Grievance Redressal Policy

TRADECLOVER LLP Grievance Redressal Policy (IT Rules)

1. Introduction and Objective

TRADECLOVER LLP ("TRADECLOVER", "we", "us", "our") operates an online marketplace platform ("Platform") that enables third-party sellers and buyers to interact and transact. In its capacity as an intermediary under the Information Technology Act, 2000 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, as amended from time to time ("IT Act" and "Intermediary Guidelines"), TRADECLOVER is committed to:

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  Providing a transparent, accessible and effective grievance redressal mechanism for users and other stakeholders;
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  Ensuring timely acknowledgement and resolution of grievances in accordance with applicable law; and
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  Maintaining appropriate records and reporting with respect to grievances and actions taken.

This Grievance Redressal Policy (IT Rules) ("Policy") sets out the framework, roles, responsibilities, timelines, and processes for receiving, acknowledging, investigating and resolving grievances received in relation to the Platform and services provided by TRADECLOVER as an intermediary.

This Policy should be read in conjunction with the Website/App Terms of Use, Buyer Terms and Conditions, Seller Agreement / Seller Terms, Privacy Policy, Listing & Prohibited Items Policy, IP Infringement Takedown Policy, Refund, Cancellation & Dispute Policy, and any other applicable policies of TRADECLOVER (collectively, the "Platform Policies"). In case of any inconsistency, the provisions required under applicable law (including the IT Act and Intermediary Guidelines) shall prevail to the extent of such inconsistency.

2. Definitions

For the purposes of this Policy, unless the context otherwise requires:

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  1. "Act" means the Information Technology Act, 2000, as amended from time to time.
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  2. "Applicable Law" means all applicable laws, statutes, rules, regulations, ordinances, notifications, circulars, guidelines and other legal requirements in force in India, including the Act, the Intermediary Guidelines, and rules made thereunder.
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  3. "Grievance" means any written complaint, concern or objection submitted in accordance with this Policy by a user or any other person in relation to access or usage of the Platform, alleged violation of Platform Policies, alleged violation of Applicable Law by content hosted, published, transmitted, updated or shared on the Platform, processing of personal data by TRADECLOVER as an intermediary to the extent governed by this Policy, or any other matter specifically covered by this Policy or required to be addressed under the Intermediary Guidelines.
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  4. "Grievance Officer" means the officer designated by TRADECLOVER in accordance with the Act and the Intermediary Guidelines to address and redress Grievances received in relation to the Platform.
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  5. "Intermediary Guidelines" means the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, as amended or re-enacted from time to time.
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  6. "Law Enforcement Agency" or "LEA" means any lawfully constituted authority or government agency empowered under Applicable Law to seek information, issue directions or require assistance from intermediaries.
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  7. "User" means any natural or legal person who accesses or uses the Platform in any manner, including buyers, sellers, visitors, account holders, and other end-users.

Capitalised terms not specifically defined in this Policy shall have the meanings ascribed to them in the Platform Policies.

3. Legal Framework and Guiding Principles

This Policy is framed in accordance with, and is intended to be consistent with:

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  Section 79 of the IT Act;
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  The Intermediary Guidelines, including Rules 3 and 4 thereof as applicable to intermediaries; and
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  Any other rules, notifications or directions issued by competent authorities related to grievance redressal obligations of intermediaries.

In implementing this Policy, TRADECLOVER shall be guided by the following principles:

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  1. Accessibility - Grievance channels shall be clearly published, easy to use, and available to Users and stakeholders without undue burden.
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  2. Transparency - The status, actions taken, and final outcome of Grievances shall be communicated to complainants within legally prescribed timelines.
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  3. Timeliness - Grievances shall be acknowledged and resolved within timelines required under Applicable Law and internal standards of TRADECLOVER.
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  4. Fairness and Due Process - All Grievances will be assessed fairly, consistently and objectively, with appropriate opportunity provided to affected parties to respond where necessary.
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  5. Confidentiality and Data Protection - Information submitted in Grievances will be handled in accordance with Applicable Law and TRADECLOVER's Privacy Policy, ensuring confidentiality and security of personal data to the extent reasonably possible.
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  6. Documentation and Accountability - Records of Grievances, action taken, and responses shall be maintained for such period and in such manner as may be prescribed by Applicable Law and TRADECLOVER's internal policies.

