Privacy Policy

1 About This Policy

This Privacy Policy ("Policy") sets out the manner in which Justech Computing Private Limited ("Justech", "we", "us", or "our") — a company incorporated under the Companies Act, 2013, with its registered office in Mumbai, Maharashtra, India — collects, processes, stores, uses, discloses, and protects personal information when you access or use the Netoo mobile application (Android package: in.netoo.app) and its associated web platform at netoo.in (collectively referred to as the "Platform" or the "Services").

Netoo is a hyperlocal social communication platform that enables residents, community members, and local stakeholders within a village, gram panchayat, or locality in India to communicate, share information, access government-published data, and engage in locality-level communications.

This Policy is published in compliance with, and to give effect to the requirements of, the following applicable Indian legislation and subordinate regulations, as amended from time to time:

• The Information Technology Act, 2000 ("IT Act")
• The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 ("IT Rules 2021"), as amended by the Amendment Rules of October 2022, April 2023, October 2025, and February 2026
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules")
• Any other applicable law, guideline, advisory, or standard operating procedure issued by the Ministry of Electronics and Information Technology ("MeitY") or any other competent governmental authority from time to time

By downloading, installing, accessing, registering on, or using the Platform in any manner — whether as a registered user or a guest — you acknowledge that you have read, understood, and expressly consented to the collection and use of your information as described in this Policy. If you do not agree with any provision of this Policy, you must immediately discontinue access to and use of the Platform.

This Policy constitutes an electronic record within the meaning of the IT Act and the Information Technology (Electronic Records) Rules, 2000, and does not require physical or digital signatures.

2 Definitions

Unless the context otherwise requires, the following terms used in this Policy shall bear the meanings assigned to them below. Terms not defined herein shall have the meaning assigned to them under the IT Act or IT Rules 2021, as applicable.

3 Information We Collect

We collect information in the categories described below. The scope of information collected varies depending on how you interact with the Platform and whether you are a Guest User or a Registered User.

3.1 Information You Provide at Registration

When you create an account on the Platform, you will be asked to provide the following information:

3.2 Location (Locality) Information

Location data (i.e. your village or locality broadly) is fundamental to the Netoo experience and is collected in two distinct forms:

• GPS Coordinates (Transient): With your explicit permission, we request access to your device's GPS during the location-selection process at onboarding, or when you choose to update your active location. The GPS coordinates are used solely and transiently to map your physical position to the lowest available administrative level within our location hierarchy (State → District → Sub-District → Gram Panchayat → Village or State → City → Area → Subarea → Locality) and to pre-select the most appropriate village or locality. Raw GPS coordinates are not required and not stored on our servers beyond the duration of this mapping operation.
• Selected Location (Persistent): Your chosen village or locality — either GPS-assisted or manually selected from the dropdown — is stored on our servers as your active Village Group affiliation. This constitutes personal location information for the purposes of the SPDI Rules and applicable law.

You may deny GPS permission and select your location manually at any time. A User may belong to only one Village Group at a time. Your can update your village group at any point.

3.3 User-Generated Content

When you use the interactive features of the Platform, we receive and collect content that you create or share, including:

• Broadcast messages and short announcements posted to your Village Group
• Private messages exchanged with other Registered Users within your Village Group
• Media attachments (optional) if any, along with the messages : up to one (1) image file, one (1) audio file, one (1) video and one (1) document file per message
• Live video streams broadcast to your Village Group (maximum session duration: four minutes). Live video streams are only sent as received, to other watchers (registered users who have chosen to watch the live video), and are not stored on the platform once the streaming is closed.

3.4 Netoo Device Information

Upon first-time use, post installation of the Platform, a Device ID — a unique identifier generated locally by the application — is stored. This identifier is used exclusively to enforce our policy of permitting a maximum of four (4) registered accounts per physical device. The Netoo Device ID is stored on our servers along with the registration details, and is not used for behavioural profiling or advertising.

3.5 Technical and Usage Data

We may automatically collect certain technical data when you access the Platform, which may include: date, time, and duration of access; device type and operating system version; features accessed; error and crash logs; and general performance metrics. This information is used solely for the purpose of maintaining service reliability, diagnosing technical faults, and improving Platform performance. It is not linked to your personal identity unless necessary to resolve a reported issue.

