Welcome to RE::DACT

Thank you for choosing RE::DACT! These Terms of Service (“Terms”) govern your access to and use of the RE::DACT platform, SPARK content discovery tool, RE::CORD voice transcription, and related services (collectively, the “Services”).

Please read these Terms carefully before using our Services. By accessing or using the Services, you agree to be bound by these Terms. If you do not agree to these Terms, you must not access or use the Services.

Table of Contents

§ 1. CONTRACTING ENTITY AND GOVERNING LAW

1.1 Contracting Entity

Based on your geographic location, you are entering into this agreement with one of the following legal entities:

FOR USERS IN THE UNITED STATES AND REST OF WORLD:
REDACT Inc.
1111B S Governors Ave STE 99573
Delaware, United States
Email: contact@redact-app.com
Governing Law: State of New York, USA
Jurisdiction: State and federal courts located in New York County, New York

FOR USERS IN THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, UNITED KINGDOM, AND SWITZERLAND:
REAI Prosta Spółka Akcyjna
Aleja Jana Pawła II 5/6
64-920 Piła, Poland
NIP: 7642729249
KRS: 0001218484
Email: contact@reai-strategy.com
Prawo właściwe: Prawo polskie
Sąd właściwy: Sąd powszechny właściwy dla siedziby spółki
Compliance: RODO (Rozporządzenie UE 2016/679), Dyrektywa ePrivacy, EU AI Act (Rozporządzenie UE 2024/1689)

1.2 Location Determination

Your geographic location is determined by one or more of the following factors (in order of priority):

a) The country in your billing address;
b) Your IP address at the time of registration;
c) The country you select during account setup.

If you change your location, the contracting entity and applicable governing law may change accordingly. We will notify you of such changes.

1.3 References in These Terms

Throughout these Terms, “we,” “us,” “our,” and “Company” refer to the applicable legal entity based on your location as described in Section 1.1. “You” and “your” refer to you as an individual user or the legal entity you represent.

§ 2. DEFINITIONS

“Account” means your registered user account for accessing the Services.

“AI Models” means third-party artificial intelligence models provided by OpenAI, Anthropic, Google, and other providers, integrated into our Services.

“Beta Phase” means the testing period during which the Services are provided free of charge for evaluation purposes (currently in effect as of February 14, 2026, expected to end June 2026).

“Content” means any text, articles, documents, data, images, audio recordings, or other materials uploaded, created, or processed through the Services.

“Personal Data” means any information relating to an identified or identifiable natural person, as defined under GDPR and applicable data protection laws.

“PWA” means Progressive Web App — a web application that can be installed on devices for app-like experience without app store distribution.

“RE::CORD” means our voice recording and transcription feature.

“RE::DACT” means our web-based platform for AI-assisted journalism and content creation.

“SPARK” means our content discovery tool, including both the web application and browser extension components.

“Subscription” means your paid access to the Services under a selected plan (available after Beta Phase ends).

“User Content” means Content that you upload, create, or submit to the Services.

§ 3. ACCEPTANCE OF TERMS

3.1 Binding Agreement

By clicking “I Agree,” creating an Account, or accessing the Services, you acknowledge that:

a) You have read, understood, and agree to be bound by these Terms;
b) You have read and understood our Privacy Policy;
c) You have the legal capacity to enter into this agreement;
d) If you are accepting on behalf of an organization, you have the authority to bind that organization.

3.2 Updates to Terms

We may modify these Terms at any time. When we make material changes, we will:

a) Update the “Last Updated” date at the top of these Terms;
b) Notify you via email or through the Services;
c) Provide at least 30 days’ notice before changes take effect (unless legally required to implement sooner).

Continued use of the Services after changes take effect constitutes acceptance of the modified Terms. If you do not agree to the changes, you must stop using the Services and may terminate your Account.

§ 4. ELIGIBILITY AND ACCOUNT REGISTRATION

4.1 Minimum Age Requirement

You must be at least 18 years old to use the Services.

For users in the European Union: The minimum age is 16 years (or the applicable age of consent for data processing in your Member State, whichever is higher).

If you are under the required age, you may not use the Services.

4.2 Account Registration

To use the Services, you must create an Account.

Registration Methods:

a) Email + Password:

b) Google Sign-In (SSO):

c) Other SSO providers (to be added in future):

Required Information:

For Individual Users:

For Organizational Accounts (Newsrooms/Media Organizations):

We do NOT require:

4.3 Email Verification

After registration, you must verify your email address by clicking the verification link sent to your inbox.

Unverified accounts have limited functionality until verification is complete.

If you don’t receive the verification email:

4.4 Account Security

You are responsible for:

a) Maintaining confidentiality of your password and Account credentials;
b) All activities that occur under your Account;
c) Notifying us immediately of any unauthorized use or security breach at security@redact.ai;
d) Ensuring accuracy of all information provided.

We are not liable for any loss or damage arising from your failure to protect your Account credentials.

4.5 One Account Per User

Each user may maintain only one Account. Creating multiple accounts to circumvent restrictions, abuse trials, or violate these Terms is prohibited and may result in termination of all your accounts.

4.6 Organizational Accounts

If you create an Account for an organization:

a) The organization is the “Subscriber”;
b) You represent and warrant that you have authority to bind the organization to these Terms;
c) The organization is responsible for all activities under the Account;
d) The organization must designate an “Account Owner” with administrative rights.

§ 5. DESCRIPTION OF SERVICES

5.1 RE::DACT Platform

RE::DACT is an AI-powered web application designed for journalists and media professionals, accessible at https://editor.redact-app.com/

Platform Features:

a) Content Creation Tools — AI-assisted writing, editing, and content generation
b) Fact-Checking — Automated verification and source analysis
c) Research Assistance — AI-powered research and information gathering
d) Document Analysis — Processing and analyzing documents, reports, and sources
e) Collaboration Features — Team workspaces for newsrooms and editorial teams
f) Source Protection — Tools for protecting journalistic sources and sensitive information
g) Audit Trail — Hedera Hashgraph-based transparency (PRO and Enterprise plans)

Access Methods:

Note: PWA functionality requires a modern browser with PWA support (Chrome, Edge, Safari, Firefox).

5.2 SPARK — Content Discovery Tool

SPARK helps you monitor sources and discover relevant content through two integrated components:

a) SPARK Web Application
Manage your content monitoring through “Spark Boxes”:

b) SPARK Chrome Extension
Quick web clipping and research tools:

Installation: Available via Chrome Web Store (support for other browsers planned)

How SPARK Monitoring Works:

1. You configure a “Spark Box” with topics/keywords of interest, websites to monitor (URLs or domains), and monitoring frequency (hourly, daily, weekly).

2. Our monitoring bot checks robots.txt first (respects site crawling policies), honors crawl-delay directives (follows rate limiting rules), respects disallow directives (skips restricted content), scans for content matching your topics, does NOT download or store full article text, and extracts only metadata (title, URL, publication date, brief description).

3. You receive notifications with the article title and link to original source, brief description or snippet (from page metadata), publication date and source, and relevance score based on your keywords.

4. You access content by clicking the link to read the full article on the original publisher’s website, saving notes and annotations in RE::DACT, and organizing into research projects.

Important — What SPARK Does NOT Do:

If a website blocks bots:

5.3 RE::CORD (Voice Recording & Transcription)

Voice recording and AI-powered transcription features for journalism and content creation:

Features:

Availability: Included in all paid plans (SPARKS, FREELANCER, PRO, Enterprise)

Privacy: Recordings and transcripts are encrypted and stored securely. Only you have access to your voice data.

5.4 AI-Powered Search

Integrated Search Providers:

a) Tavily AI Search — Optimized for journalistic research and fact-checking

b) Brave Search — Privacy-focused web search

c) SPARK Search — Our proprietary content discovery

Search queries and results may be processed by these third-party providers in accordance with their respective privacy policies. See Section 15 for details on third-party services.

5.5 Hedera Hashgraph Audit Trail (PRO & Enterprise Only)

For transparency, accountability, and compliance, PRO and Enterprise users have access to Auditable AI features powered by Hedera Hashgraph distributed ledger technology.

