01The Operator of the Platform

1.1. The Libertos News Platform is a product operated by BOSTAN ENTERPRISE S.R.L., a Romanian legal entity with its registered office at București, str. Navigatorilor 2 A, sector 1, Romania, registered with the Trade Register Office under no. J2026046044002, CUI 55281310, contact e-mail [email protected], hereinafter referred to as the “Operator”.

1.2. Libertos offers users a digital information and content-personalisation service, by identifying, aggregating, analysing and synthesising information originating from publications, press agencies and other third-party sources.

1.3. The content available through Libertos is synthesised with the help of artificial intelligence systems, on the basis of the articles and information identified in the sources indicated within the Platform and of the topics preferred by users according to the choices they make when registering on the Platform. Through this selection of topics, the Platform offers you only informative material from your areas of interest.

02Definitions

For the purposes of this document:

• “Platform” means the website www.libertos.org and the digital services associated with it;
• “User” means any person who accesses or uses the Platform, whether or not they hold an Account;
• “Account” means the individual account created by the User in order to access the personalised services;
• “Subscriber” means the User who purchases a paid subscription plan;
• “Service” means the functionalities made available through Libertos, including briefings and personalised information feeds, access to content, the selection of interests and of the frequency of communications, and other functionalities available at any given time;
• “Briefing” means the personalised selection and synthesis of information created by Libertos according to the interests, fields and parameters selected by the User;
• “Sources” means the publications, press agencies, websites, databases and other third-party sources on the basis of which information is identified and synthesised;
• “Subscription” means paid access, for a fixed period or with automatic renewal, to the functionalities included in the plan chosen by the User;
• “Order” means the electronic expression of the User's intention to purchase a Subscription or another paid Service through the Platform.

03Nature of the Service and use of artificial intelligence systems

3.1. Nature and functionalities of the Service

Libertos is a digital information service that facilitates Users' access to information of interest by identifying, selecting, aggregating, analysing, synthesising, structuring and presenting information originating from external sources.

Depending on the functionalities available, the User may configure their fields and topics of interest, geographical area, language, the frequency of Briefings and other relevant preferences, for the purpose of being provided with an information feed adapted to their choices.

The Service uses automated technologies and artificial intelligence systems to carry out these operations and to generate or synthesise the content presented through the Platform.

Libertos is not a source publication for all of the information presented through the Platform. Where information is based on material originating from third parties, the relevant sources may be indicated within the Platform so as to allow the User to consult the original material.

3.2. The role of artificial intelligence systems

In order to provide and improve the Service, Libertos also uses systems, models and other technologies based on artificial intelligence (“AI Systems”), including, where applicable, solutions supplied or operated by specialised third-party providers.

Depending on the characteristics and functionalities of the Service, the AI Systems may be used, in whole or in part, for:

• a) identifying and selecting relevant information;
• b) aggregating and grouping information relating to the same event or topic;
• c) analysing and comparing information originating from several sources;
• d) synthesising, summarising, rephrasing and structuring information;
• e) identifying differences, perspectives or common elements between reports originating from different sources;
• f) classifying and prioritising information;
• g) generating or assisting in the generation of Briefings;
• h) personalising content according to the preferences and criteria relevant to the User; and
• i) other technical operations necessary for providing the functionalities of the Platform, within the limits and under the conditions laid down by the applicable legislation.

The use of AI Systems is a technological component of the Service, for the selection of informative material. It does not alter the informative nature of the content provided and does not turn the information available through Libertos into legal, financial, tax, medical or investment advice or into any other form of professional advice.

3.3. Sources used

The information processed and presented through Libertos may originate from press publications, press agencies, official releases and official pages, websites, databases, public sources and other external sources relevant to the provision of the Service.

Libertos may use technical, automated and/or editorial mechanisms for selecting, comparing, classifying and verifying the information and the sources used.

