INTUCATE

1. Introduction

Dharia Enterprises Private Limited, operating its online learning platform under the brand name Intucate (hereinafter referred to as 'Intucate', 'the Platform', 'the Company', 'we', 'us', or 'our'), is committed to fostering a lawful, respectful, and intellectually honest digital learning environment for Chartered Accountancy (CA) students, educators, and all associated stakeholders across India and beyond.
Intucate recognises and deeply respects the rights of intellectual property owners, content creators, academic publishers, authors, educators, and institutions whose original works form the foundation of quality education. Unauthorised reproduction, distribution, or public communication of copyrighted educational materials-including but not limited to video lectures, study notes, mock test papers, PDF documents, and proprietary course content-causes serious harm to content creators and undermines the integrity of the educational ecosystem.
This Content Takedown Policy ('Policy') establishes a clear, transparent, and legally compliant framework through which copyright holders, intellectual property owners, authorised representatives, and other affected parties may report, to the Platform, any content that they reasonably believe infringes upon their rights. This Policy also sets out the procedures the Platform will follow upon receipt of a takedown notice, including the rights of users and instructors to submit a counter-notification. This Policy is applicable across all interfaces through which the Intucate Platform is accessed, including the web-based application available at www.intucate.com (or such other URL as may be notified) and all versions of the Intucate mobile application available on Android and iOS platforms.
This Policy has been formulated with due regard to and in compliance with the following applicable laws and frameworks:

• The Information Technology Act, 2000 ('IT Act'), as amended from time to time.
• The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 ('IT Rules, 2021'), including all subsequent amendments.
• The Copyright Act, 1957 (India), as amended from time to time, including the Copyright (Amendment) Act, 2012.
• The Trade Marks Act, 1999 (India)
• The Digital Personal Data Protection Act, 2023 ('DPDP Act'), to the extent applicable.
• International best practices in notice-and-takedown procedures, including principles analogous to the United States Digital Millennium Copyright Act ('DMCA'), applied to the extent consistent with Indian law

2. Definitions

For the purposes of this Policy, the following terms shall have the meanings ascribed to them below:

3. Scope of the Policy

This Policy applies to all Content hosted, published, stored, distributed, or otherwise made available on or through the Platform, regardless of the form or medium in which such Content is presented. Specifically, this Policy governs the following categories of Content:

3.1 Video Lectures and Recorded Sessions:
This includes all pre-recorded and live video lectures, tutorials, demonstrations, webinars, and any other audiovisual educational material uploaded by Instructors or Users to the Platform, whether made available as part of paid courses, free modules, or trial previews.

3.2 Study Materials and Notes:
This includes all written study materials, handwritten or typed notes, summaries, revision sheets, mnemonics, charts, diagrams, and any other educational documents uploaded to the Platform in PDF, Word, image, or any other digital format.

3.3 Mock Tests and Examination Materials:
This includes all practice questions, mock examinations, test series, previous year question papers (where reproduction is not otherwise authorised), answer keys, model answer sheets, and any other assessment-related materials hosted on the Platform.

3.4 Presentation Slides and Infographics:
This includes all PowerPoint presentations, Keynote files, PDF slide decks, infographics, flowcharts, and any other visual educational aids uploaded to the Platform.

3.5 Community Discussions and User-Generated Content:
This includes posts, messages, comments, replies, queries, images, links, and any other Content published or shared by Users and Instructors in the Platform's community discussion boards, forums, chat features, or comment sections.

3.6 Software and Code:
This includes any software code, scripts, tools, plugins, or technological works made available on the Platform, to the extent such works are subject to copyright protection.

3.7 Third-Party Embedded Content:
This includes any external content that Instructors or Users embed, link to, or reference from the Platform, where such linking or embedding may constitute secondary or indirect infringement.

This Policy applies equally to Content accessible through the web platform and the mobile applications of Intucate. The procedures described herein shall apply uniformly regardless of the device, operating system, or interface through which the Content is accessed.

4. Respect for Intellectual Property

Intucate firmly believes that robust intellectual property protection is essential to sustaining a high-quality educational ecosystem. We recognise that the creators of educational content-whether they are independent educators, academic institutions, publishers, or subject matter experts-invest significant time, effort, and resources in producing original works, and that such investments must be protected and incentivised.

