Grievance Redressal Policy

1. Introduction

1.1 Purpose of this Policy

This Grievance Redressal Policy (“Policy”) establishes the framework adopted by Setura Mobility Private Limited (“SetuRa”, “Company”, “we”, “us” or “our”) for receiving, acknowledging, assessing, investigating, resolving and closing grievances, complaints, concerns and service-related representations submitted by users, customers, visitors, business partners and other stakeholders in connection with SetuRa’s website, digital platforms, products, services and business operations.

The objective of this Policy is to provide a structured, transparent, accessible and accountable mechanism through which legitimate grievances may be raised and addressed in a fair and timely manner, while maintaining appropriate standards of confidentiality, information security, procedural fairness and regulatory compliance.

1.2 Commitment to Stakeholders

SetuRa is committed to maintaining a high standard of customer and stakeholder experience. The Company recognises that an effective grievance-redressal mechanism is an important component of responsible business conduct, consumer protection, data governance, operational accountability and trust.

SetuRa accordingly seeks to ensure that grievances are considered objectively and handled through an appropriate internal escalation framework without prejudice to any statutory, contractual or other rights or remedies available to the complainant under applicable law.

1.3 Scope of the Policy

This Policy applies to grievances relating to SetuRa’s website, digital interfaces, products, services, transactions, communications, customer support, privacy and personal-data practices, payments, refunds, cancellations, representations, service quality, technology- related issues and other matters falling within SetuRa’s responsibility.

Where a matter is governed by a specific contractual arrangement, statutory mechanism, sector-specific framework or dedicated policy, such framework may operate in conjunction with, or take precedence over, this Policy to the extent required by applicable law.

2. Definitions and Interpretation

2.1 “Complainant”

“Complainant” means any individual or legal entity who submits a grievance or complaint to SetuRa concerning an act, omission, service, transaction, representation, process or other matter relating to SetuRa.

2.2 “Grievance”

“Grievance” means a genuine complaint, concern, dissatisfaction, representation or request for redress arising from or relating to SetuRa’s products, services, systems, transactions, personnel, processes, data practices or other activities within the Company’s responsibility.

2.3 “Grievance Officer”

“Grievance Officer” means the person designated by SetuRa to receive, coordinate, investigate and oversee the resolution of grievances under this Policy and applicable law.

2.4 “Personal Data”

“Personal Data” shall have the meaning assigned to it under applicable data-protection law and, where applicable, the Digital Personal Data Protection Act, 2023 and rules made thereunder.

2.5 Interpretation

The headings contained in this Policy are for convenience and shall not affect its interpretation. References to applicable law shall include amendments, modifications, re- enactments, subordinate legislation, rules, regulations, notifications, directions and governmental requirements applicable from time to time.

3. Principles Governing Grievance Redressal

3.1 Accessibility

SetuRa shall endeavour to maintain grievance channels that are reasonably accessible and capable of being used by customers and other stakeholders without unnecessary procedural complexity.

3.2 Fair and Objective Consideration

Every legitimate grievance shall be considered objectively, based on the information and records reasonably available to SetuRa. The Company shall endeavour to avoid arbitrary or discriminatory treatment in the handling of grievances.

3.3 Timely Resolution

SetuRa shall endeavour to acknowledge and address grievances within reasonable and legally prescribed timelines, having regard to the nature, complexity and urgency of the matter.

Where additional time is reasonably required for investigation, the Complainant may be informed of the status of the grievance and, where appropriate, the anticipated timeframe for further response.

3.4 Confidentiality

SetuRa shall seek to maintain appropriate confidentiality in relation to grievances and the information submitted in connection with them, subject to disclosures required for investigation, service delivery, legal compliance, regulatory requirements, dispute resolution, fraud prevention or protection of the rights and interests of SetuRa and other persons.

3.5 Non-Retaliation

SetuRa shall not ordinarily subject a Complainant to adverse treatment merely because the Complainant has raised a genuine grievance in good faith.

This principle shall not prevent SetuRa from taking appropriate action in cases involving fraud, impersonation, abuse of grievance mechanisms, knowingly false information, threats, unlawful conduct or other prohibited activity.