However, Libertos does not in all situations control the content published by third parties and does not guarantee that the information contained in external sources is at all times complete, accurate, up to date or free of errors.

The indication, use or inclusion of a source within the Platform does not imply that Libertos is affiliated with that source, nor that Libertos approves or endorses all of the opinions, statements or information published by it.

Libertos does not guarantee that all of the information or all of the sources existing in relation to a particular event or topic will be identified, analysed or included in a Briefing.

3.4. Quality of the information and limitations of the AI Systems

Libertos makes reasonable efforts to ensure that the information provided through the Service is relevant, useful and referenced to the sources identified.

The User understands that the AI Systems, by the nature of the technology used, may generate incomplete or inaccurate results and may interpret, synthesise, classify or contextualise certain information incorrectly. In particular, content generated or processed with the help of the AI Systems may contain errors, omissions, inconsistencies, inaccurate interpretations or information that is no longer current, including where such deficiencies originate from the external sources used.

Libertos may use, depending on the nature of the Service and the risks identified, technical and automated measures and/or human intervention intended to improve the quality, relevance, accuracy and traceability of the information provided. Nevertheless, Libertos does not guarantee the exhaustiveness or the absolute absence of errors in the content generated, synthesised or processed with the help of the AI Systems.

This clause does not exclude or limit the Operator's obligations regarding the provision and conformity of the Service, nor any other rights of the User which cannot be excluded or limited under the applicable legislation.

For information that may form the basis of decisions with legal, financial, medical, professional or other significant consequences, the User must consult the relevant original sources and, where appropriate, seek the opinion of a qualified professional.

3.5. Personalisation of content

Where personalised functionalities are used, Libertos uses AI Systems and/or other automated systems to select, order and present the information considered relevant to the User.

Personalisation may take into account, as applicable, information such as the fields and topics of interest selected, the preferences expressed within the Platform, the language, the geographical area, the frequency of Briefings and other criteria relevant to the provision of the Service.

Consequently, two Users may receive different Briefings or selections of information, even if these are generated in the same period, since they are based on the fields selected differently by those same Users.

The personalisation of content does not guarantee that all of the information that might be of interest to the User will be identified or included, nor that the order in which the information is presented reflects its objective importance.

3.6. Personal data in the context of the use of AI Systems

In so far as the operation of the AI Systems involves the processing of Users' personal data, such processing is carried out in accordance with the applicable legislation on the protection of personal data and with the Libertos Privacy Policy.

Libertos seeks to apply the principle of data minimisation, so that the data used or transmitted in the course of operations carried out through the AI Systems are limited to those that are adequate, relevant and necessary in relation to the specific purpose of the processing.

Depending on the technical architecture and the functionality used, certain information necessary for the personalisation of the Service may be processed with the help of the AI Systems and/or of the technology providers used by Libertos.

The categories of personal data processed, the purposes and legal bases of the processing, the recipients or categories of recipients, the retention period, any international data transfers and the rights of Users are described in the Privacy Policy.

In so far as the User's direct identification data are not necessary for the operation of a particular AI component of the Service, Libertos seeks to avoid transmitting such data to the AI System concerned.

3.7. External providers of AI Systems

Libertos may use AI services and infrastructure supplied by third parties.

In so far as such a provider processes personal data on behalf of Libertos, the relationship with that provider will be managed in accordance with the applicable requirements on the protection of personal data.

The information that must be communicated to Users regarding the recipients of the data, the relevant providers, international transfers and the applicable safeguards will be included in the Privacy Policy, to the extent required by the applicable legislation.

3.8. Use of data for the development or improvement of AI Systems

Users' personal data will not be used by Libertos for the training, development or improvement of artificial intelligence models except in so far as such processing is permitted by the applicable legislation and the requirements regarding the legal basis, transparency, purpose limitation and the other applicable safeguards are met.

