Terms & Conditions

Effective Date: June 1, 2026

Last Updated: June 1, 2026

CANISMAJORIS21 SRL, Tudor Arghezi 15, Brasov, Romania

Contact: hello@net21.app

1. About net21

net21 is a product operated by CANISMAJORIS21 SRL, a Romanian legal entity registered at Tudor Arghezi 15, Brasov, Romania. The net21 platform, accessible at net21.app, is a Software-as-a-Service (SaaS) service that provides ecommerce brands with customer base analysis tools and personalized commercial campaign delivery. By accessing or using the net21 platform in any manner, you agree to be bound by these Terms and Conditions, our Privacy Policy, and any additional policies we may publish. If you do not agree, you are not authorized to use the platform.

2. Definitions

Platform: the net21 application and all associated services, accessible at net21.app Brand: any company, legal entity, or authorized individual registering as a product or service provider Customer: any natural person with an account on the net21 Customer Portal or whose data has been processed from purchases at partner brands Campaign: a commercial offer created by a brand, subject to net21 approval, and distributed to eligible customers Existing Customers Campaign: campaign targeting exclusively customers who have previously purchased from that brand; FREE Network/Marketplace Campaign: campaign targeting all net21 network customers matching target attributes; cost is EUR 0.01 per customer reached Wallet: a brand's EUR balance, used exclusively for marketplace campaigns Attribute: a behavioral characteristic derived from a customer's purchase history, stored with an intensity value (strength) between 0 and 1 Reputation Score: the numerical indicator (0-100) reflecting a brand's policy compliance history Match engine: the platform's technical component responsible for identifying eligible customers and creating offers

3. Brand Terms

3.1 Registration and Approval Registration on the net21 platform is the first step in a multi-stage process including verification and explicit account approval by the net21 team. Completing the registration form does not grant access to the platform's full features. net21 reserves the discretionary right to approve, reject, or revoke any brand account without obligation to provide a detailed explanation. Brands must provide accurate, complete, and up-to-date information. Providing false information constitutes grounds for immediate account suspension. 3.2 Connecting the Shopify Store The platform's main features require connecting a Shopify store through the authorized OAuth flow. By initiating this flow, the brand authorizes net21 to access order, customer, and product data for the purposes described in these terms; confirms it has the rights to authorize this access, including having informed store customers about data sharing with third-party processors per their own GDPR obligations; and understands that the OAuth token can be revoked at any time from Shopify store settings. 3.3 Campaign Policy All campaigns require prior net21 approval before being distributed to customers. Review takes a maximum of 5 business days. Campaigns may be rejected for promoting illegal products, containing false or misleading claims, using offensive or discriminatory language, constituting phishing or fraud attempts, violating third-party intellectual property rights, or having insufficient quality. Approved campaigns are active for 30 calendar days from approval. Anti-spam rules apply: a customer never receives the same offer twice; each customer has a weekly offer limit (default 5, configurable 1-20); brands cannot directly contact customers. 3.4 Reputation Score Each brand starts with a reputation score of 100. Formula: (Approved campaigns / Total campaigns) x 100. Score >= 50 or fewer than 3 total campaigns: full platform access. Score < 50 with 3+ campaigns: marketplace campaign creation blocked. Score < 20 with 10+ campaigns: may result in account suspension. 3.5 Wallet and Pricing Existing Customers campaigns: FREE - no cost per customer reached Marketplace campaigns: EUR 0.01 per customer reached, automatically deducted from wallet Minimum top-up amount: EUR 10 per transaction No balance expiration Low balance notification: when balance drops below EUR 5 When balance reaches EUR 0, marketplace campaigns stop automatically Refunds for unused balance processed upon written request, minus Stripe processing fees 3.6 Prohibited Use for Brands Brands explicitly agree not to: use platform data to individually identify and contact customers through external channels; extract or store customer data in external databases; create false or misleading campaigns; use the platform for spam, phishing, or unfair commercial practices; attempt to circumvent the campaign approval system; share account credentials with unauthorized persons; or use automated scripts to access the platform outside normal use. Violation of any prohibition constitutes grounds for immediate account suspension without wallet refund.

4. Customer Terms

4.1 Creating a Customer Account Any natural person aged at least 16 years may create an account using a valid email address. By creating an account, the customer confirms they meet the minimum age requirement, their information is accurate, and they have read and agree to these Terms and Privacy Policy. If the email address already exists in the net21 database from a partner brand's synchronization, the new account will be automatically linked to the existing history. 4.2 The Customer Attribute Profile net21 automatically builds and updates a behavioral attribute profile based on purchase data synchronized by partner brands. These attributes are used exclusively for selecting and delivering relevant offers, and for calculating estimated reach for brand campaigns in aggregate format without individual customer identification. Customers cannot directly view the numerical values of their attributes - this design decision reflects the platform's core principle: relevance should be felt, not explained. 4.3 Offers and Delivery Rules Uniqueness: a customer never receives the same offer twice Weekly limit: default 5 offers per week, configurable between 1 and 20 Duration: offers expire after 30 days from campaign approval and automatically disappear from the interface Relevance: offers are selected based on attribute matching; net21 does not guarantee a specific number of offers Anonymization: the brand launching the campaign does not know the identity of customers who received the offer 4.4 Account Deletion Customers may request account deletion at any time from Settings or by emailing hello@net21.app. Upon deletion: all behavioral attributes are immediately deleted; all offers disappear from the interface; the account is deactivated within 24 hours and permanently deleted within 30 days; brands that benefited from the customer's data are notified that access has expired retroactively.