Purpose:

What is recorded on Hedera (public ledger):

a) Cryptographic hashes (SHA-256) of:

b) Metadata:

What is NOT recorded publicly:

Storage Architecture:

Data Element          | Primary Storage              | Visibility                     | On Hedera Ledger
----------------------|------------------------------|--------------------------------|---------------------
Prompt content        | Firestore + BigQuery (enc.)  | User + LLM provider + RE::DACT | SHA-256 hash only
Response content      | Firestore + BigQuery (enc.)  | User + LLM provider + RE::DACT | SHA-256 hash only
User identity         | Firestore (encrypted)        | User only                      | SHA-256 hash only
Source identity       | Firestore (encrypted)        | User only                      | Salted hash only
Article content       | Firestore (encrypted)        | User only                      | SHA-256 hash only
AI model used         | Firestore + BigQuery         | User + LLM provider + RE::DACT | SHA-256 hash only
Merkle root           | Hedera HCS                   | PUBLIC                         | Plaintext (crypto hash)
Canary checkpoint     | Hedera HCS                   | PUBLIC                         | Plaintext (hash)
Consensus timestamp   | Hedera HCS                   | PUBLIC                         | aBFT verified timestamp

Key Technical Properties:

a) Hashes are one-way:

b) Immutable:

c) Independently verifiable:

d) Privacy-preserving:

How to use Auditable AI:

a) Enable “Auditable AI” in Account settings (PRO/Enterprise plans)
b) Work normally — hashing happens automatically in background
c) Export audit trail report when needed (PDF or JSON)
d) Share verification link with editors, fact-checkers, or for publication

5.6 Service Availability and Limitations

Current Status (Beta Phase — until June 2026):

Future Status (Post-Launch — June 2026 onward):

We reserve the right to:

We will provide reasonable advance notice (typically 30 days) of material changes that adversely affect your use of paid features.

§ 6. BETA TESTING PHASE

6.1 Current Status — Free Testing Period

THE SERVICES ARE CURRENTLY IN BETA TESTING (as of February 14, 2026).

Expected Production Launch: June 2026

During this Beta testing phase:

a) All features are provided FREE OF CHARGE for testing, evaluation, and feedback purposes
b) No payment system is active — pricing is displayed for informational purposes, but no charges are applied
c) No credit card required — you can use all features without providing payment information
d) Testing and feedback encouraged — the platform is being actively developed and improved based on user feedback
e) Features may change without notice — functionality is under development and may be modified, added, or removed
f) Stability not guaranteed — you may experience bugs, errors, downtime, or service interruptions
g) Data preservation is best-effort — while we implement regular backups, we cannot guarantee against data loss during Beta

6.2 Beta User Responsibilities

As a Beta tester, you agree to:

a) Use the Services primarily for testing and evaluation purposes
b) Provide feedback on bugs, issues, and user experience (optional but greatly appreciated)
c) Report technical problems, security issues, or unexpected behavior to support@redact.ai
d) Understand that data preservation during Beta is best-effort only
e) Not rely on the Services for critical production workflows during the testing phase
f) Accept that features may change, be removed, or function differently than expected
g) Participate constructively in the Beta community (if applicable)

Recommended practices during Beta:

6.3 Transition to Paid Service

Expected Production Launch: June 2026

When we transition from Beta to paid service:

a) We will notify all Beta users at least 60 days in advance via email and in-app notifications
b) Pricing plans will be activated (see Section 7 for details)
c) You will have the following options:

d) Beta users may receive special early adopter benefits:

e) Your data will be preserved during transition:

f) Grace period:

6.4 No Guarantees During Beta

USE OF BETA SERVICES IS ENTIRELY AT YOUR OWN RISK.

During the Beta phase, we provide the Services “AS IS” and “AS AVAILABLE” with:

By participating in Beta, you acknowledge and accept these limitations.

6.5 Beta Termination Rights

We reserve the right to:

a) End the Beta phase at any time with reasonable notice (minimum 30 days for active users)
b) Limit the number of Beta users or implement waitlists for new registrations
c) Modify, add, or remove features during Beta testing without prior notice
d) Terminate individual Beta accounts for violations of these Terms
e) Reset or migrate Beta data as necessary for technical improvements
f) Change the expected production launch date (June 2026 is an estimate, not a guarantee)

If we decide not to proceed to production launch:

§ 7. SUBSCRIPTION PLANS AND PRICING (Post-Beta)

Note: This section describes our planned pricing structure for when we launch paid service (expected June 2026). During Beta (current phase), all features are free and no payments are collected.

7.1 Available Subscription Plans

Upon production launch, we will offer the following tiers:

SPARKS PLAN - $10/month

Includes:

Annual billing: 20% discount = $96/year (save $24)

Best for: Freelance journalists focused primarily on content discovery and monitoring

Limitations:

FREELANCER PLAN - $25/month

Includes:

Annual billing: 25% discount = $225/year (save $75)

Best for: Independent journalists, freelance writers, and solo content creators

Typical limits (subject to change):

RE::DACT PRO - $50/month

Includes:

Annual billing: 30% discount = $420/year (save $180)

Best for: Professional journalists requiring accountability, transparency, compliance, and reliability

Typical limits:

ENTERPRISE - Custom Pricing

Includes:

To get pricing: Contact contact@reai-strategy.com with:

Best for: Newsrooms, media organizations, publishing companies, editorial teams with 5+ users

Typical features:

7.2 Pricing Currency and Regions

Prices will be displayed and charged in:

! Approximate conversions: 40zł, 100zł, 200zł (based on current exchange rates) Exchange rates are updated periodically (typically monthly). The final price shown at checkout is

based on:

Currency conversion:

7.3 Annual Billing Discounts

Save money with annual billing commitment:

Annual subscription details:

7.4 Usage Limits and Fair Use

Each plan includes specific usage limits for:

a) AI queries per month - Number of prompts sent to AI models (GPT, Claude, Gemini, etc.)

b) Content storage - Total storage for articles, documents, notes, and uploads

c) SPARK monitored sources - Number of websites/feeds you can actively monitor

d) RE::CORD transcription hours - Audio recording and transcription capacity per month

e) Team members (Enterprise only) - Number of user accounts

If you exceed your plan limits:

a) Soft limits (first occurrence):

b) Hard limits:

c) Options when limits are reached:

d) Enterprise plans:

Fair Use Policy:

Even for "unlimited" Enterprise plans, usage must be reasonable and in good faith:

We will contact you if usage appears inconsistent with normal business operations. Exact limits for each plan will be published on our pricing page at https://redact-app.com/ before production launch.

7.5 Free Tier (Availability To Be Determined)

We may offer a limited Free tier after production launch, subject to:

Potential features:

Availability:

7.6 Plan Changes (Upgrades and Downgrades)

Upgrades (moving to higher-priced plan):

a) Take effect immediately upon confirmation

b) Prorated credit applied for unused time on previous plan

c) New plan limits and features accessible immediately

d) Next billing date remains the same (unless switching from monthly to annual)

e) Example:

Downgrades (moving to lower-priced plan):

a) Take effect at next billing cycle (end of current paid period)

b) No refund for current billing period

c) Warning if downgrade affects your usage:

d) Grace period:

Switching billing frequency:

a) Monthly to Annual:

b) Annual to Monthly:

7.7 Pricing Changes

We reserve the right to change our pricing at any time, but will honor the following commitments:

For existing subscribers:

a) 60 days advance notice of any price increase via email

b) Price changes apply at your next renewal date (not mid-subscription)

c) Current subscription period honored at original price

d) You may cancel before renewal to avoid price increase

e) Grandfathered pricing may be offered at our discretion for:

For new subscribers:

a) New pricing applies immediately upon sign-up

b) No grandfathered rates for new customers after price change

c) Pricing page always shows current rates

Price decreases:

Example scenario:

§ 8. PAYMENT TERMS (Applicable After Beta)

Note: During Beta (current phase through June 2026), no payments are processed and this section does not apply. This section will become effective when we launch paid subscriptions.

8.1 Payment Processing

When we launch paid plans:

a) All payments will be processed through Stripe, a certified PCI DSS Level 1 Service Provider

b) Supported payment methods:

c) Payment information security:

d) By subscribing, you agree to:

8.2 Billing Cycles and Timing

Billing frequency options:

a) Monthly subscriptions:

b) Annual subscriptions:

When billing begins:

a) Immediate subscription (no free trial):

b) Free trial subscription (if offered):

Billing day changes:

8.3 Automatic Renewal

Subscriptions automatically renew unless you cancel before the renewal date.

By subscribing, you authorize us (via Stripe) to:

a) Charge your payment method automatically for each renewal period

b) Update payment information if your card is replaced or renewed (via Stripe Account Updater)

c) Continue billing until you explicitly cancel or we terminate your Account

d) Retry failed payments according to our retry schedule (Section 8.4)

You will receive:

a) Email confirmation after each successful payment with:

b) Renewal reminder 7 days before next charge:

c) Annual renewal reminder (for annual plans):

To prevent automatic renewal:

8.4 Failed Payments

If a payment fails (insufficient funds, expired card, declined transaction, etc.):

Our retry schedule:

a) Day 0 (payment date):

b) Day 3:

c) Day 7:

d) Day 10:

During suspension (Day 7-10):

Restoring access:

You remain responsible for:

8.5 Taxes

Prices displayed do not include applicable taxes unless explicitly stated as "tax-inclusive."

