4.5 Upon subscribing to this Service, based on your subscription, you will receive an online training tailormade for your subscription level.

4.6 Please note that adding keywords or switching on/off service elements may modify the fees. Upon your request for additional keywords and service elements, Neticle shall inform You about the modified package fees. You must confirm the acknowledgement of the modified fees in order for Neticle to start the provision of the modified Service.

4.7 You shall be exclusively entitled to use the data originated from your profile and You are the legal owner of analysis made by Neticle. You are entitled to hand over the data and analysis to 1 (one) third party.

4.8 Neticle shall refrain from using the data originated from your profile.

4.9 In addition, the data generated by NMI may be access via an API connector as per your individual request and pricing.

V. Neticle Text Analysis API

5.1 This part of the Terms introduces the general terms and conditions related to the Neticle Text Analysis Service (“NTA”) in addition to the general rules described in the GTC.

5.2 Text Analysis provides market leading, humanly accurate sentiment and semantic analysis toolkits for in-house corporate use.

5.3 The NTA is currently capable of providing the following service elements:

• Automated entity oriented and document level sentiment analysis in the languages that are available based on the service documentation: https://neticle.com/textanalysisapi/en/documentation;
• Identifying positive and negative phrases and opinions of texts;
• Automated entity (topic, brand, person, location, emotion, etc.) recognition; - Revealing hidden connections, patterns and cognitive rules; - Create custom keywords and categories (automated coding.

5.4 Upon subscribing to the NTA service You will be able to check the Text Analysis API usage data through the online dashboard provided by Neticle.

5.5 As part of your subscription, You are given access tokens and You are able to access the NTA Service with these tokens. You are liable to keep these tokens safe from third parties. If You give these tokens to third parties or lose them, You may need to purchase new tokens to replace the lost ones.  

VI. Zurvey.io

6.1 This part of the Terms introduces the general terms and conditions related to the Zurvey.io Service (“Zurvey.io”) in addition to the general rules described in the GTC.

6.2 Zurvey.io is a self-service text analysis solution providing diagnostic and evaluative human level precise automated text analysis of the uploaded or collected texts:

• Automated entity oriented and document level sentiment analysis in the following, but not limited to, Albanian, Bosnian, German, Bulgarian, Czech, Danish, English, Spanish, Estonian, Finnish,  Georgian, Greek, Croatian, Hungarian, Indonesian, Italian, Latvian, Dutch, Norwegian, Polish, Portuguese, Romanian, Russian, Swedish, Slovenian, Slovak, Serbian, Turkish, Ukrainian language texts.
• Identifying positive and negative phrases and opinions analysis in the following, but not limited to, Albanian, Bosnian, German, Bulgarian, Czech, Danish, English, Spanish, Estonian, Finnish,  Georgian, Greek, Croatian, Hungarian, Indonesian, Italian, Latvian, Dutch, Norwegian, Polish, Portuguese, Romanian, Russian, Swedish, Slovenian, Slovak, Serbian, Turkish, Ukrainian language texts.
• Automated entity (topic, brand, person, location, emotion, etc.) recognition currently in analysis in the following, but not limited to, Albanian, Bosnian, German, Bulgarian, Czech, Danish, English, Spanish, Estonian, Finnish,  Georgian, Greek, Croatian, Hungarian, Indonesian, Italian, Latvian, Dutch, Norwegian, Polish, Portuguese, Romanian, Russian, Swedish, Slovenian, Slovak, Serbian, Turkish, Ukrainian texts.
• Summarization and quantification of opinion, pain points and entities.
• Revealing hidden connections, patterns, and cognitive rules of the text database.

6.3 You can request manual data preparation and report creation service directly from Neticle.

6.4 Upon subscribing to the Service, the You are given username and password (“Credentials”) and with the help of it You are able to access the Zurvey.io dashboard. Your Credentials are confidential information. You are liable to keep your Credentials safe from third parties.

6.5 The fee related to Zurvey.io is defined by the number of the unit of texts to be analysed provided by You. The text unit means an entry of text data:

• one feedback/comment,
• one Excel cell’s text data of the uploaded Excel file data sheet, - one survey question answer,
• one article, patient description entry, etc.

