User Agreement

1.1 Acceptance of Terms

This User Agreement ("Agreement") is entered into between Gulf Return managed by Sheruh, a company organised under the laws of India ("Company", "We", "Us", or "Our"), and You ("User," "You," or "Your"). By clicking "I Agree," "Sign Up," "Register," or by accessing, browsing, or using the Gulf Return platform, website, mobile applications, or related services (collectively, the "Platform"), You acknowledge that You have read, understood, and agree to be bound by all the terms and conditions of this Agreement, along with Our Privacy Policy, Community Guidelines, and any other policies incorporated by reference. This Agreement constitutes a valid and legally binding clickwrap contract under Section 10A of the Information Technology Act, 2000 (as amended from time to time), and the Indian Contract Act, 1872. Your use or continued use of the Platform signifies Your acceptance of the terms of this Agreement and represents Your intent to be legally bound by them.

1.2 Modifications to Terms

The Company reserves the right to modify, update, or revise this Agreement at any time, at its sole discretion. Any changes will be effective immediately upon posting the revised Agreement on the Platform, unless otherwise specified. We will make reasonable efforts to notify You of material changes through email, in-app notifications, or prominent notices on the Platform. Your continued use of the Platform after such modifications constitutes Your acceptance of the modified Agreement. If You do not agree to the modified terms, You must immediately cease using the Platform and close Your Account.

1.3 Controller and Affiliate Designation

For the purposes of data protection law in India and applicable international frameworks, Gulf Return managed by Sheruh (registered in India) is the Controller or Data Fiduciary in respect of personal data collected and processed through the Platform. Any affiliates, subsidiaries, or related entities shall be considered Data Processors or sub-processors unless separately designated. For cross-border services or localised offerings, regional affiliates may be designated as joint controllers or independent controllers where applicable under local data protection laws, in which case supplemental notices will be provided.

1.4 Policy Hierarchy and Precedence

In the event of any conflict between this User Agreement, the Privacy Policy, and any other policies or guidelines (including Community Guidelines, Cookie Policy, or service-specific policies), the order of precedence shall be: (1) this User Agreement; (2) Privacy Policy; (3) service-specific policies; and (4) other ancillary policies or guidelines. To the extent any provision of a lower-ranked policy conflicts with a higher-ranked document, the higher-ranked document shall prevail unless expressly stated otherwise.

3.1 Eligibility Criteria

To use the Platform, You must: • Be at least eighteen (18) years of age or the age of majority in Your jurisdiction, whichever is higher. • Possess the legal capacity and authority to enter into a binding contract under applicable law. • Not be prohibited or restricted from using the Platform under any applicable law or regulation. • Not have been previously suspended or banned from the Platform. By registering an Account, You represent and warrant that You meet all the eligibility criteria and that all information provided during the registration process is accurate, current, and complete.

3.2 Account Registration

To access certain features of the Platform, You must create an Account by providing accurate and complete information, including Your name, email address, phone number, and other details as required. You agree to: • Provide truthful, accurate, current, and complete information during the registration process. • Maintain and promptly update Your Account information to keep it accurate and complete. • Accept full responsibility for all activities that occur under Your Account. • Notify the Company immediately of any unauthorised use of Your Account or any security breach. The Company reserves the right to suspend, terminate, or refuse registration of any Account at its sole discretion.

3.3 Account Security

You are solely responsible for maintaining the confidentiality and security of Your Account credentials, including Your username and password. You agree not to: • Share Your Account credentials with any third party. • Allow any third party to access Your Account. • Use another User's Account without authorisation. You agree to immediately notify the Company of any unauthorised access or use of Your Account. The Company shall not be liable for any loss or damage arising from Your failure to comply with these security obligations.

3.4 Security, Authentication and Account Recovery

The Platform may offer or require multi-factor authentication (MFA), one-time passwords (OTP), or other security measures for Account access. You agree to enable and maintain such features where offered or required. Should You lose access to Your Account, You may initiate account recovery through the procedures specified on the Platform. The Company may require identity verification and may delay or refuse recovery where fraud or misuse is suspected. You are responsible for securing the email address and phone number associated with Your Account.

3.5 Responsible Disclosure

If You discover a security vulnerability, bug, or weakness in the Platform's systems or infrastructure, You agree to report it responsibly to security@gulfreturn.com. You shall not exploit, publicly disclose, or share the vulnerability with third parties prior to the Company having a reasonable opportunity to remediate it. The Company will acknowledge receipt and work in good faith to address valid disclosures. This provision does not limit Your statutory rights or obligations under applicable law.

