General Terms and Conditions

1.1. The Provider's details:

• (a) company name: TOPiN-HUB Korlátolt Felelősségű Társaság;
• (b) registered office and postal address: 2161 Csomád, József Attila utca 1., Hungary;
• (c) company registration number: 13-09-223835; registry court: Court of Registration of the Budapest Environs Regional Court (Budapest Környéki Törvényszék Cégbírósága);
• (d) tax number: 32134234-2-13;
• (e) EU VAT number: HU32134234;
• (f) email address: [email protected];
• (g) telephone number: +36 20 479 0790.

1.2. The Provider provides the hosting of the Website and the Application itself: the Website and the Application are served by a virtual machine operated by the Provider in Hungary, in the V188 data centre (1138 Budapest, Váci út 188.). The name, registered office and contact details of the hosting provider are therefore the same as the details given in Section 1.1. The data traffic of the Website and the Application passes through the network (proxy) service of Cloudflare, Inc.

1.3. The Provider operates a single electronic point of contact for Customers, Users and authorities: the email address [email protected]. The language of communication is Hungarian or English. Enquiries are answered by a member of the Provider's staff – not exclusively by automated means – within a reasonable time. The Provider does not operate a telephone customer service, but it can also be reached at the telephone number given in point (g) of Section 1.1.

2.1. The Terms use the concepts of personal data, processing, controller, processor, recipient, third country, profiling, consent and personal data breach within the meaning of Article 4 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “GDPR”). The concepts of Consumer and Business are based on Section 8:1 of Act V of 2013 on the Civil Code (the “Ptk.”). Capitalised terms in the Terms have the following meanings:

• Account: the User's personal access to the Application, created either by registration (with an email address and password or with a Google account) or – for a Team Member – by the Owner or an Admin of the Brand.
• Application: the web application available at app.pagioo.com and the programming interface serving it, available at app-api.pagioo.com, through which the Service can be used.
• Autopilot: an operating mode of the Service that can be switched on per Brand (in the interface: “Autopilot”; in Hungarian: „Autopilóta”), in which the Service, on the basis of the Brand's settings and without human involvement or prior human approval, selects topics, produces Generated Content and publishes it on a schedule on the Connected Accounts.
• Bonus Credit: a Credit credited free of charge by the Provider as part of a promotion (in particular the referral programme).
• Brand: a workspace within the Organisation that comprises the Brand Brief, Source Materials, content, Connected Accounts and Team Members of a business, product or service.
• Brand Brief: the brand profile approved by the User that records the characteristics of the Brand (in particular the summary, target audience, value proposition, tone of voice, keywords, topics and the answers to the onboarding questions) (in the interface: “Brief”).
• Business: a Customer acting within the scope of its profession, independent occupation or business activity (point 4 of Section 8:1(1) of the Ptk.).
• Connected Account: an account or website of the Customer or the User with a Third-party Service (a Facebook Page, an Instagram account, a LinkedIn profile or LinkedIn Page, or a website based on WordPress or with a custom programming interface) that is connected to the Service for the purpose of publishing or delivering Generated Content (in the interface: “Integrations”; in Hungarian: „Integrációk”).
• Consumer: a Customer who is a natural person acting outside the scope of their profession, independent occupation or business activity (point 3 of Section 8:1(1) of the Ptk.).
• Contract: the contract concluded between the Customer and the Provider on the basis of the Terms for the use of the Service, together with its annexes and the Orders.
• Credit: a unit of account within the Service that cannot be converted into money and expresses the extent to which individual operations, in particular those using artificial intelligence, are used.
• Credit Pack: a quantity of Credits that can be purchased for a one-off fee, alongside a Subscription, in addition to the Monthly Credit Allowance.
• Customer: the natural person, legal person or organisation without legal personality that concludes the Contract with the Provider: the User who registers the Account or, if the User creates the Organisation on behalf of another person (in particular a business), that person; in the case of a One-off Service without an Account, the person placing the order.
• Customer Content: all data and content that the Customer, the User or an External Reviewer enters into, uploads to or makes available to the Service (in particular the Brand Brief, Source Materials, the website addresses provided and the text read from them, instructions, edits, comments and the data of Connected Accounts), including any personal data contained in them; Generated Content is not Customer Content.
• Data Processing Terms: Annex 1 to the Terms, which sets out the terms of the processing carried out by the Provider on behalf of the Customer (Article 28(3) GDPR).
• Data Subject: an identified or identifiable natural person to whom personal data relates (point 1 of Article 4 GDPR).
• External Reviewer: a person without an Account who views content through a reviewer link shared by the User and adds comments to it.
• Generated Content: the output produced by the Service with the help of artificial intelligence on the basis of Customer Content and the User's instructions (in particular articles, social media posts, images, titles, descriptions, topic and calendar suggestions, summaries and Research Reports), including any version of it edited by the User.
• Highlighted Term: a provision of the Terms that differs materially from the law or from usual contractual practice and is therefore marked “Highlighted Term” in the Terms and expressly accepted by the Customer after separate information (Section 6:78(2)–(3) of the Ptk.).
• Monthly Credit Allowance: the quantity of Credits available in each calendar month under a Plan.
• One-off Service: the SEO and GEO research that can be ordered for a one-off fee, also without a Subscription (in the interface: “Full research”; in Hungarian: „Teljes kutatás”), the result of which is the Research Report.
• Order: the Customer's contractual declaration involving the payment of a fee for a Subscription, a Plan Change, a Credit Pack or a One-off Service.
• Organisation: the billing unit belonging to the Customer in the Application, to which the Plan, the Subscription, Credits and the payment of fees are linked, and which comprises one or more Brands.
• Owner: a Team Member of a Brand with the Owner Role; the Owner of an Organisation is the Owner of any Brand of the Organisation.
• Plan: the scope of use of the Service determined by the Provider (Free, Starter, Growth or Scale), which comes with a Monthly Credit Allowance, usage limits and features; the Free Plan is free of charge.
• Privacy Notice: the Provider's privacy notice, available at https://pagioo.com/adatvedelem/; it does not form part of the Contract.
• Provider: TOPiN-HUB Korlátolt Felelősségű Társaság (registered office: 2161 Csomád, József Attila utca 1., Hungary; company registration number: 13-09-223835; tax number: 32134234-2-13).
• Publishing Mode: the publishing mode that can be set per Brand: “Manual” (in Hungarian: „Kézi”), “Approval” (in Hungarian: „Jóváhagyásos”) or Autopilot.
• Quick Scan: the limited SEO and GEO analysis that can be requested free of charge on the Website without an Account (in the interface: “Free quick scan”; in Hungarian: „Ingyenes SEO/GEO gyorskutatás”); it does not form part of the Service.
• Research Report: the report produced as the result of SEO and GEO research, both in the form displayed in the Application and in downloadable (PDF) form.
• Role: the permission level of a Team Member within a Brand: Owner, Admin, Editor, Approver or Viewer.
• Service: the content marketing software service using artificial intelligence, provided by the Provider under the name “Pagioo” in the Application, with all of its features, including the One-off Service.
• Source Material: a document, image, video or pasted text that the User uploads to the Brand's knowledge base (in the interface: “Materials”; in Hungarian: „Forrásanyagok”).
• Sub-processor: a further processor engaged by the Provider for the processing carried out on behalf of the Customer (Article 28(2) and (4) GDPR); the list of Sub-processors is set out in Privacy Notice Section 10.1.
• Subscription: the use of the Starter, Growth or Scale Plan for an Organisation against a fee, for a monthly or annual period, renewing automatically.
• Team Member: a User who has a membership with a Role in a Brand.
• Third-party Service: a service or platform provided by a third party independent of the Provider (in particular Facebook, Instagram, LinkedIn, Google and the website engine used by the Customer), which the Service uses at the Customer's choice and whose terms are set by that third party.
• User: a natural person who has an Account and uses the Service through their Account, either as the Customer or as a Team Member of the Customer.
• Website: the website available under the pagioo.com domain, together with its subpages.

