INTRODUCTION

Penpay Technologies Private Limited, is a private limited company incorporated as per the provisions of the Companies Act 2013, having its registered office at H.No. 147, Kh.No.241/2, 3rd Floor New Mangla Puri, Gadaipur, South West Delhi, New Delhi, India, 110030, (hereinafter referred to as “Penpay” or “Company”) provides payment solutions to businesses helping them to collect and disburse payments. Further the Customer/Merchant using the Company’s services or visiting the Website shall be hereinafter referred to as “You” or “Your”.

By accessing this website we assume you accept these terms and conditions. Do not continue to use Penpay if you do not agree to take all of the terms and conditions stated on this page.

The Company acts as an intermediary between its business customers (“Merchants”) and the end users (“Consumer”) by aggregating various payment instruments to facilitate online transactions. Penpay offers financial services to the Merchants or other Business entities and Customers, as the Company places a high value on customer happiness in an effort to build lasting relationships and encourage safe and secure digital transactions.

Penpay has outlined this Grievance Redressal Policy to include mechanisms such as (a) guaranteeing that Merchants and Customers are treated equally and impartially at all times, and (b) giving them a chance to voice and/or escalate complaints to Penpay.

This Policy is applicable to Penpay, and all the products and services offered by Penpay including, its Merchants, Partners, Employees, Customers, and Agents doing business with it.

PRINCIPLES GOVERNING THIS POLICY

Penpay’s policy on grievance redressal is governed by the following principles:

• Customers / Merchants shall be treated fairly at all times.
• Complaints raised by Customers/ Merchants shall be attended with courtesy and on time.
• Customers / Merchants shall be fully informed of avenues for grievance redressal within the organization and their right to approach the Grievance Redressal Officer in case they are not fully satisfied with the response of the Customer Support

OBJECTIVE

As a financial service provider, customer service and customer satisfaction are the prime concerns of the Company and thus the objective of this policy is to minimize instances of customer complaints through proper service delivery and review mechanism and prompt redressal of various types of Customer Grievances and/or Complaints.

DEFINITIONS

• “Customer(s)” is defined as an end-customer who will be purchasing goods /services from the Merchants by making payment via different payment instruments such as credit/debit card, UPI transactions, Wallets etc.
• “Merchant(s)” shall be a user of Penpay’s services for accepting various payment instruments from the Customers for completion of their payment obligation.
• “Grievance” shall mean communication in any form by a customer expressing discontent with the Company’s or its representative's conduct or inaction, or with the quality of service provided in connection with the use of Penpay Services.
• “Redressal” shall mean the final disposal of the Grievance of the Complainant by Penpay.
• “Business Day” shall mean any day (other than Sunday & Public Holiday) on which Penpay’s Office is open for business operations.
• “Complaint(s)” shall include service deficiency or error on the part of Penpay in offering any service and /or non-conformance in any of the Penpay’s product / process leading to a dispute / grievance by the Merchant or the Customer. Examples of such complaints -
  • Customer facing unreasonable delay (beyond delivery due date) or failure on part of the Merchant in delivering goods / services for which the payment transactions were processed using Penpay services, and Merchant is not supporting the Customer;
  • Customers having noticed an unauthorised electronic fund in their account, and the funds were used to process transactions on Penpay’s platform, and the Customer approached Penpay through appropriate legal procedures;
  • Unreasonable delay (beyond the time communicated to the Customer by the Merchant) on refunding the transaction amount post refund confirmation;
  • Merchants not getting services as promised by Penpay, including downtime of the payment gateway etc.
  • Any other issue pertaining to the transaction processed by Penpay.

GRIEVANCE REDRESSAL MECHANISM

Escalation Matrix and Turnaround Time

The Customer/Merchant may raise queries/Complaints with Penpay using any of the following methods:

Level 1:

• In case the Merchant / Customer wishes to raise a complaint/grievance, the Merchant/Customer can write to us at legal.penpay@gmail.com .
• The Company shall attempt to respond within 30 business days from the date on which grievance was filed.
• The Company shall provide an option to the Customers / Merchants to seek / track the status of their grievances, throughout the lifecycle of a grievance, via the merchant dashboard on its website.
• The Company shall provide an option to the Customers / Merchants to seek / track the status of their grievances, throughout the lifecycle of a grievance, via the merchant dashboard on its website.
• If the Merchant / Customer is not satisfied with the response provided, the Merchant / Customer can go for the next level of raising a complaint.

