Consumer Grievance Redressal Policy

For Co-Branded PPIs of PayU Payments Private Limited

Authority Details
Scope This Consumer Grievance Redressal Policy for Co-branded PPIs sets out the grievance redressal mechanism of PayU Payments available to the Consumers in accordance with the RBI Master Direction.
Drafted by Legal and Compliance Department
Approved by Board of Directors

Version 1.0

Date Version Description Approved by
February 26, 2022 1.0 Consumer Grievance Redressal Policy For Co-Branded PPIs Board of Directors

DEFINITIONS AND INTERPRETATION

1 Definitions

"Applicable Laws"
means all applicable laws, statutes, enactments, acts of central or state legislature, ordinances, rules, regulations, notifications, guidelines, directions, directives, policies, circulars, decisions and any other pronouncements issued in accordance with the Companies Act, the PSS Act, the RBI Master Direction, the RBI Integrated Ombudsman Scheme, the RBI ODR Circular, the RBI TAT Circular or any other law applicable to the jurisdiction of India by any central, state, local, or other governmental, administrative or regulatory authority exercising executive, legislative, judicial, regulatory or administrative functions of or pertaining to the government.
"Board"
means the board of directors of PayU Payments.
"Co-branded PPI"
means the PPI proposed to be issued by PayU Payments along with a Co-branding Partner pursuant to a co-branding arrangement entered into between PayU Payments and the Co-branding Partner.
"Co-branding Partner"
means an entity with which PayU Payments may enter into an agreement for issuance of Co-branded PPIs from time to time.
"Companies Act"
means the Companies Act, 2013, and rules and regulations issued thereunder, as amended from time to time.
"Consumer"
means an individual or an organisation to whom a Co-branded PPI is issued by PayU Payments in accordance with the co-branding arrangement(s) entered into between PayU Payments and the Co-branding Partner(s).
"Consumer Grievance Redressal Policy for Co-Branded PPIs"
means this consumer grievance redressal policy, in relation to the Co-branded PPIs, adopted and implemented by PayU Payments, as may be amended from time to time.
"Grievance"
means any complaint, dispute, disagreement by a Consumer arising as a result of and/or relating to the services and products provided by PayU Payments.
"Nodal Officer"
means the person appointed by PayU Payments who shall be the authority placed above the authorities in the grievance redressal mechanism of PayU Payments to address Grievances of the Consumers.
"ODR"
means the online dispute resolution mechanism of PayU Payments established in accordance with the RBI ODR Circular.
"PayU Payments"
means PayU Payments Private Limited, a company incorporated under the Companies Act, 1956.
"PPI"
means a prepaid payment instrument as defined under the RBI Master Direction.
"Principal Nodal Officer"
means the principal nodal officer appointed by PayU Payments in accordance with the RBI Integrated Ombudsman Scheme.
"PSO"
means a payment system operator registered under the PSS Act.
"PSS Act"
means the Payment and Settlement Systems Act, 2007 and rules and regulations issued thereunder, as amended from time to time.
"RBI"
means the Reserve Bank of India.
"RBI Act"
means the Reserve Bank of India Act, 1934, as amended from time to time.
"RBI Integrated Ombudsman Scheme"
means the Reserve Bank – Integrated Ombudsman Scheme, 2021 having reference number CEPD. PRD. No.S873/13.01.001/2021-22 dated 12 November 2021, as amended from time to time.
"RBI Master Direction"
means the Reserve Bank of India Master Direction on Prepaid Payment Instruments (PPIs), 2021 having reference number RBI/DPSS/2021-22/82 Master Direction CO.DPSS.POLC.No.S-479/02.14.006/2021-22 dated 27 August 2021, as amended from time to time.
"RBI ODR Circular"
means the RBI circular on Online Dispute Resolution (ODR) System for Digital Payments having reference number RBI/2020-21/21 DPSS.CO.PD No.116/02.12.004/2020-21 dated 6 August 2020, amended from time to time.
"RBI TAT Circular"
means the RBI circular on Harmonization of Turn Around Time (TAT) and customer compensation for failed transactions using authorised Payment Systems bearing reference no. RBI/2019-20/67 DPSS.CO.PD No.629/02.01.014/2019-20 dated 20 September 2019, as amended from time to time.

