Comprehensive Complaints & Alternative Dispute-Resolution (ADR) Procedure

1. Purpose & Policy Statement

SkinJoker Tech Ltd. (“SkinJoker,” “we,” “our”) is committed to providing a transparent, fair, and timely mechanism for resolving player complaints and disputes related to the cryptocurrency-based gaming services offered via skinjoker.com (the “Site”). This Procedure establishes a multi-stage complaint-handling system and an optional ADR pathway that—while not mandated by a state regulator—aligns with ISO 10002:2018 (Customer-Satisfaction Management), UKGC LCCP SR Code 6 best practice, and the EU ADR Directive 2013/11/EU.

2. Regulatory Context & Guiding Principles

Framework	Relevance
ISO 10002:2018	Complaint-management system design & continuous improvement
EU ADR 2013/11	Quality requirements for impartiality, transparency, effectiveness
UKGC LCCP SR 6	Timelines, escalation, ADR provider criteria
Hong Kong Trade Descriptions Ordinance	Prohibits misleading commercial practices; ensures redress mechanisms
GDPR Arts. 77-79	Right to lodge complaints with supervisory authority

Core Principles: Accessibility • Fairness • Confidentiality • Timeliness • Transparency • Non-Retaliation.

3. Scope & Applicability

In Scope	Out of Scope*
Disputes over wager settlement, game malfunctions, bonus eligibility, wallet credits/debits, withdrawal processing, KYC decisions, RG tool enforcement, staff conduct	General feedback or suggestions; matters already litigated or arbitrated; requests lodged outside the 30-day window without exceptional reason

* Out-of-scope items are routed to Feedback Management (CSR-004 SOP).

4. Definitions

See Appendix A for the full glossary; key terms include Complaint, Dispute, ADR, Working Day.

5. Roles & Responsibilities

Role	Responsibilities
Player	Submit complete, truthful information; cooperate during investigation; keep personal data current.
Customer-Support Agent (CSA)	Stage 1 intake, acknowledgement, simple resolutions, CRM logging.
Complaints Officer (CO)	Stage 2 review, evidence collation, root-cause analysis, decision drafting.
Head of Player Protection (HPP)	Approval of Stage 2 decisions involving RG tools or AML suspensions.
Chief Compliance Officer (CCO)	Oversight of the entire framework, quarterly Board reporting.
Independent ADR Body	Impartial mediation or arbitration, compliance with ISO 17024 competence criteria.

6. Complaint Categories & Severity Matrix

Code	Category	Severity	Examples	Default Stage 1 SLA
C-01	Financial (Deposits/Withdrawals)	High	Withdrawal delay, incorrect payout	24 h
C-02	Game Outcome / RNG	High	Alleged wrong result, game freeze	24 h
C-03	Bonus & Promotions	Medium	Wagering calculation, expiry disputes	48 h
C-04	Account & KYC	Medium	Verification delay, document rejection	48 h
C-05	Responsible-Gaming	High	Limit not applied, self-exclusion breach	24 h
C-06	Staff Conduct	Low–Medium	Rudeness, unprofessional chat	5 days
C-07	Privacy & Data	High	Alleged GDPR breach, data disclosure	24 h

Severity influences escalation priority but not outcome fairness.

7. How to File a Complaint

Mandatory data (use Template B – Complaint Form in Appendix):

Username & registered e-mail.
Transaction / Game ID(s).
Date & time (UTC).
Detailed narrative (≤ 1,000 words).
Supporting evidence links or attachments (max 10 MB).

Submission channels (monitored 24 / 7 / 365):

E-mail: [email protected]
Secure online form: skinjoker.com/complaints
Live-chat: select “Complaint” from topic drop-down.
Postal (last resort): Complaints Officer, 22/F, 2 IFC, 8 Finance Street, Central, Hong Kong.
Voice calls are accepted but must be followed by written confirmation to preserve audit trail.

8. Data Requirements & Evidence Standards

Blockchain proof
Provide full TX hash; screenshots alone are insufficient.
Game proof
Use built-in “Copy Fairness Log” button; do not alter JSON.
Video evidence
MP4 < 50 MB; must include address bar & system clock.
Document authenticity
Metadata must match file creation date; altered PDFs may be rejected.

