Grievance Redressal Policy

Introduction

1. Spice Money Limited (“SML”), is a Regulated Entity (“RE”) as SML has been granted Certificate of Authorisation (COA)bearing No. 138/2019 for issuing and operating of Prepaid Payment Instruments (“PPI”) and COA bearing No. 139/2019 for operating as Bharat Bill Payment Operating Unit (“BBPOU”)under Bharat Bill Payment System (“BBPS”), in India.
2. SML has a network of KYC compliant authorised/ designated agents, through whom various financial activities (under PPI and BBPS) are facilitated to Customers.
3. This policy will apply to Customers of PPI and will also act as guiding tool to the Customers availing service of BBPS and other products/ services facilitated by SML.
4. For the purpose of this Policy, the term ‘Customer(s)’ shall mean the PPI holder, customer availing service of BBPS and customers availing other products/ services facilitated by SML.
5. This Policy is to be read with the Master Directions on Prepaid Payment Instruments (“PPI Master Directions”) and the circulars, guidelines or other mandates issued by the Reserve Bank of India (“RBI”) or the National Payments Corporation of India (“NPCI”).

Customer Protection and Grievance Redressal Framework

1. SML shall disclose all important terms and conditions in clear and simple language (preferably in English, Hindi and the local language) to the Customers while issuing the instruments. These disclosures shall include:
   1. All charges and fees associated with the use of the instrument; and
   2. The expiry period and the terms and conditions pertaining to expiration of the instrument.
2. SML shall put in place a formal, publicly disclosed Customer grievance redressal framework, including designating a nodal officer to handle the Customer complaints / grievances, the escalation matrix and turn-around-times for complaint resolution. The complaint facility, if made available on website / mobile, shall be clear and easily accessible. The framework shall include, at the minimum, the following:
   1. SML shall disseminate the information of Customer protection and grievance redressal policy in simple language (preferably in English, Hindi and the local language).
   2. SML shall clearly indicate the Customer care contact details, including details of nodal officials for grievance redressal (telephone numbers, email address, postal address, etc.) on website, mobile wallet apps, and cards.
   3. SML’s agents shall display proper signage of the SML and the Customer care contact details as at Para II(2)(b) above.
   4. SML shall provide specific complaint numbers for the complaints lodged along with the facility to track the status of the complaint by the Customer.
   5. SML shall initiate action to resolve any Customer complaint / grievance expeditiously, preferably within 48 hours and endeavour to resolve the same not later than 30 days from the date of receipt of such complaint / grievance.
   6. SML shall display the detailed list of its authorised / designated agents (name, agent ID, address, contact details, etc.) on the website / mobile app.
3. SML shall create sufficient awareness and educate Customers in the secure use of the PPIs, including the need for keeping passwords confidential, procedure to be followed in case of loss or theft of card or authentication data or if any fraud / abuse is detected, etc.
4. SML shall provide an option for the PPI holders to generate / receive account statements for at least past 6 months. The account statement shall, at the minimum, provide details such as date of transaction, debit / credit amount, net balance and description of transaction. Additionally, the SML shall provide transaction history for at least 10 transactions.
5. Customers shall have recourse to the Reserve Bank - Integrated Ombudsman Scheme, 2021 (as amended from time to time) for grievance redressal.
6. SML shall report regarding the receipt of complaints and action taken status thereon in the enclosed format (as mentioned in the PPI Master Directions) on a Quarterly basis by the 10th of the following month to the respective Regional Office of DPSS, RBI.
7. SML shall ensure transparency in pricing and the charge structure as under
   1. Ensure uniformity in charges at agent level.
   2. Disclosure of charges for various types of transactions on its website, mobile app, agent locations, etc
   3. Specific agreements with agents prohibiting them from charging any fee to the Customers directly for services rendered by them on behalf of the SML.
   4. Require each retail outlet / sub-agent to post a signage indicating their status as service providers for the SML and the fees for all services available at the outlet.
   5. The amount collected from the Customer shall be acknowledged by issuing a receipt (printed or electronic) on behalf of the SML.
8. SML shall be responsible for addressing all Customer service aspects related to all PPIs (including co-branded PPIs) issued by them as well as their agents.
9. SML shall also display Frequently Asked Questions (FAQs) on its website / mobile app related to the PPIs.
10. SML shall also display Frequently Asked Questions (FAQs) on its website / mobile app related to the PPIs.
    1. Harmonisation of Turn Around Time (TAT) and Customer compensation for failed transactions using authorised Payment Systems issued vide DPSS circular DPSS.CO.PD No.629/02.01.014/2019-20 dated September 20, 2019 (as amended from time to time)
    2. Online Dispute Resolution (ODR) system for resolving Customer disputes and grievances pertaining to digital payments, using a system-driven and rule-based mechanism with zero or minimal manual intervention, issued vide DPSS circular DPSS.CO.PD No.116/02.12.004/2020-21 dated August 6, 2020 (as amended from time to time).

