Statement of Compliance

Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021

1. SubNub Technologies Pvt. Ltd. (STPL) is a company registered under the Companies Act, 2013 (CIN U80903OR2020PTC034017) and has its registered office at Plot No. 331/1943-B, Road No.6, Aurobindo Nagar, Chandrasekharpur, Bhubaneswar, Odisha, 751016, India.STPL operates SubNub App (for iOS & Android), a social networking platform and the website SubNub App Website

2. Significant Social Media Intermediary

   STPL is a Significant Social Media Intermediary and has implemented policies and procedures to comply with the requirements of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (hereinafter the “Rules”).

3. Due Diligence

   1. STPL’s Privacy Policy, Terms & Conditions of Use and Community Guidelines (collectively “SubNub Policies”) are available on its website as well as within the SubNub App. STPL will inform users of any changes in the SubNub Policies at least once in a calendar year.
   2. In addition to other requirements prescribed by the Rules, SubNub Policies specifically prohibit users from publishing content that is
      1. invasive of another’s bodily privacy or harmful or harassing on the basis of gender especially children; or
      2. Is patently false or misleading but appearing as a fact; or
      3. Impersonates or deceives or is false with the intention of causing injury or wrongful loss or harassment, wrongful gain or fraud; or
      4. Threatens the unity, integrity, defence, security or sovereignty of India, or
      5. Violates any law. SubNub will endeavour to deploy technology-based measures, including automated tools or other mechanisms to proactively identify content which falls within the above categories and others.
   3. Orders by a court of competent jurisdiction or Appropriate Government or its agency or takedown or any other purposes should be addressed for compliance to the Resident Grievance Officer with a copy to Nodal Contact Officer and Chief Compliance Officer (contact details below).
   4. On receipt of a written request for information from a lawfully authorized government agency clearly stating the purpose for which it is required, STPL shall provide such information or assistance in its control or possession to the government authority within 72 hours.
   5. In compliance with the Rules, registration information from a user and/or information which has been removed or to which access has been disabled, shall be retained by STPL for a period of 180 days from the date of cancellation or withdrawal or removal or disablement.

4. Additional Due Diligence

   1. The physical contact address of STPL for the purposes of receiving communication addressed to it under the Rules is Plot No. 331/1943-B, Road No.6, Aurobindo Nagar, Chandrasekharpur, Bhubaneswar, Odisha, 751016, India.

   2. STPL has implemented the following mechanism for dealing with grievances:(i) Grievances relating to violation of the Rules must be addressed to the Resident Grievance Officer at redressal@subnub.com with a copy to the Chief Compliance Officer at compliance.officer@subnub.com. The complaint must contain such information as is necessary in order for STPL to investigate and take action.(ii) Reported grievances will be acknowledged within 24 hours of receipt along with a unique identification number. Grievances will be disposed of within 15 days from date of receipt. Wherever practical, information on action taken or not taken by STPL may be provided to the reporter of the grievance.(iii) Grievances by an individual relating to exposure of their private areas, full or partial nudity or depicting such individual in any sexual act or conduct; or impersonation in an electronic form, including artificially morphed images will be acted upon within 24 hours.(iv) A monthly compliance report containing information as specified by the Rules will be published on the website under the link Compliance.

   3. Users may opt for voluntary verification of accounts using an active Indian phone number. All such requests may be sent to redressal@subnub.com or raised within the SubNub App. A visual identifier will be shown against the profiles of users who have voluntarily verified themselves.

   4. Publishers (as defined under the Rules) of news and current affairs content should take note of the information statement in compliance with the Rules can be found under the link Compliance. On confirmation by such publishers of compliance with the Rules, SubNub will display a visible verification mark against their profiles

   5. STPL also displays a visible verification mark on content that is advertising or sponsored or is exclusively controlled.

   6. STPL has appointed Indian residents to ensure compliance with the Rules:

      Chief Compliance Officer for ensuring compliance with the Information Technology Act, 2000 and Rules.

      Email: compliance.officer@subnub.com

      Nodal Contact Officer for 24x7 coordination with law enforcement agencies and officers to ensure compliance to their orders or requisitions made in accordance with the provisions of law or rules made there under email: nodal.officer@subnub.com

      Resident Grievance Officer to

      1. Acknowledge a complaint in relation to the Rules within 24 hours and dispose off such complaint within a fifteen days from the date of its receipt; and

      2. Receive and acknowledge any order, notice or direction issued by the Appropriate Government, any competent authority or a court of competent jurisdiction.

         Name: Mr. Asit Mohanty

         Email: redressal@subnub.com

Compliance Statement for Publishers of News and Current Affairs Content

This Compliance Statement is with reference to Rule 5 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (hereinafter "Rules") and applies to Publishers of News and Current Affairs Content (as defined under the Rules). Please note that according to the Rules, if you are a Publisher of News and Current Affairs Content, then in addition to the common terms of service for all users, you are required to furnish the details of user accounts on the services of intermediaries to the relevant ministry prescribed under Rule 18. If you have already done so please inform SubNub by sending a mail to redressal@subnub.com and we will provide a demonstrable and visible mark of verification as being Publishers against your profile. Thank you.