Terms
of Service

Language notice

This document is a translation of the German Terms and Conditions of SIMINEO. In the event of discrepancies or differences in interpretation between this translation and the German version, the German version shall prevail, to the extent permitted by applicable mandatory law.

1. Introductory provisions

1.1 Purpose of the Terms and Conditions

These Terms and Conditions (hereinafter: “Terms and Conditions”) define the conditions for using the SIMINEO online service (hereinafter: “Service”), as well as the rights and obligations existing between the Provider and the User in connection with the use of the Service.

These Terms and Conditions regulate in particular the provisions relating to the creation and use of user accounts, the operation of the platform, the publication of user content, moderation, the use of subscription-based functions, and liability rules.

The rules relating to the processing of personal data are set out in SIMINEO’s separate Privacy Policy.

1.2 Provider information

The operator of the SIMINEO service is:

Name:
Jozsef Török

Legal form:
Sole proprietorship (Einzelunternehmen)

Registered office:
Schäfersteige 53.
73770 Denkendorf
Germany

Email address:
[email protected]

Website:
https://simineo.com

VAT identification number (USt-IdNr.):
DE312957247

1.3 Scope of the Terms and Conditions

These Terms and Conditions apply to the use of the SIMINEO Service and to the legal relationship established between the Provider and the User in connection with the use of the Service.

The Terms and Conditions apply to all registered Users of SIMINEO.

For paid subscriptions, SIMINEO uses Paddle as Merchant of Record and authorized reseller. The paid purchase and the associated payment and billing processes are handled through Paddle. In addition to these Terms and Conditions, the applicable contractual terms and policies of Paddle also apply to this transaction.

1.4 Contracting parties

On the basis of these Terms and Conditions, the legal relationship relating to the use of the Service is established between the Provider and the registered User.

If the User uses paid subscription-based functions, the paid purchase is made through Paddle as Merchant of Record and authorized reseller. The use of the SIMINEO service and the applicable access and usage conditions continue to be governed by these Terms and Conditions; the applicable contractual terms and policies of Paddle additionally apply to the transaction processed through Paddle.

SIMINEO manages access rights related to subscriptions on the basis of its own internal entitlement system. Subscription processes handled by the payment service provider and SIMINEO’s internal access management are separate systems.

1.5 Acceptance of the Terms and Conditions

By completing the registration of the user account and accepting these Terms and Conditions, the User declares that they have read, understood and accept the Terms and Conditions as binding on them.

Acceptance of the Terms and Conditions is a prerequisite for using the Service.

1.6 Modification of the Terms and Conditions

The Provider is entitled to modify these Terms and Conditions in particular in the event of changes in law, changes to the operation of the Service, the introduction of new functions, the discontinuation of existing functions, for security reasons, or due to other operational, technical or legal circumstances.

The amended Terms and Conditions enter into force at the time specified by the Provider.

The amendments apply to the use of the Service from the time they enter into force. The Provider informs Users in an appropriate manner of material amendments to these Terms and Conditions. Where the law or the nature of the amendment requires prior information, such information is provided before the amendment enters into force.

2. Definitions

2.1 Provider

The operator of the SIMINEO online service, whose details are set out in section 1.2 of these Terms and Conditions.

2.2 User

A natural person who registers a user account for the SIMINEO service or uses the Service in accordance with the provisions of these Terms and Conditions.

In the case of a Company profile, the User is the natural person acting on behalf of the business or organisation, who is authorised to represent it or has been authorised by it.

2.3 Service

The online platform operated by SIMINEO and the entirety of all functions, services and related systems available through it.

2.4 User account

The individual access created for the User, which enables the use of the Service, management of the profile and the exercise of the rights set out in these Terms and Conditions.

2.5 Private profile

A user profile created in the SIMINEO service for a private individual.

2.6 Company profile

A user profile used to present a business or organisation on SIMINEO, managed by a natural person who is authorised to represent the business or organisation or has been authorised by it.

2.7 Content

Any text, image, graphic, media file or other information published or made available by the User or the Provider within the framework of the Service.

2.8 Subscription

The entitlement related to a subscription established through the external payment service provider, on the basis of which SIMINEO’s internal entitlement system may provide access to subscription-based functions in accordance with these Terms and Conditions.

2.9 Entitlement

SIMINEO’s internal authorisation record, on the basis of which the system determines whether the User is entitled to use subscription-based functions.

2.10 Moderation

The entirety of measures carried out by the Provider that serve to ensure the secure, lawful and proper operation of the Service.

2.11 Report

A report submitted through a community reporting function provided within the Service in relation to content or conduct which, in the opinion of the reporting User, may violate these Terms and Conditions or other platform rules. Such a report may trigger a moderation review but does not automatically constitute a formal notice of illegal content under Section 2.12.

2.12 Formal notice of illegal content

A notice submitted by a person or entity through the electronic notice-and-action mechanism provided for this purpose pursuant to Article 16 of Regulation (EU) 2022/2065 (Digital Services Act – DSA) concerning specific information within the Service that such person or entity considers to constitute illegal content. This formal procedure is separate from the community reporting functions under Section 2.11.

2.13 Terms and Conditions

The current version of these Terms and Conditions.

3. The SIMINEO service

3.1 Purpose of the platform

SIMINEO is an online platform that enables businesses to create their own profile and publish their own content, and enables Users to browse, follow and like such content and manage their user account.

The purpose of the Service is to provide businesses and Users with a transparent, secure and unified online interface for viewing content published by businesses and interacting with such content.

3.2 Characteristics of the service

The operation of SIMINEO is based on the functions and rules defined in these Terms and Conditions.

The Service provides in particular:

• creation and public display of business profiles;
• display of content published by businesses;
• user Follow function;
• user Like function;
• user Report option;
• application of moderation and platform security measures;
• possibility to use subscription-based functions.

The availability of certain functions of the Service may depend on an active subscription or internal entitlement status.

3.3 Operation of display and sorting logic

When displaying content and business listings, SIMINEO primarily applies time-based and predefined display rules.

In the general Browse view, the order of displayed business content is primarily based on recency. More recently published content is displayed before older content. Where the view is limited to one item per business, the most recent visible item of that business is taken into account. Search or filter criteria selected by the User first determine which content or businesses are included in the result set; within that result set, recency remains the decisive sorting parameter.

For Private Search, the location specified by the private User determines which search requests may be displayed to a business on the basis of its saved locations. Among matching search requests, newer requests are displayed before older requests. Location acts as an eligibility criterion and not as a weighted relevance score.

For Radar, the search point and search radius selected by the User first determine which business profiles are included. Within that area, distance from the selected search point is the decisive sorting parameter. The detailed Radar ordering rules are set out in section 3.3.1.

For Company NOW, active entries are generally displayed according to recency, with newer entries appearing before older entries. A User-selected restriction to followed businesses determines only the scope of displayed entries and does not constitute an additional weighted ranking parameter.

The relative importance of the main parameters therefore depends on the function used: for Browse and Company NOW, recency is the decisive sorting parameter; for Private Search, location-based selection takes place first and is followed by time-based ordering; for Radar, the selected search radius first limits the result set and the subsequent ordering is determined by distance. Search terms, filters and User-selected views determine the relevant result set without creating any additional weighted ranking within that set.

SIMINEO’s current operation does not apply ranking based on user activity, number of Likes, follower counts, popularity indicators, individual behavioural profiles or paid prioritisation. Businesses currently cannot obtain a better position in these display or sorting orders either through payment or by choosing a particular subscription. If paid highlighting or any other payment-dependent influence on ordering is introduced in the future, the relevant conditions and their effects on display will be disclosed in the applicable contractual information before introduction.

If any content becomes subject to a moderation measure, its visibility may be restricted in accordance with the provisions of these Terms and Conditions relating to moderation.

3.3.1 Radar search results and ordering

The Radar function applies function-specific geographical ordering that is separate from the time-based display and sorting rules used in other areas.

The main parameter determining the order of business profiles displayed in the Radar results list is the geographical distance between the Radar search point selected by the User and the coordinates provided by the relevant business for participation in the Radar function. Businesses located at a shorter distance are displayed before businesses located farther away.

Geographical distance is the decisive sorting parameter for this results list because the purpose of the Radar function is to make businesses discoverable within the geographical radius selected by the User.

Follow status, Likes, popularity, other interaction or engagement values, Company NOW, and the amount or type of any payment or subscription do not improve a business's position in the Radar results list. SIMINEO currently does not offer paid prioritisation within this Radar ordering.

The radial distance of a business from the centre of the graphical Radar display represents its distance from the selected search point. By contrast, the angular position within the circular display does not represent a geographical direction, distance-based ordering or any other substantive ranking. It is used solely to provide a clear visual arrangement that avoids overlaps as far as reasonably possible. Where not all businesses within the selected search radius can be shown in the graphical Radar at a particular zoom level without material overlap, results are considered for this graphical display in distance order; additional businesses may appear at higher zoom levels once sufficient display space becomes available. Businesses already shown during the same Radar search generally retain their assigned angular position in order to avoid visual jumps when zooming in or out. This graphical display logic does not change either the result set or the complete Radar results list, which remains sorted by distance.

3.4 Follow

Users are entitled to follow business profiles and to stop following them.