5. net21 Responsibilities and Limitations

5.1 Commitments to Brands Reviewing all campaigns and providing clear feedback on rejection within maximum 5 business days Maintaining platform availability at minimum 99.0% (SLA), excluding planned maintenance announced 48 hours in advance Notifying brands at least 30 days before significant changes to features or pricing Protecting brand data in accordance with GDPR and the Privacy Policy Accurate and transparent processing of wallet transactions 5.2 Commitments to Customers Personal data protection in accordance with GDPR and the Privacy Policy Rigorous enforcement of anti-spam rules (offer uniqueness, weekly limits, expiration) Anonymizing customer identity from brands in all interactions Processing data deletion requests within 30 days Maintaining customer control over profile and preferences 5.3 Limitations of Liability net21 is not responsible for: the quality, legality, or accuracy of products and services promoted in campaigns; brand commercial losses from rejected campaigns or underperforming approved campaigns; interruptions caused by third parties (Shopify, Stripe, Clerk, Vercel, Resend); incorrect or fraudulent data provided by brands; customer purchasing decisions; or indirect losses including loss of profit, data loss, lost business opportunity, or reputational damages. Maximum net21 liability to a brand for any incident is limited to the total amount paid by that brand in the 3 calendar months preceding the incident.

6. Intellectual Property

The net21 platform, including source code, design, user interface, algorithms, names, logo, documentation, and all other platform elements are the exclusive property of CANISMAJORIS21 SRL, protected by copyright, trademark, and other applicable intellectual property laws. Users do not acquire any intellectual property rights by using the platform. Copying, modifying, distributing, selling, licensing, or commercially exploiting any platform component without prior written consent from net21 is strictly prohibited. Brands retain intellectual property rights over their campaign content and grant net21 a non-exclusive, free license for using this content for service delivery purposes. Aggregated and anonymized data generated by net21 network activity is the property of CANISMAJORIS21 SRL.

7. Privacy and Data Protection

Personal data processing by net21 is described in detail in the Privacy Policy, available at net21.app/privacy, which forms an integral part of these Terms and Conditions. By accepting these Terms, you confirm you have read and understood the Privacy Policy.

8. Service and Terms Modifications

net21 may modify platform features, terms of use, or pricing structure. Significant changes to features or terms: email notification at least 30 days in advance. Price changes: notification at least 30 days in advance, with option to request wallet balance refund if in disagreement. Minor changes may be made without prior notice, updating the document date. Continued use of the platform after modifications take effect constitutes implicit acceptance. If you disagree with changes, you must stop using the platform and request account closure.

9. Suspension and Termination

9.1 Brand Account Closure at Brand's Initiative A brand may request account closure at any time by emailing hello@net21.app. Upon closure: active campaigns are immediately deactivated; remaining wallet balance is refunded within 30 calendar days, minus applicable Stripe processing fees; synchronized Shopify data is anonymized and deleted per the retention policy (3 years from last synchronization). 9.2 Brand Account Suspension or Closure by net21 net21 may suspend or close a brand account, with or without notice, in case of: violation of any Terms and Conditions; providing false information; fraud or illegal activity; reputation score below 20 with 10+ processed campaigns; complete inactivity for 12 consecutive months; or competent authority requests. Upon suspension, the brand is notified by email with the reason and, if applicable, remediation steps. 9.3 Customer Account Deletion Customers may request account deletion at any time. The process and consequences are described in section 4.4. Accounts cannot be recovered after deletion.

10. Force Majeure

net21 is not responsible for failure to fulfill contractual obligations when such failure is caused by circumstances beyond the company's reasonable control, including but not limited to: natural disasters, earthquakes, floods, fires, terrorist acts, military conflicts, governmental authority acts, pandemics, widespread power outages, large-scale cyberattacks, or critical internet infrastructure failures.

11. Governing Law and Dispute Resolution

These Terms and Conditions are governed by Romanian law in force, including the Civil Code, Law no. 365/2002 on electronic commerce, Law no. 190/2018 on GDPR implementation measures, and any other applicable regulations. Any dispute arising from or in connection with these Terms will first be addressed through amicable negotiation. If negotiation does not lead to a solution within 30 days of dispute notification, parties may resort to the competent courts of Brasov, Romania. EU users may also use the European Commission's Online Dispute Resolution (ODR) platform at ec.europa.eu/consumers/odr.

12. Miscellaneous

If any provision of these Terms is declared void or unenforceable, the remaining provisions remain in full force net21's failure to exercise any right provided in these Terms does not constitute a waiver of that right These Terms, together with the Privacy Policy, constitute the entire agreement between you and net21 regarding platform use The Romanian language version of these Terms prevails in case of conflict with the English version

13. Contact

For any questions, complaints, or requests related to these Terms and Conditions: CANISMAJORIS21 SRL, Tudor Arghezi 15, Brasov, Romania, hello@net21.app, net21.app. By using the net21 platform, you confirm that you have read, understood, and agree to these Terms and Conditions.