Accordingly, the Company:

• Prohibits all Instructors and Users from uploading, sharing, or distributing Content that infringes the copyright, trademark, trade secret, or any other intellectual property right of any third party.
• Requires all Instructors to represent and warrant, at the time of onboarding and at all times thereafter, that the Content they upload to the Platform is either their original creation or that they hold all necessary licences, permissions, and authorisations to upload and distribute such Content through the Platform.
• Requires all Users to acknowledge, upon registration, that the Platform's Content is proprietary and may not be downloaded, reproduced, shared, transmitted, or distributed without the express written consent of the respective Copyright Owner or as otherwise permitted under applicable law.
• mplements reasonable technical and organisational measures to detect and prevent the upload and distribution of Content that is clearly infringing, including digital watermarking, access controls, and periodic content reviews.
• Cooperates fully with Copyright Owners to address legitimate claims of infringement through the procedures set out in this Policy.
• Reserves the right to remove or disable access to Content that is determined to be infringing, in accordance with applicable law and this Policy.

Nothing in this Policy shall be construed as limiting the Company's right to take such additional measures as it considers appropriate to protect intellectual property rights on the Platform.

5. Types of Violations Covered

This Policy covers Takedown Requests relating to the following categories of intellectual property violations:

5.1 Copyright Infringement:
Unauthorised reproduction, adaptation, distribution, public performance, public display, or communication to the public of any copyrighted work, including but not limited to educational texts, video lectures, audio recordings, photographs, artistic works, software, and compilations, in violation of the Copyright Act, 1957.

5.2 Trademark Violations:
Unauthorised use of registered or unregistered trademarks, trade names, logos, brand identifiers, or service marks belonging to third parties in a manner that is likely to cause confusion, deception, or misrepresentation as to the source, affiliation, or endorsement of any Content on the Platform.

5.3 Unauthorised Reproduction of Educational Materials:
Reproduction, digitisation, scanning, retyping, or redistribution of proprietary educational content, including textbooks, study guides, reference materials, lecture handouts, courseware, and similar works published by recognised academic publishers, educational institutions, professional bodies, or individual authors.

5.4 Piracy of Course Content:
Unauthorised recording, capture, download, re-upload, redistribution, or resale of video lectures, live sessions, recorded webinars, or any other course content that is proprietary to an Instructor or third-party content provider, whether hosted on the Platform or elsewhere and re-distributed through the Platform.

5.5 Unauthorised Distribution of Proprietary Study Materials:
Unauthorised sharing, distribution, or making publicly available of proprietary study materials, mock test question banks, model answer papers, notes, or any other educational materials that are designated as confidential, subscription-only, or restricted by their creators or publishers, including materials proprietary to coaching institutes, professional examination bodies such as the Institute of Chartered Accountants of India ('ICAI'), and individual subject matter experts.

5.6 Moral Rights Violations:
Acts that infringe the moral rights of an author, including attribution violations (failure to credit the original author), false attribution (incorrectly crediting authorship), and derogatory treatment of a work that is prejudicial to the honour or reputation of the author, as protected under Section 57 of the Copyright Act, 1957.

5.7 Other Intellectual Property Violations:
Any other violation of intellectual property rights not expressly enumerated above but recognised under applicable Indian law, including violations of design rights, performers' rights, and broadcast reproduction rights.

6. Submitting a Takedown Request

6.1 Submission Method:
A Takedown Request may be submitted to the Platform through any of the following channels:

• Email: support@intucate.com (subject line: 'Content Takedown Request – [Brief Description]')
• Physical mail addressed to the registered office of Dharia Enterprises Private Limited (address specified in Section 20 of this Policy)
• Any online grievance submission form as may be made available on the Platform from time to time

The Platform strongly recommends submission by email to ensure prompt acknowledgment and traceability. All Takedown Requests submitted by post must also be sent simultaneously by email to ensure timely processing.

6.2 Required Information in a Complaint
To enable the Platform to process a Takedown Request efficiently, completely, and in accordance with applicable law, the complainant must provide all of the following information:

6.2.1 Complainant's Identity

• Full legal name of the individual or entity submitting the request;
• Designation or role (e.g., author, publisher, licencee, legal counsel, authorised agent);
• Complete postal and email address;
• Contact telephone number;
• If submitting on behalf of an entity: name of the entity, the complainant's authority to act on its behalf (e.g., letter of authorisation, power of attorney, or employment verification).

