Terms of Service

Last updated: July 3, 2026

1. Agreement

These Terms of Service ("Terms", "Regulamin") govern your use of EduPilot, a service provided by Aiventor Sp. z o.o. In these Terms, "EduPilot", "the Platform", "we", "us", and "our" mean:

• Aiventor Sp. z o.o., al. Solidarności 117-615, 00-140 Warszawa, Poland
• NIP: 7252347037 | REGON: 529689160 | KRS: 0001128173
• Share capital: 2500 PLN (fully paid up)
• Contact: admin@aiventor.eu

By creating an account or using EduPilot, you agree to these Terms. These Terms are made available in a form that allows storage and reproduction before concluding the contract, in accordance with Art. 8 of the Polish Act on Provision of Electronic Services (Ustawa o świadczeniu usług drogą elektroniczną).

1a. Additional Terms

The following documents supplement these Terms and prevail over them for their subject matter:

• Marketplace Creator Terms — publishing and selling Courses on the Marketplace
• Marketplace Purchase & Enrollment Terms — buying and enrolling in Courses
• Credit Policy — Credits for AI generation features
• Community Guidelines & Content Policy — content and conduct rules
• Privacy Policy and Cookie Policy — data and cookies
• Data Processing Agreement (DPA) — for schools, organisations, and educators processing learner data

2. Service Description (Art. 8.1 Ustawa o świadczeniu usług drogą elektroniczną)

EduPilot is an AI-powered platform that helps educators create, edit, manage, and sell educational courses, and helps learners study them. Services provided electronically include:

1. Course Generation — AI-assisted creation of complete courses and lessons from user instructions
2. Content Editing — AI-assisted editing, restructuring, and improvement of educational materials
3. Assessment Creation — Generation of quizzes, tests, and learning activities
4. Course Marketplace — a catalogue where Creators publish Courses and users browse, enroll in, and purchase them
5. Learner Account — a study space with course access, progress tracking, and an AI tutor (the tutor is an AI system and is identified as such in the interface)
6. Student View & Sharing — sharing created courses with students via link
7. Dashboard — overview of created courses and analytics

Technical Requirements

To use EduPilot, you need:

• Web browser: Chrome 90+, Firefox 90+, Safari 14+, Edge 90+ (latest versions recommended)
• Internet connection (minimum 5 Mbps)
• JavaScript enabled
• Cookies enabled (essential cookies required)
• Screen resolution: minimum 1024x768

3. Account Registration

• You must provide accurate information when creating an account
• You are responsible for maintaining the security of your account credentials
• You must be at least 16 years old to create an account (in accordance with the Polish age of consent for data processing). Users under 16 may use the service only with verified parental or guardian consent
• One person or organization may not maintain more than one free account
• Depending on how you use the Platform, you may act as an educator, a Creator (seller on the Marketplace), a Learner, or an organisation; role-specific rules are set out in the Additional Terms (Section 1a)

4. Acceptable Use

You agree to:

• Use EduPilot only for lawful educational purposes
• Not upload content that is illegal, harmful, or violates third-party rights
• Not attempt to reverse-engineer, hack, or disrupt the service
• Not use the service to generate content that promotes violence, discrimination, or harm
• Not resell or redistribute the service without our written consent
• Comply with all applicable laws, these Terms, and the Community Guidelines & Content Policy

5. Content Ownership

Your Content

• You retain full ownership of all content you create using EduPilot (courses, lessons, assessments, materials)
• You grant us a limited license to host, display, and process your content solely to provide the service
• This license terminates when you delete your content or close your account
• Additional licences for Courses published on the Marketplace (including licences to enrolled Learners) are set out in the Marketplace Creator Terms

AI-Generated Content

• Content generated by AI through EduPilot is provided to you for your use
• You are responsible for reviewing, editing, and validating AI-generated content before using it with students
• We do not guarantee the accuracy, completeness, or appropriateness of AI-generated content
• You should not rely on AI-generated content without professional review

Our Content

• EduPilot's interface, branding, documentation, and underlying technology remain our property
• These Terms do not grant you any rights to our intellectual property beyond using the service

6. AI Disclaimer

EduPilot uses artificial intelligence to assist in content creation and learning. Important:

• AI is a tool, not a replacement for professional judgment. You are responsible for reviewing all generated content
• AI may produce inaccurate, incomplete, or inappropriate content ("hallucinations"). Always verify before use
• AI-generated content should be adapted to your specific educational context, curriculum standards, and student needs
• The AI tutor supports learning; it does not set final grades or make final academic decisions — educators do
• We continuously improve our AI systems, but we cannot guarantee error-free output

See also our AI Transparency Notice.

7. Data and Privacy

Your use of EduPilot is also governed by our Privacy Policy. Key points:

• We do not use your data or content to train AI models
• We process data in accordance with GDPR and applicable privacy laws
• Schools, organisations, and educators inviting learners act as data controllers and accept our Data Processing Agreement (DPA) before processing student data

8. Service Availability

• We strive to maintain high availability but do not guarantee uninterrupted service
• We may perform maintenance with reasonable advance notice
• We reserve the right to modify, suspend, or discontinue features with notice

9. Payment Terms

• Free tier: subject to usage limits as described on our pricing page
• Paid plans: billed monthly or annually as selected
• All fees are exclusive of applicable taxes (VAT will be added where applicable); consumer-facing prices are displayed inclusive of VAT
• Price changes: We will notify you at least 30 days in advance of any price changes. You have the right to terminate your subscription without penalty if you do not accept the new pricing. Continued use after the change takes effect constitutes acceptance of the new price

Credits, Wallet, and Crystals

• Credits are a unit of account for AI generation features, governed by the Credit Policy. Credits are not money and have no cash value
• Wallet is a prepaid balance for Marketplace purchases, governed by the Marketplace Purchase & Enrollment Terms
• Crystals are earned through study only, cannot be purchased, have no monetary value, and are spent on optional perks. Nothing on the Platform — Credits, Wallet funds, or Crystals — can buy grades, certificates, or course completions

9a. Right of Withdrawal (Prawo odstąpienia od umowy)

If you are a consumer in the EU/EEA, you have the right to withdraw from this contract within 14 days without giving any reason. The withdrawal period expires 14 days after the day of the conclusion of the contract.

To exercise the right of withdrawal, you must inform us of your decision by an unequivocal statement (e.g., email to admin@aiventor.eu).

Model withdrawal form:

To: Aiventor Sp. z o.o., admin@aiventor.eu I hereby give notice that I withdraw from my contract for the provision of EduPilot service. Ordered on / received on: [date] Name: [your name] Address: [your address] Date: [date] Signature (only if sent on paper): ___________

Effects of withdrawal: We will reimburse all payments received from you no later than 14 days from the day on which we receive your withdrawal notice, using the same means of payment.

