KFintech e-voting System

1. Copyright Policy
2. Hyperlinking Policy
3. Privacy Policy
4. Content ownership, moderation & approval policy (COMAP)
5. Content review policy (CRP)
6. Content retention policy and Content Archival Policy
7. Data Retention Policy
8. Feedback Policy
9. Security policy
10. Contingency Management plan
11. Website Monitoring policy

This website is owned and operated by KFin Technologies Limited. The material, all design, text and images on the website, therein called “the Site”, is protected by copyright and trademark laws. You may access the Site in several ways, including but not limited to the World Wide Web.

The use of the Site is subject to the following terms and conditions

No one is permitted to copy, broadcast, download, store (in any medium), transmit, show or play in public, adapt or change in any way the content of these web pages for any other purpose whatsoever without the prior written permission of KFintech

KFintech has taken reasonable care to make sure that the information appearing on the web site is accurate and up to date. However, the accuracy of the information may not be taken for granted, because we do not have control over the use to which the information should be put, we do not warranty, expressly or impliedly, as to the quality, accuracy, timeliness, completeness, performance, fitness for a particular purpose of the web site or any of its contents.

We will not be liable for any damages (including without limitation damages for loss of profit, revenue or anticipated savings) arising in contract, tort or otherwise from the use of or inability to use the web site or any of its contents or from any action taken (or refrained from being taken) as a result of using the web site or any such contents. The contents of this website cannot be used in any misleading or objectionable context.

It is our policy to respond to notices of alleged infringement that comply with The Indian Copyright Act, 1957. Responses to these notices may include removing or disabling access to Website including Hyperlinks, for websites claimed to be involved in infringing activity, and/or terminating accounts. KFintech will make an attempt in good-faith to contact the owner or administrator of the affected website so that they may make a counter notification pursuant to the “The Indian Copyright Act, 1957 as amended up to date.

KFintech respects the intellectual property rights of others and requires that Site users do the same. In case you find any infringement, you may notify us. You may keep in mind that vague, wild and bald allegation may be taken seriously as it can tarnish the image, reputation and goodwill of KFintech

While notifying provide information, if possible, sufficient enough to permit KFintech to notify the owner/administrator of the allegedly infringing webpage or other content (email address is preferred). Include the following statement: "I have a good faith belief that use of the copyrighted materials described above as allegedly infringing is not authorized by the copyright owner, its agent, or the law." Include the following statement: "I swear, under penalty of jury, that the information in the notification is accurate and that I am the copyright owner or am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed."

Send the written communication to the following address (by certified mail):
♦  KFin Technologies Limited, Selenium Tower B, Plot Nos. 31 & 32 | Financial District Nanakramguda |Serilingampally Mandal | Hyderabad - 500032

We reserve the right to send your notice to one or more third parties who may make it available to the public.

Links to external websites/portals

Hyper linking is of two categories, providing links to external websites and the second one is linking pages with in the website. The policies governing the respective links are given below.

At many places in this website, you may find links to other websites/portals. These links have been placed for your convenience. KFin Technologies Limited is not responsible for the contents and reliability of the linked websites and does not necessarily endorse the views expressed in them. Mere presence of the link or its listing on this website should not be assumed as endorsement of any kind. We cannot guarantee that these links will work all the time and we have no control over availability of linked pages.

At many places in the website there are links pointing to other pages of the website. Website administrator is responsible to ensure that the links work all the time. From time to time or whenever there is an up gradation, revision change, and change in hardware on which the application is hosted the administrator checks the website for any broken links with-in the website and make necessary corrections if required.

Links to the KFin Technologies Limited E voting website by other websites /portals

Prior permission is required before hyperlinks are directed from any website/portal to thi site. Permission for the same, stating the nature of the content on the pages from where the link has to be given and the exact language of the Hyperlink should be obtained by sending the request to website manager as per the contact us section in the website.

Thanks for visiting the website https://evoting.kfintech.com. We collect NO personal information, like names or addresses, when you visit our website.

Information collected and stored automatically

The information we collect and store about your visit is listed below:

• The Internet domain of your service provider (e.g. mtnl.net.in)and IP address
• The date and time you accessed our site
• The pages/URLs you have visited and
• The referring website from which you had come to visit the website.