The Follow function may only be used with an authenticated user account and, where required by the Service, with the appropriate entitlement.

Follow relationships are data connected to SIMINEO’s internal operation. In the current operation of the Service, follow relationships do not constitute a publicly displayed social relationship network.

3.5 Like

Users are entitled to like content published in the Service and to withdraw a like.

Likes constitute internal interaction data connected to the User. The Service may publicly display only the aggregated number of likes, but not the identity of the individual Users who liked the content.

The Like function may only be used with an authenticated user account and, where required by the Service, with the appropriate entitlement.

3.6 Public business profiles

Only Company profiles may appear publicly in the SIMINEO service.

Only those business profile data and content appear publicly that the business provides or publishes within the framework of the Service for the purpose of public display, as well as those aggregated system data that SIMINEO displays publicly in connection with the operation of the service.

Publicly published business profiles and posts may be shared through a unique internet link (URL). Such content may be indexed by search engines and may therefore be accessible to anyone who has the relevant link.

The personal data of private user profiles are not public.

During follows and likes, SIMINEO does not publicly display the identity of individual Users. The Service may display only aggregated follower and like counts.

The Provider may apply moderation and security measures defined in these Terms and Conditions to publicly displayed business profiles and content, which may affect the visibility of content or profiles.

3.7 Availability of the service

The Provider endeavours to ensure that the SIMINEO service is continuously and securely available.

However, the operation of the Service may temporarily be partially or fully restricted or unavailable due to periodic maintenance, development, security measures, technical errors or other operational circumstances.

The detailed rules relating to the availability, maintenance and modification of the operation of the Service are set out in section 14 of these Terms and Conditions.

4. Registration and user account

4.1 Registration

The SIMINEO service requires registration.

When creating a user account, the User is obliged to provide the data requested during the registration process truthfully and to select the profile type they wish to use during registration.

The User is entitled to create a user account only in their own name or, in the case of a Company profile, as a natural person authorised to represent the relevant business or organisation or authorised by it.

Completion of registration is subject to acceptance of these Terms and Conditions.

4.1.1 Minimum age

A SIMINEO user account may be created and used only by natural persons who have reached the age of 18.

By registering, the registering natural person expressly confirms that they are at least 18 years old.

In the regular registration process, SIMINEO does not require the date of birth or the presentation of an identity document solely for the purpose of confirming the minimum age. The confirmation made during registration constitutes a declaration by the User and not an age verification carried out by SIMINEO.

If SIMINEO obtains reasonable knowledge that a User has not reached the required minimum age, the contractual relationship associated with the user account may be terminated in accordance with the applicable legal provisions and these Terms and Conditions, and the technical termination process provided for this purpose may be carried out.

4.2 Account types

SIMINEO provides two different user account types:

• Private profile;
• Company profile.

The selected profile type determines the functions, interfaces and certain operational characteristics of the service available to the User.

The profile type is selected during registration.

4.2.1 Private profile

The Private profile is a user account created for natural persons.

The Private profile enables, in particular, browsing business profiles, following them, liking content, and using other user functions provided by SIMINEO in accordance with the provisions of these Terms and Conditions.

4.2.2 Company profile

The Company profile is used for the presentation of businesses and organisations in the SIMINEO service.

The Company profile is a user account connected to the business or organisation.

The Company profile is intended exclusively for use in the course of a commercial, business or independent professional activity. Registration and use of a Company profile do not take place for predominantly private purposes.

The Company profile is managed by a natural person who is authorised to represent the business or organisation or has been authorised by it.

The manager of the Company profile declares that they are entitled to act on behalf of the business or organisation and to accept these Terms and Conditions and use the Service.

The Company profile enables, in particular, the public display of the business profile, publication of own content and use of the functions provided for businesses.

4.3 Formation of the contract

In the case of a Private profile, the contract is concluded between the Provider and the registering natural person.

In the case of a Company profile, the contract is concluded between the Provider and the business or organisation on behalf of which the registering natural person is entitled to act.

The contract is concluded upon successful completion of registration and acceptance of these Terms and Conditions.

The later use of subscription-based services does not result in the conclusion of a new user contract, but provides additional entitlements within the framework of the existing legal relationship in accordance with the provisions of these Terms and Conditions.

The rules relating to the payment relationship and billing connected to subscriptions are set out in section 6 of these Terms and Conditions.

4.4 Account security

The User is obliged to keep the access data of their user account confidential and to take all measures reasonably expected of them to prevent unauthorised use.

The User is responsible for any activity carried out with their user account in connection with a breach of these Terms and Conditions or the unauthorised transfer of access data.

If the User notices or reasonably suspects that an unauthorised person may have gained access to their user account, they must notify the Provider without undue delay.

4.5 Recovery Code and email ownership

In the SIMINEO service, the primary identifier of the user account is the email address provided during registration.

Verification of ownership of the user account and the security of the procedure for changing the email address are supported by SIMINEO’s Recovery Code system.

The Recovery Code serves exclusively to verify ownership of the user account within the procedures provided by the Provider, and the User is obliged to keep it secure.

The detailed conditions for changing the email address and recovering the account are determined by the security and identification procedures provided by SIMINEO.

4.6 Management of the user account

The User is entitled to manage their user account within the functions provided by the Service and to use it in accordance with the provisions of these Terms and Conditions.

The Provider is entitled to apply security, authentication and administrative measures connected to the operation of the user account where these are necessary to ensure the secure operation of the Service, the protection of user accounts or compliance with legal obligations.

Measures relating to the user account do not affect the Provider’s moderation, subscription management or other rights defined in these Terms and Conditions.

5. Rights and obligations of the parties

5.1 Rights and obligations of the Provider

The Provider is entitled to operate, develop, maintain and preserve the security of the SIMINEO service, and to enforce the provisions of these Terms and Conditions.

The Provider is obliged to operate the Service in accordance with the applicable laws, taking into account the technical and organisational possibilities available to it.

The Provider is entitled to apply technical, administrative and moderation measures in order to ensure the security, integrity and lawful operation of the Service.

The Provider is entitled to carry out developments, maintenance, security measures and other operational activities affecting the operation of the Service.

The Provider is entitled, under the conditions defined in these Terms and Conditions, to modify or restrict the availability of certain functions of the Service and user entitlements.

5.2 Rights and obligations of the User

The User is entitled to use the SIMINEO service in accordance with the provisions of these Terms and Conditions.

The User is obliged to provide truthful data during registration, to manage their user account securely, and to use the Service lawfully and properly.

The User is obliged to refrain from any conduct that violates or endangers the security or operation of the Service, the rights of other Users, or the legitimate interests of the Provider.

In the case of a Company profile, the business is responsible for the operation of the profile and for the content published on the profile. The business must ensure that the Company profile is managed only by a person authorised to represent it or authorised by it.

5.3 Proper use

The User is obliged to use the SIMINEO service in accordance with its intended purpose, these Terms and Conditions, the applicable laws and the requirements of good-faith exercise of rights.

The Service may only be used for the proper use of the functions provided by SIMINEO.

The User is obliged to cooperate with the Provider in all cases where this is justified in order to ensure the security, operation or lawful use of the Service.

5.4 Usage restrictions

The User is not entitled to use the Service in a manner that endangers its security, operation or the enforcement of the rights of other Users.

Restrictions on the use of individual functions or on access may be imposed only within the procedures technically provided for this purpose and applicable under these Terms and Conditions, in particular on the basis of actually existing security, authentication, access or subscription requirements, as well as within the moderation measures provided for specific User Content.

The detailed rules are set out in particular in the provisions of these Terms and Conditions concerning subscriptions and access entitlements, moderation and reporting procedures, the user account and access, and termination of the contractual relationship.

6. Subscriptions and payments

6.1 Subscription plans and launch free-access period

SIMINEO currently offers subscriptions for Private profiles and Company profiles with monthly or annual billing. For a Private profile, the price is EUR 4.99 with monthly billing or EUR 49.90 with annual billing. For a Company profile, the price is EUR 19.99 with monthly billing or EUR 199.90 with annual billing.

At the launch of SIMINEO, a single fixed free-access period applies to both Private profiles and Company profiles. This free-access period lasts through 31 October 2026 at 23:59 (Europe/Berlin).

During the launch free-access period, the Service may be used within the intended scope without entering into a paid subscription. The launch free-access period is not an individual trial period and does not start separately for each User.

Use of the launch free-access period does not require entering into a Paddle subscription or providing a payment method. When the free-access period expires, no paid subscription is automatically created, activated or renewed, and no automatic charge is made.

From 1 November 2026, continued use of subscription-based or correspondingly access-protected functions generally requires a subscription initiated by the User, unless another internal entitlement is granted by SIMINEO.

Existing valid subscriptions are not affected by the launch free-access period.

The Provider is entitled to determine, modify or expand the scope of subscription-based functions within the limits of applicable legal and contractual requirements.

The subscription does not affect the creation or continued existence of the user account, but grants entitlement to use the services that are subscription-based at the relevant time.

6.2 Creation and duration of the subscription

A subscription is created only upon successful completion of a payment process initiated by the User. Expiry of the launch free-access period does not by itself create a subscription.

