Cookie Policy

PART I – PRELIMINARY PROVISIONS

1. Introduction

Welcome to ConsulTOpen.

This Cookie & Data Retention Policy ("Policy") explains how ConsulTOpen uses, stores, manages, retains and deletes Cookies and similar technologies while providing access to the Platform.

ConsulTOpen is committed to maintaining transparency regarding the technologies used to improve Platform functionality, enhance User experience, strengthen security, analyse Platform performance and comply with applicable legal obligations.

This Policy governs the collection, storage, retention, deletion and management of Cookies, Browser Storage, Local Storage, Software Development Kits (SDKs), Device Identifiers, Pixel Technologies, Web Beacons and every other similar technology presently used or introduced in the future.

This Policy also explains the categories of Cookies used by ConsulTOpen, the purposes for which they are used, the duration for which they may be retained, the rights available to Users regarding Cookie Preferences and the circumstances under which third-party technologies may interact with the Platform.

Nothing contained in this Policy shall be interpreted as limiting ConsulTOpen's unrestricted right to introduce, modify, replace, discontinue or enhance Cookie Technologies or similar technologies in accordance with applicable law and the Terms & Conditions.

2. Purpose of This Policy

The purpose of this Policy is to establish a comprehensive framework governing the collection, use, storage, retention and management of Cookies and similar technologies used by the ConsulTOpen Platform.

Without limitation, this Policy governs:

• the categories of Cookies used by the Platform;
• the purposes for which Cookies are used;
• Cookie retention periods;
• Cookie consent mechanisms;
• Cookie preferences;
• Browser Storage;
• Local Storage;
• Software Development Kits (SDKs);
• Device Identifiers;
• Pixel Technologies;
• Web Beacons;
• Cross-Device Recognition technologies;
• third-party Cookie Technologies;
• Cookie deletion procedures;
• User rights relating to Cookies;
• future Cookie Technologies; and
• every other matter reasonably connected with Cookie management and data

retention.

This Policy is intended to promote transparency, accountability and responsible data practices while enabling ConsulTOpen to continuously improve the Platform and User experience.

3. Scope of This Policy

This Policy applies to every individual or entity who accesses, browses, registers for, logs into or otherwise uses the ConsulTOpen Platform.

Without limitation, this Policy applies to:

• Students;
• Working Professionals;
• Parents or Guardians acting on behalf of Minor Students;
• Educational Institutions;
• Universities;
• Schools;
• Corporate Organisations;
• Enterprise Customers;
• Strategic Partners;
• Beta Programme Participants;
• Visitors to the Platform; and
• every future category of User accessing the Platform.

This Policy applies irrespective of whether a User creates an account, purchases a subscription, books a consultation or simply visits the Platform.

4. Definitions

For the purposes of this Policy:

"Cookie" means a small text file placed on a User's browser, device or system to recognise the User, remember preferences, improve functionality, analyse usage or enhance security.

"Session Cookie" means a Cookie that is automatically deleted when the User closes their browser or ends the browsing session.

"Persistent Cookie" means a Cookie that remains stored on a User's device until it expires or is manually deleted.

"Browser Storage" means any browser-based technology used to store information locally on a User's device.

"Local Storage" means browser storage used to retain information beyond an individual browsing session.

"Software Development Kit (SDK)" means software components integrated into the Platform for providing functionality, analytics, security or other services.

"Device Identifier" means a unique identifier associated with a User's browser, device or application that assists in authentication, security, analytics or Platform functionality.

"Pixel Technology" includes tracking pixels, pixel tags and similar technologies capable of recording interactions with the Platform.

"Web Beacon" means a small electronic object or transparent image used to measure user engagement, monitor activity or analyse Platform performance.

"Cookie Consent" means a User's freely given, specific, informed and unambiguous agreement to the use of non-essential Cookies where required under applicable law.

"Cross-Device Recognition" means technologies capable of recognising or associating a User across multiple browsers, devices or applications.

Unless otherwise defined in this Policy, capitalised terms shall have the meanings assigned to them in the ConsulTOpen Terms & Conditions or Privacy Policy.

5. Relationship with Other Policies

This Cookie & Data Retention Policy forms an integral part of the comprehensive legal framework governing the ConsulTOpen Platform.

It shall be read together with:

• Terms & Conditions;
• Privacy Policy;
• Subscription & Membership Policy;
• Community Guidelines;
• Artificial Intelligence Policy; and
• every future Platform Policy published by ConsulTOpen.

