Grievance Policy

Objectives

This policy summaries an organized protection & grievance redressal of customers including partners for escalating their queries and grievances to get a resolution. This policy covers all the services offered by Eroute Technologies Private Limited. It aims to improve customer experience and service delivery by ensuring fast redressal of all the grievances.

Eroute Technologies Private Limited strives to provide superior service delivery and has a dedicated Help desk team for managing any queries and grievances.

Scope

Eroute Technologies Private Limited is authorized by the Reserve Bank of India under the Payment & Settlement Act, 2007 to issue and operate Pre-paid Payment instruments as per Master directions on Issuance and Operations of Prepaid Payment Instruments 2021. This policy highlights the mechanism and framework for customer protection, reporting and resolution of issues reported by the customers using our wallet backed card PPI under the name of “OmniCard”.

Grievance Redressal Framework

Eroute Technologies Private Limited has disclosed all important terms and conditions in clear and simple language to its customers on the “OmniCard” website and mobile APP. These disclosures include:

1. All charges and fees associated with the use of the instrument; and
2. The expiry period and the terms and conditions pertaining to expiration of the instrument.

The Company further takes constant initiatives for creating sufficient awareness and educate customers in the secure use of OmniCard, including the need for keeping passwords confidential, procedure to be followed in case of loss or theft of card or authentication data or if any fraud / abuse is detected, etc.

The customers can request to generate / receive account statements for at least past 6 months via placing a request. Additionally, the customer has option to view transaction history for at least 6 months on the mobile application.

The company is responsible for addressing all customer service aspects related to all PPIs (including co-branded PPIs) issued by us as well as our agents.

The FAQ has been provided on the OmniCard website and mobile application for address to customer queries. The FAQ is updated as and when required for ready reference to the customers.

The company is also guided by the following DPSS circulars:

1. Harmonisation of Turn Around Time (TAT) and customer compensation for failed transactions using authorised Payment Systems issued vide DPSS circular DPSS.CO.PD No.629/02.01.014/2019-20 dated September 20, 2019 (as amended from time to time);
2. Online Dispute Resolution (ODR) system for resolving customer disputes and grievances pertaining to digital payments, using a system-driven and rule-based mechanism with zero or minimal manual intervention, issued vide DPSS circular DPSS.CO.PD No.116/02.12.004/2020-21 dated August 6, 2020 (as amended from time to time).

Our Response Time

The following is a tabular representation of our turnaround time for complaints / grievances:

If any of the above complaint/grievance is not addressed to the satisfaction of the customer, then the customer can choose to escalate the same to the next level, with the original complaint ticket number and the details, of the grievance/query raised.

Note:

1. A reference number will be generated for all queries for future reference.
2. Customer and Partner will be informed regarding the progress.
3. All queries will be closed, after receiving the customer’s and partner’s feedback or acceptance of closure.

Escalation Matrix:

Level 1

1. Complaint / Grievance lodged by the customer through Level 1 with OmniCard Help & Support team will be initiated for action within 48 hours of the receipt of the complaint.
2. For every complaint/ grievance filed by the customer, a unique ticket number will be generated & Communicated for future reference.
3. The complaint shall be resolved within 7 days of the receipt of the complaint.
4. Resolution on the complaints may get delayed due to technical or operational reasons or there may be a case where resolution provided to a complaint is instant but it may take time to get reflected in the system for example, in the cases of refund. In such scenarios, customer shall be proactively informed of the timelines.
5. Complaints related to ‘fraud and risk assessment’ often take longer to investigate due to the involvement of multiple agencies. The resolution time in such cases is dependent on the severity and complexity of the case. Customer shall be proactively informed of the timelines in such cases.
6. Guidelines and instructions issued by the authorities shall be strictly adhered to.

Level 2

1. For unsatisfactory resolution at Level 1, customer can escalate the complaint / grievance to Level 2 support.
2. The complaint / grievance at Level 2 shall be resolved within 7 days of the escalation.

Level 3

1. The customers dissatisfied with the resolution at Level 2 can escalate their complaint/grievance to Level 3 with the Nodal Officer.
2. The Nodal / Grievance Officer shall look into the complaint and provide the resolution within 15 days from the date of the escalation
3. The Company will make all efforts to resolve the complaint in a timely manner but in case of any inadvertent situation where additional time is needed, we will inform the customer the reasons for the delay and provide expected timelines for resolution of the issue.

Banking Ombudsman

If customer complaint has not been satisfactorily resolved at previous levels within 30 days, Customer can seek recourse to the Banking Ombudsman Scheme Reserve Bank - Integrated Ombudsman Scheme, 2021 (as amended from time to time for grievance redressal).

To Block and Report Unauthorized Transaction on OmniCard wallet and / or card:

To report unauthorized electronic payment transaction on OmniCard wallet and/ or card, customer can Report via OmniCard APP by visiting the Help & Support Section on the OmniCard APP and choose option ‘Fraudulent Use’ to report. A ticket Id will be generated for reference or communication with our investigation officer.

