Terms and Conditions

1. IDENTIFICATION OF THE PARTIES AND NATURE OF THE AGREEMENT

This document constitutes a binding, obligatory and fully enforceable legal agreement between the user, purchaser, subscriber or any person who accesses, browses or interacts with the Company's digital environments (hereinafter, the "Customer"), and Freedom Coaching LLC, a company duly organized under the laws of the State of Florida, United States of America (hereinafter, the "Company").

This agreement governs, in a comprehensive, exhaustive and legally consistent manner, the conditions of access, acquisition, use, enjoyment, limitations, responsibilities and consequences arising from the purchase of digital products offered by the Company through its websites, sales pages, technology platforms, membership systems, digital tools, applications or any other digital distribution channel now existing or that may be developed in the future.

The Customer expressly acknowledges that accessing, browsing or using the Company's services implies the free, informed, express and unequivocal acceptance of the entirety of these Terms and Conditions, which constitute a valid and enforceable contract under the legislation in force in the United States, including, without limitation, the Electronic Signatures in Global and National Commerce Act (E-SIGN Act) and the Uniform Electronic Transactions Act (UETA), which grant full legal validity to agreements entered into by electronic means.

The Customer declares that they have sufficient legal capacity to contract, that they act voluntarily and without coercion, and that they understand the legal scope of the obligations assumed by accepting this agreement.

Intended users of the service. The Company's products and services are designed and marketed for professionals in coaching, mentoring, consulting and related activities, for use in the course of their professional or business activity: managing their clients, sessions, calendar, invoicing, programs and working materials. The Company does not direct its offer to the general public for personal, family or household purposes.

Declaration of professional purpose. On purchasing, the Customer expressly declares that they acquire the services for their professional or business activity, whether as an independent professional or on behalf of a company or organization for which they have sufficient authority to contract.

Record of the professional nature of the purchase. The Customer may state their professional or business name during the purchase process. As a record of the professional nature of the purchase, the Company may keep the Customer's declaration, the professional details provided and the records of the Customer's use of the platform in their activity. The retention of these records shall be limited to the data necessary to evidence the purchase and the use of the service, in accordance with the Privacy Policy and the applicable retention periods.

Intended professional use. The intended professional use of the service includes managing clients, sessions, appointments, invoicing, programs and working materials for the Customer's business or professional activity, whether carried out full-time or part-time. The Customer's legal status and applicable rights shall be determined under applicable law and the circumstances of the contract.

Accuracy of the declaration. The Customer undertakes that the information provided when purchasing is truthful. If the Customer does not intend to use the services for their professional activity, they must refrain from purchasing them.

Relationship with statutory rights. This clause does not exclude or limit any rights available to the Customer under applicable mandatory law, regardless of their declaration of professional purpose. Section 9 expressly preserves those rights.

If the Customer does not agree with any of the terms set out herein, they must refrain from using the services, accessing the content or carrying out any transaction with the Company.

2. LEGAL NATURE OF THE DIGITAL PRODUCTS AND CONFIGURATION OF THE SERVICE

The products and services offered by the Company consist of intangible digital services, which may include, without limitation: subscription access to a management platform for coaching professionals (comprising, among others, CRM and client records, calendar and bookings, invoicing, video calls, interactive tools and spaces for their clients to work between sessions), as well as resource libraries, templates, downloadable documents, training content, methodologies and any other asset distributed in digital format.

The Customer acknowledges and accepts that such products do not constitute physical goods and are not subject to material delivery, but are legally configured as digital services with immediate access, provided through electronic means.

Delivery of the product is carried out through digital mechanisms, such as access to private platforms, download links, user areas, membership systems or any other technological system enabled by the Company.

For legal purposes, provision of the service shall be deemed complete at the moment the Customer receives access to the digital content, regardless of whether the Customer decides to use, view or consume that content.

The Customer acknowledges that this delivery model constitutes immediate performance of the contracted service, this being an essential element of the agreement, with direct implications regarding guarantee, refund and withdrawal rights.

3. IMMEDIATE PERFORMANCE OF THE SERVICE AND AVAILABILITY OF ACCESS

The Customer acknowledges and accepts that, these being digital services with immediate access, performance begins at the moment access to the content or the platform is enabled, with no further action required from the Company.

