Complaints procedure

COMPLAINTS PROCEDURE OF KULIN LANGUAGE CENTRE Version: 10 November 2026 GENERAL PROVISIONS 1. Kulin Language Centre strives to provide high-quality, accessible and carefully organised language education and attaches great importance to student satisfaction and the protection of students' rights. 2. This complaints procedure describes how complaints concerning the services, educational activities, administration, communication and other operations of Kulin may be submitted, investigated and resolved. 3. The purpose of this complaints procedure is to ensure that complaints are handled carefully, independently, transparently, confidentially and within reasonable timeframes. 4. Kulin considers complaints an important instrument for quality assurance and continuous improvement of its educational organisation. 5. This complaints procedure applies to all students, former students, applicants and other individuals directly involved in the educational services provided by Kulin. 6. Kulin Language Centre is a trade name of Tochict, established at Verdunplein 17, UNIT C2582, 5627 SZ Eindhoven, the Netherlands. 7. Tochict is registered with the Dutch Chamber of Commerce under registration number 77830326 and establishment number 000045498822. 8. The complaints procedure is available free of charge to individuals submitting a complaint. 9. Submitting a complaint must not result in disadvantage, discrimination or unjustified adverse consequences for the complainant. 10. This complaints procedure is published on the Kulin website and is freely accessible to interested parties. DEFINITIONS 11. Kulin refers to Tochict, operating under the trade name Kulin Language Centre. 12. A complainant is any individual who submits a complaint in accordance with this procedure concerning Kulin's services or conduct. 13. A complaint is a written or electronic expression of dissatisfaction concerning an action, decision, behaviour or omission by Kulin or an individual acting on its behalf. 14. Internal complaints handling refers to the first stage of the procedure, during which Kulin investigates the complaint and attempts to resolve it. 15. An independent third party is a person who, independently of daily business operations and the parties involved, may assess a complaint after the internal complaints procedure has been completed. 16. Written communication also includes communication by email or another electronic communication method designated by Kulin. 17. Working days are Monday to Friday, excluding generally recognised public holidays in the Netherlands. 18. Final resolution refers to the written communication of the outcome of the internal complaints procedure or, where applicable, the completion of the independent assessment. SCOPE OF THE COMPLAINTS PROCEDURE 19. A complaint may concern the content, organisation or delivery of a course. 20. A complaint may concern the quality of teaching, guidance, educational materials or the digital learning environment. 21. A complaint may concern communication with teachers, employees or other individuals acting on behalf of Kulin. 22. A complaint may concern the registration procedure, waiting list, placement offers or administrative processing of information. 23. A complaint may concern payments, invoicing, refunds or the application of the study terms and conditions. 24. A complaint may concern the failure to honour agreements or provide adequate information to students. 25. A complaint may concern inappropriate behaviour, unequal treatment, discrimination, intimidation or other circumstances affecting the safety or accessibility of the learning environment. 26. Complaints concerning the processing of personal data may also be submitted to Kulin, without prejudice to the rights and obligations established by the General Data Protection Regulation (GDPR). 27. A general request for information or a routine administrative enquiry is not automatically regarded as a formal complaint unless the individual clearly indicates an intention to submit a complaint. 28. Where it is unclear whether a message should be treated as a complaint, Kulin will ask the sender for clarification. PRINCIPLES OF COMPLAINTS HANDLING 29. Kulin handles complaints carefully, objectively and with respect for all parties involved. 30. Each complaint is assessed on the basis of relevant facts, agreements, applicable study terms and conditions, and current laws and regulations. 31. The principle of allowing all relevant parties to be heard is applied throughout the complaints procedure. 32. The complainant is given a reasonable opportunity to explain the complaint and provide additional relevant information. 33. Individuals to whom a complaint relates are given an appropriate opportunity to present their position. 34. Kulin aims to achieve practical, reasonable and sustainable solutions to complaints. 35. Complaints are handled with due regard for confidentiality and the protection of personal data. 36. Information about a complaint is not shared unnecessarily with individuals who are not involved in its handling. 37. Kulin requests only information that is necessary and relevant for a careful assessment of the complaint. 38. Complainants are not required to provide identity documents, diplomas, medical documents or other sensitive personal documents unless such information is genuinely necessary. 39. Where identity verification is necessary, it is carried out in a proportionate and privacy-conscious manner. SUBMITTING A COMPLAINT 40. Complaints should preferably be submitted directly to Kulin in the first instance, allowing the organisation an opportunity to investigate and resolve the matter. 