Customer Grievances Policy

1. Introduction

PAY10 SERVICES PRIVATE LIMITED (formerly known as Bhartipay Services Private Limited) (“Pay10” or the “Company”) operates as a regulated payment services provider and offers technology-enabled digital payment solutions in accordance with the approvals and authorizations granted by the Reserve Bank of India (“RBI”) and other applicable regulatory frameworks.

The Company’s platform is ISO 27001 certified and PCI-DSS (Version 4.0) compliant.

Pay10’s operations are governed by the applicable regulatory framework issued by the Reserve Bank of India (“RBI”), including but not limited to:

• Guidelines on Regulation of Payment Aggregators and Payment Gateways (“PA PG”)
• Master Direction on Prepaid Payment Instruments (PPIs), 2021 (as amended from time to time)
• Applicable directions and circulars governing Payment Aggregator Cross Border (“PA-CB”), wherever applicable

In line with the applicable regulatory requirements, Pay10 has formulated this Customer Grievances Redressal Policy (“Policy”) with the approval of the Board of Directors (“Board”), to establish an effective, transparent, and structured mechanism for grievance registration, redressal, and escalation for merchants and customers.

This Policy sets out the grievance registration channels, redressal framework, escalation mechanism, resolution timelines, and the role and responsibilities of the designated Nodal Officer.

2. Objective

Through this Policy, Pay10 aims to achieve the following objectives:

• Establish a structured and transparent grievance redressal framework for merchants and customers availing services of Pay10
• Ensure timely resolution of complaints within the prescribed Turnaround Time (“TAT”).
• Provide complainants with adequate communication, acknowledgment, and complaint tracking facilities;
• Strengthen customer trust by promoting accountability and responsiveness in complaint management; and
• Ensure compliance with applicable regulatory requirements and industry best practices.

3. Definitions

For the purpose of this Policy, key definitions are as follows:

• Complainant means any merchant or customer availing the services of Pay10, directly or indirectly, through any of its payment platforms, applications, websites, or associated channels, and having a grievance as defined hereinunder.
• Customer means any end user who avails or uses the payment services, products, or solutions offered by Pay10, whether directly or indirectly through a merchant or any other authorized channel.
• Grievance / Complaint means any dissatisfaction, whether oral or written, expressed by a Complainant in relation to the services, products, or payment solutions offered by Pay10, including any deficiency in service, delay, omission, error, or any act or occurrence causing inconvenience or financial impact to the Complainant.
• Merchant means an individual, proprietorship, partnership, company, or any legal entity with whom Pay10 has entered into a valid agreement for availing payment aggregation or allied services.
• Nodal Officer means the designated official responsible for overseeing the grievance redressal mechanism and ensuring compliance with regulatory requirements.
• PPI means Prepaid Payment Instrument as defined under RBI regulations.
• Complaint Management System (CMS) means the internal complaint tracking and management system maintained by Pay10 for recording, monitoring, processing, and resolving complaints.
• PPI Wallet means a digital prepaid payment instrument issued by the Company, which stores monetary value and enables customers to undertake permitted transactions in accordance with applicable law.

4. Appointment of Nodal Officer

Pay10 has appointed a Nodal Officer who shall be responsible for overseeing the regulatory and customer grievance handling functions of the Company.

Contact Details:

The key responsibilities of the Nodal Officer shall include:

• Undertaking end-to-end ownership of the grievance management lifecycle;
• Ensuring redressal of customer complaints within the prescribed timelines;
• Acting as a single point of contact for regulatory and grievance-related matters;
• Monitoring complaint trends and identifying service improvement opportunities; and
• Ensuring adherence to regulatory instructions, circulars, and changes in relation to customer grievance redressal.

5. Grievance Redressal Framework

Pay10 recognizes the importance of customer grievances and feedback as an integral component of its service delivery framework. The Company is committed to maintaining high standards of customer service and ensuring that complaints and grievances are addressed in a fair, transparent, and time-bound manner.

The Company maintains all grievance-related records through its internal Complaint Management System (CMS) for effective monitoring, tracking, review, and closure.

Complaints may arise in relation to the services, products, or payment solutions offered by the Company, including but not limited to issues relating to service delays, technical difficulties, merchant integration, customer support, or any other operational or service-related concern.