The subscription is entered into with a monthly or annual billing period, as selected by the User, and automatically renews for another billing period of the same duration unless it is cancelled. There is no minimum contractual term extending beyond the billing period selected at the relevant time. The subscription may be cancelled at any time, with cancellation taking effect at the end of the current billing period that has already been paid for.

The paid subscription purchase and the associated payment and billing processes are handled through Paddle as Merchant of Record and authorized reseller.

For the transaction-, payment-, billing- and tax-related aspects managed by Paddle, as well as the recurring billing managed there, the applicable contractual terms of Paddle apply additionally. The use of the SIMINEO service and the internal access entitlements are governed by these Terms and Conditions.

Based on the existence of the subscription, SIMINEO’s own internal entitlement system decides on the availability of subscription-based functions.

6.3 Paddle as Merchant of Record

SIMINEO uses the Paddle payment service operated by Paddle.com Market Limited and its affiliated companies for the management of subscriptions.

Payment transactions, the handling of payment data, billing, financial management of the subscription and related payment operations take place in Paddle’s systems.

When entering into the subscription, the User also accepts the applicable contractual terms and data processing rules of Paddle.

SIMINEO does not store card data or other payment data that is processed by Paddle.

6.4 SIMINEO’s internal entitlement system

The use of subscription-based services is determined by SIMINEO’s own internal entitlement system.

Access entitlements are not determined exclusively on the basis of information displayed on the external payment service provider’s interface.

SIMINEO’s internal system may grant access in particular on the basis of an active subscription, an active launch free-access period or another internal entitlement granted by SIMINEO. Where no sufficient entitlement exists, use of subscription-based functions may be restricted accordingly.

Access entitlements related to subscriptions may only be exercised in accordance with these Terms and Conditions and SIMINEO’s internal operating rules.

6.5 Customer Portal

SIMINEO may provide the User with access to the Customer Portal provided by Paddle.

By using the Customer Portal, the User may in particular be entitled to manage their subscription, payment method and billing data, where this is enabled by Paddle’s system.

Paddle is responsible for the operation, availability and functions of the Customer Portal.

6.6 Cancellation

The User is entitled to cancel their subscription according to the procedures provided by Paddle.

Cancellation of the subscription does not automatically result in deletion of the user account.

Cancellation may result in a change to the subscription status in SIMINEO’s internal entitlement system in accordance with the provisions of these Terms and Conditions.

6.7 Scheduled deletion

If the subscription is terminated, SIMINEO’s internal system may maintain the entitlements related to the subscription until the end of the relevant subscription period.

Thereafter, the internal entitlements related to the subscription may cease, and SIMINEO’s internal subscription record may be closed in accordance with lifecycle management related to the operation of the service.

6.8 Termination of the subscription

Termination of the subscription does not automatically result in termination of the user contract or deletion of the user account.

The user account may remain in existence; however, the use of subscription-based services may be restricted or cease.

Termination of the subscription, deletion of the user account, and administrative or moderation measures applied by SIMINEO are separate legal and operational events.

7. User content

7.1 Publication of content

The SIMINEO service enables Users with a Company profile to publish content within the framework of the Service.

The User is entitled to publish only content that they are authorised to publish and that does not violate these Terms and Conditions, applicable laws or the rights of third parties.

The Provider is entitled to technically check, perform security checks on, process, convert the format of, and carry out other technical operations necessary for the secure operation of the Service in relation to uploaded content and media files.

Technical processing may in particular include file checks, image processing, format conversion, storage, temporary processing, and technical clean-up operations related to faulty or unsuccessful uploads.

7.2 Responsibility for content

The User is fully responsible for the lawfulness, accuracy and lawful usability of the content published or uploaded by them.

In the case of a Private profile, the natural person publishing the content is responsible for the content.

In the case of a Company profile, the business or organisation operating the profile is responsible for the published content. The business must ensure that the Company profile is managed only by a person authorised to represent it or duly authorised by it.

Technical checks, validations, image processing, format conversion, storage operations, security measures or other technical processing carried out by SIMINEO do not result in responsibility for the published content being transferred to the Provider.

7.3 Rights of third parties

The User must refrain from publishing any content that infringes the copyright, industrial property rights, personality rights, data protection rights or other rights of third parties.

The User is responsible for ensuring that they have the necessary rights to use, disclose and display the published content in the Service.

Where content provided or published by the User contains special categories of personal data concerning an identified or identifiable natural person within the meaning of Article 9(1) GDPR, the User must, insofar as required by applicable data protection law, ensure that any required legal basis under Article 6 GDPR and an applicable condition under Article 9(2) GDPR or other sufficient authorisation under applicable law are in place. Where the information concerns a person other than the publishing User, the User's publication alone neither constitutes that person's consent nor means that the data subject has manifestly made the data public themselves.

Where content published by the User contains an identifiable depiction of another person, the User is responsible for ensuring that the publication and display of that person within the Service is based on valid consent or another legal basis or authorisation sufficient under applicable law.

Where a minor is identifiably depicted, the User must additionally ensure that all consents, approvals or other authorisations required under applicable law have been obtained; where required, this includes consent or approval from the minor's legal representative.

If a third party asserts a claim or demand in relation to the published content, the User is obliged to cooperate with the Provider in order to clarify the necessary facts.

7.4 Licence granted to SIMINEO

By publishing content, the User grants the Provider a non-exclusive right of use, to the extent necessary for the operation of the Service, to store, display, technically process, convert the format of, transmit and make copies of the published content as necessary for the operation of the Service.

This right of use may be exercised only to the extent necessary for the proper operation of SIMINEO, the provision of the service, maintaining its security, and performing the technical and operational tasks set out in these Terms and Conditions.

The right of use under this section does not result in the transfer of ownership of the content or copyright to the Provider.

This licence exists only for as long and to the extent necessary to provide and operate the published content within SIMINEO in accordance with the intended operation of the Service.

Upon deletion of the content or its permanent removal from regular provision within the Service, the licence for further public display ends. Any temporary storage or processing that is legally permitted or required, in particular for security, moderation, evidentiary or backup purposes, remains unaffected; such retention does not permit the content to be made publicly available again.

7.6 AI labelling of post images

When publishing a new image-based company post, the publishing user must declare whether its image was generated or substantially edited using artificial intelligence (AI), or whether this is not the case (Not AI), to the best of their knowledge. The declaration must be made carefully and truthfully.

The visible badge displays the classification declared by the uploader or made effective following administrative review. It is not a technical authenticity assessment, proof of origin or guarantee by SIMINEO. This feature does not perform general automated AI detection.

Older posts without a declaration may retain an unknown status and may display no AI badge. The uploader's original declaration remains recorded internally even if an administrator later changes the displayed classification.

7.5 Company NOW

SIMINEO may provide Users with a Company profile with the “Company NOW” function. This function enables the publication of a short, current message concerning the business, its activities, availability, or other current information related to the Company profile.

A Company NOW constitutes User Content within the meaning of these Terms and Conditions. In particular, the provisions of this chapter and the rules concerning prohibited content, moderation and User responsibility apply to its content.

A Company profile may publish no more than one active Company NOW at a time. The content of a Company NOW is limited to a maximum of 85 characters and remains active for no longer than 24 hours from publication. The User may delete the active Company NOW before the end of this period or replace it with a new Company NOW.

Using the settings provided by SIMINEO, the User may determine whether an active Company NOW may be displayed exclusively within the registered area of the Service or additionally on a publicly accessible SIMINEO interface before login.

Additional public visibility occurs only where the User expressly enables it for the relevant active Company NOW. The User may disable public visibility again during the active period. Changing the visibility does not alter the time limitation applicable to the relevant Company NOW.

Where public visibility is enabled, the relevant Company NOW may also be displayed to persons who are not logged in to SIMINEO together with the publicly visible Company profile information required for its display and attribution.

The public display of a Company NOW does not constitute a recommendation, review, endorsement, advertisement or paid promotion by SIMINEO. Responsibility for the lawfulness, accuracy and permissibility of the published content remains with the User or the business or organisation operating the Company profile.

7.6 AI labelling of post images

When publishing a new image-based company post, the publishing user must declare whether its image was generated or substantially edited using artificial intelligence (AI), or whether this is not the case (Not AI), to the best of their knowledge. The declaration must be made carefully and truthfully.

The visible badge displays the classification declared by the uploader or made effective following administrative review. It is not a technical authenticity assessment, proof of origin or guarantee by SIMINEO. This feature does not perform general automated AI detection.

Older posts without a declaration may retain an unknown status and may display no AI badge. The uploader's original declaration remains recorded internally even if an administrator later changes the displayed classification.

8. Intellectual property

8.1 SIMINEO’s copyright

The SIMINEO service, its source code, user interface, graphic elements, design, icons, proprietary font(s), documentation and other intellectual creations produced by the Provider constitute the intellectual property of the Provider or other rights holders and are protected by copyright and other legal protection provided by applicable laws.

These Terms and Conditions or the use of the Service do not grant the User ownership or any right to use the intellectual creations referred to in this chapter, except to the extent necessary for the proper use of the Service.

8.2 Limits on platform use

The User is not entitled to copy, modify, reverse engineer, reproduce, distribute, publicly use or otherwise use the SIMINEO service or any part of it without authorisation or in a manner contrary to law or these Terms and Conditions.