6.6 The length of a text unit is at most 1,000 characters. In so far as a text unit is longer than 1,000 characters, it is defined as a new text unit after each 1,000^th characters. (Zurvey.io will calculate only the analysed texts into the quota, the rest of the handled data (ID category, other texts and so on) will be left out of consideration.)

VII. Payments

7.1 By subscribing to any of the Packages related to any of the Services the Client is deemed to have agreed to and accepted liability for the payment of the subscription fee as determined by Neticle. Client also consents to the fee being billed and changed by Neticle in its sole discretion. Any change of the subscription fee shall take effect after the end of the billing period of the active Package of the Client.

7.2 Neticle reserves the right to increase the fees from time-to-time, especially, but not limited to based on the consumer price index published by the Central Statistical Office of Hungary. Neticle shall notify the Client in writing of the amount of the revised fees prior to their application. The Client shall be entitled to terminate the contract within 8 days of such notification if the Client does not accept the amended amount of the fees. If the Client does not exercise the right of termination within this period, the Parties shall be deemed to have accepted the amended amount of the fees.

7.3 You will receive notifications in case you have not paid the corresponding invoice in full. Neticle may stop the provision of Services if due payments are not received after the related notification has been sent.

7.4 Unless subscribing to a free Package, Clients will be charged in advance on a monthly, quarterly, or annual basis.

7.5 The Client’s subscription to a Package will automatically renew at the end of each billing cycle unless the Client cancels the subscription on the Website, via e-mail or in writing, which can be done anytime. Unless stipulated otherwise by the GTC, the fee paid for the subscribed Package is non-refundable. Any termination and cancellation of the subscription will take effect immediately, and the Client will not be eligible for a refund in case of such early termination.

7.6 Payments may be completed in the currency indicated by Neticle and by credit card. All sums owed to the Supplier must be paid in full, without deducting any currency conversion or payment-related charges. The Client represents and warrants that the credit card information it provides is correct and it will promptly notify Neticle of any changes to such information. Failure of the credit card transaction will result in refusal of use of the Services by the Client. The Client acknowledges that its payments are handled by third-party service providers and Neticle is not responsible for these parties or their services and has no liability as concerns payment processing.

7.7 Prices on the Website are exclusive of VAT. Nonetheless, if applicable, Neticle will charge the Client VAT, unless the Client provides the Services Provider with a tax/VAT identification number that allows Neticle to charge exempt from VAT. The Client shall be solely responsible for all taxes that may be charged on its payment.

7.8 As mentioned above, You may change the scope of services regarding each Service. In case the option for change of services is not available via the Website, You may turn to Neticle via email with your request. Neticle shall inform you regarding the modified subscription fee and your email confirmation on the acceptance of the modified fee shall mean that the contract with the new fee between You and Neticle is binding.

7.8 Neticle will electronically issue and provide the invoice to the Client after the successful payment of the subscription fee by credit card.

7.9 Neticle may, in its absolute discretion, charge interest on overdue amounts at the relevant statutory rate in accordance with the Hungarian Civil Code.

VIII. Limitations of Liability

8.1 Other than as expressly provided in the GTC and to the extent permitted by applicable laws, Neticle does not make any warranties of any kind, including those of merchantability, fitness for a particular purpose, and non-infringement or any representations regarding availability, reliability, or accuracy of the Website’ content and the Services.

8.2 Clients shall indemnify and hold harmless Neticle from all liabilities, damages, and costs arising out of a third-party claim regarding or in connection with the Client’s use of the Services or breach of the Terms, to the extent that such liabilities, damages, and costs were caused by the Client or its Users.

IX. Prohibited Uses

9.1 You may use Service only for lawful purposes and in accordance with Terms. You agree not to use Service:

• In any way that violates any applicable national or international law or regulation.
• For the purpose of exploiting, harming, or attempting to exploit or harm minors in any way by exposing them to inappropriate content or otherwise.
• To transmit, or procure the sending of, any advertising or promotional material, including any “junk mail”, “chain letter,” “spam,” or any other similar solicitation.
• To impersonate or attempt to impersonate Company, a Company employee, another user, or any other person or entity.
• In any way that infringes upon the rights of others, or in any way is illegal, threatening, fraudulent, or harmful, or in connection with any unlawful, illegal, fraudulent, or harmful purpose or activity.
• To engage in any other conduct that restricts or inhibits anyone’s use or enjoyment of Service, or which, as determined by us, may harm, or offend Company or users of Service or expose them to liability.

