Complaints and Dispute Resolution Policy

This Complaints and Dispute Resolution Policy explains how you may raise a complaint concerning ArvoSim and how we will review, investigate and respond to it.

It applies to complaints concerning:

• an ArvoSim Account;
• Wallet Top-Ups or Wallet Balance;
• payment processing;
• an eSIM Order;
• delivery of an eSIM QR code;
• installation or activation;
• network connectivity;
• data usage;
• cancellation or refund decisions;
• Account restrictions or closure;
• privacy and personal data;
• Website functionality;
• customer support; or
• another aspect of the ArvoSim Service.

Our aim is to resolve complaints fairly, promptly and proportionately before they develop into formal disputes.

This Policy forms part of the ArvoSim Terms and Conditions and should be read together with our:

• Terms and Conditions;
• eSIM Delivery and Activation Policy;
• Refund and Cancellation Policy;
• Payment and Wallet Policy;
• Privacy Policy;
• Cookie Policy; and
• Acceptable Use Policy.

ArvoSim is operated by ELVORIN LTD, company number 17344051, Dept 6946, 196 High Road, Wood Green, London, United Kingdom, N22 8HH. Email: info@arvosim.com. Website: arvosim.com.

In this Policy, "ArvoSim", "we", "us" and "our" refer to ELVORIN LTD.

A complaint is an expression of dissatisfaction about:

• the Service provided by ArvoSim;
• a failure to provide an expected service;
• an action or decision taken by ArvoSim;
• the conduct of our customer support;
• the handling of an Order, payment or refund;
• the use of personal data; or
• another matter for which you reasonably expect an explanation, correction or remedy.

You do not need to use the word "complaint" for us to treat your message as one.

A request for ordinary technical assistance may initially be handled as a support request. If you express dissatisfaction with the handling, outcome or underlying service, it may be registered as a complaint.

A complaint may be submitted by:

• the Account holder;
• a person who completed or attempted a Wallet Top-Up;
• a purchaser or intended user of an eSIM Plan;
• a person whose personal data is processed by ArvoSim;
• an authorised representative; or
• another person directly affected by the matter.

Where a representative acts for another person, we may request reasonable evidence of:

• the representative's identity;
• the complainant's identity; and
• the representative's authority to act.

We will not disclose confidential Account, payment or personal information to an unauthorised person.

ArvoSim does not charge a fee for submitting or investigating an ordinary complaint.

You will not lose a contractual or statutory right merely because you made a complaint.

We will not penalise a user for making a genuine complaint, requesting a refund, exercising a data protection right or disputing a transaction in good faith.

Complaints should be submitted by email to: info@arvosim.com

Please use a clear subject line, such as: Complaint – Order [reference] or: Privacy Complaint – ArvoSim Account

Where possible, send the complaint from the email address associated with your Account.

Written complaints help us maintain an accurate record of:

• the issue raised;
• supporting evidence;
• communication dates;
• investigation steps; and
• the resolution offered.

To help us investigate efficiently, your complaint should include, where relevant:

• your full name;
• the email address associated with your Account;
• the Order reference;
• the Wallet or payment reference;
• the destination and eSIM Plan;
• the date of the relevant transaction or event;
• your device manufacturer and model;
• your operating-system version;
• a clear description of what happened;
• relevant screenshots or error messages;
• troubleshooting already completed;
• previous correspondence;
• the effect the problem had on you; and
• the outcome or remedy you are seeking.

You should not send:

• your full card number;
• your card security code;
• an Account password;
• a banking password;
• a one-time authentication code; or
• unnecessary sensitive personal information.

Failure to provide all requested information will not automatically invalidate a complaint, but it may delay our investigation.

We will take reasonable steps to make the complaint process accessible.

Where a person has difficulty submitting a complaint by ordinary email because of a disability, language barrier or another genuine accessibility need, they may contact us and request reasonable assistance or an alternative format.

We may also accept a complaint submitted by an authorised representative where appropriate.

Complaints involving an immediate connectivity problem during travel should be clearly marked: URGENT eSIM SUPPORT

Examples include:

• a QR code that cannot be installed shortly before travel;
• an eSIM that fails to connect at the destination;
• a materially delayed Order required for imminent travel;
• an invalid eSIM profile;
• an incorrect destination Plan; or
• an eSIM that unexpectedly stops working.

We will prioritise urgent technical issues where reasonably possible.