3.6 Service Levels and Maintenance

The Company strives to maintain Platform availability but does not guarantee uninterrupted access. Scheduled maintenance will be announced in advance where practicable; emergency maintenance may occur without notice. During maintenance, some or all Services may be unavailable. The Company is not liable for interruptions caused by maintenance, upgrades, or technical issues.

4.1 Nature of Services

The Platform operates as an intermediary under Section 2(1)(w) of the Information Technology Act, 2000, providing a technology-enabled marketplace that connects Job Seekers with Employers and facilitates professional networking. The Services include, but are not limited to:

• **Job Search and Application Services:** Enabling Job Seekers to search for job opportunities, create profiles, upload resumes, and apply for positions posted by Employers.
• **Recruitment Services:** Enabling Employers to post job vacancies, search candidate databases, manage applications, and communicate with potential candidates.
• **Professional Networking:** Enabling Users to connect with other professionals, build networks, share updates, and engage with content.
• **Career Resources:** Providing career advice, skill assessments, learning resources, and related tools.
• **Messaging and Communication:** Facilitating communication between Users through the Platform's messaging system.

4.2 Disclaimer Regarding Employment

The Company acts solely as an intermediary platform and does not:

• Guarantee any employment or recruitment outcome.
• Verify the accuracy, authenticity, or legitimacy of job postings or employer information.
• Endorse any particular employer, job opportunity, or candidate.
• Act as an employment agency, recruiter, or placement service.
• Participate in or influence hiring decisions made by Employers.
• Guarantee the qualifications, skills, or background of any Job Seeker.
• Facilitate, supervise, or participate in any transactions arising from such postings.

Users are advised to exercise due diligence and caution when interacting with other Users and when sharing personal or professional information. Employers may request or conduct background, credential, or other checks on candidates using third-party providers. Any such screening is performed solely by the Employer or their vendor; we do not perform or guarantee the results of background checks unless expressly stated. Employers are responsible for complying with applicable laws (including consent and local requirements) when conducting checks.

4.3 Premium Services

The Company may offer premium or paid Services with additional features ("Premium Services"). Access to Premium Services is subject to payment of applicable fees and acceptance of any additional terms and conditions specific to such services.

4.4 Refunds and Refunds Process

Refunds (if any) will be processed and disbursed in strict accordance with the Company's Refund Policy, as may be in effect from time to time. For more information on the refund policy, please visit www.gulfreturn.com on our website.

4.5 Payment Authorization, Chargebacks and Taxes

By providing payment information you authorise us and our payment processors to charge applicable fees. You are responsible for any taxes (including GST) arising from your purchases. In the event of a payment dispute or chargeback, we may suspend access to Premium Services pending resolution and may recover fees and costs. Refunds for chargebacks are subject to our Refund Policy and applicable law.

4.6 Subscription Billing

If you purchase a Premium Services, your payment method will be charged automatically at the start of each renewal period. You may cancel auto-renewal at any time but payments for a billing period already begun are non-refundable unless required by law or the applicable Refund policy. Any fees, charges, or payments made by a User to the Company are strictly in consideration for access to the Platform, including subscription plans, value-added services, and/or premium features offered by the Company. The Company does not receive, collect, hold, or facilitate any consideration in respect of listings, negotiations, arrangements, or transactions entered into directly between Users. All user-to-user interactions and transactions, if any, are undertaken independently and at the Users' own risk, without any involvement or liability of the Company.

4.7 Automated Matching & Profiling

The Platform uses automated algorithms to recommend jobs, candidates and connections and to rank results. These automated processes are intended to assist Users and Employers and not to replace human decision-making by Employers. Users have the right to request a meaningful explanation of the logic involved and to raise concerns or request human review through the Privacy Centre or by contacting the Grievance Officer. Automated outputs (including generative AI) may be inaccurate; Users are responsible for verifying content before relying on it.

4.8 Beta Features and Experimental Tools

From time to time, we may make experimental features (including AI-driven functionality) available for testing. Participation is voluntary. Experimental features may be less stable and results may be inaccurate; we disclaim guarantees for such features. We will indicate when a feature is in beta and may collect feedback and usage data to improve it.