Exception for digital services: If you expressly requested that the service begins before the expiration of the 14-day withdrawal period, and you acknowledged losing your right of withdrawal once the service has been fully performed, the withdrawal right may be limited proportionally to the service already provided.

9b. Complaints Procedure (Reklamacja)

In accordance with Art. 8 of the Polish Act on Provision of Electronic Services:

1. How to file a complaint: Send an email to admin@aiventor.eu with a description of the issue, your account information, and the desired resolution
2. Response time: We will respond to your complaint within 30 days of receipt
3. Resolution: We will inform you of our decision and proposed resolution in writing (email)
4. If unsatisfied: You may pursue out-of-court dispute resolution through the European Commission's ODR platform at ec.europa.eu/consumers/odr, or through the relevant Polish voivodeship inspector of trade inspection (Wojewódzki Inspektor Inspekcji Handlowej)

10. Limitation of Liability

To the maximum extent permitted by law:

• Our total liability is limited to the amount you paid us in the 12 months preceding the claim
• We are not liable for indirect, incidental, consequential, or punitive damages
• We are not liable for losses resulting from your reliance on AI-generated content without review
• We are not liable for third-party actions or service interruptions beyond our control

11. Termination

• You may close your account at any time by contacting admin@aiventor.eu
• We may suspend or terminate accounts that violate these Terms or the Community Guidelines & Content Policy
• Upon termination, your content will be available for export for 30 days, then deleted

12. Changes to Terms

We may update these Terms to reflect changes in law, our services, or business practices. For material changes:

• We will notify you at least 14 days in advance via email and/or in-app notification
• We will clearly describe what is changing and why
• You have the right to terminate your account without penalty if you do not accept the changes, by notifying us before the changes take effect
• If you continue to use the service after changes take effect, this constitutes acceptance of the updated Terms

We will not make changes that are unfair or disproportionate to consumers (in accordance with the prohibition of unfair contractual terms under Polish law and Directive 93/13/EEC).

13. Governing Law and Disputes

These Terms are governed by the laws of Poland.

For consumers: Disputes may be resolved by the court competent for your place of residence (in accordance with Polish consumer protection law). Nothing in these Terms limits your statutory consumer rights. You may also use the EU Online Dispute Resolution platform: ec.europa.eu/consumers/odr.

For business users: Disputes shall be resolved by the courts of Warsaw, Poland.

13a. Prohibited Content

In accordance with Art. 8 of the Polish Act on Provision of Electronic Services, the User is prohibited from providing unlawful content (treści o charakterze bezprawnym), including content that:

• Infringes third-party intellectual property rights
• Contains personal data of third parties without their consent
• Promotes violence, discrimination, or illegal activities
• Contains malware or malicious code

Detailed content and conduct rules, including the enforcement procedure, are set out in the Community Guidelines & Content Policy.

14. Contact

EduPilot (Aiventor Sp. z o.o.) Email: admin@aiventor.eu

Privacy Policy

Last updated: July 3, 2026

1. Who We Are

EduPilot ("EduPilot", "the Platform", "we", "us") is a service provided by Aiventor Sp. z o.o.

• Registered office: al. Solidarności 117-615, 00-140 Warszawa, Poland
• NIP: 7252347037
• REGON: 529689160
• KRS: 0001128173
• Share capital:2500 PLN (fully paid up)
• Registered with: Sąd Rejonowy dla m.st. Warszawy w Warszawie, Wydział Gospodarczy KRS

For any privacy-related inquiries, contact us at: admin@aiventor.eu

2. What Data We Collect

When you use EduPilot, we may collect:

We do not collect sensitive personal data (health, religion, ethnicity, biometrics) unless explicitly provided by you in your educational content.

3. How We Use Your Data

We use your data to:

• Provide and maintain EduPilot services
• Authenticate your account and ensure security
• Improve our product based on aggregated usage patterns
• Communicate service updates and respond to inquiries
• Comply with legal obligations

4. AI and Your Data

We do NOT use your data, your content, or your students' data to train AI models.

EduPilot uses third-party AI services (such as large language models) to generate educational content. When processing your requests:

• Your input is sent to AI providers solely to generate the requested output
• AI providers are contractually prohibited from using your data for model training
• Generated content belongs to you
• We do not store AI interaction logs beyond what is necessary to provide the service

5. Legal Basis for Processing (GDPR)

6. Data Sharing

We share your data only with:

• Cloud infrastructure providers (hosting, storage) — as data sub-processors
• AI service providers — for content generation only, under strict contractual terms
• Analytics tools — aggregated, anonymized data only
• Law enforcement — only when legally required

We do not sell your data to third parties.

7. Data Retention

• Account data: Retained while your account is active + 30 days after deletion request
• Content data: Retained while your account is active; deleted upon account closure
• Usage/technical data: Retained for up to 12 months, then anonymized or deleted

8. Your Rights (GDPR)

You have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data ("right to be forgotten")
• Restrict processing
• Data portability — receive your data in a structured format
• Object to processing based on legitimate interest
• Withdraw consent at any time (for consent-based processing)

To exercise any of these rights, email admin@aiventor.eu. We will respond within 30 days.

9. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encryption in transit (TLS) and at rest
• Access controls and authentication
• Regular security reviews
• Incident response procedures

10. International Transfers

Your data may be processed outside the EEA (e.g., by cloud or AI providers in the USA). In such cases, we ensure adequate safeguards through Standard Contractual Clauses (SCCs) or equivalent mechanisms.

11. Children's Data

EduPilot is a tool for educators, not for direct use by children.

Age of consent for data processing: In Poland, the age threshold for independent consent to data processing is 16 years (Art. 8 GDPR, maintained at 16 by the Polish Act of 10 May 2018 on Personal Data Protection). For users under 16, processing requires verifiable consent from a parent or legal guardian.

If a school uses EduPilot to create content for students under 16, the school is the data controller and is responsible for obtaining necessary parental consents. We process such data only as a data processor under the school's instructions and our Data Processing Agreement.

12. Cookies

We use essential cookies for authentication and session management. Analytics cookies are used only with your consent. See our Cookie Policy for details.

13. Changes to This Policy

We may update this policy from time to time. We will notify you of significant changes via email or in-app notification.

14. Contact

For any questions about this Privacy Policy or your data:

Aiventor Sp. z o.o. Email: admin@aiventor.eu

If you believe we have not adequately addressed your concern, you have the right to lodge a complaint with:

Urząd Ochrony Danych Osobowych (UODO) ul. Stawki 2, 00-193 Warszawa, Poland Website: uodo.gov.pl Phone: +48 22 531 03 00

Or with the supervisory authority in your country of residence.

Cookie Policy

Last updated: July 3, 2026

1. What Are Cookies

Cookies are small text files stored on your device when you visit a website. They help the site function properly, remember your preferences, and understand how you use the service.