An urgent support request may still require:

• device information;
• screenshots;
• confirmation of settings;
• network checks;
• reasonable troubleshooting; or
• information from an eSIM or network provider.

Marking a non-urgent complaint as urgent does not guarantee immediate resolution.

We aim to acknowledge an ordinary complaint within five business days after receipt.

The acknowledgement may include:

• confirmation that the complaint has been registered;
• a reference number;
• a summary of the issue;
• the name or role of the person handling it;
• a request for additional information; and
• an indicative response timeframe.

If we provide a full resolution within the acknowledgement period, a separate acknowledgement may not be necessary.

Data protection complaints will in all cases be acknowledged within any mandatory legal period that applies.

After receiving a complaint, we will determine:

• what happened;
• which service or transaction is affected;
• whether urgent action is required;
• whether additional information is needed;
• which ArvoSim policy applies;
• whether a third-party provider must be contacted;
• whether there is a security or fraud concern;
• whether personal data is involved; and
• the appropriate person or team to investigate.

We may separate a complaint into multiple issues where this helps provide a clearer response.

Depending on the complaint, we may review:

• Account information;
• Order records;
• delivery records;
• QR-code dispatch records;
• eSIM provisioning data;
• activation and usage records;
• Wallet transactions;
• payment-provider information;
• refund records;
• Chargebacks;
• security logs;
• customer support correspondence;
• device and configuration information;
• information supplied by an eSIM provider;
• information supplied by a mobile network; and
• evidence provided by the complainant.

We will take reasonable steps to investigate fairly and will consider evidence supporting both the complainant's position and ArvoSim's position.

We may ask you to provide reasonable assistance, such as:

• confirming the affected device;
• providing an error screenshot;
• checking relevant device settings;
• confirming whether the eSIM was installed or deleted;
• attempting proportionate troubleshooting;
• confirming a transaction;
• verifying Account ownership; or
• clarifying the remedy sought.

We will not require evidence that would be impossible or unreasonably difficult for an ordinary user to obtain.

A failure to cooperate may limit our ability to resolve a technical or factual issue, but it will not remove rights that apply under mandatory law.

Before discussing confidential information or providing certain remedies, we may need to verify:

• your identity;
• Account ownership;
• access to the registered email address;
• authority to use a payment method;
• entitlement to Wallet funds; or
• authority to act for another person.

Verification measures will be proportionate to the nature and risk of the request.

We will never ask you by email to provide:

• a full payment-card number;
• a card security code;
• an online banking password; or
• a one-time banking authentication code.

Some complaints may require information or action from:

• an eSIM provisioning provider;
• a mobile network operator;
• a payment provider;
• a card issuer;
• an email-delivery provider;
• a hosting provider; or
• another technical service provider.

We remain responsible for managing your complaint concerning the ArvoSim Service, but third-party involvement may extend the time required to establish technical facts.

Where appropriate, we will keep you informed of material delays.

We aim to provide a substantive response to an ordinary complaint within 15 business days after receiving sufficient information to investigate it.

We aim to issue a final response within 30 business days.

These are service targets rather than guaranteed statutory deadlines.

A complaint may take longer where:

• it is technically complex;
• multiple transactions are involved;
• information is required from a third party;
• fraud or unauthorised activity is suspected;
• extensive records must be reviewed;
• the complainant has not yet provided required information;
• legal advice is reasonably necessary; or
• circumstances outside our reasonable control affect the investigation.

If we cannot provide a final response within 30 business days, we will aim to explain:

• why additional time is needed;
• what remains under investigation;
• whether information is required from you; and
• when the next update is expected.

Where applicable law imposes a different or shorter timeframe, the legal requirement will take priority.

During a prolonged investigation, we may provide updates concerning:

• the status of the complaint;
• additional information required;
• contact with a provider;
• temporary measures taken;
• estimated next steps; and
• the reason for any material delay.

An update may not contain confidential security, fraud-prevention or third-party information that we are not permitted to disclose.

While a complaint is being investigated, we may take proportionate temporary action, including:

• resending a delivery email;
• providing troubleshooting instructions;
• reserving disputed Wallet funds;
• pausing an unfulfilled Order;
• preventing further use of a compromised eSIM;
• temporarily restricting an Account;
• escalating an urgent provider query; or
• preserving relevant transaction and technical records.

A temporary measure does not determine the final outcome.

