Grievance Redressal Policy

Last updated: 9 September 2026 · Version: 1.0.0 · Effective date: 9 September 2026

1. Background

USR Enterprises Private Limited ("ZulePay", "we", "us", "our") operates the ZulePay app — a digital payments platform offering a prepaid payment instrument ("Wallet", comprising the Main Wallet and the Offline Pocket), offline payments through immutable single-use tokens ("ISUTs"), Unified Payments Interface ("UPI") services in partnership with our partner banks and the National Payments Corporation of India ("NPCI"), recharges and bill payments through the Bharat BillPay System ("BBPS"), and merchant solutions including QR payments and settlements.

We are committed to resolving the complaints of our customers and merchants fairly and promptly. This Grievance Redressal Policy ("Policy") standardises the grievance redressal procedure across all ZulePay products and services. It supplements Section 29 (Grievance Redressal) of the ZulePay Terms & Conditions ("General Terms") and is issued in accordance with applicable Reserve Bank of India ("RBI") directions and the Consumer Protection Act, 2019 read with the Consumer Protection (E-Commerce) Rules, 2020.

2. Scope

This Policy addresses:

1. Customer grievances relating to products and services offered on the ZulePay app — the Wallet (Main Wallet and Offline Pocket), wallet loads and withdrawals, offline payments through ISUTs and Digital Cheques, UPI payments through partner banks, recharges and bill payments through BBPS, transaction failures and refunds, and account-related issues.
2. Merchant grievances relating to the ZulePay merchant app — onboarding and KYC, QR payment acceptance, settlements, the platform fee (MDR) and offline payment sync.
3. Data-protection complaints concerning our handling of personal data under the Privacy Policy.

Where a complaint concerns a product issued or operated by a third party (for example, an instrument of a partner bank through which UPI services are provided), we will assist you and, where appropriate, route the complaint to the issuer, without prejudice to your right to approach that issuer directly.

3. Objective

The objective of this Policy is to outline the grievance redressal mechanism of ZulePay — the channels through which complaints can be raised, the service levels and turnaround times ("TAT") applicable, and the escalation matrix available to customers and merchants respectively.

4. Target Audience

This Policy caters to all customers and merchants who use ZulePay's products and services.

5. Service Levels for Customers

Service levels for complaints relating to products and services offered on the ZulePay app — the Wallet (Main Wallet and Offline Pocket), wallet loads and withdrawals, offline payments through ISUTs and Digital Cheques, UPI payments through partner banks, recharges and bill payments through BBPS, rewards and cashbacks, and account-related issues.

Level 1 — Complaint Registration

We offer customer support service 24 hours a day, 7 days a week.

Resolution of Level 1 complaints:

1. We are committed to providing customers with a first response within 24 hours of receiving the complaint.
2. We aim to resolve all customer complaints within 15 days from receipt of the complaint.
3. For BBPS (bill payment / recharge) concerns and certain other cases involving third parties, we aim to resolve within 30 days from receipt of the complaint, with the exceptions called out in the Notes (Section 5.1).
4. Complaints relating to unauthorised transactions are handled as per Section 5.2 (Limitation of Customer Liability) of this Policy.

Level 2 — Grievance Registration

If your complaint remains unresolved after the defined timelines at Level 1, or you are dissatisfied with the resolution provided, you may escalate your concern to our Grievance Officer:

Chethan Kumar TP — Grievance Officer USR Enterprises Private Limited, VO-843, WeWork 10th Floor, RMZ Latitude, No. 69/458/69, Hebbal Kempapura, Bengaluru – 560024, Karnataka, India Email: support@zulepay.com (mark "Grievance — Level 2") · Phone: +91 95381 07745

Resolution of Level 2 complaints:

1. We are committed to providing a first response within 24 hours of receiving the Level 2 complaint.
2. We aim to resolve all Level 2 complaints within 7 business days from the date of receipt of the complaint.
3. For certain categories which may involve a third party (BBPS bill payments, partner-bank UPI, card network disputes), we aim to resolve within 30 days from receipt of the complaint, with the exceptions called out in the Notes (Section 5.1).