Where external providers of AI Systems are used, Libertos will determine, depending on the applicable legal relationship, the conditions under which the data transmitted to them may be processed, including, where relevant, whether such data may be used by the provider for the development or improvement of its own services or models. The information relevant to the User regarding such processing will be presented in the Privacy Policy, under the conditions required by the applicable legislation.

3.9. Automated decisions

Unless the User is expressly informed otherwise, the use of the AI Systems for the personalisation, selection, classification or prioritisation of content serves an informative purpose and is not intended for the adoption of solely automated decisions which produce legal effects concerning the User or similarly significantly affect the User.

Should functionalities be introduced that involve such automated decision-making processes, Libertos will provide the information and ensure the safeguards and rights laid down by the applicable legislation.

3.10. Changes to the technologies used

The technologies, models and providers used for the operation of the AI Systems may be updated, changed or replaced over time, including in order to improve the quality, security, performance or efficiency of the Service.

Libertos does not guarantee the permanent use of a particular model, a particular version of a model or a particular AI technology provider, unless this has been expressly undertaken towards the User.

Where such a change results in a relevant change to the manner in which the Service is provided or to the manner in which personal data are processed, Libertos will update the information provided to Users and will fulfil, as applicable, the information obligations or the other obligations laid down by the applicable legislation.

Libertos informs Users, in a clear and appropriate manner, of the use of the AI Systems for generating, synthesising or processing the content provided through the Platform.

In cases where the applicable legislation requires the identification or labelling of content generated or manipulated with the help of AI Systems, Libertos will ensure the applicable transparency measures, taking into account, among other things, the existence of a human review process or of editorial control and the assumption of editorial responsibility, as applicable.

04Informative purpose. No professional advice

4.1. The Libertos content serves an exclusively informative and general purpose.

4.2. The information provided through the Platform does not constitute and must not be construed as legal, financial, tax, investment or medical advice or any other form of professional advice.

4.3. The User is responsible for verifying the relevant information before taking legal, financial, commercial, professional or personal decisions.

4.4. Where Libertos indicates or refers to a third-party source, the content of that source belongs to its author or rights holder and is subject to the terms and conditions laid down by that third party.

05Creation and use of the Account

5.1. Certain sections of the Platform may be accessed without creating an Account.

5.2. In order to access personalised services, save preferences, receive Briefings or use a Subscription, the creation of an Account may be necessary.

5.3. The User undertakes to provide accurate, current and complete information.

5.4. The User is responsible for keeping their login credentials confidential and for the activity carried out through their Account.

5.5. The Account is personal and may not be transferred, sold or made available to other persons, except where the plan purchased expressly allows use by several users.

5.6. The User will inform the Operator without delay if they discover or suspect unauthorised access to their Account.

5.7. If the User's account is not active for 45 consecutive days, after that period the User will be contacted by e-mail by Libertos regarding the status of the account, and if the User has no activity on the Libertos web page or mobile application within the following 15 days, the User's account will be closed.

06Rules of use

6.1. The Platform must be used in good faith and in accordance with the applicable legislation.

6.2. The following are prohibited:

• a) using the Platform for unlawful purposes;
• b) attempting unauthorised access to the Platform, servers, databases or other computer systems;
• c) impairing the security, integrity or operation of the Platform;
• d) using automated scraping, crawling or harvesting mechanisms for the systematic collection of content, except in cases authorised in writing by the Operator;
• e) systematically copying or redistributing, for commercial purposes, Briefings or other protected Libertos content;
• f) using the Service in a manner that infringes the rights of the Operator or of third parties;
• g) using fraudulent Accounts or means of payment.

6.3. The Operator may suspend or restrict access to the Platform in the event of a breach of these conditions, in proportion to the seriousness of the breach and with due regard for the User's legal rights.

6.4. Device compatibility. Libertos is designed to be accessible from a wide range of devices and technical configurations. Nevertheless, the operation, display or availability of certain functionalities may vary depending on the device, operating system, browser, internet connection, settings or other technical components used by the User.