3.6 Push Notification Tokens

If you grant permission for push notifications, a device notification token is collected and associated with your account. This token is used solely to deliver Platform-related notifications to your device. You may withdraw notification permissions at any time through your Android device settings, without affecting your ability to use other features of the Platform.

3.7 Information We Do Not Collect

For the avoidance of doubt, Justech does not collect the following categories of information at this time:

• Payment, debit/credit card, or any other financial information (the Platform is free of charge)
• Government identification numbers including Aadhaar, PAN, Voter ID, or Passport number
• Biometric data of any nature
• Continuous or background location data
• Contacts or address book data from your device
• Browsing history from other applications or websites

4 How We Use Your Information

We process the information we collect for specific, limited, and lawful purposes as described below. We do not use your personal information for purposes incompatible with those for which it was originally collected without your further consent.

4.1 Providing and Operating the Platform

• Creating, maintaining, and authenticating your account
• Determining your Village Group membership and displaying relevant community content, government information, and curated social feeds
• Enabling broadcast messaging, private messaging, announcements, and live video features
• Displaying your name, username, designation, and mobile number in the village contacts directory for community interaction
• Enforcing the four-account device registration limit via the Device ID, phone number, email address as applicable

4.2 Communications and Notifications

• Delivering push notifications related to community activity (new messages, announcements, broadcasts)
• Sending administrative communications regarding your account, policy updates, or material changes to the Platform
• Periodically notifying you, at least once every three (3) months, that violations of our Terms of Service and Community Guidelines may result in account suspension or termination, in accordance with the IT Rules 2021 (as amended)

4.3 Safety, Security, and Legal Compliance

• Detecting, investigating, and preventing fraud, abuse, spam, harassment, and violations of our Terms of Service or Community Guidelines
• Processing and responding to grievances submitted to our Grievance Officer
• Complying with lawful orders from courts of competent jurisdiction and lawful directions from authorised government officers under the IT Act and IT Rules 2021
• Taking down or disabling access to unlawful content upon receipt of a lawful notice from a competent authority within the applicable statutory timeframe
• Reporting offences related to child protection under the Protection of Children from Sexual Offences Act, 2012 (POCSO) and offences under the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) to the relevant authorities, as required by applicable law

4.4 Service Improvement and Analytics

• Analysing aggregated, anonymised usage patterns to improve the Platform's features, performance, and user experience
• Diagnosing technical problems, monitoring service stability, and conducting internal research

5 Legal Basis for Processing

We process your personal information on the following legal grounds under applicable Indian law:

• Contractual Necessity: Processing necessary to perform our obligations to you under our Terms of Service and to provide you with the features and functions of the Platform you have requested.
• Consent: Where you have provided your voluntary, informed, and specific consent, including consent to location access, push notifications, and the collection of information at registration. You may withdraw consent at any time as described in Section 15.
• Legal Obligation: Processing required to comply with our obligations under the IT Act, IT Rules 2021, SPDI Rules, POCSO, BNSS, and any other applicable law or binding regulatory direction.
• Legitimate Interest: Processing necessary for the purposes of preventing fraud and abuse, ensuring Platform security, improving service quality, and protecting the rights and safety of our Users and the public, where such interests are not overridden by your fundamental rights.

6 Information Sharing & Disclosure

Justech does not sell or rent your personal information to any third party. We disclose your information only in the specific and limited circumstances described below.

6.1 Within Your Village Group

Certain profile information — including your display name, username, designation or role, email, address, user type and mobile number — is visible to other Registered Users and Guest mode users within your Village Group as an integral part of the community contacts directory and interaction features. By registering and selecting a Village Group, you expressly acknowledge and consent to this limited sharing of your profile information within that community.