Unless expressly stated otherwise, the provisions relating to governing law, dispute resolution, limitation of liability, interpretation, notices, severability, survival and every other general legal provision contained in the Terms & Conditions shall apply equally to this Policy.

Where any inconsistency exists between this Policy and the Terms & Conditions, the more specific provision relating to Cookie Technologies shall prevail only with respect to the relevant subject matter unless otherwise required by applicable law.

6. Changes to This Policy

ConsulTOpen reserves the unrestricted right, at its sole discretion and to the fullest extent permitted by applicable law, to amend, revise, supplement, replace, update, suspend or discontinue this Policy at any time.

Without limitation, ConsulTOpen may modify:

• Cookie categories;
• retention periods;
• consent mechanisms;
• Browser Storage technologies;
• Local Storage technologies;
• third-party integrations;
• analytics technologies;
• security technologies;
• Artificial Intelligence technologies;
• tracking technologies;
• data retention practices; and
• every other aspect of Cookie management.

Material revisions may be communicated through:

• Website notices;
• Dashboard notifications;
• Email;
• SMS;
• WhatsApp;
• Push notifications;
• In-app notifications; or
• any other electronic communication channel considered appropriate by

ConsulTOpen.

Continued use of the Platform after the effective date of any revised Policy constitutes acceptance of the updated Policy to the fullest extent permitted by applicable law.

7. Electronic Acceptance

This Policy constitutes an electronic legal record.

A User shall be deemed to have accepted this Policy by:

• accessing the Platform;
• browsing the Platform;
• registering an account;
• logging into the Platform;
• accepting the Cookie banner where applicable;
• continuing to use the Platform after being presented with this Policy; or
• otherwise using any service offered through the Platform.

Electronic acceptance shall possess the same legal validity and enforceability as a handwritten signature to the fullest extent permitted by applicable law.

PART II – COOKIE FRAMEWORK

8. What Are Cookies?

Cookies are small text files placed on a User's browser, device or system when the User visits or interacts with the ConsulTOpen Platform.

Cookies enable the Platform to recognise Users, maintain secure sessions, remember User preferences, improve Platform functionality, analyse usage patterns and enhance the overall User experience.

Depending upon their purpose, Cookies may remain active only for the duration of a browsing session or may continue to be stored on a User's device for a specified period until they expire or are manually deleted.

ConsulTOpen may also use technologies similar to Cookies where appropriate and in accordance with applicable law.

9. Categories of Cookies Used

ConsulTOpen may use one or more categories of Cookies, including but not limited to:

• Essential Cookies;
• Preference Cookies;
• Analytics Cookies;
• Performance Cookies;
• Security Cookies;
• Functional Cookies;
• Session Cookies;
• Persistent Cookies;
• Third-Party Cookies;
• Future Cookie Categories introduced by ConsulTOpen.

Each category serves a different purpose and may have different retention periods depending upon operational, security and legal requirements.

ConsulTOpen reserves the unrestricted right to introduce, modify, merge or discontinue Cookie categories as the Platform evolves.

10. Similar Tracking Technologies

In addition to Cookies, ConsulTOpen may utilise similar technologies including:

• Browser Storage;
• Local Storage;
• Session Storage;
• Software Development Kits (SDKs);
• Device Identifiers;
• Pixel Technologies;
• Web Beacons;
• Application Storage;
• Authentication Tokens;
• Security Tokens;
• API-based identifiers;
• Cross-Device Recognition technologies; and
• any future technology performing substantially similar functions.

Such technologies may be used independently or together with Cookies to improve Platform functionality, security, analytics and User experience.

11. Purpose of Cookies

ConsulTOpen uses Cookies and similar technologies for legitimate business and operational purposes including, without limitation:

• authenticating Users;
• maintaining secure login sessions;
• preventing fraud;
• protecting Platform security;
• remembering User preferences;
• storing language preferences;
• improving Platform performance;
• measuring Platform usage;
• analysing User interactions;
• monitoring Platform stability;
• detecting technical errors;
• enhancing Artificial Intelligence functionality;
• improving User experience;
• facilitating payment processes;
• ensuring regulatory compliance;
• conducting security investigations; and
• supporting future Platform enhancements.

Cookies are not used for purposes inconsistent with this Policy or applicable law.

12. Third-party Cookies

Certain Cookies or similar technologies may be placed or managed by trusted thirdparty service providers engaged by ConsulTOpen.

