Canada’s Anti-Spam Legislation (CASL)

Apollo Martech Group and/or its related corporations (collectively “AMG”) related corporations such as Cetas Solutions Pvt Ltd (a subsidiary entity of AMG)

Policy Statement

This document sets forth the policy of CSPL and is designed to provide reasonable assurance that (i) a consistent process is followed with respect to the dissemination of commercial electronic messages to CSPL clients and prospective clients in Canada, and (ii) CSPL employees sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.

The CSPL Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all CSPL employees sending CEMs (Commercial Electronic Messages) from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada comply with CASL, and seeks to ensure that all CEMs sent by or on behalf of CSPL, or using an CSPL email address or using a device owned or provided by CSPL, comply with CASL.

Policy Details

The Anti-Spam Policy describes CSPL’s commitments relating to the provisions of CASL and electronic messages of a commercial nature sent to CSPL clients, prospective clients, and others, as applicable. From time to time, CSPL may implement additional policies, procedures and/or practices as it relates to anti-spam measures.

Application

This Policy applies to CSPL employees who may be sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada.

With respect to CSPL’s operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and CSPL is committed to complying with CASL. All other CSPL policies and procedures will be interpreted in a manner that is consistent with the Anti-Spam Policy and that promotes compliance with CASL to seek to deter damaging and deceptive forms of spam from occurring in Canada.

Consent

CSPL obtains express, opt-in consent, unless a verifiable basis for implied consent or an exception to consent exists, before sending a CEM to anyone who has not had an existing business relationship with CSPL within two years before the date on which the CEM is sent. Unless a valid documented basis for implied consent or an exception to consent exists, CSPL also obtains express, opt-in consent for the sending of CEMs to CSPL prospects.

The request for consent cannot be in an electronic message unless there exists a basis for implied consent to send the message. The request for consent must be sought separately within a communication (e.g. through a separate action such as affirmatively checking a checkbox) and cannot be bundled as a term of acceptance of an agreement. Verbal consent is acceptable where a record of the details of the consent is maintained in a database.

Form and Content of CEMs

All CEMs are required to comply with the form and content requirements of CASL, generally described as follows:

• identifies the sender;

• the sender’s mailing address;

• the sender’s telephone number or email address or link to a webpage; and

• an unsubscribe mechanism or withdrawal of consent from receiving CEMs from CSPL and its subsidiaries and affiliates.

7. Limitation of Liability

7.1. The Site, services and the content on Site provided by the Company are on “as is” and “as available”, and the Company hereby expressly disclaims any and all warranties, express or implied, including but not limited to, any warranties of title, condition, quality, durability, performance, accuracy, reliability, merchantability or fitness for a particular purpose. All such warranties, representations, conditions, and undertakings are hereby excluded.

7.2. The Company further makes no representations or warranties about the validity, accuracy, correctness, reliability, quality, stability, completeness or correctness of any information provided on or through the sites.

7.3. The Company does not warrant that the Site or the services would meet your requirements or you would get an error-free, secure or uninterrupted access to the Site

7.4. The Company will have no liability related to user content or third party content arising under intellectual property rights, libel, privacy or other laws.

7.5. The Company shall not be liable for any damages whatsoever (including but not limited to damages for loss of profits or savings, business interruption, loss of information) resulting from any of the following. (a) The use or the inability to use the Site or services;(b) unauthorized access by third parties to data or private information of any User.

CSPL takes steps to require that any third-party service provider who sends CEMs on behalf of CSPL complies with CASL.

Storage of Relationship Details

A key component of complying with CASL involves maintaining records of CSPL’s relationships with clients and prospective clients.

Each business unit of CSPL is required to create and maintain in the business unit’s Client Relationship Management (CRM) system (including, but not limited to, Benchmark, Salesforce), verifiable records documenting the relationships giving rise to implied consent, and verifiable records of express, opt-in consents obtained from CSPL clients and prospective clients. “Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with CSPL at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with CSPL are not considered CSPL clients for purposes of this Policy.

These Terms shall be governed in accordance with the laws of India.

Implied consent or express, opt-in consent is obtained in accordance with the CASL Procedures and recorded in the applicable CRM system in order to track the client and prospect relationships.

Records of express, opt-in consent and records documenting the relationships giving rise to implied consent are retained for a minimum of three years after CSPL ceases sending CEMs to the CSPL client or prospect.

Storage of Relationship Details

All CSPL employees sending CEMs from and/or to a computer system(s) in Canada are required to comply with this Policy and related CASL procedures and processes.

A “CEM” is defined as an electronic message that includes content (for instance, text, hyperlinks, images or attachments) that:

a. promotes, offers, or advertises CSPL or CSPL’s products or services, or employees, or contacts;

b. solicits business for CSPL or CSPL’s employees or contacts; and

c. any other similar message that encourages participation in commercial activity.

Examples include promotional event invitations (e.g., webcasts or CSPL events), marketing newsletters, etc.

Examples include promotional event invitations (e.g., webcasts or CSPL events), marketing newsletters, etc.

The following messages do not have to comply with the requirements applicable to CEMs:

• messages sent to CSPL clients about their business;

• internal communications about CSPL’s business (including communications with CSPL offices outside Canada);

• legally required notices, such as messages that are sent to comply with a regulatory requirement (e.g., material changes, required account activity information, etc.); and

• responses to requests, inquiries or complaints.

Messages that CSPL employees email each other internally using a device that CSPL owns or provides, or using an CSPL email address, should be related to CSPL. CSPL employees may not internally email each other offers, promotions, advertisements, or referrals unrelated to CSPL business without the internal recipient’s verbal consent.

Compliance by Third Parties

All third-party contracts with service providers who may send CEMs on behalf of CSPL must contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.

Unsubscribe Mechanism

CEMs that are not exempt from requirements applicable to CEMs noted above are required to include a form of unsubscribe mechanism to facilitate the withdrawal of consent or do-not-contact requests within a period of time and in a manner that would allow CSPL to process that request within 10 days of the date on which the unsubscribe, withdrawal of consent or do-not-contact request was made. This information should be maintained in the applicable database that tracks the client and prospect relationships.

All emails sent by Apollo Martech Group and its subsidiaries, and employees will be compliant with CASL and will include the option to ‘unsubscribe.’ You can ‘unsubscribe’ from our Commercial Electronic Messages at any time by visiting https://cetassolutions.com/Unsubscribe/ or by emailing dpo@cetassolutions.com with ‘Unsubscribe’ in the subject line.

Policy Administration

The Anti-Spam Policy is maintained by the Compliance department of each XpertLync legal entity and will be reviewed and updated, where necessary, and approved on an annual basis. Any changes to, or exceptions from this Policy require the approval of the respective XpertLync Board or equivalent.

Review and Approvals

XpertLync Compliance is responsible for the review and revision of this Policy, subject to the approval of the respective XpertLync Board or equivalent. This Policy is subject to review on an annual basis, or otherwise as needed.

Enforcement and Audit

Compliance with this Policy, and any related procedure, may be reviewed by XpertLync at any time. Failure to comply with this Policy, as well as any associated procedures, may result in disciplinary action in accordance with the applicable Global Human Resources Disciplinary policy or procedure.