Level 3 — Nodal Officer Contacts

If the complaint remains unresolved after the defined timelines at Level 2, you may reach out to our Nodal & Principal Nodal Officers:

Nodal Officer: Chethan Kumar TP Principal Nodal Officer: Chethan Kumar TP Contact: +91 95381 07745 · Email: support@zulepay.com (mark "Nodal Desk — Level 3") USR Enterprises Private Limited, VO-843, WeWork 10th Floor, RMZ Latitude, No. 69/458/69, Hebbal Kempapura, Bengaluru – 560024, Karnataka, India Working hours: Monday–Friday, 10:00 AM to 7:00 PM

Resolution of Level 3 complaints:

1. We are committed to providing a first response within 24 working hours of receiving the Level 3 complaint.
2. We aim to resolve all Level 3 complaints within 7 business days from the date of receipt of the complaint; for third-party-dependent categories, within 30 days.

5.1 Notes on Customer Service Levels (applicable to all levels)

1. Where the RBI, NPCI, BBPS (NBBL) or a card network has prescribed a timeline for resolution, that prescribed timeline applies.
2. For BBPS / biller-dependent complaints, we aim to resolve within the committed timelines wherever there is no external dependency. Where there is an external dependency, actual resolution depends on the time taken by NBBL and/or the respective biller / biller operating unit. Such complaints include an amount debited but: services not received; service disconnected/stopped; late-payment surcharge added in the next bill; paid to the wrong account; duplicate payment; payment information not received or delayed from the biller; and bill paid but amount not adjusted (or still showing due).
3. Offline Pocket / ISUT disputes are assessed after the merchant's device sync and reconciliation; we will provide an interim response within 3 working days of sync.
4. UPI complaints are tracked with the partner bank / NPCI TAT until closure.
5. We will share the status and any revised timeline before the original TAT expires whenever a complaint requires additional time due to external dependencies or operational/technical reasons.
6. The outer limit for resolution of any complaint is 30 days from receipt, after which you may escalate under Section 7.

5.2 Limitation of Customer Liability

A customer's liability arising out of an unauthorised payment transaction will be limited as follows:

Customer responsibilities on limited liability:

1. Take appropriate measures to safeguard your account — strong passwords and PINs, changed at regular intervals.
2. Never share PINs, passwords or OTPs with anyone by email or phone, including anyone claiming to be from ZulePay — we will never ask for such credentials.
3. Promptly inform us in writing of changes to your mobile number or email, through Customer Support.
4. Register for SMS and email alerts (wherever applicable) for electronic payment transactions.
5. Monitor transactions regularly, through alerts or the app, to identify unauthorised transactions.
6. Report any unauthorised transaction promptly, ensuring there is no delay in reporting.

Notional credit: If an investigation into a reported unauthorised transaction is not concluded within 10 days of the report, we will provide a notional credit to your wallet. The notional credit is reversed if your liability is established within the 90-day time frame; if the dispute is not resolved within 90 days, the notional credit is converted into an actual credit to your wallet. You will be informed through an app notification.

5.3 Raising a BBPS dispute

For BBPS (bill payment / recharge) concerns, you may alternatively raise a bill-pay dispute from the transaction's History → Help & Support section in the ZulePay app. We may be approached by NBBL, wherever required, for resolution of such complaints.

5.4 Information to include

To help us resolve your complaint quickly, please share:

1. your registered mobile number (and merchant ID, where applicable);
2. the transaction reference, amount and date, as shown in the app's transaction history;
3. a clear description of the issue; and
4. any supporting material (for example, screenshots, operator messages or bank statements).

6. Service Levels for Merchants

Level 1 — Complaint Registration

Merchants can raise complaints about the ZulePay merchant app and services — onboarding and KYC, QR payment acceptance, settlements, the platform fee (MDR) and offline payment sync — through:

1. the Help & Support section of the ZulePay merchant app (select the relevant topic and Chat with Us);
2. our merchant support line — +91 95381 07745; or
3. email to support@zulepay.com quoting your merchant ID.

We offer merchant support service 24 hours a day, 7 days a week.

Resolution of Level 1 complaints:

1. We are committed to providing merchants with a first response within 24 hours of receiving the complaint.
2. We aim to resolve all merchant complaints within 15 business days of receipt. For device servicing and onboarding-related issues, we aim to resolve within 30 business days from receipt.
3. Settlement complaints are investigated against the settlement ledger and the merchant's transaction records; verified short-credits are corrected in the next settlement cycle, or sooner where the amount is significant.

