Customer Grievances Policy

Grievance Redressal Mechanism

IndiaOnlinePay values all its customers, and endeavours to provide a sincere and transparent approach to all our customers. For the convenience of our customers and to offer optimum support, IndiaOnlinePay has set up a grievance redressal mechanism and implemented a Grievance Policy.

Our Grievance Policy outlines a structured mechanism for grievance redressal and the various channels available. Our policy aims at minimizing Customer grievances and grievances through a proper channelized approach, review mechanism and prompt redressal of all Customer grievances.

The Objective of our Grievance Policy shall be to ensure that:

• Customers are treated fairly and without bias always.
• The complaints raised by the Customers are dealt with courtesy and resolved in a timely manner.
• Customers are informed of the avenues to escalate their complaints within the company.
• Customers are informed of their rights so that they can opt for alternative remedies if they are not fully satisfied with the Company's response or resolution to their complaints.
• Refunds and chargebacks are processed in a timely manner and in accordance with RBI-prescribed timelines and other obligations.

If the Merchant is not responsive

The Customer can report the issue to IndiaOnlinePay. IndiaOnlinePay has always made available the above hyperlink to the Customer(s) on its website through which the Customer may report their complaints/ grievances to IndiaOnlinePay for the transactions processed using IndiaOnlinePay services. If a grievance received by any of the above channels is not resolved within the prescribed time frame or he/she is not satisfied with the resolution offered, he/she can approach the Grievance Officer appointed by IndiaOnlinePay. The Grievance Officer is the nodal officer appointed by IndiaOnlinePay for the purpose of customer grievance redressal.

A Customer may reach out to IndiaOnlinePay for disputes arising out of any of the following grounds:

• Unreasonable delay (beyond delivery due date) or failure on the part of the Merchant in delivering goods/ services to the Customers for which the transactions were processed using IndiaOnlinePay services.
• Unauthorised electronic fund transfer.
• Unreasonable delay (beyond the time communicated to the Customer by the Merchant) on refunding the transaction amount post refund confirmation.
• Non-adherence to any instructions/ circulars/ guidelines of the Reserve Bank of India or any applicable law to IndiaOnlinePay and/ or the merchant; or
• Any other issue pertaining to the transaction processed by IndiaOnlinePay.

Escalation matrix for disposal of complaints

Level 1

The Customer can visit IndiaOnlinePay Support Page and refer to the information (provided in an FAQ format) for the specific queries/issues related to their complaints/ grievances. The Customer can fill up forms to report an issue available on these pages to report their grievance. Here Customers have the option to 'Track Payment/ Refund Status' using a transaction reference ID, or 'Report an Issue' to IndiaOnlinePay. On submission of this form, a ticket is created which allots a unique reference number. The IndiaOnlinePay Support team shall respond to the grievance filed by the Customer within 4-5 working days from the date on which grievance was filed. If the Customer is not satisfied with the response provided, the Customer can go for the next level of escalation.

Level 2

In case the Customer wishes to further escalate the complaints/ grievances, the Customer can get the grievance registered by mailing the issue to IndiaOnlinePay. IndiaOnlinePay shall attempt to respond within 4-5 working days from the date on which grievance was filed. The Customer may request for an update on the grievance in case any grievance requires more than the specified time period. The Customer shall be kept updated on the status of their complaint(s). If the Customer is not satisfied with the response provided, the Customer can go for the next level of escalations.

Level 3

In case the Customer still has any complaint/ grievance, the Customer shall escalate such complaint/ grievance to IndiaOnlinePay's Grievance Officer, the details of whom are provided below.