9.2 Additionally, You agree not to:

• Use Service in any manner that could disable, overburden, damage, or impair Service or interfere with any other party’s use of Service, including their ability to engage in real time activities through Service.
• Use any robot, spider, or other automatic device, process, or means to access Service for any purpose, including monitoring or copying any of the material on Service.
• Use any manual process to monitor or copy any of the material on Service or for any other unauthorized purpose without our prior written consent.
• Use any device, software, or routine that interferes with the proper working of Service.
• Introduce any viruses, trojan horses, worms, logic bombs, or other material which is malicious or technologically harmful.
• Attempt to gain unauthorized access to, interfere with, damage, or disrupt any parts of Service, the server on which Service is stored, or any server, computer, or database connected to Service.
• Attack Service via a denial-of-service attack or a distributed denial-of-service attack.
• Otherwise attempt to interfere with the proper working of Service.

X. Disclaimer of Warranty

10.1 These Services are provided by Neticle on an “as is” and “as available” basis. Neticle makes no representations or warranties of any kind, express or implied, as to the operation of their services, or the information, content or materials included therein. You expressly agree that your use of these services, their content, and any services or items obtained from us is at your sole risk.

10.2 Neither Neticle nor any person associated with Neticle makes any warranty or representation with respect to the completeness, security, reliability, quality, accuracy, or availability of the services.

10.3 Without limiting the foregoing, neither Neticle nor anyone associated with Neticle represents or warrants that the services, their content, or any services or items obtained through the services will be accurate, reliable, error-free, or uninterrupted, that defects will be corrected, that the services or the server that makes it available are free of viruses or other harmful components or that the services or any services or items obtained through the services will otherwise meet your needs or expectations.

10.4 Neticle hereby disclaims all warranties of any kind, whether express or implied, statutory, or otherwise, including but not limited to any warranties of merchantability, non-infringement, and fitness for particular purpose. The foregoing does not affect any warranties which cannot be excluded or limited under applicable law.

XI. Termination and Cancellation

11.1 Neticle may terminate the Client’s account related to any Services and delete any content contained in it if there is no account activity (such as a log in event or payment) for over 12 months. Neticle shall send the Client at least one reminder by email before the termination of the account.

11.2 Neticle may terminate the Client’s subscription related to any Services at the end of a billing cycle by providing at least 30 days’ prior notice to the Client. Neticle may also terminate without prior notice the Client’s subscription and/or account for a material breach of Terms, or if the Client terminates its business or becomes subject to insolvency proceedings, or in case the Client uses the Services or behaves in a way which is against the norms of business cooperation, disturbing the operation of Neticle or other Clients. Such termination for cause may result the blocking of the Users of the Client and preventing them from using the Services in the future.

11.3 The Client may terminate its subscription and delete its account with 30 days' notice.. The termination will result in either the downgrade of the Client’s account to a free version if it is available or a deactivation of the Client’s account and access to it. In case of deactivation of the Client’s account, the content the Client uploaded and generated through use of the Services will be permanently deleted. In case the Client terminates a subscription during a billing cycle, the Client will not receive a refund unless required by law.

11.4 New Consumers from the member states of the European Union may cancel their subscription within 14 calendar days after the payment of the fee by credit card. Upon cancellation the Consumer’s account will be changed to a free version if it is available. Clients may exercise the cancellation by sending a notice by email or by post specifying the username and including an expressed statement on the cancellation. The fee shall be refunded within If within 14 days following the sending of the notice of cancellation.

XII. Consumer Complaints

12.1 The Consumer may submit any comments, complaints regarding Neticle’s services to the customer service run by the Neticle.

12.2 In the event of the rejection of a complaint, the Consumer may contact the Arbitration Board of Budapest (address: 1016 Budapest, 99 Krisztina krt, 3rd floor 310; mailing address: 1253 Budapest, Pf.:10. Hungary). Neticle does not declare a subordination to the recommendation of a conciliation panel.

12.3 The Consumer is entitled to initiate proceedings in respect of any dispute arising through the online dispute resolution forum. The online dispute resolution platform under Regulation (EU) No 524/2013 is available at:

• Direct access to         a          central helpdesk          operated          by        the       European         Commission: https://ec.europa.eu/info/live-work-travel-eu/consumers/resolve-your-consumer-complaint/europeanconsumer-centres-network-ecc-net_hu
• Direct access to the online dispute resolution platform operated by the European Commission:

ec.europa.eu/consumers/odr.

