GRIEVANCE POLICY

We, at Open Financial Technologies Private Limited (“OPEN”, “We” or “Us”, which includes its affiliates [Opendigi Technologies Pvt. Ltd. and Open Financial Technologies Inc.] and assigns) value all our customers, and we always strive to maintain a sincere and transparent approach during our interactions with all our customers. For the benefit and convenience of our customers, we have set up a grievance redressal mechanism and implemented this grievance policy (“Grievance Policy”). This Grievance Policy aims at resolving customer complaints and grievances by offering a proper redressal channel, review mechanism and ensuring prompt redressal of all customer grievances.

For the purpose of this Grievance Policy, (i) a “Customer” means any user having an account on our mobile/weblink platform; and (ii) a “Grievance” means any concern, dispute, complaint or feedback that a Customer desires to provide OPEN in relation to the services delivered owing to deficiency in the quality of services rendered or for any other reason whatsoever.

We understand that Grievances could arise under various circumstances. Such Grievances could arise on account of various reasons - from an unavoidable technical snag to a case involving deficiency in the quality of services delivered by OPEN. Our Customers have complete authority to share feedback / raise a complaint if they are disappointed with the services rendered by OPEN. The Customers can highlight or escalate their complaint/ feedback/ suggestions in writing, via email, or chat with our Customer support team. If a Customer’s issue is not resolved within the given time or if a Customer is dissatisfied with the resolution offered/provided by OPEN, they may approach our tiered redressal system or proceed to avail any other remedies available to them under applicable laws, which may be determined by the Customer at his/her/its own discretion. In order to make our redressal system more effective and meaningful for our Customers, we have established a structured system to resolve complaints seamlessly within the committed timeframe.

PRINCIPLES GOVERNING THIS GRIEVANCE POLICY:

All initiatives and strategies developed by OPEN are made with the Customer as the prime focus.
Prompt and efficient delivery of services to the Customer is essential for the growth of our business.
OPEN is constantly evolving newer and smarter system to collect feedback and objectively redress Grievances.
The details of OPEN’s grievance redressal mechanism are placed on its website and mobile application, in the public domain.
All employees at OPEN must work in good faith without, in any whatsoever, causing prejudice to the interests of Customers.
The Grievances of the Customers will be dealt with promptly and courteously.
OPEN promises to rectify any issue faced by a Customer effectively and in a timely manner, in accordance with this Grievance Policy.
All Customers will be treated fairly and equally at all times and under all circumstances.
The Customer must be aware of the channels available, in order to escalate their complaints, concerns and Grievances within OPEN.
There will be no charge that would be levied to the Customer for filing a complaint or a fee towards resolution of a Grievance.

TEAM SENSITIZATION ON HANDLING COMPLAINTS:

Our teams undergo regular training to ensure that Customer queries and Grievances are handled with sensitivity. They are guided and encouraged to offer a first time resolution which in turn leads to consumer trust, confidence and satisfaction. This reflects in both the operations as well as the Customer communications.

OBLIGATIONS OF CUSTOMERS:

To ensure a timely and effective grievance redressal process, We request that the Customers fully co-operate with us. Customers are expected to furnish relevant documentation and information for the verification of the complaint and investigation purposes. In certain cases, We may require Customers to furnish additional information. We request that Customers comply with such requests to ensure a smooth and efficient grievance redressal process. In addition, Customers are expected to ensure that such documentation and information is accurate, bona fide, not misleading, and up-to-date. OPEN disclaims all responsibilities and liability for non-redressal of Grievances due to false, inaccurate, mala fide, or outdated information or documents that are submitted by Customers.

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, time-out of sessions, non-credit to beneficiary’s account due to various causes, 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.

For the purposes of this Grievance Policy, terms like acquirer, beneficiary, issuer/originator, remitter, etc., have the same meanings as per common banking parlance.
‘T’ is the day of transaction and refers to the calendar date.
‘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.

The principle behind the turnaround time (TAT) is based on the following :

a. 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.

b. 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.

c. Customers who do not get the benefit of redress of the failure as defined in the TAT, can register a complaint to the Banking Ombudsman of Reserve Bank of India.

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.

Sl. No.	Description of the Incident	Framework for auto reversal and compensation
		Timeline for Auto Reversal	Compensation payable
1.	Card Transaction
(a)	Card to card transfer Card account debited but beneficiary card account not credited.	Transaction to be reversed (R) latest within T + 1 day, if credit is not effected to the beneficiary account.	Rs. 100/- per day of delay beyond T + 1 day.
(b)	Point of Sale (POS) (Card Present) including Cash at POS Amount debited but confirmation not received at merchant location, i.e., charge-slip not generated.	Auto-reversal within T + 5 days.	Rs. 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.
2.	Immediate Payment System (IMPS)
(a)	Account debited but the beneficiary account is not credited .	If unable to credit the beneficiary account, auto reversal (R) by the Beneficiary bank latest on T + 1 day.	Rs. 100/- per day if delay is beyond T + 1 day.
3.	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.	Rs. 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.	Rs. 100/- per day if delay is beyond T + 5 days.
4.	National Automated Clearing House (NACH)
(a)	Delay in crediting beneficiary’s account or reversal of amount.	Beneficiary bank to reverse the uncredited transaction within T + 1 day.	Rs. 100/- per day if delay is beyond T + 1 day.
(b)	Account debited despite revocation of debit mandate with the bank by the Customer.	Customer’s bank will be responsible for such debit. Resolution to be completed within T + 1 day.
5.	Aadhaar Enabled Payment System (including Aadhaar Pay)
(a)	Account debited but transaction confirmation not received at merchant location.	Acquirer to initiate “Credit Adjustment” within T + 5 days.	Rs. 100/- per day if delay is beyond T + 5 days.
(b)	Account debit but beneficiary account not credited.
6.	Prepaid Payment Instruments (PPIs) – Cards / Wallets
(a)
(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.	Rs. 100/- per day if delay is beyond T + 1 day.

