Complaints Policy

1. Introduction and Purpose

In short: if something's gone wrong with MoorHub, the Platform, or how we've handled a report or a request, tell us and we'll investigate in two stages, with target timescales at each. If your complaint is really about a Mooring, a Mooring Agreement, or a Partner's own conduct, we're not a party to that agreement and can't resolve it for you — but we'll point you in the right direction and record it. Complaining to us never stops you pursuing any other legal right you have.

1.1 This Complaints Policy (this “Policy”) sets out how to raise a complaint about MoorHub, the Platform, or how we've handled a matter — and, separately, what to do where a complaint is really about a Partner, a Mooring, or a Mooring Agreement, where MoorHub is not a party and cannot resolve the underlying dispute.

1.2 MoorHub is a trading name of Labello Enterprises Limited, a company incorporated in England and Wales under company number 14582462, whose registered office is at Department Leeds Dock, 4 The Boulevard, Leeds, LS10 1PZ. In this Policy, “MoorHub”, “we”, “us” and “our” mean Labello Enterprises Limited.

1.3 We want to hear when something has gone wrong, and we take every complaint seriously — whether it's about the Platform not working as it should, a delay in responding to you, how we've handled your personal data, or how we've dealt with a report you made to us.

2. Who This Policy Applies To

2.1 This Policy applies to every Boat Owner and every Partner, and to anyone else who raises a complaint about MoorHub or the Platform.

2.2 Where a clause below applies to only one group, that is stated. Where it says “you” without qualification, it applies to Boat Owners and Partners alike.

3. Definitions and Interpretation

3.1 In this Policy, unless the context requires otherwise:

“Acceptable Use Policy” means MoorHub's policy governing conduct on the Platform, as published on the Website and updated from time to time.

“Application” has the meaning given in the Website Terms of Use and the Auction Rules — a Boat Owner's enquiry, expression of interest, Bid, Fixed Price Listing request, or other submission relating to a Vacancy.

“Auction Rules” means MoorHub's rules governing the Auction and Fixed Price Listing process, as published on the Website and updated from time to time.

“Boat Owner” means any individual or organisation using the Platform to search for, enquire about, bid on, apply for or secure a Mooring, as defined in the Website Terms of Use.

“Business Day” means a day other than a Saturday, Sunday, or public holiday in England, when banks in London are open for business — the same meaning given in the Partnership Agreement, applied here to Boat Owners and Partners alike.

“Complaint” means an expression of dissatisfaction, made by a Boat Owner or a Partner, about MoorHub, the Platform, or the way MoorHub has handled a matter (including a Report) — as distinct from a Report (see clause 5.3) or a request to exercise a data protection right (see clause 5.4).

“Complaints Policy” means this Policy.

“Data Protection Legislation” means the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003, the Data (Use and Access) Act 2025, and any successor or related legislation, each as amended, re-enacted or replaced from time to time.

“Listing” means a Vacancy as advertised on the Platform, as defined in the Website Terms of Use and the Partnership Agreement.

“MoorHub, we, us, our” means Labello Enterprises Limited, trading as MoorHub, a company registered in England and Wales under company number 14582462, whose registered office is at Department, Department Leeds Dock, 4 The Boulevard, Leeds, LS10 1PZ.

“Mooring and Mooring Site” have the meanings given in the Website Terms of Use and the Partnership Agreement.

“Mooring Agreement” means the agreement, however described, entered into directly between a Boat Owner and a Partner for the mooring of a boat, to which MoorHub is not a party.

“Partner” means a mooring provider registered on the Partner Portal — referred to in the Website Terms of Use as a “Mooring Provider” — as defined in the Partnership Agreement. The two terms describe the same person.

“Partnership Agreement” means MoorHub's Mooring Provider Partnership Agreement and Partner Terms and Conditions, as amended from time to time.

“Platform” means moorhub.co.uk, the Partner Portal, all associated sub-domains, applications and related services made available by MoorHub.

“Privacy Policy” means MoorHub's privacy policy explaining how it processes personal data.

“Report” means a notification, made under clause 15 of the Acceptable Use Policy, that a Boat Owner or Partner believes another Boat Owner or Partner has breached that Policy, or that raises a security concern — see clause 5.3.

