Garagepreneurs Internet Private Limited
CUSTOMER GRIEVANCE REDRESSAL
POLICY
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Approval History
This document has been approved by Board of Directors on
1
08 September 2023
2
24 May 2024
3
10 June 2024
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Contents
1. Background ........................................................................................................ 3
2. Key Definitions ................................................................................................... 3
3. Objectives ........................................................................................................... 4
4. Grievance Redressal Framework ......................................................................... 4
5. Maintenance of records ..................................................................................... 12
6. Reporting .......................................................................................................... 12
7. Review of the policy ........................................................................................... 12
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1. Background
GaragePreneurs Internet Private Limited, (“the Company” or “slice”) is a fintech entity
incorporated under the Companies Act, 2013 in 2015 having its registered office in Bangalore. The
Company had recently applied to the Reserve Bank of India (“RBI”) seeking authorization to issue
Prepaid Payment Instruments (“PPI”) under the Master Directions on PPIs (“PPI Master
Directions”) issued by the RBI and has been granted approval by the RBI for setting up and
operating a payment system for PPI, thereby making the Company a Payment System Operator.
The Regulations mandate the Company to formulate and disclose a Customer Grievance Redressal
policy. Further, the Master Directions and Guidelines stipulate for the Company to appoint a Nodal
Grievance Redressal Officer.
Further, the Company through its mobile application “slice” offers its customers Unified Payments
Interface (UPI) based payment solutions. These activities fall under the purview of; NPCI guidelines
governing UPI (referred to as UPI Guidelines).
In view of the above, the Company has framed a consolidated Grievance Redressal Policy (“the
Policy”) with the approval of its Board of Directors (“Board”) as applicable for all the above-
mentioned activities. The Company has made this policy accessible to all the users on its mobile
app and website.
2. Key Definitions
For the purpose of this Policy, key definitions are as follows:
• “Customer” or “Complainant” or “User” - means an individual or entity – the end user
availing the services provided by the Company.
• “Grievance” or “Complaint” – refers to any correspondence that is comprehensive and
explicit in nature that conveys dissatisfaction with an inadequate level of service, inappropriate
conduct, or any act of omission or commission. However, messages intended to provide
feedback or provide explanation will not be regarded as complaints or grievances. Further, it
will also cover fraud incidence for UPI services.
• ‘Grievance Redressal Officer’ refers to an officer appointed by the PSP Bank, Issuing Bank
or RE who is responsible to overlook any grievance of the Customer for their respective product
(UPI and PPI)
• ‘Issuing Bank’ – refers to the respective bank of a customer where Customers maintain their
account and also issues UPI ID linked to the account.
• ‘Third Party Application Provider’ or ’TPAP’ – refers to the Company i.e., slice acting as
a service provider for PSP Bank while providing UPI services.
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• ‘Nodal Officer’ refers to an officer appointed by the Company to handle the customer
complaints / grievances, the escalation matrix and turn-around-times for complaint
resolution.
• ‘Product’ – may refer to either one or all of the services offered by the Company. This
currently includes PPI and UPI.
• ‘PSP’ or ‘PSP bank’ or ‘Axis Bank’ - means Axis Bank Limited, a banking entity licensed
under the Banking Regulation Act, 1949 that is a member of the UPI ecosystem. Axis Bank
functions as a ‘Payment Service Provider’ (PSP) to the Company, for undertaking all UPI based
services.
3. Objectives
The primary objective of the Policy is to:
• Design a grievance redressal framework and implement it across Products offered by the
Company to provide its Customer with a seamless service and satisfaction;
• Ensure Customer protection;
• Ensure ease of access to the Customer by providing them with options of lodging a complaint
through various channels;
• Ensure transparency in grievance redressal by providing a defined Turn-Around-Time (TAT)
and ensuring timely resolution of customer complaints. Further, the Company will endeavour
to provide the Customer with transparent communication in case of the complaint not being
resolved within the prescribed timelines or if the complaint is not capable of being resolved;
• Ensure Customer satisfaction by providing a defined escalation matrix so that in the event that
a Customer is not satisfied with the given solution, they can escalate their complaint to higher
authorities who are responsible for the same; and
• Seek regular Customer feedback through complaints and endeavour to improve the Company’s
processes and products to match Customer demand and satisfaction;
4. Grievance Redressal Framework
The Company believes that it is their primary responsibility to focus on Customer service and
satisfaction. In its endeavour of providing its Customers with a seamless experience, the Company
has designed a comprehensive grievance redressal framework to address customer complaints. The
customers are provided multiple channels to lodge their complaints and these complaints are
resolved in a timebound manner, with also providing the Customer with a choice to escalate their
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complaints. This section explores the grievance redressal framework applicable across different
products offered by the Company.
