(c) Location of Data Centres (xv) Clause 4 provides that the data centres where the data is stored are geographically located in different jurisdictions. Location data can also be stored either on cloud or on secret chats. (xvi) The servers for the EEA or UK are located in the data centres in Netherlands. (xvii) Clause 8.2 provides that Telegram may share a user’s personal data with its parent company, Telegram Group Inc. in the British Virgin Islands and Telegram FZ-LLC a group member in Dubai, to provide, improve and support its services. It notes that appropriate safeguards as per a European Commission approved agreement between Telegram and its group companies, will be implemented during such data sharing. (d) Spam, Phishing, etc. (xviii) Clause 5.2 provides that for the purpose of safety and security, to prevent spam, abuse and other violations of Telegram’s Terms of Service, Telegram may collect metadata such as IP address of the user, devices used by the user, history of username changes, etc. Such data can be stored for 12 months. (xix) Clause 5.3 notes that spamming, phishing and other kind of abuse is barred on Telegram. If there is a report of spam, which is confirmed by Telegram’s moderators, temporary or permanent disablement can take place. The account may also be finally banned. In order to stop spamming and phishing, Telegram can also use automated algorithms to analyse messages. Signature Not Verified Digitally Signed By:DEVANSHU JOSHI Signing Date:31.08.2022 12:12:31 CS (COMM) 282/2020 Page 18 of 51