“User” means, for the purposes of this Policy only, a Boat Owner or a Partner, or both, as the context requires — the same approach the Acceptable Use Policy takes, and different from, and narrower than, the Website Terms of Use's own use of “User” to mean “Boat Owner” only.

“Website Terms of Use” means MoorHub's Website Terms of Use for Boat Owners, as amended from time to time.

3.2 Terms not defined in this Policy have the meaning given to them in the Website Terms of Use, the Partnership Agreement, the Auction Rules or the Acceptable Use Policy, as the context requires.

3.3 Headings are included for convenience and do not affect interpretation.

4. Status of This Policy

4.1 For a Boat Owner, this Policy forms part of, and is incorporated by reference into, the Website Terms of Use. For a Partner, this Policy forms part of, and is incorporated by reference into, the Partnership Agreement.

4.2 This Policy is the document referred to as the “Complaints Policy” in the Website Terms of Use (clauses 2 and 28), the Partnership Agreement (clause 2 and clauses 13.1(c)/13.2(c)), the Auction Rules (clauses 2, 7.4 and 15.1(e)) and the Acceptable Use Policy (clauses 15.4 and 18.1–18.2). This Policy does not create a new complaints process for each of those documents — it is the single process all of them point to.

4.3 This Policy does not create any right for MoorHub to suspend, restrict or terminate a User's access to the Platform. Where a complaint outcome under this Policy leads to action against a Listing, a Partner's access, or a Boat Owner's access, that action is taken under the power already given to MoorHub elsewhere — clause 27 of the Website Terms of Use (a Boat Owner), or clauses 5.2, 13 and 21 of the Partnership Agreement (a Partner) — in the same way the Acceptable Use Policy's clause 4 already describes for a Report.

4.4 Where this Policy and a more specific document address the same subject — for example, the eligibility-rejection dispute route in Auction Rules clause 7.4, or the reporting route in Acceptable Use Policy clause 15 — that more specific document governs the detail, and this Policy governs the complaint-handling process itself: how a complaint is raised, investigated, escalated, and what happens if it can't be resolved.

5. What Counts as a Complaint Under This Policy

5.1 A Complaint, for the purposes of this Policy, is an expression of dissatisfaction about MoorHub, the Platform, or how MoorHub has handled a matter — for example: a fault or error on the Platform; a delay or failure by MoorHub to do something it said it would; dissatisfaction with a decision MoorHub has made under the Website Terms of Use, the Partnership Agreement, the Auction Rules or the Acceptable Use Policy; or how MoorHub has handled an earlier Report or an earlier Complaint.

5.2 Clauses 6 to 10 below explain how different kinds of complaint are handled, since MoorHub's role differs depending on what the complaint is actually about.

5.3 A Complaint is not the same thing as a Report. If you believe another Boat Owner or Partner has breached the Acceptable Use Policy — for example, fraud, harassment, shill bidding, or off-platform circumvention — raise that as a Report under clause 15 of that Policy, not as a Complaint under this one. A Complaint about how MoorHub subsequently handled your Report can still be raised under this Policy, consistent with Acceptable Use Policy clause 15.4.

5.4 A Complaint is not the same thing as a request to exercise a data protection right (for example, a request to access, correct, or delete your personal data) under Section 13 of the Privacy Policy — those requests are handled under that Policy directly, using the contact details in Section 19 of it. A genuine complaint about how MoorHub has handled your personal data is covered separately at clause 10 below.

5.5 A Complaint is not the same thing as a dispute under a Mooring Agreement between a Boat Owner and a Partner. MoorHub is not a party to a Mooring Agreement and cannot resolve a dispute arising under it (Website Terms of Use, clause 15.4; Auction Rules, clause 12.5) — see clause 7 below for what MoorHub can and can't do where a complaint touches a Partner or a Mooring.

6. Complaints About MoorHub or the Platform

6.1 If your complaint is about MoorHub itself, or about the Platform — for example, a technical fault, a billing or Fees query (Partners), or dissatisfaction with a decision MoorHub has made — raise it with us using the details in clause 20, and we will handle it under the process at clauses 11 to 13.