In particular, it is prohibited to circumvent the technical protection of the Service, to analyse the operation of the Service without authorisation, to copy it automatically, or to use it in a way that infringes the rights of the Provider or third parties.

8.3 Trademarks and other rights

The SIMINEO name, logo, brand elements and other signs are connected to the Provider’s intellectual property and may be protected under applicable laws.

The User may use these signs for business, commercial or other purposes going beyond the proper use of the Service only with the Provider’s prior written permission.

This chapter does not affect the copyrights, trademark rights or other intellectual property rights of third parties.

9. Prohibited content and prohibited conduct

9.1 General principles

The User is obliged to use the SIMINEO service lawfully, properly and in accordance with these Terms and Conditions.

It is prohibited to publish, upload, transmit or make available any content, or to engage in any conduct, that is contrary to law, infringes or endangers the rights of third parties, disrupts the security or operation of the Service, or is contrary to the purpose of SIMINEO.

In the case of a Company profile, the business or organisation is responsible for ensuring that the content published on the profile and the use of the profile comply with these Terms and Conditions, applicable laws and the rights of third parties.

The Provider is entitled to apply moderation, administrative, security or other measures under these Terms and Conditions in relation to prohibited content or prohibited conduct.

When assessing content, its meaning, context, purpose and specific manner of presentation are taken into account. The mere occurrence of individual words, expressions, visual elements, body parts or nudity does not in itself automatically constitute a violation of these Terms and Conditions. Relevant factors include the context in which the content is published, the message it conveys, the person or subject at which it is directed and its reasonably apparent purpose.

Visible skin, partial nudity or depiction of the human body may in particular be permitted where reasonably justified by an artistic, tattoo-related, cosmetic, medical, professional or comparable context. Pornographic content or content that, taken as a whole, is predominantly sexually explicit and whose principal purpose is sexual depiction or sexual arousal is not permitted within the Service.

Written or spoken content is likewise not assessed solely on the basis of individual words or expressions. Moderation takes into account in particular the overall meaning, linguistic and cultural context, direction and purpose of the communication, use as a quotation or as part of an artwork or tattoo, and whether the communication is used in an insulting, harassing, threatening, discriminatory or otherwise abusive manner directed at a person or group.

9.2 Illegal content

The User is not entitled to publish, upload or make available in the Service any content that is unlawful, infringing, misleading, harmful, abusive or contrary to these Terms and Conditions.

The prohibited content categories listed in this section are examples. The Provider is also entitled to take action against other content that is contrary to law, infringes the rights of third parties, or endangers the secure and proper operation of the Service.

9.2.1 Violent content

It is prohibited to publish content that incites violence, glorifies violent acts, contains threats, or supports conduct that endangers the physical integrity, life or safety of other persons.

9.2.2 Hateful content

It is prohibited to publish content that incites hatred against persons or groups, encourages discrimination, or attacks a protected or vulnerable group in a manner that violates human dignity.

9.2.3 Terrorism-related content

It is prohibited to publish content suitable for supporting, promoting, justifying or facilitating terrorist acts, terrorist organisations or unlawful activities related to terrorism.

9.2.4 Content harmful to children

It is prohibited to publish any content that is directed against children, endangers, exploits or abuses children, or unlawfully depicts them in any way.

9.2.5 Harassing or threatening content

It is prohibited to publish content or engage in conduct aimed at harassing, intimidating, threatening, humiliating or targeting another person.

9.2.6 Misleading or fraudulent content

It is prohibited to publish content that is misleading, fraudulent, false or contains untrue statements, or that may mislead others, particularly in relation to identity, business information, services, offers, entitlements or business communications.

9.2.7 Spam and unsolicited content

It is prohibited to use the Service for spam, mass unsolicited content, repeated promotional abuse, automated content distribution or commercial abuse incompatible with the purpose of the Service.

9.2.8 Malware and security abuse

It is prohibited to publish or transmit any content, file, code, link or other element that contains malware, malicious code, phishing elements, solutions facilitating unauthorised access, or elements endangering the security of the Service, other systems or other Users.

9.2.9 Unauthorised publication of personal data

It is prohibited to publish or make available without authorisation personal data, confidential information, access data or other non-public data of third parties.

9.2.10 Other illegal content

It is prohibited to publish any other content that violates applicable laws, infringes the rights of third parties, may violate or endanger official or court proceedings, or infringes or endangers the legitimate interests of the Provider or the secure operation of the Service.

9.3 Content infringing intellectual property

It is prohibited to publish, upload or make available content that infringes a third party’s copyright, trademark right, industrial property right, trade secret or other intellectual property right.

The User is responsible for ensuring that they have all rights necessary to use, display, publish and otherwise make use of the published content within the SIMINEO service.

The Provider is entitled to apply moderation, removal, restriction or other measures under these Terms and Conditions in relation to content infringing intellectual property or raising suspicion of such infringement.

9.4 Content infringing third-party rights

It is prohibited to publish content that infringes or endangers a third party’s personality rights, reputation, right to image or voice recording, data protection rights, trade secret, contractual rights or other legitimate interests.

The User must ensure that the published content does not infringe the rights of other persons or organisations and does not contain unauthorisedly used data, images, signs, business information or other protected content.

9.5 Prohibited platform use

The User is not entitled to use the SIMINEO service in a way that infringes or endangers the security, stability or operation of the Service, the rights of other Users, or the legitimate interests of the Provider.

9.5.1 Automated use

Unauthorised automated use of the Service is prohibited, including in particular scraping, bots, automated queries, artificial traffic, automated registrations or other unauthorised automated operations.

9.5.2 Circumvention of security measures

It is prohibited to circumvent, bypass, manipulate or attempt to circumvent the technical, security, access-management, subscription, moderation or other protective measures of the Service.

9.5.3 False or misleading accounts

It is prohibited to create, manage or use a false, misleading or unauthorised user account or Company profile, or one created or used without authorisation in the name of another person, business or organisation.

In the case of a Company profile, the person managing the profile must be authorised to act on behalf of the relevant business or organisation.

9.5.4 Abnormal use of the service

It is prohibited to use the Service in a way that overloads, disrupts, damages or causes abnormal operation of the Service, its infrastructure, security systems, upload processes, reporting system or moderation processes.

9.5.5 Other abuses

Any other abusive conduct that is contrary to the purpose of these Terms and Conditions, the intended purpose of the Service, the requirement of good-faith exercise of rights or the legitimate interests of the Provider is prohibited.

10. Moderation and reporting procedures

10.1 Community reports

SIMINEO provides community reporting functions for content for which such functions are intended, through which Users may report content or conduct that, in their opinion, violates these Terms and Conditions or other platform rules.

A community report serves to initiate a moderation review. It is separate from the formal notice of illegal content under Section 10.2 and does not become a notice under Article 16 DSA merely because the reporting User considers content to be illegal.

SIMINEO may receive, record, process and review community reports within the moderation procedure applicable to the relevant content.

Technical and security-related measures for preventing abuse may be used to ensure the proper functioning of the community reporting functions.

10.7 AI Check – review of image labels

AI Check is a separate process for reporting and reviewing potentially incorrect AI labels on post images. Eligible signed-in users may report a specific post and provide their reasons. A report does not itself establish that a label is incorrect.

Following human administrative review, SIMINEO may set the effective classification to AI or Not AI, dismiss the report without a change, or request further information. The uploader's original declaration is not overwritten. This process does not guarantee a determination of the image's technical origin.

The affected company user and participating reporters may receive service emails about review steps and decisions. A recorded email send does not guarantee actual delivery or reading.

AI Check is separate from community reports and formal illegal-content notices under Article 16 DSA. Allegedly illegal content must be reported through the separate process provided for that purpose. Knowingly false or abusive AI Check reports are prohibited.

10.2 Formal notices of illegal content under Article 16 DSA

Independently of the community reporting functions, SIMINEO provides a separate electronic notice-and-action mechanism for formal notices of illegal content pursuant to Article 16 of Regulation (EU) 2022/2065 (Digital Services Act – DSA).

This procedure enables persons and entities to notify SIMINEO of specific information within the Service that they consider to constitute illegal content. The notice must contain the information requested in the designated form that is necessary to identify the contested content and review the notice.

A formal notice does not in itself automatically result either in a finding of illegality or in the restriction or removal of the affected content. The notice is reviewed and a decision is made regarding further action.

Where the reporting person or entity provides electronic contact details, they receive an acknowledgement of receipt within the implemented procedure and, after the decision has been concluded, a notification of the decision. An electronic message technically recorded as sent does not constitute a guarantee that it was actually delivered to the recipient.

10.3 Moderation process

Neither a community report nor a formal notice of illegal content in itself means that the affected content or reported conduct is actually illegal or violates these Terms and Conditions. The mere receipt of a report or notice therefore does not automatically result in restriction or removal of content or any other measure.

SIMINEO reviews reports and notices within the procedure provided for the relevant type of report and content and decides on further action on the basis of the information available in the specific case.

The review may take into account in particular the content of the report or notice, the specifically affected content or circumstances, available evidence, applicable legal provisions and these Terms and Conditions.