41. Complaints may be submitted in writing to info@kulin.nl. 42. Complainants are encouraged to provide their full name, email address, relevant course and a clear description of the complaint. 43. Where possible, the complainant should indicate the date or period to which the complaint relates. 44. The complainant may indicate the solution or measure they consider reasonable. 45. Where available, relevant correspondence, payment confirmations or other documents necessary to substantiate the complaint may be included. 46. Providing additional documents is not mandatory where the complaint can be adequately investigated without them. 47. Kulin may request additional information where necessary for careful handling of the complaint. 48. Complaints may be submitted in Dutch or English. 49. Kulin will generally handle complaints in the language in which they were submitted, insofar as reasonably possible. 50. Where a complaint is reported verbally or through WhatsApp, Kulin may request confirmation by email to ensure that the complaint is properly registered and handled. ACKNOWLEDGEMENT AND REGISTRATION 51. Kulin will generally acknowledge receipt of a written complaint within five working days. 52. The acknowledgement will confirm that the complaint has been received and explain the next steps in the procedure. 53. Kulin records the complaint in an internal complaints register. 54. The complaints register contains only the information necessary for careful handling and administrative accountability. 55. The register may include the date of receipt, subject of the complaint, relevant course, person responsible for handling the complaint, actions taken and final outcome. 56. Where a complaint is insufficiently clear, the complainant will be given a reasonable opportunity to provide further explanation. 57. The absence of non-essential information does not, in itself, constitute grounds for refusing to handle a complaint. 58. Wherever possible, Kulin appoints a complaints handler who was not directly involved in the conduct or decision to which the complaint relates. INTERNAL COMPLAINTS HANDLING 59. Internal complaints handling constitutes the first stage of the complaints procedure. 60. Kulin investigates the complaint based on the available information and relevant circumstances. 61. Where necessary, Kulin contacts the complainant for additional clarification. 62. If the complaint concerns a teacher, employee or another individual, Kulin may request a response from that person. 63. The assessment takes into account the applicable study terms and conditions, agreements made and relevant legal obligations. 64. Kulin may propose resolving the complaint through an explanation, correction, remedial measure, additional service or another appropriate solution. 65. Where a complaint concerns a financial matter, Kulin investigates whether a refund, invoice adjustment or another financial measure is justified. 66. Where a complaint concerns the quality of education, Kulin may investigate whether additional guidance, a replacement lesson or another appropriate educational measure is possible. 67. Kulin aims to resolve complaints substantively within four weeks of receipt. 68. Where handling the complaint requires more time, the complainant will be informed in writing of the reason for the delay within this period. 69. In such cases, the complainant will also receive an indication of the additional time required to resolve the complaint. 70. The additional period will generally not exceed four weeks unless exceptional circumstances justify a longer period. 71. Kulin keeps the complainant informed of significant developments affecting the handling of the complaint. 72. The outcome of the internal complaints procedure is communicated in writing or electronically. 73. The written decision contains a brief description of the complaint, relevant findings, the decision and any proposed measures. 74. Where a complaint is declared wholly or partially unfounded, the decision will include an explanation. 75. Where Kulin undertakes to implement a measure, it will indicate how and within what reasonable timeframe the measure will be carried out. 76. The complainant will be informed of the possibility of requesting an independent assessment if they disagree with the internal resolution. INDEPENDENT COMPLAINTS HANDLING 77. Where a complainant has completed the internal complaints procedure and disagrees with the proposed solution or final decision, they may request an assessment by an independent third party. 78. Independent complaints handling provides an additional safeguard for careful and impartial assessment. 79. Kulin has appointed the following independent third party to assess complaints: Mr. M.C.M. Mendoza. 80. The independent third party can be contacted by email at mendoza.markcarlo9630@gmail.com. 81. The independent third party's contact details are made publicly available so that complainants may contact him directly when they meet the requirements for independent complaints handling. 82. The independent third party handles only complaints relating to Kulin's services for which the internal complaints procedure has, in principle, been completed. 83. When requesting an independent assessment, the complainant must explain why they consider the internal resolution insufficient. 84. The complainant may attach Kulin's written decision and relevant correspondence to the request. 85. The independent third party may request only personal data and documents necessary to assess the complaint. 86. The independent third party may not routinely request copies of identity documents, diplomas, medical documents or other personal documents that are irrelevant to the complaint. 87. The independent third party must perform his duties independently, objectively, carefully and confidentially. 