This immediate availability allows the Customer to use the service from the outset. This is without prejudice to the lifetime guarantee described in section 7, nor to the subscription cancellation rights set out in section 8.

Access to and use of the service is carried out in accordance with the applicable provisions on digital services and electronic contracts, both under United States legislation and relevant international rules.

4. LICENCE OF USE AND CONTRACTUAL LIMITATIONS

The acquisition of any digital product grants the Customer a limited, personal, non-exclusive, non-transferable and revocable licence of use, the scope of which is restricted to individual use of the content.

The Customer acknowledges that they acquire no ownership right over the content, but only a right of access and use in accordance with the terms established herein.

Any use exceeding the Customer's personal scope is expressly prohibited, including, without limitation, reproduction, distribution, public communication, transformation, commercialization, sublicensing or any form of direct or indirect exploitation of the content.

The Customer accepts that any unauthorized use shall constitute a serious breach of this agreement and of the Company's intellectual property rights.

5. INTELLECTUAL PROPERTY AND PROTECTION OF THE CONTENT

All content offered by the Company is protected by the intellectual property laws applicable in the United States, as well as by international treaties.

The Customer acknowledges that the content constitutes a protected asset and that its improper use may give rise to legal liability, including claims for damages.

The Company reserves the right to take legal action if infringements are detected.

6. ACCESS, AVAILABILITY AND CUSTOMER RESPONSIBILITY

The Company will provide access to the digital content upon confirmation of payment, using the technological systems available.

The Customer acknowledges that access may depend on external factors, including connectivity, devices and software.

The Company does not guarantee uninterrupted availability, although it will make reasonable efforts to keep the service operational.

The Customer is responsible for the confidentiality of their access credentials and for any use made from their account.

7. LIFETIME GUARANTEE

7.1. What it guarantees. The Company guarantees that the platform works for as long as the Customer keeps access to the plan purchased: for life on the lifetime access plan, and while the subscription is active on the monthly and annual plans. The guarantee covers technical failures of the platform that prevent or substantially hinder the use of an essential feature included in the plan purchased at the time of purchase, in accordance with the features described before it. Tools, modules, features or improvements that the Company adds after the purchase are offered as added value and are not covered by this guarantee. When a covered failure occurs, the Company will do its best to fix it; if it does not succeed within the set time frame, the Customer may request a refund in accordance with this section.

7.2. What it does not cover. Where the service conforms to what was purchased, the following do not, on their own, constitute grounds for a refund: a change of mind, lack of use or time, preference for another solution, learning difficulties not arising from a defect in the service, changes in the Customer's professional activity, or expectations regarding features that were not offered. Setup and learning questions are handled through the help resources and the platform's support.

This guarantee also does not cover:

• a) White Label.
• b) Bonuses included with or given alongside the purchase, including the GoHighLevel account and CoachPro GPT, as well as any other bonus.
• c) Third-party services, such as GoHighLevel, OpenAI, Google, email providers or payment gateways, and the accounts or services the Customer connects to the platform. These services depend on their respective owners, who may modify, limit or discontinue them; their failure, changes or interruption do not give rise to any claim or refund against the Company.
• d) Failures caused by the Customer's own device, browser, internet connection or settings, and temporary interruptions resolved within the time frame set out in section 7.3.

7.3. How a failure is reported. The Customer must report the failure from their account within the platform, under My account → Request a refund, explaining the problem in at least two hundred and fifty (250) words, with three (3) screenshots and one (1) link to the screen where it happens, all of which are mandatory. That report opens a support ticket, whose date is the one that counts for the time frames. The Company may request the information reasonably necessary to investigate it, without requiring technical knowledge from the Customer.

The Company will respond within two (2) business days and will do its best to fix the failure within seven (7) business days from the date of the ticket, during which the account remains active. If the Company needs additional information from the Customer to investigate it, it will state specifically what it needs, and the period will be suspended while it awaits the reply. Once the information is received, the period resumes for the business days that remained. The failure will be assessed taking into account the Customer's description and the available technical records, not only whether the Company is able to reproduce it. A workaround is considered a fix where it allows the purchased function to be substantially performed, at no additional cost and without significant inconvenience to the Customer.

7.4. Account access. If the Customer cannot access their account, they may write to [email protected] solely to recover access. Email support does not process refunds: once access is recovered, any other request, including a refund request, is made from within the platform.