In the currently implemented decision procedures for Community reports as well as formal notices under Article 16 DSA, the moderation decision is made following an administrative human review. Technical functions used to identify or assign a possible target content support this review but do not make an automated moderation decision.

10.4 Moderation measures

If the review establishes that specific content violates these Terms and Conditions or applicable legal provisions, SIMINEO may, within the moderation procedure technically provided for the relevant content, restrict its visibility or remove the content from normal user visibility.

The currently implemented content-related measures include in particular restricting the visibility or administratively removing published Posts, as well as removing Company NOW content. Such a moderation measure does not necessarily mean the final technical deletion of the underlying data record.

The type and scope of the measure depend on the specific content, the established violation and the legal or contractual basis relevant to the decision.

10.5 Technical administrative and security measures

Independently of a content-related moderation decision, SIMINEO may apply technically necessary administrative, security or access measures insofar as these are required for the secure operation of the Service, authentication, the management of actually existing access entitlements or the protection of the user account and are technically provided within the Service.

Such technical measures must be distinguished from a content-related moderation decision, an account-related moderation sanction and a subscription-related entitlement decision.

10.6 Abuse of reporting functions

Community reporting functions may be used only in good faith and for their intended purpose. In particular, they must not be misused for malicious, knowingly false, harassing reports or reports that disrupt the operation of the Service.

SIMINEO may apply technically provided abuse-prevention measures to protect the security and functionality of the community reporting functions.

Formal notices of illegal content under Article 16 DSA are subject to the requirements of the notice-and-action mechanism provided for this purpose, including the declaration requested in the form that the information submitted is accurate and complete to the best of the notifier’s knowledge and belief.

This Section does not create any automatic or currently unimplemented procedure for suspending, deactivating or terminating a user account merely because reports or notices have been submitted.

10.7 AI Check – review of image labels

AI Check is a separate process for reporting and reviewing potentially incorrect AI labels on post images. Eligible signed-in users may report a specific post and provide their reasons. A report does not itself establish that a label is incorrect.

Following human administrative review, SIMINEO may set the effective classification to AI or Not AI, dismiss the report without a change, or request further information. The uploader's original declaration is not overwritten. This process does not guarantee a determination of the image's technical origin.

The affected company user and participating reporters may receive service emails about review steps and decisions. A recorded email send does not guarantee actual delivery or reading.

AI Check is separate from community reports and formal illegal-content notices under Article 16 DSA. Allegedly illegal content must be reported through the separate process provided for that purpose. Knowingly false or abusive AI Check reports are prohibited.

11. Content status and visibility

11.1 Hidden status

Hidden status means a restriction of the visibility of content.

In Hidden status, the content may not appear, or may appear only in a restricted manner, on the normal user interfaces of the Service; however, this does not in itself constitute final deletion of the content.

Hidden status may be applied within a content-related moderation procedure technically provided for this purpose.

11.2 Administrative removal

Administrative removal is a content-related moderation measure intended to remove content from normal user visibility following a decision made within the procedure provided for this purpose.

In the case of administrative removal, the content does not appear on the normal user interfaces of the Service.

Administrative removal is not the same as deletion under data protection law and does not necessarily mean final technical deletion.

11.3 Technical deletion after expiry of the applicable retention period

A moderation measure restricting the visibility of content or administratively removing content does not automatically mean its immediate final technical deletion.

Content and data connected with a moderation or reporting decision may, insofar as necessary for the relevant processing, continue to be retained for the limited retention periods described in the Privacy Policy and may subsequently be deleted or anonymised in accordance with the applicable deletion rules.

Technical deletion after expiry of an applicable retention period must be distinguished from the preceding moderation decision and from the restriction of visibility or administrative removal of the content.

11.4 Deletion under the GDPR

Deletion under the GDPR means the data protection deletion or anonymisation process connected with the protection of personal data or the deletion of a user account.

Data protection deletion or anonymisation must be distinguished from a moderation measure restricting visibility or administratively removing content.

SIMINEO’s Privacy Policy and the applicable data protection laws apply to data protection deletion and anonymisation processes.

12. Account measures

12.1 Content moderation and user account

A moderation decision concerning an individual item of User Content does not automatically result in a warning, restriction, suspension, deactivation or termination of the associated user account.

The currently implemented content-related moderation procedures and measures are described in particular in Sections 10 and 11. They must be distinguished from the technical administration of the user account, security measures and subscription- or entitlement-related access decisions.

12.2 Security and access measures

Independently of content moderation, SIMINEO may apply technically necessary security or access measures insofar as these are required to protect the user account, for authentication, to enforce an actually existing access entitlement or for the secure operation of the Service, and are technically provided within the Service.

Such technical security or access measures do not, merely by being applied, constitute a moderation sanction relating to User Content.

12.3 No automated account sanction resulting from a report

Receipt of a community report or a formal notice of illegal content does not automatically result in suspension, deactivation or termination of the affected user account.

If separate account-related moderation measures are introduced in the future for certain types of violations, the contractual and legal rules provided and applicable at that time will apply. This Section does not establish any currently unimplemented automated account-sanction procedure.

12.4 Termination or deletion of the user account

Termination or deletion of a user account must be distinguished from a content-related moderation decision. Receipt of a report or the removal of an individual item of content does not automatically result in termination or deletion of the associated user account.

Full use of SIMINEO requires an active user account and a sufficient access entitlement at the relevant time. Such entitlement may arise in particular from an active subscription, the active launch free-access period or another internal entitlement granted by SIMINEO.

If a user account is terminated or deleted within the account deletion or termination process provided for this purpose, the associated internal access and subscription entitlements may be terminated and any existing internal subscription status may be processed accordingly.

If a Paddle subscription is connected to the terminated or deleted user account, SIMINEO may arrange for termination of the Paddle subscription on the basis of the available provider identifiers. Billing, payment and subscription-management processes carried out by Paddle itself are governed by Paddle’s applicable terms and technical procedures.

Data protection deletion and anonymisation processes, as well as any necessary limited further retention of individual moderation, security or evidentiary data, are governed by the Privacy Policy and the applicable legal provisions.

12.5 Special restriction or suspension of a Company account

Where a Company Profile is used as a business-user account within the meaning of Regulation (EU) 2019/1150 on fairness and transparency for business users of online intermediation services, and that Regulation applies to the relevant contractual relationship, the following additional rules apply to restrictions and suspensions.

SIMINEO may restrict or suspend, in whole or in part, the provision of the Service to a Company account where, in particular, there is a breach of these Terms and Conditions, unlawful activity, infringement of third-party rights, a security risk, fraud or other abuse, a legal or regulatory obligation, or another objectively justified reason.

Such restriction or suspension is not imposed automatically solely because a report or notice has been received. The decision is based on a review of the specific circumstances.

Before or at the latest at the time the restriction or suspension takes effect, the affected business receives a statement of reasons for the decision on a durable medium. To the extent legally permissible, the statement of reasons contains the specific facts and circumstances relevant to the decision, including, where relevant and legally permissible, the content of notifications from third parties, and the applicable contractual or legal basis.

Restriction or suspension of a Company account must be distinguished from final termination of the entire contractual relationship, deletion of the account, an individual content-moderation measure and termination of a subscription.

Where a restriction or suspension is revoked following a further review, SIMINEO restores the affected access without undue delay, provided that no other legal, security-related or technical restriction prevents restoration.

13. Moderation measures and legal consequences

13.1 Consequences of rule violations

If, within a review procedure provided for this purpose, it is established that User Content violates these Terms and Conditions or applicable legal provisions, SIMINEO may apply the content-related moderation measure technically provided for the relevant content and described in these Terms and Conditions.

A content-related moderation decision does not automatically result in an account-related sanction, a change to a subscription status or deletion under data protection law.

13.2 Content-related measures

The currently implemented content-related moderation measures consist in particular of restricting the visibility or administratively removing published Posts, as well as removing Company NOW content within the moderation procedures provided for this purpose.

Such a measure initially concerns the availability or visibility of the specific content. It must be distinguished from subsequent technical deletion or anonymisation in accordance with the applicable retention and data protection rules.

Receipt of a community report or a formal notice of illegal content does not in itself result in automatic removal. A decision on any measure is made after reviewing the relevant circumstances.

13.3 User account, security and access

Content-related moderation, technical account administration, security measures, authentication and subscription- or entitlement-related access decisions are separate processes.

A report or an individual content-related moderation decision does not establish any automatically operating procedure for suspending, deactivating or terminating the user account.

Technically provided security, authentication or access measures may be applied independently in accordance with Section 12.2.

13.4 Subscription-related measures

An active subscription entitlement may be a condition for certain functions or for full use of SIMINEO. The Provider is entitled to make access to the Service dependent on the subscription, the entitlement status and SIMINEO’s internal entitlement status.

Subscription-related measures may in particular include directing the User to the activation process, refusing access to protected functions, restricting access in connection with termination or expiry of the subscription, handling the canceling status, reactivating the subscription or treating the subscription as deleted.

The “inactive” status is to be understood solely as a derived access status and does not constitute a separate internal subscription lifecycle status. The internal subscription lifecycle, access entitlement, Paddle provider records and the status of the user account are separate concepts.

