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Complaints Handling & Dispute Resolution Policy

1. Policy Statement

MOBILE INCORPORATED Limited (the “Company”) is committed to maintaining a fair, transparent, and efficient mechanism for the handling of customer complaints and disputes.

This Policy establishes the procedures through which complaints are received, assessed, investigated, resolved, recorded, and — where necessary — escalated to external bodies.

The Policy applies to all customers, products, services, employees, and third-party service providers acting on behalf of the Company.

2. Legal & Regulatory Basis

This Policy is implemented in accordance with:

  • The Gaming Act (Chapter 583 of the Laws of Malta)
  • Licence conditions and directives issued by the Malta Gaming Authority
  • Applicable consumer protection legislation
  • General Data Protection Regulation (EU) 2016/679 (GDPR)

The Company ensures that its complaint-handling mechanisms meet regulatory expectations relating to fairness, accessibility, accountability, and player protection.

3. What Constitutes a Complaint

A complaint is defined as any expression of dissatisfaction concerning:

  • Game outcomes or settlement
  • Account management decisions
  • Bonus application
  • Payment processing
  • Responsible gaming measures
  • Customer support conduct
  • Technical issues

A dispute arises where a complaint remains unresolved or the customer contests the outcome.

4. Submitting a Complaint

Customers may lodge a complaint via:

  • Email: legal@sunwin.navy

Complaints should, where possible, include:

  • Full name and account username
  • Clear description of the issue
  • Relevant transaction or game references
  • Supporting documentation

Incomplete information will not invalidate a complaint but may affect resolution timelines.

5. Internal Handling Procedure

5.1 Acknowledgment

All complaints are acknowledged within 48 hours of receipt.

The acknowledgment confirms:

  • Receipt of the complaint
  • Assigned reference number
  • Expected timeframe for resolution

5.2 Investigation

Complaints are assessed objectively and may involve review of:

  • Game logs
  • Betting history
  • Payment records
  • Internal decision-making processes
  • Communication history

Escalation to Compliance or Responsible Gaming personnel occurs where necessary.

5.3 Resolution Timeline

The Company aims to resolve complaints within 14 business days.

Where complexity requires additional time:

  • Customers will be informed
  • A revised timeline will be provided

The final decision will be communicated in clear and reasoned form.

6. Escalation Process

6.1 Internal Escalation

If dissatisfied, customers may request escalation to Senior Management or the Compliance function within 14 days of receiving the decision.

The review will be conducted independently of the initial assessment where practicable.

6.2 External Resolution

If a complaint remains unresolved, customers may refer the matter to:

  • The Malta Gaming Authority
  • An Alternative Dispute Resolution (ADR) entity approved by the MGA
  • The competent courts of Malta

The Company will cooperate fully with regulatory or ADR investigations.

7. Responsible Gaming Prioritisation

Complaints involving:

  • Self-exclusion
  • Underage gambling
  • Gambling harm indicators
  • Player protection breaches

are treated as priority cases and escalated immediately to trained personnel.

Corrective measures are implemented where regulatory breaches are identified.

8. Complaints Register & Record Retention

All complaints are recorded in a secure internal register including:

  • Date of receipt
  • Nature of complaint
  • Investigation actions
  • Outcome
  • Time to resolution

Records are retained for a minimum of five (5) years and made available to the MGA upon request.

9. Confidentiality & Data Handling

All complaint information is treated confidentially and processed in accordance with GDPR and the Company’s data protection framework.

10. Staff Training and Awareness

Employees responsible for handling complaints and disputes will receive appropriate training to ensure effective, fair, and compliant complaint resolution. This Policy will be made available to staff and customers via the Company’s website or upon request.

11. Governance & Review

This Policy is approved by senior management and reviewed annually or earlier where regulatory changes require amendment.