4.9 Employer Verification

The Company may require Employers or recruiters to complete identity and business verification (KYC) prior to posting job openings or accessing enhanced features. The Company may suspend, disable, or remove job postings or recruiter accounts pending verification where there are reasonable grounds to suspect fraud or misuse. Employers warrant that job postings are accurate and lawful and will not charge candidates fees or otherwise engage in prohibited recruitment practices.

4.10 Recruitment Fees and Candidate Payments

Employers shall not require or demand payment from Job Seekers for application or interview processing unless explicitly disclosed and lawful. Any recruitment fee arrangements between Employers, agencies, and candidates are the parties' responsibility; we are not a party to such agreements and disclaim liability for related disputes.

4.11 API, Automated Access & Developer Terms

Access to any Platform API or developer tools is governed by separate API terms and developer documentation. Where we permit automated access, you must use only the approved API endpoints and follow rate limits and usage policies. Any unauthorised automated access (including scraping) is strictly prohibited and may result in suspension and legal action.

5.1 User Content Ownership and License

You retain ownership of the User Content You post or upload to the Platform. However, by posting or uploading User Content, You grant the Company a worldwide, non-exclusive, royalty-free, sublicensable, and transferable license to use, reproduce, distribute, display, publish, modify, adapt, translate, and create derivative works from such User Content in connection with operating and providing the Services. This license includes the right to:

• Display Your profile and User Content to other Users and Employers.
• Include Your User Content in search results within and outside the Platform.
• Use Your User Content for promotional and marketing purposes related to the Platform.
• Analyse and aggregate Your User Content for improving the Services.

This license continues even after You cease using the Platform, to the extent necessary to provide the Services and for reasonable archival and legal purposes.

5.2 User Representations and Warranties

By posting or uploading User Content, You represent and warrant that:

• You own or have the necessary licenses, rights, consents, and permissions to post such User Content.
• The User Content does not infringe, misappropriate, or violate any third party's intellectual property rights, privacy rights, or other legal rights.
• The User Content is accurate, truthful, and not misleading.
• The User Content does not contain any material that is defamatory, obscene, offensive, discriminatory, or otherwise objectionable.
• The User Content complies with all applicable laws, regulations, and this Agreement.

5.2(a) Third-Party Integrations and Job Distribution

Job postings and User Content may be shared, syndicated or displayed on third-party platforms or partner sites as described in the Privacy Policy. We are not responsible for how third parties use or process content after distribution. Employers remain responsible for the accuracy and compliance of syndicated listings.

5.3 Prohibited Content and Activities

In accordance with Rule 3(1)(b) of the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, You agree not to host, display, upload, modify, publish, transmit, store, update, or share any information or Content that:

• Belongs to another person and to which You do not have any right.
• Is defamatory, obscene, pornographic, paedophilic, invasive of another's privacy, including bodily privacy, insulting or harassing on the basis of gender, racially or ethnically objectionable, or otherwise inconsistent with or contrary to the laws in force.
• Is harmful to children.
• Infringes any patent, trademark, copyright, or other proprietary rights.
• Violates any law for the time being in force.
• Deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any misinformation or information which is patently false and untrue or misleading in nature.
• Impersonates another person.
• Threatens the unity, integrity, defence, security, or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting to any other nation.
• Contains software virus or any other computer code, file, or program designed to interrupt, destroy, or limit the functionality of any computer resource.
• Is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity, or agency for financial gain or to cause any injury to any person.

5.4 Additional Prohibited Activities

In addition to the above, You agree not to:

• Post fake, fraudulent, or misleading job opportunities or candidate profiles.
• Collect fees from Job Seekers for employment opportunities.
• Use automated scripts, bots, or similar tools to access the Platform without authorisation.
• Scrape, harvest, or extract data from the Platform without express written permission.
• Interfere with or disrupt the Platform's infrastructure or security features.
• Engage in multi-level marketing, pyramid schemes, or unsolicited commercial messages.
• Circumvent or manipulate any Platform features, including ratings, reviews, or search algorithms.
• Use the Platform for any purpose other than its intended use.

5.5 Moderation, Sanctions and Repeat Offenders

We operate content moderation and trust-and-safety processes. Violations may result in warnings, content removal, temporary suspension or permanent termination of Accounts, at our discretion. In serious cases (fraud, threats, sexual exploitation, large-scale scams), we may permanently ban Accounts and share information with law enforcement. Repeated breaches will accelerate enforcement.