13.5 Basis of content-related moderation decisions

In a content-related moderation decision, the specific individual case is reviewed on the basis of the information available within the relevant procedure.

Relevant factors may include in particular the affected content, the information contained in a report or notice, available evidence, the applicable provisions of these Terms and Conditions and applicable legal provisions.

A measure is applied only within the moderation procedure technically provided and actually available for the relevant content.

13.6 Documentation and notification of moderation decisions

SIMINEO may document moderation decisions and the decision-related and evidentiary data required for them within the provided internal administrative and evidentiary processes.

For formal notices of illegal content under Article 16 DSA, the decision in the currently implemented procedure is made following human administrative review. Where legally required and provided for in the relevant procedure, the decision is explained or communicated to the affected persons together with the information provided for this purpose.

Retention and subsequent deletion or anonymisation of the personal data processed in this context are governed by the Privacy Policy and the applicable legal provisions.

13.7 Diligent, objective and proportionate application of restrictions

Where SIMINEO applies and enforces restrictions in relation to information provided by users, it does so in a diligent, objective and proportionate manner, with due regard to the rights and legitimate interests of all parties involved.

In doing so, where relevant in the specific case, SIMINEO takes into account the fundamental rights of the persons concerned, including freedom of expression and information, the freedom and pluralism of the media, and other rights and freedoms enshrined in the Charter of Fundamental Rights of the European Union.

14. Operation of the service

14.1 Maintenance

The Provider is entitled to carry out maintenance, security, monitoring, clean-up, update and operational activities necessary for the operation of the Service.

Maintenance may in particular affect system availability, the operation of certain functions, technical processing of uploaded files, handling of temporary or faulty files, and the operation of logging, monitoring and security systems.

14.2 Temporary service outage

The operation of the Service may be temporarily affected by maintenance, technical error, security measure, moderation or operational measure, infrastructure problem, disruption of a third-party service or other operational circumstance.

The Provider endeavours to maintain the proper operation of the Service, but does not guarantee uninterrupted or error-free availability.

A temporary service outage or operational disruption is not the same as permanent termination of the Service.

14.3 Modification of the service

The Provider is entitled to modify the operation, structure, functions, technical solutions, security or moderation processes of the Service where this is justified for the development, security, lawful operation, operation or proper use of the Service.

The modification may in particular affect available functions, the user interface, content management processes, access rules, subscription-based or entitlement-based access, and operational and monitoring systems.

14.4 Introduction of new functions

The Provider is entitled to introduce new functions, technical solutions, security or moderation tools, and service elements subject to subscription or entitlement.

New functions may be introduced gradually, on a test basis, for a defined group of users or subject to operational conditions.

14.5 Discontinuation of functions

The Provider is entitled to modify, restrict or discontinue certain functions, service elements or technical solutions if justified by operational, security, legal, technical, economic or service development reasons.

Discontinuation of a function does not automatically mean termination of the User account, termination of the subscription relationship or permanent termination of the entire Service.

14.6 Permanent termination of the service

The Provider is entitled to permanently terminate the entire Service if justified by business, technical, legal, security, operational or other material reasons.

Permanent termination of the Service is separate from temporary service outage, maintenance, moderation measure, content visibility restriction and discontinuation of individual functions.

In the event of permanent termination of the Service, the Provider acts taking into account the applicable laws, the conditions governing the subscription relationship and the data protection rules.

15. Electronic communication and notifications

15.1 Electronic communication

The User accepts that the Provider conducts communication related to the operation of the Service electronically.

Electronic communication may take place in particular by email, on the User account interface, on certain user interfaces of the Service, on a status page, in system messages or in other forms of electronic communication.

The User is obliged to provide and maintain an email address through which communication relating to the Service can be received.

15.2 Service notifications

The Provider is entitled to send or display service notifications necessary for the operation of the Service electronically.

Service notifications may relate in particular to:

• registration;
• email address verification;
• password reset;
• Recovery Code management;
• email address change;
• security of the User account;
• subscription;
• account deletion;
• and other events necessary for the operation of the Service.

Such notifications are connected to the operation of the Service and do not constitute marketing communications.

15.3 Moderation- and security-related notifications

SIMINEO may send electronic communications concerning moderation decisions and security- or account-related processes within the respective implemented procedures.

For formal notices of illegal content under Article 16 DSA, the reporting person or entity receives, within the procedure provided for this purpose and after completion of the decision, an electronic notification of the decision where electronic contact details are available for this purpose.

Where SIMINEO, within an implemented moderation procedure, restricts or removes a specifically identified Post, Company NOW item or Private Search entry, or restricts access to a Company Profile on the basis of a formal decision, the affected responsible person is notified, within the implemented procedure provided for this purpose, of the decision and of the reasons and information provided for this purpose.

The foregoing notifications are based on the relevant moderation procedure and do not mean that a content-related decision automatically results in an account-related sanction.

In the case of a restriction or suspension of a Company account under Section 12.5, or termination under Section 17.2, any statement of reasons required by law or contract may in particular be provided by email to the electronic contact address registered for the Company account. The communication is provided in a form that enables the recipient to store it and reproduce it unchanged for an adequate period.

The technical sending of an electronic message, or its application-side recording as sent, does not constitute a guarantee that the message was actually delivered to or read by the recipient.

Communications concerning the Recovery Code, a change of email address or proof of account ownership are security-relevant. The User is obliged to keep this information confidential.

15.4 Subscription-related notifications

The Provider is entitled to send or display electronic notifications relating to the subscription and access entitlement.

Subscription-related notifications may relate in particular to:

• activation of the subscription;
• the activation process;
• entitlement status;
• termination of the subscription;
• canceling status;
• reactivation of the subscription;
• billing-related events;
• and use of the Paddle customer portal.

Billing, payment or subscription-management communication provided by Paddle takes place in Paddle’s own systems and is governed by Paddle’s own contractual terms and data processing rules.

SIMINEO’s internal subscription entitlement status, Paddle provider records and the status of the User account are separate concepts.

16. Liability

16.1 Liability of the Provider

The Provider operates the Service taking into account the available technical, security and operational possibilities, and endeavours to ensure its proper, secure and reliable operation.

The Provider is entitled to apply security, maintenance, monitoring, moderation and other operational measures necessary for the operation of the Service.

The Provider is liable for the provision of the Service within the limits permitted by law; however, these Terms and Conditions do not contain any guarantee of uninterrupted, continuous or error-free operation.

16.2 Liability of the User

The User is responsible for lawful use of the Service, compliance with these Terms and Conditions, and all User Content published, uploaded, transmitted or otherwise made available by them.

The User must ensure that their activities and the content published by them do not violate the law, the rights of third parties or the provisions of these Terms and Conditions.

Technical checking, processing, conversion, moderation, restriction, removal or other operational handling of uploaded content does not affect the User’s responsibility for their own content.

16.3 Third-party services

During the operation of the Service, the Provider may also use services provided by third parties for the performance of certain tasks.

This may include in particular hosting and infrastructure services, electronic mail infrastructure, payment and subscription-management services, and other external services necessary for the operation of the Service.

The operation, availability or failure of services provided by third parties may also affect certain functions of the Service.

The operation of payment, billing, subscription-management and customer portal services provided by Paddle is governed by Paddle’s own contractual terms and policies.

16.4 Limitation of liability

Within the limits permitted by law, the Provider does not guarantee uninterrupted availability of the Service, error-free operation or continuous availability of all functions.

The Provider does not guarantee that all uploaded content will remain available or recoverable in unchanged form for an unlimited period.

Maintenance, security measures, moderation procedures, operational processes, infrastructure problems or disruption of a third-party service may temporarily affect the operation of the Service.

A temporary operational disruption or service outage does not in itself mean permanent termination of the Service.

16.5 Force majeure

The Provider is not liable for the consequences of unavoidable external events that fall outside its operational control and partially or fully prevent the provision of the Service.

Such events may include in particular natural disasters, war, terrorist acts, epidemics, authority measures, power supply or electronic communications disruptions, cyberattacks, and significant operational failures affecting the infrastructure or service of a third party.

During the existence of force majeure, the Provider endeavours, to the extent possible, to restore the Service and continue operation.

17. Termination of the contract

17.1 Termination by the User

The User is entitled to initiate termination or deletion of their User account on the interface provided for this purpose by the Service or in another manner provided by the Provider.

Initiation of account deletion may be subject to a security check, in particular entry of the current password.

During account deletion, the Provider deactivates the User account, terminates active sessions connected to the account, and carries out data processing and technical operations related to account deletion.

17.2 Termination by the Provider

SIMINEO may terminate the contractual relationship associated with a user account in accordance with the applicable legal provisions and the contractual provisions of these Terms and Conditions where the necessary conditions for such termination are met.

An individual community report, a formal notice of illegal content or an individual content-related moderation decision does not automatically result in termination of the contractual relationship or the user account.

If a contractual relationship is actually terminated and the technical termination process provided for this purpose is carried out, this may result in loss of access and of the internal access or subscription entitlements associated with the user account.

Termination of the contractual relationship must be distinguished from a content-related moderation decision, termination of a subscription and data protection deletion or anonymisation processes.