Without limitation, such providers may include:

• cloud infrastructure providers;
• analytics providers;
• payment service providers;
• security service providers;
• Artificial Intelligence technology providers;
• authentication providers;
• customer support providers;
• infrastructure monitoring providers; and
• other technology partners assisting in Platform operations.

The collection, processing and retention of information by such third parties shall remain subject to their respective privacy practices in addition to this Policy where applicable.

ConsulTOpen undertakes commercially reasonable efforts to engage reputable service providers that maintain appropriate privacy and security standards.

13. Future Cookie Technologies

Technology continues to evolve and new methods of recognising devices, improving functionality and enhancing User experience may become available.

Accordingly, ConsulTOpen reserves the unrestricted right to introduce, replace, modify or discontinue:

• Cookie Technologies;
• Browser Storage technologies;
• Local Storage technologies;
• Device Identification technologies;
• Artificial Intelligence-enabled tracking technologies;
• privacy-enhancing technologies;
• analytics technologies;
• authentication technologies;
• security technologies;
• Cross-Device Recognition technologies; and
• any other similar technology considered appropriate.

The introduction of such technologies shall be undertaken in accordance with applicable law and, where legally required, appropriate User consent shall be obtained before deploying non-essential technologies.

Nothing contained in this Policy shall prevent ConsulTOpen from adopting future technological developments that improve security, functionality, regulatory compliance or User experience.

PART III – COOKIE CONSENT

14. Cookie Banner & Consent

Where required under applicable law, ConsulTOpen shall present Users with an appropriate Cookie Consent mechanism before placing or accessing non-essential Cookies or similar technologies on the User's device.

The Cookie Banner may appear when a User first accesses the Platform and may reappear periodically or whenever material changes are made to Cookie practices or applicable legal requirements.

Essential Cookies required for the operation, security and integrity of the Platform may be used without obtaining prior consent where permitted by applicable law.

Non-essential Cookies shall be activated only after obtaining valid User consent where such consent is legally required.

ConsulTOpen reserves the unrestricted right to modify the design, functionality, content and presentation of the Cookie Banner from time to time in accordance with applicable law.

15. Accept, Reject & Customize Options

Where technically feasible and legally required, the Cookie Banner may provide Users with one or more of the following options:

• Accept All Cookies;
• Reject Non-Essential Cookies;
• Customize Cookie Preferences;
• Save Preferences; and
• Review or Modify Preferences at a later time.

Users may choose different levels of Cookie permissions depending upon the categories of Cookies offered by the Platform.

Cookie preferences shall remain subject to browser settings, device settings and applicable legal requirements.

ConsulTOpen reserves the right to introduce additional consent options or preference management tools as the Platform evolves.

16. Withdrawal of Consent

Users may withdraw or modify their consent for non-essential Cookies at any time through the mechanisms made available by ConsulTOpen or through their browser or device settings where applicable.

Withdrawal of consent shall prevent the future placement of non-essential Cookies to the extent required by applicable law.

Withdrawal of consent shall not affect:

• the lawfulness of Cookie processing undertaken before such withdrawal;
• Essential Cookies required for Platform operation;
• Security Cookies necessary to protect the Platform;
• Cookies required to comply with legal obligations; or
• any processing otherwise permitted under applicable law.

Previously stored Cookies may remain on the User's device until they expire automatically or are manually deleted by the User.

17. Browser Controls

Most web browsers and mobile devices allow Users to manage Cookie settings through their respective privacy or security controls.

Depending upon the browser or device being used, Users may be able to:

• view stored Cookies;
• delete existing Cookies;
• block future Cookies;
• block third-party Cookies;
• receive notifications before Cookies are stored;
• restrict Browser Storage;
• clear Local Storage;
• manage website permissions; and
• configure additional privacy settings.

Users acknowledge that browser functionality may differ across browsers, devices and operating systems.

ConsulTOpen is not responsible for the availability, accuracy or operation of browserbased Cookie management tools provided by third-party browser developers.

18. Effect of Disabling Cookies

Users may choose to disable or restrict certain Cookies through the Cookie Banner, browser settings or device settings.

However, disabling certain Cookies may affect the functionality, security and performance of the Platform.

Without limitation, Users may experience:

• interrupted login sessions;
• inability to access certain Platform features;
• reduced Platform functionality;
• loss of saved preferences;
• degraded User experience;
• authentication failures;
• reduced Platform performance;
• limited Artificial Intelligence functionality;
• payment interruptions;
• increased frequency of login requests; or
• other operational limitations.

