Direct2pay Devraaj Payments and Tech Solutions Private Limited, a company duly incorporated under the provisions of the Companies Act, 2013, and having its registered office at ______________________ [insert full address], (hereinafter referred to as “SecurePay”), is engaged in the business of providing comprehensive payment solutions, including payment aggregator and gateway services, with the objective of facilitating the efficient collection and disbursement of payments for commercial enterprises across diverse sectors.
Through its robust, scalable, and custom-designed digital payment infrastructure, SecurePay enables a wide range of business entities (hereinafter referred to as “Merchants”) to seamlessly collect payments from their end customers. The platform is equipped to process transactions and is supported by a suite of proprietary products that allow Merchants to accept payments in a manner that is secure, transparent, cost-effective, and user-friendly.
As an organization operating in the domain of financial technology services, SecurePay places utmost importance on the satisfaction and trust of both its Merchants and the customers who engage with its platform. SecurePay is committed to cultivating long-term commercial relationships founded upon transparency, accountability, and efficiency, and seeks to promote the adoption of safe and reliable digital payment practices.
In furtherance of this commitment, SecurePay has established the present Customer Grievance Redressal Policy, which has been duly approved by its Board of Directors. This Policy has been instituted to define the mechanisms through which SecurePay shall ensure that all Merchants and Customers are treated equitably and without discrimination, and to provide an accessible and effective avenue through which they may raise concerns or complaints pertaining to SecurePay’s services. It further sets out the process for addressing and resolving such grievances both within SecurePay’s internal redressal framework and, where appropriate, through external regulatory or legal channels.
This Policy sets out the framework for grievance redressal and dispute resolution at SecurePay in its capacity as a Regulated Entity, and underscores SecurePay’s commitment to operate in full compliance with the regulatory directives issued by the Reserve Bank of India (“RBI”), as well as all other applicable laws, rules, regulations, and guidelines issued by competent authorities from time to time.
The primary objective of this Policy is to define and institutionalize the principles and procedures governing the redressal of grievances and resolution of disputes arising out of, or in connection with, the services and products provided by SecurePay. It seeks to ensure that grievances and complaints raised by Merchants and Customers are addressed in a fair, transparent, consistent, and expeditious manner, in accordance with applicable regulatory mandates and the highest standards of ethical business conduct.
This Policy also delineates the internal protocols and review mechanisms to be implemented by SecurePay for the effective handling of grievances, and it formalizes the obligations of SecurePay to facilitate a responsive and accessible grievance redressal infrastructure. Furthermore, it establishes a structured process through which Customers may report concerns relating to suspected or actual instances of fraud, deception, misconduct, or unethical practices allegedly perpetrated by any Merchant affiliated with SecurePay.
In accordance with applicable legal and regulatory requirements, this Policy also affirms SecurePay’s obligation to compensate Customers in a timely and appropriate manner in cases where such restitution is warranted.
This Policy is applicable to SecurePay, including all of its operations, business lines, and product offerings, whether domestic or cross-border in nature. It extends to and governs the conduct of SecurePay’s Merchants, business Partners, Employees, Customers, and any other Agents or intermediaries transacting or interacting with SecurePay in the course of its business operations.
For the purposes of this Customer Grievance Redressal Policy, the following terms shall have the meanings respectively assigned to them hereinbelow, unless the context otherwise requires:
“Customer(s)” shall mean and refer to any individual or legal entity that purchases goods and/or services from a Merchant, and who makes payments to such Merchant using one or more payment instruments facilitated through the payment solutions offered by SecurePay.
“Merchant(s)” shall mean and refer to any individual, firm, or legal entity that is registered with SecurePay for the purpose of utilizing its services in order to accept payments from Customers through various permitted payment instruments, in fulfilment of the Customers’ payment obligations for goods and/or services rendered.
“Complaint(s)” shall mean and include any expression of dissatisfaction, dispute, or grievance—whether written, oral, or electronic—lodged by a Merchant or a Customer, which arises due to any act of omission or commission on the part of SecurePay in rendering its services, or any non-conformance, deficiency, or failure in relation to SecurePay’s products, services, systems, or processes. Complaints may pertain to but are not limited to, the following illustrative scenarios:
a) Grievance Redressal Framework
Merchants and Customers who have any query, feedback, or complaint in connection with transactions processed or attempted via Direct2pay Devraaj Payments and Tech Solutions Private Limited’s (“SecurePay”) platform, or in relation to any product or service offered by SecurePay, may lodge such concerns directly with SecurePay through the available official channels.