6.2.2 Identification of the Copyrighted Work

• A clear and complete description of the original copyrighted work that is alleged to have been infringed;
• The title, author, publication date, and publisher or distributor of the work (where applicable);
• URL, ISBN, registration number, or any other reference that helps uniquely identify the original work;
• Where the copyright is registered: the registration number and jurisdiction of registration.

6.2.3 Identification and Location of the Infringing Content

• Specific URL(s) or deep link(s) on the Platform (web or mobile) where the allegedly infringing Content is located;
• A detailed description of the allegedly infringing Content sufficient to enable the Platform to locate it, in the event direct URLs cannot be provided;
• Screenshots or screen recordings (as attachments) showing the allegedly infringing Content in its context on the Platform;
• Course name, module name, or section heading (if applicable).

6.2.4 Evidence of Ownership

• Documentary evidence establishing the complainant's ownership of or authority over the rights allegedly infringed, which may include: copyright registration certificates, publication records, licensing agreements, affidavits of authorship, or such other documents as are reasonably available;
• Where the work is unpublished: a declaration of authorship with supporting evidence such as draft manuscripts, creation metadata, or correspondence.

6.2.5 Statement of Good Faith Belief
A written statement to the following effect:

"I have a good faith belief that the use of the copyrighted material described above, in the manner complained of, is not authorised by the copyright owner, its agent, or applicable law. I am the copyright owner or am authorised to act on behalf of the owner of the exclusive right that is allegedly infringed."

6.2.6 Legal Declaration
A declaration under penalty of perjury (or the equivalent civil or criminal liability under applicable Indian law, including Section 209 of the Indian Penal Code / Bharatiya Nyaya Sanhita, 2023 as applicable), that:

• The information in the notice is accurate;
• The complainant is authorised to make the complaint;
• The complainant accepts that submitting a materially false or misleading Takedown Request may result in legal liability.

A Takedown Request that does not include all required information may be returned to the complainant with a request to cure deficiencies before it is processed. The Platform is not obligated to process incomplete Takedown Requests.

7. Verification Process

Upon receipt of a Takedown Request, the Platform shall undertake the following verification steps:

• Acknowledgment: The Platform shall acknowledge receipt of the Takedown Request within twenty-four (24) hours of receipt on business days (Monday to Saturday, excluding public holidays).
• Completeness Check: The Platform's designated team shall review the Takedown Request to ascertain whether it contains all required information as specified in Section 6. Incomplete requests shall be returned within forty-eight (48) hours of receipt with a written description of the deficiencies.
• Prima Facie Review: Upon confirming completeness, the Platform shall conduct a prima facie review to determine: (a) whether the claim, on its face, plausibly alleges infringement; (b) whether the claimed copyrighted work and the infringing Content appear to match; (c) whether the complainant appears to have standing to file the request.
• Legal Assessment: Where necessary, the Platform may consult legal counsel or subject matter experts to assess the validity of the Takedown Request.
• No Obligation to Adjudicate: The Platform's verification process is not a substitute for judicial or quasi-judicial determination of copyright ownership or infringement. The Platform acts solely as an intermediary and does not guarantee the accuracy of the complainant's claims.

Notwithstanding the foregoing, in cases of clearly evident, egregious, or mass infringement (e.g., wholesale copying of entire course modules), the Platform reserves the right to expedite the takedown process and disable access to the contested Content pending full verification.

8. Takedown Procedure

Upon a successful prima facie review, the Platform shall take the following steps:

8.1 Temporary Disabling of Access
Within seventy-two (72) hours of completing its prima facie review and determining that the Takedown Request is bona fide and complete, the Platform shall temporarily disable access to the allegedly infringing Content on both the web platform and all mobile applications, pending final resolution.
Disabling access shall not permanently delete the Content from the Platform's servers during the resolution period, unless the parties agree otherwise or a court or competent authority orders permanent deletion.

8.2 Notification to the Content Uploader
Simultaneously with or promptly following the disabling of access, the Platform shall notify the User or Instructor who uploaded the Content ('Uploader') by:

• Sending a written notification to the Uploader's registered email address, informing them: (a) that a Takedown Request has been received regarding their Content; (b) that access to the Content has been temporarily disabled; (c) the general nature of the complaint; and (d) their right to submit a Counter-Notification in accordance with Section 10 of this Policy.