4. Types of Grievances

4.1 Customer and Service Grievances

Customers may submit grievances concerning the quality, availability, performance or delivery of SetuRa’s products or services, including concerns relating to customer support, service commitments, bookings, transactions or operational processes, as applicable.

4.2 Payment, Billing, Cancellation and Refund Grievances

Grievances relating to payments, invoices, billing discrepancies, cancellations, refunds, failed transactions, duplicate charges or other financial aspects of a transaction may be submitted through the designated grievance channels.

Such matters shall also be considered in accordance with SetuRa’s applicable Refund Policy, Cancellation Policy, Terms and Conditions and other contractual documents.

4.3 Privacy and Personal-Data Grievances

Individuals may raise concerns relating to the collection, processing, use, disclosure, retention, security or handling of their personal data by SetuRa.

Where applicable, such grievances shall also be handled in accordance with SetuRa’s Privacy Policy and the rights and obligations prescribed under applicable data-protection law.

The Digital Personal Data Protection Act, 2023 recognises a Data Principal’s right to a readily available means of grievance redressal concerning obligations relating to personal data and the exercise of statutory rights.

4.4 Website and Technology Grievances

Users may report concerns relating to website accessibility, account functionality, technical errors, unauthorised access concerns, security incidents or other technology-related issues associated with SetuRa’s digital environment.

4.5 Misrepresentation and Consumer-Related Grievances

Complaints concerning misleading representations, inaccurate information, unfair practices, deficient services or other consumer-related concerns may be submitted for review in accordance with applicable consumer-protection legislation.

Where SetuRa operates within the scope of the Consumer Protection (E-Commerce) Rules, 2020, the Company shall maintain grievance arrangements consistent with the requirements applicable to its business model. The Rules apply to specified forms of e-commerce involving goods and services offered through digital or electronic networks.

5. Grievance Officer

5.1 Designation of Grievance Officer

SetuRa shall designate an appropriate individual as its Grievance Officer for purposes of administering this Policy and, where applicable, satisfying statutory or regulatory requirements.

The identity and contact details of the Grievance Officer shall be displayed or otherwise made available through the appropriate SetuRa platform or communication channel to the extent required by applicable law.

5.2 Responsibilities of the Grievance Officer

The Grievance Officer shall be responsible for overseeing the grievance-redressal framework, receiving or coordinating receipt of grievances, maintaining appropriate records, facilitating internal investigation, coordinating with relevant business and technology teams, communicating material updates where appropriate and ensuring that grievances are dealt with in accordance with this Policy and applicable law.

5.3 Independence of Review

Where the nature of a grievance reasonably warrants independent or elevated review, SetuRa may refer the matter to an appropriate senior officer, legal or compliance function, management committee or other designated authority.

6. Submission of Grievances

6.1 Available Grievance Channel

A grievance may be submitted to SetuRa through the following designated channel:

Grievance Officer: Compliance Team
Email: compliance@seturamobility.com
Website: https://seturamobility.com/

6.2 Information to be Provided

A Complainant should provide sufficient information to enable SetuRa to understand and investigate the grievance, including, where relevant, the Complainant’s name and contact details, transaction or booking reference, relevant dates, nature of the grievance, supporting documents and the specific relief or resolution being sought.

SetuRa may request additional information where reasonably necessary to verify the grievance or conduct an appropriate investigation.

6.3 Anonymous Complaints

SetuRa may consider anonymous complaints where the information provided is sufficiently specific and credible to permit meaningful investigation.

However, SetuRa may be unable to provide an individual response where the identity or contact details of the Complainant are unavailable.

7. Acknowledgement and Registration

7.1 Acknowledgement

Upon receipt of a grievance through an appropriate channel, SetuRa shall endeavour to acknowledge receipt within a reasonable period and, where appropriate, provide a reference number or other identifier for subsequent correspondence.

7.2 Grievance Record

SetuRa may maintain an internal record of grievances for purposes of investigation, resolution, audit, quality improvement, regulatory compliance and governance.

7.3 Verification

Where necessary, SetuRa may undertake reasonable verification of the identity, transaction, account or relationship of the Complainant before providing information or taking action.