6.1 Privacy Policy

Your use of the Platform is subject to our Privacy Policy, which is incorporated into this Agreement by reference. The Privacy Policy describes how We collect, use, process, store, and protect Your personal data in compliance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the DPDP Rules, 2025, and other applicable laws. By using the Platform, You consent to the collection and processing of Your personal data as described in the Privacy Policy.

6.2 Consent and Lawful Basis

Where processing of Your Personal Data is based on consent, the Company will collect, record and retain Your consent in an auditable manner and enable You to withdraw consent via the Privacy Centre or Account settings. The Privacy Policy describes the specific processing purposes, the lawful basis for each purpose (consent, contractual necessity, legitimate interest or legal obligation), and the consequences of withdrawing consent. Withdrawal of consent will not affect the lawfulness of processing prior to withdrawal.

6.3 Minors

The Platform is not intended for persons under the age of 18. If you are under 18, you must not create an Account. Where law permits the Company to provide limited services to minors, such services will only be provided with verifiable parental or guardian consent consistent with applicable law and the verification procedures set out in the Privacy Policy. If verifiable parental consent cannot be obtained, the Company will delete the minor's account and associated personal data in accordance with the Retention and Deletion policy.

6.4 Data Fiduciary Obligations

The Company, as a Data Fiduciary under the DPDP Act, 2023, undertakes to:

• Process personal data only for lawful purposes and in a fair and transparent manner.
• Collect personal data only for specified purposes and with appropriate consent.
• Implement reasonable security safeguards to protect personal data from unauthorised access, use, or disclosure.
• Provide accessible means for Data Principals to exercise their rights under the DPDP Act.
• Establish a grievance redressal mechanism and respond to grievances within ninety (90) days.
• Notify the Data Protection Board of India and affected Data Principals in case of a personal data breach.

6.5 Security Incidents and Breach Notification

The Company maintains an incident response programme. In the event of a personal data breach, the Company will (i) contain and investigate the incident, (ii) notify affected Data Principals and the Data Protection Board of India in accordance with applicable law where required, and (iii) take reasonable remedial measures. The Company will maintain logs and records of security incidents and responses for investigative and compliance purposes.

6.6 Data Principal Rights

As a Data Principal, You have the following rights under the DPDP Act, 2023, which may be exercised through our Privacy Centre or by contacting our Grievance Officer:

• **Right to Access:** The right to obtain confirmation of whether Your personal data is being processed and a summary of such data and processing activities.
• **Right to Correction and Erasure:** The right to correct inaccurate or incomplete personal data and to request erasure of personal data that is no longer necessary.
• **Right to Grievance Redressal:** The right to have readily available means of grievance redressal in respect of any act or omission regarding Your personal data.
• **Right to Nominate:** The right to nominate another individual to exercise Your rights in the event of Your death or incapacity.

6.7 Retention and Deletion

Personal Data will be retained only as long as necessary for the purpose for which it was collected, to provide the Services, to comply with legal obligations, or to resolve disputes. You may request correction or erasure of Your Personal Data via the Privacy Centre; we will process such requests in accordance with the DPDP Act, 2023 and applicable rules. Certain data may be retained as required by law or for legitimate business/legal purposes (e.g., fraud prevention, dispute resolution). We retain user data only as necessary for service provision, legal compliance, or fraud prevention. Standard retention periods are: active account data (as long as account is active), deactivated accounts (archived for 12 months), and logs/metadata (up to 24 months), unless longer retention is required by law. You may request a machine-readable export of your profile and content through the Privacy Centre; standard export requests are processed within 30 days.

6.8 Handling of Data Principal Requests

(a) For requests under the DPDP Act (access, correction, erasure, portability), we will acknowledge receipt within **7 calendar days** and will generally provide a substantive response within **30 calendar days** for routine requests. Complex requests that require coordination with third-party processors or additional verification may take up to **90 calendar days**, where this is the case, we will notify you of the reason and expected timeline. (b) The timelines above apply only to data-subject requests under the DPDP Act. Content takedown, moderation or trust & safety complaints are handled under Section 11 (Grievance Redressal) and may have different acknowledgement and resolution timelines.

6.9 International Transfers

To provide the Services, the Company may transfer Personal Data to third parties or processors located outside India. Such transfers will be subject to appropriate safeguards as required by applicable law (including contractual protections). Where Personal Data is transferred outside India, we will disclose the list of relevant categories of recipients in our Privacy Policy. Users acknowledge and agree that notwithstanding the Company's establishment in India, personal data may be stored, processed, or transferred to cloud infrastructure situated in jurisdictions outside India. Users hereby provide informed consent to such cross-border data processing, subject to compliance with applicable data protection legislation.