2.2. The following rules apply to the interpretation of the Terms:

• (a) an individual agreement concluded by the parties in writing takes precedence over the Terms on any matter on which it conflicts with them;
• (b) in matters relating to the processing of personal data, Annex 1 takes precedence over the other provisions of the Terms;
• (c) towards a Consumer, Chapter 15 takes precedence over the other provisions of the Terms;
• (d) the headings of the chapters do not serve to interpret the Terms, and a list introduced by the words “in particular” is illustrative;
• (e) the Customer's own general terms and conditions do not become part of the Contract, even if the Customer refers to them.

3.1. The Terms set out the conditions for using the Service, including the One-off Service. The Contract consists of the Terms, Annexes 1–4 and the Orders. Annex 2 contains the fees, the content of the Plans and the Credit costs, and Annex 1 contains the Data Processing Terms. The Privacy Notice does not form part of the Contract.

3.2. The Terms apply to the Customer and to every User. Users – including Team Members working in a Brand of another Customer – must comply with the rules on the use of the Account (Section 4.6) and with Chapters 9 and 10. The Customer is liable for the conduct, in connection with the Service, of the Team Members of the Brands belonging to its Organisation and of other Users acting in its Organisation as if it had acted itself.

3.3. The Terms apply to both Businesses and Consumers; the derogations applicable to Consumers are set out in Chapter 15. A person who creates the Organisation on behalf of another person, in particular a business, declares on creating it that they are authorised to represent that person, accepts the Terms on that person's behalf and expressly accepts the Highlighted Terms in accordance with Section 4.5. In that case, the Contract is concluded with that person. If the authority to represent is lacking, the User who created the Organisation is deemed to be the Customer and is liable to the Provider for any damage resulting from the lack of authority.

3.4. The Service may be used only by natural persons who have reached the age of 18 and have capacity to act, either in their own name or as the representative of another person. By accepting the Terms, the User declares that they meet this condition. The Provider does not verify age or capacity to act. If the Provider becomes aware that the declaration is untrue, it closes the Account.

3.5. Use of the Website without an Account does not fall within the scope of the Contract. When requesting a Quick Scan, the requester accepts the Terms and expressly accepts the Highlighted Terms in accordance with Section 4.5. This creates a contract for the Quick Scan between the requester and the Provider that is free of charge and separate from the Contract; for the purposes of that contract, the provisions of the Terms relating to the Customer apply to the requester. Chapters 1 and 2, Sections 3.4, 6.1, 6.2 and 6.5, Chapter 9, Section 10.4, Sections 11.1, 11.3–11.6 and 11.9, and Chapter 16 apply to that contract mutatis mutandis. For a Consumer, Chapter 15 also applies mutatis mutandis. The Provider sends the link to the result of the Quick Scan to the email address provided; the result is for information only. Privacy Notice Section 5.12 governs the processing of personal data in connection with the Quick Scan.

4.1. An Account can be created with an email address or with a Google account. The steps of registration with an email address are:

• (a) entering the name, the email address and the password (twice) on the registration form;
• (b) accepting the Terms and expressly accepting the Highlighted Terms by ticking a separate checkbox (Section 4.5);
• (c) submitting the registration;
• (d) confirming the email address by means of a link sent by the Provider and valid for 60 minutes; this email also acknowledges receipt of the registration and states where the Terms can be accessed.

Before submitting the registration, the User can check and correct the data entered on the form. After registration, the Provider changes the name and the email address upon a request sent to [email protected]. In the case of registration with a Google account, the Provider uses the name, email address and profile picture link received from Google and treats the email address verified by Google as confirmed; in this case, the User accepts the Terms and the Highlighted Terms at the first login, and the Provider confirms the acceptance by email. Section 5.3 governs the creation of a Team Member's Account. A Brand can be created only in an Account with a confirmed email address.

4.2. The Contract is concluded when the Account is created:

• (a) for registration with an email address, by submitting the registration;
• (b) for registration with a Google account, by the first login;
• (c) for an Account created for a Team Member by someone else, by the User's first login.

A condition for the conclusion of the Contract is that the User accepts the Terms and the Highlighted Terms in accordance with Sections 4.1 and 4.5. The Organisation is created when the first Brand is created; the rights and obligations relating to the Organisation form part of the Customer's Contract. No separate Order is required to use the Free Plan.

4.3. The steps of placing an Order subject to a fee are:

• (a) selecting the Plan and the period (monthly or annual) or the Credit Pack in the Application; for the One-off Service, starting the Order on the result page of the Quick Scan or in the Application;
• (b) providing the purchasing capacity (Consumer or Business) and the billing details; for a Business, the company name and the tax number, and for a Business registered in another Member State of the European Union, the EU VAT number as well;
• (c) the Provider's summary, which the person placing the order sees in the Application or on the Website before submitting the Order: the essential characteristics of the service ordered, the total fee payable and the value added tax included in it, the total cost of the period, the terms of renewal and cancellation, the method of payment and invoicing, and for a Consumer the information under Section 15.2 and the declarations under Section 15.3;
• (d) submitting the Order by means of the “Order with obligation to pay” button;
• (e) redirection to the payment page of the payment service provider, where the subject matter and the fee of the Order are displayed again and the payment details can be entered;
• (f) completing the payment.

The person placing the order may correct input errors before submitting the Order: from the summary under point (c) they may return to the previous steps and change the purchasing capacity, the billing details and the service ordered (Section 5(2) of the Ekertv.). The Order can be abandoned by leaving the payment page. For an Order without an Account, the person placing the order accepts the Terms and the Highlighted Terms before submitting the Order, in accordance with Section 4.5. The legal relationship relating to the service subject to a fee is established when the payment has been completed successfully. Only the Owner may place an Order on behalf of the Organisation.

4.4. The Provider acknowledges receipt of every Order by email without delay, and in any event within 48 hours. The acknowledgement contains the subject matter and the fee of the Order and states where the Terms can be accessed. For a Consumer, the Provider sends the acknowledgement on a durable medium, with the content set out in Section 15.2.

4.5. The Provider informs the Customer of the Highlighted Terms by means of the summary at the beginning of the Terms and by separate information. The separate information is displayed during registration, when an invitation is accepted, on the first use of an Account created by someone else, when an Organisation is created on behalf of another person, when a Quick Scan is requested and when an Order is placed without an Account. The Customer expressly accepts the Highlighted Terms separately from the acceptance of the Terms, by ticking a separate checkbox. A Highlighted Term becomes part of the Contract only through this acceptance.

4.6. The User must provide true data in the Account and keep it up to date. The Account is personal: it is not transferable and may not be shared by several persons. The User must keep their login details confidential, take care of the security of their Google account when logging in with a Google account and, if unauthorised access is suspected, notify the Provider without delay at [email protected]. The User – and, under Section 3.2, the Customer – is responsible for the operations carried out with the Account, unless the operation was made possible by the Provider's breach of contract, in particular a security flaw in the Service.

4.7. The Contract qualifies as a contract concluded in writing (Section 6:7(3) of the Ptk.). The Provider does not file the Contract separately, but it records electronically the fact and time of acceptance, the data identifying the accepting person and the version of the Terms accepted; the accepted version of the Terms remains accessible later in the archive referred to in Section 13.6. The language of the Contract is Hungarian. Any version of the Terms in another language is for information only; in the event of any discrepancy, the Hungarian version prevails. The interface of the Application is available in Hungarian and English. The Provider has not submitted to any code of conduct.

5.1. The Service supports content marketing tasks using artificial intelligence (“AI”). Its main features are:

• (a) onboarding: entering the basic data of the Brand, analysing one page of the website provided, answering the questions asked by the AI and approving the Brand Brief;
• (b) uploading and processing Source Materials (Section 5.6);
• (c) text and image generation (in particular articles, social media posts, images, titles and descriptions), and setting the brand voice;
• (d) AI editing operations (for example regeneration, shortening, expanding, changing the tone, translation, rewriting) and the AI-based conversational feature called “Writing partner” (in Hungarian: „Szerkesztőtárs”);
• (e) planning campaigns and producing their content;
• (f) content calendar, scheduling and recurring schedules;
• (g) approval, and reviewer links for External Reviewers (Section 5.9);
• (h) publication on the Connected Accounts (Section 5.5);
• (i) SEO and GEO research, the research monitor and sharing of the Research Report (Section 5.7);
• (j) internal statistics on the operation of the Service (in the interface: “Analytics”), showing the number and success of publications.