6.2 Third-Party Service Providers

We engage carefully selected third-party service providers to assist in operating, hosting, and improving the Platform. These entities process data on our behalf only, under binding contractual obligations, and are not permitted to use your information for any purpose other than providing the contracted services to us:

• Amazon Web Services, Inc. (AWS): Cloud infrastructure, server hosting, and data storage
• Firebase / Google LLC: Push notification delivery

6.3 Compliance with Legal Process and Government Directions

We may access, preserve, and disclose your personal information or User Content when we have a good-faith belief that doing so is required or authorised by applicable law, including in response to:

• A valid court order or judicial direction from a court of competent jurisdiction in India
• A lawful direction from an authorised government officer of the rank of Joint Secretary or above to the Central or State Government (or equivalent), or a Deputy Inspector General of Police or above in the case of police authorities, issued under the IT Act or IT Rules 2021, specifying the legal grounds and the precise URL or content identifier
• Any other binding legal obligation under applicable Indian law

We will, to the extent permitted by law and where practicable, notify you of such disclosure prior to complying with the request.

6.4 Protection of Rights, Safety, and Integrity

We may disclose information where we hold a reasonable, good-faith belief that such disclosure is necessary to: (a) protect the rights, property, or safety of Justech, our Users, or the general public; (b) detect, investigate, or prevent fraud, illegal activity, harassment, or violations of our Terms of Service or Community Guidelines; (c) respond to a genuine emergency involving risk to life or physical safety; or (d) fulfill our mandatory reporting obligations under POCSO or the BNSS.

6.5 Business Transfers

In the event of a merger, acquisition, amalgamation, restructuring, sale of business or assets, or similar corporate transaction involving Justech, your personal information may be transferred to the successor entity as part of that transaction. We will use reasonable efforts to notify you of any such change and to ensure that appropriate data protection obligations remain in place in respect of your information.

6.6 With Your Consent

We may share your information with third parties for any other purpose, provided we have obtained your explicit, prior, and informed consent for such sharing.

7 User-Generated Content & Public Information

7.1 Nature of Broadcast and Community Content

Broadcast public messages, short announcements, and other content posted by a registered user to a Village Group are visible to all members of that group, including Users accessing the Platform in Guest Mode without a registered account but belonging to that village or locality. You should exercise careful judgment about what you choose to post in these public messages and announcements, as such content is effectively public within the village community and cannot be guaranteed to remain within that audience.

7.2 Private Messaging

Private messages are visible only to the specific Registered User with whom you are corresponding. However, Netoo does not employ end-to-end encryption for private messages. Private messages may be accessible to Justech for the purposes of safety monitoring, responding to lawful legal process, or investigating complaints. You are strongly advised not to share sensitive personal, financial, medical, or legally privileged information through the private messaging feature.

7.3 In-App User Controls — Hide, Block, and Report

The Platform provides every Registered User with a set of safety and content controls accessible directly from any piece of content — whether a community post, announcement, private message, social feed item, or live broadcast. These controls are available through a menu associated with each item or user profile and include the following:

• Hide a specific message or post: Removes a particular item from your personal view on the Platform. The content remains visible to other members of the Village Group but will no longer appear in your app. This action affects only your own experience and does not notify the author.
• Hide all content (i.e. the ability to hide various category of messages a) public posts, b) private messages, c) announcements) from a specific user: Suppresses all current and future content, of that category, from a particular User from your personal view of the Platform. This is a personal preference setting and does not restrict the other user's ability to post or interact with the community. A "hidden" user (for each cateogry of content) can be un-hidden by the user anytime.
• Block a user: Removes the user from your contacts, and prevents all forms of that user's interactions with you on the Platform. Blocking is mutual in its effect on direct interaction i.e. it works both way. The blocked User is not notified of the block. You may unblock a User at any time through your account settings.
• Report a message or post: Submits a complaint about a specific piece of content to Justech's moderation team. Upon submission, you will receive an on-screen confirmation that your report has been received. If you attempt to report the same content again, the Platform will inform you that a report has already been submitted. Reports are reviewed by our moderation team and may result in the content being hidden from the community, the author being warned, or the author's account being suspended or permanently banned, depending on the nature and severity of the violation.
• Report a user: Submits a complaint about a specific User's conduct or pattern of behaviour to our moderation team. This is distinct from reporting an individual piece of content and is appropriate where the concern relates to the User generally rather than a single post or message. The same review and action process applies as described above for content reports.

All reports submitted through the in-app mechanism are stored in our backend systems and routed to our moderation team for review. In-app reports constitute a complaint for the purposes of our Grievance Redressal Mechanism under IT Rules 2021 and are subject to the same acknowledgement and resolution timelines described in Section 19.

