GRIEVANCE REDRESSAL POLICY

1.PURPOSE

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This Grievance Redressal Policy(“Policy”)is adopted by Ayurooms and Wellness Pvt Ltd, a company incorporated under thelaws of India (“Company”), in furtherance of its obligations under applicableIndian data protection law relating to the publication of grievance-redressalcontact information and timely resolution of grievances (together, the “DPDPFramework”), and applicable Indian consumer protection law governinge-commerce entities, including the requirement to appoint a grievance officerand resolve consumer complaints within prescribed timelines (the “E-CommerceRules”).

This Policy sets out themechanism through which any Data Principal, Customer, or other user of thePlatform may raise a Grievance, the timelines within which the Company shallrespond, and the escalation avenues available in the event a Grievance remainsunresolved.

This Policy is incorporated byreference into, and shall be read together with, the Company’s Privacy Policy,Customer Terms & Conditions, and Booking, Payment, Cancellation &Refund Policy. In the event of any conflict between this Policy and any otherpolicy of the Company solely in relation to the grievance-handling mechanism,timelines, and escalation process, this Policy shall prevail.

2.DEFINITIONS& INTERPRETATIONS

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In this Policy, unless thecontext otherwise requires, the following expressions shall bear the meaningsset out below, and cognate expressions shall be construed accordingly:

“Board” means the Data Protection Board of India, being thestatutory authority empowered to receive and adjudicate complaints relating tothe processing of Personal Data.

“Business Day” means any day other than aSaturday, Sunday, or a public holiday observed by the Company at its registeredoffice.

“Customer”    means any individual who hassubmitted an enquiry, requested a personalised package, or made a Bookingthrough the Platform.

“DataPrincipal”    means the individualto whom the Personal Data relates.

“Grievance”  means any expression ofdissatisfaction made by a Complainant to the Company, whether relating to (a)the processing of Personal Data or the exercise of rights under the PrivacyPolicy; (b) a Booking, payment, cancellation, or refund; (c) the conduct, quality,or standard of services rendered by a Partner Resort to the extent arrangedthrough the Platform; (d) visa assistance or other concierge services; or (e)the functioning of the Platform generally.

“GrievanceOfficer”   means the officerappointed by the Company under Clause 4 of this Policy, who shall also functionas the Company’s Data Protection Officer and Nodal Officer for the purposes ofthe DPDP Framework and the E-Commerce Rules respectively, unless the Companydesignates separate individuals for each such role.

“PartnerResort” means anindependently owned and operated Ayurvedic resort, wellness centre, orhealthcare facility with which the Company has an arrangement for the purposeof offering bookings through the Platform.

“Platform” means the website www.ayurooms.comand any related mobile or digital interfaces operated by the Company.

“Complainant” means a Data Principal,Customer, or other user of the Platform who raises a Grievance under thisPolicy.

3.SCOPEOF THE POLICIES

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The objective of this Policy isto ensure that every Grievance is acknowledged, investigated, and resolved in afair, transparent, and time-bound manner, and that Complainants are keptinformed of the status of their Grievance throughout the process.

This Policy applies toGrievances of the categories set out in Clause 6 below. It does not apply to:(a) commercial or contractual disputes between the Company and a PartnerResort, vendor, or business partner, which shall be governed by the terms ofthe applicable agreement between the parties; or (b) employment-relatedgrievances of the Company’s employees, which shall be governed by the Company’sinternal human resources policies.

4. APPOINTMENTAND PUBLICATION OF GRIEVANCE OFFICER

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The Company has appointed aGrievance Officer, resident in India, who shall be responsible for theredressal of Grievances in accordance with this Policy, and whose contactinformation shall be published on the Platform.

The name, designation, andcontact details of the Grievance Officer are set out in Schedule I to thisPolicy and shall be published and kept current on the Platform.

Where the Company designatesseparate individuals to act as Data Protection Officer and Nodal Officer forthe purposes of the DPDP Framework and the E-Commerce Rules respectively, thedetails of each such individual shall likewise be set out in Schedule I.

5. GRIEVANCEREPORTING PROCESS

A Complainant may file aGrievance through any of the following channels:

➢ Email to the Grievance Officer at the addressset out in Schedule I;

➢ The contact/enquiry form available at www.ayurooms.com/contact-us;

➢ Written communication addressed to theregistered office of the Company set out in Schedule I.

A Grievance should, to the extent possible, include: (a)the Complainant’s full name and contact details; (b) the Booking referencenumber, if applicable; (c) a clear and specific description of the Grievance;and (d) copies of any supporting documents or correspondence.

Upon receipt of a Grievance, the Company shall issue theComplainant a unique ticket number, which the Complainant may use to track thestatus of the Grievance.