4. Appointment and Details of Grievance Officer

4.1 Designation and Authority

TRADECLOVER shall designate a senior officer as Grievance Officer with sufficient authority, resources and independence to:

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  Receive, acknowledge, review, and address Grievances;
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  Coordinate with relevant internal teams, sellers, and service providers;
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  Communicate with complainants and LEAs; and
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  Ensure compliance with timelines and reporting obligations under the Intermediary Guidelines.

4.2 Current Grievance Officer Details (to be published on Platform)

The above details (with updated particulars as applicable) shall be conspicuously published:

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  On the Website/App under the "Grievance Redressal", "Contact Us", and/or "Legal" section(s); and
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  Within the relevant Platform Policies where mandated by the Intermediary Guidelines.

4.3 Change in Details

TRADECLOVER may, from time to time, modify or replace the Grievance Officer and/or update the contact details. Any such change shall be promptly updated on the Platform and, where required, notified to the appropriate authorities in accordance with Applicable Law.

5. Scope of Grievances Covered

Without limitation, the following categories of issues may be raised as Grievances under this Policy:

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  1. Content-Related Grievances: Alleged unlawful content, listings that fall under TRADECLOVER's Listing & Prohibited Items Policy, and misleading, fraudulent or abusive content posted by Users or sellers.
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  2. User Account and Access Issues: Suspension or termination of User accounts, unauthorized access or suspected compromise of User accounts, and access restrictions perceived as unfair or erroneous.
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  3. Transactional and Marketplace Issues: Disputes between buyers and sellers, limited to the extent TRADECLOVER's intervention is provided for in the Refund, Cancellation & Dispute Policy and other Platform Policies; and complaints relating to non-delivery, short-delivery, product quality or mismatch where TRADECLOVER's policies envisage grievance handling through the Platform.
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  4. Privacy and Data Handling Concerns: Concerns relating to collection, use, disclosure, retention or security of personal data on the Platform, to the extent processed by TRADECLOVER as an intermediary; and suspected misuse of User data by Platform interfaces.
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  5. Violation of Platform Policies or Applicable Law: Any act or omission by Users or sellers allegedly in violation of Platform Policies; and any matter required under the Intermediary Guidelines to be addressed by the Grievance Officer.

This Policy does not govern disputes that are purely contractual between buyers and sellers where TRADECLOVER is not required under Platform Policies to intervene, relate solely to services of third parties integrated via the Platform except to the limited extent TRADECLOVER is required to assist as an intermediary, or are explicitly excluded in the applicable Platform Policies.

6. Grievance Submission Channels and Requirements

6.1 Channels for Submitting Grievances

Complainants may submit a Grievance to the Grievance Officer using any of the following modes:

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  1. Email: To grievance.officer@tradeclover.in with the subject line "Grievance - [Short Description of Issue] - [User ID / Order ID (if any)]"
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  2. Online Form (if available on Platform): By filling the designated "Submit a Grievance" form under the "Grievance Redressal" section, providing required details and attachments.
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  3. Physical Letter / Courier: Addressed to Grievance Officer - TRADECLOVER LLP, 10th Floor 1002 Shiv Shrushti New Link Road Kandivali West 400067, Mumbai, Maharashtra, India.

TRADECLOVER encourages use of the email or online form channels for faster processing and communication.

6.2 Mandatory Information for a Valid Grievance

To enable prompt and effective handling, a Grievance should contain, at a minimum:

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  Full name of the complainant;
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  Relationship with TRADECLOVER (e.g., buyer, seller, visitor, rights holder, legal representative, LEA, etc.);
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  Contact details (email address and phone number) for communication;
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  Description of the issue, including nature of the complaint, date(s) and approximate time(s) of occurrence, and relevant URLs, screenshots, order IDs, listing IDs, User IDs, or other identifiers (if applicable);
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  Clear statement of the relief or action sought from TRADECLOVER;
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  Declaration confirming that the statements made in the Grievance are true and correct to the best of the complainant's knowledge and belief, and that the complainant is authorised to act on behalf of any person whose rights are alleged to be affected (if applicable); and
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  Supporting documents, if any (e.g., identity proof, proof of ownership of rights, prior correspondence, legal notices).