For EU/EEA/UK Customers:

VAT (Value Added Tax) applies based on your location:

a) For individual consumers:

b) For businesses with valid EU VAT number:

c) VAT invoices:

VAT number validation:

For US Customers:

Sales tax may apply depending on your state:

a) Tax nexus:

b) Example:

c) Tax exemption:

For Other Countries:

a) GST/VAT equivalent taxes may apply based on local law

b) Tax rates determined by Stripe based on your billing address

c) Compliance with local tax law is handled via Stripe Tax

Your responsibilities:

a) Provide accurate billing information including correct address and tax ID

b) Pay all applicable taxes in addition to subscription price

c) Notify us of tax status changes (e.g., business registration, VAT number)

d) Retain tax invoices for your records and tax filing

We are responsible for:

8.6 Invoices and Receipts

We provide electronic invoices for all transactions:

Delivery: a) Sent via email immediately after successful payment

b) Available in Account " Billing " Invoices section

c) Can be downloaded as PDF at any time

d) Retained for 7 years for tax compliance purposes

Invoice contents:

a) For EU customers (VAT invoices):

b) For US customers:

c) For other customers:

For businesses:

To receive invoices with your company details:

a) Update billing information in Account " Settings " Billing

b) Provide:

Corrected invoices:

If you need a corrected invoice (wrong company name, address, VAT number, etc.):

a) Email contact@reai-strategy.com within 30 days of original invoice

b) Provide:

d) Original invoice will be marked as "Cancelled - Replaced by [new invoice number]”

Note: Corrections after 30 days may not be possible due to tax reporting deadlines.

8.7 Currency Conversion and Foreign Transaction Fees

If your payment method uses a different currency than your selected billing currency:

a) Currency conversion:

b) Foreign transaction fees:

To avoid currency conversion fees:

a) Choose billing currency that matches your payment method currency

b) Use a credit card with no foreign transaction fees

c) For EU customers: Use EUR billing + EUR-denominated card

d) For US customers: Use USD billing + US-issued card

Multi-currency support:

§ 9. CANCELLATION AND REFUNDS

9.1 Cancellation by You

You may cancel your Subscription at any time through:

a) Account settings " Billing " "Cancel Subscription", OR

b) Email to contact@reai-strategy.com with subject "Cancel Subscription" and your account email

Effect of Cancellation:

a) Access continues until end of current billing period:

b) No partial refunds for early cancellation:

c) Account status after cancellation:

d) Cancellation confirmation:

To reactivate:

9.2 Refund Policy - 7-Day Money-Back Guarantee

We offer a full refund if you are dissatisfied with your paid subscription.

Eligibility:

a) Request must be made within 7 calendar days of:

b) One refund per user/Account:

c) Applicable to:

How to request a refund:

a) Email contact@reai-strategy.com within 7 days of purchase

b) Subject line: "Refund Request - [Your Account Email]"

c) Include:

d) We will process your request within 2 business days

e) Refund issued to original payment method within 5-10 business days

f) Access to paid features terminates immediately upon refund approval

Refund does NOT apply to:

a) After 7-day period - all sales are final beyond guarantee period

b) Enterprise custom contracts - refund terms specified in your agreement

c) Add-on purchases (if we offer them in future)

d) Accounts terminated for violations - no refund for Terms violations

e) Second/subsequent refund requests - only one refund per Account

f) Chargebacks - filing a chargeback forfeits refund eligibility and results in Account termination

Important notes:

9.3 Our Right to Suspend or Terminate

We may suspend or terminate your Account and access to the Services if:

Violations:

a) You violate these Terms or our Acceptable Use Policy (Section 13)

b) Payment fraud or chargeback abuse

c) Unauthorized use of another person's Account

d) Abusive behavior toward our staff or other users

e) Security threats - using Services to attack others, distribute malware, etc.

Non-Payment:

f) Payment fails and you don't update payment information within 10 days (Section 8.4)

g) Disputed charges resolved in our favor but you refuse to pay

Inactivity:

h) Account inactive for more than 12 consecutive months with no login activity

Legal Requirements:

i) Required by law - court order, subpoena, regulatory requirement

j) Sanctions compliance - you are in or become subject to sanctions (Section 23.9)

k) Service discontinuation - we cease operations (minimum 90 days notice)

In case of termination for violation:

a) Effective immediately:

b) No refund:

c) Data handling:

d) Account ban:

Appeal process:

If you believe termination was in error: a) Email legal@redact.ai within 14 days b) Provide explanation and evidence c) We will review and respond within 7 business days d) Our decision is final

9.4 Data Retention After Cancellation or Termination

What happens to your Content when subscription ends:

During 30-Day Grace Period:

a) Your Content is retained but inaccessible:

b) You may reactivate at any time:

c) You may request data export:

d) Read-only access option:

After 30-Day Grace Period:

a) Permanent deletion from active systems:

b) Backup retention (90 days maximum):

c) What is NOT deleted:

d) Metadata retained (anonymized):

To preserve your data before deletion:

Option 1: Use Account settings (if available):

Option 2: Email request:

Option 3: Reactivate within 30 days:

We strongly recommend:

GDPR Right to Erasure (EU users):

If you want immediate deletion (waiving 30-day grace period):

§ 10. RIGHT OF WITHDRAWAL (EU CONSUMERS ONLY)

This section applies ONLY to individual consumers (not businesses) in the European Union, EEA, UK, and Switzerland. Under EU Consumer Rights Directive 2011/83/EU, you have the right to withdraw from this contract within 14 days without giving any reason.

10.1 Withdrawal Period

The withdrawal period expires 14 calendar days from:

a) The date you subscribe to a paid plan (date of first payment), OR

b) The date you agree to these Terms (if earlier) The later of these two dates determines the start of your withdrawal period.

10.2 How to Exercise Right of Withdrawal

To exercise your right of withdrawal, you must inform us of your decision by a clear statement:

Contact methods:

a) Email: contact@reai-strategy.com

b) Subject: "Right of Withdrawal - EU Consumer"

c) Include:

Model Withdrawal Form (optional but recommended):

To: REAI Prosta Spółka Akcyjna contact@reai-strategy.com I hereby give notice that I withdraw from my contract for the following service: Service: RE::DACT Subscription - [SPARKS/FREELANCER/PRO] Ordered on: [Date] Name: [Your full name] Account email: [Your email] Date: [Today's date] [Your signature if sent by post] You may use this form but are not obliged to. Any clear statement of withdrawal is sufficient.

10.3 Effects of Withdrawal

If you withdraw from this contract, we will reimburse:

What we reimburse:

a) All payments received from you, including:

b) Timeline:

c) Method:

Important: We may withhold reimbursement until we have received proof that you have returned any goods (not applicable to digital services) or until you have supplied evidence of having returned the goods.

10.4 Proportionate Payment for Services Already Provided

If you requested that Services begin during the 14-day withdrawal period:

You acknowledge and agree that by using the Services during the withdrawal period, you have:

a) Expressly requested immediate access to digital services

b) Agreed that we begin providing Services immediately

c) Acknowledged that you may forfeit your withdrawal right once Services are fully performed

Partial withdrawal (if you use Services then withdraw):

If you withdraw before Services are fully performed:

a) You pay for the proportionate amount of Services provided up to withdrawal

b) Proportionate amount calculated based on:

c) We will inform you of the proportionate amount before processing refund

10.5 Waiver of Withdrawal Right (Digital Content)

By clicking "I Agree" and beginning to use the Services, you acknowledge:

a) Express consent to immediate access to digital services during withdrawal period

b) Acknowledgment that your right of withdrawal may be lost once:

10.6 Business Customers - Withdrawal Right Does NOT Apply

This right of withdrawal does NOT apply if:

a) You are a business, company, or organization (even sole proprietorship)

b) You use Services for professional or commercial purposes

c) You register using a business email or provide business VAT number

d) You select "Business" or "Organization" during registration

Business customers are subject to:

10.7 Withdrawal vs. Money-Back Guarantee

You have TWO separate rights (both apply to EU consumers):

Right

Period

EU Withdrawal Right

14 days

No reason needed

EU consumers only

Money-Back Guarantee

7 days

No reason (but appreciated)

All users worldwide

Reason Required

Applies To

If you're an EU consumer:

We honor the more favorable term in all cases.

§ 11. USER CONTENT AND INTELLECTUAL PROPERTY RIGHTS

11.1 Your Ownership of User Content

You retain all ownership rights to any Content you create, upload, or submit through the Services

("User Content"), including:

a) Articles, documents, written works, and editorial content

b) Research materials, notes, annotations, and highlights

c) Voice recordings and transcripts (RE::CORD)

d) SPARK Boxes and curated source lists

e) Comments, feedback, and collaborative contributions

f) Any other original content you create using the Services We do not claim ownership of your User Content. Your User Content remains your property before, during, and after your use of our Services.

