend analysis;
• staff training;
• policy improvement; and
• demonstrating how a Complaint was handled.

Complaint records may include:

• complainant information;
• transaction references;
• Complaint category;
• evidence;
• correspondence;
• findings;
• decision;
• Remedy;
• review outcome; and
• closure date.

Retention

Complaint information shall be retained only for so long as an applicable lawful purpose exists.

Retention shall be governed by the Privacy Policy and applicable law.

41Confidentiality

Complaint Information

Famepify shall process Complaint information in accordance with applicable confidentiality, privacy and security obligations.

Complaint information may be disclosed where reasonably necessary to:

• investigate the matter;
• obtain supplier information;
• consult professional advisers;
• process a Payment dispute;
• respond to a regulator;
• comply with law;
• defend a legal claim; or
• implement a Remedy.

No Absolute Confidentiality Guarantee

A Complaint cannot necessarily be treated as absolutely confidential where investigation requires disclosure to:

• affected service providers;
• Payment Providers;
• regulators;
• courts;
• professional advisers; or
• other lawful recipients.

Disclosure shall remain limited to what is reasonably necessary or legally required.

42Legal Privilege

Protected Legal Communications

Nothing in this Policy shall require Famepify to disclose information protected by legal professional privilege or another legally recognised protection.

The existence of privileged advice shall not prevent Famepify from providing a reasonable explanation of a Complaint decision where required.

43Conflicts of Interest

Fair Review

Where reasonably practicable, a person with a direct personal conflict concerning a Complaint should not be the sole final decision-maker for that Complaint.

Ordinary operational involvement in the original transaction shall not necessarily constitute a disqualifying conflict.

44Complaint Analytics and Systemic Issues

Repeated Complaint Patterns

Famepify may analyse aggregated Complaint information to identify:

• recurring Service failures;
• supplier problems;
• payment issues;
• confusing Service descriptions;
• technical defects;
• refund patterns;
• support shortcomings;
• security risks; or
• other systemic issues.

Where a recurring issue is identified, appropriate corrective action may include:

• changing Service descriptions;
• suspending a supplier;
• updating systems;
• changing support procedures;
• correcting legal wording;
• improving payment reconciliation;
• improving user education; or
• another appropriate operational measure.

Complaint Resolution Does Not End Systemic Responsibility

Resolving an individual Complaint shall not necessarily be sufficient where Famepify becomes aware of a material systemic issue affecting multiple customers.

Reasonable steps should be taken to address the wider cause where practicable.

45No Retaliation

Right to Complain

Famepify shall not:

• suspend an Account;
• terminate an Account;
• restrict a User;
• deny a legitimate refund;
• degrade Service;
• retaliate through support; or
• otherwise materially disadvantage a person

solely because the person submitted a genuine Complaint, challenged a decision, contacted a regulator or exercised a lawful consumer right.

This provision does not prevent independent enforcement arising from:

• fraud;
• chargeback abuse;
• threats;
• security violations;
• Acceptable Use violations;
• unpaid amounts; or
• another legitimate reason unrelated to the Complaint itself.

46False and Fraudulent Complaints

Good-Faith Complaints Are Protected

A Complaint shall not be classified as false merely because:

• Famepify disagrees with it;
• evidence is ultimately insufficient;
• the complainant misunderstood a transaction;
• the Complaint is unsuccessful; or
• the complainant strongly criticises Famepify.

Deliberately Fabricated Complaints

A materially fabricated Complaint may constitute abuse where the complainant knowingly submits:

• altered payment evidence;
• false screenshots;
• fabricated delivery records;
• false identity information;
• knowingly false fraud allegations;
• duplicate recovery claims; or
• other deliberately falsified evidence.

Such conduct may be addressed under the Acceptable Use Policy.

47Repetitive Complaints

Repeated Contact About the Same Matter

Famepify may consolidate repeated Complaints concerning substantially the same facts.