The Company has defined a multi-level Escalation matrix to ensure that a Complainant is able to
appeal and escalate their grievance to a higher level. The degree of escalation varies according to
the product offered by the Company. Level 1 and Level 2 of escalation are applicable to the Products
offered by the Company.
Additionally, the Turn-Around-Time (TAT) for addressing grievances has been explicitly defined
by the Company in accordance with relevant guidelines. The Company has designed its grievance
redressal process to ensure a smooth and timely resolution of Customer complaints.
The following table provides a snapshot of the escalation matrix and the TAT vis-à-vis the various
products offered by the Company.
S. No.
Escalation level
Description
Product(s)
1.
Level 1 –
Customer Service
Agent
Lodging a grievance
via the channels
mentioned in (4.2).
PPI and UPI
2.
Level 2
Appealing to the
PPI and UPI
Customer Service
Manager / Head of
the Company.
3.
Level 3
Escalating to the
Nodal Officer /
Grievance Redressal
Officer, as
applicable.
A)
Escalating a
PPI
complaint to the
Nodal Officer
B)
Escalating the
UPI
grievance to the PSP
bank (Axis Bank)
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S. No.
Escalation level
Description
TAT
Product(s)
4.
UPI Level 4
Escalating the
grievance to the
Customer’s
respective bank
(issuing bank)
Issuing bank to respond
within T+1 days of
lodging the complaint.
UPI
5.
UPI Level 5
Escalating the
grievance to NPCI
-
7.
RBI Ombudsman
A Customer may
approach the RBI
Ombudsman on
their CMS portal
after exhausting all
levels of escalation.
-
PPI and UPI
4.1 Channels of Lodging a Complaint
The Company provides a Customer with an option of 3 channels to lodge their grievance. These
channels for Level 1 are mentioned below.
S.
No
Channel
Process
1.
slice mobile app
Help and Support (slice app>Profile>help and
support>raising a ticket)
2.
Email
help@sliceit.com
3.
Helpline Number
+918048329999
4.2 Grievance Redressal Process
A Customer can lodge a complaint / grievance via any of the three channels provided by the
Company which include the slice app, a dedicated Customer grievance Email Id and via a phone
call (the three channels are mentioned in detail in Section 4.1).
While raising a complaint, a Complainant must also provide the following information:
i.
Customer’s complete name;
ii.
Customer’s complete correspondence address;
iii.
Phone number;
iv.
Email address;
v.
Details of the complaint.
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Post registering a complaint, the Complainant will receive an acknowledgement from the Company
within 48 hours of making the complaint.
Escalation Matrix
• Level 1 – Customer Service Agent (PPI and UPI)
Any complaints raised by the Complainant will be first handled at this level. The Company will send
a written reply / resolution to the complainant within 5 working days of lodging the complaint. The
Complainant will receive the communication on their registered Email Id. The nature and time
taken for the reply will depend on the Complainant’s grievance i.e., whether the customer service
team is able to resolve the complaint, else they will communicate their inability to do so within the
specified time frame.
• Level 2 – Customer Service Manager / Head (PPI and UPI)
If the Complainant is not satisfied with the response received from the Customer Service (in Level
1), they can escalate their grievance to this Level 2 via email custom[email protected]. The
Customer Service Manager / Head will ensure to resolve the and respond within 5 working days of
receiving the complaint.
• Level 3 – Nodal Officer / Grievance Redressal Officer as applicable
A) Level3 – Nodal Officer for PPI product
If the Complainant is not satisfied with the response received from the customer service in Level 2,
they can escalate their grievance to level 3 by appealing to the Nodal Officer of the Company.
The Complainant may contact the Nodal Officer at the details mentioned below. The Officer must
respond within 10 workings days of receiving the complaint.
