Vulnerable Customers and Accessibility Policy

KAINET WAVE LTD

A private company limited by shares, incorporated in England and Wales.

Company number: 17180527

Registered office: Flat 30, Kew Court, Richmond Road, Kingston upon Thames, England, KT2 5BF, United Kingdom

Website: https://farvia.online

Support email: support@farvia.online

Complaints email: complaints@farvia.online

Legal notices and privacy contact: legal@farvia.online

Customer support phone: Pending / being set up

WhatsApp support: Pending / being set up

Complaints web form: https://farvia.online/complaints

In this Policy, “Kainet”, “Kainet Wave”, “we”, “us” and “our” mean KAINET WAVE LTD.

KAINET™ is used as a trade mark of KAINET WAVE LTD. A UK trade mark application for the word mark KAINET has been filed. Until registration is completed, the mark should be treated as a pending trade mark application and not as a registered trade mark.

KAINET™ is a prepaid app-based international calling service for consumers. Customers purchase calling credit directly from KAINET WAVE LTD and use the Kainet app to place ordinary person-to-person international voice calls to saved contacts in supported destinations. The service is designed as a saved-contact click-to-call international calling service.

Kainet does not currently provide VPN access services, internet access services, broadband services, general connectivity services, inbound customer telephone numbers, UK telephone numbers for customers, number porting, a replacement mobile phone service, a replacement landline service, enterprise PBX services to customers, call-centre services to customers, wholesale telecom resale by customers, or a public emergency calling service.

Kainet aims to treat customers fairly and to provide appropriate support where customers have accessibility needs, communication difficulties, vulnerability, disability, illness, bereavement, financial difficulty, limited digital confidence, limited English ability, or other circumstances that may affect their ability to use, understand, pay for, manage, or complain about the service.

This Policy explains:

• when a customer may need additional support;
• how customers can tell us about support needs;
• what support Kainet may be able to provide;
• how we handle vulnerability and accessibility information;
• limits on the service; and
• how customers can complain if they are unhappy with the support provided.

A customer may be vulnerable or may need additional support because of circumstances that are temporary, permanent, occasional, or situation-specific.

Examples may include:

• disability;
• illness;
• mental health difficulty;
• hearing, speech, visual, cognitive, or mobility impairment;
• neurodiversity;
• bereavement;
• financial difficulty;
• domestic abuse or coercive control;
• low confidence using digital services;
• limited literacy;
• limited English ability;
• difficulty understanding contracts, pricing, or support information;
• difficulty using apps, online checkout, or digital accounts;
• age-related difficulties;
• caring responsibilities;
• temporary stress, crisis, or hardship; or
• any other situation that affects the customer’s ability to use or manage the service.

A customer does not need to provide a medical diagnosis or formal evidence in order to ask for reasonable support. In some cases, we may need enough information to understand what support is appropriate.

You can tell us about accessibility needs, vulnerability, or support needs using the following contact methods.

Support email: support@farvia.online

Complaints email: complaints@farvia.online

Customer support phone: Pending / being set up

WhatsApp support: Pending / being set up

Complaints web form: https://farvia.online/complaints

If you prefer a particular communication method, please tell us.

If you need help making a complaint, understanding a bill, understanding a refund decision, using the app, or managing your account, please tell us what type of help you need.

Depending on the circumstances, Kainet may provide reasonable and appropriate support, which may include:

• using a preferred communication method where reasonably practicable;
• allowing additional time to respond to support or complaint queries;
• explaining information in clearer language;
• helping a customer understand pricing, credit, refund, or account information;
• providing written confirmation of important information;
• signposting to the Complaints Code;
• helping with the complaints process;
• considering accessibility or vulnerability when reviewing complaints or refund requests;
• making reasonable adjustments to support communications;
• pausing non-urgent support communications where appropriate;
• escalating a case for internal review where appropriate;
• helping identify account misuse, payment concerns, or unauthorised activity; or
• limiting account use where this is necessary to protect the customer, the account, or the service.

Support will depend on the customer’s needs, the information available, the nature of the service, legal and regulatory requirements, security, fraud prevention, payment rules, and what is reasonably practicable.

Kainet aims to make customer information clear, accessible, and easy to understand.

We may provide important information through:

• website pages;
• app notices;
• email;
• support messages;
• complaint responses;
• written confirmations;
• phone support once available;
• WhatsApp support once available; or
• other reasonable communication methods where available.

Customers should tell us if they need information in a clearer format, need extra time, have difficulty using the app, or need support communicating with us.

Kainet is an app-based and online service. Some parts of the service require internet access, a compatible device, account access, app access, payment method access, and the ability to use digital interfaces.

Kainet is not a replacement for a mobile phone, landline, broadband service, internet access service, or emergency calling method.

Kainet does not provide public emergency calling. Customers must keep an alternative communications method for emergency, safety-critical, medical, life-critical, or time-critical communications. If a customer cannot safely or reliably use an app-based service, Kainet may not be suitable as that customer’s communications method.

