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Doc 18 — Complaints, Support & Escalation Policy

Document18 — Complaints, Support & Escalation Policy
Version18-complaints-policy-2026-08 (in force on publication)
Party / entityDPW Pte. Ltd. (UEN 202017982R) ("DPW", "we", "us") for the Platform; each Participating Firm for complaints concerning its Professional Services
AudienceCustomers, Users and Authorised Representatives

1. Purpose of this policy

1.1 This policy explains how to raise a support request or complaint, what response you can expect, how matters are escalated, and the external routes that remain open to you. It applies to the Platform and, at the referral stage described in Section 4, to Professional Services provided by a Participating Firm.

1.2 This policy creates a process. The timelines in Section 3 are commitments about how we run that process; they are not new rights, remedies or service levels. This policy does not amend, and is subject to, the Platform Terms of Service (Doc 02), the Singapore Terms of Business (Doc 03) and your Engagement, and it does not create any liability or warranty beyond those documents.

2. How to raise something — support first

2.1 Most issues are resolved fastest as support requests. Contact us through:

  • (a) the support/help function in your client portal;
  • (b) email to support@csfile.ai; or
  • (c) any other support channel published on the website from time to time.

2.2 If support does not resolve the issue, or you want it treated as a formal complaint from the outset, say so — tell us "this is a complaint", what happened, when, what service or Engagement it concerns, and the outcome you are seeking. That helps us route it correctly under Section 4.

3. What you can expect

3.1 Acknowledgement. We will acknowledge your complaint within 2 Business Days of receipt. A "Business Day" is a day other than a Saturday, Sunday or public holiday in Singapore.

3.2 Substantive response. We will give you a substantive response — our findings and what we will do — within 10 Business Days of acknowledgement. If we need longer (for example, because the complaint involves a Participating Firm or a Third-Party Service Provider), we may extend that period once, and will tell you in writing why we need the extension and the new date by which you will receive our response.

3.3 No detriment. Making a complaint in good faith will never result in worse treatment of you, your account or your Engagement. Raising a complaint does not by itself suspend payment obligations or statutory deadlines in your matter.

4. Escalation ladder and routing

4.1 Complaints move through this ladder:

  • Step 1 — Support. First-line support attempts resolution (Section 2).
  • Step 2 — Platform management. If unresolved, or on request, the complaint is escalated to DPW's management for review of anything concerning the Platform Services — the portal, workflow tooling, communications, billing and collection, or our handling of your account.
  • Step 3 — Referral to the Participating Firm. Where the complaint concerns Professional Services — the professional work, advice, filings or conduct of a Participating Firm or its Professionals — DPW does not adjudicate it. We will refer it, with your knowledge, to the Participating Firm's own complaints procedure and its named complaints contact stated in your Engagement, and we will tell you we have done so. A complaint about the amount or fairness of the Firm's fees for Professional Services is a Professional Services complaint handled by the Firm under this Step 3, even though DPW collected the fee as the Firm's agent; complaints about the mechanics of collection — charging, invoicing, receipts or refund processing — are Platform Services matters handled by DPW under Step 2. The Firm is responsible for handling each complaint referred to it; DPW will provide relevant Platform records to the Firm as its platform provider (see Doc 05 — Data Processing Addendum (the "DPA")).

4.2 Mixed complaints (part platform, part professional) are split: DPW answers for the Platform Services component and the Firm answers for the Professional Services component, and we will tell you which part has gone where.

4.3 Regulated conduct. Complaints about a Firm's regulated conduct as a registered Corporate Service Provider — including its registered qualified individuals, filings and anti-money-laundering obligations — are for the Firm and its regulator, not DPW. Nothing in this policy limits or delays your right to complain directly to ACRA about a registered CSP or qualified individual at any time.

5. Specific complaint types

5.1 Privacy and personal data. Complaints or requests about personal data go to our Data Protection Officer route — see Doc 19 — DPO / Data Subject Request Procedure (the "DSR Procedure"); contact dpo@csfile.ai. You also have the right to complain to the Personal Data Protection Commission (PDPC) at any time.

5.2 Payments, refunds and disputed charges. Billing disputes, refund requests and chargeback matters are handled under Doc 10 — Payment, Cancellation & Refund Terms; raise them through the channels in Section 2 and we will apply that document.

5.3 Content, security and acceptable use. Reports of abuse, security issues or unlawful content are handled under Doc 08 — Acceptable Use Policy; urgent security reports should be marked as such.

6. What we record, and for how long

6.1 For each complaint we record: who complained and how to reach them; the date received; the services and (where relevant) the Engagement and Firm concerned; the substance of the complaint; the steps taken, including any referral under Section 4; the outcome; and the dates of acknowledgement and response.

6.2 Complaint records are retained in line with Doc 17 — Document Retention / Records Notice (the "Retention Notice"). They are personal data and are handled under Doc 04 — Privacy Notice; where a complaint concerns an Engagement, relevant records may be shared with the Participating Firm as described in Section 4.

7. External routes

7.1 This policy never removes your external options. In summary:

  • ACRA — regulatory complaints about a registered CSP or registered qualified individual (Section 4.3);
  • PDPC — personal data complaints (Section 5.1);
  • CASE / mediation — consumers may approach the Consumers Association of Singapore, and the dispute-resolution path in your governing terms (good-faith negotiation, then mediation at the Singapore Mediation Centre) remains available (see Doc 02 and Doc 03);
  • Singapore courts — nothing in this policy prevents you from exercising your legal rights, including any non-excludable rights under the Consumer Protection (Fair Trading) Act.

7.2 Using this policy first is encouraged but is not a precondition to any statutory right.

8. Changes

8.1 We may update this policy from time to time; the current version is published on the website and the version date at the top tells you when it last changed. Complaints already in progress are completed under the version in force when they were made, unless the newer version is more favourable to you.

Version: 18-complaints-policy-2026-08 · Approval: management-attested