Contact details of the Nodal Officer:
Name
Swetha S
Address
Indiqube Ashford Park View, First Floor, Municipal No.9, 80 Feet Rd,
Industrial Layout, Koramangala 3rd block, Ward No 68, Bengaluru -
560034, Karnataka
Email id
swetha.s@sliceit.com
Contact Number
+91 80 4552 3323
B)- Level 3 – Payment Service Provider (PSP) for UPI
In accordance with National Payments Corporation of India (NPCI) guidelines, an end Customer
availing UPI services offered by the Company is provided with a five-step escalation matrix to raise
their grievance.
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The Guidelines mandate the Company (a TPAP) to undertake the first step grievance redressal via
its app or call or Email. This initial grievance redressal is the responsibility of the TPAP which has
been covered across Level 1 (Customer Service Agent) and Level 2 (Customer Service
Manager/Head) of this policy.
Further as per the NPCI Guidelines, the Company has provided its customers with 2 additional
levels of grievance escalation.
If the complainant is not satisfied by the solution provided by Level 2 – Customer Service Manager
/ Head, they may escalate their grievance by appealing to the PSP Bank. As the Company has
collaborated with Axis Bank to provide UPI services to its customers, the Complainant may lodge a
complaint via any of the channels provided by Axis Bank on this link -
https://www.axisbank.com/contact-us/grievance-redressal/retail-banking-grievance-redressal .
As per the NPCI guidelines, the PSP must respond within T+1 days to the grievance registered by
the complainant.
• Level 4 – Issuing bank only for UPI
A Complainant who is not satisfied with the grievance redressal offered by the PSP may approach
the issuing bank i.e., the bank at which the complainants maintain their account connected to the
slice app. The concerned bank must respond to the query within T+1 days to the grievance
registered by the complainant.
• Level 5 – NPCI only for UPI
Further, if the Complainant is still not satisfied with the grievance addressal undertaken by Axis
Bank (PSP), they may approach the NPCI for escalating their grievance. The Complainant may
approach the NPCI via its website – https://www.npci.org.in/what-we-do/upi/dispute-redressal-
mechanism to register their grievance escalation.
4.3 The RBI Ombudsman
A Complainant may approach the RBI Ombudsman (under the Reserve Bank – Integrated
Ombudsman Scheme, 2021) after exhausting all grievance redressal measures offered by the
Company (as mentioned in section 4.2 above). The complainant can lodge their grievance on the
‘Complaint Management System’ (CMS) portal of the RBI.
Note:
i.
A Customer availing PPI services may approach the RBI Ombudsman if they remain
unsatisfied with the grievance redressal solution provided by the Company in Level 3 of the
escalation matrix.
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ii.
In accordance with NPCI Guidelines, a Customer availing UPI services may approach the
RBI Ombudsman only in the order of escalation i.e., if they are not satisfied with the
grievance redressal solution provided by NPCI.
4.4 Customer Compensation and TAT for failed transactions
The Company has a defined Customer compensation and TAT process for failed transactions for its
PPI and UPI products. This process is in accordance with RBI’s “Harmonisation of Turn Around
Time (TAT) and Customer compensation for failed transactions using authorised Payment
Systems, 2019”. The following table details the said process:
(Note: Here, T refers to the day of transaction and refers to the calendar date; R refers to the day
on which the reversal is concluded.)
S.
No.
Product
Description
Timeline for
auto-reversal
Compensation
payable
1.
PPI (On-Us
transaction)
Beneficiary’s PPI
not credited.
Reversal affected in
Remitter’s account
within T+1 days.
INR 100/- per day if
delay is beyond T+1
dayy.
PPI debited but
transaction
confirmation not
received at
merchant location.
2
UPI
Account debited but
If unable to credit
INR 100/- per day if
the beneficiary
the beneficiary
delay is beyond T+1
account is not
account, auto
days.
credited (transfer of
Reversal (R) by the
funds)
beneficiary bank
latest on T+1 day.
Account debited but
Auto-reversal
INR 100/- per day if
transaction
within T+5 days.
delay is beyond T+5
confirmation not
days.
received at
merchant location
(payment
4.5 Reporting of Un-authorised PPI transactions and liability of the Customer
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It is the Customer’s liability to report any unauthorised electronic payment transaction to the PPI
issuer (the Company). The Company has endeavoured to provide all its customers availing PPI
services a 24x7 facility to lodge complaints relating to unauthorized transactions.