INTRODUCTION

2 Background

2.1 PayU Payments has been authorised by the RBI to issue PPIs and operates as a PSO. PayU Payments is also engaged, amongst other things, in the business of payment aggregation and provides comprehensive online payment solutions to different merchant segments.

2.2 PayU Payments wishes to offer Co-branded PPIs to the Consumers wherein PayU Payments would be the issuer of the Co-branded PPI. The RBI Master Direction requires the issuer of the Co-branded PPI to be responsible for all customer-related aspects of the Co-branded PPI.

2.3 The RBI Master Direction also requires a PPI issuer (including a Co-branded PPI issuer) to put in place a formal, publicly disclosed customer grievance redressal framework, which among other things, contains details in relation to the nodal officer designated to handle the Grievances, the escalation matrix and the turn-around period for Grievance resolution.

2.4 In view of the above, the Board has approved and adopted this document as the Consumer Grievance Redressal Policy for Co-branded PPIs of PayU Payments which, among other things, outlines a structured grievance redressal mechanism available to Consumers for raising their Grievances to PayU Payments and the manner in which PayU Payments shall or shall attempt to redress such Grievances.

3 Objectives

3.1 The objective of this Consumer Grievance Redressal Policy for Co-branded PPIs is to have a well defined, publicly disclosed, comprehensive and easily accessible redressal mechanism in place for addressing Grievances of the Consumers.

4 Overview

This Consumer Grievance Redressal Policy for Co-branded PPIs is divided into the following parts:

  • 4.1 Part 1 (Grievance Redressal Mechanism), which among other things, sets out the principles that govern the grievance redressal mechanism adopted by PayU Payments;
  • 4.2 Part 2 (Registration of Grievances), which among other things, provides a framework for registration and handling of Grievances;
  • 4.3 Part 3 (Limiting Liability of Consumers), which among other things, sets out the policy to limit the liability of Consumers in unauthorised electronic payment transactions;
  • 4.4 Part 4 (RBI Ombudsman), which among other things, sets out details in relation to the RBI Integrated Ombudsman Scheme; and
  • 4.5 Part 5 (Review and Oversight), which among other things, sets out the general terms and conditions, and procedural aspects for evaluation and review of this Consumer Grievance Redressal Policy for Co-branded PPIs.

PART 1
GRIEVANCE REDRESSAL MECHANISM

5 Principles

5.1 The principles governing this Consumer Grievance Redressal Policy for Co-branded PPIs are as follows:

  • 5.1.1 to primarily focus on Consumers while developing all initiatives and strategies of PayU Payments;
  • 5.1.2 to treat all Consumers fairly and to deal with Consumers’ Grievances promptly and courteously, and to rectify issues faced by a Consumer effectively and in a timely manner;
  • 5.1.3 to constantly devise newer and smarter mechanisms to receive and redress Consumers’ Grievances;
  • 5.1.4 to ensure that all employees at PayU Payments work in good faith and without prejudice to the interests of the Consumers;
  • 5.1.5 to inform Consumers about the channels to escalate their Grievances within PayU Payments; and
  • 5.1.6 to ensure that no charges or fees are levied to the Consumer for registering a Grievance or towards resolution of the Grievance.

6 Due diligence of Co-branding Partners

6.1 PayU Payments will conduct appropriate due diligence on each of the entities that approaches PayU Payments for a co-branding arrangement. While selecting the Co-branding Partner, PayU Payments will, among other things, assess the ability of the entity to handle Consumers’ Grievances.