Limiting liability of Customers in unauthorised electronic payment transactions in PPIs

1. SML shall adhere to the following criteria for determining the Customers’ liability in unauthorised electronic payment transactions resulting in debit to its PPIs. PPIs issued under the arrangement of PPI-MTS will be outside the purview of these paragraphs except for the cases of contributory fraud / negligence / deficiency on the part of the PPI-MTS issuer.
2. The electronic payment transactions have been divided into two categories:
   1. Remote / Online payment transactions : Transactions that do not require physical PPIs to be presented at the point of transactions e.g. wallets, card not present (CNP) transactions, etc.; and
   2. Face-to-face / Proximity payment transactions : Transactions that require physical PPIs to be present at the point of transactions e.g. transactions at ATMs, PoS devices, etc.
3. Reporting of unauthorised payment transactions by Customers:
   1. SML shall ensure that its Customers mandatorily register for SMS alerts and wherever available also register for e-mail alerts, for electronic payment transactions.
   2. The SMS alert for any payment transaction in the account shall mandatorily be sent to the Customers and e-mail alert may additionally be sent, wherever registered. The 7 transaction alert should have a contact number and / or e-mail id on which a Customer can report unauthorised transactions or notify the objection.
   3. Customers shall be advised to notify the SML of any unauthorised electronic payment transaction at the earliest and, shall also be informed that longer the time taken to notify the SML, higher will be the risk of loss to the SML / Customer. In this respect, the Company shall temporarily block the wallet of Customer till the completion of investigation to prevent further misuse.
   4. To facilitate this, SML shall provide Customers with 24x7 access via website i.e. https://www.spicemoney.com or any other website / SMS / e-mail / a dedicated toll-free helpline for reporting unauthorised transactions that have taken place and / or loss or theft of the PPI.
   5. Further, a direct link for lodging of complaints, with specific option to report unauthorised electronic payment transactions shall be provided by SML on its mobile app / home page of its website i.e. https://www.spicemoney.com or any other website / any other evolving acceptance mode.
   6. The loss / fraud reporting system so established shall also ensure that immediate response (including auto response) is sent to the Customers acknowledging the complaint along with the registered complaint number. The communication systems used by SML to send alerts and receive their responses thereto shall record time and date of delivery of the message and receipt of Customer’s response, if any. This shall be important in determining the extent of a Customer’s liability. On receipt of report of an unauthorised payment transaction from the Customer, SML shall take immediate action to prevent further unauthorised payment transactions in the PPI.
4. A Customer’s liability arising out of an unauthorised payment transaction will be limited to:

   #	Particulars	Maximum Liability of Customer
   (a)	Contributory fraud / negligence / deficiency on the part of the SML, 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 SML nor with the Customer but lies elsewhere in the system, and the Customer notifies the SML 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 SML and the reporting of unauthorised transaction by the Customer to the SML -
   	i. Within three days#	Zero
   	ii. Within four to seven days#	Transaction value or ₹10,000/- per transaction, whichever is lower
   	iii. Beyond seven days#	On case to case basis
   (c)	In cases where the loss is due to negligence by a Customer, such as where he / she has shared the payment credentials, the Customer will bear the entire loss until he / she reports the unauthorised transaction to the SML. Any loss occurring after the reporting of the unauthorised transaction shall be borne by the SML.
   (d)	SML 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 SML.