2. How We Use Cookies

Essential Cookies (Always Active)

These cookies are necessary for EduPilot to function. They cannot be disabled.

Analytics Cookies (With Your Consent)

Analytics cookies help us improve the product. They are only set with your explicit consent. Data is aggregated and anonymized.

We Do NOT Use

• Advertising or tracking cookies
• Third-party social media cookies
• Cross-site tracking cookies

3. Legal Basis

Our use of cookies complies with:

• Regulation (EU) 2016/679 (GDPR) — for personal data processing through cookies
• Prawo komunikacji elektronicznej z 12 lipca 2024 r. (Polish Electronic Communications Law) — which requires prior explicit consent for all non-essential cookies

Essential cookies are placed based on legitimate interest (necessary for service operation). All other cookies require your prior, informed, opt-in consent before being placed on your device. Browser settings alone are not considered valid consent.

4. Your Choices

When you first visit EduPilot, a cookie consent banner will ask for your consent before any non-essential cookies are placed. You can:

• Accept all — essential + analytics cookies
• Essential only — only necessary cookies (default)
• Change preferences — at any time in Settings

No non-essential cookies are set until you make an active choice. Pre-ticked boxes are not used.

You can also delete cookies through your browser settings at any time.

5. Contact

For questions about our use of cookies: admin@aiventor.eu

Aiventor Sp. z o.o. NIP: 7252347037 | KRS: 0001128173

AI Transparency Notice

Last updated: July 3, 2026

In this Notice, "EduPilot", "we", and "us" mean Aiventor Sp. z o.o., al. Solidarności 117-615, 00-140 Warszawa, Poland (NIP: 7252347037). Contact: admin@aiventor.eu.

How EduPilot Uses Artificial Intelligence

EduPilot uses AI (large language models) to help educators create educational content — courses, lessons, assessments, and learning materials — and to support learners through an AI tutor.

What AI Does

• Generates draft educational content based on your instructions (topic, audience, learning objectives)
• Suggests lesson structures, assessment questions, and learning activities
• Assists with editing and improving existing content
• Adapts content for different audiences and difficulty levels
• Supports learners with explanations, practice, and study guidance through the AI tutor

What AI Does NOT Do

• Does not make autonomous decisions about students (final grading, placement, admission)
• Does not set final grades — the AI tutor supports learning; educators make all final academic decisions
• Does not process student personal data for AI model training
• Does not replace educator judgment — all generated content requires human review
• Does not profile students or create behavioral predictions

The AI Tutor Is Identified as AI

The learner account includes an AI tutor. It is an artificial intelligence system and is clearly identified as such in the interface, so learners always know they are interacting with a machine and not a human teacher.

AI-Generated Content Is Labelled

Courses and materials created with substantial AI assistance carry a "Created with AI assistance" label on the platform and the Marketplace. In addition, AI-generated outputs are marked in a machine-readable format (metadata) so that they are detectable as artificially generated, in line with Art. 50(2) of the EU AI Act.

Your Data and AI

Your data is NOT used to train AI models.

When you use EduPilot:

1. Your instructions are sent to AI providers to generate content
2. AI providers process the request and return the output
3. AI providers do not retain your data or use it for training
4. The generated content belongs to you

AI Limitations

AI-generated content may:

• Contain factual errors or inaccuracies
• Not fully align with specific curriculum standards without human review
• Reflect biases present in training data
• Require adaptation to local context and student needs

You are always responsible for reviewing and approving all content before use with students.

AI Providers

EduPilot routes requests through OpenRouter and may use the following AI model providers:

• Anthropic (Claude)
• OpenAI (GPT)
• Google (Gemini)

All providers are bound by data processing agreements that prohibit the use of your data for model training.

EU AI Act Compliance

EduPilot complies with the EU AI Act (Regulation (EU) 2024/1689) on the following timeline:

• Transparency (Art. 50(1)), from 2 August 2026: users are informed when they interact with an AI system. The AI tutor is identified as AI in the interface, and AI-assisted courses are labelled.
• Machine-readable marking of AI-generated content (Art. 50(2)): for systems placed on the market before 2 August 2026 — including EduPilot — this obligation applies from 2 December 2026. We are implementing metadata marking of generated outputs ahead of that date.
• High-risk AI systems (Annex III), from 2 December 2027 (following the 2026 amendments to the AI Act): we assess EduPilot, as intended to be used, not to be a high-risk AI system. EduPilot is a content-generation and learning-support tool in which educators make all final decisions about students; the AI does not determine access to education, does not set final grades, and does not steer learners' educational paths autonomously. We keep this assessment under review and will update it before the applicable date.

Measures implemented:

• Human-in-the-loop: all AI-generated content requires educator review before use
• The AI never sets final grades or makes final academic decisions
• Technical documentation of AI system capabilities and limitations
• Transparency about AI usage (this Notice, interface disclosures, and content labels)

Polish AI Legislation

We are monitoring Poland's forthcoming Act on Artificial Intelligence Systems (Ustawa o systemach sztucznej inteligencji) and the establishment of the national market surveillance authority (Komisja Rozwoju i Bezpieczeństwa Sztucznej Inteligencji, KRiBSI). We will update this Notice upon enactment.

Contact

For questions about our use of AI: admin@aiventor.eu

EduPilot (Aiventor Sp. z o.o.)

EduPilot Marketplace — Purchase & Enrollment Terms

Last updated: July 3, 2026

These Purchase & Enrollment Terms ("Purchase Terms") supplement the EduPilot Terms of Service and apply when you enroll in or purchase Courses on the EduPilot Marketplace (marketplace.aiventor.eu).

In these Purchase Terms, "EduPilot", "the Platform", "we", and "us" mean Aiventor Sp. z o.o., al. Solidarności 117-615, 00-140 Warszawa, Poland (NIP: 7252347037, REGON: 529689160, KRS: 0001128173) — the seller of record for Marketplace purchases. Contact: admin@aiventor.eu.

1. Who You Buy From

1.1 EduPilot is your seller. Courses on the Marketplace are created by independent Creators (educators, schools, organisations) and by EduPilot itself. When you purchase a Course, your contract for the supply of the digital content is with EduPilot as the merchant of record. This means EduPilot is responsible to you for payment processing, invoicing, VAT, delivery of access, refunds, and your statutory consumer rights.

1.2 Creator identity and status. Each course page shows the Creator's name and whether the Creator acts as a trader or a non-trader (private individual), based on the Creator's own declaration (Art. 6a of Directive 2011/83/EU). Because EduPilot is your contractual seller, your EU consumer rights apply to your purchase in either case.

1.3 Course content responsibility. The substance of each Course (its pedagogy, claims, and materials) is authored by its Creator, who warrants its accuracy and legality to the platform. If a Course does not conform to its description, contact us — Section 7 describes your remedies.

