Complaints Policy

1. Introduction

1.1 This complaints policy (this "Policy") explains how Raffio Limited, a company registered in Scotland (Company Number SC879232) and having its registered office address at 9 Newton Place, Office 1, Glasgow, Scotland, G3 7PR ("Raffio", "we", "us" or "our"), handles formal complaints made by users of the Platform.

1.2 This Policy forms part of, and should be read together with, our Terms and Conditions, our Refund Policy, our Shipping and Prize Fulfilment Policy, and our Privacy Policy, and capitalised terms used but not defined in this Policy have the meaning given to them in our Terms and Conditions.

1.3 This Policy sets out how to raise a formal complaint, how we will handle it through our two-stage internal review process, and what to do if you remain dissatisfied once that process has concluded. It does not affect your statutory rights.

2. What is a complaint

2.1 For the purposes of this Policy, a "complaint" is an expression of dissatisfaction, whether justified or not, about our conduct, our Platform, a Draw, the selection, notification or verification of a Winner, the publication of Winner information, an Entry, a Prize (including the withholding or fulfilment of a Prize), or our handling of a request under our Refund Policy or Shipping and Prize Fulfilment Policy, where you are seeking a formal response and, where applicable, a remedy.

2.2 A routine customer service query or a first request for a refund is not treated as a formal complaint for the purposes of this Policy unless you ask us to treat it as one, or unless you remain dissatisfied after we have responded to that query or request.

3. How to raise a complaint

3.1 To raise a formal complaint, please contact us using the details in clause 11 and mark your correspondence "Formal Complaint".

3.2 To help us investigate your complaint as quickly as possible, please include:

• (a) your full name and the email address registered to your Account;
• (b) your Account or order/transaction reference, where applicable;
• (c) a clear description of your complaint and the outcome you are seeking; and
• (d) any supporting evidence relevant to your complaint (for example, screenshots or correspondence),

3.3 For the avoidance of doubt, complaints made in respect of a Free Postal Entry do not require an email address registered to your Account or an Account itself.

3.4 If you have already raised the matter with us informally, for example as a customer service query or a refund request under our Refund Policy, and remain dissatisfied with our response, please tell us this when you raise your formal complaint so that we can take it into account.

3.5 To allow us to investigate effectively, please raise your complaint as soon as reasonably possible and, in any event, within 3 months of the event giving rise to it. We may still consider a complaint raised outside this period, but our ability to investigate it fully may be limited. For the avoidance of doubt, this time limit does not affect your statutory rights.

4. How we handle complaints – first review

4.1 We will acknowledge receipt of your formal complaint within 5 business days.

4.2 We will investigate your complaint and aim to provide a full written response within 20 business days of receipt. Where a complaint is complex or requires input from a third party, such as a Delivery Partner, RANDOM.ORG, or a payment provider, we will write to you to explain the delay and provide an updated timeframe.

4.3 Our response will set out the outcome of our investigation, our decision, and the reasons for it, together with details of any remedy we consider appropriate, and will explain how to ask for your complaint to be escalated for a second review if you remain dissatisfied.

4.4 We handle all complaints fairly, consistently, and on their individual merits, and will treat you courteously throughout the process.

5. Escalation – second review

5.1 If you are dissatisfied with our first-tier response under clause 4, you may ask us to escalate your complaint for a second review. Please make this request within 20 business days of the date of our first-tier response, using the contact details in clause 11.

5.2 An escalated complaint will be reviewed by a manager who was not involved in the first-tier decision. If no manager independent of the first-review decision is available, the complaint will instead be reviewed in accordance with clause 5.3.

5.3 Where, due to the size of our team or the nature of the complaint, no manager who was uninvolved in the first-review decision is reasonably available, the escalated complaint will instead be reviewed by a more senior member of staff (for example, a senior manager or director) who was not involved in the first-tier decision. If no such person is available within Raffio, the escalated complaint will be reviewed in accordance with clause 5.4.

5.4 Where no manager or senior member of staff who was uninvolved in the first-tier decision is available within Raffio, we will either: (a) arrange for an independent external reviewer to conduct the second review; or (b) where that is not practicable, arrange for the second review to be conducted by the person who made the first-tier decision. Where we do this, our final response will say so, confirm that the complaint has been reconsidered afresh rather than simply reaffirmed, and remind you of your right to bring court proceedings under clause 6.

5.5 We will acknowledge your escalation request within 5 business days and aim to provide a final written response within 20 business days of receipt of that request. Where the escalation is complex or requires input from a third party, we will write to you to explain the delay and provide an updated timeframe.

5.6 Our final response will confirm whether our first-tier decision is upheld, varied, or overturned, and the reasons for that outcome. This is the end of our internal complaints process.

6. If you remain dissatisfied

6.1 If, having completed a second review of your complaint under clause 5 we are unable to resolve it to your satisfaction, we will write to you to confirm this.

6.2 That written notification will include the name and website address of a certified alternative dispute resolution ("ADR") provider that is competent to deal with your complaint, together with confirmation of whether we agree to use that provider to resolve the dispute.

6.3 We are not obliged to use ADR to resolve a complaint, but where we do agree to do so, we will engage with the process in good faith.

6.4 Nothing in this Policy affects your right to bring proceedings before a court of competent jurisdiction, or any other statutory right you may have, whether or not you choose to use ADR.

6.5 We keep a record of all formal complaints we receive, including how they were resolved, and review these records periodically to identify trends and improve our service.

7. Vulnerable customers

7.1 If you consider yourself to be in a vulnerable position, or if you require reasonable adjustments to raise or progress a complaint (for example, because of a disability or a language barrier), please tell us when you contact us so that we can support you appropriately.

8. Data Protection

8.1 We will handle any personal data provided to us in connection with a complaint in accordance with our Privacy Policy.

9. Confidentiality

9.1 We will keep the details of your complaint confidential and will not disclose them to any third party except: (a) where necessary to investigate or resolve your complaint, including to a Delivery Partner, RANDOM.ORG, a payment provider, or an ADR entity; (b) where required or permitted by law or by a regulator; or (c) with your consent.

10. Changes to this Policy

10.1 We may update this Policy from time to time. Any changes will be published on the Platform with an updated "Last updated" date. Your continued use of the Platform following such an update constitutes your acceptance of the revised Policy.

11. Contact us

11.1 To raise a formal complaint, or if you have any questions about this Policy, please contact us:

• (a) Email address: support@raffio.co.uk (marked "Formal Complaint")
• (b) Platform: through your account settings or customer support
• (c) Postal address: Raffio Limited, 9 Newton Place, Office 1, Glasgow, Scotland, G3 7PR