7.4 Content Moderation Actions by Justech

Justech reserves the right — and in certain cases is legally obligated — to remove, restrict access to, or otherwise act on User Content or User accounts where:

• A report is received through the in-app reporting mechanism or via the Grievance Officer
• Content violates our Terms of Service or Community Guidelines
• Removal is required pursuant to a lawful court order or government direction within the applicable statutory timeframe
• Content constitutes non-consensual intimate imagery, impersonation, or content depicting sexual violence or terrorism — action within twenty-four (24) hours of a valid complaint
• Content constitutes unlawful Synthetically Generated Information (deepfakes) — action within three (3) hours of receiving actual knowledge through a valid lawful notice, per the IT Rules Amendment 2026
• Other unlawful content subject to a valid court order or authorised government notice — action within thirty-six (36) hours

Moderation actions available to Justech include: hiding or removing specific content from community view, issuing a warning to the relevant User, temporarily suspending an account, or permanently banning an account. Affected Users may dispute moderation decisions through the Grievance Officer as described in Section 19.

7.5 External Social Media Feed Content

The Platform displays a curated feed of publicly available content from social media accounts relevant to your village, gram panchayat, or district. This content is retrieved by our backend systems on a periodic basis and stored in our database for in-Platform display. It is not delivered via real-time API calls from your device. Justech does not claim ownership of such third-party content, which is displayed solely for community information purposes.

7.6 Government Information

The Platform disseminates publicly available information sourced from official government websites and portals, pertaining to schemes, metrics, programmes, and data relevant to your village or gram panchayat. Justech does not modify, editorially alter, or represent the accuracy of such content and is not liable for any inaccuracy, omission, or delay in government-sourced information.

8 Location Data

Location is intrinsic to the functioning of the Netoo Platform, as community membership, content visibility, and social interaction are all structured around geographic boundaries at the village and gram panchayat level. The following provisions apply to our collection and handling of location information:

• Permission-Based Access: GPS access is requested only at the time of location selection during onboarding or when you initiate a location update. We do not access your device's GPS in the background, while the application is not in active foreground use, or at any other time without your active initiation.
• Transient GPS Processing: Raw GPS coordinates are processed transiently on our servers only for the purpose of resolving your location to the appropriate administrative hierarchy (State → District → Sub-District → Gram Panchayat → Village). They are not stored as part of your permanent profile.
• Stored Location Affiliation: Your selected village or locality name is stored as your active Village Group affiliation. This information is visible to other Users within your group and constitutes personal location information under the SPDI Rules.
• Optional GPS: You are not obligated to grant GPS access. You may manually select your village or locality from the dropdown selector at any time. Denying GPS permission will not restrict your ability to register or use any other feature of the Platform.
• Changing Your Location: You may update your active location at any time through the Platform's settings. Doing so will transfer your membership from your current Village Group to the newly selected group.

9 Live Video Broadcasts

The Platform supports real-time live video broadcasting, enabling Registered Users to stream video to all members of their Village Group for up to four (4) minutes per session. We do not store any live broadcast videos on our platform at the end of the operation. The following provisions apply:

• Audience Visibility: A Live video broadcast can be started by any Registered user. They are transmitted through our servers and are available for viewing in real time to other registered users of your Village Group only.
• Content Responsibility: You are solely responsible for the content of your live broadcast. You should not broadcast content that reveals sensitive personal information, private residential locations, information about third parties without their consent, or any content that violates our Community Guidelines, Terms of Service, or applicable law.
• Technical Limitations: Justech does not warrant or guarantee the quality, availability, or uninterrupted delivery of the live video feature, which is subject to network connectivity, device capabilities, and server load at the time of broadcast.
• Moderation Rights: We reserve the right to terminate any live broadcast session, without prior notice, that we determine to be in violation of our Community Guidelines, Terms of Service, or applicable law.

