Grievance Redressal Policy

1 Purpose & Legal Mandate

1.1. BrainBit Infotech Private Limited ("Company", "We", "Us") is committed to providing a transparent, accessible, and effective grievance redressal mechanism for all users of the BrainBit-SOMS platform ("Platform").

1.2. This Grievance Redressal Policy ("Policy") is published in compliance with:

• Section 79 of the Information Technology Act, 2000 - Due diligence obligations of intermediaries
• Rule 3(11) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 - Requirement to appoint a Grievance Officer and publish contact details prominently
• Section 13 of the Digital Personal Data Protection Act, 2023 - Right of the Data Principal to have an accessible and effective means of grievance redressal against a Data Fiduciary
• Consumer Protection Act, 2019 - Rights of consumers to seek redressal for deficiency in services
• Consumer Protection (E-Commerce) Rules, 2020 - Obligations of e-commerce entities regarding grievance redressal

1.3. The Company is committed to resolving all grievances in a fair, impartial, transparent, and time-bound manner, ensuring that no user is disadvantaged or denied their rights under applicable Indian law.

1.4. This Policy applies to all interactions with the Platform, including but not limited to usage of the web application, parent and student portals, payment processing, data handling, communications, and customer support.

2 Grievance Officer Details

2.1. The Grievance Officer shall acknowledge all grievances within the timelines specified in this Policy and ensure that grievances are resolved in accordance with applicable law.

2.2. In the event the designated Grievance Officer is unavailable due to leave, transfer, or any other reason, the Company shall ensure that an alternate officer is designated and the updated details are published on this page within 24 hours.

2.3. The name of the Grievance Officer may be updated from time to time at the discretion of the Company. Any change shall be reflected on this page.

3 Who Can File a Grievance

3.1. Any of the following persons may file a grievance under this Policy:

• Institute Administrators - Principals, directors, or any authorized personnel of subscribing educational institutions
• Teachers and Staff - Teaching and non-teaching staff whose data is processed through the Platform
• Parents and Guardians - Parents or lawful guardians accessing the Parent Portal or whose data is processed by the Platform
• Students - Students accessing the Student Portal or whose data is processed by the Platform (through their parent/guardian if minor)
• Website Visitors - Any person visiting the BrainBit-SOMS website or interacting with our online services
• Any Affected Person - Any person who is affected by content hosted on, data processed by, or services provided through the Platform
• Data Principals - Any individual whose personal data is processed by the Company, exercising their rights under the DPDP Act, 2023

3.2. Grievances may be filed on behalf of a minor (below 18 years) by their parent or lawful guardian, in compliance with Section 9 of the DPDP Act, 2023.

4 Types of Grievances Handled

4.1. The following categories of grievances are handled under this Policy:

Category	Description	Examples
Data Privacy	Complaints related to personal data handling	Personal data misuse, unauthorized data sharing, data breach concerns, consent-related issues, data access/correction/erasure requests
Service-Related	Issues with Platform functionality	Platform malfunction, feature not working as expected, performance degradation, downtime beyond SLA commitments
Payment & Refund	Disputes related to financial transactions	Failed payment not reversed, incorrect charges, refund not processed, double deduction, missing payment receipt
Account-Related	Issues with user account access	Unauthorized access to account, account lockout, inability to reset password, role/permission issues
Content-Related	Complaints about content on the Platform	Objectionable content uploaded by another user, incorrect information displayed, defamatory content
Billing & Subscription	Disputes related to billing	Incorrect invoice amount, GST-related concerns, auto-renewal disputes, plan downgrade/upgrade issues
Communication	Issues with Platform communications	Unsolicited SMS/Email/WhatsApp messages, inability to opt out, communication preferences not respected
Other	Any other user concern	Any grievance not covered above that relates to the Platform or the Company's services

5 How to File a Grievance

5.1. A grievance may be filed through any of the following channels:

5.1.1. Email (Preferred Method)

Send a detailed email to the Grievance Officer at grievance@brainbitinfotech.com. Your email should include the following information:

• Full Name of the complainant
• Contact Details - Email address, phone number
• Institute Name (if applicable) - The name of the educational institution associated with the grievance
• User Role - Administrator, Teacher, Staff, Parent, Student, or Other
• Detailed Description of the grievance, including dates, times, and relevant context
• Supporting Documents - Screenshots, transaction IDs, error messages, or any other evidence relevant to the complaint
• Expected Resolution - What outcome the complainant seeks
• Previous Communication (if any) - Reference numbers of any prior tickets or correspondence related to the same issue

5.1.2. Phone

Call the Grievance Officer at +91 99343 14471 during working hours (Monday to Saturday, 10:00 AM to 6:00 PM IST). The support representative will record the details of your grievance and provide a reference number.