88. The independent third party must not have a direct personal or financial interest in the outcome of the specific complaint. 89. Where a potential conflict of interest exists, it must be disclosed in advance and an appropriate solution must be sought. 90. The independent third party will be given access to the relevant information necessary to assess the complaint, subject to the requirements of the GDPR. 91. The independent third party may ask both the complainant and Kulin to clarify their positions. 92. Both parties will be given a reasonable opportunity to respond to relevant information and statements. 93. The independent third party assesses the complaint based on the relevant facts, applicable conditions, agreements made and applicable law. 94. The independent third party may recommend a reasonable solution, remedial measure, financial compensation or another appropriate form of resolution. 95. The independent third party aims to assess the complaint substantively within six weeks of receiving a complete request. 96. Where additional time is necessary, the parties involved will be informed of the reason and the expected timeframe for completion. 97. The outcome of the independent assessment will be communicated in writing to both the complainant and Kulin. 98. The written outcome will contain the relevant considerations, assessment of the complaint and proposed or determined resolution. 99. The independent third party acts within the powers granted to him under his separate agreement with Kulin. 100. Where the independent third party is authorised to issue a binding decision and such an arrangement has been validly agreed, the decision will be implemented in accordance with that arrangement. 101. Where the independent third party has advisory powers only, the outcome will be treated as independent advice. 102. Independent complaints handling is free of charge for the complainant. 103. Any costs associated with engaging the independent third party will be borne by Kulin, unless another legally permissible arrangement expressly applies. 104. The independent complaints procedure does not restrict the complainant's statutory rights or the possibility of bringing a dispute before the competent court. DIRECT CONTACT WITH THE INDEPENDENT THIRD PARTY 105. The independent third party does not replace Kulin's regular customer service or internal complaints procedure. 106. General enquiries about courses, registrations, payments or timetables must be directed to Kulin. 107. A request for independent assessment will generally be considered only after Kulin has had the opportunity to investigate and resolve the complaint internally. 108. Where Kulin fails to respond within the established timeframe or does not handle the complaint without valid reason, the complainant may contact the independent third party without waiting for a final internal decision. 109. The independent third party may refer a request that does not yet meet the requirements for independent assessment back to Kulin. 110. In such cases, the complainant will be informed of the reason for the referral and the procedure to be followed. CONFIDENTIALITY AND PRIVACY 111. All complaints are handled confidentially. 112. Personal data provided in connection with a complaint is processed only for handling the complaint and related legitimate purposes. 113. Kulin and the independent third party limit processing to the information necessary for the relevant complaint. 114. Personal data will not be disclosed to unauthorised third parties without a valid legal basis. 115. The independent third party is subject to appropriate confidentiality obligations regarding information received during the complaints procedure. 116. Where the independent third party processes personal data on behalf of Kulin, the applicable data protection and confidentiality arrangements will be documented in writing. 117. Where the independent third party acts as an independent data controller for certain processing activities, he must comply with the corresponding legal obligations. 118. Any international transfer of personal data must comply with the applicable requirements of the GDPR. 119. Complaint information will not be used for commercial purposes. 120. Complainants may exercise their statutory privacy rights in accordance with Kulin's Privacy and Cookie Policy. 121. Where a complaint contains sensitive information, additional measures will be taken to prevent unauthorised access or disclosure. 122. The independent third party may not use complaint information for other assignments or purposes without a valid legal basis. COMPLAINTS REGISTRATION AND RETENTION PERIODS 123. Kulin maintains an internal record of complaints received and how they have been handled. 124. The register is used to monitor the complaints process, document outcomes and improve service quality. 125. Only relevant information is included in the register. 126. Kulin generally retains complaint records for a maximum of two years after final resolution, unless longer retention is necessary due to an ongoing dispute, legal obligation or another valid legal basis. 127. Once the retention period has expired, the information will be deleted or anonymised. 128. The independent third party will not retain complaint information longer than necessary for performing and accounting for his duties, subject to applicable legal obligations. 129. Kulin may use anonymised information about complaints for internal evaluations and quality improvement. 130. Such evaluations will not unnecessarily identify individual complainants. QUALITY ASSURANCE AND IMPROVEMENT 131. Kulin considers complaints a valuable source of information about the quality of its education and services. 