The Service does not collect performance indicators (for example reach, reactions or follower numbers) from Third-party Services, does not provide industry benchmarking data and does not offer the restoration of earlier versions of content. The availability of individual features depends on the Plan (Section 5.2).

5.2. Annex 2 sets out the fees, the limits (in particular the number of Brands, of Team Members per Brand, of Connected Accounts and of website targets, the storage space and the scheduling window) and the features of the Plans. The storage space is a limit that applies to all Source Materials of the Organisation together. When a limit is reached, the operation concerned cannot be carried out until the Customer switches to a higher Plan or usage falls below the limit. A User may create no more than one Organisation on the Free Plan.

5.3. An Organisation comprises one or more Brands. Users access each Brand separately, as Team Members with a Role. The main permissions of the Roles are set out in the table below.

Team Members may be added by the Owner and by Admins, in the following ways:

• (a) an existing member of the Organisation who has an Account can be added immediately;
• (b) an invitation can be sent, which is valid for 7 days and can be accepted only with the Account belonging to the invited email address;
• (c) the Owner or an Admin may create an Account on behalf of the Team Member; in this case, the Team Member receives a password-setting link valid for 60 minutes.

The Provider sends an email about the addition of a Team Member. A Team Member may be added only with the knowledge of the person to be added. The Owner Role can be granted or revoked only by an Owner, and the last Owner of a Brand cannot be removed. When a Team Member is removed, their membership ends, but their Account and the content they created in the Brand remain. The Team Members of a Brand can see each other's names and email addresses as well as the Brand's team log. Pending invitations also count towards the per-Brand Team Member limit.

5.5. Where the Third-party Service concerned permits the connection, the Service can publish or deliver Generated Content to the following Connected Accounts:

• (a) a Facebook Page;
• (b) a professional (business or creator) Instagram account linked to a Facebook Page;
• (c) a LinkedIn profile and a LinkedIn Page administered by the User, in the Growth and Scale Plans;
• (d) a website based on WordPress;
• (e) a website with a custom programming interface;
• (f) a website using the article retrieval interface of the Service, which itself retrieves the articles intended for it (Section 5.10).

A personal Facebook profile or a personal Instagram account cannot be a target. The Service publishes content to the extent and within the limits permitted by the Third-party Service (for example by observing the daily publishing limit); the Provider does not guarantee the availability of the Third-party Service. Under LinkedIn's rules, the LinkedIn connection has to be reconnected approximately every 60 days. The Service indicates whether a publication was successful on the basis of the response of the target system; checking that the content has actually appeared is the Customer's task.

When a website is connected, the Service may carry out a test publication, which creates a draft on the website and then deletes it. When a social media account is disconnected, the Provider deletes the stored access token; the Customer can revoke the permission granted at the Third-party Service there. When a website is disconnected, publication stops and the Provider deletes the access data provided for the website (password, key, custom HTTP header); revoking any access granted on the website's side is the Customer's task. On switching to a lower Plan, the Connected Accounts above the limit are suspended in accordance with Section 7.4.

5.6. The User may upload documents (PDF, DOCX, TXT, MD, CSV), images (PNG, JPG, WEBP), videos (MP4, MOV, WEBM, M4V) and pasted text to the Brand's knowledge base as Source Material. A file other than a video may be no larger than 25 MB, and pasted text no longer than 200,000 characters; the maximum size of a video file, the storage space and the availability of AI processing of Source Materials are set out in Annex 2. The interface shows the current limits at the time of upload.

With every upload, the User declares that they are entitled to upload the Source Material and to use it in the Service; without this declaration, the upload is not possible. The Service moderates visual content (images, video keyframes, scanned PDF pages) with an automated tool; if moderation flags prohibited content, the Source Material cannot be used (Section 9.4). The Provider does not undertake to scan uploaded files for viruses; the User may upload only files free of malware. The Provider may temporarily restrict uploads where the storage capacity so requires. The website analysis reads the text of the one page specified by the User and does not follow links.

5.7. In the Starter, Growth and Scale Plans, SEO and GEO research can be run using Credits. The research monitor automatically repeats the research at the set frequency and deducts the Credit cost on each run; the Customer can switch off the monitor in the Application. The research relies on external data sources (in particular keyword and search result data, public websites, ad libraries and AI-based search), and its results are estimates; the Provider does not warrant their accuracy or completeness. The Research Report can also be shared through a public sharing link. The link is valid for 1–90 days, and anyone who obtains the link can view the shared content of the Research Report. The Customer is responsible for the sharing.

5.8. The One-off Service can be ordered without an Account from the result page of the Quick Scan, and with an Account from the Application, for the fee set out in Section 7.1. After successful payment, the person placing the order starts the research by answering the questions asked on the interface or by choosing the “without questions” option. The Provider prepares and delivers the Research Report within a reasonable time after the research is started, and in any event within 5 working days. Until the person placing the order has started the research, the Provider sends them reminders by email. If the person placing the order has not started the research within 30 days of payment, the Provider starts it without questions on the 30th day.

The Provider delivers the Research Report by email in PDF format and, for Orders placed from the Application, also in the Application. For Orders without an Account, the Provider stores the Research Report for 90 days from the Order and deletes it thereafter; keeping the PDF version is the responsibility of the person placing the order. If the Research Report is not completed for a reason attributable to the Provider, the Provider refunds the fee within 14 days in accordance with Section 7.8. For a Consumer, Section 15.3 also applies.

5.9. In the Growth and Scale Plans, content can also be shared with persons without an Account through a reviewer link. The link is valid for the period specified on the interface, but for no more than 90 days. An External Reviewer may comment on the content by giving their name. Anyone in possession of the link can view the content as well as the names and comments of the other External Reviewers. The Customer is responsible for passing on the link and for selecting and informing the External Reviewers. Privacy Notice Section 6.3 governs the processing of the External Reviewers' data.

5.10. In the Scale Plan, the Owner may create and revoke a key providing programmatic access (API token); the token is visible only when it is created. Through the API, data on Brands, content plan runs, content and publications can be retrieved, and content plan runs can be started, with Credits being deducted. In the Scale Plan, the Service sends signed notifications (webhooks) about specified events (for example the completion of a content plan run, the success or failure of a publication, or an approval request) to the address specified by the Customer; after repeated failed deliveries, the webhook may be switched off automatically. For a website target, the Service issues an article retrieval key, with which the website can retrieve the published articles intended for it.

Keeping the API token, the article retrieval key and the webhook secret safe and, if their compromise is suspected, revoking them is the Customer's responsibility; the Customer is responsible for the operations carried out with them. Access is protected by rate limiting, which must not be circumvented. In the event of overload or abuse, the Provider may restrict or suspend access.

5.11. In the Scale Plan, the PDF version and the public sharing page of the Research Report can be displayed with the logo, name, accent colour, contact line and footer specified by the Customer. The Application, the reviewer page and the emails sent by the Provider bear the Provider's mark; if the Customer does not set up its own branding, a mark referring to the Service may appear in the PDF version and on the sharing page of the Research Report. The Customer may pass on or resell the Research Report to its own clients. In doing so, it acts in its own name and is responsible for checking and using the Research Report and for the obligations it has undertaken towards its own clients. No legal relationship is established between the Customer's client and the Provider.

5.12. The Service can be used with an internet connection and an up-to-date, modern web browser and requires no installation. The Service does not apply technical protection measures (for example copy protection). The Provider continuously develops and updates the Service; updates, including security updates, take effect without the User's involvement. The interoperability of the Service with Third-party Services depends on their programming interfaces and terms as in force from time to time. For a Consumer, Section 15.6 also applies.

6.1. To produce Generated Content, to process Source Materials (text and image recognition, audio transcription), to moderate visual content and to carry out research, the Service uses AI models developed by third parties. The list of AI providers is set out in Privacy Notice Section 10.1. The Writing partner is an AI-based conversational feature: when using it, the User communicates with an AI system, not with a human. The Provider does not train or fine-tune the AI models.

