GRIEVANCE REDRESSAL POLICY
Hunch — operated by CMA Solutions LLP
Document Reference: HUN-LEG-GRP-V3.0 Version: 3.0 (Draft for attorney review) Effective Date: [TO BE INSERTED] Last Updated: [TO BE INSERTED]
NOTICE — DRAFT INSTRUMENT. For counsel review before publication. Not legal advice.
1. PURPOSE
1.1 This Grievance Redressal Policy ("Policy") establishes the mechanism through which CMA Solutions LLP ("Company") receives, investigates, and resolves complaints, concerns, and grievances raised by Users of the conversational AI service marketed as "Hunch" (the "Service").
1.2 This Policy is published in compliance with: (a) Rule 5(9) of the SPDI Rules, 2011; (b) the Digital Personal Data Protection Act, 2023 ("DPDP Act"), Section 8(10) (mechanism to redress grievances); (c) the Consumer Protection Act, 2019, and the E-Commerce Rules, 2020; (d) Section 13(2) of the Mental Healthcare Act, 2017, in respect of complaints relating to professional referrals (Version 2).
1.3 This Policy is a Constituent Document under the Terms of Service (HUN-LEG-TOS-V3.0).
2. GRIEVANCE OFFICER AND DATA PROTECTION OFFICER
2.1 The Company has appointed the following officer as Grievance Officer pursuant to Rule 5(9) of the SPDI Rules and as Data Protection Officer pursuant to Section 8(5) of the DPDP Act:
| Particular | Detail |
|---|---|
| Name | Sanhit Jain |
| Designation | Grievance Officer and Data Protection Officer, CMA Solutions LLP |
| support@use-hunch.com | |
| Telephone | +91 9667674105 (Monday to Friday, 10:00 to 18:00 IST) |
| Postal address | Kh No. 316/274, Ground Floor, Front Side Saidulajab, Western Marg, near Lane No. 3, Gadaipur, Saidulajab, New Delhi, South West Delhi – 110030, India |
2.2 The Company shall transition to an independent India-resident Data Protection Officer, distinct from the Grievance Officer, upon the earlier of: (a) classification of the Company as a Significant Data Fiduciary under Section 10 of the DPDP Act; or (b) the closing of an institutional fundraising round of the Company.
3. CATEGORIES OF GRIEVANCE
3.1 This Policy covers, without limitation, the following categories:
(a) Data-privacy grievances — unauthorised collection, processing, sharing, or retention of Personal Data; failure to honour consent withdrawal or deletion requests; concerns relating to a personal-data breach.
(b) Service grievances — service-quality issues; inaccurate Service outputs; technical failures; response-time delays.
(c) Payment grievances — transaction failures; billing errors; refund claims under the Refund Policy (HUN-LEG-RP-V3.0).
(d) Content grievances — content generated by the Service that is offensive, harmful, inappropriate, or contrary to the Disclaimer.
(e) Professional-referral grievances (Version 2 only) — concerns relating to a Professional referred through the Service, the conduct of an Engagement, the accuracy of the Behavioural Brief, or the Handoff process.
(f) Consumer-protection grievances — misleading claims, unfair trade practices, or other concerns under the Consumer Protection Act, 2019.
4. FILING A GRIEVANCE
4.1 A User may file a grievance through any of the following channels:
(a) Email: support@use-hunch.com with subject line "GRIEVANCE: [brief description]".
(b) WhatsApp / Telegram: message "COMPLAINT" or "SHIKAYAT" to the Service.
(c) Telephone: +91 9667674105 during business hours.
(d) Post: Grievance Officer, at the address in Clause 2.1.
4.2 Where practicable, the User shall include with the grievance: (a) the User's name and phone number for identification; (b) the date and approximate time of the issue; (c) a detailed description of the grievance; (d) supporting evidence (screenshots, transaction identifiers, message references); (e) the relief or resolution sought.
5. RESOLUTION PROCESS
5.1 Acknowledgement. Each grievance shall be acknowledged within forty-eight (48) hours of receipt, with a unique Grievance Reference Number ("GRN"). The acknowledgement shall be sent through the channel of receipt.
5.2 Investigation. The Grievance Officer shall investigate the grievance, consulting internal teams as required, and may request further information from the User.
5.3 Timelines.
| Category | Resolution Timeline |
|---|---|
| Standard grievance | Within thirty (30) days of receipt (Rule 5(9) of the SPDI Rules) |
| Payment-related grievance | Within seven (7) to ten (10) business days of receipt |
| Personal-data breach grievance | Acknowledged within twenty-four (24) hours; resolved in accordance with the Breach Notification Protocol |
| Professional-referral grievance (Version 2) | Investigated within seven (7) calendar days |
| Emergency or safeguarding grievance | Escalated immediately |
5.4 Communication of outcome. The Company shall communicate the resolution in writing (email or message). Where resolution requires more than thirty days, the User shall be informed of the reason and an estimated revised timeline.