Kainet provides prepaid calling credit and prepaid calling products. Customers should only buy calling credit that they can afford and expect to use.

Kainet may apply spending limits, account limits, destination controls, risk controls, or payment review where appropriate. If you are experiencing financial difficulty, unauthorised spending, family account misuse, coercive control, or payment concerns, please contact us as soon as possible. Depending on the circumstances, Kainet may review the account, restrict future use, investigate payment concerns, provide information about refund or complaint routes, or take other appropriate action.

Kainet does not provide credit, lending, money transfer, remittance, customer wallets, e-money, cash withdrawal, or cash-equivalent stored value.

A customer may ask someone else to help communicate with Kainet, such as a family member, carer, adviser, or support worker. Before discussing account information, payment information, complaint details, or personal data with another person, Kainet may need evidence that the customer has authorised that person to act on their behalf.

Kainet may refuse to share account or personal information with a third party where authority is unclear, where there is a security risk, or where disclosure would breach data protection law.

If Kainet becomes aware of possible coercion, account misuse, unauthorised access, financial abuse, or safeguarding concerns, we may take protective action where appropriate.

Protective action may include:

• asking for verification;
• restricting account access;
• pausing certain account actions;
• refusing to discuss information with an unauthorised person;
• signposting to complaint routes;
• reviewing payment or usage activity;
• applying spending or destination controls; or
• taking other steps reasonably necessary to protect the customer, account, or service.

Kainet is not an emergency service, safeguarding authority, law-enforcement body, healthcare provider, or crisis service. If there is immediate danger or an emergency, customers should contact the appropriate emergency service using a reliable phone service, not Kainet.

If you tell us about accessibility needs, vulnerability, health information, disability, financial difficulty, communication needs, or other sensitive circumstances, we will use that information only where reasonably necessary to provide support, make reasonable adjustments, handle complaints, protect the account, comply with law, or manage the service. Please only provide information that is necessary for us to help you. We may record relevant support needs or communication preferences where appropriate, so that you do not need to repeat the same information each time you contact us. We will handle this information in accordance with our Privacy Policy and applicable data protection law.

Kainet will handle personal data, including accessibility or vulnerability information, in accordance with the Kainet Privacy Policy and applicable data protection law. Access to vulnerability or accessibility information will be limited to people or service providers who need it to provide support, handle a complaint, manage risk, comply with law, or protect the customer or service.

Kainet may use support staff, contractors, or service providers located in the United Kingdom, the European Economic Area, including the Netherlands, and other permitted locations to provide customer support, technical support, complaint handling, and service operations, subject to appropriate safeguards.

If you are unhappy with how Kainet has handled your accessibility needs, vulnerability, support request, complaint, refund request, or communication needs, you may raise a complaint under the Kainet Complaints Code.

You can complain using:

• Complaints email: complaints@farvia.online
• Complaints web form: https://farvia.online/complaints
• Phone: Pending / being set up
• Post: KAINET WAVE LTD, Flat 30, Kew Court, Richmond Road, Kingston upon Thames, England, KT2 5BF, United Kingdom

If your complaint remains unresolved after six weeks from the date it was first raised with Kainet, or if Kainet issues a deadlock letter before that time, you may be able to refer the complaint to Kainet’s approved Alternative Dispute Resolution scheme once membership is active.

ADR scheme: CISAS – membership pending / being set up.

ADR is free for eligible customers.

This Policy does not guarantee that Kainet can provide every requested adjustment, feature, support method, refund, destination, route, or service configuration.

Support may be limited by:

• legal requirements;
• sanctions compliance;
• payment processor rules;
• bank or card network requirements;
• fraud prevention;
• security controls;
• supplier restrictions;
• technical limitations;
• app or platform limitations;
• service scope;
• data protection law;
• safety concerns; or
• what is reasonably practicable.
• Nothing in this Policy limits mandatory consumer rights that cannot legally be excluded or limited.

Kainet aims to ensure that staff, contractors, or support providers involved in customer support or complaints understand the importance of treating vulnerable customers fairly and escalating appropriate cases.

Kainet may provide internal guidance or instructions on:

• identifying possible support needs;
• handling vulnerability information confidentially;
• avoiding unnecessary collection of sensitive data;
• escalating urgent or complex support issues;
• treating customers respectfully;
• using plain language where appropriate;
• recognising payment or account misuse concerns; and
• following the Complaints Code where a complaint is raised.

Kainet may update this Policy from time to time. Updates may be made to reflect changes in law, regulation, Ofcom expectations, service features, support channels, accessibility needs, payment processor requirements, supplier arrangements, or operational needs. The version and date at the top of this Policy show when it was last updated. Before paid public service availability begins, this Policy should be reviewed to ensure that the customer support phone number, WhatsApp support number, CISAS membership details, Terms and Conditions, Privacy Policy, Complaints Code, Cancellation and Refund Policy, checkout wording, and public website information are consistent and up to date.