Where a Grievance is incomplete or lacking essential information, TRADECLOVER may, at its discretion, request additional details before initiating or completing the review.

7. Processing of Grievances - Steps and Timelines

7.1 Acknowledgement

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  TRADECLOVER shall acknowledge each valid Grievance within twenty-four (24) hours of receipt, in accordance with the Intermediary Guidelines.
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  Acknowledgement shall, where feasible, include a unique Grievance Reference Number, date and mode of receipt, and a brief indication of next steps and indicative timelines.

7.2 Preliminary Assessment

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  Verify whether the Grievance falls within the scope of this Policy and Applicable Law;
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  Classify the Grievance based on its nature and priority, such as high priority, medium priority, or standard; and
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  Determine immediate interim measures if required (e.g., temporary disabling of content or listings pending review, where appropriate).

7.3 Investigation and Decision

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  Consult relevant internal teams and, where appropriate, involved sellers or Users;
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  Examine evidence and materials submitted by the complainant and available on the Platform;
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  Review relevant Platform Policies and Applicable Law; and
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  Where necessary, seek clarifications or additional documentation from the complainant or other concerned parties.

In cases involving alleged unlawful content or violation of the Intermediary Guidelines, the decision may involve one or more of the following actions:

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  Removal, disabling or restriction of access to the impugned content or listing;
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  Suspension, restriction or termination of the responsible User's or seller's account in accordance with Platform Policies;
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  Reporting the matter to LEAs or cooperating with duly authorised investigations; or
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  Refusal of the relief sought with reasons recorded, where the Grievance is found to be unsupported, frivolous or outside the scope of this Policy.

7.4 Resolution and Response Timelines

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  TRADECLOVER shall resolve or dispose of Grievances within fifteen (15) days from the date of receipt, or within such shorter period as may be mandated under Applicable Law for certain categories of complaints.
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  Resolution shall mean communication to the complainant of the decision taken, any action implemented, and reasons or explanation, at least in brief, for acceptance or rejection of the Grievance.

7.5 Escalation

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  If a complainant is dissatisfied with the resolution, they may respond to the resolution communication, setting out specific grounds for reconsideration within 7 (seven) days of such communication.
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  The Grievance Officer may, at their discretion, review the matter again, seek additional information, and either reaffirm the prior decision or modify or reverse the decision and take further action.
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  The outcome of reconsideration shall ordinarily be communicated within 10 (ten) days from receipt of the escalation, subject to the complexity of the matter and Applicable Law.

8. Cooperation with Law Enforcement and Government Authorities

8.1 Receipt of Orders and Directions

TRADECLOVER shall comply with any lawful order, direction, or request received from courts or judicial bodies in India, Law Enforcement Agencies, or any government authority empowered under Applicable Law to require information, content takedown, blocking of access, or other action.

8.2 Processing of LEA / Government Requests

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  The Grievance Officer or authorised delegate shall verify the authenticity and jurisdictional competence of the order/direction, to the extent reasonably possible.
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  TRADECLOVER shall take such steps as may be necessary to comply within the timelines specified in the order/direction or under Applicable Law.
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  To the extent permissible, TRADECLOVER may inform affected Users or sellers of the action taken, except where prohibited by Applicable Law or the order/direction itself.

8.3 Confidentiality and Record-Keeping

All such orders, related correspondence, and documents shall be maintained confidentially and securely, subject to Applicable Law and TRADECLOVER's internal policies.

9. Data Protection and Confidentiality

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  Grievance records may contain personal data of complainants, Users, sellers, and other individuals. TRADECLOVER shall process such data strictly in accordance with Applicable Law and its Privacy Policy.
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  Access to Grievance records shall be limited to authorised personnel strictly on a need-to-know basis.
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  TRADECLOVER may anonymize or aggregate Grievance data for internal monitoring, analytics, and improvement of Platform services, provided such data does not identify individuals.

10. Record Retention and Reporting

10.1 Record Retention

TRADECLOVER shall maintain records relating to Grievances and actions taken, including:

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  Date and mode of receipt;
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  Name and contact details of complainant (where provided);
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  Description and classification of the Grievance;
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  Internal notes, analysis, and actions taken;
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  Date of acknowledgement and resolution;
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  Communications exchanged with the complainant and third parties; and
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  Copies of any orders/directions from government/LEAs and compliance actions.

