Grievance Policy

Open Financial Technologies Private Limited (“Open” or we”) operates as an intermediary between its customers (“Merchants”) and end users (“Merchant’s customer”) (collectively “User”) by facilitating online transactions as a licensed Payment Aggregator. The Reserve Bank of India (“RBI”), vide notification dated 17/03/2020 bearing reference number RBI/DPSS/2019-20/174 DPSS.CO.PD. No. 1810/02/14/008/2019-2020 (as amended from time to time) has issued guidelines for Payment Aggregators (“PA Guidelines”). We at Open are committed to resolving grievances faced by our User in accordance with the PA Guidelines. To that end, we have set up a grievance redressal mechanism to implement this grievance redressal policy (“Policy”). This Policy aims at resolving User complaints and grievances by offering a proper redressal channel, review mechanism, and ensuring prompt redressal of grievances faced by a User.

For the purpose of this Policy, a “Grievance” means any concern, dispute, complaint or feedback that a User desires to provide to Open in relation to the services delivered owing to deficiency in the quality of services rendered.

We understand that a Grievance could arise under various circumstances. Such Grievance could arise on account of an unavoidable technical snag to a case involving deficiency in the quality of services delivered by Open. Our User have complete authority to share feedback / raise a complaint, if they are disappointed with the services rendered by Open. The User can highlight or escalate their complaint/ feedback/ suggestions in writing, via email, or chat with Open’s customer support team. If a User issue is not resolved within the given time or if a User is dissatisfied with the resolution offered/provided by Open, they may approach our tiered grievance redressal system. In order to make our grievance redressal system more effective and meaningful for our User, we have established a structured system to resolve complaints seamlessly within the committed timeframe.

PRINCIPLES GOVERNING THIS GRIEVANCE POLICY :

All initiatives and strategies developed by Open are made with the User as the prime focus.
Prompt and efficient delivery of services to the User is essential for the growth of our business.
Open is constantly evolving newer and smarter system to collect feedback and objectively redress Grievances of the User within the framework of this Policy.
The details of Open’s grievance redressal mechanism are placed on its website in the public domain in the interest of transparency and ease of access.
All employees at Open must work in good faith without, in whatsoever, causing prejudice to the interests of the User.
The Grievances of the User will be dealt with promptly and courteously within the timelines as prescribed under the applicable law including respective RBI guidelines.
Open promises to rectify any issue faced by a User effectively and in a timely manner, in accordance with the Policy.
The User will be always treated fairly and equally under all circumstances.
The User must be aware of the channels available, in order to escalate their Grievances within Open.
There will be no charge that would be levied to the User for filing a complaint or a fee towards resolution of a Grievance.

TEAM SENSITIZATION ON HANDLING COMPLAINTS

Our teams undergo regular training to ensure that User queries and Grievances are handled with sensitivity. They are guided and encouraged to offer a first-time resolution which in turn leads to trust, confidence and satisfaction. This reflects in both the operations as well as the User communications.

To ensure a timely and effective grievance redressal process, We request that the User fully co-operate with us. User is expected to furnish relevant documentation and information for the verification of the complaint and for the investigation purposes. In certain cases, We may require User to furnish additional information. We request that User comply with such requests to ensure a smooth and efficient grievance redressal process. In addition, User is expected to ensure that such documentation and information is accurate, bona fide, not misleading, and up- to-date.

FAILED TRANSACTIONS

A ‘Failed Transaction’ is a transaction which has not been fully completed due to any reason not attributable to the User such as failure in communication links, time-out of sessions, non- credit to beneficiary’s account due to various causes, 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.

For the purposes of this Policy, terms like acquirer, beneficiary, issuer/originator, remitter, etc., have the same meanings as per common banking parlance.
T’ is the day of transaction and refers to the calendar date.
‘R’ is the day on which the reversal is concluded, and the funds are received by the issuer / originator. Reversal should be effected at the issuer / originator end on the same day when the funds are received from the beneficiary end.