12.4 We are committing to the protection of consumers against unfair commercial practices without applying a formal code of conduct.

XIII. Protection of Personal Data

13.1 The Privacy Policy published on the Website and related to the Services governs the terms of the use of the personal data of the Clients and contained in the data uploaded to the Website by the Clients. You can find the Privacy Policy here:

• https://neticle.com/company/en/author-privacy-statement,
• https://zurvey.io/zurvey/en/privacy-policy
• https://neticle.com/mediaintelligence/en/privacy-policy.

13.2 With regards to the data uploaded or created by the Client by using the Services, the Client shall act as data controller and Neticle shall act as data processor. The terms between the parties concerning the personal data processing are governed by the data processing agreement constituting an integral part of the GTC.

XIV. Confidentiality

14.1 Neticle shall be liable to keep the data uploaded to the Website by the Client confidentially without limitation in time.

14.2 During the use of the Website and the Services by the Client under the GTC, each party may be given access to information (in whatever form) that relates to the other party’s past, present and future business activities, internal information, products, services know-how and/or intellectual property (“Confidential Information”).

14.3 Each party receiving Confidential Information (“Receiving Party”) from the other party (“Disclosing Party”) under or in connection with the Services shall keep any such Confidential Information confidential and shall not divulge the same to any third party without the prior written consent of the Disclosing Party or save as specifically permitted below in this clause. Confidential Information shall not be used by the Receiving Party for any purpose other than in connection with the use of the Services. Confidential Information disclosed by the Disclosing Party that (i) is publicly available; (ii) has been received by the Receiving Party from a third party who is under no obligation of confidentiality with respect thereto; (iii) is known to the Receiving Party prior to disclosure by the Disclosing Party without an obligation of confidentiality; (iv) is independently developed by the Receiving Party; (v) is expressly authorized to be disclosed by the Disclosing Party in writing; or (vi) is required by law to be disclosed by the Receiving Party or in accordance with the requirement of any regulatory or supervisory authority to which the party is subject (in which case the Receiving Party shall use reasonable endeavours to notify the Disclosing Party in advance of such disclosure) shall be disclosed without the prior consent of the Disclosing Party.

XV. Final Provisions

15.1 Neticle owns all intellectual property rights in and related to the Website and the Services, including design and know-how, and any derivative works of them. All rights not expressly granted to the Client are reserved to Neticle.

15.2 Neither party shall be in breach of the GTC nor liable for delay in performing, or failure to perform, any of its obligations under the GTC if that delay or failure result from events, circumstances or causes beyond its reasonable control.

15.3 The Client shall not assign, transfer, charge, subcontract, declare a trust over or deal in any other manner with any or all of its rights and obligations under the GTC without Neticle’s prior written consent. Neticle may at any time assign, transfer, charge, subcontract, declare a trust over or deal in any other manner with any or all of its rights under the GTC.

15.4 The GTC constitutes the entire agreement between the parties and supersedes and extinguishes all previous agreements, promises, assurances, warranties, representations, and understandings between them, whether written or oral, relating to the Services.

15.5 If any provision or part-provision of the GTC is or becomes invalid, illegal, or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal, and enforceable. If that modification is not possible, the relevant provision or part-provision shall be deemed deleted. Any modification to or deletion of a provision or part-provision under this clause shall not affect the validity and enforceability of the rest of this agreement.

15.6 The GTC, and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims), shall be governed by, and construed in accordance with the law of Hungary.

15.7 Neticle and the Client irrevocably agrees that the courts of Hungary shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with the GTC or its subject matter or formation (including non-contractual disputes or claims).

15.8 Neticle may give notice to the Client by posting the notice on the Website or using a messaging feature of the Website or by email to the address associated with his or her account or by mail or courier to the address provided by the Client. All notices, requests, enquiries, complaints, and other communications to the Supplier should be sent to the appropriate email or postal address specified by the GTC. A notice

shall be deemed to have been received: (a) the same day if given through a notice on the Website or by email; or in the case of a notice sent by mail or courier, on the day of the proven receipt of the notice, or in case of unsuccessful delivery 5 (five) days following the first delivery attempt.

