Customer Protection and Grievance Redressal Policy
As a service organization we promote "Excellence in Delivery" and hence feedback from our valued customers forms an integral part of all decisions taken by the organization. The feedback provided by our customers is treated as an asset to the organization, evaluated and customized to improve our products and services.
This policy document aims at communicating the various mechanisms available for our customers to reach out to us, our service guarantee and timelines by which we will try and ensure resolution to our customer concerns.
Our Principles:
Customers remain the Key focus for all initiatives and strategies developed at ToPAY.
"Delighted" customers are a necessity for business growth and survival.
Our Customers and their Feedback is treated as the most valuable asset for the organization, forming the foundation for development and innovation.
We endeavor to simplify our customer’s life through our innovations and product offerings.
Constantly evolve and invest in our grievance redressing systems for a seamless service delivery.
Our Promise:
All grievances will be dealt with, promptly and courteously.
We promise to resolve any or all issues faced by our customers effectively and within the communicated time frame.
All Service Level Agreements and turnaround time for each third-party transaction would be published on our website.
The company has a dedicated Customer Engagement Centre under the Customer Service Department (CSD) to manage customer queries and ease out grievances if any.
We Value your Feedback:
All customers have the right to share their feedback or complaint in case they find our services are not meeting their expectations or are dissatisfied with any interaction with any of our staff members.
The Customers can send in their Queries, Requests or Complaints in the following ways:
Over Phone - Customer Engagement Centre: -Customers can call us on 09821387958 (Call Charges may applicable apply), between 07:00 AM to 11:00 PM, 7 Days working (National Holidays excluded).
Over Email: - Sending us an email on care@mobilepefintech.com
Contact us section: - Customers can choose the contact us section on our website http://www.topay.live or contact us 044-29898160.
These mechanisms are dedicated for redressing our customer complaints, providing online resolution wherever possible, and capturing valuable feedback regarding our services.
On receiving customer feedback, our executives would reach out to the customers and ensure that all grievances are redressed within a predefined Service Level Agreement as communicated below.
If the complaint is not resolved within the given timelines or the response is unsatisfactory the customer can choose to escalate the concern to our level 2 escalation officer, with relevant details such as Complaint Reference Number provided at the time of raising the initial complaint. The escalation methodology is mentioned in this policy under the Escalation Section.
Customer Resolution Timelines:
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ATM Charges:
Cash withdrawals from PPI’s are allowed up to a maximum limit of Rs. 2,000 per transaction, with an overall monthly limit of Rs. 10,000 per PPI across all ATM transactions. Charges applicable (Including GST) as per below:
Cash withdrawal: Rs.25 per transaction
Balance Enquiry and Mini Statement: Rs. 10 per transaction and
Features of such PPIs shall be clearly communicated to the PPI holder by SMS / e-mail / any other means at the time of issuance of the PPI / before the first loading of funds.
Acknowledgement of Grievances:
Customer Engagement Centre team will acknowledge the grievance immediately on the receipt of complaint in the form of: -
Auto response in case of Emails or Contact us section, or
Answering the calls at the call center, or
In all the scenarios a reference number would be provided for all future communication around the complaint.
The customer will also be kept informed on the progress towards the final resolution, or communicate any delays in redressing the concern
All complaints would be closed based on the customer’s feedback only and acceptance of closure
Customer Grievance Redress Escalation:
As "Customer Delight" our priority, we are committed to provide Best Payment Solution Experience to all our customers. We extend a level 3 escalation matrix to all our customers.
In case the customer is not satisfied with the Resolution provided by Level 1 executives Behavior of any representative or staff member at ToPAY
The customer may choose to escalate the concern using the below mentioned methods
Write to us at:
Escalation: Level 1
Customer Service Department,
MobilePe Fintech Private Limited,
Email id: care@mobilepefintech.com
contact us 09821387958
All escalations received with the required details such as reference number provided at Level 1, contact details (both phone & email) would be addressed within forty-eight (48) working hours up to a max of three (3) days in special cases pertaining to third party transactions.