ConsulTOpen shall not be responsible for any loss of functionality, reduced performance or interruption of services resulting from a User's decision to disable Cookies or similar technologies.

Where Essential Cookies are disabled through browser settings, certain portions of the Platform may become unavailable or function improperly.

PART IV – COOKIE DATA RETENTION

19. Essential Cookie Retention

Essential Cookies are necessary for the proper functioning, security and integrity of the ConsulTOpen Platform.

Such Cookies may be retained:

• for the duration of an active browsing session;
• until the User logs out;
• until the relevant security function has been completed; or
• for a maximum period of twelve (12) months where continued retention is

reasonably necessary for authentication, fraud prevention, security, operational continuity or legal compliance.

Essential Cookies cannot ordinarily be disabled where they are strictly necessary for the operation of the Platform.

20. Preference Cookie Retention

Preference Cookies are used to remember User choices and personalise the Platform experience.

Without limitation, such Cookies may remember:

• language preferences;
• accessibility settings;
• dashboard preferences;
• interface customisations;
• display settings;
• notification preferences; and
• other User-selected options.

Preference Cookies may ordinarily be retained for a period of up to twelve (12) months unless deleted earlier by the User or replaced by updated preference settings.

21. Analytics Cookie Retention

Analytics Cookies assist ConsulTOpen in understanding how Users interact with the Platform.

Such Cookies may be used to analyse:

• page visits;
• feature usage;
• navigation patterns;
• User engagement;
• Platform performance;
• Artificial Intelligence feature usage;
• technical errors;
• security events; and
• other analytical information.

Analytics Cookies may ordinarily be retained for a period of up to twenty-four (24) months unless a shorter retention period is required by applicable law or operational necessity.

Analytics information may also be aggregated or anonymised for statistical, research and Platform improvement purposes.

22. Performance Cookie Retention

Performance Cookies assist in monitoring and improving the efficiency, reliability and responsiveness of the Platform.

Without limitation, such Cookies may be used to:

• measure loading times;
• identify performance bottlenecks;
• optimise Platform resources;
• monitor application stability;
• improve infrastructure performance;
• detect system failures; and
• support continuous Platform improvement.

Performance Cookies may ordinarily be retained for a period of up to twelve (12) months unless otherwise required for operational or legal purposes.

23. Security Cookie Retention

Security Cookies are used to protect the Platform, Users and Platform infrastructure against fraud, abuse, unauthorised access and cybersecurity threats.

Security Cookies may support:

• User authentication;
• account protection;
• fraud detection;
• suspicious login detection;
• abuse prevention;
• cyberattack mitigation;
• session integrity;
• identity verification;
• risk monitoring; and
• regulatory compliance.

Security Cookies may remain active only for as long as reasonably necessary to fulfil their intended security purpose and may, where appropriate, be retained beyond standard retention periods if required for fraud investigations, legal proceedings, regulatory obligations or cybersecurity purposes.

24. Marketing Cookies

ConsulTOpen does not presently use Marketing or Advertising Cookies for behavioural advertising, remarketing or targeted advertising activities.

However, ConsulTOpen reserves the unrestricted right to introduce Marketing Cookies, Advertising Cookies, Remarketing Technologies, Conversion Tracking Technologies and similar technologies in the future.

Where required under applicable law, such Cookies shall only be deployed after obtaining the User's valid consent through the applicable Cookie Consent mechanism.

The introduction of Marketing Cookies shall be reflected through appropriate updates to this Policy and the Cookie Banner.

25. Cookie Expiry

Every Cookie deployed by ConsulTOpen shall ordinarily expire automatically upon completion of its applicable retention period unless:

• renewed through continued User interaction;
• replaced by an updated Cookie;
• manually deleted by the User;
• removed by browser or device settings;
• required for ongoing security purposes; or
• retained for compliance with applicable law.

Automatic expiry shall occur in accordance with the technical configuration of the relevant Cookie or similar technology.

26. Cookie Deletion

Users may delete Cookies at any time through their browser, device or application settings, subject to the functionality provided by the relevant software.

In addition, Cookies may be deleted:

• automatically upon expiry;
• following withdrawal of consent where applicable;
• upon clearing browser data;
• following account deletion where technically feasible;
• through Platform-provided Cookie management tools; or
• by other technically appropriate methods.

Deletion of Cookies may result in the loss of stored preferences, interruption of active sessions, reduced Platform functionality or other operational limitations.

ConsulTOpen shall not be responsible for any loss of functionality resulting from the deletion of Cookies by the User or through browser settings.