6.2 PayU Payments will ensure that each Co-branding Partner has in place, at all times during the subsistence of the co-branding arrangement, an appropriate policy or mechanism for smooth and effective handling and resolution of Consumers’ Grievances.

7 Team sensitisation of handling of Grievances

7.1 PayU Payments will provide periodic trainings to its internal consumer support teams to ensure that the Consumers’ Grievances and other queries are handled in an appropriate manner. The consumer support team will be encouraged to work in a manner which helps PayU Payments to offer effective and efficient resolution to the Consumers and build the confidence of the Consumers.

8 Updating the grievance redressal mechanism

8.1 PayU Payments will endeavour to update its grievance redressal mechanism on a periodic basis and take requisite action at the grass root levels for identifying and rectifying recurring Grievances. PayU Payments will also endeavour to improve overall quality of the service levels on an ongoing basis and remain Consumer-centric in its operations.

PART 2
REGISTRATION OF GRIEVANCES

9 Manner of registering Grievances

A Consumer can register Grievances in accordance with the process set out in this Consumer Grievance Redressal Policy for Co-branded PPIs. PayU Payments will endeavour to follow a ‘three level’ process for registering and addressing all the Grievances (other than Grievances in relation to unauthorised payment transactions which have to be registered and addressed in accordance with Part 4) as described below:

9.1 Level 1: Co-branding Partner

  • 9.1.1 In the co-branding arrangement, PayU Payments and the Co-branding Partner will agree that at Level 1, the point of contact for the Consumer for lodging any Grievance will be the Co-branding Partner.
  • 9.1.2 The Consumer will be required to reach out to the Co-branding Partner at the first instance in case of any Grievance. The contact details of the Co-branding Partner will be provided on its website and/or mobile application. The Consumer can send its Grievance in writing by email, communicate it via telephone or send it through any other mechanism provided by the Co-branding Partner.
  • 9.1.3 Every Grievance received by the Co-branding Partner will be endeavoured to be acknowledged by a system generated response or via individual emails (to the extent possible), after the receipt of such Grievance. The Co-branding Partner will initiate action to resolve each Grievance expeditiously, preferably within 48 hours of receipt.
  • 9.1.4 The Consumer will receive a Grievance reference number or another appropriate identifier from the Co-branding Partner which would enable them to track the Grievance and to follow up with the Co-branding Partner, if required.
  • 9.1.5 The Consumer will be kept informed, as necessary, of the action taken in pursuance of receipt of any Grievance, the progress made by the Co-branding Partner towards the Grievance redressal process, and/or the reasons for delay, if any, in such process.
  • 9.1.6 All Grievances received by the Co-branding Partner will be endeavoured to be resolved within a period of 10 working days of the receipt of such Grievance. In case any Grievance takes more than 10 working days, or any such time as may be specified by the Co-branding Partner to that Consumer, the Consumer will be updated accordingly till such time that the Grievance is not resolved. In any case, the Co-branding Partner will endeavour to resolve the Grievance within 15 days from the date of receipt of such Grievance.
  • 9.1.7 In case the Consumer does not receive a response to their Grievance within the specified time from the Co-branding Partner at Level 1 or if the Consumer is dissatisfied with the response received, the Consumer may escalate the Grievance to the next level and reach out to the customer care team of PayU Payments for redressal by sending an email on citrusfeedback@payu.in.