Cookies

Cookies used do not collect personal information and are non-persistent. Cookies are not used to determine the personal identity of anyone who is merely visiting Site.

Collection and use of Personal information

KFIN TECHNOLOGIES LIMITED only collects information that is provided to it voluntarily when a user completes the user's name, address and any additional details the user chooses to provide electronically in any applications, e-mails or use of the "Contact us" portions of this Site. Users do not have to give KFIN TECHNOLOGIES LIMITED personal information to visit this site. KFIN TECHNOLOGIES LIMITED has implemented information security measures to protect this information and keep it in strictest confidence. KFIN TECHNOLOGIES LIMITED does not provide any representations, warranties or guarantees that personal information so volunteered will be protected against loss, misuse or alteration.

KFIN TECHNOLOGIES LIMITED may retain the content of electronic submissions, applications, emails or other use of the "Contact us" portions of this Site, including the e-mail address from which the transmission was sent and responses thereto in order to handle any follow-up. A user is deemed to have provided the user's permission to the collection and use of information for the purposes set out herein by using the site.

Email management - collection of Personal Information:

Currently KFIN TECHNOLOGIES does not record any of the personal details such as Email ID. But In future if we need to send out any communicate your email address will be recorded if you choose to disclose. The email ID so collected will only be used for the purpose for which you have provided it and will not be added to a mailing list. Your email address will not be used for any other purpose, and will not be disclosed, without your consent.

If you are asked for any other Personal Information you will be informed how it will be used if you choose to give it. If at any time you believe the principles referred to in this privacy statement have not been followed, or have any other comments on these principles, please notify the webmaster through the contact us page. Note: The use of the term “Personal Information” in this privacy statement refers to any information from which your identity is apparent or can be reasonably ascertained.

Site Security

KFIN TECHNOLOGIES LIMITED has taken steps to safeguard the integrity of the data and prevent unauthorized access. These measures are designed to prevent corruption of data, block unknown or unauthorized access to our systems and information, and provide reasonable protection of private information in our possession.

Entire content published on the e-voting website is thoroughly checked, reviewed, verified and approved. Also, the website Manager ensures that the content is latest and Authentic.

The https://evoting.kfintech.com of KFin Technologies Limited represents multiple divisions/Departments. We hereby adopt 3-tiered structure to implement CMAP needing minimum 3 officials to execute the CMAP roles, viz.,

• Contributor
• Moderator
• Approver

Section	Roles
	Contributor	Moderator	Approver
Background information	Rajitha Cholleti - Client Co- ordination V Balakrishnan - Client Co- ordination	M Pavan Prakash – IT	MRV Subrahmanyam - Operations Head
Policies (relevant DARPG guidelines clause)	Ishrath - Manager - CISO team	T Umesh – IT	Srinivas Yadav Karra - CISO
Responsibility and Authority ( website management team)	M Pavan Prakash - IT	M Sreejith - IT	T Mallikarujuna - IT Head
Plans	Ishrath - Manager - CISO team	T Umesh – IT	Srinivas Yadav Karra - CISO
Organization Structure	M Pavan Prakash - IT	M Sreejith - IT	T Mallikarujuna - IT Head
Compliance statement	Ishrath - Manager - CISO team	T Umesh – IT	Srinivas Yadav Karra - CISO
Miscellaneous	M Pavan Prakash - IT	M Sreejith - IT	T Mallikarujuna - IT Head

KFIN TECHNOLOGIES LIMITED understands that the content of the website needs to be reviewed and updated as and when needed. As per KFIN TECHNOLOGIES , content policy procedure is to be reviewed and uploaded as and when the need arises.

KFIN TECHNOLOGIES LIMITED e-Voting System does have Archival policy which ensure the data is Archived every 1 year. Website Manager ensures that the data is Archived every 1 year with proper security and Storage.

Once the Scrutinizer issues the Results. The same will be published by the Company within 3 days of the Closure of General Meeting. The data will be maintained for 1 year from the General body Meeting.

Feedback from the visitors is the best way to judge a website’s performance and make necessary improvements. KFIN TECHNOLOGIES has an customer satisfaction analysis process and the results will be analyzed to carry out the changes and enhancements as suggested by the visitors. The Queries raised through Feedback form will be at evoting@kfintech.com. An auto acknowledgement gets triggered to the Shareholders. The same will be redressed within 24hrs or maximum within a week time.