Depending on the complaint, we may:

• provide an explanation;
• apologise;
• correct Account information;
• correct a Wallet entry;
• resend a QR code;
• repair or reprovision an eSIM;
• issue a replacement eSIM;
• provide an equivalent Plan;
• restore funds to the Wallet Balance;
• refund an eligible Wallet Top-Up;
• return an eligible closing balance;
• provide a full or proportionate price reduction;
• remove an incorrect Account restriction;
• confirm that the original decision was correct;
• improve internal guidance;
• refer a technical issue to a provider; or
• take another remedy required by applicable law.

The remedy will depend on:

• the nature of the failure;
• whether the eSIM was used;
• the benefit received;
• the evidence available;
• the practical remedy still available;
• the relevant ArvoSim policies; and
• applicable consumer law.

Where a financial remedy is approved, it will be handled in accordance with the Refund and Cancellation Policy and Payment and Wallet Policy.

In particular:

• an approved voluntary eSIM refund will normally be restored to the Wallet Balance;
• a qualifying Wallet Top-Up refund will normally be returned to the original payment method;
• an eligible unused Cash-Funded Balance will be returned when the Account is permanently closed; and
• Promotional Credit is not ordinarily redeemable for cash.

We will not deduct an administrative fee from an approved full refund unless a fee is expressly permitted by applicable law and the relevant contract.

Where an eSIM was allegedly not delivered, we may review:

• whether the Order was accepted;
• whether the QR-code email was sent;
• the email address used;
• any bounce or rejection notice;
• spam or filtering issues;
• whether the Plan remained available;
• whether the Plan price was deducted; and
• whether the email was resent.

Where delivery cannot be established or completed, we may:

• resend the email;
• deliver to a verified replacement address;
• issue a replacement eSIM;
• provide an equivalent Plan; or
• restore the Plan price to the Wallet Balance.

For activation or connectivity complaints, we may consider:

• device compatibility;
• whether the device is carrier-unlocked;
• installation status;
• APN settings;
• data-roaming settings;
• network selection;
• destination coverage;
• Supported Network availability;
• activation records;
• data-consumption records;
• temporary outages;
• provider fault reports; and
• troubleshooting already completed.

A local variation in speed or coverage will not automatically establish that the eSIM is faulty.

A remedy may be appropriate where the Plan was materially unusable and the problem was attributable to the supplied eSIM or service.

Where you dispute data consumption, we may review:

• provider usage records;
• activation times;
• session records;
• remaining data;
• device screenshots;
• hotspot or tethering use;
• background data activity;
• software updates;
• cloud backups; and
• technical anomalies.

Network or provider records will normally be the primary evidence of consumption, but we will consider credible evidence of an error.

If you disagree with a refund decision, you should explain:

• which part of the decision you dispute;
• which facts you believe are incorrect;
• whether relevant evidence was overlooked;
• whether the eSIM was used;
• what remedy you believe is appropriate; and
• any new evidence supporting your position.

A complaint about a refund decision will be reviewed separately from the original decision where reasonably practicable.

Payment complaints may concern:

• a failed Top-Up;
• a pending authorisation;
• an incorrect amount;
• a duplicate payment;
• missing Wallet credit;
• an unauthorised payment;
• currency conversion;
• a delayed refund;
• a reversed payment;
• a Chargeback; or
• a negative Wallet Balance.

We may need to distinguish between:

• an amount received by ArvoSim;
• a pending bank authorisation;
• an issuer fee;
• an exchange-rate difference;
• a completed refund; and
• a delay within the card issuer's systems.

Some banking or card-issuer matters may need to be addressed directly with the relevant financial institution.

We encourage users who recognise a transaction but dispute the service outcome to contact us before initiating a Chargeback.

This gives us an opportunity to:

• investigate the complaint;
• correct an error;
• provide a refund where due;
• identify the relevant transaction; and
• avoid unnecessary Account restrictions.

However, nothing in this Policy prevents you from exercising rights available through your card issuer, Payment Provider or applicable law.

Where a Chargeback is already open, we may:

• provide relevant transaction evidence;
• suspend the disputed Wallet funds;
• place unfulfilled Orders on hold;
• correct an established error;
• cooperate with the Payment Provider; and
• continue trying to resolve the underlying complaint directly.

You must not knowingly seek and retain both:

• a payment reversal; and
• the corresponding Wallet credit or purchased benefit.

If your Account, eSIM, Order or Wallet has been restricted, you may request a review.