The User is responsible for checking, before accessing or purchasing any Service, including a Subscription, whether the device and configuration used allow the Service to be accessed and used properly. By purchasing a Subscription or another paid Service, the User confirms that they have carried out this check and that they have the technical means required to use the Service.

Libertos is not liable for the impossibility or limitation of access to the Service caused by the incompatibility, configuration, settings, performance or operation of the device, software, browser, internet connection or other systems outside Libertos's control, to the extent permitted by law.

This limitation does not apply to situations where the impossibility of using the Service is attributable to Libertos and does not affect the rights of Users which cannot be limited or excluded under the applicable legislation.

07Subscriptions and paid services

7.1. Libertos may offer both free functionalities (one monthly briefing by e-mail) and functionalities available under a Subscription.

7.2. The characteristics of each plan, the price, the billing period, any usage limits and the benefits included are presented to the User before the Order is placed.

7.3. The following may be offered, as applicable:

• monthly subscriptions;
• annual subscriptions;
• packages of monthly briefings;
• other subscription plans or periods as may be created by Libertos;
• free or promotional trial periods.

7.4. Before the Order is placed, the User will be clearly presented with the essential characteristics of the chosen Subscription, the total applicable price, including taxes, where applicable, the billing period, the duration of the Subscription, the conditions of automatic renewal, where applicable, and any other relevant costs or conditions. The Order will be concluded on the terms of the offer thus presented to the User and accepted by the User at the time the Order is placed.

7.5. The Subscription becomes active after confirmation of payment, unless a different start date is indicated in the relevant offer.

08Prices, payment and invoicing

8.1. Prices of the Services

The prices of the Subscriptions and of the other paid products or Services available through Libertos are indicated in the presentation of each of them and, as applicable, during the process of placing the Order.

Before the Order is completed, the User will be clearly presented with the total price due, the currency, the applicable taxes, where applicable, the billing period and, for recurring Subscriptions, the frequency of the payments, processed through the payment processor Stripe, and the conditions applicable to renewal.

The User is obliged to check the information relating to the Order before confirming it.

8.2. Payment methods

Payment for the Services may be made by the payment methods available and indicated to the User during the purchase process.

Online payments may be processed through STRIPE, which is one of the authorised third-party providers of payment services (the “Payment Processor”), in accordance with the conditions and security standards applicable to them.

Depending on the payment method used and the requirements of the Payment Processor or of the institution issuing the payment instrument, the User may be asked to carry out additional payment authentication or authorisation steps.

After the payment has been successfully confirmed, the User will receive a confirmation of the Order and/or of the payment by e-mail or through the Account, as applicable.

8.3. Card data and payment security

In the case of card payments, the data necessary for processing the payment are provided and processed through the Payment Processor and/or the financial institutions involved in carrying out the transaction, in accordance with the technical manner in which the payment service is implemented.

In so far as the technical infrastructure used for processing payments is configured so that the full card data are entered directly into the systems of the Payment Processor, such data cannot be accessible to the Operator and are not stored by the Operator or by Libertos.

Further information on the processing of personal data in the context of making payments is set out in the Privacy Policy.

The User is responsible for the safe use of their Account and for protecting their login credentials. The User must not disclose their password or other authentication elements to unauthorised persons and must inform Libertos without undue delay if they suspect unauthorised use of the Account.

8.4. Issuing of the invoice

For paid Services purchased through the Platform, the Operator will issue the corresponding invoice in accordance with the applicable tax legislation.

The User is obliged to provide, where necessary, the complete, accurate and up-to-date information requested for the issuing of the invoice in accordance with the legislation in force.

The User is responsible for the accuracy of the billing details provided and for updating them whenever changes occur.

8.5. Communication of invoices

Invoices will be issued and communicated in electronic form, under the conditions permitted by the applicable legislation.