A Customer may lodge a complaint against unauthorised transaction by visiting the Company’s
website ( https://www.sliceit.com/beware-of-fraud ) or its app and fill the required details.
Additionally, a Customer may lodge their complaint via the Company’s helpline number for
reporting fraud - +91 80483 29999 or email the grievance to [email protected]. The following table
represents a Customer’s liability basis the nature of unauthorised transaction and the time taken
by the customer to report such transactions since the longer they take to notify the Company, higher
will be the risk of loss to the Customer or the Company.
S.
No.
Particulars
Maximum Liability of
Customer
(a)
Contributory fraud / negligence / deficiency on the part
of the Company, including PPI-MTS issuer (irrespective
of whether or not the transaction is reported by the
customer)
Zero
(b)
Third party breach where the deficiency lies neither
with the Company nor with the Customer but lies
elsewhere in the system, and the Customer notifies the
Company regarding the unauthorised payment
transaction.
The per transaction Customer liability in such cases will
depend on the number of days lapsed between the
receipt of transaction communication by the customer
from the Company and the reporting of unauthorised
transaction by the Customer to the Company -
i. Within three days#
Zero
ii. Within four to seven days#
Transaction value or INR
10,000/- per transaction,
whichever is lower
iii. Beyond seven days#
The Company to decide on a
case-to-case basis.
(c)
In cases where the loss is due to negligence by a Customer, such as where they have shared
the payment credentials, the Customer will bear the entire loss until they report the
unauthorised transaction to the Company. Any loss occurring after the reporting of the
unauthorised transaction shall be borne by the Company.
(d)
The Company may also, at its discretion, decide to waive off any Customer liability in case
of unauthorised electronic payment transactions even in cases of Customer negligence.
# The number of days mentioned above shall be counted excluding the date of
receiving the communication from the PPI issuer.
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Additionally, the Company will endeavour to facilitate notional credit of the transaction value or
INR 10,000, whichever is lower, into a shadow account within 10 days of the receipt of the
Customer’s grievance, irrespective of settlement of insurance claim, if any.
Further, as per the PPI Master Directions, the Company will resolve the grievance within 90 days
of receiving the grievance and establish the liability of the Customer, if any. If the Company is not
able to either resolve the grievance or establish any customer liability within 90 days of receiving
the grievance, then the Company will compensate the Customer as per the norms laid out in the
table above.
4.6 Customer awareness
In order to promote customer awareness and to educate the Customers on safe and secure use of
digital payments using PPI, the Company will:
• disseminate information on secure electronic payment practices through multi-lingual
campaigns via either of the channels such as website, mobile app, SMS, email etc. This
information will cover:
o customers' rights and obligations,
o emphasize the importance of not disclosing sensitive information such as User ID,
password, PIN, card number, CVV, OTP, etc.
o importance of not swapping SIM cards or opening links received in emails or
messages etc.
• communicate to its customers to keep updated their mobile number/ email id etc. registered
with the Company to receive SMS alerts for all their payment transactions conducted using
PPI. Subject to system capabilities, the Company may in future also use alternate channels
such as email or in-app notifications etc. to send transaction alerts.
• provide multiple channels for reporting unauthorized electronic payments transactions,
including SMS, email, website, mobile app, etc.
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5. Maintenance of records
In accordance with applicable regulations, the Company shall save and retain any records relating
to complaints it has received, especially the following:
•
Mobile no. of the Complainant;
•
Nature of complaints received;
•
Status;
•
Resolution provided; and
•
Compensation awarded, if any.
6. Reporting
The Company will immediately notify the RBI of any breach of security or leakage of confidential
information pertaining to Customers. Further, the Company also on a quarterly basis will submit
the PPI Customer Grievance Report to the RBI as prescribed in Annexure 6 of the PPI Master
Directions.
The Company will endeavour to report any fraud, cyber-attack or suspicious transaction to NPCI
fraud risk team at frau[email protected] on a daily basis.
Further, the Board or any committee of the Board on a periodic basis be apprised on the
•
number of customer liability cases handled by the Company.
•
the aggregate value involved in such cases and
•
action taken on such cases.
7. Review of the policy
The Policy will be reviewed at least once a year, or sooner if there are any changes affecting the
Company's business operations or changes in the regulatory framework. Any such policy changes
will be approved by the Board and communicated to all relevant departments.