A complainant shall not lose the right to a fair response merely because the issue required multiple follow-ups.

However, once:

• the Complaint has been investigated;
• a Final Response has been issued;
• an Internal Review has been completed where applicable; and
• no materially new evidence has been provided,
• Famepify may decline to repeatedly reopen the same Complaint.

The complainant shall remain free to exercise any applicable external remedy.

48Closing a Complaint

Complaint Closure

A Complaint may be closed where:

• the requested issue has been resolved;
• the complainant accepts the Remedy;
• a Final Response has been issued;
• Internal Review has been completed;
• necessary information has not been provided after reasonable attempts to obtain it;
• the matter has moved into litigation or another external process requiring separate handling;
• the Complaint has been withdrawn; or
• another reasonable closure basis applies.

Closure of the internal Complaint shall not erase underlying transaction or Complaint records that remain lawfully required.

Reopening a Complaint

A closed Complaint may be reconsidered where materially new evidence becomes available or a significant factual or procedural error is identified.

Repeated requests based solely upon the same information need not result in indefinite reopening.

49Preservation of Evidence

Complaint-Related Holds

Where a Complaint reasonably gives rise to a dispute, investigation, chargeback, regulatory matter or foreseeable legal claim, Famepify may preserve relevant records beyond ordinary operational periods where lawful.

Such records may include:

• transaction information;
• Order records;
• Wallet ledger;
• emails;
• support communications;
• technical logs;
• security records;
• supplier responses; and
• documents submitted by the complainant.

A preservation hold shall not authorise unrelated use of the retained information.

50Interaction With Legal Proceedings

Existing Proceedings

Where formal litigation, regulatory proceedings or another external adjudicatory process has commenced concerning the same dispute, Famepify may determine that continued internal Complaint handling should be:

• continued;
• coordinated;
• suspended; or
• concluded,
• depending upon the circumstances and advice concerning the external process.

Nothing in this provision shall be used to obstruct lawful regulatory or judicial proceedings.

51Governing Law

Nigerian Law

This Policy shall be governed principally by the laws of the Federal Republic of Nigeria.

Subject to any mandatory right that cannot lawfully be excluded, the courts located in Abuja, Nigeria shall have jurisdiction over any dispute arising out of or in connection with this Policy.

Nothing in this clause shall exclude mandatory consumer, privacy or other rights that apply under another jurisdiction.

52Relationship With Consumer Protection Law

Federal Competition and Consumer Protection Act

Nothing in this Policy shall exclude a right available under the Federal Competition and Consumer Protection Act 2018.

Where applicable, a consumer may seek to enforce a right or resolve a dispute through mechanisms recognised under the FCCPA.

This may include direct engagement with the undertaking, referral to an applicable industry-sector regulator, complaint to the FCCPC or recourse to a court of competent jurisdiction as provided by applicable law.

Consumer Remedies

Where applicable law provides a consumer with a remedy concerning defective, materially delayed, unperformed or improperly performed Services, Famepify shall not use this Complaint procedure to contractually extinguish that remedy.

Internal procedures are intended to facilitate resolution rather than reduce statutory protection.

53Relationship With the Terms of Service

Contractual Disputes

The Terms of Service govern the general contractual relationship between Famepify and Users.

This Policy establishes the procedural framework for handling Complaints arising from that relationship.

54Relationship With the Refund Policy

Refund Disputes

The Refund Policy determines eligibility for refunds, Wallet restoration, External Refund and related remedies.

This Policy provides a mechanism to challenge the handling or outcome of a refund matter.

55Relationship With the Billing, Wallet & Payment Policy

Payment Complaints

The Billing, Wallet & Payment Policy governs Payment, Wallet and billing mechanics.

A Complaint concerning those matters shall be interpreted together with that Policy.

56Relationship With the Acceptable Use Policy

Enforcement Appeals

The Acceptable Use Policy governs prohibited conduct and enforcement.

A User challenging an enforcement decision may use the Complaint process established here.