Depending on the functionalities available on the Platform, the invoice may be sent to the e-mail address associated with the Account and/or may be made available to the User through their Account.

Where invoices are available in the Account, the User may consult, download and keep them for their own records, for as long as they are available on the Platform.

The User is obliged to keep the contact details and billing details associated with the Account up to date, so that the documents and information relating to their Orders can be duly communicated.

8.6. Electronic invoicing

By placing an Order and providing the details necessary for invoicing, the User acknowledges that the documents relating to the Order, including the invoice, may be issued and communicated in electronic form, under the conditions of the applicable legislation.

In situations where tax legislation requires the invoice to be transmitted, reported or made available to the tax authorities through a mandatory electronic system, the Operator will proceed in accordance with the applicable legal requirements.

8.7. Failed or unauthorised payments

Where a payment is refused, cannot be processed, is cancelled or is not duly authorised, the Operator may refrain from activating the corresponding Service or Subscription until the payment has been confirmed.

In the case of a recurring Subscription, if the payment for a new billing period cannot be processed, the Operator may attempt to process the payment again, to the extent permitted by the payment mechanism used, and/or may suspend access to the functionalities of the paid Subscription until the amounts due have been paid.

Any measure taken in this situation will not affect the rights to which the User is mandatorily entitled under the applicable legislation.

09Automatic renewal of the Subscription

9.1. Where the chosen plan expressly so provides, the Subscription renews automatically at the end of each billing period.

9.2. Before contracting, the User will be informed of:

• a) the recurring nature of the Subscription;
• b) the billing frequency;
• c) the price due;
• d) the method of deactivating automatic renewal.

9.3. By contracting a Subscription with automatic renewal and accepting these Terms and Conditions, the User gives their express consent to and authorises the automatic charging of the payment method associated with the Account, on each due date, without a new authorisation being required for each recurring payment, until automatic renewal is deactivated. This provision does not exclude any additional authentication or security measures required by the Payment Processor or by the institution issuing the payment instrument.

9.4. The User may deactivate automatic renewal from the Account, through the function made available for this purpose, or by contacting the Operator at the following e-mail address: [email protected].

9.5. Deactivating automatic renewal does not result in the immediate termination of the Subscription. The User will be able to continue using the Service until the expiry of the period already paid for.

9.6. After the expiry of that period, no further recurring payments will be made and the Account will be moved to the level of access corresponding to the free service.

10Changes to the Subscription price

10.1. The Operator may change the prices of the Subscriptions for future periods.

10.2. A change in price does not affect the subscription period already paid for.

10.3. In the case of a Subscription with automatic renewal, a change in the price applicable to a future period will be communicated to the User in advance, within a reasonable period of 30 days before the new subscription takes effect, so as to allow the User to decide on the continuation of their commercial relationship with the Operator.

10.4. If the User does not wish to continue the Subscription at the new price, they may deactivate renewal before the start of the next billing period.

11The consumer's right of withdrawal

11.1. This Article applies to Users who are natural persons and have the status of consumers under the applicable legislation.

11.2. In the case of distance contracts, the User has the right to withdraw from the contract within 14 days, without having to justify their decision and without incurring any costs other than those provided for by law. For service contracts, the 14-day period runs from the date of conclusion of the contract.

11.3. Commencement of the provision of the Service during the withdrawal period. At the express request of the User, the provision of the Service may begin before the expiry of the 14-day withdrawal period. If the User exercises their right of withdrawal after the provision has begun, they may owe, under the conditions provided for by law, an amount proportionate to the Services provided up to the time the withdrawal was communicated.

11.4. Full performance of the Service. In the case of a Service for which the User has an obligation to pay, the right of withdrawal is lost after the Service has been fully performed, if performance began with the User's prior express consent and after the User confirmed that they were aware that they would lose their right of withdrawal once the contract had been fully performed, under the conditions provided for by law.

