1. Definitions

"Platform" means the Adriavela website, web application, mobile application, APIs, and all associated software and services operated by Adriavela Ltd ("Company", "we", "us", "our").

"Tourist" / "Guest" means any natural or legal person who browses, registers, or submits a booking request through the Platform.

"Charter Operator" / "Captain" means any professional yacht owner, operator, or licensed charter entity listing vessels on the Platform.

"Charter Contract" means the legally binding agreement for yacht charter services entered into exclusively between the Tourist and the Charter Operator.

"Booking" means a confirmed reservation facilitated through the Platform, the legal effect of which arises solely from the Charter Contract.

"Total Charter Price" means the full price payable for a charter service as listed on the Platform, sourced from third-party systems including NauSYS and MMK API.

2. Nature of the Platform — Marketplace Intermediary

2.1 Intermediary Role

The Platform provides technology infrastructure enabling Tourists to discover vessels listed by Charter Operators and submit booking requests. All contractual obligations for charter services arise solely between the Tourist and the relevant Charter Operator.

2.2 No Agency

Nothing in these Terms constitutes or creates an agency, partnership, joint venture, employment, or fiduciary relationship between the Company and any User or Charter Operator.

2.3 Third-Party Data Dependency

All vessel availability, pricing, and fleet information is sourced in real time from NauSYS CRM and the MMK API. The Company does not independently verify the accuracy, completeness, or reliability of any such data and shall have no liability for any errors or omissions originating from third-party systems.

2.4 No Endorsement

Listing of any vessel or Charter Operator does not constitute endorsement, certification, or approval by the Company. The Company does not verify credentials, licences, or seaworthiness of any listed vessel or operator.

3. Eligibility and Account Registration

3.1 Eligibility

Use of the Platform is restricted to persons who are at least 18 years of age with full legal capacity to enter binding contracts under the law of their jurisdiction.

3.2 Account Registration

By registering, you warrant that all information provided is accurate and current, you are authorised to create the account, and you will maintain the confidentiality of your credentials. You are solely responsible for all activities under your account.

3.3 Suspension and Termination

The Company reserves the right to suspend or permanently terminate any User's access at any time, without notice, for any reason including breach of these Terms, fraudulent conduct, or reputational risk. No liability shall attach to the Company for any such action.

4. Charter Operators — Obligations and Warranties

4.1 Operator Warranties

Each Charter Operator warrants on a continuing basis that: (a) it holds all requisite licences and permits to operate; (b) all vessels are seaworthy and comply with safety regulations; (c) all vessels carry adequate insurance; (d) all listed content is accurate and not misleading; and (e) the Operator will honour all confirmed Bookings.

4.2 Operator Indemnification

Charter Operators shall indemnify, defend, and hold harmless the Company from all claims, losses, and expenses arising from: (a) their vessels, services, or conduct; (b) any Charter Contract or dispute with a Tourist; (c) any personal injury, death, or property damage during a charter; or (d) breach of applicable law.

4.3 Listing Accuracy

Charter Operators bear sole responsibility for the accuracy of all listing information, pricing, availability, and terms. The Company has no liability for inaccuracies in Charter Operator listings.

5. Booking Process and Payments

5.1 Booking Process

A Booking is confirmed only when: (a) the Charter Operator confirms availability; (b) payment is processed successfully by Stripe; and (c) a booking confirmation email is issued with a unique reference (ADV-YYYYMMDD-XXXX) and recorded in NauSYS CRM.

5.2 Payment Processing

All payments are processed by Stripe, Inc. The Company is not a payment institution and does not process or store card data. The Company has no liability for any payment failures, errors, or delays attributable to Stripe.

5.3 Pricing

All prices are sourced from NauSYS and MMK API and may change without notice. The Company makes no representation that displayed prices are current or accurate. Final pricing is subject to Charter Operator confirmation.

5.4 Cancellations and Refunds

Cancellation and refund policies are determined solely by the relevant Charter Operator and Charter Contract. The Company is not a party to such arrangements and has no obligation to process or fund any refund. Any refund requests submitted via the Platform are routed to backoffice administration and are subject to Charter Operator policies.

5.5 No Guarantee of Service

The Company makes no guarantee that charter services will be delivered as described or at all. In the event of operator cancellation or force majeure, the Tourist's sole recourse is against the relevant Charter Operator.

6. AI-Assisted Chat Support — Limitations

6.1 AI Disclaimer

The Platform integrates an AI-assisted chat function (powered by Claude AI, developed by Anthropic, PBC) for general informational support. The Company does not review or endorse any specific AI response.

6.2 No Liability for AI Outputs

To the maximum extent permitted by law, the Company has no liability for any loss or harm arising from reliance on AI-generated outputs. Users acknowledge that AI content may contain errors and must be independently verified.

6.3 Human Escalation

Where human support is required, users may escalate via WhatsApp or Telegram as indicated on the Platform. Response times for human support are not guaranteed.

