Introduction
Bhartipay Services Private Limited(hereinafter referred to as “Pay10” or the “Company”), operates as a payment aggregator platform under the brand name “Pay10”. The Company provides technology enabled digital payment solutions to its users through various instruments and channels such as credit cards, debit cards, wallets, net banking, UPI, and QR code along with value added services through its dashboard console. The Company’s platform is ISO 27001 Certified & PCI-DSS (v.4.0) compliant.
The activities undertaken by the Company fall under the purview of the Guidelines on Regulation of Payment Aggregators and Payment Gateways (“PA Guidelines”) issued by the Reserve Bank of India (“RBI”). The Company has received in-principle authorization from RBI to operate as a Payment Aggregator (“PA”) and is applying to the RBI for approval to establish its presence in cross-border space under the ambit of Regulation of Payment Aggregator – Cross Border (PA - Cross Border) (“PA-CB Regulations”).
In line with the requirements emanating from the PA Guidelines read with PA-CB regulations, the Company has formulated this Customer Grievance Redressal Policy (“Policy”) with the approval of the Board of Directors (“Board”), for effective grievance redressal of the merchants as well as customers concerning merchants. this Policy puts forth the details of complaint registrations, timeframe for resolutions, designated nodal officer and the escalation matrix.
Objective
Through this Policy, the Company aims to achieve the following objectives:
- Formulate and implement a well-defined complaint handling and grievance redressal mechanism specifically designed to cater to the requirements of the merchants or the customers
- Ensure that all the complaints are effectively addressed in accordance with the pre-defined Turnaround Time and Escalation Matrix.
- Providing the complainants with transparent communication regarding their grievance and the ability to track their complaints.
Key Definitions
For the purpose of this Policy, key definitions are as follows:
- Complainant means any merchant or customer availing the services of the Company directly or indirectly and having a grievance as defined hereinunder;
- Customer means the end user of the services provided by the merchants;
- Grievance" or “Complaint” means any dissatisfaction expressed for deficiency of service / conduct or any act of omission / commission which causes inconvenience to the complainant but does not include feedback of non-binding nature;
- Merchant means an individual or legal entity(ies) with whom the Company has entered into a contract (Merchant Agreement) for the purpose of providing payment solutions/services.
- Nodal Officer means a designated employee of the Company responsible for overseeing the grievance redressal process;
- Pay10 Shield is an end-to-end digital solution designed and developed in- house by the Company that assists in the automation of various processes involved in the merchant management cycle. The features include document validation and verification, risk assessment, ongoing monitoring, generating reports etc. for improving the overall functioning;
Appointment of Nodal Officer
The Company has appointed a Nodal officer who is responsible for regulatory and customer grievance handling functions of the Company.
The contact details of the Nodal Officer are as follows:
| Name | Mr. Amit Rana |
| Address | Property Bearing No. 4, First Floor Ring Road, Lajpat Nagar -IV, New Delhi, 110024 |
| Email id | nodal.officer@pay10.com |
| Phone no. | +91-7290829087 |
The key responsibilities of the Nodal Officer include:
- Undertake end-to-end ownership of the customer grievance and complaint management life cycle of the Company
- Implement the policy and take responsibility of its timely review and updation, in light of the regulatory developments
- Ensure redressal of customer complaints within the stipulated turn-around-times (TAT) / timelines
- Act as a single point of contact internally as well as with the regulator, for all customer grievance related matters
- Ensure prompt and effectual adherence with regulatory instructions / changes in relation customer grievance redressal
Grievance Redressal Mechanism
The Company understands the importance of customer feedback whether positive or negative in upgrading its services and being ahead of its competitors in the era of cut-throat competition. The Grievance redressal process designed by the Company is aimed at facilitating a smooth and timely resolution of merchant complaints. The Company maintains all the customer grievances redressal information through Pay10 Shield.
Some of the common scenarios that result into a complaint are as below:
- When merchant is facing issue in the integration with the Company’s system.
- When the customer is not able to do successful online transactions.
- Settlement related issues such as when the merchant does not receive the settlement or there is a delay in the settlement or receives less settlement.
- When customer is not able to do transactions for any specific payment mode, viz., Credit Card/Debit Card/Net Banking or may be for any particular bank.
- When customer has any grievance against the merchant, or the products sold by the merchant.
- When order is not generated at the time of the transaction or for refund-related queries.
The Customer grievance redressal framework of the Company is broadly classified under the following heads:
- Channels for complaint registration
- Redressal process
- Escalation Matrix
- Turn Around Time (‘TAT’)
A. Channels for complaint registration
The customers/merchants may register their complaints/grievances through various channels listed below:
Upon receipt of the complaint, the Company will redress the same as per the process given below and within the TAT given in the ensuing paragraphs.
B. Redressal Process
The Company’s redressal process includes the following steps:
Step 1. The Complainant lodges the complaint* with the Level 1 support of the Company using the abovementioned channels on Pay10 Shield.
Step 2. Once a complaint is raised, the Pay10 Shield, sends an acknowledgment to the complainant within 24 hours along with the ticket number through the same mode (email/SMS) using which the complaint was raised.
Step 3. Depending upon the information (or additional information) received, the Level 1 support will redress the complaint and provide a response to the complainant.
Step 4. If the complainant is not satisfied with the redressal provided, the complainant may escalate the same to Level 2 for resolution and thereafter to Level 3 and ultimately to Level 4.
Step 5. The redressal will be provided as per TAT provided hereinafter.
Step 6. Once the complaint is resolved, the same will be closed in the system.