Grievance Officer: Prisha
Address: IndiaOnlinePay Pvt Ltd, Mumbai, India
E-Mail: grievances@indiaonlinepay.com

Level 4

If the Customer is not satisfied with the resolution provided by IndiaOnlinePay. or has not received a reply within 30 days of filing the complaint with IndiaOnlinePay., then he can file the complaint with the RBI Integrated Ombudsman located at the RBI Office in Chandigarh. Complaint lodging portal of the Ombudsman: https://cms.rbi.org.in/

Toll-Free Phone No: 14448
E-Mail Id: CRPC@rbi.org.in
Address: Centralized Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh 160017

For more details, please refer to the link: RBI Ombudsman

Listing of other common queries and resolutions with TATs:

Dispute Management/ Chargebacks Mechanism

A dispute, also known as chargeback, arises when a Customer raises a claim with the issuing bank for a purchase/transaction that was made on their account. Card networks and regulated entities such as National Payments Corporation of India (NPCI) provide the rights to the cardholder/ consumer to claim a chargeback for various reasons such as:

• Fraud transactions.
• Product/ services not delivered.
• Defective product or services are delivered.
• Duplicate payments/ double debits; etc.

The timeline(s) for raising such dispute may vary from card association to card association as per their policy which is posted or made available on their website. Every dispute raised carries a reason also referred to as reason code, which is defined by card networks. The reason codes are listed hereunder in Annexure II- Reason Codes

Stages of chargeback

The stages of chargebacks (or lifecycle) are as follows:

Chargeback Process

The chargeback process would involve parties such as the cardholder, the issuer, the acquirer, the processor, and the merchant who renders the goods or services, each of which has different responsibilities in the lifecycle.

The overview of the process is as follows:

Where a customer has reached out to the issuing bank/ other institution and has disputed the transaction made by them using his/ her payment mode/ mechanism on the merchant site, the following process is followed:

• The acquiring partner sends us a dispute notification to determine the validity of the transaction and we create a dispute corresponding to such transaction(s) in our system.
• Upon receiving such notification from the bank, IndiaOnlinePay notifies the merchant with the dispute details and the deadline (as defined by IndiaOnlinePay based on the bank's deadline) to submit such supporting documents.
• The acquiring partner sends us a dispute notification to determine the validity of the transaction and we create a dispute corresponding to such transaction(s) in our system.
• Upon receiving such notification from the bank, IndiaOnlinePay notifies the merchant with the dispute details and the deadline (as defined by IndiaOnlinePay based on the bank's deadline) to submit such supporting documents.

Chargeback Resolution

A chargeback is resolved when the case is closed either through acceptance of the Customer's claim or by contesting the claim by means of providing compelling evidence to IOP (IndiaOnlinePay) which is further shared with the Card Networks. The timelines for the chargeback resolution are subject to the timelines outlined by the respective networks. The possible outcomes of a chargeback are tabulated below:

Turnaround times for each stage

The customer has 120 days (or as defined by the network or issuer) from the date of transaction to raise a chargeback. The chargeback resolution, however, is subject to the ruling of the case.

Refunds

How are refunds initiated in IOP (IndiaOnlinePay)

The customer requests a refund from the merchant due to reasons such as the non-delivery of goods or poor service quality. Merchants can initiate refunds against transactions with IOP (IndiaOnlinePay) either via the website or via APIs. All refunds are made to the original method of payment unless agreed explicitly by the end customer to credit to an alternate mode. Credits towards reversed transactions (where funds are received by IOP (IndiaOnlinePay)) and refund transactions shall be routed back through IOP (IndiaOnlinePay)'s PA escrow account unless as per contract the refund.

What is the Payment Gateway refund process?

Once the merchant makes a refund request, IOP (IndiaOnlinePay) will check if the request is eligible, accept the request and then propagate this information to the respective acquiring banks and other banking institutions via APIs.

A refund request typically involves an exchange of information between 3 to 4 parties. Each of them has its own processes to file the request, map to their respective payment IDs and then process it forward. Many of these processes are not fully automated today and thus take around 5 - 10 working days to reach the customer's account/ card balance. IOP (IndiaOnlinePay) or any other payment aggregator acts only as a mediator between the customer and the banks.