The principle behind the turnaround time (TAT) is based on the following:

a. If the transaction is a ‘credit-push’ funds transfer and the beneficiary account is not credited while the debit to originator has been effected, then credit is to be effected within the prescribed time period failing which the penalty has to be paid to the beneficiary.
b. If there is delay in initiation of a transaction at the originator bank’s end beyond the TAT, then penalty must be paid to the originator.
c. Users who do not get the benefit of redress of the failure as defined in the TAT, can register a complaint to the Banking Ombudsman of Reserve Bank of India.

Sl. No.	Description of tde Incident	Framework for auto reversal and compensation
Sl. No.	Description of tde Incident	Timeline for Auto Reversal	Compensation payable
1	Card Transactions
(a)	Card to card transfer Card account debited but beneficiary card account not credited	Transaction to be reversed (R) latest within T + 1 day, if credit is not effected to the beneficiary account	Rs. 100/- per day of delay beyond T + 1 day
(b)	Point of Sale (POS) (Card Present) including Cash at POS Amount debited but confirmation not received at merchant location, i.e., charge- slip not generated.	Auto-reversal within T + 5 days	Rs. 100/- per day of delay beyond T + 5 days
(c)	Card Not Present (CNP) (e-commerce) Account debited but confirmation not received at merchant’s system
2	Immediate Payment System (IMPS)
(a)	Account debited but the beneficiary account is not credited	If unable to credit the beneficiary account, auto reversal (R) by the Beneficiary bank latest on T + 1 day	Rs. 100/- per day if delay is beyond T + 1 day
3	Unified Payments Interface (UPI)
(a)	Account debited but the beneficiary account is not credited (transfer of funds)	If unable to credit the beneficiary account, auto reversal (R) by the Beneficiary bank latest on T + 1 day	Rs. 100/- per day if delay is beyond T + 1 day
(b)	Account debited but transaction confirmation not received at merchant location (payment to merchant).	Auto-reversal within T + 5 days.	Rs. 100/- per day if delay is beyond T + 5 days.
4	National Automated Clearing House (NACH)
(a)	Delay in crediting beneficiary’s account or reversal of amount.	Beneficiary bank to reverse the uncredited transaction within T + 1 day.	Rs. 100/- per day if delay is beyond T + 1 day.
(b)	Account debited despite revocation of debit mandate with the bank by the Customer	User’s bank will be responsible for such debit. Resolution to be completed within T + 1 day
5	Aadhaar Enabled Payment System (including Aadhaar Pay)
(a)	Account debited but transaction confirmation not received at merchant location	Acquirer to initiate “Credit Adjustment” within T + 5 days	Rs. 100/- per day if delay is beyond T + 5 days
(b)	Account debit but beneficiary account not credited
6	Prepaid Payment Instruments (PPIs) – Cards / Wallets)
(a)	Off-Us transaction** The transaction will ride on UPI, card network, IMPS, etc., as the case may be. The TAT and compensation rule of respective system shall apply.
(b)	On-Us transaction* Beneficiary’s PPI not credited PPI debited but transaction confirmation not received at merchant location	Reversal effected in Remitter’s account within T + 1 day	Rs. 100/- per day if delay is beyond T + 1 day

* On-Us transaction: A settlement transaction where the acquirer and issuer banks are one and the same party.

** Off-Us transaction: A settlement transaction where the acquirer and issuer banks are distinct from each other

TYPES OF DISPUTES

The types of disputes/issues faced by User may include:

Technical issues while accessing Open’s platform.
Identifying or being subject to fraudulent transactions.
Facing issues while onboarding on Open’s platform.
Issues in relation to the payments of fees to Open.
Issues in relation to chargeback transactions, which will be resolved in accordance with the terms and conditions hosted at https://open.money/tnc
Disputes relating to rejection/ suspension of payments, refunds and/or any other dispute relating to the transactions.
Billing disputes.

TRANSACTION LIFE CYCLE

The different modes of transactions that are available on the Open platform and the corresponding timelines are set out below:

Fund transfer and collection

IMPS (Instant)
UPI (Instant)

All the above modes of transaction are facilitated through APIs of the underlying bank.