17.2.1 Termination of the entire service relationship with a Company account

Where Regulation (EU) 2019/1150 applies to the contractual relationship with a Company account and SIMINEO intends to terminate the provision of its online intermediation services in their entirety to that business, the affected business will, as a general rule, receive a statement of reasons for the decision on a durable medium at least 30 days before the termination takes effect.

To the extent legally permissible, the statement of reasons contains the specific facts and circumstances relevant to the decision, including, where relevant and legally permissible, the content of notifications from third parties, and the applicable grounds under these Terms and Conditions or applicable law.

Full termination by SIMINEO takes place exclusively through a termination process provided for this purpose. General administrative account deletion does not replace this process.

17.2.2 Exceptions to the 30-day notice period

The period under Section 17.2.1 does not apply where SIMINEO is subject to a legal or regulatory obligation requiring it to terminate the entire service in a manner that does not allow compliance with that period; where an imperative reason for termination exists under applicable national law that is consistent with Union law; or where SIMINEO can demonstrate that the affected business has repeatedly infringed the applicable Terms and Conditions and this results in termination of the entire Service.

Where the 30-day period does not apply because of a legally provided exception, the statement of reasons for the decision is provided on a durable medium without undue delay, insofar as disclosure of the relevant information is legally permitted.

The statement of reasons may be omitted or limited in content to the extent that SIMINEO is prohibited by a legal or regulatory obligation from communicating specific facts, circumstances or grounds. A statement of reasons may also be omitted where SIMINEO can demonstrate that the affected business has repeatedly infringed the applicable Terms and Conditions and this results in termination of the entire Service, to the extent permitted by Article 4(5) of Regulation (EU) 2019/1150.

17.3 Effects of termination of the subscription

An active subscription entitlement may be required for certain functions or for full use of SIMINEO.

Cancellation, expiry, the “canceling” status, the “deleted” status or the absence of an active access entitlement may result in restriction of access to the Service.

The “canceling” status may allow access until the end of the respective subscription period where this is provided for by the internal subscription status and provider-side subscription management.

The “inactive” status is to be understood solely as a derived access status and does not constitute a separate internal subscription lifecycle status.

Cancellation of the subscription, expiry of the access entitlement, scheduled deletion, the status of a deleted subscription and deletion of the user account are separate processes.

17.4 Deletion and anonymisation of personal data

Deletion or termination of a user account and the deletion or anonymisation of personal data under data protection law are distinct technical and legal processes. Details of the processing are governed by SIMINEO’s Privacy Policy and the applicable data protection provisions.

Within an account deletion process provided for this purpose, active sessions may be terminated and data associated with the account may be processed in accordance with the applicable deletion and anonymisation rules.

Account deletion may affect in particular contact details, content created by the User, media files, profile data, follow and like relationships and local subscription-related records.

If a Paddle subscription is associated with the account and the necessary provider identifiers are available, SIMINEO may arrange for termination of the associated Paddle subscription and process the internal subscription status accordingly.

Account deletion or deletion under data protection law does not mean that all data are immediately removed from all storage layers regardless of their purpose and legal basis. Where individual data remain necessary for legal, accounting, security, moderation, evidentiary or other permitted purposes, they may continue to be processed solely for the limited retention periods applicable to those purposes and subsequently be handled in accordance with the applicable deletion or anonymisation rules.

17.5 Legal consequences of termination

Termination of the contractual relationship, the user account or the subscription entitlement may result in partial or complete termination of access to the Service.

Termination does not affect those obligations and provisions which, by their nature or by operation of law, continue to apply after termination, in particular in connection with liability, intellectual property, data protection, payments, accounting, security and necessary evidentiary documentation.

Backups, archive files, audit logs, subscription event logs and billing- or provider-side records may be subject to different, individually limited retention and deletion cycles. Details are governed by the Privacy Policy, the applicable legal provisions and the respective relevant technical retention rules.

The handling of historical data or backups must not result in reactivation of a deleted or anonymised user account, restoration of a usable access status or reversal of completed data protection deletion or anonymisation.

17.6 Data access for Company accounts under the P2B Regulation

Where Regulation (EU) 2019/1150 applies to the contractual relationship with a Company account, the following additional rules apply to access to personal and other data.

17.6.1 SIMINEO's access to Company-related data

As part of the technical operation and administration of the Service, SIMINEO has access to data provided by a Company User for use of the Service and data generated through use of the Service, insofar as such access is necessary for providing and administering the Service, security, moderation, billing or entitlement management, enforcement of rights, or compliance with legal obligations.

The relevant categories of data may include in particular:

• account and identification data, including internal and public account identifiers, username, email address, profile type, registration and account status, and verification status;
• Company profile and business data, including company name, address, telephone number, city, postal code, country, company description, business type, public profile identifier or profile URL, and location data required for location-based functions;
• content provided or published by the Company account and related technical metadata, including Posts, images, Company NOW content and other information published through the functions provided for that purpose;
• technical data concerning account access and entitlement status and subscription-related technical data, including provider, plan, subscription status, period or term information and technical provider identifiers, insofar as such information is available to SIMINEO for entitlement or subscription management;
• data generated through use of platform functions insofar as technically processed for the relevant function, including interaction, reach, search, Radar, Follow, Like or comparable functional data in the form currently implemented;
• moderation, reporting, restriction, security, support, audit and evidentiary data insofar as they relate to a Company account or its content and are necessary for handling the relevant matter.

Access is not unrestricted. Within SIMINEO, Company-related data are used only through the technical or administrative functions provided for the relevant purpose and only to the extent necessary for that purpose. Protected administrative and moderation functions are limited to authorised administrative access.

Where data are processed exclusively by an external service provider and are not received by SIMINEO, SIMINEO has no corresponding direct access to those data. This applies in particular to full payment-card details and other payment data processed exclusively by Paddle. SIMINEO may nevertheless process technical subscription and provider information supplied by Paddle where required for entitlement, subscription and evidentiary management.

The detailed purposes, legal bases, recipients and retention periods applicable to personal data are additionally governed by SIMINEO's Privacy Policy and the applicable data protection laws.

17.6.2 Company User access to own and service-generated data

Through the authenticated functions provided for this purpose, the Company User has access to certain data that the Company User has provided in connection with the use of SIMINEO and to certain data generated through provision of the Service to that Company account and in connection with its profile and content.

Under the functions currently provided, these include in particular:

• the Company User's own account and Company profile data, including username, email address and the business, contact, description, type, profile-image and other profile information provided or displayed through the relevant profile functions;
• the Company User's own published Posts, including related content, publication, processing and moderation-status data and the aggregated Like and share counts made available for the relevant Post;
• the Company User's own active Company NOW, including its text, creation and expiry times and the currently selected public-visibility setting;
• information concerning the Company User's own access, entitlement and subscription status, including provider, plan, subscription status, current period end, any scheduled termination time and information concerning any applicable free-access period;
• aggregated activity and performance information assigned to the relevant Company account where SIMINEO provides a corresponding function. This includes in particular follower count, aggregated information concerning Follow, Like, share and content activity, and the reach and interaction metrics made available through the Company Performance function.

Through these functions, the Company User does not as a general rule receive the identity of individual users merely because they follow the Company profile, Like or share a Post, view it or otherwise interact with the profile or its content. Such information is made available to the Company User only in the aggregated or statistical form implemented for the relevant function, unless a separate specific function expressly provides otherwise.

Access is limited to the functions and interfaces made available by SIMINEO and to the data categories available through them. It does not provide access to internal administrative, security, audit, moderation or backend data, full payment data, or other technical information that is not made available to the Company account.

17.6.3 Company statistics and performance information

Under the functions currently provided, SIMINEO makes aggregated statistics concerning the use and performance of the Company User's own SIMINEO presence available to an authenticated Company account. Within the Company Performance function, the Company User may select an evaluation period of 7 or 30 days.

For the selected period, the following metrics are currently displayed in aggregated form:

• profile views;
• Post views;
• new Follows;
• Likes;
• shares;
• telephone clicks or call starts;
• map clicks or directions starts.

The values for the selected period are compared with the immediately preceding period of the same length. Where mathematically meaningful, the percentage change compared with that preceding period may also be displayed for each metric. If the preceding value is zero and the current value is positive, no percentage change is displayed.

Separately from the periodic Company Performance evaluation, the Company account may also access its current number of active and verified followers and aggregated information concerning certain activities not yet marked as read. Such activity information may include gained and lost Follows, added and removed Likes, shares, the hiding of a Post, and corresponding Post-level summaries. This activity function is a separate operational function and is not the same as the periodic Company Performance evaluation.

Statistics and activity values made available to the Company account relate exclusively to its own SIMINEO presence and are provided in aggregated form. In the statistical events stored for Company Performance purposes, SIMINEO does not store the identity of the user or visitor who caused the relevant interaction. Where technically necessary, an existing account association may be taken into account before the event is stored, in particular to exclude a Company account's own interactions from its own performance statistics; such a user identifier does not become part of the stored statistical event.

The Company statistics function does not provide access to the underlying individual statistical events or to the identities of individual visitors or interacting users. Detailed rules concerning the processing and retention of the data used for these purposes are additionally governed by SIMINEO's Privacy Policy.

