(x) Clause 7.2 notes that credit card information submitted through payment gateways for premium services is not made available to Telegram and the said data is not stored. (xi) Clause 9.3 notes that minimal data may be required for the Telegram application to function in a secured manner. (xii) Clause 2 provides that the data collected is processed to further Telegram’s legitimate interest, including for the provision of effective and innovative services, detection, prevention of fraudulent activities, and security related concerns. (xiii) As per clause 2 of the Privacy Policy, processing of personal data is done unless the user’s overriding interest is to be protected or the fundamental rights mandate protection of the personal data. The relevant clause is as under: “We process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (1) providing effective and innovative Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.” (xiv) A section of the Privacy Policy deals with the rights of the user in respect of personal data under Clause 9.1. If a user wishes to seek deletion or a copy of the data, amendment of the data, object to the processing of the data and correct any data or lodge a complaint with the National Data Protection Authority, a specific link has been provided for contacting Telegram. Signature Not Verified Digitally Signed By:DEVANSHU JOSHI Signing Date:31.08.2022 12:12:31 CS (COMM) 282/2020 Page 17 of 51

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