10 AI & Synthetically Generated Content

In accordance with the IT Rules 2021 as amended by the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2026, which came into force on 20 February 2026, the following provisions apply to Synthetically Generated Information (SGI) on the Platform:

10.1 User Obligations Regarding SGI

By using the Platform, you are expressly informed and hereby warned that the creation, uploading, sharing, or distribution of Synthetically Generated Information — including AI-generated images, deepfake videos, cloned audio, or algorithmically manipulated audio-visual content — that is unlawful, misleading, defamatory, obscene, or otherwise in violation of the IT Act or any other applicable Indian law may attract civil and criminal penalties and punishment under applicable law.

10.2 Platform Action on SGI Violations

Upon receiving actual knowledge of SGI that violates applicable law or our Community Guidelines, Justech shall take expeditious and appropriate action within the timeframes mandated by the IT Rules 2021 as amended:

• Three (3) hours for the removal of unlawful SGI (deepfakes, manipulated audio-visual content) upon receipt of a lawful notice from a competent government authority
• Twenty-four (24) hours for content involving non-consensual intimate imagery, impersonation, or similar violations
• Thirty-six (36) hours for other categories of unlawful content upon receipt of a valid court order or authorised government notice

10.3 Labelling and Declaration

While Netoo does not currently provide built-in AI content generation tools, any User who shares content on the Platform that has been created or substantially modified using AI or algorithmic tools is encouraged to disclose this to their audience in good faith. We reserve the right to introduce SGI labelling mechanisms on the Platform in future versions, in compliance with the requirements of the IT Rules 2021 as amended.

11 Third-Party Services

The Platform integrates with the third-party services listed below. Each service provider operates under its own independent privacy policy and data practices, for which Justech accepts no responsibility.

We do not integrate with third-party advertising networks, behavioural analytics SDKs, data brokers, or tracking technologies. External social media content is retrieved by our backend systems only and does not involve real-time API calls from your device that could expose your information to third-party platforms.

12 Content Visibility, Expiry & Data Retention

This section addresses two distinct concepts: (a) Content visibility expiry — when content ceases to be visible to Users on the Platform; and (b) Data retention — how data is retained on our servers for operational and legal purposes after it is no longer visible. These are not the same thing and are described separately below.

12.1 Content Visibility Expiry

The Platform applies automatic visibility expiry to certain categories of User Content. Once the applicable period expires, content is no longer visible to any User on the Platform — including the author. Content that has expired from view is not necessarily deleted from our servers simultaneously; see Section 12.3 for data retention practices.

12.2 Village Group Isolation

All content on the Platform is strictly bounded to the Village Group in which it was created. The following rules apply:

• Village switching: A User may belong to only one Village Group at a time. When a User switches their active location to a different village or locality, they immediately lose visibility to all content from their previous Village Group. A user can switch back to an earlier village group and view content bound by the visibility expiry rules
• Content portability: No posts, broadcast messages, announcements, or private messages from a User's previous Village Group are transferred to or visible in their new Village Group.
• Private message history: Private messages sent to or by a User while they were a member of a different Village Group are not accessible after a location switch. Message history is tied to Village Group membership at the time of the conversation.
• Server-side records: Although inaccessible to the User after a village switch, prior content may be retained on our servers for operational and legal compliance purposes as described in Section 12.3.
• Premium Users: Certain Registered users can be marked as Premium users on the platform. This allows the user to send public messages which are broadcast at a higher administrative level than the Village group. This is applicable only to broadcast public messages so that the premium user's message reaches a wider audience of users belonging to multiple Village Groups within the administrative hierarchy. For eg a Premium user can send a public broadcast message at a Gram Panchayat level which will be visible to all users of all Village groups within that Gram Panchayat. Further, any individual Registered user can reply privately to that message and this private conversation can continue with the premium user as a response to the original public message sent by the Premium user.

12.3 Data Retention

We retain personal information and User Content on our servers for as long as necessary to fulfil operational purposes, comply with our legal obligations under the IT Act and IT Rules 2021, resolve disputes, and enforce our agreements. We do not apply fixed automatic deletion schedules to all categories of data at this time; however, data that is no longer required for any legitimate purpose is reviewed and removed periodically.

Please note that content you have shared publicly within your Village Group may have been viewed or saved by other Users prior to expiry, and Justech cannot guarantee the removal of such copies from third-party devices or systems.

