Introduction
This policy is created by PayGlocal Technologies Private Limited (hereinafter referred to as the "Company" or PayGlocal or "we") to clearly document the guidelines and practices followed by the Company for refund processing during its Payment Aggregator ("PA") and Payment Aggregator – Cross Border ("PA-CB") businesses.
PayGlocal is committed to ensuring that all refunds are processed in a fair, transparent, and timely manner in accordance with applicable regulatory requirements and the rules of the relevant payment systems.
Scope and Applicability
This Policy applies to:
- All payment transactions facilitated by PayGlocal in its capacity as a PA-Online and as a PA-CB.
- All merchants onboarded on the PayGlocal platform with whom PayGlocal has a contractual relationship.
- All refund scenarios arising from failed transactions, merchant-initiated refunds, disputed transactions, and cancelled transactions.
Objectives
The key objectives of this Policy are:
- To ensure that refunds are processed in a timely and transparent manner in accordance with applicable laws and regulations.
- To ensure that all refunds are credited back to the original payment method used by the payer, except in permitted circumstances as set out in this Policy.
- To establish clear standards for refund processing across all payment methods and transaction types applicable to PayGlocal's PA and PA-CB businesses.
- To protect the interests of payers and merchants by providing a fair and efficient refund mechanism.
- To ensure that refund processing is conducted in compliance with applicable anti-money laundering and counter-financing of terrorism requirements.
Refund to Original Payment Method
All refunds shall be made to the original method of payment used by the payer. This applies across all payment instruments including, but not limited to, credit cards, debit cards, UPI, net banking, and prepaid payment instruments (PPIs).
Refund to Alternate Payment Mode
As an exception to the above, a refund may be credited to an alternate payment mode only where:
- the payer has specifically and explicitly instructed PayGlocal or the merchant to credit the refund to an alternate mode; and
- the alternate payment mode is verified to belong to the same payer.
Where a payer requests a refund to an alternate payment mode, the following process shall apply:
- The merchant shall collect the payer's alternate bank account or payment instrument details, along with supporting documentary proof, and submit the same to PayGlocal.
- PayGlocal shall subject the alternate account details to an internal verification process, including a maker-checker control, to confirm that the alternate payment mode belongs to the same payer before processing the refund.
- Refunds to an alternate mode shall be processed only upon successful completion of this verification. PayGlocal reserves the right to decline a refund to an alternate mode where it is unable to verify the payer's ownership of the alternate account.
- All instructions and verification evidence shall be documented and retained as part of the transaction record.
Refund Process
Standard Merchant-Initiated Refund
The standard refund process is as follows:
- The payer raises a refund request with the merchant for the relevant transaction.
- The merchant evaluates the refund request in accordance with its own return and refund policy, the terms of which shall be clearly disclosed on the merchant's website or platform.
- Upon approval, the merchant initiates the refund via the PayGlocal platform, either through the API or the PayGlocal Command Centre using merchant login credentials.
- PayGlocal processes the refund to the original payment method used by the payer.
- All refunds initiated via the API or PayGlocal Command Centre are follow-on refunds against the original transaction. Standalone refunds (i.e., refunds without a corresponding original transaction processed through PayGlocal) are not supported through these channels.
PayGlocal-Assisted Refund
Where a merchant faces a technical issue or is otherwise unable to process a refund through its own platform, the merchant may request PayGlocal to process the refund on its behalf. In such cases:
- The merchant shall submit a formal request to PayGlocal, including the unique transaction identifier and relevant transaction details.
- PayGlocal shall process the refund on the merchant's behalf as an exception, subject to verification of the transaction details.
- All such refunds shall be processed to the original payment method of the payer, in accordance with the Refund to Original Payment Method section of this Policy.
Refund Timelines and TAT Compliance
Failed Transactions
PayGlocal is committed to ensuring that failed transactions (being transactions where the payer's account has been debited but the transaction has not been completed for reasons not attributable to the payer) are resolved within the timelines prescribed by the RBI TAT Circular (DPSS.CO.PD No.629/02.01.014/2019-20 dated September 20, 2019, as amended from time to time). The TAT framework for failed transactions shall be applied instrument-wise in accordance with the applicable rules prescribed for each authorised payment system under the TAT Circular.
Where financial compensation is due to the payer because of a delay beyond the prescribed TAT, PayGlocal shall endeavor to ensure such compensation is affected suo motu, without waiting for a complaint from the payer. PayGlocal shall maintain internal controls and monitoring mechanisms to track failed transactions and ensure adherence to the TAT framework.
Merchant-Initiated Refunds
For merchant-initiated refunds on successfully completed transactions, PayGlocal shall process refunds in accordance with the applicable rules and timelines of the relevant payment method and the policies of the issuing bank, card network, or payment system operator. Indicative processing timelines vary by payment method and are subject to the processing cycles of the relevant payment system. PayGlocal shall clearly communicate expected refund timelines to merchants and, where applicable, to payers, through its platform documentation and merchant agreements.
AML/CFT Compliance in Refund Processing
All refund transactions facilitated by PayGlocal are subject to the Company's KYC/AML/CFT Policy and the applicable provisions of the Prevention of Money Laundering Act, 2002 and the rules framed thereunder. In particular:
- Refunds shall only be processed to the verified original payment method or, in permitted cases, to a verified alternate payment mode belonging to the same payer, so as to prevent refund transactions from being used as a vehicle for money laundering or layering.
- Refunds processed by PayGlocal on behalf of a merchant shall be subject to appropriate transaction monitoring controls.
- Any refund transaction that presents indicators of suspicious activity shall be handled in accordance with the Company's KYC/AML/CFT Policy.
Record Keeping
PayGlocal shall maintain records of all refund transactions, including failed transaction reversals, merchant-initiated refunds, and PayGlocal-assisted refunds, for such periods and in such manner as may be required by applicable laws and regulations. Records shall include transaction identifiers, refund amounts, payment methods, timestamps, and, where applicable, documentation of alternate-mode verification and payer instructions.
Policy Review
This Policy shall be reviewed at least annually, or when significant regulatory changes occur, to ensure its continuing suitability, adequacy, and effectiveness, and to incorporate any updates required by regulatory changes or operational developments. Any material changes to this Policy must be approved by the Board of Directors of the Company.