2. Accounts and Age

2.1 You need an EduPilot account to enroll. Account rules (accuracy, security, one free account) are in the Terms of Service.

2.2 Age. You must be at least 16 to purchase independently. Users under 16 may use the platform and enroll only with verifiable parental or guardian consent; purchases for users under 16 should be made by a parent, guardian, or their school. Where a school or organisation enrolls its students, the school is responsible for the necessary consents (see our Data Processing Agreement).

3. Prices, Payment, and Wallet

3.1 Prices. Prices shown to consumers include VAT. The applicable VAT rate depends on your country of residence and is itemised at checkout and on your receipt. Prices are in EUR.

3.2 Payment methods. Payment is processed by our payment providers (currently Stripe). We never see or store your full card details.

3.3 Wallet. You may top up a prepaid Wallet balance and pay for Marketplace purchases from it. Wallet rules:

• The Wallet is a prepayment towards purchases from EduPilot; it is not electronic money, is personal, and is non-transferable.
• Wallet balance can be spent on Marketplace purchases; it cannot be exchanged for AI Credits or Crystals, and cannot buy grades, certificates, or course completion.
• Unused Wallet balance is refundable on request at its paid value, subject to statutory rules and fraud checks; balances of closed accounts are refunded to the original payment method.

3.4 Promotions and 100 % discounts. Enrollments obtained free of charge or under a 100 % discount grant the same personal licence as paid enrollments (Section 5). An order confirmation/invoice is issued for every enrollment, including €0 enrollments.

3.5 Credits and Crystals are separate. AI Credits (generation fuel) are governed by the Credit Policy; Crystals are earned through study only and are governed by the Terms of Service. Neither is a payment method for Courses.

4. Order and Delivery

4.1 Your order is placed when you complete checkout; the contract is concluded when we confirm the order (email and/or in-product). Access to the Course is granted immediately after confirmation.

4.2 Technical requirements for access are listed in the Terms of Service (Section "Technical Requirements").

5. Your Licence and Access Period

5.1 Licence. On enrollment you receive a personal, non-transferable, non-commercial licence to access and use the Course through the platform for your own learning. You may not copy, redistribute, resell, publicly perform, or share access to the Course, or use it to build competing content or train AI models.

5.2 Access period. Your access lasts for as long as the Course remains licensed to the platform, and in any case not less than 12 months from enrollment for paid Courses. If a Course you paid for must be removed earlier for legal reasons, we will offer a replacement of equivalent value or a pro-rata refund.

5.3 Creator departure. If a Creator leaves the Marketplace or unpublishes a Course, already-enrolled Learners keep access under the licence granted at enrollment.

6. Right of Withdrawal and Refunds

6.1 Statutory 14-day withdrawal. As an EU/EEA consumer you may withdraw from a purchase within 14 days of the contract without giving reasons — the procedure and model form are in Section 9a of the Terms of Service.

6.2 Digital content exception. At checkout you may ask for immediate access to the Course. If you expressly consent to immediate performance and acknowledge that you thereby lose the right of withdrawal once access begins (checkbox at checkout), the statutory withdrawal right lapses upon first access, as permitted by Art. 16(m) of Directive 2011/83/EU.

6.3 EduPilot refund promise (goodwill, in addition to statutory rights). Independently of 6.1–6.2, we refund a paid Course on request within 14 days of purchase if you have consumed less than 20 % of the Course and have not completed it or downloaded its certificates/materials in bulk. Refunds go to the original payment method or, at your choice, to your Wallet. We may refuse goodwill refunds in cases of abuse (e.g., repeated purchase-consume-refund patterns); your statutory rights are never affected.

6.4 Wallet top-ups. Statutory withdrawal applies to Wallet top-ups; unused top-up amounts are refunded per Section 3.3.

7. Conformity of Digital Content

Under Directive (EU) 2019/770 and its Polish implementation, the Course must conform to its description on the course page. If it does not (for example, the content materially differs from the advertised outcomes, or access is defective), you may request that we bring it into conformity, and where that fails — a proportionate price reduction or termination with refund. Report conformity issues to admin@aiventor.eu; the complaints procedure and response time (30 days) are in Section 9b of the Terms of Service.

8. AI-Generated Content

Courses created with substantial AI assistance carry a "Created with AI assistance" label (Regulation (EU) 2024/1689, Art. 50). AI-assisted content may contain inaccuracies; Creators are required to review their Courses, and course pages must accurately describe what the Course delivers. Our AI Transparency Notice explains how AI is used on the platform.

9. Reviews and Conduct

9.1 You may review Courses you are enrolled in. Reviews must reflect your genuine experience; incentivised, fake, or retaliatory reviews are removed. We indicate whether reviews come from verified enrollments.

9.2 Learner conduct in Courses (Q&A, submissions, communities) is governed by the Terms of Service and the Community Guidelines & Content Policy. Attempting to obtain grades, certificates, or completions by fraud is prohibited — nothing on the platform can buy academic results.

10. Complaints and Disputes

Complaints: admin@aiventor.eu, answered within 30 days (Terms of Service, Section 9b). You may also use the EU Online Dispute Resolution platform (ec.europa.eu/consumers/odr) or the consumer protection bodies of your country of residence. These Purchase Terms are governed by Polish law; mandatory consumer protections of your country of residence remain unaffected, and consumer disputes may be brought before the courts of your place of residence.

11. Contact

EduPilot — admin@aiventor.eu

EduPilot Marketplace — Creator Terms

Last updated: July 3, 2026

These Creator Terms ("Creator Terms") supplement the EduPilot Terms of Service and govern the publication and sale of Courses on the EduPilot Marketplace (marketplace.aiventor.eu). By publishing a Course on the Marketplace, you agree to these Creator Terms. In case of conflict between these Creator Terms and the Terms of Service, these Creator Terms prevail for Marketplace matters.

In these Creator Terms, "EduPilot", "the Platform", "we", and "us" mean Aiventor Sp. z o.o., al. Solidarności 117-615, 00-140 Warszawa, Poland (NIP: 7252347037, REGON: 529689160, KRS: 0001128173) — the platform operator and merchant of record. Contact: admin@aiventor.eu.

1. Definitions

• Creator — a user who publishes one or more Courses on the Marketplace (an individual, a sole trader, or a legal entity such as a school, training centre, or company).
• Course — a course, lesson set, assessment pack, or other educational content published by a Creator on the Marketplace.
• Learner — a user who enrolls in a Course (free of charge or against payment).
• Marketplace — the EduPilot course catalogue at marketplace.aiventor.eu where Courses are listed, discovered, and sold.
• List Price — the price of a Course set by the Creator from the price points permitted by the current platform price list (including "free").
• Gross Amount — the amount actually paid by a Learner for a Course.
• Net Amount — the Gross Amount less (a) VAT and other transaction taxes, and (b) payment processing and currency conversion fees actually incurred.
• Creator Share — the Net Amount multiplied by (100 % minus the applicable Platform Commission).
• Platform Commission — the percentage retained by EduPilot under Section 6.

