4. Grievance Redressal Policy

Effective date: April 03, 2025 Company: RAB CORP Pvt Ltd Service: SYNC Grievance Officer: Ashish Bhawkar Email: Ashish Bhawkar, Ashish.bhawkar@rabcorp.co.in Physical address in India: B401 Ashwini Paradise, Gangadham chowk Kondhwa Bibvewadi road Pune 37

4.1 Purpose

This Grievance Redressal Policy explains how Users, victims, authorised representatives, and other affected persons may submit complaints or grievances relating to SYNC, including complaints under the IT Rules, the Terms of Use / User Agreement, the Privacy Policy, the Community Guidelines, the Child Safety Policy, and Applicable Law.

We aim to provide a clear, accessible, and effective mechanism for receiving, acknowledging, reviewing, resolving, preserving, escalating, and appealing grievances.

4.2 Who may submit a grievance

A grievance may be submitted by:

a SYNC User;

a person affected by Content or conduct on SYNC;

a victim of privacy invasion, nudity, sexual content, impersonation, morphed images, child harm, harassment, or other harm;

a parent or legal guardian acting for a child;

an authorised representative acting on behalf of an affected person;

a rights holder or authorised agent;

a court, competent authority, government agency, or law enforcement authority; or

any person permitted under Applicable Law.

4.3 How to submit a grievance

You may submit a grievance through any of the following channels:

in-app reporting or support tools;

email to Ashish Bhawkar, Ashish.bhawkar@rabcorp.co.in;

email to support@rabcorp.co.in where available;

website form at www.rabcorp.com/sync/legal;

written notice to B401 Ashwini Paradise, Gangadham chowk Kondhwa Bibvewadi road Pune 37; or

any other mechanism we publish in the app or on the website.

For urgent complaints involving private areas, nudity, sexual acts, impersonation, artificially morphed images, CSAM, child safety, public order, cyber security, or imminent harm, please use the dedicated in-app urgent reporting option where available and email Ashish Bhawkar, Ashish.bhawkar@rabcorp.co.in with the subject line “URGENT SAFETY COMPLAINT”.

4.4 Information to include

To help us review a grievance, please provide as much of the following as possible:

your full name and contact email or phone number;

your SYNC Account identifier, phone number, email, or handle, if you are a User;

the reported User’s name, phone number, handle, Account identifier, group, channel, or broadcast details, if known;

message ID, group ID, channel ID, link, screenshot, file name, timestamp, or other electronic location of the Content;

the category of complaint, such as child safety, nudity, morphed image, impersonation, misinformation, IP infringement, malware, harassment, privacy invasion, or unlawful Content;

a clear description of the issue;

why you believe the Content or conduct violates our policies or Applicable Law;

documents proving authority if you are acting on behalf of someone else;

copyright, trademark, or ownership details where relevant;

whether there is immediate risk of harm; and

any police complaint, court order, government notice, or other legal document related to the complaint.

For E2EE private messages, we may not be able to review the content unless you use the in-app report function or otherwise voluntarily provide the relevant message or media to us.

4.5 Acknowledgement and general resolution timeline

We will acknowledge receipt of a grievance within twenty-four hours.

We will resolve grievances within seven days from the date of receipt, unless a shorter timeline applies, additional information is required, the matter involves a lawful authority process, or Applicable Law requires or permits a different process.

Resolution may include action, partial action, no action, request for additional information, referral to another process, preservation, escalation, or explanation of why action cannot be taken.

4.6 Thirty-six-hour harmful Content timeline

Complaints in the nature of requests for removal of information or communication links relating to prohibited Content categories under the IT Rules, except categories relating to ownership rights, intellectual property rights, and general violation of law where the special timeline does not apply, will be acted upon as expeditiously as possible and resolved within thirty-six hours of reporting, where Applicable Law requires.

This may include complaints involving obscene or pornographic Content, paedophilic Content, privacy-invasive Content, gender-based harassment, racially or ethnically objectionable Content, gambling or money laundering related harmful Content, enmity with intent to incite violence, child harm, misinformation, impersonation, public order threats, malware, prohibited online gaming related material, and similar categories.

We may develop safeguards to prevent misuse of this process.

4.7 Two-hour urgent privacy and impersonation timeline

Within two hours from receipt of a complaint made by an individual or by any person on that individual’s behalf, we will take all reasonable and practicable measures to remove or disable access to Content hosted, stored, published, or transmitted by us that is prima facie in the nature of:

material exposing the private area of the individual;

material showing the individual in full or partial nudity;

material showing or depicting the individual in any sexual act or conduct;

impersonation in electronic form; or

artificially morphed images of the individual.