7. Intellectual Property

All intellectual property rights in the Platform — including software, architecture, design, trademarks, logos, and all proprietary technology — are the exclusive property of the Company or its licensors. No licence is granted to any User except as expressly stated herein.

By submitting Content to the Platform, the User grants the Company a worldwide, perpetual, irrevocable, royalty-free, sub-licensable licence to use, reproduce, adapt, and display such Content for purposes connected with the Platform.

8. Limitation of Liability

8.1 Disclaimer of Warranties

THE PLATFORM IS PROVIDED STRICTLY ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT ANY WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR PURPOSE, OR ACCURACY.

8.2 Maximum Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE COMPANY SHALL NOT BE LIABLE FOR: (A) INDIRECT, INCIDENTAL, OR CONSEQUENTIAL DAMAGES; (B) LOSS OF PROFITS OR DATA; (C) PERSONAL INJURY OR DEATH FROM CHARTER SERVICES; (D) VESSEL DAMAGE OR UNSEAWORTHINESS; (E) LOSSES FROM THIRD-PARTY SYSTEMS (NAUSYS, MMK API, STRIPE); OR (F) ANY OTHER ECONOMIC LOSS — UNDER ANY THEORY OF LIABILITY.

8.3 Aggregate Cap

IN NO EVENT SHALL THE COMPANY'S TOTAL AGGREGATE LIABILITY EXCEED THE GREATER OF: (A) THE SERVICE FEES ACTUALLY RECEIVED FROM THE RELEVANT USER IN THE THREE MONTHS PRECEDING THE EVENT; OR (B) ONE HUNDRED EUROS (€100).

8.4 No Liability for Third-Party Acts

The Company has no liability for any act, omission, negligence, or breach of law by any Charter Operator, Captain, crew member, data provider, payment processor, or other third party.

9. Indemnification

Each User shall indemnify, defend, and hold harmless the Company from all claims, losses, damages, and expenses (including legal fees) arising from: (a) breach of these Terms; (b) Content submitted by the User; (c) any Charter Contract or dispute with a Charter Operator; (d) personal injury, death, or property damage during a charter; (e) infringement of any third-party rights; or (f) violation of applicable law.

10. Force Majeure

The Company shall not be liable for any failure in performance to the extent resulting from causes beyond its reasonable control, including acts of God, natural disasters, pandemics, war, terrorism, government orders, internet outages, failures of third-party infrastructure (including NauSYS, Stripe, or Anthropic AI services), or cyberattacks.

11. Governing Law and Dispute Resolution

11.1 Governing Law

These Terms shall be governed by and construed in accordance with the laws of [JURISDICTION], without regard to conflict of law principles.

11.2 Mandatory Pre-Arbitration Mediation

Prior to any arbitration, the parties shall attempt in good faith to resolve any dispute through structured mediation for no less than 30 days.

11.3 Arbitration

Any unresolved dispute shall be finally settled by binding arbitration. The arbitral award shall be final and binding on both parties.

11.4 Class Action Waiver

TO THE FULLEST EXTENT PERMITTED BY LAW, EACH USER WAIVES ANY RIGHT TO PARTICIPATE IN ANY CLASS, COLLECTIVE, OR REPRESENTATIVE PROCEEDING AGAINST THE COMPANY.

12. General Provisions

Severability: If any provision is held unenforceable, the remainder of these Terms continues in full force.

Entire Agreement: These Terms together with the Privacy Policy constitute the entire agreement between the User and the Company.

No Waiver: No failure by the Company to exercise any right shall operate as a waiver thereof.

Assignment: The Company may freely assign these Terms. Users may not assign without prior written consent.

13. Amendments

The Company reserves the right to amend these Terms at any time. Notice of material changes will be provided by posting the updated Terms with a revised effective date. Continued use constitutes acceptance. If you do not agree, your sole remedy is to cease using the Platform.

14. Contact

• Legal: legal@adriavela.com
• Bookings: bookings@adriavela.com
• General: hello@adriavela.com

Version 2.0 · © Adriavela Ltd. All rights reserved.

1. Data Controller

The data controller for personal data collected through the Platform is Adriavela Ltd ("Company", "we", "us", "our").

Data Protection Contact: privacy@adriavela.com

Where the Company processes personal data on behalf of Charter Operators, the Charter Operator shall be the data controller and the Company shall act as data processor, subject to a separate data processing agreement.