PART V – THIRD-PARTY SERVICES

27. Analytics Providers

ConsulTOpen may engage trusted third-party analytics providers to help understand how Users interact with the Platform and to improve the quality, performance and reliability of its services.

Without limitation, such providers may assist in:

• measuring Platform usage;
• analysing User interactions;
• monitoring feature adoption;
• identifying technical issues;
• measuring Platform performance;
• generating aggregated usage reports;
• improving Artificial Intelligence functionality;
• detecting unusual activity; and
• supporting product development.

ConsulTOpen reserves the unrestricted right to introduce, replace or discontinue analytics providers from time to time.

Where required under applicable law, appropriate User consent shall be obtained before enabling non-essential analytics technologies.

28. Cloud & Infrastructure Providers

ConsulTOpen may utilise trusted cloud computing, hosting and infrastructure service providers to securely operate and maintain the Platform.

Such providers may process information through Cookies or similar technologies for purposes including:

• Platform hosting;
• content delivery;
• load balancing;
• system availability;
• infrastructure monitoring;
• data backup;
• disaster recovery;
• security monitoring;
• performance optimisation; and
• operational continuity.

ConsulTOpen undertakes commercially reasonable efforts to engage providers maintaining appropriate security, confidentiality and privacy standards.

29. Payment Providers

Payment-related Cookies and similar technologies may be utilised by authorised payment service providers to facilitate secure payment processing.

Without limitation, such technologies may support:

• payment authentication;
• fraud prevention;
• transaction verification;
• payment security;
• recurring subscription billing;
• payment confirmation;
• risk assessment;
• regulatory compliance; and
• dispute resolution.

ConsulTOpen presently utilises Razorpay as its primary payment service provider but reserves the unrestricted right to integrate additional payment providers in the future.

Payment-related technologies remain subject to the privacy practices and legal obligations of the relevant payment service providers.

30. AI & Technology Partners

ConsulTOpen may collaborate with Artificial Intelligence providers and other technology partners to enhance Platform functionality and improve User experience.

Such partners may utilise Cookies or similar technologies where necessary for:

• Artificial Intelligence services;
• intelligent recommendations;
• language processing;
• platform automation;
• feature optimisation;
• service monitoring;
• infrastructure management;
• system security;
• technical diagnostics; and
• future AI-powered functionality.

ConsulTOpen shall use commercially reasonable efforts to ensure that such partners implement appropriate technical and organisational safeguards for information processed through their technologies.

31. Future Third-party Integrations

As the Platform evolves, ConsulTOpen may engage additional third-party service providers to support new products, technologies and operational requirements.

Without limitation, future third-party integrations may include:

• analytics providers;
• Artificial Intelligence providers;
• payment processors;
• authentication providers;
• cybersecurity providers;
• customer support platforms;
• communication service providers;
• cloud infrastructure providers;
• educational technology partners;
• enterprise service providers;
• marketing and advertising technology providers;
• social media integrations;
• identity verification providers;
• fraud prevention providers; and
• any other technology partner reasonably necessary for the operation, improvement

or expansion of the Platform.

Where required under applicable law, ConsulTOpen shall implement appropriate contractual, organisational and technical safeguards before permitting such providers to process information through Cookies or similar technologies.

The engagement, replacement or discontinuation of third-party providers shall not require amendment of this Policy unless a material change in Cookie practices or applicable legal obligations necessitates such update.

PART VI – USER RIGHTS

32. Managing Cookie Preferences

ConsulTOpen respects every User's right to manage Cookie Preferences in accordance with applicable law.

Where technically feasible, Users may manage their Cookie Preferences through:

• the Cookie Banner;
• the Cookie Preference Centre;
• browser settings;
• device settings;
• operating system privacy settings; or
• other preference management tools made available by ConsulTOpen.

Users may update, modify or review their Cookie Preferences at any time, subject to applicable technical limitations and legal requirements.

Changes to Cookie Preferences shall ordinarily apply prospectively and may not affect Cookies that have already been processed before such changes become effective.

33. Cross-device Recognition

ConsulTOpen may, now or in the future, utilise Cross-Device Recognition technologies to improve Platform functionality, security, fraud prevention and User experience.

Such technologies may assist in:

• recognising Users across multiple devices;
• maintaining secure login sessions;
• synchronising User preferences;
• improving Platform continuity;
• detecting suspicious activity;
• preventing fraudulent access;
• enhancing Artificial Intelligence functionality;
• improving Platform performance; and
• supporting future technological developments.