6.4. The Provider marks Generated Content in a machine-readable format as artificially generated: it embeds a digital watermark invisible to the naked eye in images, and marks texts in the metadata of the outputs (application programming interface, webhook, data export, the metadata of posts sent to a website). Anyone may check free of charge whether the marking is present at https://pagioo.com/mi-jeloles/. The Customer may not remove or alter the marking unless the law permits it. If the Customer uses the Service in the course of its professional activity, it qualifies as a deployer within the meaning of Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act) (the “AI Act”). The Customer is responsible for the disclosure required by Article 50(4) of the AI Act, in particular where it publishes:

• (a) image, audio or video content forming part of Generated Content that resembles real persons, objects, places or events in a deceptively realistic way (deep fake);
• (b) text forming part of Generated Content that serves to inform the public on matters of public interest and that it publishes without human review or editorial control.

6.5. Owing to the way AI models work, similar or identical output may be generated for other Customers from similar input. The Provider does not grant exclusivity in Generated Content and is not liable if another person produces or uses similar content.

7.1. Annex 2 sets out the fees for the Plans, the Credit Packs and the One-off Service in Hungarian forints and in euros; the fee is payable in the currency indicated on the payment page. The fees shown – in forints and in euros alike – are fees including 27% Hungarian value added tax (gross fees). A Consumer pays the gross fee shown, even if the value added tax of another Member State applies to the fee and even if their residence or habitual residence is outside the European Union. If the Customer is a Business registered in another Member State of the European Union and provides a valid EU VAT number when placing the Order, it pays the fee shown without value added tax: the fee shown divided by 1.27, rounded to the nearest whole forint for forint amounts and to the nearest whole cent for euro amounts. The Provider issues the invoice without value added tax under the reverse charge rules, and the Customer accounts for the value added tax itself in its own Member State. If the Customer is a Business established outside the European Union and provides, when placing the Order, the tax number (registration number) issued by the country where it is established, it likewise pays the fee shown divided by 1.27. In that case, under Section 37(1) of the Áfa tv., the place of supply is the place where the Customer is established, so the transaction falls outside the territorial scope of Hungarian value added tax. The Provider issues the invoice without Hungarian value added tax; any tax obligation under the rules of the country where the Customer is established is borne by the Customer. If a Business does not provide its purchasing capacity or the tax number referred to in this Section 7.1, it pays the gross fee shown. The fee for a monthly Subscription is payable monthly, and the fee for an annual Subscription in a single amount, in each case in advance at the beginning of the period. The fee also covers the cost of using the payment method; the Provider does not charge a separate fee for the payment method. The Subscription fee includes all costs relating to the billing period. The Provider makes the Subscription and the Credit Pack available without delay after successful payment.

7.2. The fee can be paid by bank card or by any other payment method offered on the payment page of Stripe Payments Europe, Limited (“Stripe”). The payment data is processed by Stripe; the Provider does not receive the bank card data. Stripe's own terms also apply to the payment. Privacy Notice Section 5.5 governs the processing of personal data in connection with payment.

7.4. The Owner may change the Plan in the Application (Plan Change), including switching between the monthly and the annual period. A Plan Change takes effect immediately. For a paying Customer, Stripe settles the difference between the old and the new fee pro rata and takes it into account at the next charge. Switching to the Free Plan counts as cancellation of the Subscription (Section 14.2). On switching to a lower Plan, the Service suspends the Connected Accounts above the limit, keeping the oldest ones; no data is deleted, and the suspended connections are restored on switching to a higher Plan.

7.5. If a charge fails, the Provider notifies the Owner by email, and Stripe may retry the charge. During a grace period of 3 days from the failed charge, the Plan remains available unchanged. If the fee is not paid during the grace period either, the Subscription ends at the end of the grace period and the Organisation is moved to the Free Plan; the Organisation's content and settings are retained. After the Subscription has ended, the Provider does not initiate any further charges.

7.6. The Provider issues an invoice for every payment of a fee in accordance with the law and sends it electronically. The Customer agrees that the Provider issues the invoice as an electronic invoice. Providing the billing details (name, address, tax number) and ensuring that they are correct is the Customer's responsibility.

7.7. If the Customer is a Business, in the event of late payment it must pay default interest under Section 6:155 of the Ptk. and the forint amount equivalent to EUR 40 under Act IX of 2016 on the Fixed Sum for Recovery Costs.

7.8. The Provider makes any refund due under the Contract to the original payment method, within 14 days of the obligation to refund arising.

8.1. Credits are not money, electronic money or vouchers. They cannot be exchanged for cash or any other means of payment and cannot be transferred to another person or to another Organisation. The Credit cost of individual operations and the content of the Credit Packs are set out in Annex 2; Credits are consumed only by the operations specified in Annex 2. The value (unit price) of one Credit of a Credit Pack is the fee paid for the Credit Pack divided by its quantity of Credits. For a Consumer, Section 15.8 also applies.

8.4. The Service deducts the Credit cost first from the Monthly Credit Allowance and, once that is exhausted, from the Credit Pack or Bonus Credits expiring earliest. If the available Credits are insufficient, the operation cannot be started. The Service shows the expected Credit cost in advance wherever the interface displays it. If an operation fails due to an error of the Service, the Credits deducted are automatically returned to the Monthly Credit Allowance of the current month and can be used until the end of the calendar month. Credits are not returned if the operation is only partly completed (for example, some sections of the Research Report are omitted for lack of data), if the User cancels a campaign that has already started, or if moderation blocks a generated image for breach of Section 9.2. The Service sends a notification when 80% and when 95% of the Monthly Credit Allowance have been used.

8.5. The Provider may credit Bonus Credits as part of a promotion. Bonus Credits can be used for 90 days from being credited, and their value is not refunded. The rules of the referral programme are:

• (a) the User may share their unique referral link on their own channels;
• (b) the invited User's Organisation receives 30 Bonus Credits when its first Brand Brief is approved;
• (c) the inviter's Organisation receives 50 Bonus Credits if the invited Organisation's paid Subscription is still in place on the 14th day after the first payment;
• (d) the inviter may receive rewards for no more than 25 successful invitations.

A Customer who requests a Quick Scan and takes out a Subscription with the same email address within 30 days may receive a one-off free research bonus, and an Organisation whose Subscription has been cancelled may receive Bonus Credits for returning. The Provider may amend or discontinue promotions with effect for the future; this does not affect Bonus Credits already credited. In the event of abuse (in particular self-referral, multiple Accounts or sending unsolicited invitations), the Provider may withdraw the Bonus Credits. Privacy Notice Section 5.10 governs the processing of personal data in the referral programme.

8.6. The Free Plan can be used for an indefinite period, free of charge and without providing a bank card. The Service is not available as a time-limited trial period or as a trial version. The Provider may amend the content of the Free Plan in accordance with Chapter 13.

9.1. The Service may be used only for lawful purposes and in accordance with the Terms and the terms of the Third-party Services. The Customer is responsible for ensuring that the use of the Connected Accounts complies with the rules of the Third-party Service concerned.

9.2. It is prohibited to use the Service, in particular, for the following purposes or in the following ways:

• (a) producing, storing or publishing content that is unlawful, misleading, inciting hatred or violence, or infringing the rights of third parties (in particular copyright, trade mark rights or personality rights);
• (b) producing or altering content that realistically depicts the intimate body parts or sexual activity of an identifiable natural person without the express consent of the person depicted;
• (c) producing, storing or distributing content depicting child sexual abuse;
• (d) misleading impersonation of a real person or organisation;
• (e) producing or distributing political or electoral disinformation;
• (f) sending unsolicited bulk messages, or the mass production of misleading content;
• (g) uploading special categories of personal data (for example health data) where this is not necessary for the intended use of the Service;
• (h) reverse engineering the Service, extracting its source code, circumventing its security measures, overloading it, or security testing it (for example vulnerability scanning or load testing) without the Provider's prior written permission;
• (i) automated or mass creation of Accounts, and abuse of the Free Plan, Credits or the referral programme (for example creating multiple Accounts or Organisations);
• (j) reselling or renting out access to the Service, except for passing on the Research Report in accordance with Section 5.11;
• (k) using Generated Content or the Service to develop an AI model or service competing with the Service.