Your complaint should explain:

• which restriction is disputed;
• when it began;
• why you believe it is incorrect;
• whether your Account may have been compromised;
• whether a payment was reversed; and
• any relevant supporting information.

We may be unable to disclose detailed fraud-prevention methods or confidential provider information.

A restriction may remain in place during review where continued access would create a reasonable legal, payment, security or network risk.

An Account cannot currently be closed through a self-service function.

Requests for closure must be sent to info@arvosim.com.

A complaint may be raised if:

• a closure request was not processed;
• verification was unreasonably delayed;
• a closing balance was calculated incorrectly;
• an eligible refund was not initiated; or
• information was retained without a clear explanation.

Before closing an Account, we may need to complete verification, settle pending Orders, resolve disputes and identify the source of Wallet funds.

A data protection complaint may concern:

• inaccurate personal data;
• access to personal data;
• deletion or retention;
• direct marketing;
• cookies;
• an alleged unauthorised disclosure;
• international transfers;
• security;
• a privacy-rights request;
• automated processing; or
• another use of personal data.

Data protection complaints should be clearly marked: Data Protection Complaint

We will:

• provide a clear method for making the complaint;
• acknowledge it within 30 days at the latest;
• take appropriate steps to investigate without undue delay;
• make appropriate enquiries;
• keep the complainant informed of material progress; and
• communicate the outcome without undue delay.

Our general five-business-day acknowledgement target will normally apply, but the legal 30-day requirement remains the maximum applicable acknowledgement period.

Further information is provided in the Privacy Policy.

If you are dissatisfied with how we have handled a data protection complaint, you have the right to complain to the UK Information Commissioner's Office.

We encourage you to contact ArvoSim first so that we have an opportunity to investigate and correct the issue, but you do not need our permission before contacting the ICO.

The ICO can consider data protection matters. It does not resolve ordinary eSIM quality, Wallet or contractual disputes that do not involve personal data.

When our investigation is complete, we will provide a final response on a durable medium, normally by email.

The final response should include, where appropriate:

• a summary of the complaint;
• the material facts considered;
• the outcome;
• reasons for the decision;
• any remedy offered;
• any action required from you;
• the expected remedy timeframe;
• information about internal reconsideration;
• information about applicable ADR arrangements; and
• any other external escalation option that must be disclosed.

The response may omit confidential security controls, legally privileged material or third-party information that we are not authorised to disclose.

If you disagree with the final response, you may request one internal reconsideration.

The request should normally be submitted within 30 calendar days after the final response and should identify:

• the part of the decision disputed;
• any factual or legal error;
• information that was overlooked;
• new evidence; and
• the remedy requested.

Where reasonably practicable, the reconsideration will be handled by a person who was not solely responsible for the original final decision.

A reconsideration is not intended to repeat the entire investigation without a stated reason.

After reconsideration, we may:

• uphold the original outcome;
• change the decision;
• provide a different remedy;
• request further information;
• reopen part of the investigation; or
• confirm that the internal complaint process is exhausted.

We will explain the result on a durable medium.

Alternative Dispute Resolution, or ADR, is a method of resolving certain consumer disputes outside court with the involvement of an independent third party.

ArvoSim is not identifying a specific ADR provider in this Policy because:

• the competent provider may depend on the nature and value of the dispute;
• ADR accreditation and legal requirements may change; and
• we must not imply membership of or commitment to a scheme that has not been confirmed.

Where the internal complaint process is exhausted and applicable law requires ADR information, the final response will state:

• that ArvoSim has been unable to settle the complaint;
• the name and website of a competent ADR provider or other applicable dispute-resolution arrangement;
• whether ArvoSim is legally or contractually required to participate; and
• whether ArvoSim is prepared to participate voluntarily.

The identification of an ADR provider does not itself mean that ArvoSim has agreed to participate unless the final response expressly confirms this or participation is legally required.

Unless required by law, a contract or an applicable scheme, neither party is automatically required under this Policy to submit a dispute to ADR.

Where both parties agree to use ADR, the process will be governed by:

• the applicable ADR provider's rules;
• any legal requirements;
• the scope of the agreement to participate; and
• any binding effect properly accepted by the parties.

A Consumer will not be bound by a pre-dispute term requiring participation in a process where such a term would be unenforceable under applicable law.

UK Consumers may seek independent information about consumer rights from the Citizens Advice Consumer Service or another appropriate consumer-advice body.