13 Data Security

Justech implements commercially reasonable and industry-appropriate technical, organisational, and administrative safeguards to protect your personal information from unauthorised access, disclosure, alteration, destruction, or misuse.

13.1 Transport Security

All communication between your device and the Netoo servers is transmitted exclusively over encrypted connections using industry-standard secure transport protocols. This ensures that data in transit — including login credentials, messages, and profile information — is protected from interception. Unencrypted connections to the Platform are not permitted.

13.2 Authentication and Session Security

The Platform uses industry-standard token-based authentication to manage your session securely. Upon login, a cryptographically signed, time-limited token is issued to your device. This token must be presented with each subsequent authenticated request and is invalidated upon logout or session expiry, preventing unauthorised continued access.

13.3 Data Storage and Encryption

• Public posts, broadcast messages, and announcements: Stored without additional encryption beyond transport security, as these are publicly visible to all Village Group members including Guest Mode users by design. Encrypting publicly accessible content at the storage layer would provide no meaningful security benefit.
• Private messages (1:1 conversations): Private message content is encrypted at rest in our database. However, private messages are not end-to-end encrypted — Justech's systems can access message content where necessary for safety monitoring, legal compliance, and moderation. You are strongly advised not to share sensitive personal, financial, medical, legal, or commercially sensitive information through the private messaging feature.
• Account and profile data: Stored on our database.
• All above:All data is stored on our cloud-hosted database infrastructure, protected by our hosting provider's enterprise-grade physical and network security controls.

13.4 Platform Limits as Abuse Prevention Controls

• Device registration limit: We limit the number of accounts that may be registered from a single device to prevent mass account creation, spam, and abuse originating from a single source.
• Live video duration limit: Live video broadcasts are limited to a maximum of four (4) minutes per session, managing server resources and reducing the risk of sustained harmful content broadcasting.
• Village Group isolation: All content interaction is strictly bounded to a User's active Village Group. A User cannot access content from, or interact with members of, any other Village Group. This boundary prevents cross-community data exposure.
• Message attachment limits: Each message may contain a maximum of one (1) image, one (1) audio file, and one (1) video file, limiting the potential for unsolicited bulk content distribution.
• Premium user limits: A premium user's can choose to broadcast a messagee beyond their village group, but it is still bounded at the higher administrative location level, based on their premium membership. This is true for public messages only. Other registered users can respond privately to such a message and that conversation is bound between the two users only.

13.5 Infrastructure and Access Controls

• All Platform infrastructure is hosted on Amazon Web Services (AWS), which maintains internationally recognised security certifications and implements comprehensive physical, network, and system-level security controls
• Access to personal data within Justech is restricted on a strict need-to-know basis through role-based access controls
• Our technical and organisational security measures are periodically reviewed and updated
• Incident response procedures are maintained to identify, contain, and respond to security events in a timely manner

13.6 Limitations and Breach Notification

No method of electronic data storage or transmission is completely secure. Despite our safeguards, we cannot guarantee the absolute security of your information. In the event of a data security incident that is reasonably likely to result in risk or harm to your rights and interests, we will take immediate steps to contain the incident, notify affected Users through available communication channels, and report to relevant competent authorities as required under applicable Indian law.

14 Cross-Border Data Transfers

Your personal information is stored and processed on servers operated by Amazon Web Services. While Justech is an Indian entity and our primary operations are in India, and we have chosen AWS infrastructure within India, AWS infrastructure may involve data storage or processing in data centres located outside India. By using the Platform and consenting to this Policy, you acknowledge and consent to the transfer of your information to servers that may be located outside the territory of India, subject to the following safeguards:

• AWS is contractually bound to implement data protection standards consistent with applicable Indian law and industry best practices. AWS's data protection practices are available at aws.amazon.com/compliance.
• We take reasonable steps to ensure that any cross-border transfer of your data is subject to appropriate contractual protections commensurate with the requirements of the SPDI Rules.
• Push notification services may similarly involve processing of notification tokens outside India. This processing is limited to the delivery of notifications and message titles, and does not involve transfer of your profile or message content.

15 Your Rights

As a User of the Platform, you have the following rights with respect to your personal information, subject to applicable Indian law and any overriding legal obligations of Justech:

15.1 Right to Access and Review

Pursuant to Section 5(6) of the SPDI Rules, you have the right to review the personal information we hold about you and to request a copy of such information. You may access and review most of your profile information directly within the Platform's account settings.