Merchants and Customers may first access SecurePay’s Support Portal, which contains a comprehensive repository of Frequently Asked Questions (FAQs) to assist with common concerns, at: ____________ [insert SecurePay support URL].
Customers may also check the status of their transaction using the transaction reference number provided by SecurePay via the transaction tracker portal available at: _____________ [insert URL].
Should the complainant be dissatisfied with the resolution provided, or where the response is not received within the prescribed timeline, the grievance may be escalated in accordance with the escalation matrix provided below.
Furthermore, Customers may also seek redressal through alternative channels including, but not limited to, their issuing banks in cases involving non-delivery of goods or services by a Merchant, or through appropriate law enforcement authorities in cases of unauthorised or fraudulent transactions, in accordance with applicable legal procedures.
b) Escalation Matrix and Timelines for Resolution
Level 1 – Primary Escalation
If the Merchant or Customer is dissatisfied with the initial response or resolution, they may escalate the matter by writing to:
Email: [________________________.com]
SecurePay shall endeavour to respond within five (5) business days from the date the grievance is escalated. Throughout the lifecycle of a complaint, SecurePay shall provide the Merchant or Customer with the ability to track the status of their grievance via email correspondence and/or the Merchant dashboard.
In the event that the complaint cannot be resolved within the specified timeline, SecurePay shall proactively provide interim updates regarding the status of the resolution to the complainant until final closure is achieved.
Level 2 – Escalation to the Grievance Redressal Officer
Should the Merchant or Customer remain dissatisfied with the outcome at Level 1, or where no response is received within the prescribed timeline, the matter may be further escalated to SecurePay’s designated Grievance Redressal Officer. The contact details are as follows:
Grievance Redressal Officer: ______________ [Insert Full Name]
Address: ________________ [Insert Full Office Address]
Email: [_________________.com]
The Grievance Redressal Officer shall aim to address the complaint and provide a formal response within five (5) business days from the date of escalation. Ongoing communication regarding the status of the complaint shall be maintained in the event that additional time is required to resolve the issue.
Level 3 – External Escalation to the Reserve Bank of India
In circumstances where the complainant is not satisfied with the final resolution provided by SecurePay, or where no response has been received within thirty (30) calendar days from the date the complaint was first lodged, the complainant may approach the Reserve Bank of India (RBI) under the Integrated Ombudsman Scheme. The relevant contact details are as follows:
Online Complaint Portal: https://cms.rbi.org.in/
Toll-Free Number: 14448
Email: crpc@rbi.org.in
Address: Centralised Receipt and Processing Centre,
Reserve Bank of India,
4th Floor, Sector 17, Chandigarh – 160017
Further information regarding the RBI’s Integrated Ombudsman Scheme is available at: https://rbidocs.rbi.org.in/rdocs/content/pdfs/RBIOS2021_121121.pdf.
A dispute, also referred to as a "chargeback," arises when a Customer lodges a claim with the Issuing Bank in respect of a transaction or purchase that was executed on their account. Card networks, along with regulatory bodies such as the National Payments Corporation of India (NPCI), confer upon cardholders and consumers the right to initiate a chargeback under certain specified conditions, which include, but are not limited to:
The permissible timeframe within which such disputes may be raised is governed by the dispute resolution rules of the respective card networks or payment systems, and may accordingly vary from one card association to another.
In the event of a chargeback, the case may culminate in one of the following outcomes, depending on the response provided by the Merchant within the prescribed timelines.
Customers may seek a refund from the Merchant for reasons including, but not limited to, non-delivery of goods or services, delivery of defective or damaged goods, or unsatisfactory service quality. In such cases, the Merchant may initiate a refund in respect of the original transaction processed through SecurePay’s payment gateway services. Unless expressly agreed otherwise by the Customer, refunds shall be credited to the original method of payment used by the Customer at the time of the transaction.
All such refunds or reversals, including those arising from chargebacks or other forms of transaction reversals as detailed in preceding sections, shall be processed through SecurePay’s Payment Aggregator (PA) escrow account in accordance with applicable regulatory requirements.
Refund requests shall not be entertained beyond a period of 120 (one hundred and twenty) days from the date of the original transaction, unless supported and permitted by the acquiring bank and other relevant financial partners.