Escalation: Level 2
Principal Officer
Mr.V R Udhayakumar
Head Risk and Compliance
Contact: 9043678160
MobilePe Fintech Private Limited,
Email ID: udhay@mobilepefintech.com
In case the customer is still not satisfied with the resolution provided or delay in response beyond the timelines communicated even after following the escalation steps at Levels 1 & 2 respectively, the customer can escalate the concern to the highest level by:
Escalation: Level 3
Nodal Officer
Mr.S.Parthasarathy
Director
Contact: 9043668160
MobilePe Fintech Private Limited,
Email ID: vp@mobilepefintech.com
On receiving the escalation, the complaint will get acknowledged within twenty-four (24) working hours post acknowledgement, up to a maximum of three (3) working days in special cases pertaining to third party transactions.
All escalations received with the required details such as reference number provided at Level 3, contact details (both phone & email) would be addressed within forty-eight (48) working hours.
RBI-Integrated Ombudsman
The company aims to address all grievances within a 30-day timeframe from the receipt of the complaint. However, in the unfortunate event that a complaint remains unresolved within this period or if a customer is dissatisfied with the resolution provided by the company after exhausting all escalation levels, they have the option to appeal their grievance to the RBI Ombudsman under the Reserve Bank- Integrated Ombudsman Scheme, 2021. The complainant can submit their grievance through the 'Complaint Management System' (CMS) portal of the RBI by accessing the following link:
"https://cms.rbi.org.in/cms/indexpage.html#eng"
Customer Compensation and TAT for failed transactions
In accordance with RBI’s "Harmonisation of Turn Around Time (TAT) and Customer compensation for failed transactions using authorised Payment Systems, 2019", the Company has defined a Customer compensation and TAT process for failed ToPAY transactions.
The details of the process are as under:
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Customer liability in case of unauthorised PPI transactions
Introduction:
ToPAY is authorised by the Reserve Bank of India (RBI) to operate a Payment System. It is governed by the Payment and Settlement Systems Act, 2007 (“the PSS Act”), Regulations made there under and the Issuance and Operation of Prepaid Payment Instruments in India (Reserve Bank) Directions, 2017 (“the RBI Guidelines”) laid down by the RBI ToPAY has invested in technology with robust security systems and fraud detection and preventions mechanisms. With the increasing thrust on financial inclusion and customer protection, the Reserve Bank of India had issued a circular on Customer Protection – Limiting Liability of Customers in Unauthorized Electronic Banking Transactions. (RBI/2018-19/101 DPSS.CO.PD.No.1417/02.14.006/2018-19 dated January 04, 2019) which, inter- alia, requires PPI Issuers to formulate a Board approved policy in regard to customer protection and compensation in case of unauthorized PPI transactions, if eligible.
Objective:
This policy seeks to communicate in a fair and transparent manner the ToPAY policy on:
- Customer protection (including mechanism of creating customer awareness on the risks and responsibilities involved in PPI transactions),
- Customer liability in cases of unauthorized PPI transactions
- Customer compensation due to unauthorized PPI transactions (within defined timelines), if eligible.
Scope:-
Electronic financial transactions usually cover transactions through the below modes:
- Remote / online payment transactions [transactions that do not require physical payment instruments to be presented at the point of transactions, e.g., internet banking, mobile banking, card not present (CNP) transactions, Pre-paid Payment Instruments (PPI), etc.]
- Face-to-face / proximity payment transactions (transactions which require the physical payment instrument such as a card or mobile phone to be present at the point of transaction e.g., ATM, POS, etc.)
- c) Any other electronic modes of credit effected from one entity to another currently being used or adopted from time to time
Applicability:
- Number of days will be computed based on ToPAY working days.
- Mode of reporting will be care@mobilepefintech.com through which customer complaint is received first time by the ToPAY, independent of multiple reporting of the same unauthorized transaction.
- Unauthorized transaction is defined as debit to customer’s account without customer’s consent.
- Consent includes authorization of a transaction debit either through additional authentication required by ToPAY such as use of security passwords, input of dynamic password (OTP) or any other electronic authentication option provided by ToPAY
Force Majeure:
ToPAY shall not be liable to compensate customers for delayed credit if some unforeseen event (including but not limited to civil commotion, sabotage, lockout, strike or other labor disturbances, accident, fires, natural disasters or other “Acts of God”, war, damage to ToPAY facilities or of its agents, absence of the usual means of communication or all types of transportation, etc., beyond the control of ToPAY prevents it from performing its obligations within the specified service delivery parameters.