11.2 License to Us

By uploading or creating User Content, you grant us a limited, non-exclusive, worldwide, royaltyfree, sublicensable license to:

What we can do:

a) Store and host your User Content on our servers (Google Cloud Platform)

b) Process and display your User Content within the Services

c) Transmit to AI providers (OpenAI, Anthropic, Google) to provide AI features you request

d) Use AI Models to analyze, edit, translate, summarize, or generate related content at your explicit request

e) Create backups and copies for data protection, disaster recovery, and service continuity

f) Cache and optimize for performance (CDN, compression, format conversion)

g) Create derivative works necessary to provide Services (e.g., thumbnails, previews, excerpts)

h) Share with service providers as necessary (Hedera for audit trail, Tavily/Brave for search)

License limitations:

This license:

a) Exists only for the duration of your use of the Services

b) Is limited to providing and improving the Services for you

c) Does NOT grant us the right to:

d) Terminates automatically when you:

e) May survive termination only for:

All sublicenses are subject to confidentiality obligations and use restrictions.

11.3 AI-Generated Content

When you use our AI features to generate, edit, translate, summarize, or enhance content:

Ownership of AI Outputs:

a) You own the AI-generated output, subject to limitations below

b) We do not claim ownership of AI-generated content you create using our Services

c) AI providers (OpenAI, Anthropic, Google) do not claim ownership under their enterprise API terms

Important Limitations and Disclaimers:

a) Originality not guaranteed:

b) Copyright considerations:

c) You are solely responsible for:

d) No warranties regarding AI output:

Third-party AI provider terms:

When you use AI features, you also agree to be bound by the terms of our AI providers:

Enterprise API zero-retention:

11.4 Responsibility for User Content

You represent and warrant that:

a) You own or have rights to all User Content you upload, create, or submit

b) Your User Content does not infringe any third-party rights, including:

c) Your User Content complies with:

d) You have obtained all necessary permissions:

You are solely responsible for:

a) The accuracy, legality, and reliability of your User Content

b) Ensuring compliance with journalistic ethics, editorial standards, and professional codes of conduct

c) Obtaining necessary rights, permissions, and licenses before publishing

d) Consequences of publishing or distributing your User Content

e) Any legal claims arising from your User Content (defamation, copyright infringement, privacy violations, etc.)

We are NOT responsible for:

11.5 Our Intellectual Property

All rights, title, and interest in the Services and related intellectual property, including but not limited to:

a) Software and code:

b) Trademarks and branding:

c) Content and documentation:

d) Designs and interfaces:

e) Data and analytics:

f) Proprietary systems:

are owned exclusively by REDACT Inc., REAI P. S.A., and/or our licensors.

Your limited license to use:

We grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Services in accordance with these Terms.

You may NOT:

a) Copy, modify, or create derivative works from the Services or any component thereof

b) Reverse engineer, decompile, or disassemble the Services or attempt to derive source code

c) Remove, alter, or obscure any copyright, trademark, or proprietary notices

d) Use our trademarks, logos, or branding without prior written permission

e) Frame, mirror, or create links to the Services that misrepresent relationship or endorsement

f) Scrape, crawl, or use automated tools to access the Services (except SPARK monitoring which respects robots.txt)

g) Rent, lease, sell, sublicense, or transfer your access to the Services

h) Use the Services to build competing products or reverse engineer our features for competitive purposes

Permitted uses of our trademarks:

You may:

You must:

11.6 Feedback and Suggestions

If you provide us with feedback, suggestions, ideas, recommendations, or other input regarding the

Services ("Feedback"):

We may use your Feedback without any obligation to you:

a) No compensation required - we are not obligated to pay you for Feedback

b) No attribution required - we are not obligated to credit you for implemented ideas

c) No approval needed - we may implement, modify, or reject Feedback at our discretion

d) No confidentiality - unless covered by separate written agreement, Feedback is non-confidential You grant us an unrestricted, perpetual, irrevocable, worldwide, royalty-free license to:

a) Use, implement, modify, and commercialize your Feedback in any manner

b) Incorporate Feedback into the Services or create new products based on Feedback

c) Sublicense Feedback to third parties (e.g., white-label partners)

d) Create derivative works from Feedback

e) Disclose Feedback publicly (e.g., in product announcements, marketing materials)

You waive any rights to:

a) Compensation or royalties for implemented Feedback

b) Credit or attribution (though we may choose to credit you at our discretion)

c) Approval of how Feedback is used or implemented

d) Ownership or co-ownership of features developed from your Feedback

e) Patent claims related to Feedback (to the extent permitted by law) Providing Feedback is entirely voluntary. You are not required to provide suggestions, and withholding Feedback does not affect your use of the Services.

Examples of Feedback:

What is NOT Feedback:

11.7 DMCA and Copyright Infringement

We respect intellectual property rights and comply with the Digital Millennium Copyright Act (DMCA) (17 U.S.C. § 512).

If you believe your copyrighted work has been infringed on our Services:

Submit a DMCA Takedown Notice to our Copyright Agent:

Email: contact@reai-strategy.com Subject: DMCA Takedown Notice

Your notice must include:

a) Identification of copyrighted work claimed to be infringed:

b) Identification of infringing material:

c) Your contact information:

d) Statement of good faith belief:

e) Accuracy statement:

f) Your physical or electronic signature

We will:

a) Investigate promptly (typically within 2-3 business days)

b) Remove or disable access to allegedly infringing content if claim appears valid

c) Notify the user who posted the content (if identifiable)

d) Provide copy of your notice to the alleged infringer

e) Terminate repeat infringers - users with multiple valid DMCA claims will have accounts permanently terminated

DMCA Counter-Notification:

If your content was removed and you believe it was removed by mistake or misidentification: Submit a Counter-Notification to: legal@redact.ai Subject: DMCA Counter-Notification

Your counter-notice must include:

a) Your contact information (name, address, email, phone)

b) Identification of removed content and its prior location

c) Statement under penalty of perjury:

We will:

a) Forward your counter-notification to the original complainant

b) Inform them they have 10-14 business days to file a lawsuit

c) Restore your content within 10-14 business days unless the complainant files a court action and notifies us

d) If lawsuit is filed, content remains disabled pending court resolution

False claims:

Submitting false or bad-faith DMCA notices or counter-notices may result in:

a) Liability for damages under 17 U.S.C. § 512(f), including:

b) Account termination for submitting knowingly false claims

c) Legal action - we may pursue claims for perjury, fraud, or abuse of process

d) Reporting to authorities - false DMCA claims may be criminal offenses

Repeat infringer policy:

Users with three (3) or more valid DMCA claims against their content will:

a) Have their Account permanently terminated

b) Be banned from creating new accounts

c) Forfeit any remaining Subscription period (no refund)

d) Have 30 days to export data before permanent deletion

Questions about DMCA process:

Email legal@redact.ai with subject "DMCA Question" - we can clarify the process but cannot provide legal advice.

§ 12. AI-POWERED FEATURES AND DATA USAGE

12.1 Third-Party AI Providers

We integrate AI models from leading providers to power our features:

a) OpenAI - GPT-4, GPT-3.5-turbo, and other models

b) Anthropic - Claude 3 (Opus, Sonnet, Haiku) and future models

c) Google - Gemini Pro, Gemini Ultra, PaLM, and other AI services

d) Other providers as we integrate additional AI capabilities

When you use AI features:

a) Your input prompts and Content are transmitted to these providers' servers:

b) Processing occurs on provider infrastructure:

c) We use enterprise API plans with:

International data transfers (EU " USA):

For users in the European Union, EEA, UK, and Switzerland:

a) Legal mechanisms protecting your data:

b) Certified providers (as of February 2026):

c) Your consent:

d) Transfer Impact Assessment:

Third-party AI provider terms:

When using AI features, you also agree to:

a) OpenAI Terms of Use (Business):

b) Anthropic Commercial Terms:

c) Google Cloud AI/ML Terms:

Important: We do NOT control these third-party providers and are NOT responsible for:

We ARE responsible for:

12.2 Search Providers

We integrate search engines to power research and fact-checking features:

a) Tavily AI Search:

b) Brave Search:

When you use search features:

a) Your search queries are sent to these providers:

b) Search providers may log queries according to their privacy policies:

c) We anonymize requests where possible:

You agree to search provider terms:

We are NOT responsible for:

12.3 SPARK Content Discovery and Monitoring

How SPARK monitoring bot operates:

SPARK helps you discover relevant content by monitoring websites you specify. Our monitoring

system operates as follows:

a) Your Configuration:

You create "Spark Boxes" containing:

b) Our Monitoring Bot Behavior:

IMPORTANT: We respect web standards and publisher rights.

