Introduction
Concerto Software and Systems Private Limited, a company incorporated under the Companies Act 2013, having its registered office at Building 305, Millenium Business Park, Sector 2, Mahape, Navi Mumbai, Maharashtra 400710 India, (hereinafter referred with the brand name “VegaaH”) provides payments solutions (including payment aggregator and gateway services) that helps businesses collect and disburse payments.
VegaaH facilitates a variety of Business Institutions (“Merchants”) to collect payments, from their end customers, through its powerful, scalable, tailor-made payments platform, for both domestic and international transactions. VegaaH offers multiple products to its Merchants, which allows the Merchants to collect payments in a secure, transparent, affordable, and convenient manner from their end customers. Being a service oriented financial services company, satisfaction of Merchants and the Customers using VegaaH, is of prime importance of VegaaH to maintain a lasting relationship, and to encourage Merchants and Customers to transact digitally in a safe and secured way.
Therefore, VegaaH has delineated this Policy, duly approved by its Board of Directors, to define mechanisms (a) to ensure that the Merchants and Customers are treated fairly and without bias always, and (b) to provide for an opportunity to the Merchants and the Customers to raise and/ or escalate their complaints within and outside VegaaH, if they are unsatisfied with VegaaH’s products or services.
Objective & Scope
- Define VegaaH’s responsibility as a Regulated Entity.
- Comply with the RBI’s policies, and all other relevant and applicable regulations.
- Document protocols and principles for customer and merchant grievance redressal and dispute resolution, and to put in place systems, procedures and review mechanisms for customer and merchant complaints / grievances and to ensure prompt redressal of the same.
- Define mechanisms through which the Customers can raise their concerns against suspected/ actual fraud, deception, or unethical practices against any of VegaaH’s Merchants.
- Ensure that there is a mechanism for compensating customers expeditiously as required under the applicable laws.
This Policy is applicable to VegaaH, and all the products and services offered by VegaaH, including Cross Border Payments, its Merchants, Partners, Employees, Customers, and Agents doing business with VegaaH.
Governance & Oversight
The Board shall oversee the implementation of VegaaH’s Grievance Redressal framework and be responsible for approving the Policy, and any change thereafter, to set the tone from the top for continuous adherence to applicable laws and regulations and RBI’s directions. The Board has appointed a Nodal Officer for the purpose of ensuring adherence to the Policy requirements.
The Nodal Officer shall, on a quarterly basis, monitor the complaint trends, corrective and preventive actions being taken to reduce complaints along with other customer focused initiatives to enhance customer experience, and along with the inputs from the senior management, if any, on the improvement of the quality of service delivered to customers, put the key results and recommendations to the Board for consideration. Senior Management shall include the Business Unit heads of the functions, contributing to the majority of grievances during the period under review.
Record Keeping
The records pertaining to customer complaints shall be maintained for at least five years after the business relationship is ended. Moreover, timely backup of system data of complaints shall be taken to ensure availability of data at all times.
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 offered by VegaaH.
- “Merchant(s)” shall be a user of VegaaH’s services for accepting various payment instruments from the Customers for completion of their payment obligation.
- “Complaint(s)” shall include service deficiency or error on the part of VegaaH in offering any service and /or non-conformance in any of the VegaaH’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 VegaaH services, and Merchant is not supporting the Customer;
- Customers having noticed an unauthorised electronic fund transfer in their account, and the funds were used to process transactions on VegaaH’s platform, and the Customer approached VegaaH through appropriate legal procedures;
- Unreasonable delay (beyond the time communicated to the Customer by the Merchant) on refunding the transaction amount post refund confirmation;
- Non-adherence to any instructions / circulars / guidelines of the Reserve Bank of India or any applicable law to VegaaH and/ or the Merchant;
- Merchants not getting services as promised by VegaaH, including downtime of the payment gateway etc. or;
- Any other issue pertaining to the transaction processed by VegaaH.
Grievance Redressal and Escalation Matrix
Concerto will contractually require its Merchants to function as the primary point of contact for addressing customer grievances related to fulfillment, quality, delivery, refunds, cancellations, and non-receipt of products or services, and the Merchant shall be required to respond to any complaints within 48 hours of receipt.
Concerto shall not be liable for any issues regarding the quality, quantity, or delivery of the goods and services provided. Concerto will contractually obligate its Merchant to communicate its return and cancellation policies to customers at the time of purchase.