Payment Gateway

Amounts deducted from the User’s account shall be remitted to the escrow account maintaining bank on Tp+0 / Tp+1 basis. Where, ‘Tp’ is the date of charge / debit to the User’s account against the purchase of goods / services. At the end of the day, the amount in escrow account shall not be less than the amount already collected from User as per ‘Tp’ or the amount due to the User.

UPDATING OF GRIEVANCE REDRESSAL MECHANISM

At Open, we focus on optimising User experience, and we always analyse and implement our policies and processes centred around the feedback received from the Users. Therefore, a mechanism has been instated for analysis and requisite working towards rectification of any concerns identified within the system at the root level.

MANNER OF REGISTERING COMPLAINTS AND PROCEDURE FOR ADDRESSING THE GRIEVANCE

At Open, we love to hear from our Users - be it feedback or a complaint. We truly believe and follow that User satisfaction is our priority.

Level-1 :

If a User wishes to report a Grievance, she/he can seek redressal using any of the following channels:

For Merchant - Please click chat icon from the Open dashboard and initiate a chat thread to raise the complaint.
For Merchant’s Customers Email Id - Please e-mail us at [email protected]

Acknowledgement

Complaints received through the chat mechanism or e-mail will be acknowledged by an immediate system generated response or by way of an email response. The acknowledgment marks initiation of the Grievance resolution process.
The User will also be kept informed of the action taken, the progress while redressing Grievances, and the reasons for delay if any, in redressing.
The follow up action taken in respect of such Grievances shall be advised to User by e-mail and/or chat.

Resolution: All Grievances received will be acknowledged immediately by a system generated response and resolved within 3 (three) working days. In case the resolution of any Grievance takes more than the specified resolution time, the User will be intimated accordingly and kept updated on the progress / status of the Grievance on a periodic basis till such time that the Grievance is resolved. However, it is to be noted that the time taken to resolve a Grievance will be further extended, if assistance of third-party service providers is required to address the Grievance.

In case the User does not receive a response within the specified time for a Level 1 Grievance or if the User is dissatisfied with the response received from OPEN, the User may escalate the complaint to the next level as indicated below.

Level-2 :

The User can address the Grievance to the below mentioned Nodal Officer for escalations:

Nodal Officer – Mr. Biju Sukumaran
3rd floor, Tower 2, RGA Tech Park,
18 Sarjapur Road, Hadosiddapura,
Doddakannelli, Carmelaram,
Bengaluru – 560 035, Karnataka.
Email-Id: [email protected]

All escalations received would be acknowledged with 24 (twenty-four) hours and a resolution would be provided within 3 (three) working days. In case any escalation takes more than the specified resolution time, the User will be intimated accordingly and kept updated on the progress / status of the escalation on a periodic basis till such time that the escalation is resolved. However, it is to be noted that the time taken to resolve a Grievance may exceed, if the assistance of third-party service providers or partners is required.

Please note: You are requested to raise this higher Level – 2 service request using the Level – 1 service request details provided to you. This is to ensure that you get correct resolution faster based on the same ticket for resolution.

Level-3 :

In case there is no response within the defined timeframe for Level 2 service request or in case the response provided is not satisfactory, or if any User so desires for any reason whatsoever, they can reach out to the Grievance Officer for the matter:

Grievance Officer – Mr. Anish Pisharody
3rd floor, Tower 2, RGA Tech Park,
18 Sarjapur Road, Hadosiddapura,
Doddakannelli, Carmelaram,
Bengaluru – 560 035, Karnataka.
Email-Id: [email protected]

All escalations received would be acknowledged with 24 (twenty-four) working hours and a resolution would be provided within the next 3 (three) working days. In case any escalation takes more than the specified resolution time, the User will be intimated accordingly and kept updated on the progress / status of the escalation on a periodic basis till such time that the escalation is resolved. All of this would be available within the escalation reference number in our systems. However, it is to be noted that the time taken to resolve a Grievance may exceed, if any assistance of third-party service providers or partners is required.

For any queries or concerns regarding the financial products and services provided by SBM Bank (India) Ltd. ("SBM Bank"), you may contact SBM bank on [email protected] & 18001020370