Upon initiation of the refund by the Merchant through SecurePay, and subsequent processing by the bank, the refunded amount typically reflects in the Customer’s bank account or card statement within a period of five (5) to seven (7) working days. However, these timelines are indicative and may vary depending on the operational timelines and processes of various stakeholders involved, including but not limited to acquiring banks, issuing banks, card networks, and other intermediaries.
S.NO
Payment Mode
Minimum TAT
Maximum TAT
1. Credit/Debit Cards
2. UPI
3. Net Banking
4. Wallets
Failed Transactions and Reversals
In accordance with the Reserve Bank of India’s Notification on Harmonisation of Turnaround Time (TAT) and Customer Compensation for Failed Transactions, a "failed transaction" shall be construed as any transaction that is not successfully completed due to reasons not attributable to the Customer. Such reasons may include, but are not limited to, failure of communication links, unavailability of funds at an Automated Teller Machine (ATM), system timeouts, or technical errors at any stage of the transaction processing cycle.
Failed transactions shall also include instances where credit to the beneficiary’s account could not be effected due to incomplete or inaccurate information, or delays in initiating a reversal of the transaction. The said guidelines are applicable to domestic transactions, wherein both the originator and the beneficiary are located within the territory of India.
SecurePay shall ensure that all such failed transactions are reversed within the turnaround time (TAT) prescribed under the applicable regulatory guidelines, based on the payment instrument or channel used. In the event that the reversal is not completed within the prescribed TAT, SecurePay shall be liable to provide compensation to the Customer, in accordance with the standards laid down by the Reserve Bank of India or any other competent authority.
In the event SecurePay receives an alert or communication from a Law Enforcement Agency (LEA) including, but not limited to, notifications via the National Cybercrime Reporting Portal (NCRP), or official correspondence from the Income Tax Department, Ministry of Home Affairs (MHA), or any other competent authority pertaining to an unauthorised or suspicious transaction involving a Customer’s account, SecurePay shall take all reasonable and necessary steps to restrict further movement of funds at the Merchant’s end.
Such steps may include initiating fund recovery procedures or obtaining documentary evidence from the Merchant to establish that the goods or services in question were duly provided in good faith.
SecurePay shall also adhere to all lawful directions and instructions issued by the relevant LEA in connection with such matters. A dedicated internal team, under the supervision of a designated Nodal Officer, has been established to manage and respond to such LEA requests promptly and in accordance with applicable legal requirements.
The contact details of the Nodal Officer for LEA support are as follows:
Nodal Officer ________________
Address: __________________
Email: _________________
Details of the Nodal Officer shall also be made available and kept up to date on SecurePay’s official website.
This Policy shall be subject to periodic review by the Board of Directors of SecurePay, as and when deemed necessary, to ensure its continued relevance, effectiveness, and alignment with applicable regulatory requirements and industry best practices. The Board shall, at a minimum, conduct an annual review of the functioning and efficacy of the grievance redressal mechanism established under this Framework.
SecurePay shall maintain strict confidentiality with respect to all information pertaining to its Merchants and Customers that arises from, or is incidental to, the contractual relationship between SecurePay and the respective parties. Such information shall be safeguarded in accordance with applicable laws and the principles of data protection and banking secrecy.
In evaluating requests for disclosure of data or information from governmental authorities or other external agencies, SecurePay shall ensure that any such disclosure does not contravene the statutory provisions governing the confidentiality of banking transactions. Information shall be disclosed only where such disclosure is:
SecurePay shall not disclose or utilise Customer information for purposes such as cross-selling or any other commercial use without obtaining the Customer’s prior explicit consent.
This Policy shall be governed by and construed in accordance with all applicable laws, rules, regulations, guidelines, directives, and instructions issued by the Reserve Bank of India (RBI) and other competent authorities, as amended from time to time. This Policy supersedes all prior versions and shall include, without limitation, compliance with the following regulatory provisions:
Regulations pertaining to Payment Aggregator – Cross Border (PA-Cross Border), as amended from time to time.
Any subsequent amendments, modifications, or supplements to the applicable laws or regulatory requirements relating to the establishment and maintenance of an appropriate grievance redressal mechanism shall be deemed to be incorporated herein by reference, and this Policy shall be deemed to have been amended and revised accordingly without the need for separate approval or notification.