Concerto will allow customers to connect with Concerto for grievances related to technical glitches where transactions have failed or timed out, but the funds have been debited from the end consumer. Concerto shall be required to provide L1 support services for such issues, ensuring a turnaround time (TAT) of 48 hours from the receipt of the grievance.
Grievance Redressal Framework
Merchants / Customers, having any Query, Feedback or Complaint, pertaining to the transactions they may have processed or attempted to process using VegaaH’s platform, or with regards to the product or services offered by VegaaH, may directly reach out to VegaaH via any of the following channels -
The Merchant / Customer can visit Customer Support Page – VegaaH Support and refer to the information for the specific queries / issues related to their complaints / grievances at https://www.vegaah.com/customer.php
Merchant / Customer can provide their Transaction ID or Email ID or Complaint ID to raise grievances. Similarly, they may provide same information to retrieve details of already raised complaints.
Merchant / Customer may alternately raise their complaints by writing to email pgsupport@vegaah.com.
Upon receipt of the query, feedback or complaint from the Customer or the Merchant, a ticket is generated, and a unique reference number is allotted and the same is communicated via email. The VegaaH Support team shall respond to the grievance filed by the Merchant / Customer within 3 business days from the date of receipt of such complaint.
In the event that the Merchants or the Customers are not satisfied with the resolution provided for their queries or the complaints, they may use the following mechanisms to escalate their concerns to VegaaH.
Additionally, Customers may reach out to VegaaH through alternate channels, such as via their Issuing Banks where they face challenges regarding the non-delivery of goods / services or through Law Enforcement Agencies when they see an unauthorised transaction in their account, for which the process is detailed in the subsequent sections.
Escalation Matrix & Turn Around Time for Disposal of Complaints
Level 1
In case the Merchant / Customer wishes to escalate the complaints / grievances, the Merchant / Customer can write to: checkout@vegaah.com.
VegaaH shall attempt to respond within 5 business days from the date on which grievance was filed.
VegaaH shall provide an option to the Customers / Merchants to seek / track the status of their grievances, throughout the lifecycle of a grievance, via email and / or through the merchant dashboard.
The Merchant / Customer may request for an update on the grievance in case any grievance requires more than the specified time period. The Merchant / Customer shall be kept updated on the status of their complaint(s).
If the Merchant / Customer is not satisfied with the response provided, the Merchant / Customer can go for the next level of escalations.
Level 2
In case the Merchant / Customer still has any complaint / grievance, the Merchant / Customer may escalate such complaint / grievance to VegaaH’s Grievance Officer, the details of whom are provided as follows:
NODAL OFFICER (Grievance Redressal): Mr. Lokesh Rele
ADDRESS: Concerto Software and Systems Private Limited, Building 305, Millenium Business Park, Sector 2, Mahape, Navi Mumbai, Maharashtra 400710 India
E-MAIL: pgsupport@concetosoft.com
The Grievance Officer shall attempt to respond within 5 business days from the date on which grievance was filed.
The merchant/customer may request for an update on the grievance in case any grievance requires more than the specified time period. The Merchant / Customer shall be kept updated on the status of their complaint(s).
Level 3
In case of grievance of customer/Merchant not resolved they shall escalate such grievance to the Nodal Officer. Response time to resolve the said query will vary between 0 to 2days and can exceed to 180 working days in case of chargebacks
NODAL OFFICER NAME: Mr. Manish Mer
ADDRESS: Concerto Software and Systems Private Limited, Building 305, Millenium Business Park, Sector 2, Mahape, Navi Mumbai, Maharashtra 400710 India
E-MAIL: nodalofficer@concertosoft.com
Tel No.: 022 68815300
Regulatory Reporting
VegaaH shall intimate the details of the Nodal Officer appointed for the purpose of grievance redressal to RBI and prominently display the details of the Nodal Officer on their website. Further, VegaaH shall also ensure timely submission of any ad hoc / periodic reports required by RBI related to Customer / Grievance Redressal.
Dispute Management/ Chargebacks Mechanism
A dispute, also known as ‘chargeback’, arises when a Customer raises a claim with the Issuing Bank for a purchase/transaction that was made on their account. 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; etc.
The timeline(s) for raising such disputes may vary from card association to card association.
Chargeback Process
The chargeback process would involve parties such as the cardholder, the issuer, the acquirer, the processor, and the merchant who renders the goods or services, each of which has different responsibilities in the life cycle.