Refund processing timelines

All refund requests, once eligible and accepted are initiated with the banking partners immediately. The refund request is sent via APIs or other channels based on the support provided by the acquiring banks.

Standard processing time (5 to 7 days):

Once the refund is initiated with the bank, it generally takes about 5 to 7 working days to get reflected on the customer's account/ card statement. This is due to the processes in the banking ecosystem which are not fully automated and require some manual oversight. Given the number of entities involved and the variance in their processes to handle refunds, it takes 5 to 7 business days to credit the money to the customer's account.

Extended processing time (beyond 7 days):

Sometimes a refund request gets dropped at different points in the process due to system failures and hence won't go through the API route or the online refund status can't be updated. In such scenarios, IOP (IndiaOnlinePay) intervenes with manual oversight to escalate cases with the bank and get them resolved. Since there is a manual oversight required at various parties the turnaround times get further extended. The standard turnaround time is 5 - 7 business days. However, each payment mode has a slightly different time frame for refunds.

*Exceptions may arise due to dependancy on partner banks for Processing refunds

Failed transactions and reversals

The PA Guidelines require RBI instructions on the harmonisation of Turn Around Time for the resolution of failed transactions. This has been put in place under the RBI Notification on Harmonisation of Turnaround Time (TAT) and customer compensation for failed transactions using authorised Payment Systems, vide DPSS.CO.PD No.629/02.01.014/2019-20, dated September 20, 2019. As per these guidelines, a 'failed transaction' is defined as follows:

A 'failed transaction' is a transaction which has not been fully completed due to any reason not attributable to the customer such as failure in communication links, non-availability of cash in an ATM, time-out of sessions, etc. Failed transactions shall also include the credits which could not be affected to the beneficiary account on account of lack of full information or lack of proper information and delay in initiating a reversal transaction.

It must be ensured that internal TAT as defined under this section comply with these guidelines. The details of the timelines are outlined in Annexure I herein.

In these circumstances, a customer tries to make a payment on a website, but the payment status is shown as failed. However, the customer is notified that the money has been deducted already. IOP (IndiaOnlinePay)'s reconciliation team identifies such transactions marked as failed or user dropped in our systems and yet we have received credit for these transactions. The IOP (IndiaOnlinePay) reconciliation team then initiates reversals of funds to the customer. All refunds and reversals are made to the original method of payment unless agreed explicitly by the end customer to credit to an alternate mode. Exceptions may also arise in cases where the underlying instrument from which the customer paid is unavailable (expired VPA, closed card, etc.). Credits towards reversed transactions (where funds are received by IOP (IndiaOnlinePay)) and refund transactions shall be routed back through IOP (IndiaOnlinePay)'s PA escrow account unless as per contract the refund is directly managed by the merchant and the customer has been made aware of the same.

All reversals are created within T+0/ T+1 days (subject to settlement report from bank/ PG partner). Reversal requests are again raised with the respective banking partners via APIs or other channels based on the support provided by the acquiring banks which are then subject to the various handling processes at each of the parties

Internal Timelines are as follows

**subject to settlement report from bank/PG partner

*Exceptions may arise due to dependancy on partner banks for Processing refunds

Fraud alerts from the LEA

Upon receiving a fraud alert from the Law Enforcement Agencies, the following process is followed:

• IOP (IndiaOnlinePay) raises a dispute and further service delivery proof is sought from the merchant.
• Once the merchant submits the relevant documentation like invoices and proof of delivery, these are reviewed.
• Action is taken accordingly i.e., marked as merchant lost or merchant won.
• In case of 'merchant lost', i.e., if the merchant loses the dispute raised, the amount is refunded back to source.
• In case of 'merchant won', i.e., if the dispute is resolved in the favour of the merchant, then the amount is settled to the merchant as per the settlement cycle.

Any LEA or other investigating agencies seeking to contact IOP (IndiaOnlinePay), may reach out to IOP (IndiaOnlinePay)'s Nodal Officer appointed as per the PMLA and other applicable regulations for this purpose.