7.5. How to request a refund. If the covered failure is not fixed within the set time frame, the Customer may continue with the refund request exclusively from their account within the platform, under My account → Request a refund. Refund requests are not processed by email, WhatsApp, social media or any other channel. If the failure is fixed within the time frame, no refund is due.

When the Customer continues with the request, the account is put on hold: the Customer no longer has access to it, but their data is not deleted while it is being resolved. Before continuing, the Customer may export all their data. The Company will resolve the request within a maximum of thirty (30) business days and will inform the Customer of its decision. If the refund is due, it will be made and access will be closed. If it is not due, access will be restored as it was.

7.6. Refund amount. The refund is always calculated on the amount actually paid for the affected plan, after applying any discounts, coupons or promotions used at purchase, and excluding White Label, bonuses and any other products purchased separately.

• a) Lifetime access plan: the amount actually paid for the plan is refunded. If it was paid in instalments, the sum of the instalments actually paid.
• b) Monthly plan: the amount for the current month is refunded.
• c) Annual plan: the portion corresponding to the unused period of the current year is refunded, calculated by days from the date of the ticket in which the failure was reported.

The refund is processed to the original payment method, and future charges are cancelled.

7.7. Change of mind and legal rights. Outside the cases covered by this guarantee and the rights granted by applicable law, there is no contractual right to a refund for a change of mind or subjective dissatisfaction. This commercial guarantee does not exclude or limit the rights the Customer may have for breach of contract, non-performance, incorrect charges or any other cause protected by applicable law (section 9).

8. SUBSCRIPTIONS, AUTOMATIC RENEWAL AND CANCELLATION

Certain Company plans are sold as recurring-payment subscriptions (for example, monthly or annual). By taking out a subscription, the Customer expressly authorizes the Company, through its payment provider, to make the corresponding recurring charges automatically until the subscription is cancelled.

Monthly plan: renews automatically each month. The Customer may cancel at any time; cancellation stops future charges and access remains active until the end of the monthly period already paid for, with no subsequent charges.

Annual plan: is paid in advance and entails a commitment for the annual period contracted. The Customer may cancel the renewal at any time; in that case, access remains active until the end of the year already paid for and the subscription does not renew on expiry. Except as provided in the guarantee in section 7, the annual plan does not provide for pro-rata refunds for the unused fraction of the period.

Cancellation is managed exclusively from the Customer's account within the platform, under My account (Cancel subscription or Delete my account, as applicable). Cancellations are not processed by email, WhatsApp, social media or any other channel. If the Customer cannot access their account, they may write to [email protected] to recover access and complete the process from it. Before the account is closed, the Customer may export their data, including their CRM in CSV format and each client's reports and tools in PDF.

Payment in instalments: certain one-off payment products may be offered with the amount divided into monthly instalments. In that case, the Customer expressly authorizes the Company, through its payment provider, to make automatic monthly charges to the registered payment method, for the number of instalments and the amount stated at the time of purchase. The number of instalments and their amount are stated at the time of purchase.

The total amount paid in instalments is higher than that of the one-off payment, the difference corresponding to the instalment arrangement. That total amount is stated before the transaction is confirmed.

Access during the instalment plan: access remains active while payments are up to date. If a charge cannot be completed, access is suspended immediately; the payment provider retries the charge according to its schedule and, if it goes through, access is restored automatically without any action by the Customer.

Completion: lifetime access becomes final once the last instalment is paid. If the plan is interrupted before then — whether because the Customer cancels or because the charges cannot be completed — lifetime access is not granted and the instalments already paid are not refundable, as they correspond to the period during which the Customer had access to the service, without prejudice to the lifetime guarantee described in section 7. The Customer may start a new purchase at any time, at the price in effect at that moment.

Consent: acceptance of an instalment plan requires the Customer's express confirmation, setting out the number of instalments, the amount of each one, the frequency and the total amount.

9. NATURE OF THE SERVICE AND REFUNDS OUTSIDE THE GUARANTEE

The Company's services combine access to a digital platform for continued use with downloadable digital content and tools. The Customer acknowledges that, outside the cases covered by the guarantee in section 7, and except as provided for subscriptions in section 8, the amounts paid are not refundable, given the digital nature of the service and the immediate and continued availability of access.