The overview of the process is as follows:
- Customer disputes the transaction with the issuing bank
- Issuing bank forwards the chargeback claim to acquirer
- Acquirer identifies transactions and intimates VegaaH
- VegaaH creates a dispute on the dashboard and intimates the merchant to share relevant proofs
- VegaaH updates the chargeback status post receiving the necessary Inputs from the merchant
- Case status is updated to acquire and further to the issues
Broadly, where a customer has reached out to the Issuing Bank/other institution and has disputed the transaction made by them using his/her payment mode/mechanism on the merchant site, the following process is followed:
- The acquiring partner sends us a dispute notification to determine the validity of the transaction and we create a dispute corresponding to such transaction(s) in our system.
- Upon receiving such notification from the bank, VegaaH notifies the merchant with the dispute details to submit such supporting documents.
- Once the Merchant uploads such documents for evaluation, VegaaH further submits them to the banks for their review.
- The banking partner analyses the evidence/documents and determines whether the services are delivered by the Merchant as promised.
Chargeback Resolution
A chargeback case may have one of the following outcomes –
| Possibility | Outcome |
|---|---|
| Acceptance | 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. |
| Contestation/ Representation | When services / goods are rendered against the said payment, the Merchant can upload the relevant documents such as proof of delivery, service utilisation proofs etc. The documents hence submitted are further represented to the acquiring banks and subsequently to the issuers and networks. |
| Deemed accepted | 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 the case of acceptance this too shall have a permanent debit to the Merchant’s VegaaH account. |
Refunds
Customers may request a refund from the Merchant due to reasons such as the non-delivery of goods or poor service quality. Merchants can initiate refunds against transactions with VegaaH payments, which are posted to the original method of payment unless otherwise agreed by the end Customer. Credits for such refunds or reversals (as detailed in the previous section) shall be routed back through VegaaH’s PA escrow account.
Refund processing timelines
Refund requests are not accepted after a period of 120 days from the date of the transactions unless the acquiring banking partners support such a request.
Once the refund is initiated with the bank, it generally takes about 5 to 7 working days to get reflected on the customer's account / card statement, however, actual timelines may differ given the dependencies of multiple stakeholders involved during the process –
| Payment Mode | Minimum TAT (days) | Maximum TAT (days) |
|---|---|---|
| Cards | 5 | 10 |
| UPI | 1 | 7 |
| NetBanking | 2 | 10 |
| Wallets | 1 | 5 |
Failed transactions and reversals
As per RBI’s Notification on Harmonisation of Turnaround Time (TAT) and customer compensation for failed transactions, a ‘failed transaction’ is a transaction which has not been fully completed due to any reason not attributable to the customer such as failure in communication links, non-availability of cash in an ATM, time-out of sessions, etc. 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.
Therefore, VegaaH shall ensure that the reversals happen within the TAT prescribed in the guidelines, corresponding to the payment mode used, or provide compensation to the customer wherever there is a delay.
Review
This Policy is subject to review by the Board of Directors of Concerto Software and Systems Private Limited as and when deemed necessary. The Board of Directors shall annually review the functioning of the grievance redressal mechanism.
Obligation of Secrecy
VegaaH shall maintain secrecy regarding the Merchant / Customer information which arises out of the contractual relationship between VegaaH and the Merchant.
While considering the requests for data / information from the Government and other agencies, VegaaH shall satisfy themselves that the information being sought is not of such a nature that will violate the provisions of the laws relating to secrecy in the banking transactions. The exceptions to the said rule shall be as under:
- Where disclosure is under compulsion of law.
- Where there is a duty to the public to disclose.
- Where the interest of bank requires disclosure; and
- Where the disclosure is made with the express or implied consent of the Customer.
Customer information shall not be divulged for the purpose of cross selling, or for any other purpose without the express permission of the Customer.
Applicable Regulations / Guidelines
This Policy shall be subject to the applicable laws including but not limited to the rules, regulations, guidelines, directives and instructions issued by the RBI, from time to time and shall supersede the earlier version of the Policy, including the following -
- RBI Guidelines on Regulation of Payment Aggregators and Payment Gateways as amended from time to time.
- RBI Notification on Harmonisation of Turnaround Time (TAT) and customer compensation for failed transactions using authorised Payment Systems.
- RBI Notification on Integrated Ombudsman Scheme, 2021.
- Regulation of Payment Aggregator – Cross Border (PA - Cross Border) as amended from time to time.
Any change / amendment in applicable laws with regard to the maintenance of an appropriate grievance redressal mechanism shall be deemed to be incorporated in this Policy by reference and this Policy shall be deemed to have been amended and revised accordingly.