Consumers located outside the United Kingdom may seek assistance from a competent consumer-protection organisation in their country of residence.

ArvoSim does not control the advice, eligibility rules or dispute procedures of independent organisations.

This Policy does not prevent either party from bringing court proceedings where legally entitled to do so.

Before commencing proceedings, the parties should, where reasonable:

• exchange sufficient information about the claim;
• identify the remedy sought;
• consider whether the dispute can be resolved directly;
• consider proportionate ADR; and
• comply with any applicable pre-action requirements.

Nothing in this section requires a user to delay urgent legal action where delay could prejudice a legal right.

The governing-law and jurisdiction provisions in the Terms and Conditions apply, subject to mandatory consumer protections.

A Consumer resident in another part of the United Kingdom or another country may have mandatory rights to:

• bring proceedings in their place of residence;
• use a local consumer-protection body;
• rely on mandatory local consumer law; or
• access another dispute-resolution procedure.

Nothing in this Policy removes rights that cannot legally be excluded.

A Business User should submit complaints through the same email address unless a separate written business agreement provides another procedure.

Consumer-specific rights and procedures apply only where the complainant qualifies as a Consumer.

Business disputes may be subject to:

• the relevant business agreement;
• the Terms and Conditions;
• agreed commercial dispute procedures; and
• the exclusive jurisdiction provisions applicable to Business Users.

Where substantially the same complaint has already received a final response and no material new information is provided, we may:

• refer the complainant to the previous response;
• decline to repeat the investigation;
• address only the new issue; or
• confirm that the internal complaint process is exhausted.

We will not classify a complaint as repetitive merely because the complainant disagrees with the outcome or requests a legitimate reconsideration.

We understand that complaints may involve frustration.

However, users must not:

• threaten violence;
• harass staff;
• use discriminatory abuse;
• send malicious content;
• deliberately overwhelm communication channels;
• impersonate another person;
• falsify evidence; or
• use complaints to facilitate fraud.

Where communications become abusive, we may:

• request that communication remain respectful;
• limit communications to writing;
• designate a single contact channel;
• restrict unnecessary repeated messages; or
• report credible threats or unlawful conduct.

We will continue to address the substantive complaint where reasonably possible.

A privacy complaint will not be rejected merely because it is inconvenient, critical or difficult.

Where applicable law permits action in response to a manifestly unfounded or excessive request, we will consider the specific circumstances and document the reasons for our decision.

Any fee, refusal or restriction will be applied only where legally permitted.

We will handle complaints with appropriate confidentiality.

Information may be shared only where reasonably necessary with:

• staff handling the complaint;
• eSIM or network providers;
• payment providers;
• professional advisers;
• regulators;
• courts;
• law-enforcement authorities; or
• another authorised recipient.

Personal data will be processed in accordance with the Privacy Policy.

We may retain records of:

• the complaint;
• evidence supplied;
• correspondence;
• investigation steps;
• provider responses;
• internal decisions;
• the remedy;
• the final response; and
• any reconsideration or external escalation.

Records may be retained where reasonably necessary for:

• complaint management;
• service improvement;
• accounting;
• fraud prevention;
• legal compliance;
• Chargebacks;
• regulatory requests; and
• legal claims.

Retention is governed by the Privacy Policy.

We may analyse complaints to identify:

• recurring technical failures;
• delivery delays;
• confusing Plan descriptions;
• payment problems;
• refund trends;
• accessibility barriers;
• provider performance;
• support-training needs; and
• possible policy improvements.

Where possible, reporting used for service improvement will be aggregated or anonymised.

An investigation, apology, goodwill credit, replacement or voluntary resolution does not by itself constitute an admission of legal liability.

This does not prevent a communication from expressly accepting responsibility where appropriate.

We may update this Policy to reflect changes to:

• the Service;
• complaint processes;
• eSIM providers;
• payment providers;
• ADR arrangements;
• data protection requirements;
• consumer law; or
• our business operations.

The updated version will be published on arvosim.com with a revised "Last updated" date.

A change will not retrospectively reduce rights relating to a complaint already submitted.

Complaints, reconsideration requests and dispute-related correspondence may be directed to ELVORIN LTD, company number 17344051, Dept 6946, 196 High Road, Wood Green, London, United Kingdom, N22 8HH.

Email: info@arvosim.com. Website: arvosim.com.