Level 2:

In case the Merchant / Customer still has any complaint / grievance, the Merchant / Customer may escalate such complaint / grievance to Penpay’s Grievance Officer, having the following details:

Address:

H. No. 147, Kh.No.241/2, 3rd Floor New Mangla Puri, Gadaipur, South West Delhi, New Delhi, India, 110030.

E-Mail:

legal.penpay@gmail.com

The Grievance Officer shall attempt to respond within 30 business days of lodging the complaint. Such responses may either contain the resolution or an intimation that the Company requires more time to examine the complaint, along with the reason for seeking such extension. The Merchant/Customer may request for an update on the grievance in case any grievance requires more than the specified time period.

CHARGEBACK MECHANISM AND HANDLING PROCESS

When a customer files a claim with the issuing bank against a purchase or transaction that was made on their account, it is referred to as a “chargeback”. It serves as a protection mechanism for consumers against fraudulent or unsatisfactory transactions.

Card networks and regulated entities such as National Payments Corporation of India (NPCI) provide the rights to the cardholder/consumer to claim a chargeback for various reasons such as:

• Fraud transactions;
• Product/ services not delivered;
• Defective product or services are delivered;
• Duplicate payments/ double debits;

The timeline(s) for raising such disputes may vary from card association to card association.

Chargeback Process

It is to be noted that the issues related to chargeback and fraud alerts are to be raised at legal.penpay@gmail.com . Penpay has an internal dispute management system responsible to handle each query that gets forwarded from the Issuing Bank to the Acquiring Bank who in turn raises the dispute to the merchant to initiate an investigation.

Dispute/Chargeback Management

1. Chargeback Notification and Alert System

• Immediate Notification

  Penpay has tied up with a payment facilitator which will send an automated alert system to notify merchants immediately when a chargeback is initiated. The notification includes comprehensive details such as the transaction ID, disputed amount, reason code, and the response deadline and thereafter it is shared through email, SMS, or an in-platform notification.

• Merchant Dashboard

  A dashboard is provided on company’s website where a merchant can view all chargeback notifications in real-time and track their status throughout the dispute process.

2. Automated Data Collection and Record Keeping

Penpay complies with all relevant transaction data and keep a record of the same when a chargeback complaint is received, which includes: Transaction amount and date; customer information; product or service details; payment method and authorization codes.

3. Merchant Support and Guidance

Penpay provides assistance to merchants on how to respond to a chargeback, including what type of evidence to gather based on the chargeback reason code.

Penpay also supports the merchant to submit the response and evidences directly through its platform, ensuring that the correct documents have been uploaded by the Merchant so that the gathered evidences can be forwarded to the acquirer’s bank in realtime. Penpay also confirms the receipt of the submission and provide tracking for merchants to monitor the status of their disputes.

4. Financial Reconciliation

After the resolution of the Chargeback dispute, Penpay automatically adjust the merchant’s account based on the outcome. In case the decision is in favour of the Merchant, then under such circumstances, Penpay ensures that the disputed funds are credited back to their account promptly, displaying a clear breakdown of any fee or adjustments made due to the chargeback.

5. Preventive Measures to avoid disputes

Penpay conducts regular review of chargeback data to identify patterns in order to avoid fraud and future disputes. Further, the company also advices the merchants on implementing best practices to reduces chargeback disputes such as enhanced fraud detection, clear communication and improved customer services.

Chargeback Resolution and Possible Outcomes

All the Chargeback alerts must be sent to legal.penpay@gmail.com where Penpay’s internal team will process it and ask the merchant for supporting documents and further evidences. In case of turnaround time, the dispute is submitted to acquirer within maximum 30 business days from the day of chargeback complaint received by the acquiring bank.

Further, there shall be financial impacts in case the chargebacks remain unaddressed within the stipulated deadline or if insufficient documentation results in chargeback loss, a corresponding amount will be deducted or adjusted from the merchant. Additionally, fees and penalties imposed by the networks relevant to the chargeback stage will be recovered from the merchant.