57Relationship With Privacy Policies

Privacy Complaints and Rights

The Privacy Policy, Data Rights & Privacy Requests Policy and GDPR & International Privacy Rights Policy govern privacy matters.

Where a Complaint also involves a statutory privacy right, the applicable privacy procedure and deadline shall continue to apply.

58Changes to This Policy

Policy Amendments

Famepify may update this Policy to reflect:

• changes in law;
• regulatory guidance;
• changes to complaint channels;
• changes to internal review procedures;
• changes to Platform functionality;
• improvements to customer redress;
• new Services;
• payment-system changes; or
• other legitimate operational developments.

The Last Updated date shall identify the current version.

Existing Complaints

A procedural update may apply to an existing Complaint where doing so does not unfairly remove an accrued right or materially prejudice the complainant.

No later Policy amendment shall be used to retrospectively remove a Remedy required by law.

59Mandatory Law

Mandatory Rights Prevail

Where this Policy conflicts with a mandatory requirement of applicable law, the mandatory legal requirement shall prevail to the extent of the conflict.

Nothing in this Policy shall be interpreted as:

• requiring waiver of consumer rights;
• preventing a complaint to the FCCPC;
• preventing a complaint to the NDPC;
• preventing access to an applicable industry regulator;
• preventing genuine chargebacks;
• preventing judicial redress;
• requiring mandatory arbitration where none has lawfully been agreed;
• allowing retaliation for a genuine Complaint; or
• permitting Famepify to retain money contrary to applicable law.

60Severability

Invalid Provisions

If any provision of this Policy is determined by a competent authority to be unlawful, invalid or unenforceable, the remaining provisions shall continue to apply to the fullest extent permitted by law.

The affected provision shall be modified only to the minimum extent necessary to preserve its lawful purpose.

61No Waiver

Failure to Enforce

Failure by Famepify to rely upon a contractual right during one Complaint shall not automatically constitute permanent waiver of that right.

Likewise, a Remedy granted in one matter shall not necessarily create an entitlement to the same Remedy in another matter involving materially different facts.

62Contact and Complaint Submission

Formal Complaints

Formal Complaints may be submitted through the Complaint mechanism made available on this page or through:

Where the Complaint concerns a specific Account, Order, Payment or refund, sufficient reference information should be provided to enable identification of the matter.

Refund Requests

Formal requests seeking an External Refund shall be submitted through:

Privacy Requests

Privacy rights requests shall be submitted in accordance with the Data Rights & Privacy Requests Policy.

Legal Centre

The complete Famepify legal framework is available through the Famepify Legal Centre.

Related policies include:

63Final Legal Effect

Complaint Resolution Does Not Remove Legal Rights

This Policy is intended to provide a practical, fair and documented mechanism through which Famepify can receive, investigate and resolve Complaints.

Nothing in this Policy shall be interpreted as:

• making Famepify the sole judge of a consumer’s legal rights;
• preventing a complainant from challenging a Famepify decision;
• preventing the submission of a complaint to the FCCPC;
• preventing a privacy complaint to the NDPC;
• preventing use of an applicable sector regulator;
• preventing access to a court where legally available;
• requiring waiver of a genuine chargeback right;
• requiring acceptance of a proposed settlement;
• permitting retaliation for a good-faith Complaint;
• converting silence into acceptance of a decision;
• extinguishing an applicable refund right;
• authorising indefinite delay of a Complaint;
• allowing a supplier’s position to override a mandatory consumer remedy; or
• excluding another remedy that applicable law does not permit Famepify to exclude.

Complaints shall be determined according to the applicable facts, evidence, contractual terms, Famepify Policies, consumer rights and mandatory law.

Where Famepify has made an error, the Complaint process is intended to provide a reasonable route to correction and redress.

Where Famepify has complied with its obligations and the evidence does not establish the claimed failure, the Complaint process is intended to provide a documented explanation and a defined route for any available review or external escalation.