2. Who May Sell

2.1 Eligible plans. Publishing paid Courses on the Marketplace is available on the Lite (limited to one published paid Course at a time), Pro, Studio, and Enterprise plans, subject to each plan's limits on the pricing page. Free-plan users may browse and enroll but may not publish paid Courses.

2.2 Creator categories. When activating Marketplace publishing, you must declare which category you belong to:

2.3 Trader status disclosure. Your declared status (trader / non-trader) is displayed on your Course pages, as required by EU consumer law (Art. 6a of Directive 2011/83/EU as amended by Directive (EU) 2019/2161). You must keep this declaration accurate and update it if your status changes. If you sell Courses regularly, systematically, or with a profit-making purpose, you are likely acting as a trader; if in doubt, seek your own advice.

2.4 Verification. We may verify the information you provide (including through our payment providers) and may suspend Marketplace payouts or publishing until verification is complete. Providing false information is a material breach of these Creator Terms.

2.5 Age. Creators must be at least 18 years old, or the age of majority in their jurisdiction, whichever is higher. Minors may not sell on the Marketplace.

3. How Selling Works — Merchant of Record Model

3.1 EduPilot is the seller of record. When a Learner buys your Course, the sale contract for the supply of the digital content is concluded between the Learner and EduPilot. You authorise EduPilot to offer, sell, and deliver your Course to Learners in EduPilot's own name but for your account (commission/reseller structure).

3.2 What EduPilot does as merchant of record:

• collects payment from the Learner (via Stripe or other payment providers);
• calculates, collects, and remits VAT on sales to Learners, including under the EU One Stop Shop regime — consistent with Art. 9a of Council Implementing Regulation (EU) No 282/2011, under which a platform facilitating electronically supplied services is deemed the supplier for VAT purposes;
• issues receipts and invoices to Learners;
• handles refunds, chargebacks, and payment disputes with Learners;
• pays you the Creator Share under Section 7.

3.3 What remains your responsibility: the content, accuracy, legality, and quality of your Course (Section 9); your own income taxes and social contributions (Section 8); and keeping your account, payout, and tax information current.

3.4 No employment or agency. Nothing in these Creator Terms creates an employment, joint venture, or general agency relationship. You act as an independent content provider.

4. Licences

4.1 You keep ownership. You retain all intellectual property rights in your Courses. We claim no ownership of your content.

4.2 Licence to EduPilot. You grant us a non-exclusive, worldwide licence, for the duration of the Course's publication (and thereafter as needed under 4.3 and for legal/backup purposes), to host, store, reproduce, format, display, market, promote, offer, sell, and deliver the Course to Learners through the Marketplace and the EduPilot platform, including in marketing materials for the Marketplace (course title, cover, description, Creator name, and short excerpts).

4.3 Licence to enrolled Learners — survival. For each Learner who enrolls in your Course (paid or free), you grant that Learner a personal, non-transferable, non-commercial licence to access and use the Course through the platform. This licence survives removal of the Course from sale, your downgrade to a non-publishing plan, and termination of your Creator relationship, so that already-enrolled Learners keep access for the access period promised at purchase. This mirrors standard marketplace practice and protects your buyers' statutory rights.

4.4 No AI training. Consistent with our Privacy Policy and Data Processing Agreement: we do not use your Courses, prompts, or Learner data to train AI models.

5. Publishing, Content Standards, and AI Disclosure

5.1 Standards. Courses must comply with the Terms of Service, the Community Guidelines & Content Policy, and applicable law. You warrant that you own or have licensed all rights needed for every element of the Course (text, images, audio, video, third-party materials) and that the Course does not infringe third-party rights.

5.2 Quality review. We may review Courses before or after publication (including automated review and Pedagogy Score assessment) and may decline, unpublish, or require changes to Courses that do not meet our published standards.

5.3 AI-generated content disclosure (EU AI Act). Courses generated or substantially assisted by AI must carry the platform's "Created with AI assistance" disclosure. The platform applies this label automatically to AI-generated output; you must not remove or obscure it, and you must accurately indicate AI involvement where the platform asks you to. This implements transparency obligations under Regulation (EU) 2024/1689 (the EU AI Act, Art. 50).

5.4 Accuracy of course pages. Course titles, descriptions, learning outcomes, and audience declarations must be accurate and not misleading. Fake reviews, review manipulation, and enrollment manipulation are prohibited.

5.5 Learner data. You receive, through the platform, the information needed to deliver your Course: enrolled Learners' display names, progress, submissions, and Q&A activity. You must (a) use this data only to deliver and improve the Course, (b) not export, sell, or use it for off-platform marketing without the Learner's separate, explicit consent, and (c) comply with the GDPR. For school/organisation deployments, data handling is governed by our Data Processing Agreement.

6. Pricing, Promotions, and Commission

6.1 List Price. You set the List Price of each Course from the price points permitted by the current platform price list (including "free"). Consumer-facing prices are displayed inclusive of VAT.

6.2 Platform Commission by plan. The Platform Commission depends on your subscription plan at the time of the sale:

Commission rates may be changed with at least 15 days' prior notice (Section 12.1). Sales made before a change takes effect are settled at the old rate.

6.3 Platform promotions. We may run Marketplace-wide promotional campaigns, including discounts of up to 100 % of the List Price (e.g., launch fairs and seasonal events). Participation of your paid Courses in platform-initiated discounts is opt-in via your publishing settings, except for Courses you have listed as free. Where a Learner enrolls under a 100 % discount, no Creator Share is payable for that enrollment; you gain the enrollment, reviews, and visibility.

6.4 Your own promotions. You may promote your Courses off-platform. Creator-generated discount codes, where available, apply to your Courses only and are settled at the discounted Gross Amount.

6.5 Wallet purchases. Purchases paid from a Learner's prepaid Wallet balance are treated identically to card purchases for commission and payout purposes.

7. Payouts

7.1 Cycle. Creator Shares are calculated per calendar month. Payout for sales of month M is made within 45 days after the end of month M — the delay covers the Learner's 14-day withdrawal window, the platform refund window, and chargeback processing.

7.2 Minimum threshold. Payouts are issued when your accrued balance is at least €25. Smaller balances roll over and are paid once the threshold is reached, or by the end of the calendar year in which they were earned, whichever comes first.

7.3 Method and currency. Payouts are made in EUR by SEPA bank transfer to the IBAN you registered (other methods may be added). You are responsible for the accuracy of your payout details; we are not liable for transfers executed to the details you provided. Bank fees charged by your receiving bank are yours.