The Platform shall not, as a matter of standard practice, disclose the full personal details of the complainant to the Uploader, unless required by applicable law or a court order.

8.3 Internal Documentation
The Platform shall maintain a confidential internal log of all Takedown Requests received, including: date and time of receipt; identity of the complainant; the Content complained of; actions taken; and the outcome of the process.
Such records shall be retained for a minimum period as prescribed under applicable law and in accordance with the Company's data retention policies.

8.4 Communication of Outcome
Upon resolution of the matter (whether through takedown, restoration, or other outcome), the Platform shall notify both the complainant and the Uploader of the final outcome within a reasonable time.

8.5 Timeline Summary

9. Counter-Notification Process

An Uploader who believes, in good faith, that their Content was removed or disabled as a result of a mistake or misidentification, or that the Takedown Request was made in bad faith or without valid legal basis, may submit a Counter-Notification to the Platform.

9.1 How to Submit a Counter-Notification
A Counter-Notification must be submitted in writing to support@intucate.com with the subject line: 'Counter-Notification – [Course/Content Name]'.
The Counter-Notification must contain all of the following:

• The Uploader's full legal name, postal address, email address, and telephone number;
• Specific identification of the Content that has been removed or disabled, including its location on the Platform prior to removal (URL, course name, module name);
• A clear and detailed statement explaining why the Uploader believes the Takedown Request was erroneous, including: (a) evidence of the Uploader's original authorship or valid licence to use the Content; (b) reasons why the use falls within a permitted exception under the Copyright Act, 1957 (such as fair dealing for private study or research under Section 52);
• A statement under penalty of perjury (or equivalent liability under Indian law) that the Uploader has a good faith belief that the Content was removed or disabled as a result of mistake or misidentification;
• A statement consenting to the jurisdiction of the competent courts located in Mumbai, India for the resolution of disputes relating to the Takedown Request;
• The Uploader's physical or electronic signature.

9.2 Processing of Counter-Notification
Upon receipt of a valid Counter-Notification:

• The Platform shall acknowledge receipt of the Counter-Notification within twenty-four (24) hours on business days.
• The Platform shall forward the Counter-Notification to the original complainant within five (5) business days.
• The complainant shall have fourteen (14) calendar days from the date of receipt of the Counter-Notification to notify the Platform in writing whether they have initiated legal proceedings before a competent court or authority seeking to restrain the Uploader from engaging in the complained-of activity.
• If the complainant fails to notify the Platform of pending legal proceedings within the stipulated period, the Platform may, at its sole discretion, restore the removed Content.
• If the complainant notifies the Platform of pending legal proceedings within the stipulated period, the Platform shall maintain the disabled status of the Content until the matter is resolved by the competent court or authority or the parties reach a mutual settlement.

10. Content Restoration Procedure

Content that has been removed or disabled pursuant to a Takedown Request may be restored in the following circumstances:

• The complainant withdraws the Takedown Request in writing and confirms that they have no objection to the Content remaining on the Platform;
• A competent court, tribunal, or other authority issues an order directing the Platform to restore the Content;
• The Platform determines, following its review, that the Takedown Request was invalid, frivolous, or filed in bad faith;
• Following submission of a valid Counter-Notification and expiry of the complainant's response period without notification of legal proceedings, as described in Section 9.2;
• The complainant and the Uploader reach a mutual agreement (such as a licencing arrangement) and provide written confirmation thereof to the Platform;
• The Uploader successfully modifies the Content to remove the infringing elements and provides the Platform with satisfactory evidence of such modification.

The decision to restore Content is at the sole discretion of the Platform, acting in good faith and in accordance with applicable law.
Restoration shall not be construed as an admission that the original Takedown Request was invalid or that the Platform endorses or guarantees the legality of the restored Content.

11. Repeat Infringer Policy

Intucate maintains a strict policy against repeat infringement of intellectual property rights on the Platform. In furtherance thereof:

11.1 Tracking of Violations
The Platform shall maintain an internal record of Takedown Requests that have been upheld against individual Uploaders, whether Users or Instructors.
Each upheld Takedown Request shall constitute a 'strike' against the Uploader's account.