Such verification shall be proportionate to the nature and sensitivity of the grievance.

8. Grievance Assessment and Investigation

8.1 Preliminary Assessment

Upon receipt of a grievance, SetuRa may conduct a preliminary assessment to determine the nature of the issue, the relevant business function, the applicable policy or contractual terms and the appropriate investigation or escalation pathway.

8.2 Internal Investigation

Where required, the grievance may be referred to relevant personnel or functions including customer support, operations, finance, technology, information security, legal, compliance or senior management.

The scope of investigation shall depend upon the nature and seriousness of the grievance.

8.3 Supporting Information

SetuRa may review relevant records, communications, transaction information, system logs, contractual documents and other information reasonably required to assess the grievance, subject to applicable law and confidentiality obligations.

8.4 Third-Party Dependencies

Where a grievance involves a third-party service provider, payment processor, technology provider, business partner or other external party, SetuRa may coordinate with such party to investigate and resolve the matter.

The involvement of a third party shall not, by itself, prevent SetuRa from communicating an appropriate response to the Complainant.

9. Resolution of Grievances

9.1 Resolution Assessment

Following appropriate review, SetuRa shall determine the action reasonably available in relation to the grievance, having regard to the facts established, applicable contractual terms, Company policies, applicable law and the nature of the relief sought.

9.2 Corrective Measures

Where appropriate, corrective measures may include clarification, rectification of an operational error, service correction, account-related action, refund or adjustment where contractually or legally applicable, technical remediation, process correction or other appropriate remedial measures.

9.3 Communication of Resolution

SetuRa shall endeavour to communicate the outcome of the grievance to the Complainant through the contact details provided, subject to applicable law, confidentiality requirements and the availability of sufficient information.

The response may include the reasons for the decision where reasonably appropriate.

9.4 No Automatic Admission of Liability

The review, acknowledgement or investigation of a grievance shall not constitute an admission of liability, fault, deficiency, wrongdoing or breach by SetuRa.

Any resolution shall be determined based on the facts and applicable legal and contractual framework governing the matter.

10. Escalation Mechanism

10.1 Escalation by the Complainant

Where a Complainant is dissatisfied with the response or believes that the grievance has not been adequately addressed, the Complainant may request an internal escalation by referring to the original grievance reference number and explaining the grounds for seeking further review.

10.2 Senior Review

An escalated grievance may be reviewed by an appropriately senior representative of SetuRa or another designated function, depending upon the nature and materiality of the matter.

10.3 Legal and Regulatory Escalation

Matters involving significant legal, regulatory, consumer-protection, privacy, cybersecurity, fraud or reputational considerations may be escalated internally to SetuRa’s legal, compliance or senior management functions.

10.4 External Remedies

Nothing contained in this Policy shall restrict or extinguish any statutory right, regulatory remedy, contractual remedy or judicial remedy available to a Complainant under applicable law.

Where applicable law prescribes an internal grievance mechanism that must be exhausted before approaching a competent statutory authority, the relevant statutory procedure shall apply.

11. Privacy and Data-Protection Grievances

11.1 Data-Related Complaints

A person may contact SetuRa regarding concerns relating to the processing of personal data, including concerns relating to collection, use, disclosure, retention, correction, erasure, security or other processing activities.

11.2 Coordination with Privacy Function

Where appropriate, privacy-related grievances may be referred to SetuRa’s designated privacy, data-protection, legal or compliance function for assessment and response.

11.3 Verification and Security

SetuRa may undertake reasonable identity verification before responding to requests involving personal data, particularly where disclosure could affect the rights or privacy of another individual.

11.4 Applicable Data-Protection Framework

SetuRa shall administer personal-data grievances in accordance with the data-protection framework applicable to its processing activities, including the Digital Personal Data Protection Act, 2023 and applicable rules, regulations and governmental requirements, to the extent applicable.

The Ministry of Electronics and Information Technology currently publishes the Digital Personal Data Protection Rules, 2025 and related implementation materials, which should be considered when finalising SetuRa’s operational data-governance framework.