1. robots.txt compliance (ALWAYS checked first):

2. Before accessing any website, our bot:

1. - Fetches robots.txt from domain root (e.g., example.com/

2. robots.txt)

3. - Parses User-agent rules

4. - Honors all Disallow directives

5. - Respects Crawl-delay instructions

6. - Obeys Allow directives (if specified)

1. If robots.txt permits crawling:

2. !

3. !

! ! !

1. Scans pages matching your topics

2. Extracts metadata only:

3. # Article title (from <title> or <h1>)

4. # Publication date (from metadata or structured data)

5. # Author (if available in metadata)

6. # Brief description (from meta description tag)

7. # URL of the article

8. Does NOT download full article text

9. Does NOT bypass paywalls or authentication

10. Does NOT store copyrighted article content

If robots.txt blocks our bot:

! ! !

SPARK cannot monitor that site automatically You are notified: "Site blocks automated monitoring - use manual capture" You can still use SPARK Chrome extension to manually save articles (by visiting yourself)

10. Rate limiting and politeness:

! Respects Crawl-delay directive (typically 1-5 seconds between requests) ! Default: Maximum 1 request per 2 seconds to any single domain ! Distributed monitoring (not all sites checked simultaneously) ! Backs off if site returns 429 (Too Many Requests) or 503 (Service Unavailable) !

11. User-Agent identification:

User-Agent: SPARK-Bot/1.0

1. !

2. !

3. !

Clear identification as automated crawler Link to documentation explaining bot purpose Contact information for webmasters

c) What You Receive (Notifications):

When relevant content is discovered:

a) Email or in-app notification containing:

b) Saved to your Spark Box:

c) To read full article:

d) What SPARK Does NOT Do:

We do NOT:

We DO:

e) Webmaster Opt-Out:

If you are a website owner and wish to block SPARK monitoring:

Option 1: robots.txt (recommended):

User-agent: SPARK-Bot Disallow: /

Option 2: Contact us:

f) Compliance with Publisher Terms:

Users are responsible for:

12.4 AI Training on Your Data

We may use anonymized data from your usage to improve our Services.

What data may be used:

a) Anonymized AI interactions:

b) Aggregated usage statistics:

c) Anonymized SPARK data:

How we protect your privacy:

a) Remove ALL personal identifiers before any analysis:

b) Aggregate across many users:

c) Legitimate purposes only:

What we NEVER use for training or share:

Opt-Out of AI training:

You may opt out of having your anonymized data used for AI training:

a) In Account Settings:

b) Via email:

Opting out does NOT affect:

Third-party AI providers (OpenAI, Anthropic, Google):

Under our enterprise API agreements:

12.5 Hedera Hashgraph Audit Trail (Expanded)

(Available for RE::DACT PRO and ENTERPRISE plans only) This section expands on the technical details introduced in Section 5.5.

Purpose and Use Cases:

The Hedera-based audit trail provides:

a) Accountability:

b) Integrity verification:

c) Compliance:

d) Source protection:

Technical Implementation:

Step 1: Content Hashing

When you create or edit content with AI assistance:

1. Your prompt " SHA-256 hash (64-character hexadecimal)

Example: 8f3a2b1c4d5e6f7a8b9c0d1e2f3a4b5c... 2. AI response " SHA-256 hash

Example: 1a2b3c4d5e6f7a8b9c0d1e2f3a4b5c6d... 3. Final article " SHA-256 hash

Example: 6d5c4b3a2f1e0d9c8b7a6f5e4d3c2b1a… Step 2: Hierarchical Merkle Tree

Hashes organized in parent-child genealogy:

Article Root Hash $%% Paragraph 1 Hash & $%% Prompt Hash (what you asked AI) & '%% Response Hash (what AI generated) $%% Paragraph 2 Hash & $%% Prompt Hash & '%% Response Hash '%% Metadata Hash $%% Author $%% Timestamp '%% AI Model Used Key property: If you edit ANY parent node, ALL descendant hashes change. This creates tamperevident genealogy - you can't modify one part without breaking the entire chain. Step 3: Hedera Consensus Service (HCS) Anchoring

Periodically (e.g., every 5 minutes or on-demand):

1. Calculate Merkle Root of all recent hashes 2. Submit to Hedera HCS topic

3. Hedera network consensus:

- Timestamp (Byzantine Fault Tolerant, cannot be forged) - Order (guaranteed sequence) - Immutability (permanent, cannot be deleted or modified)

4. Receive Consensus Timestamp + Topic Sequence Number

Example: 2026-02-14T23:17:31.123456Z, sequence #145678 Step 4: Canary Checkpoints (Quantum-Inspired)

Random "canary" hashes inserted periodically:

1. Every 100th hash is a canary (random data) 2. Stored encrypted in your account

3. If someone unauthorized accesses system:

- They cannot know which hashes are canaries - Modifying or observing canaries triggers detection - Similar to quantum key distribution (observation = collapse)

4. Detection mechanism:

- Canaries verified on each login - If missing or modified " alert sent immediately - Indicates potential unauthorized access or tampering

What goes on public Hedera ledger:

Public/Private

Data Element

Stored Where

Merkle Root Hash

Hedera HCS Topic

PUBLIC

❌ No (one-way hash)

Canary Checkpoint Hash

Hedera HCS Topic

PUBLIC

❌ No (random data hash)

Consensus Timestamp

Hedera HCS Topic

PUBLIC

✅ Yes (plaintext timestamp)

Topic Sequence Number

Hedera HCS Topic

PUBLIC

✅ Yes (integer)

Your prompt content

Firestore (encrypted)

PRIVATE

❌ No (AES-256 encrypted)

AI response content

Firestore (encrypted)

PRIVATE

❌ No (encrypted)

Article content

Firestore (encrypted)

PRIVATE

❌ No (encrypted)

Your identity

Firestore (encrypted)

PRIVATE

❌ No (encrypted)

Source identities

Firestore (encrypted)

PRIVATE

❌ No (salted hash)

Privacy guarantees:

Can Reverse?

a) Public ledger contains ONLY hashes:

b) Hashes reveal ZERO information about content:

c) Your content stays encrypted:

Verification process (for third parties):

If you want to prove authenticity of published article:

1. Export audit trail report from RE::DACT (PDF or JSON)

2. Report contains:

- Article text (that you choose to share publicly) - SHA-256 hash of article - Hedera consensus timestamp - Topic ID and sequence number

3. Anyone can verify:

Step 1: Hash the published article text Step 2: Compare to hash in audit report Step 3: Check Hedera public ledger for that hash + timestamp Step 4: Confirm match " article is authentic and unmodified

4. Verification tools:

- Hedera explorer: https://hashscan.io - RE::DACT verification page: https://redact.ai/verify - Command-line tools (open source)

Cost:

Limitations:

a) Not quantum-resistant (yet):

b) Hashes are forever:

c) Requires trust in Hedera:

Disabling Auditable AI:

If you don't want Hedera audit trail (PRO/Enterprise users):

12.6 Human Oversight and AI Limitations (CRITICAL - READ CAREFULLY)

IMPORTANT: AI is a tool to assist humans, not replace human judgment.

AI may produce:

a) Factual errors ("hallucinations"):

b) Biased content:

c) Non-original content:

d) Inappropriate or harmful content:

e) Lack of context and nuance:

YOU are responsible for:

a) Reviewing ALL AI-generated content before publication:

b) Fact-checking with original sources:

c) Ensuring editorial quality:

d) Verifying originality:

e) Disclosing AI use appropriately:

f) Taking responsibility for published work:

NEVER:

a) Maintain human editorial oversight for all published content

b) Use AI as research assistant, not final authority

c) Apply same verification standards to AI outputs as to any draft

d) Combine AI tools with traditional journalism practices

e) Stay updated on AI limitations and best practices

f) Consult professional guidelines (e.g., AP Stylebook on AI use)

Professional standards:

Many journalism organizations have issued guidance on AI use:

Familiarize yourself with and follow your industry's standards.

Disclaimers and warranties:

We make NO WARRANTIES that AI outputs are:

You use AI features AT YOUR OWN RISK.

We are NOT liable for:

See Section 17 (Disclaimers and Limitation of Liability) for complete details.

12.7 AI Disclosure Compliance.

In accordance with the EU AI Act (Regulation 2024/1689), users are solely responsible for ensuring that any AI-generated content published through the Services is appropriately labeled as such, where required by law. You acknowledge that you maintain full editorial control and must perform a "human-in-the-loop" review of all AI outputs before any public dissemination to ensure accuracy and prevent misinformation.