7.4 Deductions and clawbacks. The following are deducted from your accrued balance (and, if insufficient, from future payouts): (a) refunds and withdrawals relating to your Courses; (b) chargebacks and associated processor fees relating to your Courses; (c) amounts paid on manifestly fraudulent enrollments. We may hold a reasonable reserve where a Course shows an abnormal refund or chargeback pattern, and will state the reason.

7.5 Statements. A monthly revenue report is available in your Creator dashboard, showing per-enrollment Gross Amount, taxes and fees, commission, refunds, and your Creator Share.

7.6 Suspension of payouts. We may suspend payouts (with a statement of reasons) while investigating suspected fraud, rights infringement, or breach of these Creator Terms, and for as long as your identification or tax information is materially incomplete.

8. Taxes and Reporting

8.1 Your taxes. You are solely responsible for income tax, social contributions, and any business registrations applicable to your Creator Share in your country. Payouts are made gross of your income taxes.

8.2 VAT on the commission. The Platform Commission is our fee for intermediation/distribution services. For VAT-registered Creators in other EU member states, the reverse-charge mechanism applies; for Polish VAT payers, Polish VAT applies; for non-registered individuals, the commission is settled as displayed at the time of sale. We issue commission documentation through the Creator dashboard.

8.3 Information reporting (DAC7 and analogous rules). Where platform-reporting rules (such as Council Directive (EU) 2021/514, "DAC7", as implemented in Poland) apply to your activity, we will collect the required identification data (including tax identification number) and report your revenue to the competent tax authority as required by law, notifying you of what was reported. Failure to provide legally required identification data may lead to payout suspension or account restriction, as the law requires.

9. Your Warranties and Indemnity

9.1 You warrant that: (a) you hold all rights needed to publish and sell each Course; (b) the Course and its course page are accurate, lawful, and comply with the Community Guidelines; (c) the Course conforms to its description for the purposes of consumer conformity rules (Directive (EU) 2019/770); (d) your trader-status declaration and tax information are accurate.

9.2 Indemnity. You will indemnify and hold harmless EduPilot, its officers, employees, and agents against all claims, damages, penalties, and reasonable costs (including legal fees) arising from: (a) your Course content or course page; (b) your breach of these Creator Terms or applicable law; (c) third-party IP, privacy, or consumer claims relating to your Course, including conformity claims brought by Learners against EduPilot as seller of record to the extent caused by your Course. This Section survives termination.

10. Moderation, Notice-and-Action, and Copyright Complaints

10.1 Notice-and-action. Anyone may report a Course believed to be illegal or infringing via admin@aiventor.eu. We process such notices in line with the Digital Services Act (Regulation (EU) 2022/2065): we review the notice, act proportionately (which may include unpublishing), and provide the affected Creator a statement of reasons and a way to contest the decision.

10.2 Copyright complaints. Rights holders may submit complaints identifying the work, the allegedly infringing Course, and a good-faith statement. We may remove or disable access pending review. Repeat infringers will have Marketplace publishing terminated.

10.3 Effect on Learners. Where a Course is removed for legal reasons, we may suspend Learner access; where removal is for other reasons, enrolled Learners retain access under Section 4.3.

11. Ranking Transparency (P2B)

The main parameters determining the ranking of Courses in Marketplace search and category pages are: relevance of the course page to the query; Pedagogy Score; Learner ratings and completion signals; enrollment and recency signals; and language/audience match. Studio-plan promoted placements are labelled as promoted. This disclosure is made under Regulation (EU) 2019/1150 ("P2B" — the EU regulation on fairness and transparency for business users of online intermediation services).

12. Changes, Suspension, Termination

12.1 Changes to these Creator Terms. We will give Creators at least 15 days' notice of changes (email and/or in-product), or longer where the change requires technical adaptation. You may terminate your Creator relationship before the change takes effect. Changes required by law or urgent security needs may take effect sooner, with explanation.

12.2 Restriction or suspension of a Creator. If we restrict or suspend your Marketplace publishing, we will provide a statement of reasons on or before the time the restriction takes effect, except where prohibited by law or where doing so would defeat fraud prevention. Termination of the whole Creator relationship at our initiative is notified at least 30 days in advance, except for repeated or manifest infringements, legal obligations, or fraud.

12.3 Complaints. Creators may raise complaints about moderation, ranking, payouts, or these Creator Terms at admin@aiventor.eu; we respond within 30 days.

12.4 Your termination. You may unpublish Courses at any time and terminate Marketplace publishing with effect from the end of the current month. Section 4.3 (enrolled-Learner licences), accrued payout rights and deductions, Section 8 (reporting), and Section 9 (indemnity) survive. Final payout follows the normal Section 7 schedule.

13. Liability

To the maximum extent permitted by law, our total liability to a Creator under these Creator Terms is limited to the total Creator Shares paid or payable to that Creator in the 12 months preceding the claim. Nothing limits liability that cannot be limited under applicable law. We are not liable for the volume of sales, ranking outcomes, or Learner behaviour.

14. Governing Law and Disputes

These Creator Terms are governed by the laws of Poland. For Creators acting as businesses, disputes are resolved by the courts of Warsaw, Poland. For Creators who are consumers, mandatory consumer forum and protection rules of their country of residence remain unaffected.

15. Contact

EduPilot — admin@aiventor.eu

EduPilot Credit Policy

Last updated: July 3, 2026

In this Credit Policy, "EduPilot", "the Platform", "we", and "us" mean Aiventor Sp. z o.o., al. Solidarności 117-615, 00-140 Warszawa, Poland (NIP: 7252347037, REGON: 529689160, KRS: 0001128173). This Credit Policy supplements the EduPilot Terms of Service. Contact: admin@aiventor.eu.

1. What Credits Are — and What They Are Not

1.1 Credits are a unit of account for measuring your use of AI generation features on the Platform (course generation, lesson regeneration, edits, translations, and other AI-powered actions). One Credit corresponds to a defined amount of generation capacity as set out in the current price list.

1.2 Credits are not money, electronic money, a currency, a gift card, a voucher, a deposit, or a payment instrument. Credits:

• have no cash value and cannot be exchanged for money, Wallet balance, or Crystals;
• are personal and non-transferable between accounts (except allocation inside a team workspace by its owner, where the plan supports this);
• cannot be used to purchase Courses on the Marketplace, subscriptions, or any goods or services other than AI generation actions;
• can never buy grades, certificates, or course completions.

2. How You Receive Credits

3. How Credits Are Spent

3.1 Price before action. The Credit cost of every action (which depends on the action type and the AI model tier selected) is displayed before you start the action. Credits are deducted when the action completes.

3.2 Credit Log. Your account contains a full Credit Log showing, for every entry: date and time, action, model tier, Credits deducted or credited, and your balance after the entry. The Credit Log is the record of account activity for billing purposes.

3.3 Consumption is final. A completed generation consumes its Credits. Dissatisfaction with the style or substance of a completed output does not entitle you to a Credit return; edits and regenerations are separate actions with their own displayed cost.