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6. CLASSIFICATION OF GRIEVANCES AND APPLICABLE TIMELINE

Grievances shall be classified and processed in accordance with the following table:

CATEGORY DESCRIPTION TIMELINE
Data Protection Grievance Relating to the processing of Personal Data, or the exercise of the Data Principal’s rights of access, correction, erasure, and nomination. Acknowledged and resolved within ninety (90) days of receipt, being the timeline prescribed under applicable data protection law.
Consumer / Booking / Payment Grievance Relating to a Booking, payment, cancellation, or refund made through the Platform. Acknowledged within fortyeight (48) hours and resolved within one (1) month of receipt, being the timeline prescribed under applicable consumer protection law for e-commerce entities.
Partner Resort Service Grievance Relating to the conduct, quality, or standard of treatment or hospitality service rendered by a Partner Resort. Acknowledged within fortyeight (48) hours; the Company shall use reasonable efforts to facilitate resolution with the Partner Resort within thirty (30) days, recognising that final resolution may depend on the Partner Resort’s own response.
Platform / Technical Grievance Relating to the functioning, accessibility, or technical performance of the Platform. Acknowledged within fortyeight (48) hours and resolved within a reasonable time having regard to the nature of the technical issue.

7. GRIEVANCEREDRESSAL PROCESS

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➢ Acknowledgement:The Company shall acknowledge receipt of a Grievance within the timelinespecified in Clause 6, confirming the ticket number and the expected timelinefor resolution.

➢ Investigation:The Grievance Officer shall examine the Grievance, which may include seekingclarification from the Complainant, reviewing internal records, and, where theGrievance concerns a Partner Resort, requesting information or a response fromthe relevant Partner Resort.

➢ Resolutionand Communication: Upon completing its review, the Company shallcommunicate its findings and proposed resolution to the Complainant in writing,in plain and simple language.

➢ Closure:A Grievance shall be treated as closed upon communication of the resolution tothe Complainant, unless the Complainant raises a substantive objection withinfourteen (14) days of such communication, in which case the Grievance Officershall review the matter afresh.

➢ Extensions:Where a Grievance is complex or requires information from a third party(including a Partner Resort or payment service provider), the Company mayrequire additional time to resolve the Grievance, and shall inform theComplainant of the revised expected timeline, providing reasons for theextension.

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8. ESCALATION MATRIX

Where a Complainant is not satisfied with the resolution of a Grievance at the first level, the following escalation avenues are available:

LEVEL FORUM NATURE / APPLICABILITY CONTACT
Level 1 Grievance Officer (Company) Initial point of contact for all Grievances. See Schedule I
Level 2 — Data Protection Grievances Data Protection Board of India Statutory escalation where a Data Protection Grievance remains unresolved, or the Complainant is dissatisfied with the Company’s resolution. See Schedule II
Level 2 — Consumer / Booking Grievances National Consumer Helpline (NCH), Department of Consumer Affairs Voluntary, free-of-charge mediation channel prior to formal litigation. See Schedule II
Level 3 — Consumer / Booking Grievances Consumer Disputes Redressal Commission (District / State / National, as applicable based on claim value) under the Consumer Protection Act, 2019 Formal adjudicatory forum, including via the e-Daakhil online filing portal. See Schedule II

A Complainant is encouraged, though not obligated beyond what applicable law requires, to first exhaust the Level 1 mechanism under this Policy before approaching a Level 2 or Level 3 forum, so as to afford the Company a fair opportunity to resolve the Grievance directly.

Nothing in this Policy shall be construed as limiting or waiving any statutory right of a Complainant to approach the Board, the Consumer Disputes Redressal Commission, or any other competent authority or court at any time in accordance with applicable law.

9.CONFIDENTIALITY

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Information disclosed by aComplainant in the course of raising a Grievance shall be treated asconfidential and used solely for the purpose of investigating and resolvingthat Grievance, save where disclosure is required to a Partner Resort or thirdparty strictly for the purpose of resolution, or as required by applicable law.

10.NON-RETALIATION

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The Company shall not penalise,restrict access to the Platform, or otherwise retaliate against a Complainantfor raising a Grievance in good faith.

11.RECORD-KEEPING

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The Company shall maintain aregister of Grievances received, including the date of receipt, ticket number,nature of the Grievance, and date and manner of resolution, for such period asmay be required under applicable law.

The Grievance register shall be reviewed periodically by the Company’ssenior management to identify recurring issues and improve the Company’sservices and processes.

12.AMENDMENTAND REVIEW

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The Company may amend thisPolicy from time to time to reflect changes in applicable law or itsoperational practices. The version of this Policy in force at the time aGrievance is raised shall apply to that Grievance, save where a subsequentamendment is more favorable to the Complainant and the Company elects to applyit.

13.GOVERNINGLAW

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This Policy shall be governed by the laws of India.Nothing in this Clause shall affect the jurisdiction of the Board, the ConsumerDisputes Redressal Commission, or any other authority conferred by applicablelaw.

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