5. The above shall be clearly communicated to all PPI holders.
6. On being notified by the Customer, the SML shall credit (notional reversal / shadow reversal) the amount involved in the unauthorised electronic payment transaction to the Customer’s PPI within 10 days from the date of such notification by the Customer (without waiting for settlement of insurance claim, if any), even if such reversal breaches the maximum permissible limit applicable to that type / category of PPI. The credit shall be value-dated to be as of the date of the unauthorised transaction
7. SML shall ensure that a complaint is resolved and liability of the Customer, if any, established within 90 days from the date of receipt of the complaint, and the Customer is compensated as per provisions of paragraph IV(4) above. In case the SML is unable to resolve the complaint or determine the Customer liability, if any, within 90 days, the amount as prescribed in paragraph IV(4) shall be paid to the Customer, irrespective of whether the negligence is on the part of Customer or otherwise.
8. SML shall implement an effective mechanism of creating Customer awareness on the risks and responsibilities involved in electronic payment transactions and Customer liability in cases of unauthorised electronic payment transactions. Under the said mechanism, SML shall inter alia regularly communicate with the Customers and shall frequently run awareness campaigns, conducted in the middle of every 2-3 months.
9. The burden of proving Customer liability in case of unauthorised electronic payment transactions shall lie on the SML.
10. SML shall put in place a suitable mechanism and structure for reporting of the Customer liability cases to the Board or one of its Committees. The reporting shall, inter-alia, include volume / number of cases and the aggregate value involved and distribution across various categories of cases. The Board or one of its Committees shall periodically review the unauthorised electronic payment transactions reported by Customers or otherwise, as also the action taken thereon, the functioning of the grievance redressal mechanism and take appropriate measures to improve the systems and procedures

Harmonisation of Turn Around Time (TAT) and Customer compensation for failed transactions: General Instructions covering the TAT :

1. The principle behind the TAT is based on the following :
   1. If the transaction is a ‘credit-push’ funds transfer and the beneficiary account is not credited while the debit to originator has been effected, then credit is to be effected within the prescribed time period failing which the penalty has to be paid to the beneficiary;
   2. If there is delay in initiation of a transaction at the originator bank’s end beyond the TAT, then penalty has to be paid to the originator.
2. 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 effected to the beneficiary account on account of lack of full information or lack of proper information and delay in initiating a reversal transaction.
3. Terms like, Acquirer, Beneficiary, Issuer, Remitter, etc., have meanings as per common banking parlance.
4. T is the day of transaction and refers to the calendar date.
5. R is the day on which the reversal is concluded and the funds are received by the issuer / originator. Reversal should be effected at the issuer / originator end on the same day when the funds are received from the beneficiary end.
6. The term bank includes non-banks also and applies to them wherever they are authorised to operate.
7. Domestic transactions i.e., those where both the originator and beneficiary are within India are covered under this framework.
8. Harmonisation of Turn Around Time (TAT) and Customer compensation for failed transactions using authorised Payment Systems is mentioned in below table:

   Sl. no.	Description of the incident	Framework for auto-reversal and compensation
   		Timeline for auto-reversal	Compensation payable
   I	II	III	IV
   1	Automated Teller Machines (ATMs) including Micro-ATMs
   a	Customer’s account debited but cash not dispensed.	Pro-active reversal (R) of failed transaction within a maximum of T + 5 days.	₹ 100/- per day of delay beyond T + 5 days, to the credit of the account holder.
   2	Card Transaction
   a	Card to card transfer Card account debited but the beneficiary card account not credited.	Transaction to be reversed (R) latest within T + 1 day, if credit is not effected to the beneficiary account.	₹ 100/- per day of delay beyond T + 1 day.
   b	Point of Sale (PoS) (Card Present) including Cash at PoS Account debited but confirmation not received at merchant location i.e., charg-slip not generated.	Auto-reversal within T + 5 days	₹ 100/- per day of delay beyond T + 5 days.
   c	Card Not Present (CNP) (e-commerce) Account debited but confirmation not received at merchant’s system.
   3	Immediate Payment System (IMPS)
   a	Account debited but the beneficiary account is not credited.	If unable to credit to beneficiary account, auto reversal (R) by the Beneficiary bank latest on T + 1 day.	₹100/- per day if delay is beyond T + 1 day.
   4	Unified Payments Interface (UPI)
   a	Account debited but the beneficiary account is not credited (transfer of funds).	If unable to credit the beneficiary account, auto reversal (R) by the Beneficiary bank latest on T + 1 day.	₹100/- per day if delay is beyond T + 1 day.
   b	Account debited but transaction confirmation not received at merchant location (payment to merchant).	Auto-reversal within T + 5 days.	₹100/- per day if delay is beyond T + 5 days.
   5	Unified Payments Interface (UPI)
   a	Off-Us transaction, The transaction will ride on UPI, card network, IMPS, etc., as the case may be. The TAT and compensation rule of respective system shall apply
   b	On-Us transaction, Beneficiary’s PPI not credited. PPI debited but transaction confirmation not received at merchant location.	Reversal effected in Remitter’s account within T + 1 day.	₹100/- per day if delay is beyond T + 1 day.