11.5. Digital content not supplied on a tangible medium. In the case of the purchase of digital content which is not supplied on a tangible medium, the User loses their right of withdrawal once performance of the contract has begun, if they have given their prior express consent to performance beginning during the withdrawal period and have confirmed that they are aware that, by performance beginning, they will lose their right of withdrawal, subject to the other conditions provided for by law.

For this purpose, before the supply of the digital content begins, the User will be asked to give the corresponding consent.

11.6. Exercising the right of withdrawal. In cases where the right of withdrawal applies, it may be exercised before the expiry of the statutory period by sending an unequivocal statement of the decision to withdraw to the e-mail address [email protected] or by any other means made available by the Operator for this purpose.

11.7. Where the right of withdrawal is validly exercised, the Operator will reimburse the amounts due to the User under the conditions and within the time limits laid down by the applicable legislation.

11.8. The provisions of this Article do not limit the rights to which consumers are mandatorily entitled under the applicable legislation.

12Cancellations and refunds

12.1. The User may request the termination of a Subscription at any time, under the conditions set out in this document.

12.2. With the exception of the statutory right of withdrawal, cases of lack of conformity of the Service or other situations required by law, the amounts relating to a subscription period that has already begun are not refundable on a pro rata basis merely because the User decides to stop using the Service.

12.3. Any refund will be made in the cases and under the conditions provided for in this document and by the applicable legislation.

12.4. In the event of a payment made in error, a duplicate payment or a technical problem, the User may contact the Operator at the e-mail address: [email protected].

13Conformity of the digital service

13.1. The Operator will provide the Service in accordance with the characteristics, functionalities and benefits described in this document and in the offer applicable to the Subscription chosen by the User, as well as with the requirements laid down by the legislation applicable to digital services and digital content.

13.2. The Operator seeks to maintain the functionality, continuity, security and quality of the Service and will provide, where necessary, the updates necessary to keep it in conformity. The Platform may be subject to temporary interruptions caused by maintenance, updates, technical problems or other causes which may temporarily affect the availability of the Service.

13.3. Where the Service is not provided or does not conform to the agreed conditions, the User may request that the lack of conformity be remedied, under the conditions of this document and of the applicable legislation. Users who have the status of consumers additionally enjoy all of the rights and remedies mandatorily provided for by consumer protection legislation, including, as applicable, bringing the Service into conformity, a price reduction or termination of the contract.

13.4. The limitations inherent in the AI Systems and in external sources, set out in Article 3, do not remove the Operator's obligation to provide the Service in accordance with the agreed requirements and with the applicable legal provisions.

13.5. No provision of these Terms and Conditions will be construed as excluding or limiting the User's rights regarding the conformity of the Service, in so far as such rights are mandatorily provided for by the applicable legislation. In the case of Users who have the status of consumers, all of the mandatory rights and guarantees provided for by consumer protection legislation remain applicable.

14Promotional periods and free access

14.1. The Operator may offer free trial periods, discounts, promotional codes or other benefits.

14.2. The specific conditions of the promotion will be presented to the User before activation.

14.3. If a free period converts automatically into a paid Subscription, this fact, together with the price and the date of the first payment, will be clearly indicated before the free period is activated.

14.4. The User may avoid payment by cancelling the Subscription before the expiry of the free period, under the conditions communicated upon its activation.

15Newsletters and communications

15.1. Libertos may send the User Briefings, alerts, notifications and other communications necessary for the provision of the Service, in accordance with the User's preferences and settings.

15.2. The Operator may send communications necessary for the administration of the Account and of the contractual relationship, including regarding the Subscription, payments, invoicing, the security of the Account or changes to the Service.

15.3. Commercial and promotional communications will be sent in compliance with the applicable legislation and, where necessary, on the basis of the User's consent. The User may unsubscribe at any time, without this affecting the communications necessary for the provision of the Service.

