COMPLAINTS POLICY AND COMPLAINTS HANDLING PROCEDURE

1. PURPOSE

IPK is committed to operating a transparent, fair and professional auction platform.

This Complaints Procedure & Consumer Redress Policy explains how users may submit complaints relating to:

• operation of the Platform;
• auction administration;
• bidder onboarding procedures;
• identity verification procedures;
• payment procedures;
• customer support interactions;
• other matters relating to services provided by IPK.

The purpose of this Policy is to ensure that complaints are handled consistently, fairly and efficiently.

2. OPERATOR

3. COMMITMENT TO FAIR TREATMENT

IPK seeks to

• acknowledge complaints promptly;
• investigate complaints fairly;
• communicate clearly with complainants;
• resolve complaints where reasonably possible;
• learn from complaints and improve Platform operations.

Submission of a complaint shall not adversely affect a user's rights under applicable law.

4. HOW TO SUBMIT A COMPLAINT

Complaints should be submitted by email to:

complaints@ipk.pt

Where reasonably possible, complaints should be submitted in writing to ensure an accurate record of the issues raised.

IPK may request additional information where necessary to investigate the complaint.

5. INFORMATION TO INCLUDE

To assist efficient handling, complaints should include:

• complainant's full name;
• account email address;
• contact details;
• property reference (if applicable);
• auction reference (if applicable);
• date of the relevant event;
• description of the complaint;
• supporting documents or evidence where available.

Failure to provide sufficient information may delay investigation.

6. ACKNOWLEDGEMENT OF COMPLAINTS

IPK will normally acknowledge receipt of a complaint within a reasonable period following receipt.

Acknowledgement of a complaint does not constitute acceptance of the complaint.

7. INVESTIGATION PROCESS

Upon receipt of a complaint, IPK may:

• review relevant records;
• review audit trails;
• review communications;
• review bidding records;
• request additional information;
• consult relevant service providers;
• conduct any other investigation reasonably considered appropriate.

The nature and scope of the investigation will depend upon the circumstances of the complaint.

8. RESPONSE TIMEFRAMES

IPK will seek to investigate and respond to complaints within a reasonable period.

Some complaints may require additional time due to:

• complexity;
• volume of documentation;
• involvement of third parties;
• technical investigations;
• legal or regulatory considerations.

Where additional time is required, IPK will seek to keep the complainant informed.

9. MATTERS OUTSIDE IPK'S CONTROL

IPK operates an auction platform and related infrastructure services.

Certain matters may fall outside IPK's direct control, including:

• decisions of Sellers;
• decisions of Buyers;
• actions of Seller Lawyers;
• actions of Partner Agencies;
• mortgage lender decisions;
• notarial procedures;
• conveyancing processes;
• completion of transactions.

IPK may not be able to resolve complaints relating exclusively to matters outside its control.

10. PROPERTY TRANSACTION DISPUTES

IPK is not a party to the underlying property transaction.

Accordingly, disputes arising directly between

• Sellers and Buyers;
• Buyers and Seller Lawyers;
• Sellers and Partner Agencies;
• parties to the Agreed-Form CPCV;

may fall outside the scope of complaints that IPK can resolve.

IPK may, where appropriate, provide factual information or records relating to Platform activity but shall not be obliged to act as mediator, arbitrator or legal representative.

11. AUCTION RECORDS

Where relevant to a complaint, IPK may review:

• account registration records;
• bidder activation records;
• identity verification records;
• payment verification records;
• bidding logs;
• auction audit trails;
• communication records;
• Auction Result Certificates.

Such records may assist in determining the facts relevant to the complaint.

12. PAYMENT-RELATED COMPLAINTS

Complaints relating to payment processing may involve third-party payment providers.

Where appropriate, IPK may liaise with the relevant payment provider in connection with investigation of the complaint.

The handling of payment disputes may also be subject to the rules of the relevant payment provider.

13. COMPLAINT OUTCOMES

Following investigation, IPK may

• reject the complaint;
• uphold the complaint in whole;
• uphold the complaint in part;
• provide clarification;
• provide corrective action where appropriate;
• propose another reasonable resolution.

Each complaint shall be considered on its own facts and circumstances.

14. LIVRO DE RECLAMAÇÕES

IPK maintains and makes available a Livro de Reclamações (Complaints Book) in accordance with applicable Portuguese legislation.

Consumers may submit complaints through

• the physical Livro de Reclamações maintained at IPK's establishment where required by law; and
• the Livro de Reclamações Eletrónico.

The availability of the Livro de Reclamações does not prevent consumers from contacting IPK directly through the complaints procedures described in this Policy.

IPK shall cooperate with the operation of the Livro de Reclamações system and any procedures arising from complaints submitted through that system in accordance with applicable law.

15. LIVRO DE RECLAMAÇÕES ELETRÓNICO AND CONSUMER REDRESS

Consumers may submit complaints electronically through the Portuguese Electronic Complaints Book platform.

The Livro de Reclamações Eletrónico is available at:

Where a complaint is submitted through the Livro de Reclamações Eletrónico, the complaint may be transmitted to the competent supervisory or regulatory authority in accordance with applicable Portuguese legislation.

Nothing in this Policy limits any rights available to consumers under Portuguese law.

Nothing in this Policy prevents consumers from:

• submitting complaints through the Livro de Reclamações;
• contacting competent public authorities;
• seeking legal advice;
• pursuing remedies available under applicable law.

16. ALTERNATIVE DISPUTE RESOLUTION

Where required by Portuguese law, information regarding applicable consumer alternative dispute resolution entities shall be made available through the Platform.

Consumers may request information regarding applicable consumer dispute resolution mechanisms by contacting:

complaints@ipk.pt

Nothing in this Policy limits any rights available under mandatory consumer protection legislation.

17. RECORD RETENTION

IPK may retain complaint records and related documentation for:

• operational purposes;
• compliance purposes;
• audit purposes;
• legal purposes;
• dispute resolution purposes.

Retention periods shall be determined in accordance with applicable law and operational requirements.

18. ABUSIVE OR VEXATIOUS COMPLAINTS

IPK reserves the right to limit or decline further engagement where complaints are:

• abusive;
• threatening;
• repetitive without new evidence;
• frivolous;
• vexatious.

This shall not affect any rights available under applicable law.

19. DATA PROTECTION

Personal data processed in connection with complaints shall be handled in accordance with:

• applicable data protection legislation;
• the Privacy Policy;
• operational requirements relating to complaint handling.

Users should review the Privacy Policy for further information.

20. CHANGES TO THIS POLICY

IPK may update this Policy from time to time.

The most recent version shall be published on the Platform.

Users should review the current version periodically.

21. CONTACT DETAILS