Complaints Procedure

Last updated: 26 August 2026

1. Purpose and scope

1.1. Lumivant Technologies Limited ("Lumivant", "we", "us"), company registration number 251824, registered office F2-2A, Oceanic House, Providence Estate, Mahé, Seychelles, supplies business-to-business iGaming platform software to licensed operators. This procedure sets out how to complain to us, how we handle complaints, and what to do if you are not satisfied with our answer.

1.2. This procedure is available to our operator clients, to game studios, payment providers and other suppliers and partners, and to any other person or organisation with a complaint about our own conduct, our staff, or the software and services we supply.

1.3. A complaint under this procedure means an expression of dissatisfaction that asks us to put something right — as distinct from a routine support ticket, a change request, or a commercial negotiation. Our support channels remain the right route for day-to-day technical issues, and most matters are resolved there without needing this procedure.

2. What this procedure does not cover

2.1. Player complaints. We do not operate gambling sites, hold player accounts or hold player funds. If you are a player on a site built on our platform, your complaint is a matter for the licensed operator of that site, who holds the contractual relationship with you and is responsible for answering you. Please use that operator's own complaints procedure. Section 7 explains what happens if a player contacts us directly.

2.2. Data protection. Complaints and requests about personal data are handled under our Privacy Policy, clause 10.

2.3. Responsible gaming. Concerns about responsible gaming, including self-exclusion, should be raised with the operator of the site concerned, and may also be sent to rg@lumivanttech.com. See our Responsible Gaming Policy.

2.4. Suspected financial crime. Reports of suspected money laundering, terrorist financing or sanctions breaches are handled under our AML & KYC Policy rather than as complaints, and are escalated internally on receipt.

3. How to raise a complaint

3.1. Send your complaint by email to complaints@lumivanttech.com, or by post to Lumivant Technologies Limited, F2-2A, Oceanic House, Providence Estate, Mahé, Seychelles.

3.2. To let us investigate properly, please include as much of the following as you can:

• your name, your organisation, and how we should reply to you;
• any contract, account or tenant reference that identifies the relationship;
• what happened, and the dates and times it happened;
• which part of the platform or which service the complaint concerns;
• what you would like us to do to put it right;
• any supporting material — correspondence, screenshots, reference numbers, log extracts.

3.3. You may complain in a language other than English, but doing so may extend the timeframes in section 4 while we arrange translation.

3.4. You may ask a representative — for example your legal adviser or a colleague — to complain on your behalf. We may ask for written confirmation of their authority before we disclose information to them.

4. Timeframes

4.1. We acknowledge every complaint in writing within three business days of receiving it, confirming who is handling it and how to reach them.

4.2. We aim to give a substantive written response within twenty business days of acknowledgement.

4.3. If a complaint is complex — for example it requires forensic examination of transaction or game logs, evidence from a third-party supplier, or input from more than one operator — we will tell you before the twenty business days expire, explain why we need longer, and give you a revised date. We will keep you updated at least every ten business days until the matter is closed.

4.4. Where a written agreement between us and a client sets different timeframes or an agreed service level, those contractual terms take precedence over this section for that client.

5. How we investigate

5.1. Each complaint is assigned to a named owner who was not directly involved in the matter complained of, wherever that is practicable. Complaints concerning regulatory or compliance matters are notified to management on receipt.

5.2. We review the relevant records, which may include correspondence, configuration history, transaction records, and platform and audit logs. We may need to ask you for further information, and where a complaint concerns activity on an operator's tenant we may need to involve that operator.

5.3. We handle complaints confidentially and share the details only with those who need them to investigate and resolve the matter, or where we are required to disclose them to a regulator, auditor or court. Personal data is handled in accordance with our Privacy Policy.

5.4. We do not treat a complaint as a reason to withdraw or degrade service, and raising one will not prejudice how we deal with you.

6. Our response and possible outcomes

6.1. Our substantive response will set out what we found, the reasons for our conclusion, whether we uphold the complaint in whole or in part, and what we will do about it.

6.2. Depending on the finding, the outcome may include correcting a defect or misconfiguration, changing a process or control, recovering or correcting affected records, an apology, a remedy or credit provided for under the relevant written agreement, or an explanation of why no further action is warranted.

6.3. Where the response requires work on our side, we will tell you what will be done and by when.

7. Player complaints referred to us

7.1. If a player contacts us directly, we will tell them to contact the operator of the site they play on, and — where we can identify the operator — let that operator know they have been in touch. We will not disclose account information to a player, because we hold that data on the operator's behalf and not our own.

7.2. Where an operator escalates a player matter to us because it concerns how the platform behaved — for example a disputed game outcome on a Lumivant Originals title, a wallet or transaction discrepancy, or a bonus calculation — we will investigate on the operator's instruction and provide our findings and supporting evidence, including audit and game logs, to the operator.

7.3. The operator remains responsible for responding to its player and for the final outcome of the player's complaint. Our role is to give the operator the evidence and analysis it needs.

8. If you are not satisfied

8.1. If our response does not resolve the matter, reply to complaints@lumivanttech.com within twenty business days, saying what remains unresolved. Your complaint will be reviewed at management level by someone who did not decide it the first time, and we will respond within a further twenty business days.

8.2. If a written agreement between us contains a dispute resolution or escalation clause, that clause governs what happens after the internal review is exhausted.

8.3. Nothing in this procedure limits any right you have to refer a matter to a competent regulator, or to pursue it in court. As set out in clause 13.2 of our Terms and Conditions, disputes that cannot be resolved amicably are subject to the exclusive jurisdiction of the competent courts of Anjouan, without prejudice to any dispute resolution provisions agreed in a written agreement between us and a client.

8.4. Lumivant's application for a B2B gaming service provider licence with the Anjouan Gaming Board is in progress. Once that licence is issued, complaints concerning our licensed activity may also be referred to that regulator, and this procedure will be updated with the referral route. Our current licensing status is set out on our compliance page.

9. Records and oversight

9.1. We record every complaint in a complaints register, capturing the date received, who raised it, its nature, the investigation and outcome, any remedial action, and the date it was closed.

9.2. We retain complaint records for as long as we need them to evidence how the matter was handled and to meet our legal, regulatory and licensing obligations, and then delete them.

9.3. Management reviews complaints periodically to identify recurring causes and to correct the underlying process or control, rather than only the individual case. Where a licence condition or a client agreement requires us to report complaints data, we do so.

10. Contact

10.1. Complaints: complaints@lumivanttech.com. General enquiries: contact@lumivanttech.com. Post: Lumivant Technologies Limited, F2-2A, Oceanic House, Providence Estate, Mahé, Seychelles.