Professional nature of the contract. The Customer declares that they contract the services for their professional or business activity as a coach. Without prejudice to the rights granted by applicable mandatory law and to the commercial guarantee set out in section 7, no refunds shall be granted for a mere change of mind, failure to use the platform or any of its features, dissatisfaction based solely on personal preferences where the service conforms to what was contracted, changes to the Customer's professional or business plans, or failure to cancel a renewal that was validly authorized and properly disclosed.

Rights that cannot be excluded. Nothing in these Terms excludes or limits any rights or remedies that cannot be excluded or limited by contract under applicable law, including those arising from non-performance or breach of the Company's obligations.

Relationship with the commercial guarantee. The Customer's statutory rights are independent of the commercial guarantee in section 7. The expiry or inapplicability of that commercial guarantee shall not prevent the exercise of those rights. The reasons listed in the first paragraph do not, by themselves, constitute grounds for a refund outside the commercial guarantee, unless applicable law provides otherwise.

Procedure. To facilitate handling, the Customer shall report the issue from within the platform, by opening a ticket in the support section, identifying their purchase and describing the problem. The Company will assess the claim taking into account the information provided by the Customer and the available technical records, and will respond within a reasonable time. Where a remedy is due, the appropriate correction, re-performance, price reduction, termination or refund shall apply, respecting the rights of choice and time limits established by applicable law. This procedure does not limit other legally available means of redress.

10. LEGITIMATE USE OF THE GUARANTEE AND PREVENTION OF ABUSE

The lifetime guarantee is intended to be used in good faith.

Nevertheless, the Company may refuse or limit the refund in cases of evident abuse, such as repeated requests by the same Customer, the creation of multiple accounts in order to obtain successive refunds, or any fraudulent use of the guarantee.

11. IMPROPER USE OF THE CONTENT AND CORRECTIVE MEASURES

The Customer undertakes to use the acquired content responsibly and in accordance with applicable legislation.

The Company may suspend, restrict or cancel access to the content without prior notice where it detects conduct indicating improper use, including, without limitation, unauthorized distribution, account sharing, reproduction of the content on public platforms or any form of commercial exploitation not permitted.

In such cases, cancellation of access shall not give rise to any refund. The Company may also adopt additional measures to protect its rights, including legal action.

12. TECHNOLOGICAL PROTECTION AND ACCESS CONTROL

The Company may implement technical mechanisms intended to protect the digital content, including access control systems, download limitations, user identification, activity monitoring and any other reasonable measure.

The Customer acknowledges that these mechanisms form part of the legitimate protection of the content and undertakes not to attempt to circumvent them.

13. CUSTOMER RESPONSIBILITY IN RELATION TO USE OF THE CONTENT

The Customer shall be solely responsible for the use they make of the acquired content, including any consequence arising from that use. The Company shall not be responsible for the results obtained by the Customer, which depend on multiple factors beyond its control.

14. GENERAL PRINCIPLES OF CONTRACTUAL GOOD FAITH

The Customer acknowledges that the contractual relationship with the Company is based on the principles of good faith, transparency and legitimate use of the digital services offered.

Accordingly, the Customer undertakes not to use payment, complaint or dispute mechanisms in an abusive or fraudulent manner, or in a manner contrary to the nature of the contracted service.

15. NATURE OF THE BUSINESS MODEL AND IMMEDIATE DELIVERY

The Customer acknowledges that the Company operates under a model of digital services with immediate delivery, which means that access to the platform and to the content is enabled automatically upon confirmation of payment.

This characteristic constitutes an essential element of the contract. The applicable refund conditions are those described in section 7 (lifetime guarantee) and section 8 (subscriptions), without prejudice to the handling of subsequent disputes or claims under this agreement.

16. ANTI-FRAUD CLAUSE AND PREVENTION OF IMPROPER USE OF PAYMENT SYSTEMS

The Customer expressly undertakes not to initiate disputes, chargebacks, claims for unauthorized transactions, allegations of product not received or any other payment reversal mechanism without having first contacted the Company through its official support channels or made the request from their account in accordance with sections 7 and 8.

The Customer acknowledges that improper use of payment systems, including the submission of unfounded or misleading claims, constitutes a breach of this agreement and may be considered a form of financial fraud, commonly known as "friendly fraud".

The Customer further accepts that any attempt to obtain an economic benefit through the simultaneous use of the digital content and a request for payment reversal shall be considered unlawful conduct.