§ 13. ACCEPTABLE USE POLICY

13.1 Permitted Use

You may use the Services for lawful purposes related to journalism, content creation, research, and

media production, including:

Permitted activities:

a) Journalistic work:

b) Content creation:

c) Research and analysis:

d) Collaboration:

e) Professional services:

Use with integrity:

When using the Services, you agree to:

13.2 Prohibited Activities

You agree NOT to use the Services for any of the following prohibited purposes:

A. Content Violations

a) Misinformation and Disinformation:

You may NOT create, generate, or distribute:

Note: Satire, parody, and clearly labeled fiction are permitted.

b) Defamatory, Libelous, or Slanderous Content:

You may NOT create content that:

c) Intellectual Property Infringement:

You may NOT:

d) Privacy Violations:

You may NOT:

e) Hateful, Violent, or Discriminatory Content:

You may NOT create content that:

Legitimate news reporting on these topics is permitted with appropriate context.

f) Sexually Explicit or Exploitative Content:

You may NOT create, upload, or share:

Legitimate journalism about sexual topics (e.g., sex trafficking investigations) is permitted.

g) Impersonation and Deception:

You may NOT:

B. Technical Violations

a) Malicious Code and Security Threats:

You may NOT:

b) Hacking and Unauthorized Access:

You may NOT:

Authorized security research with responsible disclosure is permitted - contact@reai-strategy.com

c) Service Disruption and Abuse:

You may NOT:

d) Circumvention and Exploitation:

You may NOT:

C. Commercial Misuse

a) Unauthorized Reselling:

You may NOT:

Enterprise white-label partnerships available - contact@reai-strategy.com

b) Illegal Activities:

You may NOT use the Services for:

c) Spam and Unsolicited Communications:

You may NOT:

Legitimate email newsletters with proper consent are permitted.

d) Trademark and Brand Abuse:

You may NOT:

D. Account and Usage Abuse

a) Multiple Accounts:

You may NOT:

One account per user. Organizations should use Enterprise multi-user plans.

b) Payment Fraud:

You may NOT:

c) Data Mining and Competitive Intelligence:

You may NOT:

Legitimate competitive analysis and reviews are permitted.

13.3 Enforcement

If we determine (in our sole discretion) that you have violated this Acceptable Use Policy:

Warning (for minor or first-time violations):

a) Email notification detailing the violation

b) Request to cease the violating activity immediately

c) Opportunity to cure within specified timeframe (typically 24-48 hours)

d) Warning recorded on your Account

Suspension (for repeated or serious violations):

a) Temporary Account suspension:

b) Notification:

c) During suspension:

Termination (for severe or repeat violations):

a) Immediate and permanent termination for:

b) Account permanently closed:

c) No refund:

d) Data handling:

e) Legal action:

Automated enforcement:

a) Automated detection systems monitor for:

b) Immediate automated suspension for:

c) Human review follows automated actions within 24 hours

Appeals:

If you believe enforcement action was taken in error:

a) Email: contact@reai-strategy.com

b) Subject: "Appeal - [Account Email]"

c) Include:

Note: Appeals for severe violations (CSAM, terrorism, illegal activity) will not be considered.

13.4 Reporting Violations

If you become aware of violations of this Acceptable Use Policy by other users:

How to report:

a) Email: contact@reai-strategy.com

b) Subject: "Report Violation - [Type]"

c) Include:

What happens after you report:

a) Acknowledgment within 2 business days

b) Investigation:

d) Outcome notification to reporter (if you provided contact info): We will inform you that action was taken (or not) We will NOT disclose specific details (privacy reasons)

Reporting illegal content:

For serious illegal content (CSAM, terrorism, etc.):

a) Also report to authorities:

b) We will cooperate with law enforcement investigations

Responsible disclosure (security vulnerabilities):

If you discover a security vulnerability in our Services:

a) Email: contact@reai-strategy.com

b) Do NOT:

c) We will:

d) Bug bounty program details: https://redact.ai/security/bug-bounty

False reports:

Submitting false or bad-faith reports:

a) May result in your Account being suspended or terminated

b) May constitute abuse of reporting system

c) Wastes resources that could be used for legitimate reports

Please report only genuine violations.

§ 14. PRIVACY AND DATA PROTECTION

14.1 Privacy Policy

Our collection, use, storage, and protection of your personal data is governed by our Privacy Policy, which is incorporated into these Terms by reference. Please review our Privacy Policy at: https://redact-app.com

The Privacy Policy covers:

By using the Services, you consent to:

The Privacy Policy may be updated from time to time. Material changes will be notified via email or in-app notification at least 30 days before taking effect.

14.1.1 Business User DPA.

If you use the Services in a professional or institutional capacity (e.g., as a Newsroom or Media Organization) and process personal data of third parties, our Data Processing Agreement (DPA) is hereby incorporated by reference into these Terms. You acknowledge that for such data, you act as the "Data Controller" and RE::DACT acts as the "Data Processor" under GDPR.

14.2 GDPR Compliance (For Users in the European Union, EEA, UK, and

Switzerland) We comply with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and related data protection laws.

Lawful basis for processing your personal data:

a) Contract (Article 6(1)(b)):

b) Consent (Article 6(1)(a)):

c) Legitimate interests (Article 6(1)(f)):

d) Legal obligation (Article 6(1)(c)):

Your rights under GDPR:

a) Right to access (Article 15):

b) Right to rectification (Article 16):

c) Right to erasure / "Right to be forgotten" (Article 17):

d) Right to restriction of processing (Article 18):

e) Right to data portability (Article 20):

f) Right to object (Article 21):

g) Right to withdraw consent (Article 7(3)):

h) Right not to be subject to automated decision-making (Article 22):

How to exercise your rights:

Primary method: Email contact@reai-strategy.com with:

Response times:

UK (for UK users):

Other EU/EEA countries:

a) Legal mechanisms:

b) Safeguards:

c) Your consent:

14.3 CCPA/CPRA Compliance (For California Residents)

We comply with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Your rights under CCPA/CPRA:

a) Right to know:

b) Right to delete:

c) Right to correct:

d) Right to opt-out of sale/sharing:

e) Right to limit use of sensitive personal information:

f) Right to non-discrimination:

Categories of personal information we collect:

See our Privacy Policy for complete CCPA disclosure including:

How to exercise your rights:

Methods: a) Email: privacy@redact.ai with subject "CCPA Request" b) Web form: https://redact.ai/ ccpa-request (if available) c) Toll-free phone: [IF PROVIDED - TBD]

Verification:

Response time: Within 45 days (may extend to 90 days for complex requests)

Do Not Sell My Personal Information:

We do NOT sell personal information. There is no need to opt-out.

If we ever change this practice, we will:

Shine the Light Law (California Civil Code § 1798.83):

California residents may request information about disclosure of personal information to third parties for direct marketing purposes. We do not disclose for third-party direct marketing.

14.4 Data Security

We implement industry-standard security measures to protect your data:

Technical safeguards:

a) Encryption:

b) Access controls:

c) Authentication:

d) Network security:

Organizational safeguards:

a) Security policies:

b) Vendor management:

c) Access management:

d) Monitoring and logging:

Compliance and certifications:

We work towards:

Third-party security:

Our infrastructure providers maintain:

Regular security assessments:

a) Internal assessments:

b) External assessments:

However:

We cannot guarantee absolute security. No system is 100% secure. Despite our best efforts:

You are responsible for:

If you suspect a security issue: Email contact@reai-strategy.com immediately.

14.5 Data Breach Notification

In the event of a data breach affecting your personal data:

Our obligations:

For EU/EEA/UK users (GDPR):

a) Notification to supervisory authority:

b) Notification to you:

For California residents (CCPA):

a) Notification to you:

For all users:

a) Transparency:

b) Notification contents:

c) Support:

Types of breaches we will notify:

a) Personal data breaches:

b) Security incidents:

Our incident response process:

1. Detection: Automated monitoring, user reports, vendor notifications

2. Containment: Immediate steps to stop breach and prevent further damage

3. Investigation: Forensic analysis to determine scope and cause

4. Notification: Compliance with legal requirements (72 hours GDPR, etc.)

5. Remediation: Fix vulnerabilities, enhance security

6. Review: Post-incident review and lessons learned

Your responsibilities after a breach:

If we notify you of a breach:

a) Change your password immediately b) Enable two-factor authentication (if not already enabled) c) Monitor your accounts for suspicious activity d) Review financial statements if pay-

ment data affected e) Be alert for phishing attempts exploiting the breach f) Contact us if you notice any suspicious activity: contact@reai-strategy.com

We will NEVER:

If you receive suspicious communications claiming to be from us, forward to contact@reai-strategy.com before taking any action.

§ 15. THIRD-PARTY SERVICES AND INTEGRATIONS

15.1 Third-Party Service Providers

The Services integrate with and depend on various third-party services, including:

a) AI and Machine Learning Providers:

b) Cloud Infrastructure:

c) Payment Processing:

d) Search Providers:

e) Distributed Ledger:

f) Other Services (as integrated):

These third-party providers:

a) Have their own terms and privacy policies that apply to their services

b) May collect and process your data independently according to their policies

c) Are not under our control - we select reputable providers but cannot guarantee their practices

d) May change their terms without our advance knowledge

e) May experience outages or service degradation beyond our control

Our relationship with third parties:

a) We are NOT responsible for:

b) We ARE responsible for:

Data sharing with third parties:

We share your data with third parties only:

See Section 12 and our Privacy Policy for complete details on data sharing.