6.2 This includes a complaint by a Partner about a decision MoorHub has made under clause 13 of the Partnership Agreement (suspending, hiding, removing or restricting a Listing or Partner Content, or suspending or terminating Partner Portal access), and a complaint about how an IP Claim under clause 19.2–19.5 of that Agreement has been handled.

7. Complaints About a Partner, a Listing or a Mooring

7.1 If your complaint concerns a Partner, a Mooring, or a Mooring Agreement — for example, the condition of a Mooring, a dispute over Mooring Fees, or a Partner's conduct towards you — please raise this with the Partner in the first instance. MoorHub is not a party to the Mooring Agreement and cannot resolve a dispute arising under it (Website Terms of Use, clause 15.4; Auction Rules, clause 12).

7.2 You may still tell us about it. Where you do, we may, at our discretion:

(a) put you in touch with the Partner, where we hold current contact details for them;

(b) record the complaint against the Partner's account for monitoring purposes; and

(c) where the complaint is one MoorHub has been unable to resolve with the Partner, treat it as a factor relevant to our rights under Partnership Agreement clause 13.1(c) (suspending, hiding or removing a Listing or Partner Content) or clause 13.2(c) (suspending or terminating Partner Portal access, where complaints against that Partner are repeated and substantiated).

7.3 Telling us about a complaint against a Partner does not create any obligation on MoorHub to resolve it, to compensate you, or to take any particular action against the Partner, and does not affect your own right to pursue the Partner directly, including through the courts.

7.4 The same approach applies in reverse: if a Partner's complaint concerns a Boat Owner's conduct in connection with a Mooring Agreement (for example, non-payment or failure to vacate), MoorHub is equally not a party to that Agreement and cannot resolve it (Auction Rules, clause 9.2), but clauses 7.2(a)–(c) above apply in the same way.

8. Complaints About an Auction or Fixed Price Listing Outcome

8.1 Being the highest Bidder in an Auction, or submitting an eligible-looking Application for a Fixed Price Listing, does not guarantee a Partner will accept it — a Partner may reject an Application on Eligibility Criteria grounds (Auction Rules, clause 7).

8.2 Where a Partner rejects an Application on those grounds, you do not have a right to have that decision overturned by MoorHub — we are not a party to the Mooring Agreement and do not adjudicate eligibility (Auction Rules, clauses 7.4 and 12). The Platform may capture a Partner's stated reason for rejecting an Application, but disclosing that reason to you is not MoorHub's responsibility — if you want to understand why your Application was rejected, raise this with the Partner directly (Auction Rules, clause 7.3). You may still raise a Complaint under this Policy about how the Auction or Fixed Price Listing process itself was conducted — for example, a technical fault. Where you do, and a rejection reason was captured by the Platform, it is available to us to support our investigation.

8.3 This does not affect any other legal right you have.

9. Complaints About Another Boat Owner's or a Partner's Conduct

9.1 If your complaint is that another Boat Owner or Partner has breached the Acceptable Use Policy, raise this as a Report under clause 15 of that Policy, not as a Complaint under this one — see clause 5.3 above.

9.2 If you're unhappy with how MoorHub handled a Report you already made, that is a Complaint, and clauses 11 to 13 below apply to it in the usual way.

10. Complaints About How We've Handled Your Personal Data

10.1 If you're unhappy with how MoorHub has processed your personal data, you can raise this as a Complaint under this Policy — addressed to our Data Protection Contact, Brad Cahill, using the contact details in clause 20, or via Section 14 of the Privacy Policy.

10.2 With effect from 19 June 2026, the Data (Use and Access) Act 2025 gives you a statutory right to complain directly to us about our processing of your personal data. Where you do, our Data Protection Contact will acknowledge your complaint within 30 days and aim to resolve it without undue delay — this statutory 30-day acknowledgement is a legal minimum for a data-protection complaint specifically, and applies in addition to, not instead of, the Stage 1 and Stage 2 process at clauses 12 and 13 below.

10.3 You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent regulator for data protection, at any time — details are in Section 14.3 of the Privacy Policy. Making a complaint to us or to the ICO does not affect your right to seek a remedy through the courts.

11. How to Make a Complaint

11.1 To make a Complaint, contact us using the details in clause 20. Please give us as much detail as you reasonably can, including what happened, when, who was involved (if relevant), and what outcome you're looking for.