15.2 Right to Correction

If any personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request its correction. You may update most information directly within the Platform, or by writing to us at the contact details in Section 20.

15.3 Right to Withdraw Consent

Pursuant to Section 5(7) of the SPDI Rules, you have the right to withdraw your consent to the collection, use, or processing of your personal information at any time by notifying us in writing. Please note that withdrawal of consent may result in your inability to access certain features of the Platform or, in some cases, the Platform as a whole. Withdrawal of consent does not affect the lawfulness of any processing conducted prior to the withdrawal, nor does it override our obligations under applicable law.

15.4 Right to Account Deletion

You may request the deletion of your account and associated personal data by writing to us at contactus@netoo.in with the subject line "Account Deletion Request". We will process your request and confirm deletion within a reasonable timeframe, subject to our data retention obligations under applicable law as described in Section 12.

15.5 Right to Opt Out of Notifications

You may withdraw permission for push notifications at any time through your Android device settings (Settings → Apps → Netoo → Notifications). This will not affect your ability to use other features of the Platform.

15.6 Right to Grievance Redressal

If you believe that your rights under this Policy or applicable Indian law have been violated, or if you have any complaint regarding the processing of your personal information or any content on the Platform, you may file a complaint with our Grievance Officer as described in Section 19.

15.7 Exercising Your Rights

To exercise any of the above rights, please contact us using the information in Section 20 or through the Grievance Officer as set out in Section 19. We will respond to valid requests within a reasonable timeframe and in any event within 15 days of receipt, except where shorter timelines are mandated by applicable law.

16 Children's Privacy

The Platform is intended exclusively for use by individuals who are eighteen (18) years of age or older. The interactive features of the Platform — including private messaging between community members, live video broadcasting, and the public contacts directory — are designed for adult engagement in community communication and are not appropriate for minors.

By completing the registration process and checking the age confirmation box, you represent and warrant to Justech that you are at least 18 years of age. If you are registering on behalf of a minor, or if you permit a minor to use your account, you do so at your own risk and assume full responsibility for any consequences arising therefrom.

Justech does not knowingly solicit or collect personal information from individuals below the age of 18. If a parent, guardian, or any person has reason to believe that a minor has registered on the Platform or has provided personal information without appropriate authorisation, they are requested to contact us immediately at contactus@netoo.in or through the Grievance Officer. Upon verification of such a report, we will promptly investigate and, where confirmed, take appropriate action including the deletion of the relevant account and associated data.

We reserve the right to immediately suspend or terminate any account that we have reasonable grounds to believe is registered by or operated by an individual below the age of 18.

17 Platform Conduct & Content Moderation

17.1 Intermediary Status and Safe Harbour

Justech operates the Platform as an intermediary within the meaning of Section 2(1)(w) of the IT Act and Rule 2 of the IT Rules 2021. As an intermediary, Justech does not exercise editorial control over User Content and is not the author, publisher, or owner of any content posted by Users on the Platform. Our liability in respect of User Content is governed by and limited to the extent permitted under Section 79 of the IT Act, subject to our compliance with the due diligence obligations under the IT Rules 2021.

17.2 Due Diligence Obligations

In order to maintain our safe harbour protection and comply with our legal obligations as an intermediary, we observe the following due diligence measures:

• Publication and enforcement of Terms of Service and Community Guidelines informing Users of prohibited content categories under applicable Indian law
• Maintenance of a Grievance Redressal Mechanism as described in Section 19
• Preservation and, where required by lawful authority, disclosure of User records for a minimum period of six (6) months
• Cooperative assistance to law enforcement agencies as required under applicable law
• Periodic notification to Users (at least once every three months) that violation of platform rules may result in account suspension or termination

17.3 Prohibited Content

Users are informed that the Platform must not be used to host, display, upload, modify, publish, transmit, store, or share information that:

• Belongs to another person to which the User does not have any right
• Is defamatory, obscene, pornographic, paedophilic, invasive of another's privacy including bodily privacy, or harassing on the basis of gender
• Is racially or ethnically objectionable, or promotes hatred, discrimination, or violence against any person or group
• Threatens the unity, integrity, defence, security, or sovereignty of India, or incites the commission of any cognisable offence
• Contains or constitutes unlawful Synthetically Generated Information, including deepfakes
• Constitutes or facilitates child sexual abuse material (CSAM) or any content prohibited under POCSO
• Deceives or misleads the addressee about the origin of a message, or communicates knowingly false or misleading information perceived as fact
• Otherwise violates any law for the time being in force in India

Violation of these prohibitions may result in immediate account suspension or termination, and may be reported to appropriate law enforcement authorities.