Subprocessor list:

Complete list of all third-party processors of your data: https://redact.ai/legal/subprocessors

We will notify you 30 days in advance of adding new subprocessors (GDPR Article 28 requirement).

15.2 Links to External Sites

The Services may contain links to third-party websites, articles, resources, or services.

These external links:

a) Are provided for convenience and information purposes only

b) Do not imply endorsement by us

c) Are not under our control - we have no responsibility for their content

d) Have their own terms and privacy policies that apply when you visit them

e) May collect your data when you click through or visit

We are NOT responsible for:

When you click external links:

a) You leave our Services and our Terms no longer apply

b) External site's terms apply - review them before providing information

c) External site may collect data - review their privacy policy

d) You use external sites at your own risk

We recommend:

§ 16. SERVICE LEVEL AGREEMENT (SLA)

16.1 Applicability

Service Level Agreement (SLA) applies ONLY to:

a) RE::DACT PRO subscribers ($50/month plan)

b) ENTERPRISE customers (per terms of custom agreement)

NO SLA for:

16.2 Uptime Commitment

For eligible plans:

RE::DACT PRO:

ENTERPRISE:

What "uptime" means:

Service is considered "available" when:

Service is considered "down" (counts against uptime) when:

16.3 Uptime Calculation

Formula:

Uptime % = (Total minutes in month - Downtime minutes) / Total minutes in month × 100

Example:

Downtime calculation:

INCLUDES (counts against uptime):

EXCLUDES (does NOT count against uptime):

16.4 Service Credits

If we fail to meet SLA targets:

RE::DACT PRO Service Credits:

Monthly Uptime Achieved

Service Credit

99.0% to < 99.5%

10% of monthly subscription fee

98.0% to < 99.0%

25% of monthly subscription fee

95.0% to < 98.0%

50% of monthly subscription fee

< 95.0%

100% of monthly subscription fee

ENTERPRISE Service Credits:

Per terms of custom agreement. Typically:

Service credit details:

a) Form of credit:

b) Maximum credits:

c) Claiming credits:

d) Processing:

e) Dispute resolution:

Example calculation:

PRO plan: $50/month April 2026 uptime: 98.7% Falls in 98.0% to < 99.0% range Service credit: $50 × 25% = $12.50

Applied to May 2026 invoice: $50 - $12.50 = $37.50 charged

16.5 Exclusions from SLA

We are NOT liable for downtime caused by:

a) Third-party service failures:

b) Your actions:

c) Force majeure:

d) Scheduled maintenance:

e) Beta and experimental features:

f) User environment issues:

g) Service degradation below threshold:

16.6 Monitoring and Reporting

How we monitor uptime:

a) Automated monitoring:

b) Internal monitoring:

c) User reports:

Incident communication:

When incidents occur:

a) Immediate:

b) During incident:

c) After resolution:

d) Post-mortem (for major incidents):

For Enterprise customers:

16.7 No Other Remedies

Service credits are your SOLE and EXCLUSIVE remedy for SLA failures.

We are NOT liable for:

a) Consequential damages:

b) Costs incurred:

c) Amounts beyond service credits:

Exceptions:

See Section 17 (Limitation of Liability) for complete details.

§ 17. DISCLAIMERS AND LIMITATION OF LIABILITY

17.1 "AS IS" and "AS AVAILABLE" Disclaimer

THE SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, INCLUDING:

a) Merchantability - fitness for a particular purpose

b) Non-infringement - that Services don't violate third-party rights

c) Accuracy or reliability - correctness of AI outputs, fact-checking, research

d) Uninterrupted or error-free operation - continuous access, no bugs

e) Security - complete protection against unauthorized access

f) Results - that Services will meet your requirements or expectations

g) Defect correction - that we will fix all bugs or issues

We do NOT warrant that:

Particularly regarding AI features:

You use the Services at your own risk.

17.1.1 Specific Disclaimer for Journalism.

RE::DACT is not liable for any claims of defamation, libel, or breach of professional ethics arising from unverified AI "hallucinations" or biased outputs. The "Spark" and "Cord" features are creative aids, not primary sources of factual truth. You use all AI outputs at your own professional risk.

17.2 Beta Disclaimer (Emphasis)

During Beta Phase (current - through June 2026):

SERVICES ARE EXPERIMENTAL AND FOR TESTING PURPOSES ONLY.

We provide NO WARRANTIES OR GUARANTEES regarding:

Beta users expressly acknowledge and agree:

USE BETA SERVICES AT YOUR OWN RISK.

17.3 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW:

WE (RE::DACT INC., RE::AI STRATEGY S.A., AND OUR AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, CONTRACTORS, LICENSORS) SHALL NOT BE

LIABLE FOR:

a) Indirect, incidental, consequential, punitive, or special damages, including:

Even if we were advised of the possibility of such damages.

b) Damages exceeding the amount you paid us:

Our total liability is capped at:

Examples:

c) Damages arising from:

This limitation applies:

17.4 Exceptions to Limitations

The above limitations DO NOT apply to:

a) Gross negligence or willful misconduct by us

b) Death or personal injury caused by our negligence

c) Fraud or fraudulent misrepresentation

d) Any liability that cannot be excluded or limited by law:

e) For EU consumers: Consumer protection laws may provide additional rights that cannot be waived

Note: Some jurisdictions do not allow exclusion or limitation of certain damages. If your jurisdiction does not allow these limitations, they may not apply to you, but will apply to maximum extent permitted.

17.5 Basis of Bargain

You acknowledge that:

a) These limitations of liability are a fundamental basis of our agreement

b) Our pricing reflects these limitations

c) We would not provide Services without these limitations

d) These limitations are reasonable and have been negotiated In other words: We can offer affordable pricing because liability is limited. Without these limitations, pricing would need to be significantly higher to cover insurance and risk.

§ 18. INDEMNIFICATION

18.1 Your Obligation to Indemnify Us

You agree to indemnify, defend, and hold harmless RE::DACT Inc., RE::AI Strategy S.A., and

our:

From and against any and all:

Arising from or relating to:

a) Your use or misuse of the Services:

b) Your User Content:

c) Your published work (including AI-assisted content):

d) Your violation of laws or regulations:

e) Third-party claims:

Examples of indemnifiable situations:

18.2 Defense and Settlement

If a claim subject to indemnification arises:

a) We will notify you promptly (though delay doesn't eliminate your obligation unless it prejudices your defense)

b) You will assume defense with counsel of your choice (subject to our approval, not to be unreasonably withheld)

c) We may participate in defense at our expense

d) You will NOT settle without our prior written consent (not to be unreasonably withheld)

We reserve the right to:

a) Assume exclusive defense and control of any matter subject to indemnification by you

b) Settle any claim on your behalf if you fail to defend

c) At your expense - you reimburse our costs if we assume defense

Your obligations during defense:

a) Cooperate fully with us

b) Provide information and documents we request

c) Not prejudice our defense

d) Not admit liability or fault without our consent

e) Not make statements to claimants or media without our approval

18.3 Survival

This indemnification obligation:

a) Survives termination or expiration of these Terms

b) Continues for claims arising from use during your subscription

c) Extends to claims discovered after termination

Example: You terminate account in 2026, but claim arises in 2028 for content you published in 2025 using our Services " you still must indemnify us.

§ 19. TERM AND TERMINATION

19.1 Term

These Terms:

a) Begin when you first accept them (account creation or first use)

b) Continue for as long as you access or use the Services

c) Remain in effect until terminated by you or us

19.2 Termination by You

You may terminate your Account and these Terms at any time by:

a) Account settings: Account " Settings " "Delete Account"

b) Email: contact@reai-strategy.com with subject "Account Termination"

Effect of termination:

19.3 Termination by Us

We may terminate or suspend your Account immediately, without prior notice, for:

a) Terms violations (see Section 9.3 and 13.3)

b) Illegal activities

c) Security threats

d) Payment failures (after retry period)

e) Inactivity (12+ months)

f) Legal requirements

g) Service discontinuation (with 90 days notice to active users)

Effect of our termination:

19.4 Survival

The following provisions survive termination:

§ 20. MODIFICATIONS TO SERVICES AND TERMS

20.1 Changes to Services

We reserve the right to:

a) Modify, add, or remove features at any time

b) Change technical requirements or specifications

c) Implement new features or discontinue existing ones

d) Improve or downgrade functionality

e) Suspend Services temporarily for maintenance, upgrades, or security

Notice for material adverse changes:

20.2 Changes to Terms

As stated in Section 3.2, we may modify these Terms at any time.