17. INFORMED CONSENT AND VALIDATION OF THE PURCHASE PROCESS

The Customer declares that, upon completing the purchase process, they were informed clearly, visibly and comprehensibly about:

• The digital nature of the product purchased
• The immediate delivery of the content
• The conditions of access to the service
• The lifetime guarantee and its conditions (section 7)
• The subscription, automatic renewal and cancellation conditions (section 8)

The Customer accepts that this information forms an essential part of the consent given and that its acceptance constitutes validation of the contract in accordance with applicable rules on electronic transactions.

18. DIGITAL EVIDENCE AND EVIDENTIARY VALIDITY

The Company may generate, store and use digital evidence in order to demonstrate the correct provision of the service and to defend its rights in the event of disputes or claims. Such evidence may include, without limitation:

• Platform access logs
• IP addresses used by the Customer
• Timestamps of access and activity
• Navigation history within the system
• Content download records
• Interactions with digital materials
• Electronic delivery confirmations
• Emails sent and received
• Technical data of the device used

The Customer acknowledges that these records constitute valid evidence under United States legislation, including the E-SIGN Act and UETA.

19. ACTIVE DEFENCE AGAINST DISPUTES AND CHARGEBACK PROCEDURES

Should the Customer initiate a dispute, chargeback or claim before a financial institution or payment platform, the Company reserves the right to submit all available evidence to demonstrate the correct performance of the service.

The Customer accepts that the Company may use technical information, activity logs and any other relevant data to contest the claim. The Customer further acknowledges that payment systems operate under specific rules that recognize the validity of digital delivery and access to the content as proof of contractual performance.

20. CONSEQUENCES OF IMPROPER USE OF CHARGEBACKS

Should the Customer initiate a chargeback or dispute without legitimate grounds, the Company may, to the maximum extent permitted by law, adopt measures intended to protect its economic and operational interests.

Such measures may include the immediate suspension or cancellation of the Customer's access to all associated products and services, the restriction of future purchases, the inclusion of the Customer in internal fraud prevention systems and the taking of legal action to recover the amounts claimed.

The Company may also claim the costs associated with handling the dispute, including administrative expenses, payment platform fees and legal fees.

21. FRAUD DETECTION SYSTEMS AND RISK ANALYSIS

The Company may implement automated fraud detection, risk analysis and identity verification systems in order to prevent fraudulent activity and protect the integrity of its operations.

These systems may analyse behavioural patterns, correlation of technical data, consistency of the information provided and any other relevant indicator. The Customer accepts that the Company may, where it detects an elevated risk, request additional information, delay activation of the service or cancel the transaction.

22. RELATIONSHIP WITH PAYMENT PLATFORMS AND CARD NETWORK RULES

The Customer acknowledges that the use of payment methods entails acceptance of the rules established by the card networks and payment platforms used.

The Customer undertakes not to make improper use of the dispute mechanisms offered by those entities, understanding that these mechanisms are designed for exceptional situations and not to circumvent the contractual conditions accepted.

23. GENERAL LIMITATION OF LIABILITY

The Customer acknowledges and accepts that the products and services offered by the Company are strictly educational, informational and training in nature, and that their use does not guarantee specific results of any kind.

The Company shall not be liable, to the maximum extent permitted by applicable law, for the results obtained by the Customer as a consequence of using the digital content, as those results depend on multiple factors beyond its control.

The Company shall likewise not be liable for indirect, incidental, consequential, special or punitive damages, including, without limitation, economic losses, loss of income, loss of business opportunities, business interruption or any other consequence arising directly or indirectly from the use or inability to use the products or services.

24. FINANCIAL LIMITATION OF LIABILITY

In any event, the Company's total aggregate liability towards the Customer, arising from any claim related to the acquisition or use of digital products, shall be limited to the amount actually paid by the Customer in the specific transaction giving rise to the claim.

The Customer accepts that this limitation constitutes a reasonable allocation of risk between the parties, taking into account the nature of the service provided.

25. EXCLUSION OF WARRANTIES

To the maximum extent permitted by applicable law, the Company expressly excludes any warranty, whether express or implied, in relation to the products and services offered.

This includes, without limitation, warranties of merchantability, fitness for a particular purpose, continuous availability, absence of errors or specific results. The Customer acknowledges that the content is provided "as is" and "as available". This disclaimer does not affect the lifetime guarantee expressly offered in section 7, which is governed by its own conditions.