15.4. The User may unsubscribe from commercial communications by using the unsubscribe mechanism included in the message.

15.5. Unsubscribing from commercial communications does not affect the sending of messages strictly necessary for the administration of the Account or the performance of the Subscription.

15.6. The processing of personal data in connection with these communications is carried out in accordance with the Libertos Privacy Policy and with the applicable data protection legislation.

16Third-party sources, links and services

16.1. In order to provide the Service, Libertos uses information originating from external sources, including publications, press agencies, websites, releases, databases and other relevant sources, which may be identified or indicated within the Platform, clearly highlighted at the end of the articles.

16.2. Links to third-party websites or services are provided for informative purposes and, as applicable, to allow the User to consult and verify the information directly at its source.

16.3. Libertos does not exercise control over the content, availability, security, editorial policies, practices or terms and conditions applicable to websites and services operated by third parties and is not liable for the content published or for the products or services supplied directly by such third parties.

16.4. Access to and use of third-party websites or services take place in accordance with the terms, policies and conditions laid down by their operators, and the User is encouraged to consult them before use.

16.5. The indication, citation or use of a source and the inclusion of information originating from it in a Briefing do not imply the existence of a relationship of affiliation, partnership, approval or mutual endorsement between Libertos and that source, unless such a relationship is expressly indicated.

16.6. The opinions, statements and information published by third-party sources belong to their authors or providers and do not, by their mere inclusion or use within the Service, constitute opinions or statements endorsed by Libertos.

17Intellectual property

17.1. The rights in the original elements of the Platform, including the trade mark, logo, design, structure, software, databases, selections, systems of organisation and original Libertos texts, belong to the Operator or its licensors, as applicable.

17.2. The rights in materials belonging to third-party publications and sources remain the property of their respective holders.

17.3. The User is granted a limited, personal, non-exclusive and non-transferable right to use the Platform and the Briefings for their own use, for as long as they have a right of access to the Service.

17.4. The reproduction, distribution, resale or systematic commercial exploitation of Libertos content without the prior authorisation of the Operator is prohibited, other than in situations permitted by law.

17.5. Nothing in this document transfers to the User any intellectual property rights in the Platform or in third-party materials.

18Availability and modification of the Platform

18.1. The Operator makes reasonable efforts to ensure the availability and security of the Platform.

18.2. Access may be temporarily interrupted for maintenance operations, updates, technical problems, security incidents or other causes beyond the Operator's control.

18.3. The Operator may update and develop the functionalities of the Service.

18.4. In the case of digital services supplied over a period of time, modifications which significantly affect the consumer's access to or use of the Service will be made in compliance with the conditions and rights laid down by the applicable legislation.

19Limitation of liability

19.1. Libertos makes reasonable efforts to provide a functional Service and relevant and useful information. Given the nature of the Service, of the sources used and of the artificial intelligence technologies, the Operator does not guarantee that the information generated, aggregated or synthesised is exhaustive, permanently up to date or absolutely free of errors.

19.2. The User understands that:

• information may change after it has been collected or published;
• third-party sources may contain erroneous, incomplete or outdated information;
• artificial intelligence systems may generate errors, omissions or inaccurate interpretations;
• a personalised Briefing does not necessarily constitute an exhaustive presentation of all of the information available; and
• information relevant to professional, commercial, financial, legal or other significant decisions must be verified by the User by consulting the relevant sources.

19.3. The Operator is not liable for the content, availability or accuracy of third-party sources and services, nor for damage attributable exclusively to such third parties. This limitation does not release the Operator from the liability it bears for the provision of its own Service, under these Terms and Conditions and the applicable legislation.

19.4. The Operator does not guarantee the uninterrupted operation of the Platform. The Service may be temporarily unavailable or affected by maintenance, updates, technical faults, the unavailability of third-party providers or other circumstances which cannot reasonably be prevented by the Operator.