For material changes:

Your options:

a) Accept: Continue using Services = acceptance

b) Reject: Terminate account before changes take effect = old Terms apply until termination

For non-material changes:

§ 21. GOVERNING LAW AND DISPUTE RESOLUTION

21.1 For Users Contracting with REDACT Inc. (USA)

Governing Law:

These Terms shall be governed by and construed in accordance with the laws of the State of New York, USA, without regard to its conflicts of law principles. The United Nations Convention on Contracts for the International Sale of Goods (CISG) shall NOT apply.

Jurisdiction and Venue:

Any disputes arising from or relating to these Terms or the Services shall be subject to the exclusive jurisdiction of the state and federal courts located in New York County, New York. You consent to personal jurisdiction and venue in these courts and waive any objection based on inconvenient forum.

Arbitration:

See Section 22 for binding arbitration agreement (if you do not opt-out).

21.2 For Users Contracting with REAI P.S.A. (EU)

Prawo właściwe:

Niniejszy Regulamin podlega prawu polskiemu i będzie zgodnie z nim interpretowany, z wyłączeniem norm kolizyjnych.

Sąd właściwy:

Dla przedsiębiorców (B2B):

Wszelkie spory wynikające z niniejszego Regulaminu lub korzystania z Usług będą rozstrzygane przez sąd powszechny właściwy dla siedziby REAI P. S.A. w Warszawie.

Dla konsumentów (B2C):

Jeśli jesteś konsumentem w rozumieniu przepisów UE:

a) Nie możesz być pozbawiony ochrony wynikającej z bezwzględnie obowiązujących przepisów prawa kraju, w którym masz miejsce zwykłego pobytu

b) Możesz wybrać sąd:

Pozasądowe rozstrzyganie sporów (ODR):

Zgodnie z Rozporządzeniem UE 524/2013, konsumenci mają prawo do pozasądowych sposobów

rozpatrywania reklamacji i dochodzenia roszczeń:

a) Platforma ODR (Online Dispute Resolution):

b) Polubowne rozwiązywanie sporów:

c) Nasza polityka:

21.3 Class Action Waiver (US Users Only)

TO THE EXTENT PERMITTED BY LAW, you agree that:

a) Any dispute will be resolved on an individual basis only

b) You waive the right to participate in:

Note: Some jurisdictions (e.g., California for certain consumer rights) may not permit class action waivers. If unenforceable in your jurisdiction, this Section 21.3 is severable from remaining Terms.

§ 22. ARBITRATION AGREEMENT (US USERS ONLY)

This section applies ONLY to users contracting with RE::DACT Inc. (USA).

22.1 Agreement to Arbitrate

You and REDACT Inc. agree to resolve disputes through binding arbitration instead of in

court, EXCEPT for:

a) Small claims court disputes:

b) Intellectual property disputes:

c) Injunctive relief:

d) Claims you opt-out of (see Section 22.5) By agreeing to these Terms, you waive your right to a jury trial and to participate in a class action.

22.2 Arbitration Rules

Arbitration will be conducted by:

Arbitrator:

Location:

Process:

22.3 Costs

For claims under $75,000:

a) Filing fees:

b) Arbitrator fees:

c) Attorney's fees:

For claims over $75,000:

If you prevail:

22.4 No Class Actions (Reiteration)

You agree:

If class action waiver is found invalid or unenforceable:

22.5 Opt-Out of Arbitration

You may opt out of this arbitration agreement:

How:

a) Email contact@reai-strategy.com

b) Subject: "Arbitration Opt-Out”

c) Include:

Deadline:

Effect of opt-out:

If you do NOT opt-out:

CLASS ACTION WAIVER. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU AND RE::DACT AGREE THAT ANY DISPUTE RESOLUTION PROCEEDINGS WILL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION. YOU EXPRESSLY WAIVE YOUR RIGHT TO PARTICIPATE AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS ACTION OR REPRESENTATIVE PROCEEDING.

22.6 Severability

If any part of this arbitration agreement (except class action waiver) is found invalid or unenforceable:

22.7 Changes to Arbitration Agreement

If we materially change this arbitration agreement in the future:

a) 30 days notice to existing users

b) You may reject changes by opting out within 30 days

c) Continued use = acceptance of changes

d) Changes do not apply to disputes already filed

§ 23. MISCELLANEOUS PROVISIONS

23.1 Entire Agreement

These Terms, together with:

constitute the entire agreement between you and us regarding the Services.

They supersede all prior:

Regarding the Services.

23.2 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction:

a) That provision will be modified to minimum extent necessary to make it valid and enforceable

b) If modification is not possible, the provision will be severed (removed)

c) Remaining provisions continue in full force and effect

d) The invalid provision will be replaced with a valid provision closest to original intent Exception: If class action waiver in Section 22.4 is severed, entire arbitration agreement in Section 22 becomes void (per Section 22.6).

23.3 Waiver

Our failure or delay in enforcing any provision of these Terms does NOT constitute a waiver of that provision or our right to enforce it later.

Any waiver must be:

No waiver of:

23.4 Assignment

You may NOT assign or transfer:

Any attempted assignment without consent is void. We MAY assign these Terms (including to affiliates, successors, or acquirers) without your consent, but will notify you of:

Notice of assignment:

23.5 Force Majeure

We are not liable for any delay or failure to perform due to causes beyond our reasonable control, including:

Acts of God:

War and civil unrest:

Labor and economic:

Infrastructure:

Cyberattacks:

During force majeure:

a) Obligations suspended while event continues

b) No liability for delays or failures

c) We will use reasonable efforts to mitigate impact

d) SLA does not apply (see Section 16.5)

If force majeure continues >30 days:

23.6 No Agency

These Terms do NOT create:

Between you and us.

Neither party has authority to:

23.7 Third-Party Beneficiaries

These Terms are solely for the benefit of you and us (and our respective successors and permitted assigns).

No third party has:

Except:

23.8 Export Control

The Services may be subject to export control laws and regulations, including:

You represent and warrant that:

a) You are NOT:

b) You will NOT:

We reserve the right to:

Violations:

23.9 Sanctions Compliance

You represent and warrant that you and your organization are NOT:

a) Subject to sanctions by:

b) Owned or controlled by sanctioned persons or entities

c) Acting on behalf of sanctioned persons or entities

We will:

You will immediately notify us if:

23.10 Language

Primary Language: English These Terms are drafted and provided in English.

Translations:

We may provide translations (e.g., Polish) for convenience.

In case of conflict or discrepancy between language versions:

The English version shall prevail and control. Exception: For consumer contracts governed by laws requiring local language (e.g., certain EU consumer laws), the local language version may prevail to extent required by law.

23.11 Contact for Legal Notices

For legal notices to us (service of process, legal demands, etc.):

REDACT Inc. Attn: Legal Department 1111B S Governors Ave STE 99573 Delaware, United States Email: contact@redact-app.com REAI P. S.A. Attn: Dział Prawny Aleja Jana Pawła II 5/6

64-920 Piła, Polska Email: contact@reai-strategy.com

Notices must be:

Effective when:

For service of legal process: Must comply with applicable rules of civil procedure.

§ 24. CONTACT INFORMATION

For general questions or support:

For legal matters or Terms-related inquiries:

For privacy or data protection matters:

For security vulnerabilities (responsible disclosure):

For billing and payment inquiries:

For enterprise sales and partnerships:

For media and press inquiries:

Mailing addresses:

REDACT Inc. (USA):

1111B S Governors Ave STE 99573 Delaware, United States

REAI P. S.A. (Poland/EU):

Aleja Jana Pawła II 5/6 64-920 Piła, Polska

ACKNOWLEDGMENT

BY USING THE SERVICES, YOU ACKNOWLEDGE THAT:

1. You have read and understood these Terms in their entirety

2. You agree to be bound by all provisions of these Terms

3. You have reviewed our Privacy Policy and Cookie Policy

4. You understand the Beta nature of the Services (during Beta Phase)

5. You are responsible for compliance with all applicable laws

6. You will use the Services in accordance with these Terms and applicable laws

7. You understand AI limitations and will maintain human oversight (Section 12.6)

8. You understand limitation of liability (Section 17)

9. You understand arbitration agreement (Section 22, US users) and your right to opt-out

10. You have the authority to enter into this agreement (personally or on behalf of organization)

If you do not agree with any part of these Terms, you must not use the Services.

END OF TERMS OF SERVICE

Document Information:

© 2026 REDACT Inc. and REAI Prosta Spółka Akcyjna. All rights reserved. RE::DACT, SPARK, and RE::CORD are trademarks of REDACT Inc.

Questions? Contact us at contact@reai-strategy.com