9.3. The Customer warrants that:

• (a) the Customer Content and the use of the Connected Accounts and of the websites provided or researched are lawful;
• (b) it has the rights and consents necessary for using the Customer Content in the Service, in particular in respect of copyright, trade mark rights and personality rights;
• (c) it has an appropriate legal basis for processing the personal data contained in the Customer Content and has informed the Data Subjects.

For a Consumer, Section 15.7 also applies.

9.5. Anyone may notify the Provider if they consider content stored in the Service to be unlawful. A notice can be submitted electronically, primarily via the reporting form on the Website (https://pagioo.com/bejelentes/), and also at [email protected], and must contain:

• (a) an explanation of why the notifier considers the content to be unlawful;
• (b) the exact location of the content (for example the address of the link);
• (c) the notifier's name and email address, unless the notice concerns a criminal offence related to child sexual abuse;
• (d) a statement by the notifier that they are acting in good faith and that the information and allegations in the notice are accurate and complete.

The Provider acknowledges receipt of the notice; for a notice submitted via the form, it does so automatically, by an email that also contains the text of the notice. The Provider decides on the notice without undue delay, in a diligent, non-arbitrary and objective manner, and informs the notifier of its decision, of the available means of redress and – if it used one – of the use of an automated tool. The Provider removes or disables access to content found to be unlawful without undue delay. In the event of copyright or trade mark infringement, the rightholder may also use the notice and takedown procedure under Section 13 of Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (the “Ekertv.”). Privacy Notice Section 5.20 governs the processing of personal data relating to notices.

9.6. The User or Customer affected by a measure, as well as the notifier, may lodge a complaint against a decision under Section 9.4 or 9.5 at [email protected] within 6 months of being informed of the decision. A member of the Provider's staff decides on the complaint by human review, without undue delay, and the Provider informs the person who lodged the complaint of its decision, with a statement of reasons. A person entitled to lodge a complaint may, irrespective of the complaint, apply to a court and, under Act CIV of 2023 on Certain Rules of Online Intermediary Services, lodge a complaint with the President of the National Media and Infocommunications Authority (Nemzeti Média- és Hírközlési Hatóság).

10.1. The software, interface, templates and databases of the Service, the Application and the Website, the name and mark “Pagioo”, and the other elements of the Service are subject to the rights of the Provider or its licensors. For the term of the Contract, the Provider grants the Customer and the Users a non-exclusive, non-transferable and non-sublicensable right to use the Service for its intended purpose. The Terms do not create any other rights in the elements of the Service.

10.3. To the extent that they are transferable, the Provider transfers to the Customer any rights it may have in Generated Content upon the creation of the Generated Content. Otherwise, the Provider grants the Customer a royalty-free, transferable and sublicensable licence to them, without limitation as to territory, time or mode of use. This also applies to Generated Content produced in the Free Plan. This does not include the template, structure and presentation of the Research Report or the Provider's mark; the Customer receives a licence to these to the extent necessary to use the Research Report. The Provider does not warrant that Generated Content is protected by copyright. The Customer also grants the licence under Section 10.2 in respect of Generated Content.

10.4. The Customer warrants that it is entitled to have the websites it specifies for website analysis, research and the research monitor, whether its own or those of third parties, analysed. The Provider reads and processes only the text and data from the websites that are necessary for the analysis. If the operator of a website objects to the reading, the Customer must stop the analysis of the website, and the Provider may stop the analysis.

10.5. If the Customer or the User makes a suggestion or provides feedback about the Service, the Provider may use it free of charge and without limitation in time or territory to develop the Service; the person providing the feedback expressly waives any remuneration for this. For a Consumer, after the Contract has ended the Provider uses the feedback only in a way that does not identify the Consumer.

11.1. The Provider is liable for damage caused by a breach of contract in accordance with the Ptk. The Provider is liable for the subcontractors it engages in providing the Service (in particular the AI providers, the network service providers and the email delivery provider) as if it had acted itself. Third-party Services are not subcontractors of the Provider (Section 11.2).

11.5. Sections 11.2–11.4 and 11.7 do not apply:

• (a) to intentional and grossly negligent breaches of contract;
• (b) to breaches of contract causing harm to human life, physical integrity or health;
• (c) where the law does not permit the limitation or exclusion of liability.

The Terms do not affect the Provider's liability towards Data Subjects under Article 82 GDPR.

11.8. The Provider makes reasonable efforts to ensure the continuous availability of the Service, but undertakes a numerical service level only in a separate agreement between the parties subject to a fee. The Provider gives advance notice of planned maintenance on the interface or by email and, where possible, schedules it for low-traffic periods. The Provider may restrict the Service as a whole or certain features of it, without prior notice, for the necessary period, for security reasons, to remedy a malfunction or to prevent abuse. For a Consumer, Section 15.6 also applies.

11.9. Neither party is liable for a breach of contract if it was caused by a circumstance outside its control that was unforeseeable at the time the Contract was concluded, and it could not be expected to avoid the circumstance or to prevent the damage. Such circumstances include, in particular, natural disasters, war, epidemics and widespread internet or power outages. A failure by a subcontractor of the Provider does not in itself constitute such a circumstance. This Section does not affect the obligation to pay fees.

12.1. The Provider's own processing of personal data – including the use of cookies and similar technologies – is described in the Privacy Notice; cookies are covered by Privacy Notice Chapter 9. The Privacy Notice does not form part of the Contract. Accepting the Terms does not constitute consent to any processing; where processing requires consent, the Provider asks for it separately.

12.2. With regard to the personal data contained in Customer Content and Generated Content, the Provider is the Customer's processor. The terms of the processing are set out in Annex 1.

12.4. The Provider uses Customer Content and Generated Content solely to provide the Service to the Customer concerned. The Provider does not use Customer Content or Generated Content to train AI models. Nor does the Provider transfer Customer Content or Generated Content to third parties for the purpose of training AI models. The Provider produces only aggregated statistics on the use of the Service that contain no personal data.

13.2. The Provider notifies the Owners of the Organisations and the Users of the amendment by email at least 30 days before it takes effect, and also publishes it in the Application. The notice contains a summary of the substance of the amendment and its reason, the date on which it takes effect and the rights under Section 13.4. The amended Terms are available on the Website before they take effect.

13.3. An increase in the Subscription fee applies at the earliest from the first billing period starting after the amendment takes effect. A fee increase does not affect a period already paid for or Credit Packs already purchased.

13.5. An amendment that is exclusively favourable to the Customer, that is required by law or that cannot be postponed for the security of the Service may take effect upon publication; the Provider notifies it subsequently in accordance with Section 13.2. For a Consumer, Section 15.9 also applies.

13.6. The Terms are published with a version number and an effective date. The current version of the Terms is available at https://pagioo.com/aszf/, and its earlier versions at https://pagioo.com/aszf/archivum/, in a form that can be stored and retrieved.

14.1. The Contract is concluded for an indefinite period. A Subscription runs for a monthly or annual period and renews in accordance with Section 7.3. An Order for the One-off Service is performed upon delivery of the Research Report.

14.3. The Provider offers a voluntary money-back guarantee on the following conditions:

• (a) the guarantee can be used once, within 14 days of the Organisation's very first Subscription payment;
• (b) the Subscription must be active and not cancelled at the time of the request;
• (c) the refund can be requested by the Owner in the Application;
• (d) the amount refunded is the amount of the first payment, less the value of the Credits used from the Monthly Credit Allowance since the payment; the value of one Credit is the fee paid divided by the total quantity of Credits of the Monthly Credit Allowances purchased with it (12 Monthly Credit Allowances for an annual Subscription);
• (e) the fee for Credit Packs is not refunded;
• (f) upon the refund, the Subscription ends immediately and the Organisation is moved to the Free Plan.

Credits used are not restored, and their value is not refunded. The guarantee is voluntary and does not affect the statutory rights of Consumers.