Limited Liability of a Customer:
(a) Zero Liability of a Customer
A customer’s entitlement to zero liability shall arise where the unauthorized transaction occurs in the following events:
- Contributory fraud / negligence / deficiency on the part of ToPAY (irrespective of whether or not the transaction is reported by the customer).
- Third party breach where the deficiency lies neither with ToPAY nor with the customer but lies elsewhere in the system, and the customer notifies ToPAY within three working days of receiving the communication from ToPAY regarding the unauthorized transaction.
(b) Limited Liability of a Customer
A customer shall be liable for the loss occurring due to unauthorized transactions in the following cases:
- In cases where the loss is due to negligence by a customer, such as where he/she has shared the payment credentials, the customer will bear the entire loss until he/she reports the unauthorized transaction to ToPAY. Any loss occurring after the reporting of the unauthorized transaction shall be borne by ToPAY.
- In cases where the responsibility for the unauthorized PPI transaction lies neither with ToPAY nor with the customer, but lies elsewhere in the system and when there is a delay (of four to seven working days after receiving the communication from ToPAY) on the part of the customer in notifying ToPAY of such a transaction, the per transaction liability of the customer shall be limited to the transaction value or the amount mentioned in Annexure-I, whichever is lower.
Roles and responsibility of ToPAY:
- Provide customers with 24x7 access through multiple channels (at a minimum, via website, e-mail, a customer care) for reporting unauthorized transactions that have taken place and/ or loss or theft of payment instrument such as card, etc.
- A direct link for lodging the complaints, with specific option to report unauthorized electronic transactions will be provided by ToPAY on home page of its website.
- The loss/ fraud reporting system shall also ensure that immediate response (including auto response) is sent to the customers acknowledging the complaint along with the registered complaint number.
- The communication systems used by ToPAY to send alerts and receive their responses there to must record the time and date of delivery of the message and receipt of customer’s response, if any, to them. This shall be important in determining the extent of a customer’s liability.
- During investigation, in case it is detected that the customer has falsely claimed or disputed a valid transactions, the ToPAY reserves its right to take due preventive action of the same including closing the account or blocking card limits
- This policy should be read in conjunction with Grievance Policy.
Reporting of unauthorised payment transactions by customers to ToPAY
ToPAY shall ensure that its customers mandatorily register for SMS alerts and wherever available also register for e-mail alerts, for electronic payment transactions.
The SMS alert for any payment transaction in the account shall mandatorily be sent to the customers and e-mail alert may additionally be sent, wherever registered. The transaction alert should have a contact number and / or e-mail id on which a customer can report unauthorised transactions or notify the objection.
Customers shall be advised to notify ToPAY of any unauthorised electronic payment transaction at the earliest and, shall also be informed that longer the time taken to notify the non-bank PPI issuer, higher will be the risk of loss to ToPAY / customer.
To facilitate this, ToPAY shall provide its customers with 24x7 access via website / SMS / e-mail / a dedicated toll-free helpline for reporting unauthorised transactions that have taken place and / or loss or theft of the PPI.
Further, a direct link for lodging of complaints, with specific option to report unauthorised electronic payment transactions shall be provided by ToPAY on mobile app / home page of their website / any other evolving acceptance mode.
The loss / fraud reporting system so established shall also ensure that immediate response (including auto response) is sent to the customers acknowledging the complaint along with the registered complaint number. The communication systems used by ToPAY to send alerts and receive their responses thereto shall record time and date of delivery of the message and receipt of customer’s response, if any.
This shall be important in determining the extent of a customer’s liability. On receipt of report of an unauthorised payment transaction from the customer, ToPAY shall take immediate action to prevent further unauthorised payment transactions in the PPI.
Reporting and monitoring requirements:
ToPAY tech shall report customer liability cases to the Board or one of its Committees. The reporting shall, inter-alia, include volume / number of cases and the aggregate value involved and distribution across various categories of cases. The Board or one of its Committees shall review on a quarterly basis, the unauthorised electronic payment transactions reported by customers or otherwise, as also the action taken thereon, the functioning of the grievance redressal mechanism and take appropriate measures to improve the systems and procedures.