We at Eroute Technologies Private Limited (“OmniCard”) caution our Customers and the people (who are not our users) not to fall prey to fictitious offers and or unsolicited phone calls or emails asking for financial information or any other type of personal information. It has been observed that fraudsters have resorted to defraud the susceptible public by convincing them over a phone call to divulge details of the debit / credit / prepaid card or their bank account information in order to commit cybercrimes. Recipients of such communication fall prey to frauds or scams perpetrated by individuals who impersonate to be employees of various financial institution and end up compromising their confidential information and that which is later on used by such fraudsters on ecommerce and m-commerce platforms. We apprise you that Eroute Technologies Private Limited (“OmniCard”) team will never ask for the details of your Account / PIN / Password / Full Debit / Credit Card number / Expiry Date / OTP / CVV / Confidential Bank Account details or any other security/personnel information.

OmniCard has implemented a highly secured environment in order to avoid and check fraudulent transactions – however it is important for customers to ensure that they exercise caution and refrain from compromising sensitive and personal information.

Limiting liability of customers in unauthorised electronic
payment transactions in PPIs issued by banks and non-banks

With reference to the RBI circulars BI/2018-19/101 DPSS.CO.PD.No.1417/02.14.006/2018-19 dated January 04, 2019 , as applicable on Customer Protection – Limiting Liability of Customers in Unauthorised Electronic Payment Transactions, the company has laid the below framework for determining the customers’ liability in unauthorised electronic payment transactions resulting in debit to its PPIs.

For this purpose, electronic payment transactions have been divided into two categories:

1. Remote / Online payment transactions: Transactions that do not require physical PPIs to be presented at the point of transactions e.g. wallets, card not present (CNP) transactions, etc.; and
2. Face-to-face / Proximity payment transactions: Transactions that require physical PPIs to be present at the point of transactions e.g. transactions at ATMs, PoS devices, etc.

For this purpose, Company has ensured the below mentioned provisions:

1. The customers shall mandatorily register for SMS alerts and wherever available also register for e-mail alerts, for electronic payment transactions.
2. The SMS alert for any payment transaction in the account is sent to the customers and e-mail alert may additionally be sent, wherever registered. The transaction alert shall have a contact number and / or e-mail id on which a customer can report unauthorised transactions or notify the objection.
3. Customers are advised to notify the non-bank PPI issuer of any unauthorised electronic payment transaction at the earliest and, further be informed that longer the time taken to notify the non-bank PPI issuer, higher will be the risk of loss to the non-bank PPI issuer / customer.
4. The customers are provided 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.
5. Direct link for lodging of complaints, with specific option to report unauthorised electronic payment transactions is provided on mobile APP / home page of its website / any other evolving acceptance mode.
6. The loss / fraud reporting system has an immediate acknowledgement response with complaint number (including auto response) is sent to the customers. The communication systems records time and date of delivery of the message and receipt of customer’s response

Customer’s liability arising out of an unauthorised payment transaction will be limited to:

On being notified by the customer, Company shall credit (notional reversal) the amount involved in the unauthorised electronic payment transaction to the customer’s wallet/ or card within 10 days from the date of such notification by the customer (without waiting for settlement of insurance claim, if any). The credit shall be value- dated to be as of the date of the unauthorised transaction.

Company shall ensure that a complaint is resolved and liability of the customer, if any, established within such time, as may be specified in the company’s Board approved policy, but not exceeding 90 days from the date of receipt of the complaint, and the customer is compensated as per provisions of paragraph above.

However, in case of established authorized electronic payment transaction by a customer, the case will be treated as a case of contributory fraud / negligence / deficiency on the part of the customer and refund will be only initiated as per directions of Law enforcement agencies/ Statutory/ Regulatory bodies.

The burden of proof for devising customer liability in case of unauthorised electronic payment transactions shall lie on Company and for all other cases shall lie on the customer.

Review Mechanism

The Grievance Redressal Mechanism is reviewed periodically on monthly basis as mentioned below:

The functions of the Committee are as under:

1. The Committee will be responsible for ensuring timely and effective implementation of all regulatory requirements regarding customer service.
2. The Committee will look into the simplification of procedures and practices prevailing in the Company with a view to safeguarding the interests of customers of the Company.
3. The Committee will review the regulations and procedures prescribed by RBI for customer service and whether the same are adopted in spirit and intent by the Company and make suitable recommendations for rationalization of the same.
4. The Committee will review the practice and procedures prevalent in prepaid payment solutions industry and take necessary corrective action on an on-going basis.
5. The Committee will endeavour to proactively advice the Customer Support on pending complaints.
6. The Committee will address the grievance of the Customer if he/she is not satisfied with the decision of the Customer Support.

Harmonisation of Turn Around Time (TAT) and customer compensation

All domestic transactions initiated or processed by the Company that could not be completed and got failed shall be eligible for compensation as per the TAT prescribed by RBI notification RBI/2019-20/67 DPSS.CO.PD No.629/02.01.014/2019-20 dated September 20, 2019 (as amended from time to time)

Final Redressal and Closure of Grievance

Grievance shall be treated as finally redressed and closed in any of the following circumstances:

1. Where the Complainant has communicated his acceptance of the Company's decision on redressal of grievance communicated by Customer Support and / or Grievance office OR
2. Where the Complainant has not communicated his acceptance of the Company's decision, within one month from the date of communication of decision by the Customer Support or the Committee, as the case may be.