9.2 Level 2: customer care team of PayU Payments

  • 9.2.1 The Consumer will be required to send the following details by email to citrusfeedback@payu.in:
    1. Name of the Co-branding Partner.
    2. Contact details of the Consumer.
    3. Previous Grievance reference number or another appropriate identifier, if any, issued by the Co-branding Partner.
    4. Date on which the Grievance was first lodged with the Co-branding Partner.
    5. Response provided by the Co-branding Partner.
    6. Description of the Grievance.
    7. Any additional details, that the Consumer may want to provide.
  • 9.2.2 All Grievances received by the customer care team of PayU Payments shall be acknowledged by a system generated response or via individual emails (to the extent possible), after receipt of such Grievance within stipulated time periods. PayU Payments may generate a new Grievance reference number or other appropriate identifier to enable the Customer to track the Grievance and to follow up with PayU Payments, if required.
  • 9.2.3 All Grievances received will be endeavoured to be resolved by the customer care team of PayU Payments within 7 to 10 working days of the receipt of such Grievance. In case, any Grievance takes more than 10 working days, or any such time as may be specified by the customer care team of PayU Payments to the Consumer, the Consumer will be updated accordingly. In any case, the customer care team of PayU Payments will endeavour to resolve the Grievance within 15 days from the date of receipt of such Grievance. In all cases, the Grievance will be endeavoured to be resolved by no later than within 30 days from the date the Grievance was first reported by the Customer to the Co-branding Partner at Level 1.
  • 9.2.4 In case the Consumer does not receive a response within the specified time at Level 2 or if the Consumer is dissatisfied with the response received on the Grievance from PayU Payments, the Consumer may escalate the Grievance to the next level by approaching the Nodal Officer.

9.3 Level 3: The Nodal Officer

  • 9.3.1 The Consumer can address the Grievance to the Nodal Officer for escalations by sending an email in writing on the below mentioned id:

    Nodal Officer – PayU

    Mr. Aayush Jaiswal

    PayU Payments Private Limited

    Bestech Business Tower, 9th Floor, Sohna Road, Sector 48, Gurugram - 122004, Haryana.

    Email: citrusnodalofficer@payu.in

    Contact: +91 9311417755

  • 9.3.2 The Consumer will be required to provide the following details to the Nodal Officer:
    1. Description of the Grievance.
    2. Contact details of the Consumer.
    3. Previous Grievance reference number or another appropriate identifier, if any, issued by the Co-branding Partner.
    4. Previous Grievance reference number or another appropriate identifier, if any, issued by PayU Payments.
    5. Date on which the Grievance was first lodged with the Co-branding Partner.
    6. Date on which the Grievance was first lodged with PayU Payments.
    7. Response provided by Co-branding Partner.
    8. Response provided by PayU Payments.
    9. Any additional details, that the Consumer may want to provide.
  • 9.3.3 All Grievances received by the Nodal Officer shall be acknowledged by a system generated response or via individual emails (to the extent possible), within stipulated timelines after the receipt of such Grievance.
  • 9.3.4 A resolution to all the Grievance escalations received by the Nodal Officer would be provided within 5 working days of the acknowledgement of such Grievance. In case, the redressal of any Grievance escalation takes more than 5 working days, or any such time as may be specified by the Nodal Officer to that Consumer, the Consumer will be updated accordingly. In all cases, the Grievance will be endeavoured to be resolved by no later than within 30 days from the date the Grievance was first reported by the Customer to the Co-branding Partner at Level 1.
  • 9.3.5 All the information regarding the escalated Grievance would be stored in the systems of PayU Payments and can be accessed by the Consumer using the reference number or other appropriate identifier allotted by PayU Payments at Level 2.

10 Grievances in relation to failed transactions

For registering a Grievance in relation to failed transactions, a Consumer will be required to follow the same process as set out in paragraph 9 above. The Consumer will be required to first report the Grievance to the Co-branding Partner and if required, escalate its Grievance to the customer care team of PayU Payments and finally to the Nodal Officer. The Co-branding Partner, the customer care team of PayU Payments and the Nodal Officer will ensure that the Consumer receives the compensation within the time period prescribed under the RBI TAT Circular and the RBI ODR Circular.

7. Paragraph 16.2(e) of the RBI Master Direction.

8. A ‘failed transaction’ is a transaction which has not been fully completed due to any reason not attributable to the Consumer 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 effected to the beneficiary account on account of lack of full information or lack of proper information and delay in initiating a reversal transaction.