XVI. Data Processing Agreement

16.1 This personal data processing agreement (“DPA”) contains personal data processing terms between Neticle and any Client that uses the Services to analyse texts or create and manage surveys by uploading the personal data it obtained from third party private individual data subjects in full compliance with the relevant laws as data Client.

16.2 In the context of this DPA:

• Personal Data to be processed includes personal data the Client obtained from third-party private individual data subjects (the users and respondents as explained below) and uploaded to the Website in order to analyse texts or create and manage surveys. Given the broad potential use of the Services, the scope of personal data may vary on an individual basis, and it is not possible to categorize those in advance. These data sets are usually customer reviews, social media comments, online news, survey answers collected with another survey platform. The Client, however, undertakes to minimize the scope of personal data used to an extent that is absolutely necessary for the give approved purpose.
• Approved Purposes: Personal Data is being processed only for the following purposes: use of the Services, analyse texts, create, and manage surveys.
• GTC is the General Terms and Conditions of the Services.
• Approved Sub-processors to be used for processing of Personal Data are the following companies: Microsoft Azure Cloud (cloud processing and storage provider) https://azure.microsoft.com/.
• Users are persons who are having access to the platform. The platform’s Users belong to clients, which are legal entities and – while they are also data subjects to the data controlling activity of the Neticle– they are responsible for the third-party data they upload to the platform as data controllers.
• Respondents are persons who are sending answers to the Client’s surveys that are shared via the platform. These respondents are usually customers of the Clients, potential customers, or employees of the Client.
• Administrators are employees of the Neticle. They are developers, account managers or analysts who might help the Users in steps, questions, or report creation. The Administrators are handling all Client information and data confidentially and cannot share it with 3rd parties without written permission from the Client.

16.3 Description of the data processing activity of the Neticle

16.3.1 Uploading data to the platform:

Users can upload data sets to process and analyse them with the platform. Uploaded data is analysed, text analysed and summarized by the platform. The results can be accessed via the platform dashboard or exported into different file formats. The Client’s Users have access to the uploaded data set. When data is uploaded to the platform it reaches the platform via encrypted HTTPS protocol. The platform is hosted in Microsoft Azure Cloud. The storage of the data is encrypted as well and they are physically located in the European Union, mainly in the Netherlands. Neticle is not sharing the uploaded data sets or analysis results with 3rd parties nor with other Clients. Upon client request the Administrators can have access to the data set to help in troubleshooting or platform usage. Users can create surveys with the platform and share them with specific respondents or share the survey link publicly.

16.3.2 Collecting survey data:

The Users may collect IP address, browser type, device, operation system data from the Respondents using the platform. This data collection can be switched on by the User before sharing the survey. The platform saves the Respondent answers only after fully finishing and submitting a survey by default. These settings can be changed by the User, so answers will be saved real-time. In this case the Respondents receive a notification automatically when they open the survey link. The collected survey answers and data is stored in a secure encrypted format and is not shared with 3rd parties or other Clients. Users can delete it permanently. If the Client collects personal or sensitive information from the respondents, it is the client’s responsibility to notify the respondents about their privacy and data management goals.

16.3.3 Embedded surveys:

With the platform Clients are able to integrate micro-surveys into mobile applications or web applications. These micro-surveys usually ask a few non-personal questions from the users of the application. For example: please rate this application or share your experience with your own words.

The micro-surveys may collect the respondents’ user id, their device type, and the triggering event. This data collection can be switched on by the User before activating the micro-survey. It is the Client’s responsibility to notify the respondents about the goals and details of the data collection. The collected survey answers and data is stored in a secure encrypted format and is not shared with 3rd parties or other Clients. Users can delete it permanently.

16.3.4 Integrations

Clients can also integrate the platform with their in-house IT solutions and databases. In this case the platform processes and analyses data which is collected by the Client via other channels and the Client has to notify the Respondents or data sources about the data processing with the platform.

16.3.5 Showing analysis results on dashboard

Users can see the result of the data processing and analysing via web-based dashboard from their browsers. They can see charts and summarizations and load the original data from which these values calculated. 3rd parties and other Clients’ Users do not have access to this dashboard.