Step 7. Pay10 Shield will generate a report periodically, for all the complaints redressed. This report will be used by the Company for review and analysis purposes.
*The complainant, while raising a complaint is required to briefly address the issue faced along with the following details:
- Date of transaction
- Amount of transaction
- Transaction ID
- Description of the problem
- Details of email communication (screenshot) about the problem with the Company (in case of merchant) or merchant (in case of customer).
C. Escalation Matrix
In case of dissatisfaction over the Company’s response in the redressal process, the complainant may escalate the issue to bring it to the notice of higher officials of the Company for an amicable resolution.
The Company’s escalation matrix is as below:
| Level | Team/Designation | Link |
|---|---|---|
| 1 | Support Team | info@pay10.com |
| 2 | Team Leader | support@pay10.com |
| 3 | Grievance Redressal Officer | grievance@pay10.com |
| 4 | Nodal Officer | nodal.officer@pay10.com |
If the complainant is not satisfied even after redressal provided by the Nodal Officer, the complainant may lodge the complaint with the Ombudsman as per the Integrated Ombudsman Scheme, 2021 of RBI within 30 days of redressal provided by the Nodal Officer.
The complainant can lodge their grievance on the ‘Complaint Management System’ (‘CMS’) portal of the RBI. The contact details and procedure for approaching the Ombudsman under Integrated Ombudsman Scheme, 2021 can be referred to here https://cms.rbi.org.in/. The same is also available on the Company’s website.
The Company endeavors to redress all complaints within 30 business days of initial receipt of the complaint, subject to external dependencies, such as card networks, etc. It is the responsibility of the Level 1 officer to communicate efficiently in ways which validate, accept, and understand complaints/concerns of the user. The entire chain of communication is documented by the Company for future usage.
D. Turnaround Time
The expected timeline for redressal of complaint at each level is tabulated below:
| Level | Team/Designation | TAT |
|---|---|---|
| 1 | Support Team** | 2 Working Days |
| 2 | Team Leader | 3 Working Days |
| 3 | Grievance Redressal Officer | 4 Working Days |
| 4 | Nodal Officer | 5 Working Days |
The Company endeavors to redress all the complaints within 30 business days of initial receipt of the complaint, subject to external dependencies, such as card networks, receipt of additional information, etc. It is the responsibility of the Level 1 officer to communicate efficiently in ways which validate, accept and understand complaints/concerns of the user. The entire chain of communication is documented by the Company using Pay10 Shield for future usage.
**Following types of complaints may be lodged with the Level 1 support:
| Sr. No. | Queries | Prescribed TAT |
|---|---|---|
| 1 | Enquiry about transaction status | Within 24 hours (For queries received between Monday to Friday) |
| 2 | Amount debited but transaction not found | |
| 3 | Transaction successful, but services not delivered | |
| 4 | Transaction successful & services also delivered, but the customer is not satisfied with the product/services and the merchant is not entertaining customer’s request | |
| 5 | Customer asking for refund, but the merchant is not entertaining | |
| 6 | Refund issues | |
| 7 | Refund not reflecting in the customer’s account | 24 hours to 48 hours (working days) post receiving update from the concerned entity |
| 8 | Card misused or fraudulent activity | 12 hours (For queries received between Monday to Sunday) |
Note: The TAT mentioned above may differ on case-to-case basis.
Complaints with respect to cancellation of Order/Returns/Refunds /Fraudulent Activity.
- All the queries relating to the full or partial cancellation of orders are routed to the merchant.
- A refund will be initiated only after undertaking reconciliation.
- In case the order is not generated at the time of the transaction, the customer gets the credit in their bank account within 5-7 business days failing which they can contact the Company for refund-related queries.
- Pay10 will always ensure that the refund of the concerned transaction, whether it’s a case of fraud, order cancellation, returns, etc., will always be credited back to the transaction originating bank account, card or UPI account, by triggering the refund of the concerned order ID.
- Pay10 will always seek for valid reasons and proper documentation, where the customer is asking for the refunds in some other account other than the transaction originating account. This request is considered only in exceptional circumstances, post doing proper due diligence of the scenario or in case of any directions form the Law Enforcement Agencies or banking authorities.
Note: The shipping or order dispatch related activities are directly managed by the merchant and the role of the Company is limited to directing the customer to contact the merchant and accordingly process the refund.
Complaint review mechanism
In order to keep itself abreast with the best industry practices regarding customer grievances, the Company will periodically review the complaints received and analyse the same on the basis of the following parameters:
- Number of Escalations.
- TAT Adherence.
- Frequency of a particular nature of complaint.
- Complaints escalated to the Integrated Ombudsman.
- Any shortcoming in complaint management.
Based on the above analysis, suitable changes will be made in the manner a complaint is resolved and the same will be updated in this Policy. This will ensure that complaints of similar nature are resolved more effectively and efficiently in the future.
Maintenance of Records
The Company retain records of all complaints received by it, including the following:
- Mobile no. of the Complainant,
- Nature of complaints received,
- Status,
- Resolution provided and
- Compensation awarded, if any.
The above records shall be preserved by the Company for at least 10 years.
Policy Review
The Company will review the Policy at least once a year, or sooner, if it makes changes impacting the Company's business operations or due to changes in the regulatory framework. Any such policy changes will be approved by the Board and communicated to all relevant departments.
Conclusion
The Company is committed to providing the highest standards of service to its merchants and customers. This Policy aims to provide a structured mechanism for handling complaints and ensuring their timely resolution. The Company will review this Policy periodically and make necessary amendments to align it with regulatory requirements and best industry practices.