To use this process effectively, the complainant should identify the Content, provide the relevant message, media, link, screenshot, or electronic location, and confirm that the complaint relates to the individual affected or is submitted on that individual’s behalf.

4.8 Child safety and CSAM grievances

Complaints involving child sexual abuse material, child sexual exploitation, grooming, child harm, or any Content harmful to a child will be treated as high priority. We may remove or disable access to the Content, suspend or terminate Accounts, preserve evidence, and report the matter to appropriate authorities where required by Applicable Law.

Parents, guardians, schools, and child protection representatives may contact support@rabcorp.co.in and Ashish Bhawkar, Ashish.bhawkar@rabcorp.co.in.

4.9 Court orders, government notices, and authority communications

The Grievance Officer or designated legal team will receive and acknowledge any order, notice, or direction issued by the Appropriate Government, competent authority, or court of competent jurisdiction.

Requests from courts, competent authorities, government agencies, law enforcement, or CERT-In are handled under the Law Enforcement Guidelines and Applicable Law. We may require verification of authority, legal basis, statutory provision invoked, electronic location of the Content, scope, and deadline.

4.10 E2EE limitations in grievance review

For supported end-to-end encrypted private communications, we do not have routine access to plaintext message content. We may review only information that is lawfully available to us, including metadata, account information, group or channel information, support communications, voluntarily reported messages, screenshots or attachments provided by the complainant, and other information under our control or possession.

If you submit a complaint about E2EE Content, please use the in-app reporting function where possible so that the relevant Content and metadata can be securely sent to us for review.

4.11 Possible outcomes

After review, we may take one or more of the following actions:

dismiss the grievance where no violation is found or information is insufficient;

request additional information;

issue a warning;

remove or disable access to Content;

restrict forwarding, group, channel, or broadcast features;

suspend or terminate an Account;

preserve evidence and associated records;

notify affected Users where appropriate and lawful;

provide reasons for action or non-action to the complainant where reasonable;

escalate to legal, child safety, cyber security, or law enforcement teams;

report to appropriate authorities where required; or

comply with a lawful order or direction.

4.12 Evidence preservation

Where Content is removed or disabled, or where we receive a grievance, lawful request, or actual knowledge requiring preservation, we may preserve the relevant Content and associated records without vitiating evidence. Such preservation may continue for at least one hundred and eighty days for investigation purposes, or longer where required by a court, government agency, law enforcement authority, CERT-In, or Applicable Law.

4.13 Notice to affected Users and reinstatement

Where required or reasonably appropriate, we may notify the User who created, uploaded, shared, disseminated, or modified Content about the action taken and the reasons for it. We may provide an opportunity to dispute the action and request reinstatement.

We may withhold notice or reinstatement where disclosure would be unlawful, unsafe, harmful to a child, harmful to an investigation, contrary to a court or government order, likely to cause further harm, technically infeasible, or inconsistent with Applicable Law.

4.14 Appeals to the Grievance Appellate Committee

If you are aggrieved by a decision of the Grievance Officer, or if your grievance is not resolved within the applicable timeline, you may prefer an appeal to the Grievance Appellate Committee within thirty days from the date of receipt of communication from the Grievance Officer or expiry of the applicable timeline, as permitted under the IT Rules.

The Grievance Appellate Committee may endeavour to resolve the appeal finally within thirty calendar days from receipt of the appeal and may conduct the process through digital mode. We will comply with orders of the Grievance Appellate Committee as required by Applicable Law and upload or publish compliance reports where required.

4.15 Significant Social Media Intermediary readiness

If SYNC becomes an SSMI or is otherwise required to comply with additional obligations under the IT Rules, we will implement additional mechanisms as required, including:

appointment of a Chief Compliance Officer resident in India;

appointment of a nodal contact person for 24x7 coordination with law enforcement agencies;

appointment of a Resident Grievance Officer;

publication of a physical contact address in India;

unique ticket numbers for complaints and grievances;

tracking status of complaints;

reasons for action or non-action to the extent reasonable;

monthly compliance reports; and

voluntary user verification mechanisms where applicable.

4.16 Misuse of the grievance process

You must not submit false, misleading, malicious, repetitive, abusive, forged, or bad-faith grievances. Misuse of the grievance system may result in rejection of the complaint, restriction of reporting privileges, Account action, or legal action, subject to Applicable Law.

4.17 Contact details

Grievance Officer: Ashish Bhawkar Email: Ashish Bhawkar, Ashish.bhawkar@rabcorp.co.in Support: support@rabcorp.co.in Child safety: support@rabcorp.co.in Law enforcement: law.enforcement@rabcorp.co.in Postal address: B401 Ashwini Paradise, Gangadham chowk Kondhwa Bibvewadi road Pune 37

03 April 2026