Complaints Handling Policy

(“Policy”)

Last Updated: May 20, 2024

Policy Statement

Google India Digital Services Private Limited (“Google”) has set out below its policy and framework (“Policy”) for resolving grievances, complaints and disputes received from customers and merchants (hereinafter collectively referred to as “Users”) in relation to Google Pay Services (as defined below). Google will resolve all Complaints (as defined below) as per applicable laws, National Payments Corporation of India (NPCI) circulars and guidelines, including the RBI instructions on Turn Around Time (TAT) for resolution of failed transactions issued vide DPSS.CO.PD No.629/02.01.014/2019-20 dated September 20, 2019 (“RBI Circular on TAT”), in a courteous and timely manner.

Purpose and Scope

Google has adopted this Policy with the aim to:

• educate Users about the various channels available for raising a Complaint;
• inform the Users the avenues to escalate a Complaint or seek alternative remedies, if they are not fully satisfied with Google’s resolution to their Complaint; and
• minimize instances of escalation of Complaints by aiming to provide a seamless service, through our Complaint’s handling mechanism(s) as mentioned in this Policy.

The following are the key principles underlying the Policy:

• Fairness: Users will be treated in a fair, equitable and timely manner.
• High quality: Aim to provide exceptional service delivery and strive to keep a check on services through an internal monitoring mechanism.
• Ownership: Commitment to maintain conduct in accordance with the applicable laws relating to Complaints handling.
• Empowerment: Educate Users about the various channels available to raising Complaints.
• Awareness: Inform the Users about their rights to seek alternative remedies if they are not fully satisfied with our response to their complaint.

Definitions

• “Customer” means a person who registers for Google Pay Service(s) including UPI payment facility to send or receive payments to merchants.
• “Google Pay Service(s)” means the payment transaction facilitation services, mobile recharges, bill payment services and other services provided by Google through Google Pay app or other related platforms.
• “Google Pay for Business Program” means each service access which is provided by Google to its Merchants through the ‘Google Pay for Business’ console operated by Google or its affiliates as described here or the merchant service agreement.
• “Merchant” means: an entity who uses Google Pay to collect payments from its customers for goods and services purchased from a merchant through any online platforms.
• “Users” include Customers and Merchants.
• “Complaint” means any expression of dissatisfaction, grievance, complaint, query, issue, etc. lodged by Users with Google in relation to Google Pay Service, including but not limited to the following, (as may be applicable to Users):

1. Transaction-based grievances, that include:
   1. Any failed transaction because of reasons that cannot be directly attributed to the Customer or Merchant such as disruption of communication links or time-out of sessions including the following:
      1. Account debited but the beneficiary account is not credited, in relation to UPI peer-to-peer (P2P) transactions,
      2. Account debited but transaction confirmation not received at Merchant’s location, in relation to UPI peer-to-merchant (P2M) transactions,
      3. Transaction failed but amount debited,
      4. Transaction timed out but amount debited,
      5. Transaction not permitted,
      6. Transaction declined.
   2. Fraudulent transactions;
   3. Amount incorrectly transferred to another account;
   4. Customer sent the money to the Merchant twice; or
   5. Merchant’s complaint regarding the amount not credited to the beneficiary account, but delivery of services have been completed, status of refunds initiated by Merchants via API, etc.
2. Service-based grievance, that include:
   1. Service related issue with Google Pay Service, e.g., any issues in relation to the following provided through Google Pay app, including but not limited to the following:
      • offers and rewards;
      • onboarding experience or any form of payments available over Google Pay app; or
      • account approvals and suspensions.

Customer Grievance Redressal Framework

What types of Complaints can be raised by Customers with Google?

A Customer can raise any Complaint i.e., any expression of dissatisfaction, grievance, complaint, query, issue, etc. with Google. Google will triage the Complaints in accordance with applicable laws and internal policies in a courteous and timely manner.

How can a Customer raise a Complaint?