6.10 Processors and Sub-processors

The Company may engage third-party processors (e.g., hosting providers, analytics, payment processors) to perform services. We will impose contractual obligations on such processors to implement appropriate technical and organisational measures, to process Personal Data only on the Company's documented instructions, and to assist the Company in meeting its obligations under applicable data protection laws. The Company will maintain and publish a list of sub-processors and will provide notice before engaging a new material sub-processor. Data Principals may raise objections to such new engagements where they have legitimate grounds relating to data protection.

6.11 Data Principal Duties

As a Data Principal under the DPDP Act, 2023, You have the following duties:

• To not impersonate another person while providing personal data.
• To not suppress any material information while providing personal data.
• To not register false or frivolous grievances with the Company.
• To furnish only verifiably authentic information when exercising rights.

Non-compliance with these duties may attract penalties under Section 15 of the DPDP Act, 2023.

7.1 Company's Intellectual Property

The Platform, including its design, layout, look, appearance, graphics, logos, trademarks, service marks, trade names, text, images, software, algorithms, databases, and all other elements (collectively, "Company IP"), is the exclusive property of the Company or its licensors and is protected by applicable intellectual property laws, including the Copyright Act, 1957, the Trade Marks Act, 1999, the Patents Act, 1970, and international treaties. No right, title, or interest in the Company IP is transferred to You by virtue of this Agreement or Your use of the Platform. You are granted only a limited, non-exclusive, non-transferable, revocable license to access and use the Platform in accordance with this Agreement.

7.2 Restrictions

You shall not:

• Copy, modify, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, or sell any Company IP.
• Reverse engineer, decompile, or disassemble any software or technology used in the Platform.
• Use any Company trademarks, logos, or service marks without prior written consent.
• Remove, alter, or obscure any copyright, trademark, or other proprietary notices.
• Use automated systems or software to extract data from the Platform for commercial purposes.

7.3 Feedback

Any feedback, suggestions, ideas, or recommendations You provide regarding the Platform ("Feedback") shall become the exclusive property of the Company, and You hereby irrevocably assign all rights in such Feedback to the Company without any obligation of compensation or acknowledgment.

7.4 Counter-notice Procedure

If your content was removed following a copyright notice and you believe removal was in error, you may send a counter-notice to [designated email] including: (a) identification and location of the material removed; (b) a statement, under penalty of perjury, that you have a good-faith belief the removal was mistaken; (c) your contact details; and (d) an electronic signature. Upon receipt, the Company will review and, where appropriate, restore content in accordance with applicable law.

8.1 Term

This Agreement shall remain in effect until terminated by either You or the Company as provided herein.

8.2 Termination by User

You may terminate this Agreement at any time by:

• Deleting Your Account through the Account settings; or
• Submitting a written request to terminate Your Account to our Grievance Officer.

8.3 Termination by Company

The Company may terminate or suspend Your Account and access to the Platform, in whole or in part, with or without notice, for any reason, including but not limited to:

• Violation of this Agreement or any incorporated policies.
• Engagement in prohibited activities or posting prohibited Content.
• Request or direction from law enforcement or government authorities.
• Extended periods of inactivity.
• Technical or security issues.
• Fraudulent or illegal activities.
• Discontinuation of the Platform or any part thereof.

8.4 Effect of Termination

Upon termination:

• Your right to access and use the Platform shall immediately cease.
• The Company may, but is not obligated to, delete Your User Content and Account information.
• The Company may retain certain information as required by law or for legitimate business purposes.
• Provisions of this Agreement that by their nature should survive termination shall survive, including Sections relating to intellectual property, disclaimers, limitation of liability, indemnification, and governing law.