12. Urgent and High-Risk Grievances

12.1 Security and Cybersecurity Matters

Grievances involving suspected unauthorised access, account compromise, payment fraud, security vulnerabilities, data breaches or other cybersecurity concerns may be prioritised and escalated to the relevant security, technology, legal or compliance personnel.

12.2 Fraudulent or Unauthorised Transactions

Where a Complainant reports a potentially fraudulent or unauthorised transaction, SetuRa may undertake additional verification and investigation and may coordinate with relevant payment providers, financial institutions, technology providers or competent authorities where appropriate.

12.3 Safety-Critical Matters

Any complaint involving an immediate or material safety concern should be identified as such at the time of submission so that SetuRa may determine whether expedited handling or escalation is warranted.

13. Grievances Involving Third Parties

13.1 Third-Party Services

Where a service or transaction involves an independent third-party provider, SetuRa may coordinate with that provider to investigate the grievance.

13.2 Allocation of Responsibility

The responsibility for resolving a grievance shall depend upon the contractual structure, nature of the service, applicable law and the circumstances giving rise to the complaint.

13.3 No Waiver of Rights

Referral of a matter to a third party shall not constitute a waiver of any rights or remedies available to the Complainant under applicable law.

14. Fraudulent, Abusive or Malicious Complaints

14.1 Good-Faith Use

The grievance mechanism is intended for genuine concerns raised in good faith.

14.2 Misuse of the Mechanism

SetuRa may decline to process or may appropriately restrict handling of complaints that are demonstrably fraudulent, repetitive without substantive new information, abusive, threatening, defamatory, knowingly false or otherwise submitted for an improper purpose.

14.3 Preservation of Evidence

Where a complaint indicates potential fraud, unlawful conduct, abuse of systems or other serious misconduct, SetuRa may preserve relevant information and take appropriate action in accordance with applicable law.

15. Confidentiality and Information Security

15.1 Confidential Handling

SetuRa shall endeavour to handle grievance-related information with appropriate confidentiality and shall limit access to personnel or service providers who reasonably require such information for investigation, resolution, compliance or governance purposes.

15.2 Information Security

Reasonable technical and organisational measures may be applied to protect grievance- related information against unauthorised access, alteration, disclosure, loss or misuse, subject to the nature of the information and applicable legal requirements.

15.3 Legally Required Disclosure

Information may be disclosed where required or authorised by applicable law, court order, regulatory direction, law-enforcement requirement or other lawful process.

16. Records and Retention

16.1 Maintenance of Records

SetuRa may maintain records relating to grievances, correspondence, investigation outcomes, supporting documentation and remedial actions for purposes of accountability, audit, legal compliance, dispute management and service improvement.

16.2 Retention Period

Grievance records shall be retained for a period reasonably necessary to fulfil the purpose for which they are maintained, satisfy applicable legal or regulatory requirements, establish or defend legal claims, address disputes or fulfil legitimate business and governance requirements.

16.3 Secure Disposal

Upon expiry of the applicable retention period, information may be securely deleted, anonymised or otherwise disposed of, subject to legal, regulatory, contractual or legitimate retention requirements.

17. Governance, Monitoring and Internal Controls

17.1 Grievance Governance

SetuRa shall maintain an appropriate internal governance framework for oversight of material grievances and systemic issues identified through the grievance process.

17.2 Trend Analysis

Where appropriate, grievance data may be analysed to identify recurring complaints, operational weaknesses, technology issues, customer-experience concerns, compliance risks or opportunities for process improvement.

17.3 Corrective and Preventive Measures

Where grievance analysis identifies a recurring or systemic issue, SetuRa may implement corrective or preventive measures, including process modifications, employee training, technology improvements, policy revisions or enhanced controls.

18. Interaction with SetuRa Policies

18.1 Terms and Conditions

This Policy shall be read together with SetuRa’s applicable Terms and Conditions governing the use of its website, platforms and services.

18.2 Privacy Policy

Privacy and personal-data grievances shall additionally be governed by SetuRa’s Privacy Policy and the applicable data-protection framework.

18.3 Cookie Policy

Complaints concerning cookies and similar technologies shall also be considered in conjunction with SetuRa’s Cookie Policy.