132. Complaints received may be evaluated periodically to identify recurring problems and areas for improvement. 133. Evaluations may address communication, educational organisation, teaching quality, administrative processes, accessibility and student satisfaction. 134. Where necessary, improvement measures will be identified and implemented. 135. Kulin may subsequently evaluate the effectiveness of measures taken. 136. The complaints procedure is periodically reviewed to ensure that it remains up to date, accessible and practically effective. 137. In establishing this procedure, Kulin takes into account relevant quality principles for private educational institutions, including transparency, independent complaints handling, careful registration and demonstrable follow-up. 138. Reference to such quality principles does not automatically imply that Kulin holds any specific registration, certification, accreditation or membership. 139. Kulin ensures that its complaints procedure reflects its actual organisation and applicable legal obligations. COSTS AND ACCESSIBILITY 140. Submitting a complaint and having it handled internally is free of charge. 141. Requesting independent complaints handling in accordance with this procedure is also free of charge for the complainant. 142. Complainants are responsible for any costs they voluntarily incur, such as fees for their own legal advice, unless the law or a legally valid agreement provides otherwise. 143. Kulin aims to make the complaints procedure understandable and accessible to individuals from different language backgrounds. 144. The complaints procedure is made available in Dutch and English. 145. Where a complainant needs assistance in formulating a complaint clearly, Kulin may provide an explanation of the procedure wherever reasonably possible. 146. A complainant may be assisted by a representative or adviser during the complaints procedure, subject to reasonable verification and privacy requirements. 147. Seeking assistance must not result in unjustified barriers to submitting or handling a complaint. IMPLEMENTATION OF DECISIONS AND MEASURES 148. Where a complaint is upheld, Kulin assesses which measures are necessary and appropriate. 149. A measure may involve correcting administrative information, remedying an error, adjusting a procedure or offering an appropriate educational solution. 150. Where financial compensation or a refund is justified, it will be provided in accordance with applicable legal obligations and agreements. 151. Kulin informs the complainant about the implementation of agreed or legally established measures. 152. Where a measure cannot be implemented within the originally indicated timeframe, the complainant will be informed promptly. 153. The implementation of measures will be recorded in the complaints register where relevant. 154. A complaint is administratively closed after the decision has been communicated and any promised measures have been implemented or adequately documented. EXTERNAL LEGAL PROTECTION 155. This complaints procedure does not affect the statutory rights of students or other individuals concerned. 156. A complainant may bring a dispute before the court having jurisdiction under applicable law. 157. Where a complaint concerns personal data, the individual may also exercise the rights provided under the GDPR. 158. Individuals may lodge a privacy complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) through https://autoriteitpersoonsgegevens.nl. 159. Kulin refers to an external disputes committee only where it is genuinely and validly affiliated with that committee or another legally valid basis for jurisdiction exists. 160. The existence of an internal or independent complaints procedure does not mean that a complainant is required to waive statutory legal remedies. AMENDMENTS AND APPLICABLE LAW 161. This complaints procedure is governed by Dutch law, without prejudice to any mandatory legal provisions. 162. Kulin may amend this complaints procedure where changes in its organisation, services or applicable legislation make this necessary. 163. The most recent version will be published on the Kulin website. 164. Amendments will not be applied in a manner that unjustifiably restricts the statutory rights of individuals concerned. 165. Where any provision of this complaints procedure is found to be invalid or unenforceable, the remaining provisions will continue to apply to the extent permitted by law. 166. In the event of a conflict between this procedure and mandatory applicable law, the applicable law shall prevail. CONTACT DETAILS AND FINAL PROVISIONS 167. Complaints must initially be submitted to Kulin Language Centre via info@kulin.nl. 168. Kulin Language Centre is a trade name of Tochict, Dutch Chamber of Commerce registration number 77830326 and establishment number 000045498822. 169. The registered business address is Verdunplein 17, UNIT C2582, 5627 SZ Eindhoven, the Netherlands. 170. Visits to the registered business address are by appointment only. 171. Kulin can be contacted via WhatsApp at +31 6 18939762. 172. The independent third party responsible for independent complaints assessment is Mr. M.C.M. Mendoza. 173. The independent third party can be contacted at mendoza.markcarlo9630@gmail.com. 174. The independent third party may be contacted when the internal complaints procedure has been completed and the complainant disagrees with the outcome, or when Kulin fails to handle the complaint within the established timeframe. 175. This complaints procedure must be read together with Kulin's Study Terms and Conditions and Privacy and Cookie Policy. 176. Kulin is committed to careful, transparent, accessible and independent complaints handling, with respect for the rights and interests of all parties involved.