9. Internal Complaint-Handling Workflow

Acknowledgement – auto-ticket ID + human confirmation within 24 h.
Triage – assign severity; gather logs, server seeds, KYC notes.
Investigation – cross-departmental (Risk, RG, TechOps); Player updates every 48 h.
Draft Decision – CO summarises facts, policy references, remedy proposal.
Quality Review – HPP & CCO sign-off for High severity cases.
Outcome Notification – plain-language e-mail containing decision, supporting evidence, ADR info.
Closure – CRM ticket flagged “Resolved,” “Partially Resolved,” or “Rejected”; JSON export to Complaints Register (Appendix C).

10. Key Service-Level Objectives (SLOs)

Metric	Target	Reporting
Stage 1 average response time	≤ 4 h	Monthly KPI dashboard
Stage 1 resolution rate	≥ 75 % of Complaints	Quarterly
Stage 2 resolution (calendar)	≤ 14 days	Monthly
Complaints escalated to ADR	≤ 2 % of total	Quarterly
ADR compliance with award	100 % within 48 h	Continuous

11. Root-Cause Analysis (RCA) & Corrective Actions

RCA mandatory for High-severity upheld Complaints.

Tools: 5 Whys, Fishbone (Ishikawa), Pareto charts.
Corrective actions may include game provider patch request, staff re-training, KYC SOP revision, or UI content updates. RCA report stored in Confluence with JIRA ticket linkage.

12. Alternative Dispute-Resolution (ADR) Framework

12.1 ADR Provider Criteria

ISO 17024 compliant staff competence.
Data-protection measures (GDPR, PDPO).
Decision publication policy respecting party anonymity.

SkinJoker has contracted with:

eCOGRA Mediation Service – informal document mediation (Level 1).
HKIAC – arbitration under UNCITRAL Rules, seat Hong Kong (Level 2).

12.2 Fees & Costs

Stage	Filing Fee	Cost to Player	Cost to SkinJoker
Mediation	HKD 0	HKD 0	HKD 3 500 flat
Arbitration (claim ≤ USD 10 k)	HKD 500	50 % of arbitration fee	50 %
Arbitration (claim > USD 10 k)	Per HKIAC scale	Allocated per award	Allocated per award

13. Record-Keeping, Reporting & Oversight

Record	Form	Retention	Access
Complaint files	PDF bundle	5 years	CCO, CO, MLRO
Complaints Register	Encrypted CSV	5 years	Board, QA Audit
ADR awards	PDF	7 years	Legal, CCO
RCA reports	Confluence	5 years	Management

Quarterly analytics are presented to the Board: volume, category distribution, RCA themes, corrective actions.

14. Abuse, Vexatious Conduct & Anti-Harassment Safeguards

Warn Players using abusive language, issuing threats, or spamming.
Suspend Complaint processing until respectful communication resumes.
Terminate accounts where vexatious behaviour persists (≥ 3 frivolous Complaints closed as unfounded within 6 months).

15. Continuous Improvement & Annual Review

PDCA cycle applied:

Plan: Identify KPI gaps, regulatory changes.
Do: Implement updated SOPs, staff training.
Check: Audit sample files, verify SLOs.
Act: Board approves revisions, publishes Version update.

Annual third-party audit (ISO 10002 lead auditor) verifies framework adequacy.

16. Updates & Change-Control

Material revisions (e.g., different ADR provider, time-frames) are notified via e-mail and in-site banner 7 days prior. Version log maintained in Appendix D.

17. Contact Directory

Function	E-mail	Phone	Availability
Stage 1 Complaints	[email protected]	+852 5803 8760	24 / 7 / 365
ADR Liaison	[email protected]	+852 5803 8762	09:00–18:00 HKT (Mon–Fri)
Data Protection Officer	[email protected]	+852 5803 8765	09:00–18:00 HKT

Postal: SkinJoker Tech Ltd., FAO Complaints Officer, 22/F, 2 International Finance Centre, 8 Finance Street, Central, Hong Kong SAR.

Play responsibly. 18 + only.
If gambling ever stops being fun, please use our Responsible-Gaming tools or seek help from an accredited support organization.