17.6.4 Access to aggregated and platform-wide data

Under the functions currently provided, the Company User does not receive access to data sets or statistics derived from data relating to all or multiple Company Users, Private Users or other users of the Service where those data enable platform-wide or cross-business analysis.

This also applies to platform-wide aggregated statistical data. SIMINEO may generate and retain aggregated platform-wide daily values for the internal long-term assessment of the development, use, reach and operation of the Service. Under the current technical implementation, such platform-wide aggregates contain no user, Company or Post identifier and are not made available to Company Users through a Company function or Company interface.

Accordingly, the Company User does not in particular receive access to:

• platform-wide aggregated reach, usage or performance statistics;
• cross-business comparison or benchmarking data;
• aggregated performance data relating to other Company accounts;
• non-public data relating to other Company Users or Private Users.

This does not affect the data and aggregated statistics described in Sections 17.6.2 and 17.6.3 that relate exclusively to the Company User's own Company account or its own SIMINEO presence.

If SIMINEO in the future provides Company Users with access to platform-wide, cross-business or other aggregates derived from data relating to multiple users or Company accounts, the relevant data categories and conditions of access will be described in the terms applicable at that time.

17.6.5 Data access after termination of the Company account

Following the effective termination and deletion of the Company account, the former Company User has no continuing access to the former Company account, its Company Profile, Posts, Company NOW content, Company statistics, activity information or other data and functions made available only through the authenticated Company account.

When the account is deleted, the authentication and access mechanisms required for continued use of the account are invalidated. Under the current technical procedure, access is in particular deactivated, existing sessions are invalidated by changing the token version, and the previous account identifiers are anonymized or replaced with values that can no longer be used for account access.

Operational data linked to the Company account are deleted or anonymized in accordance with the rules applicable to the relevant function. Under the current technical implementation, this includes in particular the Company Profile, the Company's own Posts and associated uploaded files, Company NOW content, Company-related raw and daily statistics, Follows, the Company's own saved search-related data and other account-related operational data.

Independently of this, SIMINEO may continue to retain certain limited data or evidence after termination of the Company account where a separate legal, billing, security, moderation, DSA, audit or evidentiary retention basis applies. This may include in particular limited billing and subscription evidence, moderation and procedural evidence, audit information or other evidence subject to its own retention period. The continued retention of such data after termination of the account does not constitute continuing access for the former Company User through a Company account or Company interface.

Detailed rules concerning the deletion, anonymization and retention of personal data are additionally governed by SIMINEO's Privacy Policy and applicable statutory retention requirements.

18. Data protection

18.1 Privacy Policy

The Provider publishes the detailed rules relating to the processing of the User’s personal data in a separate Privacy Policy.

The Privacy Policy defines in particular the purpose, legal basis, scope and duration of personal data processing, the recipients of the data, the rights of data subjects, security measures, and other essential information relating to data processing.

By creating a User account, the User declares that they have read the Privacy Policy and acknowledge that their personal data are processed in accordance with its provisions.

If there is any discrepancy between these Terms and Conditions and the Privacy Policy regarding rules relating to the processing of personal data, the provisions of the Privacy Policy prevail in data processing matters.

18.2 Cookies and browser-side storage technologies

SIMINEO currently uses technical First-Party cookies that are necessary in particular for login, the management of User sessions, CSRF protection, the protection of administrative access and the secure operation of the Service.

In addition, SIMINEO uses browser-side storage technologies such as localStorage and sessionStorage to a limited extent. These are used in particular for functional settings, language and display, navigation and return within the Service, technical synchronisation of authentication status between browser tabs, and temporary technical processes such as the administrative two-factor login procedure. The authentication JWT is not stored in localStorage or sessionStorage.

According to the current technical status, SIMINEO does not use marketing, advertising or tracking cookies or corresponding browser-side storage identifiers for such purposes.

Details of the cookies and browser-side storage technologies used, in particular their purpose, functionality and storage duration, are set out in SIMINEO’s Privacy Policy and the applicable Cookie Policy.

If the Provider introduces cookies or other technologies in the future whose use requires the User’s consent under the applicable legal provisions, they may be used only in accordance with the applicable legal provisions.

19. Contact, complaints and customer support

19.1 Contact

The User may contact the Provider electronically in relation to the Service, the user account, subscription, technical operation or other service-related matters.

The Provider’s customer support email address is:

[email protected]

Requests relating to the processing of personal data, the exercise of data subject rights or data protection matters are governed by the provisions of SIMINEO’s Privacy Policy.

19.2 General complaints and service requests

SIMINEO reviews incoming general complaints, enquiries and service notices on the basis of their content, nature and the information available for their processing.

When submitting a complaint or enquiry, the User should provide the essential information required for its processing completely and truthfully.

Where necessary and permissible for the processing, relevant account, subscription, security, moderation or administrative information may in particular be taken into account.

The general contact and support option under this Section must be distinguished from the community reporting functions and from the formal notice-and-action mechanism for illegal content under Article 16 DSA.

This general support and complaint option does not in itself constitute a separate internal complaint-handling system within the meaning of Article 20 DSA.

A business affected by a restriction, suspension or termination may use [email protected] to explain the facts and circumstances relevant to the decision, provide supplementary information and request a further review of the measure. To the extent that additional requirements concerning an internal complaint-handling system under Regulation (EU) 2019/1150 apply to SIMINEO in the specific case, those requirements remain unaffected.

Where the relevant decision is revoked following further review, SIMINEO restores the affected access without undue delay unless another lawful restriction prevents restoration.

In the case of data protection complaints or the exercise of data subject rights, the contact and procedural options described in the Privacy Policy apply. Any statutory rights to contact a competent supervisory authority or other competent body remain unaffected.

20. Consumer protection provisions

20.1 Information on digital services

SIMINEO provides digital services under the conditions defined in these Terms and Conditions, the Privacy Policy and the applicable laws.

The Provider endeavours to provide clear, transparent and understandable information regarding the operation of the Service, subscription conditions, use of the service and essential information affecting the User’s rights.

For consumer contracts concerning digital products, where applicable, Sections 327 et seq. of the German Civil Code (BGB) apply in particular. SIMINEO provides the agreed digital service in conformity with the applicable statutory requirements during the relevant period of supply.

Where required by law, SIMINEO provides during the relevant period the updates, including security updates, necessary to maintain conformity of the digital service and informs the consumer accordingly.

If the digital service is not in conformity with the contract, the consumer is entitled to the statutory remedies for defects. Subject to the applicable statutory requirements, these include in particular bringing the service into conformity as well as termination of the contract, price reduction and damages. Mandatory statutory consumer rights are not restricted by these Terms and Conditions.

Changes to a digital service supplied on a continuous basis are made only within the limits of the applicable statutory requirements.

20.2 Right of withdrawal (where applicable)

Where the User has a right of withdrawal or termination under law, the exercise of such right is governed by the applicable legal provisions.

Where, based on the commencement or nature of the provision of the digital service, the right of withdrawal cannot be exercised under law, or the User makes a declaration in accordance with the applicable laws, the restriction or exclusion of the right of withdrawal may take place in accordance with the applicable laws.

These Terms and Conditions do not intend to restrict or exclude statutory rights granted to consumers.

21. Applicable law and dispute resolution

21.1 Applicable law

These Terms and Conditions and the legal relationship established between the Provider and the User are governed by the law of the Federal Republic of Germany, unless mandatory legal provisions provide otherwise.

These Terms and Conditions do not restrict the application of mandatory legal provisions protecting consumers.

21.2 Jurisdiction

The parties endeavour to resolve any disputes that may arise primarily amicably, by consultation.

If the dispute between the parties cannot be resolved, the jurisdiction and competence of the acting court are determined by the laws in force at any given time.

21.3 Alternative dispute resolution

Where permitted or required by the applicable laws, the consumer is also entitled to use alternative dispute resolution options.

These Terms and Conditions may not be interpreted as meaning that the Provider operates its own alternative dispute resolution system or provides a dispute resolution forum different from the procedures defined by law.

22. Final provisions

22.1 Partial invalidity (severability clause)

If any provision of these Terms and Conditions proves to be partially or wholly invalid, unenforceable or inapplicable, this does not affect the validity or applicability of the other provisions of these Terms and Conditions.

The invalid or inapplicable provision shall, where necessary, be replaced by a provision that comes as close as possible to its economic and legal purpose within the framework of the applicable laws.

22.2 Authoritative language version

The authoritative language version of these Terms and Conditions is the German version.

The Provider may also publish these Terms and Conditions in other languages. In the event of any discrepancy or difference in interpretation between the language versions, the German version shall prevail, unless mandatory legal provisions require otherwise.

22.3 Entry into force and version

Version of these Terms and Conditions: 2026-10-16.1. This version applies from 28 September 2026.

The Provider is entitled to amend these Terms and Conditions in accordance with the applicable laws. The Provider ensures the entry into force and publication of amendments in accordance with the applicable laws.

23. Official external references

The following links point to the websites of official organisations, service providers or legal sources referred to in these Terms and Conditions.

• Paddle – Terms
• Paddle – Privacy Notice
• GDPR – Regulation (EU) 2016/679
• European Commission – Consumer complaint resolution
• LfDI Baden-Württemberg
• Federal Central Tax Office – VAT identification number