14.4. The User can delete their Account on the “Settings” page of the Application. Deletion is immediate and irreversible: the Provider replaces the name and email address of the Account with a marker that cannot be used for identification, disables login, and all of the User's memberships end. Deleting the Account terminates the User's Contract. If the User is the sole Owner of the Organisation, the other Team Members of the Organisation immediately lose their access, and the Organisation's Subscription ends at the end of the current period, without refund of the fee for the remaining period. In this case, if the Customer is a Consumer, the Subscription ends upon deletion of the Account, and the Provider makes a refund in accordance with Section 15.8. The Customer may export the Organisation's data before the Account is deleted in accordance with Section 14.7 and, after the deletion, may request by email – through a person authorised to represent it – that the data be released during the data retrieval period under point (f) of Section 14.7. What happens to personal data after deletion is governed by Privacy Notice Section 12.4.

14.5. The Provider may terminate the Contract without giving reasons, by email, with a notice period of at least 30 days. For a Subscription, termination can take effect only on the last day of a – prepaid – billing period, and the Provider gives notice of termination at least 30 days before the end of that period; the fee paid is not refunded, except under the guarantee in Section 14.3. During the notice period, the Provider continues to provide the Service unchanged; it performs a One-off Service already paid for irrespective of the termination. The Provider refunds the value of the unused Credits of any Credit Pack still valid at the time the Contract ends, at the unit price under Section 8.1 and in accordance with Section 7.8. After the Contract has ended, the Provider provides the data retrieval period under Section 14.7. For a Consumer, Section 15.8 also applies.

14.7. The Customer may request the Provider to hand over the data exportable from the Service to it, to transfer it to another data processing service provider or to its own infrastructure, or to delete it. Under Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonised rules on fair access to and use of data and amending Regulation (EU) 2017/2394 and Directive (EU) 2020/1828 (Data Act) (the “Data Act”), the following rules apply to switching and data export:

• (a) the request can be submitted at any time at [email protected]; the Provider provides information on the procedures, methods and formats of switching and data portability, and on the restrictions and technical limitations known to it, in this Section and on the page at https://pagioo.com/adatexport/;
• (b) the notice period required to initiate switching is 2 months and starts upon receipt of the request; the Customer may specify a shorter notice period in its request;
• (c) during the transitional period of 30 days following the expiry of the notice period, the Service continues to operate unchanged, and the Provider supports the switching with reasonable assistance, maintaining security and continuity, and informs the Customer of the known risks to continuity;
• (d) if the transitional period is not technically feasible, the Provider notifies the Customer of this, with reasons, within 14 working days and specifies an alternative transitional period of no more than 7 months; the Customer may extend the transitional period once, by a period it considers appropriate;
• (e) the Contract ends upon the successful completion of the switching or, if the Customer requests only deletion, at the end of the notice period; the Provider notifies the Customer of the termination by email;
• (f) after the end of the transitional period, or after the Contract has ended for any other reason, a data retrieval period of at least 30 days is available;
• (g) the data that can be exported on a self-service basis is a downloadable, machine-readable JSON summary of the User's Account and usage data;
• (h) the data that can be exported on request by email is the Customer Content and the Generated Content (including generated images), the original files of the Source Materials, the Research Reports, and the metadata on the status, scheduling, approval and publication of the content. The Provider releases these within 30 days of receipt of the request, in a commonly used, machine-readable format;
• (i) the Provider's prompt templates, the search index and the vector representations derived from it, and the Provider's system security logs cannot be exported, because they constitute the Provider's trade secrets or form part of the internal operation of the Service. These exceptions do not hinder switching, because the search index can be regenerated from the exported Source Materials. The data of other Customers cannot be exported;
• (j) switching and export are free of charge;
• (k) for an annual Subscription, if the Contract ends due to switching before the end of the period paid for, the Provider charges, out of the annual fee paid, the monthly Subscription fee for each month started up to the termination. The Provider refunds the difference in accordance with Section 7.8. This is the early termination fee, communicated in advance, within the meaning of the Data Act. For a Consumer, Section 15.8 applies.

While the Contract is in force, apart from switching, the export under point (h) can be requested once per calendar quarter; this does not limit the rights of access to personal data and to data portability.

On the page at https://pagioo.com/adatexport/, the Provider publishes and keeps up to date a register of the data structures and data formats of the exportable data and of the relevant standards, as well as the jurisdiction of the infrastructure used to provide the Service. On the same page, it describes the technical, organisational and contractual measures it has taken to prevent unlawful international governmental access to and transfer of non-personal data.

14.8. The Provider permanently deletes the Customer Content and the Generated Content:

• (a) in the case of successful switching, or if the Customer requests deletion, upon expiry of the data retrieval period;
• (b) in other cases, if no active Team Member remains in the Organisation, 90 days after that time.

Deletion does not extend to data that must be retained under the law.

14.9. The provisions on the payment of fees, liability and indemnity, intellectual property, data processing, data retrieval and disputes, and all provisions that by their nature relate to the period after termination, continue to apply after the Contract has ended.

15.1. This Chapter applies only to Consumers and, in the event of conflict, takes precedence over the other provisions of the Terms. Provisions beginning with the words “If the Customer is a Business” do not apply to Consumers. No provision of the Terms may be interpreted as depriving a Consumer of rights granted by law that cannot be excluded by contract.

15.2. The Terms contain the information required by Section 11(1) of Government Decree 45/2014 (II. 26.) on the Detailed Rules of Contracts between Consumers and Businesses (“Government Decree 45/2014”) in the following places:

• (a) the main characteristics of the Service: Chapters 5 and 6;
• (b) the Provider's name, postal address, telephone number and electronic contact details, and where complaints can be submitted: Sections 1.1, 1.3 and 15.10;
• (c) the total price including taxes and all costs per period: Section 7.1;
• (d) the conditions of payment and performance: Sections 4.3, 5.8 and 7.1–7.5;
• (e) the right of withdrawal and the right of termination, their loss, the proportionate fee and the model form: Sections 15.3 and 15.4;
• (f) the statutory warranty for lack of conformity: Section 15.6;
• (g) customer service: Section 1.3;
• (h) the absence of a code of conduct: Section 4.7;
• (i) the duration of the Contract, renewal and the conditions of termination: Sections 7.3, 14.1, 14.2 and 14.4; the minimum duration of the Consumer's obligations is one monthly or one annual period of the Subscription;
• (j) functionality, technical protection measures, compatibility and interoperability: Sections 5.5 and 5.12;
• (k) complaint handling and conciliation boards: Section 15.10.

The Provider does not apply personalised prices based on automated decision-making. Before the Order is submitted, directly above the order button, the Provider prominently displays the main characteristics of the service ordered, the total price, all costs per period, and the conditions of renewal and termination. The label of the order button clearly indicates that the Order involves an obligation to pay. The Provider confirms the Contract on a durable medium (by email) at the latest when performance begins. The confirmation contains the above information, or the place where it is available on a durable medium, as well as the Consumer's request and declaration under Section 15.3.

15.3. A Consumer has the right to withdraw from a contract subject to a fee without giving reasons within 14 days of its conclusion (the Order). When placing the Order – including a Plan Change to a higher Plan – the Consumer may expressly request, by ticking a separate checkbox, that the Provider begin performance before the withdrawal period expires. Together with the request, the Consumer declares that they acknowledge that, once the service has been performed in full, they can no longer exercise their right of withdrawal or termination. The effect of the request is as follows:

• (a) for a Subscription and a Credit Pack, after performance has begun the Consumer has the right to terminate without giving reasons within the 14-day period, and must pay a fee proportionate to the service performed until the termination is communicated;
• (b) for a Subscription, the proportionate fee is the part of the fee paid for the Subscription that is proportionate to the number of days elapsed from the start of performance until the termination is communicated;
• (c) for a Credit Pack, the extent of the service performed is the quantity of Credits used. The Provider performs each operation carried out with a Credit of the Credit Pack in full, and separately from the other operations, by carrying it out; the price of the operation is its Credit cost multiplied by the unit price under Section 8.1. The proportionate fee is therefore the value, at the unit price under Section 8.1, of the Credits of the Credit Pack used until the termination is communicated; Credits used are not restored. If the Consumer has used up all the Credits of the Credit Pack within the period, their right of termination is lost upon full performance;
• (d) for the One-off Service, the right of withdrawal is lost upon completion and delivery of the Research Report; the Provider confirms the request and the acknowledgement in accordance with Section 15.2;
• (e) if the research under the One-off Service has not started by the end of the withdrawal period, the Consumer may withdraw within the period, and the full fee is refunded.