6. Channels for Complaint Registration

A. For PA-PG / PA-CB Complaints

Contact Centre: 9700497004
Email: info@pay10.in
Website: Raise Grievance

B. For PPI Complaints

Contact Centre: 1800-202-1010
Email: contact.us@pay10.in
Website: Raise Grievance

7. Complaint Redressal Process

The grievance redressal process of Pay10 shall broadly consist of the following:

Step 1: The Complainant may lodge a complaint with the Level 1 support team using any of the above- mentioned channels.

Step 2: Upon receipt of the complaint, an acknowledgment along with a unique complaint reference number shall be issued to the Complainant within 24 hours.

Step 3: The Level 1 support team shall review the complaint and take necessary action for redressal based on the available information.

Step 4: In case additional investigation or clarification is required, the complaint may be escalated internally for further review.

Step 5: If the Complainant is dissatisfied with the redressal provided, the matter may be escalated through the escalation matrix provided under this Policy.

Step 6: Upon successful resolution, the complaint shall be formally closed in the Complaint Management System.

Step 7: Periodic reports shall be generated for review, analysis, and improvement of customer service standards

8. Required Details for Complaint Registration

The Complainant shall, wherever applicable, provide the following information:

• Date of transaction
• Transaction ID / Order ID (if any)
• Amount of Transaction
• Registered mobile number
• Description of issue
• Relevant supporting documents/screenshots

9. Escalation Matrix

9.1 Payment Aggregator-Payment Gateway & Payment Aggregator-Cross Border

9.2 Prepaid Payment Instrument

In case the Complainant remains dissatisfied with the resolution provided by the Company, the Complainant may approach the Reserve Bank of India under the Integrated Ombudsman Scheme, 2021, subject to the eligibility criteria and timelines prescribed therein.

The complaint may be lodged through RBI’s Complaint Management System portal at: https://cms.rbi.org.in/

10. Turnaround Time (TAT)

The Company shall endeavour to acknowledge and resolve complaints in a timely and efficient manner. The expected timeline for redressal of complaints at each level of escalation shall be as follows:

The Company shall make reasonable efforts to resolve complaints at the earliest possible stage. However, the timelines may vary depending upon the nature and complexity of the complaint and involvement of external stakeholders, including banks, merchants, payment networks, or regulatory authorities.

Under all circumstances, the Company shall ensure closure of the complaint within a maximum period of 30 working days from the date of initial receipt of the complaint.

11. Refund & Cancellation Related Complaints

• Complaints relating to cancellation, returns, refunds, and suspected fraudulent transactions shall be reviewed and addressed in accordance with the applicable policies of the Company, the concerned merchant, and relevant banking or payment network guidelines, wherever applicable.
• In cases involving merchant-related products or services, including order cancellations, returns, dispatch, or delivery-related concerns, the primary responsibility for resolution shall remain with the respective merchants.
• Where applicable, any refund arising out of a valid complaint shall be processed subject to reconciliation, verification, and applicable internal controls of the Company.
• Any request for refund or reversal into an account or payment instrument other than the original source shall be considered only in exceptional circumstances and subject to due diligence and documentary verification.
• Complaints involving unauthorized or fraudulent transactions shall be handled in accordance with applicable laws, regulatory guidelines, and the Company’s internal investigation framework.

12. Complaint Review Mechanism

In order to continuously improve its grievance management framework, Pay10 shall periodically review complaints on the basis of:

• Number of complaints received;
• TAT adherence;
• Number of escalations;
• Recurring complaint trends;
• Root cause analysis;
• Complaints escalated to the RBI Ombudsman; and
• any operational or service deficiencies identified.

Based on the review, the Company may undertake corrective actions and update this Policy accordingly.

13. Maintenance of Records

Pay10 shall maintain complete records of all complaints received, including:

• Name and Contact details of the Complainant;
• Nature of complaint;
• Complaint reference number;
• Status of complaint;
• Resolution provided;
• Communication records; and
• Compensation, if any.

Such records shall be retained in accordance with the applicable legal, regulatory, and internal record retention requirements.

14. Policy Review

This Policy shall be reviewed at least once annually or earlier in the event of:

• Changes in regulatory framework;
• Changes in business operations;
• Introduction of new products or services; or
• Directions issued by the Board or regulators.

15. Conclusion

Pay10 remains committed to maintaining the highest standards of customer service and grievance management. Through this Policy, the Company seeks to ensure fair, transparent, and efficient resolution of complaints, while upholding customer trust and regulatory compliance.