5.1.3. Written Letter

A formal written grievance may be sent by post or courier to:

5.2. Upon filing, the complainant will receive:

• A unique Grievance Ticket ID for tracking purposes
• An acknowledgment email/SMS confirming receipt of the grievance
• The name and contact details of the assigned support representative

6 Grievance Resolution Timeline

Stage	Timeline	Details
Acknowledgment of Receipt	Within 24 hours	Acknowledgment email/SMS with unique Grievance Ticket ID. For grievances received on weekends or public holidays, acknowledgment shall be sent within 48 hours.
Ticket Assignment	Within 1 business day	Grievance assigned to the appropriate team/representative based on the category. Complainant notified of the assigned person.
Initial Assessment	Within 3 business days	Preliminary review of the grievance, collection of relevant information. Complainant may be contacted for additional details if required.
Resolution / Action Taken	Within 15 days of receipt	As mandated by Rule 3(2) of IT (Intermediary Guidelines) Rules, 2021. The Grievance Officer shall communicate the resolution or action taken to the complainant.
Complex Cases (Extended)	Maximum 30 days	For grievances requiring detailed investigation or involving multiple parties, the timeline may be extended to 30 days. An interim communication shall be sent at the 15-day mark with the status update and reason for extension.
Appeal Response	Within 15 days of appeal	If the complainant is dissatisfied with the resolution at any level and escalates/appeals, the response to the appeal shall be provided within 15 days.

6.1. If the Company is unable to resolve the grievance within the prescribed timeline, the complainant shall be informed in writing of the reasons for the delay and the expected timeline for resolution.

6.2. For grievances specifically related to content takedown requests under IT Rules 2021, the Company shall act upon such complaints within 36 hours of receipt where the complaint relates to content showing individuals in full or partial nudity, or in a sexual act, or is impersonating such individuals (Rule 3(2)(b)).

7 Grievance Resolution Process

7.1. All grievances are resolved through a structured, multi-level process to ensure fairness and thoroughness:

Level 1: Customer Support Team (1-3 Business Days)

• Grievance is received and logged in the system with a unique Ticket ID
• Assigned to the Customer Support Team for initial review
• The support team investigates the issue, communicates with the complainant, and attempts resolution
• Common issues such as password resets, minor technical glitches, and billing clarifications are typically resolved at this level
• Resolution communicated to the complainant via email

Level 2: Grievance Officer (3-7 Business Days)

• If the complainant is not satisfied with the Level 1 resolution, or if the issue is complex, it is escalated to the Grievance Officer
• The Grievance Officer conducts a detailed review of the grievance, including examination of system logs, transaction records, and relevant policies
• The Grievance Officer may schedule a call or meeting with the complainant for clarification
• Issues such as data privacy complaints, payment disputes, and account security concerns are handled at this level
• A written resolution with reasons is communicated to the complainant

Level 3: Management / Director (7-15 Business Days)

• If the complainant remains dissatisfied after Level 2 resolution, the grievance is escalated to the Company's Management / Director
• A comprehensive review of the grievance and all prior resolutions is undertaken
• The Director may consult legal advisors for grievances involving regulatory compliance, data protection, or contractual disputes
• A final decision is made and communicated in writing to the complainant
• This constitutes the final level of internal grievance redressal

8 Escalation Matrix

8.1. The following table provides the escalation matrix for grievance resolution:

Level	Authority	Contact	Maximum Resolution Time
Level 1	Customer Support Team	info@brainbitinfotech.com +91 99343 14471	3 business days
Level 2	Grievance Officer	grievance@brainbitinfotech.com +91 99343 14471	7 business days
Level 3	Director / Management	director@brainbitinfotech.com	15 business days

8.2. To escalate a grievance, the complainant must reference the original Grievance Ticket ID and clearly state the reason for dissatisfaction with the previous resolution.

8.3. Escalation to a higher level is permissible only after the resolution at the current level has been communicated, or if the prescribed timeline for the current level has elapsed without communication.

9 External Escalation

9.1. If the complainant has exhausted all internal grievance redressal mechanisms (Levels 1, 2, and 3) and remains dissatisfied with the resolution, they may approach the following external authorities:

9.1.1. Data Protection Board of India (DPDP Act Complaints)

9.1.2. Consumer Disputes Redressal Commission (Consumer Protection Act, 2019)

Under the Consumer Protection Act, 2019, the complainant may approach the appropriate Consumer Disputes Redressal Commission based on the value of the goods/services and the compensation claimed:

Forum	Jurisdiction (Value of Claim)	Applicable Section
District Consumer Disputes Redressal Commission	Up to Rs. 1 Crore	Section 34, Consumer Protection Act, 2019
State Consumer Disputes Redressal Commission	Rs. 1 Crore to Rs. 10 Crore	Section 47, Consumer Protection Act, 2019
National Consumer Disputes Redressal Commission	Above Rs. 10 Crore	Section 58, Consumer Protection Act, 2019

9.1.3. Cyber Crime Cell / CERT-In

For complaints related to cyber security incidents, unauthorized access, hacking, or data theft:

• Indian Computer Emergency Response Team (CERT-In) - www.cert-in.org.in
• National Cyber Crime Reporting Portal - cybercrime.gov.in
• Local Cyber Crime Police Station / Cyber Crime Cell

9.1.4. National Consumer Helpline

9.2. Jurisdiction: For any legal proceedings arising out of a grievance, the courts of competent jurisdiction at Ranchi, Jharkhand, India shall have exclusive jurisdiction, subject to the dispute resolution mechanism outlined in our Terms of Service.