Level 2 — Grievance Registration

If the complaint remains unresolved after the defined timelines at Level 1, or the merchant is dissatisfied with the resolution provided, it may be escalated to our Grievance Officer (contact details in Section 5, Level 2), quoting the merchant ID.

1. We are committed to providing a first response within 24 hours of receiving the Level 2 complaint.
2. We aim to resolve all Level 2 complaints within 7 business days from the date of receipt of the complaint.

Level 3 — Nodal Officer Contacts

If the complaint remains unresolved after the defined timelines at Level 2, merchants may reach out to the Nodal & Principal Nodal Officers (contact details and working hours in Section 5, Level 3).

1. We are committed to providing a first response within 24 working hours of receiving the Level 3 complaint.
2. We aim to resolve all Level 3 complaints within 7 business days from the date of receipt of the complaint.

6.1 Notes on Merchant Service Levels (applicable to all levels)

1. Resolution may extend beyond the defined timelines where closure depends on the merchant providing information or documentation required to aid closure.
2. Where there is no external dependency, we aim to resolve within the committed timelines; where banks or other external parties are involved, actual resolution depends on the time taken by those parties.
3. If a complaint requires additional time for external dependencies or operational/technical reasons, merchants will be updated on the delays and the expected resolution time.
4. Offline Pocket / ISUT sync disputes are assessed after device sync and reconciliation.

7. Escalation to the RBI Integrated Ombudsman (Level 4)

If a complaint relating to our payment services is rejected, is not resolved within 30 days, or you are dissatisfied with our resolution, you may approach the Ombudsman under the Reserve Bank – Integrated Ombudsman Scheme (as amended from time to time), subject to its eligibility conditions.

A complaint to the Ombudsman can be filed in three ways:

1. through the online CMS portal at cms.rbi.org.in;
2. by email to the CRPC email address published on the RBI CMS portal; or
3. by sending the filled-in complaint form with supporting documents by post/courier to the Centralised Receipt and Processing Centre (CRPC), Reserve Bank of India, Central Vista, Sector 17, Chandigarh – 160017.

The CRPC toll-free number 14448 (with IVRS) is available 24×7 for complainants to know about the Scheme and the complaint-lodging process; the facility to connect to contact-centre personnel is available Monday to Saturday (except national holidays) between 8:00 AM and 10:00 PM.

1. The complaint must first have been raised with us. Registration with the Ombudsman is not a determination of maintainability; complaints outside the Scheme (for example, commercial disputes or matters pending before a court or other forum) may be rejected without examination.
2. Our Principal Nodal Officer (Section 5, Level 3) represents us and furnishes information in respect of complaints filed against us under the Scheme.
3. For matters outside the Ombudsman's scope, you may also approach consumer fora under the Consumer Protection Act, 2019, or other authorities with jurisdiction.

8. Data Protection Complaints

For complaints about the handling of your personal data (consent, access, correction, erasure or security), contact the Grievance Officer (Section 5, Level 2). We acknowledge within 24 hours and respond within the timelines in Section 16 of the Privacy Policy. If your grievance remains unresolved, you may escalate to the Data Protection Board of India through the mechanism notified under the Digital Personal Data Protection Act, 2023.

9. General Provisions

1. Language. This Policy is published in English; the English version prevails over any translation.
2. No fee. Raising and pursuing a complaint through any channel in this Policy is free of charge.
3. Records. Complaints and their resolutions are recorded and retained as required by applicable law and RBI directions.
4. Amendments and versioning. We may update this Policy from time to time. Each version carries a version number and effective date at the top; the current version is always available at https://zulepay.com/grievance-policy. Material changes are notified in the app and/or by other channels before they take effect.
5. Relationship with other documents. This Policy supplements the General Terms, the Privacy Policy, the Cancellation & Refund Policy and the product terms on the Terms & Conditions hub. In case of conflict, the General Terms prevail unless this Policy expressly provides otherwise.
6. Governing law and jurisdiction. This Policy is governed by the laws of India. Subject to the escalation matrix, the courts at Bengaluru, Karnataka, India have exclusive jurisdiction, without prejudice to statutory rights to approach consumer fora or other authorities.

10. Contact Us

USR Enterprises Private Limited CIN: U62011KA2026PTC224718 VO-843, WeWork 10th Floor, RMZ Latitude, No. 69/458/69, Hebbal Kempapura, Bengaluru – 560024, Karnataka, India Email: support@zulepay.com · Phone: +91 95381 07745