3.4 Order of consumption. Credits are spent in this order: subscription allowance first, then add-on pack Credits, then promotional Credits — so that longer-lived Credits are preserved for you.

4. Validity and Expiry

Expiry terms are stated at the point of purchase and on the pricing page — there are no undisclosed expirations.

5. Failed Generations

If a generation fails to complete due to a Platform error, the Credits deducted for it are returned automatically to your balance and the return is recorded in the Credit Log. If you believe a return was missed, contact admin@aiventor.eu with the Credit Log entry; we respond under the complaints procedure in the Terms of Service (30 days).

6. Fair Use

Daily usage caps per plan are stated on the pricing page and protect the service for everyone. Automated or scripted consumption outside permitted API use, Credit farming through fake referrals, and circumvention of plan limits may result in removal of promotional Credits and account measures under the Terms of Service.

7. Purchases, Right of Withdrawal, Refunds

7.1 Add-on packs. As an EU/EEA consumer you may withdraw from an add-on pack purchase within 14 days without giving reasons. Because Credits become usable immediately at your request, if you have already spent part of the pack when you withdraw, the refund is reduced proportionally to the Credits used. After the 14-day period, add-on packs are non-refundable, without prejudice to your statutory rights (including remedies for non-conforming services).

7.2 Subscription allowance. Subscription Credits are a feature of your subscription; subscription payments, renewals, cancellation, and withdrawal are governed by the Terms of Service. Cancelling a subscription stops future charges; allowance already granted remains usable until the end of the paid period and then expires (Section 4).

7.3 No cash-out. Except for the statutory withdrawal in 7.1, Credits are never converted to money.

8. Changes

We may change Credit prices per action, allowances, and this Credit Policy with at least 15 days' prior notice (email and/or in-product). Changes do not shorten the validity of add-on packs already purchased. If you do not accept a material change, you may cancel your subscription before it takes effect.

9. Contact

EduPilot — admin@aiventor.eu

EduPilot Community Guidelines & Content Policy

Last updated: July 3, 2026

In these Guidelines, "EduPilot", "the Platform", "we", and "us" mean Aiventor Sp. z o.o., al. Solidarności 117-615, 00-140 Warszawa, Poland (NIP: 7252347037, REGON: 529689160, KRS: 0001128173). Contact: admin@aiventor.eu.

These Guidelines apply to all content and conduct on the Platform: Courses and course pages, lessons and assessments, reviews and ratings, Q&A, comments, profiles, workspace collaboration, and any communication through the Platform. They apply to all users — Learners, Creators, educators, and organisations — and supplement the Terms of Service, the Marketplace Creator Terms, and the Purchase & Enrollment Terms.

1. Core Principles

EduPilot is an educational space. Everything here follows four rules:

1. Legal — content and conduct must comply with applicable law.
2. Safe — no content that endangers people, especially minors.
3. Honest — courses deliver what they promise; reviews reflect real experience; nothing buys academic results.
4. Respectful — disagreement is welcome; abuse is not.

2. Prohibited Content — Zero Tolerance

The following results in immediate removal and account termination, and, where the law requires, a report to the competent authorities:

• Child sexual abuse material and any sexualisation of minors, in any form, including AI-generated.
• Terrorism and violent extremism: promotion, glorification, or justification of terrorist acts or organisations; recruitment or fundraising for them; instructional content facilitating acts of violence; materials produced by or for designated terrorist organisations.
• Incitement to violence against any person or group.

3. Prohibited Content — Removal and Enforcement

The following is not allowed anywhere on the Platform:

3.1 Illegal and dangerous content

• Content that is unlawful under applicable law (treści o charakterze bezprawnym).
• Instructions for manufacturing weapons or explosives, or for producing illegal drugs.
• Promotion or facilitation of criminal activity, human trafficking, or the sale of regulated goods.
• Malware, phishing, or content designed to compromise accounts or devices.

3.2 Hate and harassment

• Content that promotes hatred, discrimination, or violence based on race, ethnicity, national origin, religion, disability, sex, sexual orientation, gender identity, or age.
• Harassment, threats, intimidation, or the publication of another person's private information (doxxing).

3.3 Sexual and vulgar content

• Pornographic or sexually explicit content.
• Gratuitously vulgar, obscene, or shocking content. Serious educational treatment of sensitive subjects (e.g., medical anatomy, age-appropriate health education, history of conflict) is permitted where it is accurate, contextualised, clearly described on the course page, and matched to the declared audience age.

3.4 Harmful and deceptive content

• Content promoting self-harm, suicide, or eating disorders.
• Dangerous health claims presented as fact (e.g., "courses" advising abandonment of medical treatment).
• Fraudulent schemes: pyramid and multi-level recruitment schemes, guaranteed-earnings promises, fake investment training designed to funnel victims.
• Impersonation of any person or organisation, or false claims of credentials, degrees, or affiliations.

3.5 Infringing content

• Content that infringes copyright, trademarks, or other rights. Uploading a course you did not create or license is prohibited. Copyright complaints are handled under the notice-and-action procedure in the Creator Terms; repeat infringers lose publishing rights.

4. Course Honesty Rules (Creators)

• Course titles, descriptions, learning outcomes, and audience declarations must be accurate and not misleading. No keyword stuffing, no fake urgency, no invented enrollment numbers.
• AI-assistance labels applied by the Platform must not be removed or obscured; where the Platform asks you to declare AI involvement, declare it accurately.
• Content declared for minors must be age-appropriate in language, examples, and imagery.
• Substantially duplicative re-uploads of the same course to manipulate search are prohibited.

5. Reviews and Ratings

• Reviews must reflect the reviewer's genuine experience with the course.
• Prohibited: fake reviews, purchased or incentivised reviews, review exchanges, self-reviews through other accounts, retaliatory reviews, and pressuring Learners to change or remove reviews (review extortion).
• Creators may respond to reviews publicly and respectfully; disputing a review's facts is fine, attacking the reviewer is not.
• We label reviews from verified enrollments and remove reviews that violate these rules, in either direction.

6. Academic Integrity

Nothing on the Platform can buy academic results. Prohibited for all users:

• Selling, buying, or transferring grades, certificates, completions, or assessment answers.
• Completing assessments on someone else's behalf, or offering such services.
• Manipulating progress tracking or the Pedagogy Score through technical means.

Crystals are earned through study only; Credits and Wallet funds cannot be converted into academic results. Certificates obtained through fraud are revoked.

7. Learner Data and Off-Platform Solicitation (Creators)

• Learner data visible to you exists only to deliver your course. Exporting it, selling it, or using it for off-platform marketing without the Learner's separate, explicit consent is prohibited (Creator Terms §5.5).
• Do not move Learner communication off-Platform to circumvent these Guidelines, payments, or safety controls, especially where minors are involved.