16.3.6 Exporting and sharing the data

Users can export a data set analysis result into different file formats. This file contains the original data set and the calculated data as well. The exporting functions are only available for Users of the Client and the Administrators of the platform. The output of the analysis is available via a password protected dashboard through a web-browser. Only authenticated Users who have the necessary access rights can export the results via different file formats.

16.3.7 Access to personal data during development and support

In special cases Administrators of the platform might need to access personal data for testing or troubleshooting purposes. They do not have the right to copy or share personal information.

16.3.8 Storage period and deletion

The collected or uploaded data is stored until the termination / deactivation of the Client’s account. Users can delete every data set of the Client permanently and immediately from the platform. In such cases the original data and the calculated, enriched data is deleted as well. Platform system logs do not contain such data.

16.4 Legal terms of the data processing

16.4.1 Client guarantees that all Personal Data is obtained in full compliance with the relevant data protection laws. Neticle shall only process Personal Data on documented instructions from the Client. Personal Data shall only be processed for the Approved Purpose, worldwide.

16.4.2 Neticle may also process Personal Data when required to do so by European Union or Member State law to which the Neticle is subject; in such case, Neticle shall, if legally possible, inform the Client of that legal requirement before engaging in processing.

16.4.3 Neticle shall ensure that only persons authorized to process the personal data have access to the personal data and that such personnel are subject to obligations of confidentiality or have such duty under the law.

16.4.4 Neticle shall implement technical and organizational measures to ensure a level of security appropriate to the risk presented by the processing. The Neticle uses the computing capacity of Microsoft Azure Cloud. The related physical security and availability is guaranteed by Microsoft Azure Cloud, while on the software side the Neticle does regular security maintenance, security updates and maintains a professional user permission structure.

16.4.5 Neticle LLC also does regular updates and internal security audits for each software component and their frameworks. Neticle shall not engage any sub-service providers without prior specific authorization of Client. Neticle shall inform Client of any intended changes concerning the addition or replacement of sub-service providers prior to engaging them, thereby giving Client the opportunity to object to such changes.

16.4.6 Where Neticle engages a sub-service provider for carrying out specific processing activities on behalf of the Client, the same data protection obligations as set out in this Agreement shall be imposed on that sub-Neticle. Where sub-Neticle fails to fulfil its data protection obligations, Neticle shall remain fully liable to Client for sub-service provides’ acts and omissions.

16.4.7 Taking into account the nature of processing and data available to Neticle, it shall assist Client in:

• Fulfilment of Client’s obligation to respond to requests for exercising the data subject's rights under the applicable laws
• Implementing appropriate technical and organization measures to ensure a level of security appropriate to the risk hereunder.
• Carrying out Data Protection Impact Assessment, as reasonably required by the Client. - Communicating with national Data Protection authorities.

16.4.8 In the case of a personal data breach, Neticle shall without undue delay, and at the latest within 24 hours after becoming aware of it, notify the Client in writing of the breach. Such notification shall, at a minimum, contain information laid down in Article 33(3) of GDPR.

16.4.9 At the choice of Client, Neticle shall immediately delete or return all the personal data, including any copies, after the end of the provision of services relating to processing, or upon a written request from Client.

16.4.10 Neticle shall give Client access to all information reasonably necessary to demonstrate compliance with this Agreement and allow for and contribute to audits, including inspections, conducted by Client or another auditor mandated by the Client. Each of the parties shall bear its own costs related to such audits.

16.4.11 Neticle shall fully indemnify and hold the Client harmless from all claims, liabilities, costs, expenses

and damages and loss resulting from the Neticle’s failure to comply with the requirements set out in this Agreement and laws applicable to the Neticle’s processing activities.

16.4.12 Any non-conformity with the requirements set out in this Agreement shall be regarded as a material breach of this Agreement and the GTC by Neticle.

16.4.13 Any dispute, controversy, proceedings, or claim arising out of, or in any way relating to this Agreement, including, but not limited to, its formation, interpretation, breach, termination, or invalidity, shall be exclusively governed by Hungarian law, without giving effect to its conflict provisions. Any such dispute, controversy or claim shall be exclusively resolved by Hungarian courts.

16.4.14 All terms in this DPA are to be given the same meaning as in Regulation (EU) 2016/679 (General Data Protection Regulation) and the GTC unless otherwise is expressly indicated.

16.4.15 This present DPA is concluded by and between the Parties via electronic means upon the Client’s expressed acceptance of the Services and DPA.