Where required under applicable law, Cross-Device Recognition technologies shall be implemented only after obtaining the appropriate User consent.

34. International Users

ConsulTOpen intends to expand its services internationally and acknowledges that Cookie laws and privacy requirements may vary across different jurisdictions.

Accordingly, Cookie practices, consent mechanisms, retention periods and User rights may differ depending upon:

• the User's country of residence;
• applicable regional legislation;
• regulatory requirements;
• local supervisory authorities;
• international privacy standards; or
• any other applicable legal obligation.

Where local law provides greater protection than this Policy, ConsulTOpen shall endeavour to comply with such mandatory legal requirements to the extent applicable.

35. Data Subject Rights

Subject to applicable law, Users may exercise certain rights relating to information processed through Cookies and similar technologies.

Without limitation, such rights may include:

• the right to be informed;
• the right to access information;
• the right to withdraw Cookie consent;
• the right to request deletion where applicable;
• the right to restrict processing where permitted by law;
• the right to object to certain processing activities;
• the right to manage Cookie Preferences;
• the right to lodge a complaint with the appropriate regulatory authority; and
• any other rights available under applicable data protection legislation.

The availability and scope of such rights may vary depending upon the applicable jurisdiction and the legal basis for processing.

ConsulTOpen may request reasonable verification of identity before acting upon any request relating to Cookie Technologies.

36. Contacting Consultopen

Users may contact ConsulTOpen regarding any questions, concerns or requests relating to Cookies, Cookie Preferences, Cookie Consent, Cookie Retention or similar technologies through the following authorised channels:

Support Email: support@consultopen.com

Legal Email: consultopen1@gmail.com

Grievance Officer:

Abhinav Saini

Grievance Officer Email: abhinav@consultopen.com

Contact Number: +91 9717972908

Registered Office:

House No. 20, First Floor, Khasra No. 630, Pahari Colony, Ghitorni Enclave, New Delhi – 110030, India

Official Website: https://consultopen.com

ConsulTOpen shall use commercially reasonable efforts to acknowledge and address Cookie-related requests within a reasonable period, subject to applicable law, verification requirements and the complexity of the request.

PART VII – COOKIE GOVERNANCE

37. Cookie Audit & Review

ConsulTOpen is committed to maintaining responsible, transparent and compliant Cookie management practices.

Accordingly, ConsulTOpen may periodically conduct internal reviews and audits of Cookies and similar technologies used across the Platform.

Such reviews may include, without limitation:

• identifying Cookies currently in use;
• reviewing Cookie categories;
• verifying Cookie purposes;
• reviewing retention periods;
• assessing legal compliance;
• evaluating third-party Cookie Technologies;
• removing obsolete Cookies;
• replacing outdated technologies;
• identifying unnecessary data collection;
• strengthening Platform security; and
• improving User privacy protections.

The frequency, scope and methodology of such reviews shall be determined solely by ConsulTOpen.

38. Internal Cookie Inventory

ConsulTOpen may maintain an internal inventory of Cookies and similar technologies used across the Platform.

Such inventory may include:

• Cookie names;
• Cookie categories;
• Cookie purposes;
• Cookie providers;
• retention periods;
• activation methods;
• legal basis for processing;
• applicable consent requirements;
• associated systems;
• related technologies; and
• any other operational information considered appropriate.

The internal Cookie inventory is maintained for governance, operational, compliance, security and audit purposes and does not form part of this publicly available Policy.

ConsulTOpen reserves the unrestricted right to update, expand or modify its internal Cookie inventory at any time.

39. Policy Updates

ConsulTOpen reserves the unrestricted right to amend, revise, supplement, replace or discontinue this Cookie & Data Retention Policy whenever necessary.

Without limitation, updates may occur due to:

• changes in applicable law;
• regulatory guidance;
• technological developments;
• introduction of new Platform features;
• implementation of Artificial Intelligence technologies;
• introduction of new Cookie categories;
• deployment of new third-party services;
• cybersecurity improvements;
• operational requirements;
• international expansion; or
• any other lawful business requirement.

Material updates may be communicated through:

• Website notices;
• Dashboard notifications;
• Email;
• SMS;
• WhatsApp;
• Push notifications;
• In-app notifications; or
• any other electronic communication channel considered appropriate by

ConsulTOpen.

Continued use of the Platform after the effective date of any revised Policy constitutes acceptance of the updated Policy to the fullest extent permitted by applicable law.