8. Reporting

Anyone can report content or conduct:

• via the "Report" button on course pages, reviews, and profiles, or
• by email to admin@aiventor.eu, describing the content, its location (link), and the reason.

Reports are reviewed under our notice-and-action procedure. Where we act on a report, the affected user receives a statement of reasons and can contest the decision by replying to it. Manifestly abusive or repeated bad-faith reporting is itself a violation.

9. Enforcement Ladder

Depending on severity, history, and intent, we apply measures proportionately:

Section 2 violations skip the ladder: immediate termination and, where required, reporting to authorities. Enforcement decisions can be contested at admin@aiventor.eu; we respond within 30 days. Where a Course is removed, already-enrolled Learners retain access unless the removal is for legal reasons (Creator Terms §10.3).

10. Changes

We may update these Guidelines with prior notice as described in the Terms of Service (14 days for consumers, 15 days for business users), except where urgent changes are required by law or safety.

11. Contact

EduPilot — admin@aiventor.eu

Data Processing Agreement (DPA)

Last updated: July 3, 2026

This Data Processing Agreement ("DPA") forms part of the agreement between the educational institution or the individual educator who invites learners to the platform ("Controller", "You") and Aiventor Sp. z o.o. ("Processor", "We", "EduPilot") for the provision of EduPilot services. For individual educators, this DPA is concluded electronically upon acceptance when first inviting learners.

1. Definitions

• Personal Data — any information relating to an identified or identifiable natural person, including student data, educator data, and usage data
• Controller — the educational institution that determines the purposes and means of processing personal data
• Processor — Aiventor Sp. z o.o., which processes personal data on behalf of the Controller
• Sub-processor — a third party engaged by the Processor to process personal data
• Student Data — personal data of students processed through EduPilot, including names, emails, learning progress, and generated content
• Applicable Data Protection Law — GDPR (Regulation (EU) 2016/679), and any applicable national implementations

2. Scope and Purpose of Processing

2.1 Data Processed

2.2 Purpose Limitation

The Processor shall process Personal Data only for the following purposes:

• Providing EduPilot services as described in the Terms of Service
• Technical support and troubleshooting
• Service maintenance and security
• As otherwise instructed in writing by the Controller

The Processor shall not process Personal Data for any other purpose, including but not limited to marketing, profiling, or selling data to third parties.

3. AI and Student Data

3.1 No Training on Student Data. The Processor does NOT use Student Data, educator data, or any content created within EduPilot to train, fine-tune, or improve artificial intelligence or machine learning models.

3.2 AI Processing. When EduPilot uses third-party AI services to generate educational content, inputs are processed solely to produce the requested output. AI sub-processors are contractually prohibited from retaining or using input data for model training.

3.3 AI Transparency. The Processor will clearly indicate when content is AI-generated. The Controller and its educators are responsible for reviewing AI-generated content before use with students.

3.4 No Profiling or Advertising. Data processed on behalf of educational institutions shall not be used for profiling, behavioral advertising, building marketing profiles, or any purpose beyond the contracted educational service. This applies to all Student Data without exception.

3.5 Age of Consent. In Poland, the age of consent for data processing is 16 years (Art. 8 GDPR, maintained by the Polish Act of 10 May 2018). The Controller is responsible for ensuring appropriate legal basis for processing data of students under 16, including obtaining verifiable parental consent where required.

4. Obligations of the Processor

The Processor shall:

4.1 Process Personal Data only on documented instructions from the Controller, unless required by law

4.2 Ensure that persons authorized to process Personal Data are bound by confidentiality obligations

4.3 Implement appropriate technical and organizational security measures, including:

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
• Access controls with role-based permissions
• Regular security assessments
• Incident detection and response procedures
• Backup and disaster recovery

4.4 Not engage another processor (sub-processor) without prior written authorization from the Controller (see Section 6)

4.5 Assist the Controller in responding to data subject requests (access, rectification, erasure, portability, restriction, objection) within reasonable timeframes

4.6 Assist the Controller with Data Protection Impact Assessments (DPIA) where required

4.7 Notify the Controller of any Personal Data breach without undue delay and no later than 48 hours after becoming aware of the breach, providing:

• Nature of the breach
• Categories and approximate number of data subjects affected
• Likely consequences
• Measures taken or proposed to address the breach

4.8 Upon termination of the agreement, at the Controller's choice:

• Return all Personal Data in a standard format (CSV/JSON), or
• Delete all Personal Data within 30 days and certify deletion in writing

5. Obligations of the Controller

The Controller shall:

5.1 Ensure that there is a lawful basis for processing (e.g., public task, legitimate interest, consent where required)

5.2 Obtain necessary consents or authorizations for processing student data, including parental consent where required by applicable law

5.3 Inform data subjects (educators, students, parents) about the processing

5.4 Not provide the Processor with Personal Data that is not necessary for the service

6. Sub-processors

6.1 Authorized Sub-processors

The Controller provides general authorization for the Processor to engage sub-processors. Current sub-processors:

6.2 Notification of Changes

The Processor will notify the Controller at least 14 days before adding or replacing a sub-processor. The Controller may object in writing within 14 days. If the objection cannot be resolved, either party may terminate the agreement.

6.3 Sub-processor Obligations

All sub-processors are bound by data processing agreements with equivalent protections to this DPA.

7. International Data Transfers

Where Personal Data is transferred outside the EEA (e.g., to US-based sub-processors), the Processor ensures adequate safeguards through:

• EU-US Data Privacy Framework (where applicable)
• Standard Contractual Clauses (SCCs) pursuant to Commission Decision 2021/914
• Additional technical measures (encryption, pseudonymization) where appropriate

8. Data Subject Rights

The Processor will promptly assist the Controller in fulfilling data subject requests under GDPR Articles 15-22:

9. Audits

The Processor shall make available to the Controller all information necessary to demonstrate compliance with this DPA. The Controller may conduct audits (or appoint an independent auditor) with 30 days prior written notice, no more than once per year, during normal business hours.

10. Term and Termination

This DPA shall remain in effect for the duration of the service agreement. Upon termination:

• Personal Data will be returned or deleted per Section 4.8
• Obligations of confidentiality survive termination
• The Processor will provide a written confirmation of data deletion

11. Liability

Liability under this DPA is governed by the Terms of Service and applicable law. Each party is liable for damages caused by its violation of Applicable Data Protection Law.

12. Contact

Data Processor: Aiventor Sp. z o.o. al. Solidarności 117-615, 00-140 Warszawa, Poland NIP: 7252347037 | REGON: 529689160 | KRS: 0001128173 Email: admin@aiventor.eu

Supervisory Authority: Urząd Ochrony Danych Osobowych (UODO) ul. Stawki 2, 00-193 Warszawa, Poland www.uodo.gov.pl