Customer Grievance Redressal Policy
Updated on 28-04-2024
The policy has undergone changes pursuant to issuance of Payment Aggregator-Cross Border guidelines issued by Reserve bank of India (RBI/2023-24/80 CO.DPSS.POLC.No.S-786/02-14-008/2023-24). Hence PA-CB shall be read as Payment Aggregator-Cross Border (PA-CB) for the purpose of this document.
Introduction
GoBrisk Technologies Private Limited (hereinafter referred to as ‘BRISKPE’) incorporated on February 21, 2023, is a Mumbai-based financial services technology startup. BRISKPE currently operates as an Online Payment Gateway Service Providers (‘OPGSP’), facilitating payments for the export of goods and services. BRISKPE intends to undertake the facilitation of both import and export payments upon receipt of the authorization from the RBI under the ambit of Regulation of Payment Aggregator – Cross Border (PA – Cross Border) (“PA-CB Regulations”).
BRISKPE has set up a strong system for addressing complaints and grievances, allowing Users to seek redress swiftly and efficiently for their concerns. The primary goal of BRISKPE’s grievance redressal mechanism is to deliver timely and comprehensive resolutions to User complaints, queries, and grievances.
BRISKPE has put in place a Grievance Redressal Policy (the ‘Policy’) duly approved by the Board of Directors encompassing the requirements emanating from the following guidelines:
BRISKPE has put in place a Grievance Redressal Policy (the ‘Policy’) duly approved by the Board of Directors encompassing the requirements emanating from the following guidelines:
- Guidelines on Regulation of Payment Aggregators and Payment Gateways, 2020;
- PA-CB Regulations;
- Harmonisation of Turn Around Time (TAT), 2019;
- Integrated Ombudsman Scheme, 2021; and
- Online Dispute Resolution (ODR) for Digital Payments, 2020.
For the convenience of all stakeholders, BRISKPE has made the Grievance Redressal Policy accessible on its website/ mobile application along with the details of the Nodal officer. Additionally, BRISKPE has also displayed Frequently Asked Questions (FAQs) on its website/ mobile application for ease of reference to its Users.
Key Definitions
The key definitions for the purpose of this Policy are as follows:
- Customer/ User/ Complainant: : Refers to individuals or entities utilising the payment solutions provided by BRISKPE and raising concerns or complaints regarding the services rendered.
- Complaint/ Grievance:: Any dissatisfaction or complaint raised by a User concerning the services provided by BRISKPE, including but not limited to transaction-related issues, service related concerns, etc.
Please note, communications meant to provide suggestions, feedbacks, queries or clarifications, won’t be considered as instances of complaints or grievances. - Nodal Officer:: A designated individual appointed by BRISKPE to oversee the grievance redressal process, coordinate with relevant departments, and ensure timely resolution of grievances as per the established procedures.
- Unique Ticket Number (UTN): A unique identifier assigned to each User complaint upon registration, facilitating tracking and monitoring of grievance resolution progress by both the User and BRISKPE.
Objectives
The primary objectives of the Grievance Redressal Policy are:
- To provide Users with equitable, unbiased, and fair treatment;
- To address all User-related concerns within prescribed timelines;
- To maintain the fundamental principles of integrity and transparency;
- To protect Users from fraudulent activities, deception, or unethical conduct;
- To educate Users about the available avenues and escalation procedures for grievance resolution if they are not satisfied with the resolution;
- To continually enhance our service quality based on regular evaluations of the grievance resolution framework; and
- To prevent the occurrence of similar complaints in the future.
Grievance Redressal Mechanism
BRISKPE’s Grievance Redressal Mechanism is designed to encompass accessible modes for complaint registration, escalation matrix, turn-around time for grievance redressal, etc.
The principal elements of BRISKPE’s mechanism for resolving complaints/ grievances are detailed below:
- Complaint Registration Channels for Complaint Registration
- Acknowledgement BRISKPE will send an acknowledgement email to the complainant within 24 hours of receiving a complaint.
- Tracking of Complaints BRISKPE will assign a Unique Ticket Number (‘UTN’) to each complainant with the acknowledgement email. The UTN will be used by the complainant to check the status of the resolution on any of the aforementioned channels. In addition, the Customer Support Team will keep the complainant updated on the progress and status of the complaint/ grievance periodically until resolution.
- Monitoring and TAT for Complaint Resolution Complaints will be monitored regularly for resolution within a time-bound manner, ensuring timely updates are provided to the complainant. Further, complaints will be marked as closed only after resolution. BRISKPE will ensure that complaints are disposed of within 30 working days of its receipt.
- Response to disposal of complaints BRISKPE will provide detailed reasons via email for the resolution or rejection of the complaint.
- Appointment of the Nodal Officer BRISKPE has designated Mr. Rohan Dani, as the Nodal Officer. The Nodal Officer’s responsibilities encompass managing regulatory and grievance redressal functions. BRISKPE’s website features the particulars of the appointed Nodal Officer.
- Escalation Matrix
| Level | Responsible Person | Mode | TAT |
|---|---|---|---|
| Level I | Service First |
|
Resolution within 1 to 2 working days |
| Level II |
Nodal Officer Mr. Rohan Dani Director Operations |
|
Resolution within 5 to 7 working days |
- Filing a Complaint with the Integrated Ombudsman In the event that complaints remain unresolved after reaching Level II, Users have the option to approach the RBI Integrated Ombudsman under the ‘The Reserve Bank – Integrated Ombudsman Scheme, 2021;
- Record MaintenanceBRISKPE maintains a comprehensive record of all complaints, encompassing details about the nature of the complaint, the actions undertaken for its resolution, and the corresponding timelines.
