Cachet Insurance Broker OÜ’s procedure for resolving client complaints

Version 1.0 – 07.04.2021

The purpose of this document is to inform clients how complaints are submitted and resolved when they are dissatisfied with the services of Cachet Insurance Broker OÜ.

DEFINITIONS

‘Insurance broker’ is Cachet Insurance Broker OÜ (registry code 149A20263, located at Tatari 64, Tallinn 10134), a company acting as an insurance broker in accordance with the Insurance Activities Act. 

‘Client’ is the policyholder who has entered into an insurance contract through the insurance broker, or any other client of the insurance broker, including the insured person and the beneficiary.

‘Complaint’ is a formal complaint or a complaint prepared on a durable medium with other formal data and documents (listed in clauses 6–6.3 of this document), submitted to the insurance broker by the client about the activities of the insurance broker.

‘Web portal’ is the web service https://Cachet.me/. ‘Email’ is the insurance broker’s email address info@cachet.me.

‘Complaint form’ is the recommended complaint form that the client can use to file a complaint. The form is available in the portal and on the website of the insurance broker. 

1. COMPLAINT SUBMISSION AND ACKNOWLEDGEMENT OF RECEIPT
   1. If the client is not satisfied with the activities of the insurance broker, they have the right to file a complaint with the insurance broker, following the given procedure. 
   2. In case of an oral complaint, the circumstances shall be identified and resolved immediately by the representative of the insurance broker who received the complaint (e.g. via the portal, by telephone or e-mail) and the insurance broker shall not respond to it in any other way. 
   3. If the initial answer does not resolve the complaint, the insurance broker shall inform the client of their right to submit the complaint with formal data via the web portal or by e-mail.
   4. A complaint containing a financial claim must be signed by the client digitally and sent by email.
   5. The client can use the complaint form in the web portal to file their complaint.
   6. The complaint must contain at least the following information:
      1. the name of the complainant and, if applicable, the name of the person on whose behalf they are filing the complaint, personal identification code in case of a natural person, registry code in case of a legal person, phone number and email address. If the complainant is a client of the web portal, only the first and last name and contact information are necessary;
      2. the date on which the dissatisfactory incident occurred, description of the client rights that were violated and the circumstances of the violation;
      3. the complaint must state and include any existing evidence of the violation of client’s rights or references to them, if these are available to the insurance broker.
   7. If the complaint is submitted by a person who does not have a contractual relationship with the insurance broker, the representative of the insurance broker shall do an identity check. If it is necessary to process any as of yet undisclosed personal data of the complainant in order to resolve the complaint, the insurance broker has the right to ask the complainant for their formal consent to process personal data. It is not possible to examine and resolve the complaint without consent. When filing a complaint on behalf of a legal person, the representative of the insurance broker has the right to demand proof of the right of representation.
   8. The insurance broker shall notify the complainant as soon as possible of the commencement of the complaint procedure or the rejection of it (listing the reasons for rejection) via the web portal or the client’s email address, also informing the client of the examination term of the complaint.
2. EXAMINATION OF THE COMPLAINT AND RESPONSE TO THE COMPLAINT
   1. The insurance broker shall examine and resolve the complaint as soon as possible, but no later than within 15 days in case of a consumer client and no later than within 30 days in case of a legal entity client.
   2. If it is not possible to resolve the complaint within the aforementioned term, the insurance broker shall inform the client of the reasons for extension and the new term for resolution.
   3. After examining the complaint, the insurance broker shall send a motivated response to the complainant via the web portal or by some other means.
   4. If it is not within the competence of the insurance broker to resolve the complaint, the insurance broker shall give recommendations to the complainant, if possible, about whom to turn to with the complaint.
   5. If the client does not agree with the insurance broker’s answer, they have the right to turn to the Estonian Financial Supervision and Resolution Authority (www.fi.ee) or the court (www.kohus.ee). Consumers also have the right to submit a complaint to the Consumer Protection and Technical Regulatory Authority (www.ttja.ee).