Online Dispute Resolution (ODR) System for Digital Payments:

1. Concept of the ODR system
   1. The ODR system should be a transparent, rule-based, system-driven, user-friendly and unbiased mechanism for resolving Customer disputes and grievances, with zero or minimal manual intervention.
2. Structure of the ODR system
   1. SML shall provide the Customers access for lodging disputes and grievances relating to failed transactions, irrespective of such transactions being on-us or off-us in nature.
3. Types of transactions covered under the scope of the ODR system
   1. To begin with, disputes and grievances relating to failed transactions shall be covered under the ODR system. The scope, thus, includes all transaction types mentioned in the RBI circular DPSS.CO.PD No.629/02.01.014/2019-20 dated September 20, 2019 on “Harmonisation of Turn Around Time (TAT) 12 and Customer compensation for failed transactions using authorised Payment Systems”.
   2. All provisions, including those relating to TAT and compensation to Customers mentioned in the above circular need to be adhered to while resolving disputes and grievances using the ODR system.
4. Lodging and tracking of disputes and grievances
   1. Customers shall be provided with one or more channels – web-based or paper-based complaint form, IVR, mobile application, call centre, SMS, through branches or offices, etc. – for lodging disputes and grievances. As mentioned above, such facility shall be provided by the SML (the issuer institutions with whom the Customer has a relationship) with a mechanism to link / access the ODR system put in place by SML. The industry may progressively increase the variety of these channels.
   2. In addition to the above channels, in case of mobile phone-based systems like Unified Payments Interface (UPI), third party app providers (TPAPs) shall also provide Customers with a facility to lodge disputes and grievances through the same mobile app used for making payments, which shall be integrated with the ODR system.
   3. The process of lodging the dispute or grievance shall be simple and involve only necessary minimum details. The ODR system should be made capable of automatically fetching full details based on the information provided by the Customer. The aspect of data confidentiality shall specifically be taken care of while designing such parameters.
   4. Once a Customer has lodged the dispute or grievance, a unique reference number shall be allocated by the ODR system. Facility shall be provided to the Customers for tracking the status of the dispute or grievance using this reference number.

Escalation Matrix

1. An effective escalation matrix will be made known to Customers, appropriately.

6.1 Ways to reach us

1. Website: Visit the “Contact Us” section on our website www.spicemoney.com, fill in the details of your query, and submit the form.
2. Email: You can email your queries, concerns, feedback, and complaints to customercare@spicemoney.com
3. Phone (Helpline): You can also contact our customer care number 0120-3645645, 0120-5077786 between 7:00 AM and 11:00 PM, on all days. These mechanisms are dedicated to redressing our Customer complaints, providing online resolution wherever possible, and capturing valuable feedback regarding our services. On receiving Customer feedback, our executives would reach out to the Customers, if need be, and ensure that all grievances are addressed within the estimated time to address the complaints.

6.2 Timelines for Grievance Resolution

Suitable timelines have been set for every complaint depending upon the investigations which would be involved in resolving the same. Here are the estimated timelines at various levels of queries/escalations

6.3 Escalations

Spice Money will try to address Customer’s feedbacks, queries and complaints to the best effort basis; However, if the Customer wants further recourse, the escalation matrix for the same are outlined below:

Level 1

Visit the ‘Contact Us section on our website www.spicemoney.com or write to us at customercare@spicemoney.com

You can also call our customer care numbers 0120-3645645, 0120-5077786 between 7:00 AM and 11:00 PM, on all days

Phone: 0120-3645645
Phone: 0120-5077786

Level 2

Write to our Grievance Officer, Guriya Kumari at guriya.kumari@spicemoney.com

Level 3

Write to our Nodal Officer at below address:
Spice Money Limited, Global Knowledge Park, 19A & 19B, Sector 125, NOIDA 201301, Uttar Pradesh, India.
Kind Attention: Ruchi Girdhar Email: grievances@spicemoney.com,  ruchi.girdhar@spicemoney.com
Contact Number: 0120-5029428 (Monday to Friday– 10am – 6pm)

6.4 Ombudsman Scheme & Complaint logging

To Download Ombudsman scheme click here

To lodge Ombudsman Complaint click here

6.5 Loan Related Grievance Redressal Details

Spice Money Nodal Officer Details

Lending Partner Nodal Officer Details

6.6 If you want to log a complaint related to unauthorized electronic payment, please click here