2. Categories of Personal Data Collected

2.1 Data You Provide Directly

• Identity data: Full name, nationality, date of birth, passport or ID details (where required for charter compliance)
• Contact data: Email address, telephone number, messaging identifiers (WhatsApp, Telegram)
• Booking data: Booking history, charter preferences, special requests
• Communications: All messages via the Platform including AI chat transcripts and support correspondence
• Payment references: Payment confirmation identifiers only (card data is processed exclusively by Stripe)

2.2 Data Collected Automatically

• Technical data: IP address, browser type, operating system, device identifiers
• Usage data: Pages viewed, features used, clicks, search queries, session duration
• Analytics data: Collected via Google Analytics 4 (GA4) and Meta Pixel, implemented and controlled by the Company

2.3 Data Received from Third Parties

• NauSYS CRM & MMK API: Booking status, vessel availability, operator information
• Stripe, Inc.: Transaction status and references only
• Anthropic PBC: AI chat queries processed via Claude API, subject to Anthropic's data processing terms

3. Legal Basis for Processing

The Company processes personal data on the following legal bases under Article 6 GDPR:

• Booking fulfilment: Contract performance (Art. 6(1)(b))
• Account management: Contract performance (Art. 6(1)(b))
• Payment processing: Contract performance / Legal obligation
• Platform security & fraud prevention: Legitimate interests (Art. 6(1)(f))
• Analytics & optimisation (GA4, Meta Pixel): Legitimate interests / Consent (Art. 6(1)(a)(f))
• Marketing communications: Consent (Art. 6(1)(a)) — opt-in only
• Legal compliance & dispute resolution: Legal obligation (Art. 6(1)(c))

4. Data Sharing and Third-Party Processors

The Company shares personal data with third parties only where necessary. All processors are required to process data on documented instructions and maintain appropriate security measures.

• NauSYS CRM: Receives booking data to facilitate charter reservations. Acts as a data processor under a data processing agreement.
• MMK API: Receives queries and transmits fleet availability. Data shared is limited to booking-relevant parameters.
• Stripe, Inc.: Processes payment card data as an independent data controller under Stripe's own privacy policy.
• Anthropic PBC: AI chat transcripts transmitted for processing. Subject to Anthropic's privacy policy and data processing terms.
• Google LLC (GA4): Pseudonymised analytics data transmitted to Google as data processor under Google Ads Data Processing Terms.
• Meta Platforms (Meta Pixel): User behaviour and conversion data for analytics and advertising optimisation. Users may opt out via Meta's privacy settings.
• Legal authorities: Disclosed where required by law, court order, or to protect the Company's legal rights.

5. International Data Transfers

Personal data may be transferred outside the EEA where: (a) the recipient country has been granted an adequacy decision; (b) Standard Contractual Clauses are in place; or (c) another lawful transfer mechanism applies. By using the Platform, you acknowledge the transfer of your data to servers of third-party providers including those in the United States.

6. Data Retention

• Booking and transaction data: 7 years from transaction date (or longer if required by law)
• Account data: Duration of account plus 2 years following closure
• AI chat transcripts: 90 days from conversation date, unless earlier deletion is requested
• Analytics data (GA4): 26 months
• Marketing consent records: Duration of consent plus 5 years
• Legal hold data: Indefinitely pending resolution of any dispute or legal proceeding

7. Your Rights

Subject to applicable law, data subjects have the following rights:

• Access (Art. 15 GDPR): Request a copy of personal data held about you.
• Rectification (Art. 16 GDPR): Request correction of inaccurate or incomplete data.
• Erasure (Art. 17 GDPR): Request deletion where no legitimate grounds for retention subsist.
• Restriction (Art. 18 GDPR): Request limitation of processing in certain circumstances.
• Portability (Art. 20 GDPR): Request your data in a structured, machine-readable format.
• Object (Art. 21 GDPR): Object to processing based on legitimate interests or direct marketing.
• Withdraw Consent: Where processing is consent-based, you may withdraw at any time without affecting prior lawful processing.

To exercise any right, submit a written request to privacy@adriavela.com. The Company will respond within 30 days. If unsatisfied, you may lodge a complaint with the relevant supervisory authority.

8. Cookies and Tracking Technologies

8.1 Cookie Usage

• Strictly Necessary: Essential for Platform operation, authentication, and security. Cannot be disabled.
• Analytics (GA4): Pseudonymised usage statistics to analyse Platform performance.
• Marketing (Meta Pixel): Conversion tracking and advertising optimisation.
• Functional: User preferences and session information.

8.2 Cookie Consent

Non-essential cookies are deployed only upon freely given, informed, and unambiguous consent via the Platform's cookie consent mechanism. Users may withdraw consent at any time via cookie settings.

9. Data Security

The Company implements appropriate technical and organisational measures to protect personal data. However, no transmission over the internet is entirely secure. To the maximum extent permitted by law, the Company shall not be liable for data breaches attributable to third-party processors, users, or malicious actors despite reasonable security measures.

10. Children's Data

The Platform is not directed at individuals under the age of 18. The Company does not knowingly collect personal data from minors. If such data is identified, it will be deleted promptly.

11. Amendments

The Company reserves the right to amend this Privacy Policy at any time. Material changes will be notified via email or a prominent notice on the Platform. Continued use after the effective date constitutes acceptance.

12. Contact

• Data Protection: privacy@adriavela.com
• General: hello@adriavela.com

Version 2.0 · © Adriavela Ltd. All rights reserved.