19.5. In its relations with Professional Users, to the extent permitted by law, the Operator is not liable for indirect damage, loss of profit, revenue or business opportunities or other indirect economic losses resulting from the use of the Service or from the temporary impossibility of using it.

19.6. No provision of this Article excludes or limits the Operator's liability in cases where such an exclusion or limitation is prohibited by law. In the case of Users who have the status of consumers, all of the mandatory rights and guarantees provided for by the applicable legislation remain applicable.

20Suspension and closure of the Account

20.1. The User may request the closure of the Account through the options available on the Platform or by sending a request to the Operator.

20.2. Closure of the Account does not automatically result in the reimbursement of the amounts paid for Subscription periods already provided, without prejudice to the rights mandatorily provided for by law.

20.3. The Operator may suspend or close the Account, as applicable, in situations such as:

• a serious or repeated breach of these Terms and Conditions;
• fraudulent, abusive or unauthorised use of the Platform;
• the existence of risks to the security of the Account, the Platform or other users;
• non-payment of amounts due;
• the provision of false data or the use of an identity or an Account without entitlement;
• infringement of the intellectual property rights of the Operator or of third parties; or
• the existence of a legal obligation to that effect.

20.4. The Operator will inform the User of the suspension or closure of the Account and, as applicable, of the reasons for it. The measure may be ordered without prior notice where it is necessary to prevent or limit fraud, a security incident or abusive or unauthorised use, or where prior notice is prohibited or incompatible with a legal obligation. In such cases, the User will be informed subsequently, to the extent permitted by law.

21Personal data

21.1. The processing of personal data is carried out in accordance with the Libertos Privacy Policy.

21.2. The Privacy Policy is a separate document and explains, among other things, the categories of data processed, the purposes and legal bases of the processing, the recipients of the data, the retention periods and the rights of data subjects.

22Changes to the Terms and Conditions

22.1. The Operator may update this document where necessary, including as a result of:

• a) changes to the Service;
• b) the introduction of new functionalities;
• c) legislative changes;
• d) security requirements;
• e) changes to the commercial model.

22.2. The updated version will be published on the Platform together with the date of the last update.

22.3. In the case of significant changes affecting an ongoing Subscription, the User will be informed by appropriate means before the change takes effect, where the law requires such information to be given.

22.4. Rights acquired by consumers under mandatory legal rules cannot be limited by changes to these conditions.

23Complaints and support

23.1. For questions, complaints or problems regarding the Account, the Subscription or payment, the User may contact the Operator at:

E-mail: [email protected]

Address: București, Intrarea Navigatorilor 2A, Romania

23.2. The Operator will make reasonable efforts to resolve requests within a reasonable period, having regard to their nature.

23.3. Users may also use the alternative dispute resolution mechanisms made available by the competent authorities, where these are applicable.

24Applicable law and dispute resolution

24.1. This document is governed by Romanian law.

24.2. Any disagreements will be resolved, as a matter of priority, by amicable means.

24.3. Where an amicable resolution is not possible, disputes will be settled by the competent courts of Bucharest, in accordance with the law.

25Final provisions

25.1. If a provision of this document is declared null and void, unenforceable or unlawful, the remaining provisions will continue to have effect to the extent permitted by law.

25.2. The Operator's failure to exercise a right provided for in this document does not constitute a waiver of that right.

25.3. This document is supplemented by the Privacy Policy and by any special conditions communicated for certain Services or Subscriptions.

25.4. This document enters into force on 16.09.2026.

By accessing or using the Platform, the User confirms that they have taken note of and accept the applicable provisions of these Terms and Conditions. Where an Account is created or a Subscription or another paid Service is contracted, acceptance of these Terms and Conditions forms an integral part of the contract concluded between the User and the Operator.

If the User does not agree with the provisions of these Terms and Conditions, they must not and will not use the Platform or the Services and, as applicable, will not proceed to create an Account or contract a Subscription.