- Record Maintenance BRISKPE maintains a comprehensive record of all complaints, encompassing details about the nature of the complaint, the actions undertaken for its resolution, and the corresponding timelines.
- Turn Around Time (TAT) for resolution The indicative TAT for the resolution of certain types of complaints are outlined below:
| Type of Complaints | TAT Resolution |
|---|---|
| Onboarding / Registration | Within 4 working days |
| Change in Businesses / Merchant information including KYC | Within 2 working days |
| Enquiry about transaction status | Within 2 working days |
| Settlement not received | Within 2 working days |
| Beneficiary did not receive the payment | Within 2 working days |
| Refunds / Returns | Within 4 working days |
| Chargeback | Within 7 working days |
| On Hold Transactions | Within 2 working days |
| Failed transactions | Within 2 working days |
| Transaction successful, but services not delivered | Within 4 working days |
| Transaction successful & services also delivered, but the user is not satisfied with the product/services | Within 4 working days |
| Fraudulent activity | Within 1 working day |
Note: The aforementioned TATs depend on prompt responses from any involved third parties, such as Merchants, payment service partners, etc.
Settlement Process
- All inward transactions for a customer should be permitted as per the regulatory guidelines for exports of goods and services.
- For the export inward transaction, there could be below mentioned scenarios:
- Funds received, matching invoice is not available;
- Invoice Received, matching inward is not available;
- Funds received, matching invoice is available, transaction monitoring documents are not available (In the case of transaction monitoring, BRISKPE may ask for additional documents from the merchants).
- All inward transactions, subject to satisfactory compliance requirements shall be settled within Td+1 working days. Td is defined as the working day (India and Overseas) on which Commercial Invoice, Shipping Documents (where applicable), remitter details (wherever applicable as per transaction monitoring process) and funds are received, whichever is later. Td will be ascertained once all the requisite documents are received as per our internal policy.
- In the event customer fails to provide the necessary underlying transaction details i.e. underlying invoice, shipment/delivery details, Goods/Service Contract copy to ascertain Genuity of the transactions, shall be marked for return to the remitter after 5 working days
- The compliance team reserves the right to reject and return the processing of any transaction if operations/compliance team ascertains that transaction is outside risk appetite of BRISKPE. Customer shall be informed by way of mail w.r.t. such rejections/return.
Disposal of Complaints
Customer Complaint Management Process:
Customer Complaint Management Process:
- We have implemented a systematic process for tracking and promptly resolving customer complaints at BRISKPE.
- Our objectives include ensuring adequate complaint responses, acceptable response times, complaint closure, and continuous analysis of trends for improvement.
- 3. Customer queries, when service-led deficiencies are identified, are categorized as complaints, and resolved according to the following table:
| Customer Queries | Resolution |
|---|---|
| Enquiry about transaction status or payment | Transaction details and payment status provided |
| Charge related | Information on charge with a detailed breakup is details provided |
| Buyer Payment not reflecting on app | Receipt status is verified with the concerned bank or payment provider |
| Credit not reflecting in customer’s account | Credit status verified with the concerned bank or payment provider |
| Mismatch Credit and FIRA Amount | Details of all inward, necessary charges and deduction provided |
| Return/Refund related |
|
Management of Chargebacks
1. Chargebacks, the reversal for local payment methods/SWIFT transactions initiated by customers, are managed comprehensively at BRISKPE as per the Master Direction on Export of Goods and Services
2. Types of chargebacks and associated remedies are clearly defined.
| Chargeback Reason | Description | Remedy |
|---|---|---|
| Merchandise not received | Claims of non-provided services or undelivered goods |
|
| Duplicate Processing/ Paid through other means | Payer cancels transaction; refund or credit is due |
|
| Account debited but confirmation not received | Dispute of payment made but not credited: transaction has failed | Provide confirmation of no credit to BRISKPE |
| Goods not as described | Claims that merchandise doesn’t match website/Email/Product Template description | Raise dispute with seller as per UCP under laws of ICC |
| Return/Refund related | For cases where transaction has been rejected by compliance | shall be returned to remitter and an email shall be provided to the customer |
3. For Account-to-Account payments, Chargeback request processing is subject to availability of funds in the collection A/C
4. For Card payments, BRISKPE Chargeback Management System shall oversees dispute stages and participant access (To be developed before product launch).
5. Roles and responsibilities are defined per collection rails providers/bank’s guidelines for appropriate dispute resolution.
Dispute resolution process includes obtaining supporting documents, resolving disputes, and final resolution based on bank’s/payment rail’s decisions.
Processing of Refunds
- Refunds, originating from various scenarios, are efficiently handled at BRISKPE.
- Refunds initiated by merchants processed within payment service provider/Bank’s timelines.
- Daily reconciliation is conducted with payment service providers and banks to identify failed transactions and report them accordingly.
Review of Policy
BRISKPE will review the Policy once in two years or earlier, if required, in light of any material changes in regulatory framework or for business or operational reasons. Any subsequent changes will form part of the Policy after the approval of the Board.
Contact Us and Details of Grievance Officer
We understand that you may have questions about this Privacy Policy, on how we process or handle your Customer Information, or may otherwise want to understand these aspects. We welcome you to reach out to us with your queries, grievances, feedback, and comments at
Name: Mr. Rohan Dani
Designation: Nodal Officer
Email: rohan.dani@www.briskpe.com