* On-Us transaction: A settlement transaction where the acquirer and issuer banks are one and the same party.

** Off-Us transaction: A settlement transaction where the acquirer and issuer banks are distinct from each other.

TYPES OF DISPUTES

The types of disputes/issues with the Customers may include:

Technical issues while accessing OPEN’S platform.
Identifying or being subject to fraudulent transactions.
Facing issues while onboarding on OPEN’S platform.
Issues in relation to the payments of fees to OPEN.
Issues in relation to chargeback transactions, which will be resolved in accordance with the terms and conditions hosted at https://open.money/tnc
Disputes relating to rejection/ suspension of payments to the Customers, refunds and/or any other dispute relating to the transactions.
Billing disputes.

TRANSACTION LIFE CYCLE

The different modes of transactions that are available on the OPEN platform and the corresponding timelines are set out below:

Fund transfer and collection)
IMPS (Instant)
NEFT (Based on timelines set by the acquiring bank))
RTGS (Based on timelines set by the acquiring bank))
UPI (Instant) All the above modes of transaction are facilitated through APIs of the underlying bank.)
Payment Gateway - Amounts deducted from the Customer’s account shall be remitted to the escrow account maintaining bank on Tp+0 / Tp+1 basis. Where, ‘Tp’ is the date of charge / debit to the Customer’s account against the purchase of goods / services. At the end of the day, the amount in escrow account shall not be less than the amount already collected from Customer as per ‘Tp’ or the amount due to the Customer.)

UPDATING OF GRIEVANCE REDRESSAL MECHANISM:

At OPEN, we focus on optimising Customer experience and we always analyse and implement our policies and processes centred around the feedback received from the Customers. Therefore, a mechanism has been instated for analysis and requisite working towards rectification of any concerns identified within the system at the root level.

MANNER OF REGISTERING COMPLAINTS AND PROCEDURE FOR ADDRESSING THE GRIEVANCE

At OPEN, we love to hear from our Customers- be it feedback or a complaint. We truly believe and follow that Customer satisfaction is our priority.

Level-1:

If a Customer wishes to report a Grievance, she/he can seek redressal using any of the following channels:

CHAT - Please click chat icon from the Open dashboard and initiate a chat thread to raise the complaint.
E-MAIL - Please e-mail us at letstalk@openbook.co

Acknowledgement

Complaints received through the chat mechanism or e-mail will be acknowledged by an immediate system generated response or by way of an email response. The acknowledgment marks initiation of the Grievance resolution process.
The Customer will also be kept informed of the action taken, the progress while redressing Grievances, and the reasons for delay if any, in redressing.
The follow up action taken in respect of such Grievances shall be advised to Customers by e-mail and/or chat.

Resolution: All Grievances received will be acknowledged immediately by a system generated response and resolved within 3 (three) working days. In case the resolution of any Grievance takes more than the specified resolution time, the Customer will be intimated accordingly and kept updated on the progress / status of the Grievance on a periodic basis till such time that the Grievance is resolved. However, it is to be noted that the time taken to resolve a Grievance will be further exceeded, if assistance of third party service providers is required to address the Grievance.

It is however, clarified that the timelines applicable for auto-reversal and compensation payable for delay in auto-reversal for Failed Transactions are as per the tabulation on the TAT (turnaround time) framework above.

In case the Customer does not receive a response within the specified time for a Level 1 Grievance or if the Customer is dissatisfied with the response received from OPEN, the Customer may escalate the complaint to the next level as indicated below.

Level-2:

The Customer can address the Grievance to the below mentioned Nodal Officer for escalations:

Nodal Officer – Deepika Chakraborty ,
3rd floor, Tower 2, RGA Tech Park,
Sarjapur Road, Bengaluru – 560 035,
Karnataka.
E-mail id: deepika@bankopen.co

All escalations received would be acknowledged with 24 (twenty four) hours and a resolution would be provided within 3 (three) working days. In case any escalation takes more than the specified resolution time, the Customer will be intimated accordingly and kept updated on the progress / status of the escalation on a periodic basis till such time that the escalation is resolved. However, it is to be noted that the time taken to resolve a Grievance may exceed, if the assistance of third party service providers or partners is required.

Please note: You are requested to raise this higher Level 2 service request using the L 1 service request details provided to you. This is to ensure that you get correct resolutions faster based on the same ticket for resolution.

Level-3:

In case there is no response within the defined timeframe for Level 2 service request or in case the response provided is not satisfactory, or if any Customer so desires for any reason whatsoever, the Customer can reach out to the Operations Head for the matter:

Operations Head – Mabel Chacko
3rd floor, Tower 2, RGA Tech Park,
Sarjapur Road, Bengaluru – 560 035,
Karnataka.
Email: mabel@bankopen.co

All escalations received would be acknowledged with 24 (twenty four) working hours and a resolution would be provided within the next 3 (three) working days. In case any escalation takes more than the specified resolution time, the Customer will be intimated accordingly and kept updated on the progress / status of the escalation on a periodic basis till such time that the escalation is resolved. All of this would be available within the escalation reference number in our systems. However, it is to be noted that the time taken to resolve a Grievance may exceed, if any assistance of third party service providers or partners is required.