11.2 Graduated Response
The Platform shall apply the following graduated response system:

• First Strike: The Uploader shall receive a formal written warning from the Platform, which shall be sent to their registered email address. The Uploader's account shall remain active, subject to enhanced monitoring.
• Second Strike: The Uploader's ability to upload new Content to the Platform shall be temporarily suspended for a period of up to thirty (30) days. A written notice shall be issued specifying the reason for suspension.
• Third Strike (and beyond): The Uploader's account may be permanently suspended or terminated, at the Platform's sole discretion, with all associated Content disabled or removed. Refunds (if any) in such cases shall be governed by the Platform's Terms of Service and Refund Policy.

11.3 Instructor Accounts
Instructor accounts found to have repeatedly infringed intellectual property rights may, in addition to the above measures, have their instructor status revoked, their course listings removed, and their ability to re-register on the Platform restricted.

11.4 Right to Expedite
Notwithstanding the graduated response outlined above, in cases of severe, large-scale, or wilful infringement, the Platform reserves the right to immediately suspend or terminate an account upon the first validated complaint, without prior notice, and to report the matter to appropriate authorities.

12. False or Misleading Complaints

The Platform takes seriously the potential for abuse of the takedown process, including the filing of Takedown Requests that are deliberately false, fraudulent, exaggerated, or made in bad faith for the purpose of suppressing legitimate content, harassing competitors, or disrupting the educational activities of Uploaders.

Any person who knowingly and materially misrepresents, in a Takedown Request or Counter-Notification:

• That Content is infringing when it is not; or
• That Content was removed or disabled by mistake when it was not;

shall be liable for any and all damages (including costs and attorneys' fees) incurred by any person harmed by such misrepresentation, to the extent permissible under applicable Indian law.
The Platform may also report such conduct to relevant authorities.

The Platform reserves the right to reject, decline to act on, or flag as abusive any Takedown Request that, in its reasonable judgment, appears to be:

• Filed without a genuine, good-faith belief in infringement;
• Motivated by competitive or personal animus rather than legitimate intellectual property concerns;
• Filed with materially false or fabricated evidence of ownership;
• Targeting Content that clearly falls within statutory exceptions such as fair dealing, educational use, or criticism and commentary;
• Filed in a pattern consistent with coordinated abuse or harassment.

Complainants found to have filed materially false or misleading Takedown Requests may be denied the ability to file future Takedown Requests through the Platform and may be reported to law enforcement or relevant regulatory authorities.

13. Platform Rights and Discretion

Intucate reserves the right, at its sole discretion and without prior notice, to remove, disable, restrict access to, or permanently delete any Content hosted on the Platform that:

• Is the subject of a credible and complete Takedown Request;
• Is determined by the Platform, upon reasonable review, to be infringing or potentially infringing of the intellectual property rights of any third party;
• Violates the Platform's Terms of Service, Community Guidelines, or any other applicable policy;
• Is prohibited under applicable Indian law or any order of a competent court or authority;
• Poses a significant legal, reputational, or operational risk to the Platform, its Users, or its Instructors.

The Platform's decision to remove or disable Content shall not be construed as legal advice, a binding legal determination, or an adjudication of the merits of any intellectual property dispute between the complainant and the Uploader.
The Platform acts solely as an intermediary in good faith and in accordance with applicable law.
The Platform further reserves the right to modify, adapt, or supplement its content moderation policies, workflows, and decision-making frameworks from time to time, in response to changes in applicable law, technological developments, or evolving best practices, without prior notice to Users or Instructors.

14. Liability Limitations

Intucate operates as an intermediary platform and, as such, cannot reasonably monitor, review, or independently verify all Content uploaded by the large number of Instructors and Users on the Platform before such Content is published.
To the fullest extent permissible under applicable law, and subject to compliance with the provisions of the IT Act, 2000 and IT Rules, 2021:

• The Platform shall not be held liable for any intellectual property infringement committed by Instructors or Users through Content they upload or post on the Platform, provided that the Platform: (a) does not initiate the transmission of the infringing Content; (b) does not select the receiver of the transmission; and (c) does not modify the infringing Content in its transmission;
• The Platform's liability protection as an intermediary is conditional on: (a) the Platform acting expeditiously upon receiving knowledge of infringing Content through a valid Takedown Request or otherwise; (b) the Platform not conspiring with, aiding, or abetting Uploaders in infringing activities; and (c) the Platform complying with applicable governmental or judicial orders relating to the Content;
• The Platform makes no warranty, representation, or guarantee that the Content available on the Platform is free from infringement, errors, or inaccuracies, and Users and Instructors use the Platform's Content at their own risk;
• In no event shall the Platform be liable for any indirect, incidental, consequential, punitive, or exemplary damages arising out of or in connection with any intellectual property claim, to the extent permissible under applicable law.