9. Paragraph 16.6 of the RBI Master Direction.

11 Reporting

PayU Payments will provide reports regarding the receipt of Grievances, the action taken thereon and the status of the Grievances at such intervals and in such format as the RBI may prescribe from time to time.

PART 3
RBI OMBUDSMAN

12 RBI Integrated Ombudsman Scheme

12.1 In case the Grievance is not redressed within a period of 30 days from the date of filing the Grievance with the Co-branding Partner at Level 1, the Consumer may write to the ombudsman appointed by the RBI as per the RBI Integrated Ombudsman Scheme.

12.2 The procedure for filing a complaint with the RBI ombudsman, resolution and appeal in relation to such complaint, and the enforcement mechanism has been set out in the RBI Integrated Ombudsman Scheme available at: https://rbidocs.rbi.org.in/rdocs/content/pdfs/RBIOS2021_121121.pdf

12.3 A copy of the RBI Integrated Ombudsman Scheme, details of the complaint redressal portal and a summary of the salient features of the RBI Integrated Ombudsman Scheme have been displayed on the website of PayU Payments and will be updated regularly.

12.4 A copy of the RBI Integrated Ombudsman Scheme, details of the complaint redressal portal and a summary of the salient features of the RBI Integrated Ombudsman Scheme (in Hindi, English and a regional language) have also been displayed at the office and branches of PayU Payments and is available to a Consumer upon request.

13 Principal Nodal Officer

13.1 For the purpose of the RBI Integrated Ombudsman Scheme, PayU Payments has appointed a Principal Nodal Officer.

13.2 The Principal Nodal Officer shall be responsible for representing PayU Payments and furnishing information to the RBI ombudsman and the appellate authorities in relation to the complaints against PayU Payments in accordance with the RBI Integrated Ombudsman Scheme and the RBI Master Direction.

13.3 Details of the Principal Nodal Officer have been displayed on the website of PayU Payments at the office and branches of PayU Payments.

PART 4
LIMITING LIABILITY OF CONSUMERS

14 Consumer protection policy limiting the liability of Consumers in unauthorised electronic payment transactions

14.1 PayU Payments will ensure that the Consumers mandatorily register with PayU Payments for SMS alerts, and where applicable, also register for e-mail alerts, for electronic payment transactions.

14.2 PayU Payments will send a SMS alert and where registered, also an email alert to the Consumer in relation to any electronic payment transaction in the Consumer’s account. The transaction alert will have a contact number and/or e-mail address where a Consumer can report any unauthorised transaction or notify any objection.

14.3 PayU Payments will advise its Consumers to notify any unauthorised electronic payment transaction to PayU Payments immediately and will also inform them about the risk of loss to PayU Payments and/or the Consumers on account of delay in notifying such unauthorised electronic payment transactions.

14.4 PayU Payments will endeavour to provide Consumers with multiple mechanisms for reporting unauthorised electronic payment transactions that have taken place and / or loss or theft of the Co-branded PPI and ensure compliance with necessary instructions of RBI in this regard.

14.5 On receipt of a Grievance in relation to an unauthorised payment transaction, PayU Payments will provide the Consumer an immediate acknowledgement (which may be in the form of an auto-response) and Grievance reference number via SMS / email. PayU Payments will take immediate action to prevent further unauthorised payment transactions in the Co-branded PPI.

14.6 PayU Payments will ensure that communication systems used by it to send alerts to the Consumers in relation to electronic payment transactions and receive their responses records the time and date of delivery of the message and receipt of Consumers’ response, if any.