Annexure-I
Unauthorized transaction – Extent of Liability of Customer/ ToPAY
A customer’s liability arising out of an unauthorised payment transaction will be limited to:
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Sr. No. |
Particulars |
Maximum Liability of Customer |
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(a) |
Contributory fraud / negligence / deficiency on the part of the ToPAY, irrespective of whether or not the transaction is reported by the customer. |
Zero |
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Third party breach where the deficiency lies neither with ToPAY nor with the customer but lies elsewhere in the system, and the customer notifies ToPAY regarding the unauthorised payment transaction. The per transaction customer liability in such cases will depend on the number of days lapsed between the receipt of transaction communication by the customer from ToPAY and the reporting of unauthorised transaction by the customer to ToPAY - |
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i. Within three days# |
Zero |
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ii. Within four to seven days# |
Transaction value or Rs. 10,000/- per transaction, whichever is lower |
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iii. Beyond seven days# |
100% |
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(c) |
In cases where the loss is due to negligence by a customer, such as where he / she has shared the payment credentials, the customer will bear the entire loss until he / she reports the unauthorised transaction to ToPAY . Any loss occurring after the reporting of the unauthorised transaction shall be borne by ToPAY . |
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(d) |
ToPAY may also, at its discretion, decide to waive off any customer liability in case of unauthorised electronic payment transactions even in cases of customer negligence. |
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# The number of days mentioned above shall be counted excluding the date of receiving the communication from ToPAY . |
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Reversal timeline for zero liability / limited liability of a customer:
On being notified by the customer, ToPAY shall credit (notional reversal / shadow reversal) the amount involved in the unauthorised electronic payment transaction to the customer’s PPI within 10 days from the date of such notification by the customer (without waiting for settlement of insurance claim, if any), even if such reversal breaches the maximum permissible limit applicable to that type / category of PPI. The credit shall be value-dated to be as of the date of the unauthorised transaction.
ToPAY shall ensure that a complaint is resolved and liability of the customer, if any, established within 90 days from the date of receipt of the complaint, and the customer is appropriately compensated as above. In case ToPAY is unable to resolve the complaint or determine the customer liability, if any, within 90 days, the amount as mentioned in the table above shall be paid to the customer, irrespective of whether the negligence is on the part of customer or otherwise.
Even the theft of the card or authentication should be informed by the customer on the above helpline, as well as support e-mail id. ToPAY tech shall issue a new card to the customer or reset the authentication data after a proper investigation.
Prepaid Payment Instruments (PPIs) – Cards / Wallets
- Off-Us transaction:
The transaction will ride on Semi Closed Wallet, card network, as the case may be. The TAT and compensation rule of respective system shall apply.
- On-Us transaction
Beneficiary’s PPI not credited or PPI debited but transaction confirmation not received at merchant location.
Timeline for auto-reversal:- Reversal effected in Remitter’s account within T + 1 working day.
Reversal timeline for zero liability / limited liability of a customer:
On being notified by the customer, ToPAY shall credit (notional reversal / shadow reversal) the amount involved in the unauthorised electronic payment transaction to the customer’s PPI within 10 days from the date of such notification by the customer (without waiting for settlement of insurance claim, if any), even if such reversal breaches the maximum permissible limit applicable to that type / category of PPI. The credit shall be value-dated to be as of the date of the unauthorised transaction.
ToPAY shall ensure that a complaint is resolved and liability of the customer, if any, established within 90 days from the date of receipt of the complaint, and the customer is appropriately compensated as above. In case ToPAY is unable to resolve the complaint or determine the customer liability, if any, within 90 days, the amount as mentioned in the table above shall be paid to the customer, irrespective of whether the negligence is on the part of customer or otherwise.
Even the theft of the card or authentication should be informed by the customer on the above helpline, as well as support e-mail id. ToPAY tech shall issue a new card to the customer or reset the authentication data after a proper investigation.
Prepaid Payment Instruments (PPIs) – Cards / Wallets
- Off-Us transaction:
The transaction will ride on Semi Closed Wallet, card network, as the case may be. The TAT andcompensation rule of respective system shall apply.
- On-Us transaction
Beneficiary’s PPI not credited or PPI debited but transaction confirmation not received at merchant location.
Timeline for auto-reversal:- Reversal effected in Remitter’s account within T + 1 working day.