9.1 Disclaimer of Warranties

THE PLATFORM AND SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO:

• IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.
• WARRANTIES REGARDING THE ACCURACY, RELIABILITY, COMPLETENESS, OR TIMELINESS OF CONTENT.
• WARRANTIES THAT THE PLATFORM WILL BE UNINTERRUPTED, ERROR-FREE, SECURE, OR FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.
• CONTENT CONCERNING EMPLOYMENT, BUSINESS OPPORTUNITIES, SERVICES, INVESTMENTS, OR FINANCIAL MATTERS IS PROVIDED BY THIRD-PARTY USERS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE PROFESSIONAL, FINANCIAL, LEGAL, CAREER, OR INVESTMENT ADVICE. THE COMPANY MAKES NO REPRESENTATIONS REGARDING THE ACCURACY, RELIABILITY, OR COMPLETENESS OF SUCH CONTENT AND DISCLAIMS ALL LIABILITY FOR DECISIONS MADE IN RELIANCE THEREON.

The Company does not warrant or guarantee any specific results from the use of the Platform.

9.2 Operational Disclaimer

The Company shall not be liable for any delays, interruptions, or failures in the Platform's availability or performance, regardless of cause, including but not limited to:

• Internal operational delays in processing requests, verifying accounts, reviewing content, responding to inquiries, issuing refunds, or performing any other operational tasks, which may be affected by volume, complexity, resource availability, or other operational factors.
• Third-party service dependencies, including failures or limitations of cloud infrastructure providers, database services, payment processors, email/SMS services, authentication providers, content delivery networks, or any other external services upon which the Platform relies.
• Infrastructure limitations, including server capacity constraints, bandwidth limitations, database performance issues, network connectivity problems, or technical limitations of underlying systems.
• Force majeure events and circumstances beyond the Company's reasonable control, including natural disasters, pandemics, war, terrorism, government actions, cyberattacks, telecommunications failures, power outages, or internet infrastructure failures.
• Scheduled or emergency maintenance, upgrades, security measures, or service modifications performed with or without advance notice.

9.3 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW: (a) EXCEPT FOR LIABILITY ARISING FROM GROSS NEGLIGENCE, FRAUD, WILLFUL MISCONDUCT, OR BREACH OF STATUTORY DATA PROTECTION OBLIGATIONS (INCLUDING UNDER THE DPDP ACT), THE COMPANY'S TOTAL AGGREGATE LIABILITY FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THIS AGREEMENT OR YOUR USE OF THE PLATFORM SHALL NOT EXCEED THE GREATER OF: (i) THE AMOUNT PAID BY YOU TO THE COMPANY IN THE SIX (6) MONTHS PRECEDING THE DATE OF THE CLAIM; OR (ii) RUPEES ONE LAKH (₹100,000). (b) NOTWITHSTANDING THE FOREGOING, IN NO EVENT SHALL THE COMPANY OR ITS AFFILIATES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES (INCLUDING LOSS OF PROFITS, LOSS OF BUSINESS, LOSS OF GOODWILL, LOSS OF DATA OR OTHER INTANGIBLE LOSSES), EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. (c) THE LIMITATIONS SET FORTH IN THIS SECTION SHALL APPLY REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE. (d) TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE COMPANY DISCLAIMS ALL LIABILITY FOR DAMAGES, LOSSES, MISSED OPPORTUNITIES, OR ANY OTHER CONSEQUENCES ARISING FROM SUCH DELAYS, INTERRUPTIONS, OR FAILURES AS MENTIONED IN SECTION 9.2. USERS ACKNOWLEDGE THAT DELAYS ARE INHERENT IN ONLINE PLATFORMS AND AGREE THAT REASONABLE DELAYS SHALL NOT CONSTITUTE A BREACH OF THESE TERMS.

9.4 Safe Harbour Protection

As an intermediary under Section 79 of the Information Technology Act, 2000, the Company shall not be liable for any third-party information, data, or communication link made available or hosted by it, subject to compliance with the due diligence requirements under the IT Rules, 2021.

9.5 Intermediary Due Diligence

To avail safe-harbour protections under Section 79 of the IT Act, 2000 and the IT Rules, 2021, the Company follows prescribed due diligence including maintaining records of takedown requests, appointing a Grievance Officer, and cooperating with lawful requests by authorities.

11.1 Grievance Officer

In compliance with Section 13 of the DPDP Act, 2023 and Rule 3(2) of the IT Rules, 2021, the Company has appointed a Grievance Officer to address user complaints and concerns. The Grievance Officer may be contacted at: **Name:** Mohd Raavi **Email:** support@gulfreturn.com **Phone:** +91-8868964790 **Address:** Aligarh, UP **Working Hours:** 9 AM-10 PM

11.2 Notice-and-Takedown; Preservation of Evidence

(a) Content complaints submitted to the Grievance Officer will be acknowledged within **24 hours** of receipt. Where a legal takedown is required, we will investigate and take appropriate action normally within **15 calendar days** (or such other shorter statutory timeframe as required). (b) For data protection related grievances handled under the DPDP Act, please see Section 6.6 for the data-subject request timelines. The Grievance Officer will resolve DPDP grievances within **90 days** as required by applicable law.