14.7 A Consumer’s liability arising out of an unauthorised electronic payment transaction will be limited to the amounts specified below:

Consumer liability in case of unauthorised electronic payment transactions through a Co-branded PPI
S. No. Particulars Maximum Liability of Consumer
a) Contributory fraud / negligence / deficiency on the part of PayU Payments. Zero
b) Third party breach where the deficiency lies neither with PayU Payments nor with the Consumer but lies elsewhere in the system, and the Consumer notifies PayU Payments regarding the unauthorised electronic payment transaction. The per transaction Consumer liability in such cases will depend on the number of days lapsed between the receipt of transaction communication by the Consumer from PayU Payments and the reporting of unauthorised transaction by the Consumer to PayU Payments.
i. Within three days * Zero
ii. Within four to seven days * Transaction value or INR 10,000/- per transaction, whichever is lower.
iii. Beyond seven days * As per the Board approved policy of PayU Payments.
c) In cases where the loss is due to negligence by a Consumer, such as where he / she has shared the payment credentials with any other person, the Consumer will bear the entire loss until it reports the unauthorised electronic payment transaction to PayU Payments. Any loss occurring after the reporting of the unauthorised electronic payment transaction shall be borne by PayU Payments.
d) PayU Payments may at its discretion, decide to waive off any Consumer liability even in cases of Consumer negligence.

* The number of days mentioned above will be counted excluding the date of receiving the communication from PayU Payments.

14.8 On receipt of a Grievance in relation to an unauthorised electronic payment transaction, PayU Payments will credit the amount involved in unauthorised transaction to the relevant Consumer’s Co-branded PPI within 10 days from the receipt of such Grievance. PayU Payments will not wait for any settlement and/or insurance claim for making such reversal and will make the reversal even if the amount to be credited breaches the maximum permissible limit applicable to that type / category of Co-branded PPI. PayU Payments will value the credit as of the date of the unauthorised electronic payment transaction.

14.9 PayU Payments will ensure that a Grievance in relation to unauthorised payment electronic transaction is resolved and the liability of the Consumer, if any, is assessed within 90 days from the date of receipt of such Grievance. In the event PayU Payments is unable to resolve such a Grievance within 90 days, PayU Payments will pay the amount in accordance with paragraph 14.7 above to the Consumer, irrespective of the negligence on the part of the Consumer.

14.10 PayU Payments will provide details in relation to the Grievances received in relation to unauthorised electronic payment transactions, including but not limited to the total number of Grievances received, the aggregate value involved and the action taken in relation to such Grievances, to the Board annually. The Board will review such details periodically and take such measures to improve the systems and procedures as it may deem fit.

PART 5
REVIEW AND OVERSIGHT

15 Board Approval

The Board has reviewed, approved and adopted this document as the Consumer Grievance Redressal Policy for Co-branded PPIs of PayU Payments.

16 Periodicity of Review

This Consumer Grievance Redressal Policy for Co-branded PPIs will be reviewed by the Board on a periodic basis as may be deemed appropriate by the Board.

17 Amendments

17.1 Any amendments to this Consumer Grievance Redressal Policy for Co-branded PPIs will be reviewed and approved by the Board.

17.2 Provisions of this Consumer Grievance Redressal Policy for Co-branded PPIs are subject to amendments in accordance with Applicable Laws (including rules, regulations, notifications) on the subject, as may be issued from time to time. In case any provisions of this Consumer Grievance Redressal Policy for Co-branded PPIs are inconsistent with Applicable Laws (including any subsequent amendment(s), clarification(s), circular(s), etc.) then such provisions of Applicable Laws shall prevail over the provisions hereunder and this Consumer Grievance Redressal Policy for Co-branded PPIs shall be deemed to have been amended to such extent.

18 Publication

This Consumer Grievance Redressal Policy for Co-branded PPIs shall be published on PayU Payments’ website, for information to various stakeholders.

19 Disclaimer

PayU Payments shall not be liable for any failure or delay in its performance under this Consumer Grievance Redressal Policy for Co-branded PPIs caused by force majeure events such as acts of God, acts of civil or military authorities, fires, epidemics, pandemics, floods, earthquakes, riots, sabotage or destruction of production facilities, systems failure, technical mishaps, strikes, work stoppages, or any disputes such as industrial disputes.

[End of Consumer Grievance Redressal Policy for Co-Branded PPI of PayU Payments Private Limited.]