40. Future Cookie Categories

As technology continues to evolve, ConsulTOpen reserves the unrestricted right to introduce additional Cookie categories and similar technologies where appropriate.

Without limitation, future categories may include:

• Artificial Intelligence Cookies;
• Personalisation Cookies;
• Recommendation Cookies;
• Advertising Cookies;
• Remarketing Cookies;
• Attribution Cookies;
• Conversion Tracking Cookies;
• Behavioural Analytics Cookies;
• Device Recognition Cookies;
• Fraud Detection Cookies;
• Identity Verification Cookies;
• Accessibility Cookies;
• Enterprise Cookies; and
• any other category reasonably required for Platform functionality, security,

compliance or innovation.

Where required under applicable law, appropriate User consent shall be obtained before deploying non-essential Cookie categories.

41. Reservation of Rights

Except where prohibited by applicable law, ConsulTOpen reserves the unrestricted right to:

• introduce new Cookie Technologies;
• discontinue existing Cookies;
• modify Cookie purposes;
• revise Cookie retention periods;
• update Cookie categories;
• replace third-party technology providers;
• introduce new consent mechanisms;
• implement privacy-enhancing technologies;
• deploy new Artificial Intelligence technologies;
• modify Cross-Device Recognition technologies;
• enhance Platform security technologies;
• comply with evolving legal requirements; and
• make any other commercially reasonable modification relating to Cookie

management and data retention.

The exercise of any right reserved under this Policy shall not constitute a breach of any contractual obligation and shall become effective in accordance with this Policy, the Privacy Policy, the Terms & Conditions and applicable law.

PART VIII – GENERAL LEGAL PROVISIONS

42. Relationship with the Terms & Conditions

This Cookie & Data Retention Policy forms an integral part of the ConsulTOpen legal framework and shall be read together with the Terms & Conditions, Privacy Policy and every other applicable Platform Policy.

Unless expressly provided otherwise in this Policy, all general legal provisions contained within the ConsulTOpen Terms & Conditions shall apply equally to this Policy, including but not limited to provisions relating to:

• definitions;
• interpretation;
• governing law;
• jurisdiction;
• dispute resolution;
• arbitration;
• electronic records;
• electronic acceptance;
• limitation of liability;
• indemnification;
• intellectual property;
• force majeure;
• notices;
• severability;
• waiver;
• assignment;
• survival of obligations; and
• every other applicable legal provision.

Where any inconsistency exists between this Policy and the Terms & Conditions, the provision specifically governing Cookie Technologies, Cookie Retention or similar technologies shall prevail only with respect to the relevant subject matter unless otherwise required by applicable law.

43. Survival

The following provisions of this Policy shall survive the suspension, termination or discontinuation of a User Account, Platform access or this Policy, to the extent applicable:

• Cookie consent records;
• data retention obligations;
• fraud prevention activities;
• cybersecurity investigations;
• audit rights;
• legal compliance obligations;
• intellectual property rights;
• confidentiality obligations;
• limitation of liability;
• dispute resolution provisions;
• indemnification obligations;
• enforcement rights; and
• any other rights or obligations which, by their nature, are intended to survive

termination.

Termination of Platform access shall not affect any accrued rights, obligations or liabilities existing prior to such termination.

44. No Waiver

Failure by ConsulTOpen to exercise or enforce any right, remedy or provision available under this Policy shall not constitute:

• waiver;
• abandonment;
• estoppel;
• limitation of future enforcement; or
• relinquishment of any legal right.

Any waiver shall be valid only if expressly made in writing by an authorised representative of ConsulTOpen.

45. Severability

If any provision of this Policy is held to be invalid, unlawful or unenforceable by any court or competent authority, such provision shall be enforced to the maximum extent permissible under applicable law.

The remaining provisions shall continue in full force and effect.

Where reasonably possible, the invalid provision shall be interpreted in a manner consistent with its original legal and commercial intent.

46. Assignment

ConsulTOpen may assign, transfer or otherwise deal with its rights and obligations under this Policy in connection with:

• mergers;
• acquisitions;
• investments;
• restructuring;
• business transfers;
• strategic partnerships;
• corporate reorganisations; or
• any other lawful commercial transaction.

Users may not assign, transfer or delegate any rights or obligations arising under this Policy without the prior written consent of ConsulTOpen.

47. Entire Cookie Framework

This Cookie & Data Retention Policy constitutes the comprehensive policy governing the use, management, storage, retention and deletion of Cookies and similar technologies used by the ConsulTOpen Platform.