Nothing in this section shall limit the Platform's liability for its own direct acts of infringement, gross negligence, or wilful misconduct.

15. Compliance with Indian Laws

This Policy is designed to ensure the Platform's full compliance with the following Indian legal frameworks:

15.1 The Information Technology Act, 2000
The Platform operates as an 'intermediary' within the meaning of Section 2(1)(w) of the IT Act, 2000, and seeks to avail of the safe harbour protections available under Section 79 of the IT Act, subject to compliance with the conditions prescribed therein and in the IT Rules, 2021.

15.2 The IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
In compliance with Rule 3 of the IT Rules, 2021, the Platform has:

• Published this Content Takedown Policy and all other applicable policies in a prominent location on the Platform;
• Appointed a Grievance Officer whose contact details are set out in Section 20 of this Policy;
• Established a mechanism for receiving and resolving complaints within prescribed timelines.

15.3 The Copyright Act, 1957
The Platform acknowledges and respects the rights of Copyright Owners as defined under the Copyright Act, 1957, including the exclusive rights of reproduction, distribution, performance, and communication to the public.
The Platform shall act on valid Takedown Requests expeditiously in accordance with its obligations as an intermediary under applicable law.
The Platform also acknowledges the doctrine of fair dealing under Section 52 of the Copyright Act, 1957, which permits certain acts (such as private study, research, criticism, and review) that do not constitute infringement, and shall take such provisions into account when evaluating Takedown Requests.

15.4 The Trade Marks Act, 1999
The Platform shall act on valid Takedown Requests relating to trademark infringement in a manner consistent with the protections afforded to registered and unregistered trademark owners under the Trade Marks Act, 1999.

16. Data Privacy and Confidentiality

The Platform collects and processes personal data submitted as part of Takedown Requests and Counter-Notifications in accordance with its Privacy Policy and applicable data protection laws, including the Digital Personal Data Protection Act, 2023 ('DPDP Act'), to the extent in force.
Specifically:

• Personal data submitted by complainants (including name, contact details, and ownership evidence) shall be used solely for the purpose of processing the Takedown Request and any related legal proceedings, and shall not be disclosed to third parties except: (a) to the Uploader, to the extent necessary to facilitate the Counter-Notification process; (b) to law enforcement or regulatory authorities, in response to a valid legal demand; or (c) as required by a court order or applicable law.
• Personal data submitted by Uploaders in Counter-Notifications shall be used solely for the purpose of processing the Counter-Notification and may be shared with the complainant to the extent necessary for them to assess the Counter-Notification.
• The Platform shall implement appropriate technical and organisational security measures to protect personal data submitted in the context of Takedown Requests and Counter-Notifications from unauthorised access, disclosure, alteration, or destruction.
• Personal data relating to Takedown Requests and Counter-Notifications shall be retained for a minimum period as required by applicable law and in accordance with the Platform's data retention schedule.

Individuals whose personal data is processed in connection with a Takedown Request or Counter-Notification may exercise their rights under applicable data protection law, including the right to access, correct, and (where applicable) erase their personal data, by writing to the Platform at support@intucate.com.
For further details on how the Platform handles personal data, please refer to the Platform's Privacy Policy available at www.intucate.com/privacy-policy.

17. Cooperation with Authorities

Dharia Enterprises Private Limited and the Intucate Platform are committed to cooperating fully with law enforcement agencies, governmental authorities, regulatory bodies, and courts of competent jurisdiction in connection with investigations or proceedings relating to intellectual property violations or any other unlawful activity on the Platform.
In furtherance thereof:

• The Platform shall comply with any valid court order, judicial summons, search warrant, or similar legal process requiring it to produce, preserve, or destroy specific Content or disclose information relating to Users, Instructors, or Platform activities;
• The Platform shall cooperate with the Ministry of Electronics and Information Technology ('MeitY'), the Copyright Office of India, the Intellectual Property India ('IP India') body, or any other competent governmental or regulatory authority in connection with investigations relating to intellectual property violations on the Platform;
• The Platform may proactively report to law enforcement any cases of large-scale piracy, wilful infringement, or fraudulent misuse of the takedown process discovered in the course of its operations, where it reasonably determines that such reporting is warranted in the public interest;
• The Platform shall maintain records of Takedown Requests and Counter-Notifications for such periods as may be required by applicable law and shall make such records available to law enforcement or regulatory authorities upon receipt of a valid legal demand.

