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XFLOW INDIA CUSTOMER GRIEVANCE REDRESSAL POLICY

Last Updated: 17 January 2024

1. Introduction

Xflow Payments India Private Limited (the “Company”, “we”, “us”) has a focused and pinpointed approach towards customer service. The Company will strive to provide the highest quality of customer service to ensure continued customer satisfaction and retention. We have put in place a robust mechanism via this Grievance Redressal Policy to resolve/ address customer complaints in a timely and effective manner. *Provisions relating to export are not applicable to Merchant Collection Services provided outside India by Xflow's affiliates.

For the purpose of this Grievance Redressal Policy,

  • A “customer” is an end-customer who has purchased goods and/services from the merchants.
  • A “merchant” is a user of Xflow’s services for accepting payments for export of goods and/services from India, or import of goods and/or services into India.

2. Principles and Objectives of Grievance Redressal

Through this Grievance Redressal Policy, the Company intends to put in place systems, procedures and a review mechanism for minimizing instances of dissatisfaction and to ensure prompt redressal of complaints and grievances. The Company is focused on timely and quick resolution of grievances.

The key objectives of this Grievance Redressal Policy are as follows:

  • To ensure unbiased, fair and just treatment to customers.
  • To protect customers against fraud, deception or unethical practices.
  • To consistently assess the impact of services in order to improve services of Xflow.
  • To ensure speedy and efficient resolution of issues with adherence to basic principles of transparency and integrity.
  • To educate customers about alternate escalation mechanisms within and outside the Company, for resolution of the complaints / issues if they are not satisfied with the Company’s response.

3. Applicability

This Grievance Redressal Policy will cover all the products and services with respect to cross-border payment aggregation services offered by the Company for facilitating export from, or import into, India, of goods and/or services. It applies to grievances raised by customers and merchants of the Company.

4. Chargebacks/Disputes

A chargeback occurs when a customer disputes a transaction with their payment instrument issuer or bank. Chargebacks may occur for various reasons, including but not limited to:

  • Fraudulent transactions
  • Non-delivery of goods or services
  • Dissatisfaction with the goods or service
  • Unauthorized transactions

The customer will have to reach out to their payment instrument issuer or bank to understand in what circumstances they can raise a chargeback and the process to be followed by the customer for raising the chargeback in cross-border export/import of goods and services. We strongly encourage merchants to make reasonable efforts to resolve customer disputes promptly.

Imports

When a customer raises a chargeback, the customer’s bank or issuer will reach out to our bank and they will in turn inform us. We will promptly notify the merchant regarding the chargeback. In the chargeback notification, we will require the merchant to respond to the chargeback with relevant documentary proof, including details of the transaction, all relevant correspondence between the merchant and the customer, and the proof of delivery of goods/services. The timeframes within which the chargeback needs to be responded to will also be communicated.

Merchants must communicate with our support team, providing all relevant information to dispute the chargeback. Failure to respond may result in the chargeback being upheld.

Our support team will review the information provided by the merchant. Based on the information provided by the merchant, we will dispute the chargeback. If we are unable to successfully defend the payment and the chargeback is deemed valid, the funds may be debited from the merchant's account. If there are no funds available to be debited, the Company will initiate the process for recovery of funds from the merchant through legal means. If the chargeback is successfully responded to by the merchant, the dispute will be considered to have been resolved.

Exports

Customers may use payment methods available in their location to make export payments. To enable acceptance of such payments, the Company or its payment partners may act in the capacity of merchant-on-record or agent of the merchant, depending on the applicable laws of the customer’s location. In such cases, the Company or its overseas payment partners may have to dispute the chargeback with the payment method provider. In such cases also, the Company will promptly provide chargeback notification to the merchant. In the chargeback notification, we will ask the merchant to provide us with relevant documentary proof to dispute the chargeback, as required by the chargeback process of the relevant payment method provider. Based on the information provided by the merchant, we will dispute the chargeback. If we are unable to successfully defend the payment, the Company will initiate the process for recovery of funds from the merchant through legal means.

The timelines for chargeback/dispute resolution will depend on the chargeback/dispute process of the applicable bank/payment method issuer.

4. Refunds

Refunds for goods and/or services purchased by customers from merchants will be directly handled by the merchant. While Xflow facilitates the refund payment, currently we do not manage the actual refund process.