Outcome	Details	Merchant Impact	Actions Needed
Chargeback reversed (Merchant Wins)	Funds will be returned to the merchant without any additional fee	Revenue shall be recovered	The Merchant andPenpay shouldContinue withcurrent practices.
Chargeback Upheld (Customer wins)	Funds will be retained by the customer and the merchant will have to pay possible chargeback fee (if any)	Revenue is lost and Merchant can incur potential penalties for high chargeback rates	The Merchant and Penpay should review and improve dispute handling process and subsequently implement stronger preventive measures

RESOLUTION OF COMPLAINTS AND CHARGEBACK DISPUTES

• Resolution of Your complaint may get delayed due to operational or technical reasons. In such a scenario, the Merchant/Customer will be proactively informed of the timelines during which their complaint will be addressed.
• In a few scenarios, while the resolution to a complaint is instant, it may take time for it to get reflected in the system. For example, refund approval can be instant, but it may take 7-10 business days to reflect money into the account. Please note that such delays are attributable to banking and other operational issues
• 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.
• In case of Chargeback dispute, when the Customer’s chargeback is valid, the Merchant may choose to accept the chargeback. An acceptance will result in a credit to the Customer’s account as per the network timelines and a permanent debit to the Merchant’s account.
• In the event a chargeback is not represented / accepted by the Merchant within the given timeline, the chargeback is deemed as accepted and the decision is not reversible. As in Page | 8 the case of acceptance this too shall have a permanent debit to the Merchant’s Penpay account.

COMPENSATION FOR FAILED TRANSACTIONS AND REVERSALS

A “failed transaction” is defined as a transaction that has not been completed for any reason that is not attributable to the customer, such as a communication link failure, a session timeout, etc., in accordance with RBI’s Notification on Harmonisation of Turnaround Time (TAT) and customer compensation for failed transactions. Failed transactions shall also include the credits which could not be affected to the beneficiary account on account of lack of full information or lack of proper information and delay in initiating a reversal transaction. Further, domestic transactions i.e., those where both the originator and beneficiary are within India were covered as part of the circular.

As a result, Penpay ensures that the reversals occur within the RBI guidelines with respect to Turnaround Time (TAT) for the particular payment method utilised, or else it must compensate the consumer for any delays.

REGULATORY GUIDELINES

This Policy is aligned with the applicable laws and regulations, including but not limited to those issued by the Reserve Bank of India (RBI). It supersedes previous versions and adheres to the following key regulatory frameworks:

• RBI Guidelines on Regulation of Payment Aggregators and Payment Gateways: This Policy complies with all current and future amendments to these guidelines.
• RBI Notification on Harmonisation of Turnaround Time (TAT) and Customer Compensation for Failed Transactions using Authorised Payment Systems:

  This Policy ensures adherence to the TAT and compensation rules as specified and updated by the RBI.

• RBI Notification on the Integrated Ombudsman Scheme, 2021:

  This Policy incorporates the directives under the Integrated Ombudsman Scheme to ensure effective grievance redressal.

In the event of any changes or amendments to applicable laws, including those related to the grievance redressal mechanism, such changes shall be automatically incorporated into this Page | 9 Policy. Consequently, this Grievance Redressal Policy shall be considered updated and revised in accordance with the new legal requirements without further need for modification.

REVIEW

This Grievance Redressal Policy is subject to review by the Board of Directors of Penpay as and when deemed necessary. The Board of Directors shall annually review the functioning of the grievance redressal mechanism and have all the rights to review, modify and amend this Policy from time to time.

DISCLAIMER

PENPAY TECHNOLOGIES PRIVATE LIMITED SHALL NOT BE LIABLE FOR ANY FAILURE OR DELAY IN ITS PERFORMANCE UNDER THIS GRIEVANCE REDRESSAL POLICY CAUSED BY FORCE MAJEURE EVENTS SUCH AS ACTS OF GOD, ACTS OF CIVIL OR MILITARY AUTHORITIES, FIRES, EPIDEMICS, PANDEMICS, FLOODS, EARTHQUAKES, RIOTS, SABOTAGE OR DESTRUCTION OF PRODUCTION FACILITIES, SYSTEMS FAILURE, TECHNICAL MISHAPS, STRIKES, WORK STOPPAGES, OR ANY DISPUTES SUCH AS INDUSTRIAL DISPUTES.