18 Changes to This Policy

We may revise this Privacy Policy periodically to reflect changes in our data practices, Platform features, regulatory requirements, or for other legitimate operational reasons. We are committed to transparency and will notify you of material changes in the following manner:

• Updating the "Last Updated" date and, where the change is material, the version number at the top of this Policy
• Notifying Registered Users via in-app notification or push notification prior to or upon the effective date of the material change
• Posting the updated Policy at netoo.in/privacy-policy, where all prior versions will be archived

Where a proposed change materially and adversely affects your rights under this Policy, we will seek your explicit consent before applying the change to your continued use of the Platform. Your continued use of the Platform following the effective date of any revised Policy, where no explicit consent is required, shall constitute your acceptance of the changes.

You may always access the current version at netoo.in/privacy-policy.

19 Grievance Officer & Reporting Mechanism

In accordance with Rule 3(2) of the IT Rules 2021 and Section 5(9) of the SPDI Rules, Justech Computing Private Limited maintains a Grievance Redressal Mechanism through which Users and affected persons may raise complaints regarding the Platform, its content, or the handling of their personal information. Complaints may be submitted either through the in-app reporting feature described in Section 7.3, or directly to the Grievance Officer by email or post as described below. Both routes are treated as formal complaints under the IT Rules 2021.

19.1 How to Submit a Complaint

• In-App Reporting: Use the Report option available on any post, announcement, private message, live video, feed item, or user profile within the Platform. Upon submission, you will receive an immediate on-screen confirmation that your report has been received. This constitutes acknowledgement of your complaint for the purposes of the IT Rules 2021. In-app reports are routed directly to our moderation team and logged in our backend systems.
• Email or Post to Grievance Officer: For complaints relating to privacy, data handling, or account matters, please write to the Grievance Officer at the contact details above. To enable efficient resolution, please include: your name and registered username; a description of the grievance; the specific content or account concerned, with a screenshot or URL where applicable; and the relief or action you are seeking.

19.2 How Reports Are Processed

• Reports are stored in our backend systems and reviewed by our moderation team
• Based on the nature of the report, our team may hide or remove the reported content, issue a warning to the reported User, temporarily suspend the reported account, or permanently ban the reported account
• Moderation decisions are recorded in our moderation log for audit and compliance purposes
• Where a moderation action is taken against your content or account, we will endeavour to inform you of the action and the reason, where notification is not prohibited by law
• You may dispute a moderation decision by writing to the Grievance Officer

19.3 Resolution Timelines

• Acknowledgement: In-app reports are acknowledged immediately upon submission through an on-screen confirmation. Email complaints to the Grievance Officer are acknowledged within twenty-four (24) hours of receipt.
• General complaints: Resolved and communicated to the complainant within fifteen (15) days of receipt, in accordance with Rule 3(2) of the IT Rules 2021.
• Non-consensual intimate imagery, impersonation, content depicting sexual violence or terrorism: Appropriate action taken within twenty-four (24) hours of receipt of a valid complaint.
• Unlawful Synthetically Generated Information (deepfakes): Appropriate action taken within three (3) hours of receiving actual knowledge through a valid lawful notice, per the IT Rules Amendment 2026.
• Other unlawful content subject to court order or government notice: Action within thirty-six (36) hours of receipt of a valid lawful notice from a competent authority.

19.4 Limitations

Justech is not obligated to act on complaints that are frivolous, vexatious, repetitive, made in bad faith, or that do not relate to a genuine violation of our Terms of Service, Community Guidelines, or applicable law. We reserve the right to decline to process complaints that fall into these categories, with notice to the complainant where practicable.