10 Data Principal Grievances (DPDP Act Specific)

10.1. In addition to the general grievance categories, the following data protection-specific grievances receive special handling under this Policy:

10.1.1. Right to Access (Section 11, DPDP Act)

Requests from Data Principals to obtain a summary of their personal data being processed and the processing activities undertaken by the Company.

10.1.2. Right to Correction and Erasure (Section 12, DPDP Act)

Requests to correct inaccurate personal data, complete incomplete data, update outdated data, or erase personal data that is no longer necessary for the purpose for which it was collected.

10.1.3. Consent Withdrawal (Section 6(4), DPDP Act)

Requests to withdraw previously given consent for personal data processing. The ease of withdrawing consent shall be comparable to the ease with which consent was given.

10.1.4. Objection to Processing

Objections raised by Data Principals regarding the processing of their personal data, including objections to specific purposes of processing.

10.1.5. Right to Nominate (Section 14, DPDP Act)

Requests to register a nominee who may exercise the Data Principal's rights in the event of death or incapacity.

10.2. To file a data protection-specific grievance, please email grievance@brainbitinfotech.com with the subject line: "DPDP ACT - [Nature of Request]" (e.g., "DPDP ACT - Request for Data Erasure").

10.3. For verification purposes, the Company may request proof of identity before processing data protection requests. Such verification shall be proportionate and not unduly burdensome on the Data Principal.

11 Confidentiality

11.1. All grievances filed under this Policy shall be treated with the utmost confidentiality. Details of the grievance shall be disclosed only to personnel directly involved in the resolution process.

11.2. The Company shall not disclose the identity of the complainant to any third party without the complainant's express consent, except where required by law, regulation, or court order.

11.3. No Retaliation: The Company strictly prohibits any form of retaliation, discrimination, or adverse action against any person who files a grievance in good faith under this Policy. Any employee or agent of the Company found to have engaged in retaliatory conduct shall be subject to disciplinary action.

11.4. Good Faith Requirement: Grievances must be filed in good faith and based on genuine concerns. The Company reserves the right to dismiss frivolous, vexatious, or malicious complaints after providing the complainant an opportunity to substantiate their claim.

11.5. The Company shall implement appropriate technical and organizational measures to protect the confidentiality of grievance records, including access controls and encryption where applicable.

12 Record-Keeping

12.1. All grievances received under this Policy shall be logged in a centralized grievance register with the following details:

• Unique Grievance Ticket ID
• Date and time of receipt
• Name and contact details of the complainant
• Category and nature of the grievance
• Supporting documents submitted
• Assigned personnel and escalation history
• Actions taken at each level
• Resolution provided and date of closure
• Feedback from the complainant (if any)

12.2. Retention Period: Grievance records shall be maintained for a minimum period of 2 (two) years from the date of resolution, as required under the IT (Intermediary Guidelines) Rules, 2021.

12.3. For grievances related to data protection under the DPDP Act, 2023, records shall be maintained for a period as prescribed by the Data Protection Board of India or, in the absence of such prescription, for a minimum of 3 (three) years.

12.4. The Company shall maintain monthly reports of grievances received, resolved, and pending, which may be furnished to regulatory authorities upon request.

13 Policy Review

13.1. This Grievance Redressal Policy shall be reviewed and updated on a quarterly basis (every 3 months) by the Grievance Officer in consultation with the Company's management and legal advisors.

13.2. The Policy shall also be reviewed and updated promptly upon:

• Enactment of new legislation or amendment of existing laws that affect grievance redressal obligations
• Issuance of rules, regulations, or directions by the Data Protection Board of India, CERT-In, or any other regulatory authority
• Significant changes to the Company's services, business model, or organizational structure
• Judicial pronouncements or orders that impact the Company's grievance redressal obligations
• Feedback from users or regulatory audits that identify areas for improvement

13.3. All material changes to this Policy shall be communicated to registered users via email and in-app notification. The updated "Last Updated" date on this page shall reflect the date of the most recent revision.

13.4. The Company shall periodically analyze grievance data to identify systemic issues and implement proactive measures to reduce grievances and improve service quality.

14 Contact Information