Any requests for information or assistance from law enforcement or regulatory authorities shall be directed to the Platform's legal counsel through the Grievance Officer designated in Section 20 of this Policy.

18. Policy Updates

The Platform reserves the right to amend, update, or revise this Policy at any time, without prior notice, in order to reflect:

• Changes in applicable Indian or international law;
• Amendments to governmental regulations or guidelines affecting intermediaries and digital platforms;
• Technological developments that affect the Platform's content moderation capabilities;
• Changes in the Platform's operational structure, business model, or services;
• Feedback from Users, Instructors, Copyright Owners, or legal advisors;
• Best practice developments in the EdTech or digital platform industry.

Any material changes to this Policy shall be communicated to registered Users and Instructors via:

• A prominent notice on the Platform's homepage and within Users' and Instructors' account dashboards;
• An email notification to the registered email addresses of Users and Instructors;
• An update to the 'Effective Date' appearing on this Policy.

Continued use of the Platform following the posting of any such amendments shall constitute acceptance of the revised Policy.
Users and Instructors who do not agree with any updates to this Policy are advised to discontinue use of the Platform and contact the Platform to close their accounts.
All previous versions of this Policy shall be archived and made available upon request for a period of not less than three (3) years from the date of supersession.

19. Special Provisions for Educational and CA Examination Content

Given the Platform's specialised focus on Chartered Accountancy education and examination preparation, the following additional provisions shall apply:

19.1 ICAI Material
Content that reproduces, adapts, or distributes materials published or copyrighted by the Institute of Chartered Accountants of India ('ICAI'), including study materials, practice manuals, suggested answers, revision test papers, mock test papers, and any other ICAI-branded materials, without the express written licence of ICAI, shall be treated as Infringing Content and shall be subject to expedited takedown upon receipt of a valid Takedown Request from ICAI or its authorised representative.

19.2 Publisher and Author Rights
Content that reproduces substantial portions of textbooks, reference books, or study guides published by recognised academic publishers in the CA curriculum (such as, by way of example only, ICAI publications, or privately authored reference books) without authorisation shall be subject to this Policy.
Instructors are advised to obtain appropriate licences before including third-party published content in their course materials.

19.3 Fair Dealing in Education
The Platform acknowledges that Section 52(1)(a) of the Copyright Act, 1957 permits fair dealing with a work for the purposes of private or personal use, including research, criticism, or review.
Instructors and Users who believe their Content constitutes fair dealing are encouraged to provide clear justification for such a claim in any Counter-Notification, including the nature and extent of the use and its impact on the market for the original work.

19.4 Anti-Piracy Measures
To actively combat piracy of educational content on the Platform, Intucate:

• Employs digital watermarking and access control technologies to deter unauthorised recording or distribution of video lectures;
• Prohibits screen recording and downloading of premium course content through technical measures and contractual restrictions in its Terms of Service;
• Cooperates with content protection agencies and educators to monitor and address the unauthorised redistribution of course materials on other platforms;
• Provides Instructors with reporting tools to flag potential piracy of their content on or off the Platform.

20. Contact Information

All Takedown Requests, Counter-Notifications, and enquiries relating to this Policy should be directed to:

When submitting a Takedown Request by email, please use the subject line: 'Content Takedown Request – [Brief Description of Content]' to ensure prompt routing to the appropriate team.
The Grievance Officer is required to be appointed in compliance with Rule 3(2) of the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The appointment details shall be updated on this Policy and on the Platform's website as soon as the appointment is made.
The Grievance Officer shall acknowledge complaints within twenty-four (24) hours and resolve them within fifteen (15) days of receipt, in accordance with applicable law.

21. Effective Date

This Content Takedown Policy is effective as of April 2026 and supersedes all prior policies, guidelines, or procedures of Dharia Enterprises Private Limited relating to intellectual property complaints and content removal on the Intucate Platform.
This Policy shall remain in effect until amended or withdrawn by the Company in accordance with Section 18 of this Policy.