If the Consumer has not requested that performance begin, they are not obliged to pay any fee upon withdrawal or termination. The Free Plan is free of charge; the Consumer may terminate the Contract at any time by deleting the Account (Section 14.4).

15.4. The Consumer may exercise the right of withdrawal or termination by a declaration sent before the end of the period:

• (a) by an unequivocal declaration sent via the reporting form on the Website (https://pagioo.com/bejelentes/), to [email protected] or to the postal address under Section 1.1;
• (b) using the model form in Annex 3;
• (c) using the withdrawal function labelled “Withdraw from contract here” („Elállás a szerződéstől”), which is continuously available during the withdrawal period on the “Billing” page of the Application or, for an Order without an Account, at the link provided in the confirmation email, and with which the declaration can be sent using the “Confirm withdrawal” („Elállás megerősítése”) button.

In a declaration made using the withdrawal function or the reporting form, the Consumer provides their name, the details identifying the Contract and the electronic contact details to which they request the acknowledgement of receipt. The Provider automatically sends an acknowledgement of receipt of such a declaration by email without undue delay, stating the content of the declaration and the date and time of its receipt. The Provider acknowledges receipt of a declaration made by email, by email and without undue delay. To meet the deadline, it is sufficient for the Consumer to send the declaration before the period expires.

15.5. The Provider refunds the amount due to the Consumer – less the proportionate fee under Section 15.3 – to the original payment method within 14 days of becoming aware of the withdrawal or termination. Upon withdrawal, upon termination and whenever the Contract ends for any reason, the Consumer may retrieve the content that they entered into or created in the Service and that does not constitute personal data, free of charge and in a commonly used, machine-readable format, in accordance with Section 14.7.

15.6. The Provider is liable under the statutory warranty for lack of conformity (kellékszavatosság) for any defect in the digital service (non-conforming performance) throughout the term of the Contract. The statutory warranty is governed by the Ptk. and by Government Decree 373/2021 (VI. 30.) on the Detailed Rules of Contracts between Consumers and Businesses for the Sale of Goods and the Supply of Digital Content and Digital Services (“Government Decree 373/2021”). The Consumer must notify the Provider of a defect without delay after discovering it; a defect notified within 2 months of its discovery is deemed to have been notified without delay. In the event of a defect, the Consumer may request that the service be brought into conformity free of charge within a reasonable time. The Consumer may request a proportionate price reduction for the period of non-conforming performance, or may terminate the Contract by a declaration addressed to the Provider, if:

• (a) bringing the service into conformity is impossible or would involve disproportionate additional costs;
• (b) the Provider has not remedied the defect within a reasonable time;
• (c) the defect recurs despite the attempt to bring the service into conformity;
• (d) the defect is so serious as to justify an immediate price reduction or termination; or
• (e) the Provider has not undertaken to bring the service into conformity, or it is clear that it will not do so within a reasonable time or without significant inconvenience to the Consumer.

The Contract may not be terminated if the defect is minor; the burden of proving this lies with the Provider. In the case of a price reduction, the Provider refunds the proportionate part of the fee and, in the case of termination, the part of the fee attributable to the period of non-conforming performance, in accordance with Section 7.8; Section 15.8 governs fees paid in advance for the period after termination and Credit Packs. Throughout the term of the Contract, the burden of proving that the Service was in conformity lies with the Provider. The Consumer must cooperate reasonably in establishing whether the cause of the defect lies in the Consumer's digital environment, in particular in the absence of the conditions under Section 5.12. Product warranty (termékszavatosság) does not apply to the Service.

The Provider informs the Consumer separately, at the conclusion of the Contract, of the characteristics under Section 6.2 (the possible inaccuracy of Generated Content, and the absence of any warranty as to copyright protection and business results), and the Consumer expressly accepts them by ticking a separate checkbox. Otherwise, Section 6.2 does not apply to the Consumer. Section 11.8 does not limit the Consumer's rights under the statutory warranty.

15.7. Towards a Consumer:

• (a) Sections 11.3, 11.4, 11.6, 11.7 and 11.10 do not apply;
• (b) Section 11.2 applies only to the dependence on Third-party Services described in advance in Sections 5.5 and 5.12, and does not limit the Provider's liability for its subcontractors;
• (c) the Consumer is liable for a breach of the warranty under Section 9.3 in accordance with the rules of the Ptk. on breach of contract;
• (d) if the Contract ends under Section 14.6, the pro rata part of the fee paid that is attributable to the period after termination is refunded to the Consumer, unless the termination was caused by the Consumer's serious breach of contract.

15.8. If the Consumer's Contract or Subscription ends before the end of the period paid for or of the validity period of the Credit Pack, the Provider refunds, in accordance with Section 7.8:

• (a) the value of the unused Credits of the Credit Pack at the unit price under Section 8.1;
• (b) the pro rata part of the Subscription fee attributable to the period after termination, if the Contract or the Subscription ends under Section 14.4 (deletion of the Account), Section 14.7 (switching) or Section 15.6 (termination due to non-conforming performance).

No refund is due in the case of termination due to the Consumer's serious breach of contract, after the 90-day validity of the Credit Pack has expired, for Bonus Credits, or for the part of the Monthly Credit Allowance that has expired under Section 8.2.

15.9. Beyond what is necessary to maintain conformity, the Provider may modify the Service provided to a Consumer only for a reason specified in Section 13.1 and without additional cost to the Consumer, and it informs the Consumer of the modification clearly. If the modification is detrimental to the Consumer, the Provider notifies the Consumer in advance on a durable medium (by email). In that case, the Consumer may terminate the Contract free of charge within 30 days of receiving the notice or – if later – of the modification taking effect, and the pro rata part of the fee paid for the period after termination is refunded. The Consumer has no right to terminate if the detriment is minor or if they can continue to use the Service without the modification at no additional cost.

The Provider may increase the fee for a Consumer's Subscription – except for an increase resulting directly from a change in the law (point (a) of Section 13.1) – only on the basis of point (e) of Section 13.1, and no more than once within 12 months. The increase may not exceed the consumer price index published by the Hungarian Central Statistical Office (Központi Statisztikai Hivatal) for the previous calendar year or – if the fee increase is due to increased costs – the share of the cost increase attributable to the fee, as quantified in the notice under Section 13.2. If the costs taken into account in setting the fee decrease permanently, the Provider takes this into account in the Consumer's favour at the next fee adjustment.

15.10. A Consumer may submit a complaint about the conduct of the Provider, or of a person acting on behalf of the Provider, in writing, primarily via the reporting form on the Website (https://pagioo.com/bejelentes/), and also to [email protected] or to the postal address under Section 1.1. The Provider acknowledges receipt of the complaint: for a complaint submitted via the form, automatically, by an email that also contains the text of the complaint; for a complaint received by email, without delay. The Provider responds to a written complaint in writing, on the merits and with reasons, within 30 days of its receipt. The Provider retains the complaint and the response for 3 years. If the Provider rejects the complaint, it informs the Consumer in its response of the consumer protection authority and the conciliation board competent for the Consumer's place of residence, with their contact details, and of the fact that it has not made a general declaration of submission.

Under Act CLV of 1997 on Consumer Protection (the “Fgytv.”), a Consumer may apply, for the out-of-court settlement of a dispute, to the conciliation board competent for their place of residence or stay, or to the conciliation board specified in their application. The names, areas of competence and contact details of the conciliation boards are set out in Annex 4. The Provider cooperates in conciliation board proceedings; it has not made a general declaration of submission under the Fgytv. To initiate consumer protection proceedings before an authority, the Consumer may apply to the government office competent for their place of residence.

