Export Control & Sanctions Policy

Effective Date: 1 January 2025
Last Updated: 27 November 2025

This Export Control & Sanctions Policy explains how PPLST Tech Private Limited (“we,” “our,” “us”) ensures that ProTalkie complies with global export laws, trade restrictions, and sanctions requirements.

By using ProTalkie, users agree to comply with all applicable export control and sanctions regulations.

1. Overview

ProTalkie is an end-to-end encrypted communication application.

Due to the cryptographic features in the app, ProTalkie is subject to export control regulations under:

U.S. Export Administration Regulations (EAR)
U.S. Office of Foreign Assets Control (OFAC) sanctions
EU Dual-Use Regulation (EU) 2021/821
UK Export Control Order 2008
India Foreign Trade Policy & export rules
Additional country-specific export laws

We comply with these requirements and ensure ProTalkie is not used in violation of international sanctions or export restrictions.

2. Prohibited Countries & Regions

Users may not download, access, or use ProTalkie from territories that are subject to comprehensive sanctions imposed by:

United States
European Union
United Kingdom
United Nations
India

At the time of this policy, these restricted regions may include (but are not limited to):

North Korea
Iran
Syria
Cuba
Crimea, Donetsk, Luhansk regions of Ukraine (subject to specific sanctions)
Any region under applicable international embargoes

This list may change as global regulations update.

3. Restricted or Denied Parties

You may not use ProTalkie if you are:

Listed on the U.S. Department of Treasury’s Specially Designated Nationals (SDN) List
Listed on the U.S. Commerce Department’s Entity List or Denied Persons List
Listed on EU Consolidated Sanctions List
Listed on UK Sanctions List
Listed on India’s “Proscribed Entities” list
Affiliated with, acting on behalf of, or controlled by any such prohibited party

We reserve the right to restrict or terminate access for users flagged under these sanctions requirements.

4. Encryption Export Compliance

ProTalkie uses strong end-to-end encryption, which is subject to export rules governing cryptographic software.

We comply with:

EAR §742.15 (Encryption Items)
EAR classification for consumer communication tools
Apple & Google encryption export compliance requirements

ProTalkie is classified as:

Mass-market encryption software
Eligible for ECCN 5D992 or 5A992.c (mass-market exemption) under U.S. EAR

We do not provide any encryption services outside permitted jurisdictions or to sanctioned entities.

5. User Responsibilities

By using ProTalkie, you agree that you:

Are not located in a prohibited region
Are not a sanctioned individual or entity
Will not export, re-export, or transfer the app in violation of export laws
Will not use ProTalkie for any prohibited or unlawful purpose, including
- terrorism
- cybercrime
- proliferation of weapons
- military or dual-use purposes where prohibited
- harmful conduct violating export law