Such records shall be retained for at least the minimum period required under Applicable Law and TRADECLOVER's data retention policies, whichever is longer.

10.2 Reporting and Audits

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  Where required by Applicable Law, TRADECLOVER may prepare periodic reports on Grievances received, disposed of, and pending;
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  Furnish such reports to regulators or government authorities; and
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  Facilitate internal or external audits regarding compliance with the Intermediary Guidelines and this Policy.

11. No Waiver of Legal Rights and Remedies

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  This Policy provides an internal mechanism for grievance redressal and does not restrict any rights or remedies available to Users or complainants under Applicable Law.
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  TRADECLOVER's decision under this Policy is without prejudice to its rights and remedies available under law and under the Platform Policies.
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  TRADECLOVER may, at its discretion, refer parties to other remedies where the matter is beyond the scope of this Policy as an intermediary grievance redressal mechanism.

12. Governing Law and Dispute Resolution (Relating to this Policy)

12.1 Governing Law

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

12.2 Arbitration

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  Any dispute, controversy or claim arising out of or in connection with this Policy, or the implementation, interpretation, breach, termination or validity thereof, that is directly between the complainant (who is a User of the Platform) and TRADECLOVER and is not otherwise required to be resolved under separate transactional terms, shall be finally resolved by arbitration.
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  The arbitration shall be conducted in accordance with the provisions of the Arbitration and Conciliation Act, 1996, as amended from time to time.
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  The arbitral tribunal shall consist of a sole arbitrator to be mutually appointed by TRADECLOVER and the disputing User. If the parties are unable to agree on the sole arbitrator within 30 (thirty) days of one party issuing a notice of arbitration, the sole arbitrator shall be appointed in accordance with the provisions of the Arbitration and Conciliation Act, 1996.
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  The seat and venue of arbitration shall be Mumbai, Maharashtra, India.
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  The arbitration proceedings shall be conducted in the English language.
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  The award of the arbitral tribunal shall be final and binding on the parties, and may be enforced by any court of competent jurisdiction.

12.3 Jurisdiction

Subject to the foregoing arbitration clause, the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction in respect of all matters arising out of or in connection with this Policy.

13. Policy Review and Amendments

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  TRADECLOVER may review, update or amend this Policy from time to time to reflect changes in legal requirements, operational needs, or Platform practices.
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  Any material changes shall be reflected by updating the effective date and, where required, notified to Users via the Platform.
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  Continued use of the Platform after publication of amendments shall be deemed acceptance of the revised Policy, to the extent permitted by Applicable Law.

14. Publication of Grievance Officer Details and Policy

In compliance with the Intermediary Guidelines, TRADECLOVER shall:

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  Conspicuously publish on the Platform the name and contact details of the Grievance Officer; and this Grievance Redressal Policy (IT Rules) or a clear link to it.
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  Ensure that the following indicative text (or substantially similar language) appears in appropriate sections (e.g., Website/App footer, "Contact Us", Legal/Help sections).

15. Annexures

The following annexures form an integral part of this Policy and provide standardised formats and language for implementation. These are operational templates and may be adapted by TRADECLOVER on a case-by-case basis while maintaining consistency with this Policy and Applicable Law.

Annexure A - Grievance Acknowledgement Template

Annexure B - Grievance Resolution / Disposal Template

Annexure C - Standard Online Grievance Form (Indicative Fields)

Title on Platform: "Submit a Grievance (IT Rules)"

Fields:

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  1. Complainant Details: Full Name (mandatory), Relationship with Platform, Email Address (mandatory), and Mobile Number (mandatory).
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  2. Grievance Details: Category of Grievance, date(s) and approximate time(s) of incident, relevant URL(s)/listing ID(s)/order ID(s)/user ID(s), detailed description of grievance, and relief/action sought.
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  3. Supporting Documents: Upload documents/screenshots (multiple files, acceptable formats) - optional but recommended.
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  4. Declaration and Consent: Mandatory checkboxes confirming truthfulness/authorisation and consent to TRADECLOVER LLP processing personal data for grievance handling.
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  5. Submit Button: "Submit Grievance" (with confirmation pop-up summarising key entered details).

Upon submission, the system should display an on-screen confirmation with the Grievance Reference Number and trigger an automatic email acknowledgement to the complainant.