This Policy shall be read together with:

• Terms & Conditions;
• Privacy Policy;
• Subscription & Membership Policy;
• Artificial Intelligence Policy;
• Community Guidelines; and
• every future Platform Policy published by ConsulTOpen.

Together, these documents constitute the complete legal and operational framework governing Cookies, similar technologies and data retention practices adopted by ConsulTOpen.

48. Contact Information

For questions, concerns or requests relating to this Cookie & Data Retention Policy or the use of Cookies and similar technologies, Users may contact ConsulTOpen through the following authorised channels:

Support Email: support@consultopen.com

Legal Email: consultopen1@gmail.com

Grievance Officer: Abhinav Saini

Grievance Officer Email: abhinav@consultopen.com

Contact Number:

+91 9717972908

Registered Office:

House No. 20, First Floor, Khasra No. 630, Pahari Colony, Ghitorni Enclave, New Delhi – 110030, India

Official Website: https://consultopen.com

ConsulTOpen shall use commercially reasonable efforts to acknowledge and respond to Cookie-related requests within a reasonable period, subject to applicable law and verification requirements.

49. Effective Date

This Cookie & Data Retention Policy shall become effective on the Effective Date specified in the Document Control section.

By accessing, browsing, registering for, logging into or otherwise using the ConsulTOpen Platform, every User acknowledges that they have read, understood and agree to be legally bound by this Policy together with the Terms & Conditions, Privacy Policy and every other applicable Platform Policy.

PART IX – CLOSING PROVISIONS

50. Policy Interpretation

This Cookie & Data Retention Policy shall be interpreted in a manner consistent with the ConsulTOpen Terms & Conditions, Privacy Policy and every other applicable Platform Policy.

The headings, titles and section numbers contained in this Policy are included solely for convenience and shall not affect the interpretation or construction of this Policy.

Unless the context otherwise requires:

• words importing the singular shall include the plural and vice versa;
• words importing one gender shall include every gender;
• references to legislation shall include all amendments, re-enactments and

replacements thereof;

• the words "including", "includes" and "include" shall mean "including without

limitation";

• references to Cookies shall include similar technologies unless the context

otherwise requires; and

• references to electronic records shall include every legally recognised electronic

communication.

51. Compliance with Applicable Law

ConsulTOpen is committed to collecting, using, storing, retaining and managing Cookies and similar technologies in accordance with applicable laws, regulations and recognised privacy principles.

Nothing contained in this Policy shall limit, exclude or waive any statutory rights that cannot lawfully be excluded under applicable law.

Where any provision of this Policy conflicts with mandatory legal requirements, such mandatory legal requirements shall prevail only to the extent of such conflict.

ConsulTOpen reserves the unrestricted right to modify its Cookie management practices whenever reasonably necessary to comply with changes in applicable law, regulatory guidance or judicial decisions.

52. Entire Policy

This Cookie & Data Retention Policy constitutes the complete policy governing the collection, use, storage, management, retention and deletion of Cookies and similar technologies used by the ConsulTOpen Platform.

This Policy shall be read together with:

• Terms & Conditions;
• Privacy Policy;
• Subscription & Membership Policy;
• Artificial Intelligence Policy;
• Community Guidelines; and
• every future Platform Policy published by ConsulTOpen.

Together, these documents constitute the complete legal and operational framework governing Cookie Technologies and data retention practices adopted by ConsulTOpen.

53. Contact Information

For questions, concerns or requests relating to this Cookie & Data Retention Policy, Users may contact ConsulTOpen through the following authorised channels:

Support Email: support@consultopen.com

Legal Email: consultopen1@gmail.com

Grievance Officer: Abhinav Saini

Grievance Officer Email: abhinav@consultopen.com

Contact Number: +91 9717972908

Registered Office:

House No. 20, First Floor, Khasra No. 630, Pahari Colony, Ghitorni Enclave, New Delhi – 110030, India

Official Website: https://consultopen.com

ConsulTOpen shall use commercially reasonable efforts to acknowledge and respond to Cookie-related requests within a reasonable period, subject to applicable law and reasonable identity verification requirements.

54. Effective Date

This Cookie & Data Retention Policy shall become effective on the Effective Date specified in the Document Control section.

By accessing, browsing, registering for, logging into or otherwise using the ConsulTOpen Platform, every User acknowledges that they have read, understood and agree to be legally bound by this Policy together with the Terms & Conditions, Privacy Policy and every other applicable Platform Policy.