The Consumer's right to bring proceedings before the court of their place of residence cannot be restricted (Section 27(5) of Act CXXX of 2016 on the Code of Civil Procedure (the “Pp.”)). The choice of Hungarian law does not deprive the Consumer of the protection afforded by those provisions of the law of their habitual residence that cannot be derogated from by agreement (Article 6(2) of Regulation (EC) No 593/2008 of the European Parliament and of the Council of 17 June 2008 on the law applicable to contractual obligations (Rome I) (the “Rome I Regulation”)).

16.1. The Customer and the User may submit complaints about the Service at [email protected]. The Provider investigates the complaint and responds within a reasonable time. Section 15.10 governs complaints by Consumers.

16.2. The Contract is governed by Hungarian law. For a Consumer, Section 15.10 also applies.

16.4. Privacy Notice Chapter 13 governs complaints and remedies relating to the processing of personal data.

17.1. The Provider sends notices to the Customer and the User to the email address associated with the Account or in the Application and, for an Order without an Account, to the email address provided when placing the Order. A notice sent by email is deemed delivered on the working day following its sending, unless the Provider receives a notification that delivery has failed; for a Consumer, this is a presumption that the Consumer may rebut. Keeping the email address up to date is the User's responsibility. The Customer and the User send their declarations to the Provider to [email protected].

17.2. If any provision of the Terms is invalid or unenforceable, this does not affect the validity of the other provisions. The provisions of the law apply in place of the invalid provision.

17.3. The Provider may engage subcontractors to provide the Service; Annex 1 governs Sub-processors. The Customer may transfer the Contract only with the Provider's prior written consent. For a Consumer, the Provider may transfer the Contract – except in the case of legal succession by operation of law – only with the Consumer's consent. If the Customer is a Business, the Provider may transfer the Contract to its legal successor or to an affiliated undertaking by notifying the Customer; the Customer consents to this in advance by accepting the Terms.

17.4. The Terms, together with their annexes and the Orders, constitute the entire agreement between the parties and supersede all prior statements and agreements on their subject matter, except for any individual agreement concluded by the parties in writing. For a Consumer, this does not affect the legal effect of the Provider's public statements.

17.5. If the Provider does not exercise any of its rights, or exercises it late, this does not constitute a waiver of that right.

M1.1. With regard to the personal data contained in Customer Content and Generated Content, the Customer is the controller and the Provider is the processor. If the Customer itself processes this personal data on behalf of another controller (for example its own client), the Provider acts as a further processor of the Customer, and the Customer warrants that it is authorised by the controller to have the processing under this Annex carried out. The Customer is responsible for having a legal basis for processing the personal data entered into the Service and for informing the Data Subjects. In matters relating to the processing of personal data, this Annex takes precedence over the other provisions of the Terms.

M1.2. The characteristics of the processing are set out in the table below.

M1.3. The categories of Data Subjects and the types of personal data are determined by the Customer. The Data Subjects are typically the Customer's clients, employees and contact persons, persons appearing in the Source Materials and on the websites provided, External Reviewers, and the holder of a connected LinkedIn profile. The personal data typically comprises names, contact details, job titles, images, voices and other data contained in the content. Uploading special categories of personal data is not an intended use; if the Customer nevertheless enters such data, the Customer is responsible for its legal basis.

M1.4. The Provider processes personal data only on the documented instructions of the Customer. The Terms, this Annex and the use of the features of the Service by the Customer or the User, in particular settings, generation and publication, constitute instructions. The instructions also cover the transfer of personal data to the recipients in third countries specified in Privacy Notice Section 10.1. If Union or Member State law requires the Provider to carry out other processing, the Provider informs the Customer before the processing, unless that law prohibits this. If, in the Provider's opinion, an instruction infringes the GDPR or other data protection provisions, the Provider informs the Customer without delay.

M1.5. The Provider ensures that the personal data is accessible only to those of its staff or subcontractors who need access to perform their tasks and who have committed themselves to confidentiality or are under a statutory obligation of confidentiality.

M1.6. In accordance with Article 32 GDPR, the Provider applies technical and organisational measures appropriate to the risk, in particular:

• (a) encrypted data transmission (TLS);
• (b) logical separation of data by Organisation and by Brand;
• (c) Role-based access management;
• (d) encrypted storage of the access tokens of social media accounts and of the passwords and secret keys provided for websites;
• (e) storage of keys and links providing access (in particular API tokens and invitation, reviewer and sharing links) in hashed form;
• (f) limiting login attempts and logging significant operations.

M1.7. The Customer gives the Provider general authorisation to engage Sub-processors. The list of Sub-processors is set out in Privacy Notice Section 10.1. The Provider notifies the Customer by email of the engagement or replacement of a Sub-processor at least 15 days in advance or, if the replacement is urgent to maintain the continuity of the Service, without delay before the replacement. The Customer may object on reasonable data protection grounds within 15 days of the notification. If the parties do not reach agreement on the objection, the Customer may terminate the Contract free of charge with effect from the date on which the change takes effect; in that case, the pro rata part of the fee paid for the unused period is refunded. The Provider imposes on the Sub-processor data protection obligations essentially equivalent to those set out in this Annex and is liable to the Customer for any breach of obligations by the Sub-processor as if it had acted itself.

M1.8. The Provider transfers personal data to a third country only to the recipients specified in Privacy Notice Sections 10.1 and 10.2, with the safeguard specified there (adequacy decision or standard data protection clauses).

M1.9. If a Data Subject contacts the Provider directly with a request concerning the data under Section M1.1, the Provider forwards the request to the Customer without undue delay and acts on the merits only on the Customer's instructions. The Provider may inform the Data Subject, without naming the Customer, that their request has been forwarded to the controller. The Provider assists the Customer in fulfilling data subject requests through the features of the Service and through assistance provided at the Customer's request.

M1.10. The Provider notifies the Customer of any personal data breach affecting the personal data under Section M1.1 without undue delay after becoming aware of it, and in any event within 72 hours. The notification contains – on the basis of the information available – the nature of the breach, the categories and approximate number of the data records and Data Subjects concerned, the likely consequences, the measures taken or planned, and the contact details of the contact person. Taking into account the nature of the processing and the information available to it, the Provider assists the Customer in fulfilling its obligations under Articles 32–36 GDPR (security, breach notification, data protection impact assessment, prior consultation).

M1.11. When the Contract ends, the Provider enables the retrieval of the data in accordance with Sections 14.7 and 14.8 of the Terms and then deletes the personal data at the time specified there. If the Provider makes backups, the personal data is deleted from the backups at the end of the backup cycle. Data that must be retained under Union or Member State law is exempt from deletion.

M1.12. The Provider makes available to the Customer the information necessary to demonstrate compliance with the obligations set out in this Annex, primarily by providing documentation. The Customer, or an auditor mandated by it, may also carry out an on-site audit; the auditor is bound by confidentiality and may not be a competitor of the Provider. An on-site audit may be carried out no more than once a year – and additionally in the event of a personal data breach or a request from an authority – after written notice sent at least 30 days in advance. The audit may be carried out during working hours, without unreasonably disrupting the Provider's operations and without prejudice to business secrets or to the data of other Customers. The Customer bears the costs of the audit.

M1.13. Access by the Provider under Section 12.3 of the Terms forms part of the processing; the Customer gives instructions for such access for the purposes and within the limits set out there.

M1.14. As between the parties, Chapter 11 of the Terms applies to liability in connection with the processing under this Annex. This does not affect the parties' liability towards Data Subjects under Article 82 GDPR.

M2.1. The fees for the Plans are set out in the table below. The amounts are gross fees including 27% Hungarian value added tax; a Business established in another Member State that has an EU VAT number, and a Business established outside the European Union that provides its tax number, pay the amount without value added tax (Section 7.1 of the Terms).

M2.2. The limits and features of the Plans are set out in the table below.

M2.3. The Credit cost of individual operations is set out in the table below.

After the first Brand Brief has been approved, the Service produces one sample article without deducting Credits.

M2.4. The Credit Packs are set out in the table below. Each Credit Pack is valid for 90 days from purchase.

M2.5. The fee for the One-off Service is HUF 14,990, or EUR 39 (gross).