KFIN TECHNOLOGIES LIMITED ’s e-Voting system handles critical activity of on line voting of investors. E- voting is also time critical. The lapse or failure to deliver the vote in time for voting to the scrutinizer may lead to loss of vote. Hence, an Internet application for electronic voting necessarily demands an elaborate and robust infrastructure that ensures efficient execution, secured processing and guaranteed delivery of transactions.

Physical Security

Our servers are hosted in CtrlS Datacenter, Hyderabad. We have taken the Rack Space, Power and Physical Security with CtrlS and Hosting of Server maintained by KFin Technologies Limited only. The building is equipped with Physical Security and Biometric access to ensure that there is no entry by unauthorized personnel.

Connectivity

The hosting facility is “carrier neutral”, with redundant connections from multiple service providers.

Data Security and Back-up

All data is located on secure servers that are continually monitored and maintained. All operating systems and applications are maintained at recommended patch levels for the highest level of operating system security possible.

As per our Backup policy daily full, weekly full, and monthly full backups are taken on tape media. Back-ups taken on tape media are stored at off-site at a secure location in a lock and key of the fireproof cabinet.

Perimeter Defence

All servers are monitored round the clock for attempted network attacks. Industry standard Intrusion Detection Systems (IPS Systems) are employed to ensure that any breach of the perimeter defence is detected and dealt with immediately.

System Redundancy

The data is stored in high available Raid 1 configuration in SAN configuration. Complete redundancy is built-in at every point.

SSL Data Transmission Security

The highest level of SSL browser encryption is used to ensure that all sensitive data transmissions between the customers and e-Voting system. We use SHA 3 512 128 bit encryption for password encryption and SSL

RSA 2048 Bit encryption for encrypted data transmission between the user system and application

Defacement of the website: 8.3.1

All possible security measures are taken for the application to prevent any possible defacement/hacking by unscrupulous elements. KFIN TECHNOLOGIES LIMITED employees state of the art IPS and perimeter security devices to ensure the protection. However, if despite the security measures in place, such an eventuality occurs, and if it has been established beyond doubt that the website has been defaced, the site will be immediately blocked and the DR site will be switched on. The web management team will conduct the Root cause analysis and the security assessment, website manager will take appropriate actions based on the outcome of Security Assessment.

Data Corruption: 8.3.2

Data base is backed up Daily ,Weekly and Monthly basis as per our Backup Policy.

Hardware/Software Crash: 8.3.3

The application and data base are hosted on hardened servers and are hosted on high availability servers. In the unlikely event of server crash the site can be hosted on to a DR server.

Natural Disasters: 8.3.4

KFIN TECHNOLOGIES LIMITED has a DR policy and plan to quickly recover the operations.

There could be circumstances whereby due to some natural calamity, the entire data centre where the website is being hosted gets destroyed or ceases to exist. A well planned contingency mechanism is in place for such eventualities whereby it is to be ensured that the Hosting Service Provider (KFIN TECHNOLOGIES LIMITED) has a‘Disaster Recovery Centre (DRC)’ set up at a geographically remote location and the website is switched over to the DR Server with minimum delay. The Wesbsite manager declares the disaster and manages the switch over.

Website is monitored on a Monthly in accordance with the plan to address and fix the quality and compatibility issues around the following parameters:

Performance: a. Site download time is optimized for a variety of network tested for this. (Refer the site performance report)

Functionality: b. All modules of the website should be tested for their functionality. Moreover, interactive components of the site such as discussion boards, opinion polls, feedback forms etc. should be working smoothly.

Broken Links: c. The website will be thoroughly reviewed by the website manager to rule out the presence of any broken links or errors.

Traffic Analysis: d. The site traffic will be regularly monitored to analyse the usage patterns as well as visitors’ profile and preferences. Traffic Analysis tools also give reports on broken links.

Feedback: e. Feedback from the visitors is the best way to judge a website’s performance and make necessary improvements. KFIN TECHNOLOGIES has an customer satisfaction analysis process and the results will be analyzed to carry out the changes and enhancements as suggested by the visitors.