11.3 Appeal to Grievance Appellate Committee

If You are not satisfied with the resolution provided by the Grievance Officer, You may file an appeal with the Grievance Appellate Committee (GAC) established under Rule 3A of the IT Rules, 2021, within thirty (30) days of receiving the Grievance Officer's decision. Appeals may be filed at https://www.gac.gov.in.

11.4 Escalation to Data Protection Board

For grievances relating to personal data, if You have exhausted the grievance redressal mechanism provided by the Company and are not satisfied with the resolution, You may file a complaint with the Data Protection Board of India under Section 13(3) of the DPDP Act, 2023.

11.5 Scope of Grievance Mechanism

This Grievance Redressal Mechanism applies exclusively to complaints concerning Platform functionality, service provision, account management, and alleged violations of the Company's policies. This mechanism does not extend to disputes, claims, or disagreements arising between Users inter se, including but not limited to employment-related disputes, transaction disagreements, or any other User-to-User matters. The Company is not a party to User interactions and assumes no responsibility for mediating or resolving inter-User disputes. FOR MORE INFORMATION on Grievance Redressal Mechanism please check out GRIEVANCE REDRESSAL POLICY at www.gulfreturn.com on our website.

12.1 Governing Law

This Agreement shall be governed by and construed in accordance with the laws of India, without regard to its conflict of law principles.

12.2 Arbitration

Any dispute, controversy, or claim arising out of or relating to this Agreement, including its validity, interpretation, performance, breach, or termination, shall be resolved through binding arbitration in accordance with the Arbitration and Conciliation Act, 1996 (as amended). The arbitration shall be conducted by a sole arbitrator mutually appointed by the parties, or in the absence of mutual agreement, by an arbitrator appointed in accordance with the provisions of the said Act. The seat and venue of arbitration shall be Hyderabad, India. The arbitration proceedings shall be conducted in English. The arbitral award shall be final and binding on the parties.

12.3 Jurisdiction

Subject to the arbitration clause above, the courts at Hyderabad, India, shall have exclusive jurisdiction over any disputes arising out of or relating to this Agreement.

12.4 Consumer Disputes

Nothing in this Agreement shall limit Your rights under the Consumer Protection Act, 2019, or Your right to approach consumer forums or courts of competent jurisdiction for redressal of consumer grievances.

13.1 Entire Agreement

This Agreement, together with the Privacy Policy, Community Guidelines, and any other policies referenced herein, constitutes the entire agreement between You and the Company with respect to the subject matter hereof and supersedes all prior or contemporaneous communications, representations, or agreements, whether oral or written.

13.2 Severability

If any provision of this Agreement is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable, and the remaining provisions shall continue in full force and effect.

13.3 Waiver

The failure of the Company to enforce any right or provision of this Agreement shall not constitute a waiver of such right or provision. Any waiver must be in writing and signed by an authorised representative of the Company.

13.4 Assignment

You may not assign or transfer this Agreement or Your rights and obligations hereunder without the prior written consent of the Company. The Company may assign this Agreement or its rights and obligations hereunder to any successor or affiliate without Your consent.

13.5 Third-Party Beneficiaries

This Agreement does not create any third-party beneficiary rights except as expressly provided herein.

13.6 Notices

The Company may provide notices to You through the Platform interface, email to Your registered email address, or any other reasonable means. You may provide notices to the Company by contacting the Grievance Officer at the contact details provided in Section 11.

13.7 Force Majeure

The Company shall not be liable for any failure or delay in performance of its obligations under this Agreement due to circumstances beyond its reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, riots, embargoes, acts of civil or military authorities, fire, floods, epidemics, pandemics, strikes, or power outages.

13.8 Relationship of Parties

Nothing in this Agreement shall be construed to create a joint venture, partnership, employment, or agency relationship between You and the Company. Neither party has the authority to bind the other in any manner.

13.9 Language

This Agreement is executed in English. In the event of any conflict between the English version and any translation, the English version shall prevail.

13.10 Headings

The headings in this Agreement are for convenience only and shall not affect the interpretation of any provision.