18.4 Refund and Cancellation Policies

Payment, cancellation and refund-related matters shall be considered together with SetuRa’s applicable Refund Policy and Cancellation Policy, where applicable.

18.5 Precedence

Where there is an inconsistency between this Policy and a mandatory requirement of applicable law, the applicable law shall prevail to the extent of such inconsistency.

19. Consumer Protection and Regulatory Compliance

19.1 Consumer Protection Framework

SetuRa shall seek to administer customer grievances consistently with applicable consumer- protection laws and regulations.

19.2 E-Commerce Requirements

To the extent SetuRa falls within the scope of applicable e-commerce legislation or rules, the Company shall maintain the grievance-redressal arrangements, disclosures and processes required by such framework.

The Consumer Protection (E-Commerce) Rules, 2020 prescribe requirements for covered e- commerce entities and, among other matters, contemplate clear disclosure of grievance- officer information in applicable circumstances.

19.3 Regulatory Cooperation

SetuRa may cooperate with competent governmental, regulatory, law-enforcement or statutory authorities where legally required or otherwise permitted under applicable law.

20. Communication with the Complainant

20.1 Professional Communication

All material communications relating to grievances shall, to the extent reasonably practicable, be clear, professional and appropriately responsive to the issue raised.

20.2 Requests for Additional Information

Where additional information is necessary to investigate a grievance, SetuRa may request the same from the Complainant.

20.3 Closure Communication

Where a grievance has been investigated and resolved, SetuRa may issue a closure communication setting out the outcome and, where appropriate, the basis for such outcome.

21. No Limitation of Statutory Rights

21.1 Preservation of Legal Rights

Nothing in this Policy shall be interpreted as limiting, excluding or waiving any right or remedy available to a person under applicable law.

21.2 Contractual Rights

Nothing in this Policy shall alter contractual rights and obligations unless expressly agreed or required by applicable law.

21.3 Regulatory Rights

Nothing in this Policy prevents a competent authority, regulator, court, tribunal or statutory body from exercising its powers in accordance with applicable law.

22. Amendment of This Policy

22.1 Policy Updates

SetuRa may amend, modify, update or replace this Policy from time to time to reflect changes in its business operations, technology, legal requirements, regulatory expectations, internal processes or industry practices.

22.2 Effective Date of Amendments

An updated version shall become effective from the date specified in the revised Policy unless otherwise required by applicable law.

22.3 Material Changes

Where appropriate, SetuRa may provide reasonable notice of material changes through its website, platform or other appropriate communication channels.

23. Governing Law and Jurisdiction

23.1 Governing Law

This Policy shall be governed by and construed in accordance with the laws of India, except to the extent that mandatory applicable law provides otherwise.

23.2 Jurisdiction

Subject to applicable law and any valid contractual dispute-resolution mechanism, courts and competent authorities having jurisdiction over the relevant matter and the applicable SetuRa entity shall have jurisdiction.

24. Severability

24.1 Severability of Provisions

If any provision of this Policy is determined to be invalid, unlawful or unenforceable by a competent authority, such provision shall be modified or severed to the minimum extent necessary, and the remaining provisions shall continue to remain in effect to the extent permitted by applicable law.

25. No Waiver

25.1 No Waiver by Non-Enforcement

Any failure or delay by SetuRa in exercising a right or enforcing a provision of this Policy shall not constitute a waiver of that right or provision.

25.2 Statutory Protections

No provision of this Policy shall operate to waive or exclude mandatory statutory protections available to a consumer, user, Data Principal or other person under applicable law.

26. Contact and Grievance Information

26.1 Grievance Officer

Designation: Grievance Officer
Email: compliance@seturamobility.com

26.2 Corporate Contact

Applicable Website / Platform: https://seturamobility.com/
Issued By: Setura Mobility Private Limited

26.3 Grievance Submission

All grievances should preferably be submitted through the designated grievance channel specified above so that they can be appropriately registered, tracked and addressed.

27. Version Control

27.1 Policy Information

Policy Name: SetuRa Grievance Redressal Policy
Version: 1.0
Effective Date: 21st September 2026
Last Updated: 23rd September 2026
Policy Owner: Legal / Privacy / Compliance