Canada’s Anti-Spam Legislation (CASL)

Metanova Tech Private Limited and/or its associated companies (referred to collectively as "Metanova Tech")

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Policy Statement

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This document delineates the policy of Metanova Tech and aims to provide reasonable assurance that (i) a consistent process is adhered to concerning the distribution of commercial electronic messages to Metanova Tech clients and prospective clients in Canada, and (ii) Metanova Tech employees sending commercial electronic messages from and/or to computer systems in Canada comply with the requirements of CASL.

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The Metanova Tech Anti-Spam Policy ("Anti-Spam Policy") and associated procedures (the "CASL Procedures") mandate that all Metanova Tech employees sending CEMs from and/or to computer systems in Canada or to an electronic address that will be accessed from a computer system in Canada comply with CASL. This policy also aims to ensure that all CEMs sent by or on behalf of Metanova Tech, or using a Metanova Tech email address or device, adhere to CASL.

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Policy Details

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The Anti-Spam Policy outlines Metanova Tech’s commitments regarding the provisions of CASL and electronic messages of a commercial nature sent to Metanova Tech clients, prospective clients, and others, as applicable. Metanova Tech may periodically introduce additional policies, procedures, and practices related to anti-spam measures.

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Application

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This Policy applies to Metanova Tech employees who may be sending CEMs from and/or to computer systems in Canada or to an electronic address that will be accessed from a computer system in Canada. The Anti-Spam Policy has been adopted in compliance with CASL requirements for Metanova Tech's operations, and Metanova Tech is dedicated to complying with CASL. All other Metanova Tech policies and procedures will be construed in a manner consistent with the Anti-Spam Policy to promote compliance with CASL and deter damaging and deceptive forms of spam in Canada.

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Consent

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Metanova Tech obtains express, opt-in consent before sending a CEM to anyone who has not had an existing business relationship with Metanova Tech within two years before the date on which the CEM is sent. The request for consent must be distinct from other communications and cannot be bundled as a term of acceptance of an agreement. Verbal consent is acceptable, provided that a record of the details of the consent is maintained in a database.

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Form and Content of CEMs

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All CEMs must comply with the form and content requirements of CASL, including identifying the sender, providing the sender’s contact information, and including an unsubscribe mechanism.

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Storage of Relationship Details

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Metanova Tech is obligated to maintain records of its relationships with clients and prospective clients, including records of express, opt-in consent and relationships giving rise to implied consent. These records are retained for a minimum of three years after Metanova Tech ceases sending CEMs to the client or prospect.

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Commercial Electronic Messages

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All Metanova Tech employees sending CEMs from and/or to computer systems in Canada are required to comply with this Policy and related CASL procedures. Certain messages, such as those sent to existing clients about their business or internal communications about Metanova Tech's business, may be exempt from CASL requirements.

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Compliance by Third Parties

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Third-party contracts with service providers who may send CEMs on behalf of Metanova Tech must contain clauses obligating the service provider to comply with CASL.

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Unsubscribe Mechanism

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CEMs must include an unsubscribe mechanism to facilitate the withdrawal of consent or do-not-contact requests within 10 days of the request. Recipients can unsubscribe from CEMs at any time by following the provided instructions.

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Policy Administration

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The Anti-Spam Policy is managed by the Compliance department of each Metanova Tech legal entity and is reviewed and updated as necessary on an annual basis. Any changes to or exceptions from this Policy require approval from the respective Metanova Tech Board or equivalent.

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Review and Approvals

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Metanova Tech Compliance is responsible for reviewing and revising this Policy, subject to approval from the respective Metanova Tech Board or equivalent. The Policy is subject to review on an annual basis or as needed.

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Enforcement and Audit

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Compliance with this Policy may be audited by Metanova Tech at any time. Failure to comply may result in disciplinary action in accordance with Metanova Tech's disciplinary policy or procedure.

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End of Policy