5.5 Right to reject. The User may reject the proposed resolution and escalate in accordance with Clause 6.
6. ESCALATION MATRIX
6.1 The Company maintains a four-level escalation matrix:
| Level | Authority | Timeline |
|---|---|---|
| Level 1 | Grievance Officer (Sanhit Jain), CMA Solutions LLP — support@use-hunch.com | 30 days |
| Level 2 | Designated Partner (other than the Grievance Officer), CMA Solutions LLP | 15 days following Level 1 failure |
| Level 3 (Recommended addition) | Independent Ombudsperson — to be appointed in due course | 21 days following Level 2 failure |
| Level 4 — Statutory recourse | Statutory authority (see Clause 7) | As per applicable statutory process |
6.2 The User's right to approach a statutory authority is not contingent on exhaustion of the internal escalation matrix.
7. EXTERNAL ESCALATION OPTIONS
7.1 If the User is dissatisfied with the Company's resolution, the User may escalate to:
(a) Data Protection Board of India — for data-privacy grievances under the DPDP Act, upon the Board becoming operational;
(b) Consumer Disputes Redressal Commission (District / State / National) — under the Consumer Protection Act, 2019;
(c) National Consumer Helpline — 1800-11-4000 or 14404;
(d) Cyber Crime Reporting Portal — cybercrime.gov.in for data breach or cyber fraud concerns;
(e) Cyber Crime Helpline — 1930;
(f) Rehabilitation Council of India — for Professional-conduct concerns (Version 2);
(g) Advertising Standards Council of India — for advertising-content concerns;
(h) A court of competent jurisdiction at New Delhi, India.
7.2 Statutory escalation does not preclude internal escalation, and the User may pursue both in parallel.
8. SPECIAL PROCEDURES
8.1 Data-breach grievances. Acknowledged within twenty-four (24) hours; incident-response team activated; Data Protection Board notified within seventy-two (72) hours pursuant to the DPDP Rules; affected Users notified as soon as practicable; post-incident report supplied to the complainant.
8.2 Payment grievances. Refunds for transaction failure or duplicate charge processed within seven (7) to ten (10) business days of verification, in accordance with the Refund Policy. Razorpay dispute mechanism invoked where applicable.
8.3 Professional-referral grievances (Version 2). Investigated within seven (7) calendar days. The Professional may be suspended from the directory pending investigation. The User shall be offered an alternative Professional where appropriate. The RCI shall be notified where professional misconduct is reasonably suspected.
8.4 Safeguarding grievances. Where a grievance discloses an immediate risk to life or safety, the Grievance Officer shall direct the User to the emergency contacts set out in the Disclaimer and shall offer to facilitate professional intervention. Such matters are treated as priority.
9. GRIEVANCE LOG AND RECORD-KEEPING
9.1 The Company maintains a grievance log recording, in respect of each grievance: (a) the GRN; (b) date and channel of receipt; (c) category; (d) summary of the complaint; (e) investigation steps; (f) resolution provided; (g) date of resolution; (h) User-satisfaction status.
9.2 Grievance logs are retained for three (3) years and are available for regulatory audit pursuant to the Data Retention and Deletion Policy.
10. NON-RETALIATION
10.1 The Company guarantees that: (a) no User shall face adverse consequences for filing a grievance; (b) the filing of a grievance shall not affect a User's access to the Service or the quality of service provided; (c) all grievances are treated confidentially; (d) grievance details shall not be shared with any third party save as required for resolution or by Applicable Law.
11. ACCESSIBILITY
11.1 The Company shall provide assistance to Users requiring alternative-format submission of grievances in compliance with the Rights of Persons with Disabilities Act, 2016. Requests may be made by email to support@use-hunch.com.
12. AMENDMENTS
12.1 The Company may amend this Policy from time to time. Amendments shall be notified in accordance with Clause 16 of the Terms of Service.
13. CONTACT
CMA Solutions LLP LLPIN: ACP-6029 Email: support@use-hunch.com Telephone: +91 9667674105 Postal address: as in Clause 2.1.
SCHEDULE 1 — REVISION HISTORY
| Version | Date | Summary |
|---|---|---|
| 2.0 | 16 May 2026 | Initial draft |
| 3.0 | [date] | Counsel-ready draft; Level-3 independent ombudsperson added; SDF transition note (G-4); safeguarding category |
END OF GRIEVANCE REDRESSAL POLICY.
Draft for attorney review. Not legal advice.