Set out below is the process of dealing with the Complaints from Customers:

Level 1: Complaints Registration	Option 1 - Call Google Pay India Support number: Customers can reach the Customer Care number toll free at 1-800-419-0157. Hours of operations - 16*7 (8 AM to 12 AM) Option 2 - In-app support: Customers have an option to initiate chat support for all Complaints. Hours of operations - 16*7 (8 AM to 12 AM) Customers have an option to submit in-app ticket(s) for certain Complaints. Hours of operations - 24*7 Option 3 - Visit help center: Customers can visit the ‘Google Pay Help Center’ and select the ‘Contact us’ tab. From the tab, the Customers can choose the relevant option to connect with grievance personnel. Hours of operations - 16*7 (8 AM to 12 AM) First Response - Within 24 hours from receipt of Complaint at Level 1. Turn Around Time - 15 days from receipt of Complaint at Level 1. If any Complaint needs additional time because of external dependencies, operational or technical reasons, the Customer is accordingly updated on the particulars of the delays and expected resolution timelines.
Level 2: Complaints Registration	If the Customers are not satisfied with the redressal provided at Level 1 within 15 days of raising the Complaint, they can contact Google Pay India Support by filling this form to raise a L2 request. First Response - Within 24 hours from receipt of Complaint at Level 2. Turn Around Time - 15 days from receipt of Complaint at Level 2. If any Complaint needs additional time because of external dependencies, operational or technical reasons, the Customer is accordingly updated on the particulars of the delays and expected resolution timelines.
Level 3: Complaints Registration	If the Customers are not satisfied with the redressal provided at Level 2 within 15 days of raising the Complaint, they can contact Google Pay India Nodal Officer by writing to nodal-gpay@google.com or filling this form. Name - Rahul Dhiman Address - 5th Floor, DLF Centre, Block 124, Narindra Place, Sansad Marg, New Delhi Central, New Delhi - 110001, India Email id: nodal-gpay@google.com First Response - Within 24 hours from receipt of Complaint at Level 3. Turn Around Time - 15 days from receipt of Complaint at Level 3. If any Complaint needs additional time because of external dependencies, operational or technical reasons, the Customer is accordingly updated on the particulars of the delays and expected resolution timelines. In case the Customer's Complaint remains unresolved within a time period of 15 days, to the satisfaction of the Customer, then such Customer may also undertake the alternate mechanism as highlighted below.

Alternate mechanism

NPCI Redressal	To report a Complaint to the National Payments Corporation of India (NPCI), submit a dispute redressal mechanism complaint.
Banking Ombudsman Escalation	Any aggrieved Customer, whose Complaint was rejected wholly or partly by Google, and the Complainant is not satisfied with the reply, shall have the right to approach the RBI Ombudsman as per Integrated Ombudsman Scheme 2021.

Online Merchant Grievance Redressal Framework

What types of Complaints can be raised by Merchants with Google?

• A Merchant can raise any Complaint i.e., any expression of dissatisfaction, grievance, complaint, query, issue, etc. with Google. Google will triage the Complaints in accordance with applicable laws and internal policies in a courteous and timely manner.
• All disputes, chargebacks, cancellations and refunds of Payment Transactions will be triaged in accordance with the applicable law and these Google Pay for Business Program Additional Terms of Service or the merchant service agreement.

How can a Merchant raise a Complaint?

Please note that the below mentioned Merchant grievance redressal framework is only valid for online Merchants, to the extent applicable:

Level 1: Complaints Registration	Option 1 - Merchants can reach out to Google Pay India Support by writing to gpay-imf-support@google.com Hours of operations - 14*7 (8 AM to 10 PM) Option 2 - Merchants can raise a ticket on Business Console by clicking on Contact us in “Help pop-up section” under Help and Support section. Hours of operations - 24*7 Option 3 - Merchants also have an option to reach out to their respective assigned account managers (if any) First Response - Within 24 hours from receipt of Complaint at Level 1. Turn Around Time - 15 days from receipt of Complaint at Level 1. If any Complaint needs additional time because of external dependencies, operational or technical reasons, the Merchant is accordingly updated on the particulars of the delays and expected resolution timelines.
Level 2: Complaints Registration	If the Merchants are not satisfied with the redressal provided at Level 1 within 15 days of raising the complaint, they can contact Google Pay India Support by filling this form to raise a L2 request. First Response - Within 24 hours from receipt of Complaint at Level 2. Turn Around Time - 15 days from receipt of Complaint at Level 2. If any Complaint needs additional time because of external dependencies, operational or technical reasons, the Merchant is accordingly updated on the particulars of the delays and expected resolution timelines.
Level 3: Complaints Registration	If the Merchants are not satisfied with the redressal provided at Level 2 within 15 days of raising the complaint, they can contact Google Pay India Nodal Officer by writing to nodal-gpay@google.com or filling this form. Name - Rahul Dhiman Address - 5th Floor, DLF Centre, Block 124, Narindra Place, Sansad Marg, New Delhi Central, New Delhi - 110001, India Email id: nodal-gpay@google.com First Response - Within 24 hours from receipt of Complaint at Level 3. Turn Around Time - 15 days from receipt of Complaint at Level 3. If any Complaint needs additional time because of external dependencies, operational or technical reasons, the Merchant is accordingly updated on the particulars of the delays and expected resolution timelines. In case the Merchant’s Complaint remains unresolved within a time period of 15 days, to the satisfaction of the Merchant, then such Merchant may also undertake the alternate mechanism as highlighted below.

Alternate mechanism

Banking Ombudsman Escalation

Any aggrieved Merchant, whose Complaint was rejected wholly or partly by Google, and the complainant is not satisfied with the reply, shall have the right to approach the RBI Ombudsman as per Integrated Ombudsman Scheme 2021.

Processes for Customer Grievance Redressal and Online Merchant Grievance Redressal

How will Google address the Complaints?

Google may address the Complaints in one of the following manner after initial assessment or investigation:

1. Triage the Complaint and provide a clarification or resolution, or
2. Request Customer to redirect the Complaint to the appropriate third party for further triaging e.g., if a Customer requesting to cancel a successful P2M transaction where Google Pay India Support would guide the Customer to either reach out to the Merchant for a refund or contact the issuing bank to file a chargeback.

What is the Turnaround Time for triaging Complaints?

First Response - Within 24 hours from receipt of Complaint at the concerned Level.

Overall Turn Around Time - 15 days from receipt of Complaint at the concerned Level.

Compliance with RBI Circular on TAT - All Complaints relating to ‘failed transactions’ for the forms of payment supported over Google Pay Services will be processed as per the timelines prescribed under applicable laws including the RBI Circular on TAT. Failed transactions means 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. For example, in relation to UPI Peer-to-merchant (P2M) transactions a failed transaction is an instance where the Customer’s account was debited but transaction confirmation not received at Merchant location¹. In such cases where Google has not sent the transaction confirmation to the Merchant, Google will auto-reverse the transaction amount within T+5 days; failing which Google will be liable to pay penalty as per RBI Circular on TAT to the extent applicable. If Google had sent the transaction confirmation to the Merchant, Merchant is responsible for delivering the services or initiating a refund to the Customer. Google will not be liable for non delivery of the goods or services where Google has sent the transaction confirmation to the Merchant.

In a few scenarios, while the resolution to a Complaint is instant, it may take some time to get reflected in the system. For instance, reversal initiation may take more than 10 days to reflect the money in the account. Do note that such delays could be attributed to banking and other operational issues.

If any Complaint needs additional time because of external dependencies, operational or technical reasons, the User is accordingly updated on the particulars of the delays and expected resolution timelines.

Policy Review and Approval

• The Policy shall be reviewed annually and duly approved by Google’s BOD, to effectany changes in Applicable Laws and need for revision in internal processes.
• Till such review of the Policy, the contents of the Policy will always be read in tandem with modifications which may be advised by the RBI, NPCI and/ or by any regulators as applicable and/ or by Google from time to time. The relevant provisions of the Policy would be amended/ modified in due course to make it consistent with the applicable laws.

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¹ As defined under the RBI Circular on TAT Annex (Sl. No.4 (b)).