Grievance Redressal Policy

OrbitSub, a sole proprietorship owned and operated by Karan in New Delhi, India, and registered as a micro enterprise under the Udyam (MSME) scheme of the Government of India ("OrbitSub", "we", "us", or "our") has appointed a designated Grievance Officer and established this Grievance Redressal Mechanism in strict compliance with:

1. Section 79 of the Information Technology Act, 2000 and Rule 3(2) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 as amended (the "IT Rules");
2. Section 8(10) and Section 13 of the Digital Personal Data Protection Act, 2023 (the "DPDP Act"); and
3. Rule 4(1)(b) and Rule 5(3) of the Consumer Protection (E-Commerce) Rules, 2020 under the Consumer Protection Act, 2019.

This Policy explains who our Grievance Officer is, what complaints you can raise, how to submit a formal grievance, the binding statutory time limits within which we act, and your external appellate rights.

1. Designated Grievance Officer & Contact Details

2. Matters You Can Raise with the Grievance Officer

Any user, Data Principal, copyright holder, or affected individual (whether or not you hold an Account on OrbitSub) may submit a formal grievance regarding:

1. Unlawful or Prohibited Content (IT Rules Rule 3(1)(b)): Any Content on the Service that you believe is unlawful, defamatory, obscene, invasive of privacy, harmful to children, threatens the unity/integrity/security of India, or violates our Terms of Service or Community Guidelines;
2. Urgent Intimate Imagery, Nudity, Impersonation & Morphed Images (IT Rules Rule 3(2)(b)): Any Content which prima facie exposes the private areas of an individual, shows an individual in full or partial nudity, shows or depicts an individual in any sexual act or conduct, or is in the nature of impersonation in an electronic form, including artificially morphed or deepfake images of an individual;
3. Copyright, Trademark & Intellectual Property Infringement: Any claim that Content on the Service infringes your copyright, trademark, or moral rights, as further detailed in our Copyright & IP Policy;
4. Content Moderation & Account Appeals: Any appeal against a decision by OrbitSub to remove or restrict your Content, or to warn, suspend, or terminate your Account under our Content Moderation Policy;
5. Personal Data & Privacy Rights (DPDP Act & GDPR): Any complaint or request concerning the collection, processing, retention, export, correction, consent withdrawal, or erasure of your personal data under our Privacy Policy, Data Retention Policy, or Data Deletion Policy;
6. Subscriptions, Billing & Refund Disputes (Consumer Protection E-Commerce Rules): Any complaint regarding a PayPal subscription charge, duplicate payment, auto-renewal, cancellation, or refund request under our Payment Policy and Refund & Cancellation Policy; and
7. Accessibility & General Platform Grievances: Any accessibility barrier or other concern relating to the operation of the Service.

3. How to Submit a Formal Grievance

You may submit a grievance by sending an email to team@orbitsub.com with the subject line Formal Grievance (or, for urgent intimate imagery/impersonation complaints, URGENT 2-Hour Takedown Request). Registered users may also submit privacy-specific requests directly via Settings → Privacy and content flags via the in-app Report button.

To enable swift investigation and resolution, please include:

1. Your Identity & Contact Details: Your full name, email address, and (optional) telephone number;
2. Category of Grievance: Which of the categories in Section 2 applies to your complaint;
3. Precise Location / Identifier: The exact URL(s) on orbitsub.com, Account email, or PayPal Transaction/Subscription ID concerned;
4. Detailed Grounds & Supporting Evidence: A clear explanation of why the Content or action is unlawful, breaches our policies, or infringes your rights, together with any supporting documents or screenshots;
5. Representative Capacity (if applicable): For complaints regarding intimate imagery or impersonation under Rule 3(2)(b), a statement indicating whether you are the individual depicted/impersonated or an person authorised to file the complaint on their behalf (note: anyone may file such a complaint on behalf of the affected victim); and
6. Declaration of Good Faith: A statement that the information provided in your grievance is true and accurate to the best of your knowledge.

4. Binding Statutory SLA & Resolution Timelines

We process all grievances in accordance with the strictest statutory timelines prescribed under Indian law:

5. How Grievances Are Investigated & Decided

1. Independent Review by the Grievance Officer: Every formal grievance is reviewed on its merits by the Grievance Officer against applicable law and our published policies.
2. Opportunity to Respond: Where a grievance seeks the removal of another user's Content or action against their Account, we may notify the affected user and offer an opportunity to respond or submit a counter-notice, except where immediate removal is mandated by law (such as the 2-hour window for intimate imagery/impersonation or 3-hour window for court orders) or where prior notice would endanger safety or prejudice an investigation.
3. Reasoned Written Outcome: Upon concluding our review, we send you a written response setting out the action taken (or the reasons why no action was taken) and informing you of your escalation rights.

6. Statutory Escalation & External Remedies

You are always required to exhaust our internal Grievance Redressal Mechanism first where prescribed by statute (such as Section 13(3) of the DPDP Act). If you are not satisfied with the decision of our Grievance Officer, or if your grievance is not resolved within the stipulated timeline, you have the following statutory avenues of recourse:

6.1 Grievance Appellate Committee (GAC) — Content & Moderation Decisions

Under Rule 3A of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, any person aggrieved by a decision of the Grievance Officer (or by a failure to resolve a grievance within the prescribed timeline) may file an appeal with the Grievance Appellate Committee (GAC) established by the Central Government within 30 days from the date of receipt of the Grievance Officer's communication via the official digital portal:

• Portal: https://gac.gov.in
• We comply promptly with every order passed by the Grievance Appellate Committee and publish compliance reports as required by Rule 3A(7).

6.2 Data Protection Board of India (DPBI) — Personal Data & Privacy Matters

Under Section 13(3) and Section 27 of the Digital Personal Data Protection Act, 2023, if you are not satisfied with the resolution of a personal data grievance or right request by our Grievance Officer, you have the right to make a complaint to the Data Protection Board of India (and, for UK/EEA/Swiss users, to your local data protection supervisory authority).

6.3 Consumer Disputes Redressal Commissions — Billing & E-Commerce Matters

For grievances concerning subscriptions, payments, or refunds, consumers in India may also contact the National Consumer Helpline (by calling 1915 or via https://consumerhelpline.gov.in) or approach the appropriate District, State, or National Consumer Disputes Redressal Commission under the Consumer Protection Act, 2019.

7. Good-Faith Use of the Grievance Mechanism

The Grievance Redressal Mechanism exists to protect legal rights, safety, and platform integrity. Submitting knowingly false, fabricated, or malicious complaints (for example, to harass a rival researcher or censor lawful academic speech) is a breach of our Terms of Service and may result in Account action or legal liability.

This Policy is effective from 1 October 2026 and was last updated on 25 October 2026.