Customers seeking a refund must contact the merchant from whom they made the purchase offline (i.e. outside the Xflow ecosystem). Merchants are responsible for processing refunds, addressing customer concerns, and ensuring a satisfactory resolution. Merchants may have specific terms and conditions regarding the eligibility and process for refunds. Customers are encouraged to familiarize themselves with the refund policies of individual merchants.

If the refund request is in line with the merchant’s refund policy, the merchant may initiate the refund transaction offline or via Xflow. The timelines for processing the refund will be determined by the merchant’s refund policy. If there is any issue in connection with the refund, the customer will need to directly contact the merchant.

6. Nodal Officer

The Company has designated Mr. Anand Balaji, as the Nodal Officer.

The Nodal Officer can be reached at: nodalofficer@xflowpay.com Xflow Payments India Private Limited
No. 843, 2nd Floor, 5th Main Road
Indira Nagar 1st Stage, Bangalore
Karnataka, India, 560038.

7. Registration of Complaints

Customers may reach out to the Company if the payment made via Xflow was unauthorized or there is any other issue pertaining to the transaction processed by Xflow.

Customers may register their complaint by

  • email to support@xflowpay.com or
  • by post to Xflow Payments India Private Limited, No. 843, 2nd Floor, 5th Main Road, Indira Nagar 1st Stage, Bangalore, Karnataka, India, 560038.

The complaint should provide the following minimum details:

  • Name and contact details of the complainant
  • Transaction type, date, amount, and reference number
  • Related transaction invoice copy
  • Details of the complaint:

The support team will reach out to the complainant at the contact details provided if any additional information is required.

8. Resolution of Complaints

Our goal is to address customer complaints promptly and in compliance with relevant laws. The Company will acknowledge the receipt of every customer complaint within 2 business days and endeavour to resolve it immediately. The expected time for resolution will be communicated to the customer. In case any complaint takes more time for resolution, the Company will intimate the Customer regarding the status of the complaint and updated timeline for resolution. In all cases, the Company will provide a final resolution within 30 calendar days. The customer will be responsible for providing necessary information requested by the Company in order to resolve the complaint.

9. Escalation Matrix

Level 1:
Customers can register any complaint by writing to support@xflowpay.com. A customer support representative will respond to the complaint promptly. On submission of complaint, a ticket will be created and assigned with a unique reference number for ease of tracking. The support team will respond to the complaint in accordance with the process set out in Section 9. Resolution of Complaints. The team will endeavour to provide a resolution to the customer within 10 days of receiving the complaint. If the customer is not satisfied with the process, the customer may go for the next level of escalation.

Level 2:
If at any time during the complaint resolution process, the customer wishes to escalate the complaint, or if the customer is not satisfied with the resolution provided by the support team, the customer may reach out to our customer care manager, Rahul Unnikrishnan at rahul@xflowpay.com. The customer care manager will endeavour to provide a resolution to the customer within 10 days.

Level 3:
If the customer care manager is unable to provide a satisfactory resolution to the complaint, the customer may escalate the complaint to the Nodal Officer, Anand Balaji at nodalofficer@xflowpay.com. The nodal officer will endeavour to provide a final resolution to the customer within 10 days.

In all such cases, the final resolution shall be provided to the customer within 30 calendar days.

Level 4:
If the customer does not receive a final resolution from us within 30 calendar days or is not satisfied with the resolution offered by the Company, the customer may approach the Ombudsman as provided under the Reserve Bank-Integrated Ombudsman Scheme, 2021.

10. Grievance Redressal Mechanism for Failed Transactions

Xflow has put in place a process to address all customer grievances in relation to failed transactions.

Where applicable, the resolution provided by the Company for any failed transaction shall be in accordance with the (i) RBI circular bearing reference number DPSS.CO.PD No. 629/02.01.014/2019-20 and dated September 20, 2019 on “Harmonization of Turn Around Time (TAT) and customer compensation for failed transaction using authorized Payment Systems.”; and (ii) RBI circular bearing reference number DPSS.CO.PD No.116/02.12.004/2020-21 and dated August 6, 2020 on “Online Dispute Resolution (ODR) System for Digital Payment”.

11. Policy Review and Updates

This Board approved policy will be reviewed on an annual basis for incorporating changes and regulatory updates, if any, in overall grievance redressal mechanism, to improve customer experience and satisfaction.

12. Training of Employees

The customer communications team and all relevant employees and officers at Xflow undergo regular training on handling complaints and queries.