26. SERVICE AVAILABILITY AND TECHNICAL LIMITATIONS

The Company will make reasonable efforts to ensure access to the digital products; however, it does not guarantee uninterrupted availability of the service.

The Customer acknowledges that access may be affected by external factors, including connection failures, system maintenance, technical incidents, cyberattacks or any other circumstance beyond the Company's control. Accordingly, the Company shall not be liable for temporary interruptions of the service.

27. FORCE MAJEURE

The Company shall not be liable for failure or delay in performing its obligations where such failure results from force majeure events or circumstances beyond its reasonable control.

Force majeure events shall include, among others, natural disasters, widespread internet failures, cyberattacks, labour disputes, government decisions, pandemics or any other unforeseeable or unavoidable event.

28. LEGAL COMPLIANCE AND LAWFUL USE

The Customer undertakes to use the products and services in accordance with applicable legislation and with these Terms and Conditions. The Company shall not be liable for any improper use the Customer may make of the content, nor for the consequences arising from such use.

29. ENTIRE AGREEMENT AND PRECEDENCE

These Terms and Conditions constitute the entire agreement between the Company and the Customer in relation to the subject matter of the contract, superseding any prior agreement, whether verbal or written. Should any provision be declared invalid or unenforceable, the remainder of the document shall continue in full force.

30. AMENDMENTS TO THE AGREEMENT

The Company reserves the right to amend these Terms and Conditions at any time, in response to legal, technical or commercial changes. Amendments will be published on the website and will take effect from the moment of publication. Continued use of the services shall imply acceptance of the amendments.

31. GOVERNING LAW AND JURISDICTION

This agreement shall be governed by and construed in accordance with the laws of the State of Florida, United States of America, without regard to its conflict of laws principles.

Any dispute arising from this agreement shall be submitted to the exclusive jurisdiction of the competent courts of that state. The Customer expressly accepts this jurisdiction as part of this agreement.

32. CUSTOMER CONTENT AND OWNERSHIP OF THEIR MATERIALS

All content the Customer enters into the platform — their clients' data, session notes, goals, answers, assessments, results, files, forms and any material of their own — remains entirely theirs. The Company acquires no ownership over that content, no licence to exploit it, no right to use it commercially, and no right to pass it to third parties.

The only authorization the Customer grants the Company is the strictly technical one needed to provide the contracted service: to host that content, process it, display it back to them, allow them to share it with the people they choose and generate the documents they request. That authorization is limited to that purpose, enables no other use and ends when the Customer deletes the content or their account.

The Customer keeps full freedom to use their methodologies, materials, exercises and tools outside the platform, with whomever they wish and however they wish, with no restriction arising from this agreement.

Sections 4 and 5 refer to the Company's own content and in no way alter the provisions of this section.

33. TOOLS CONTRIBUTED BY THE CUSTOMER TO THE CATALOGUE

The Customer may, if they wish, propose that the development team build inside the platform a tool they regularly use in their practice. This is voluntary and free of charge: there is no obligation to contribute anything, and not contributing does not affect the contracted service.

Unless specifically agreed otherwise beforehand, a tool developed from such a proposal is published in the catalogue and made available to the people who use the platform. A Customer who prefers it to stay private may agree that with the Company before development begins.

If the Customer wants the tool to carry visible credit under their name, the Company will include it. If they do not ask for it, the tool is published without attribution.

Contributing a tool does not transfer the Customer's methodology to the Company, nor does it stop them from using it. The Customer may keep using that tool and that methodology outside the platform, without limit and without needing permission.

A distinction applies between the Customer's methodology, which stays theirs under section 32, and the implementation the Company develops from it: the design, code, interface, calculations, supporting text and the tool as a whole as it works inside the platform are the Company's work and property, and fall under sections 4 and 5.

If the Customer later asks for the tool to be withdrawn from the catalogue, the parties will agree on the appropriate solution in light of the reason for the request.

34. CONTACT INFORMATION

For any query relating to these Terms and Conditions, the Customer may contact the Company at:

35. DATA PROTECTION

Where the Customer enters personal data about their own clients into the platform, the Customer acts as controller and the Company acts as processor, under the Data Processing Agreement available at /en/dpa.html.