11.2 A Complaint made by a Partner should be sent by, or with the authority of, an authorised Partner Portal user for that Partner's account.

12. Stage 1: Acknowledgement and Investigation

12.1 We will acknowledge your Complaint within 5 Business Days of receiving it.

12.2 We will investigate your Complaint and aim to give you a substantive response — either resolving it, or explaining our position — within 20 Business Days of receiving it. Where a Complaint is more complex and needs longer, we will tell you and give you an expected timescale.

12.3 Our Stage 1 response is not MoorHub's final position — clause 13 explains how to ask us to look again.

13. Stage 2: Escalation

13.1 If you're not satisfied with our Stage 1 response, you may ask us to escalate your Complaint by replying with the reasons you remain unhappy, within 20 Business Days of our Stage 1 response.

13.2 A Complaint escalated under this clause will be reviewed by someone more senior than whoever handled it at Stage 1, and was not otherwise involved in the original decision, where practicable. We aim to give you a final response within a further 10 Business Days.

13.3 Our Stage 2 response is MoorHub's final internal position on your Complaint.

14. If We Still Can't Resolve It: Alternative Dispute Resolution and Your Other Rights

14.1 If you remain unhappy after our Stage 2 response, you may wish to pursue the matter independently of MoorHub.

14.2 MoorHub does not participate in the European Union's Online Dispute Resolution platform. That platform has not accepted complaints against UK traders since the end of the EU–UK transition period, so referencing it here would be inaccurate.

14.3 Regardless of clause 14.2, you can also contact your local Trading Standards service or Citizens Advice for free, impartial guidance at any time, including before our internal process has finished.

14.4 For a dispute involving a sum of money, the small claims track of the County Court is often a practical, relatively low-cost option for a claim up to £10,000 in England and Wales (lower limits and different procedures apply in Scotland and Northern Ireland).

14.5 Nothing in this Policy, and the availability of our complaints process generally, prevents you from pursuing any other legal remedy available to you, at any time.

15. Unreasonable or Abusive Complaint Conduct

15.1 We want to make it as easy as possible to raise a genuine complaint. Very occasionally, a complainant's conduct — rather than the substance of their complaint — makes it difficult for us to deal with a Complaint properly: for example, abusive or threatening language towards our staff, an unreasonable number of contacts about the same matter, or persisting with a Complaint after our Stage 2 response with no new information.

15.2 Where this happens, we may, having told you why, limit the way we communicate with you about that Complaint (for example, to a single nominated channel or contact), or decline to respond further to a Complaint that has already received a Stage 2 response and raises nothing new. This does not affect our handling of any other, separate Complaint you raise, or your rights under clause 14.

16. Confidentiality and Record Keeping

16.1 We will only share details of your Complaint with those who need to know them to investigate and resolve it, including, where relevant, the Partner or Boat Owner your Complaint concerns.

16.2 We keep a record of Complaints made under this Policy, consistent with Section 12 of the Privacy Policy, for a confirmed retention period of 6 years from resolution.

17. Relationship to Other MoorHub Documents

17.1 This Policy works alongside, and does not duplicate, the rest of the MoorHub policy suite:

17.2 If there is a conflict between this Policy and another MoorHub document on how a complaint is raised, investigated or escalated, this Policy governs. On every other matter, the more specific document governs.

18. Changes to This Policy

18.1 MoorHub may update this Policy from time to time to reflect changes to the Platform, legal or regulatory requirements, or other legitimate business reasons, in the same way as described in clause 30 of the Website Terms of Use and clause 24.2 of the Partnership Agreement.

18.2 The version of this Policy published on the Platform at the time you raise a Complaint is the version that applies to it.

19. Governing Law and Jurisdiction

19.1 This Policy, and any dispute or claim (including a non-contractual dispute or claim) arising out of or in connection with it, is governed by and construed in accordance with the laws of England and Wales.

19.2 The courts of England and Wales have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with this Policy, save that this does not prevent a consumer who lives in Scotland or Northern Ireland from bringing proceedings in their own local courts.

20. Contact Information

MoorHub — a trading name of Labello Enterprises Limited

Company number: 14582462

Registered office: Department Leeds Dock, 4 The Boulevard, Leeds, LS10 1PZ

Email: info@moorhub.co.uk