General terms and conditions for the Customer's purchase of services at polads.eu, pursuant to applicable EU regulations.
Version 1.0 — July 2026. STEP A/S — Business reg. no. 25506227. Applicable EU regulations: Regulation (EU) 2024/900 of the European Parliament and of the Council of 13 March 2024, and Commission Implementing Regulation (EU) 2025/1410 as amended.
1.1 Unless otherwise explicitly stated in these general terms and conditions of sale and delivery of service (hereinafter "Terms of Sale and Delivery of Service") the capitalized terms used in these Terms of Sale and Delivery of Service shall have the meaning given in the definitions below.
"Advertiser" means a natural or legal person at whose request or on whose behalf a Political Advertisement is prepared, placed, promoted, published, delivered or disseminated, or who engages in the provision of Political Advertising services, as defined in the Regulation, with the exception of purely ancillary services. For the purposes of these Terms of Sale and Delivery of Service, "Advertiser" corresponds to the term "Sponsor" as defined in Article 3(10) of the Regulation, and the two terms shall be treated as equivalent;
"Core Platform Principles" means the principles which govern the Platform's ethical approach and will underpin any code of conduct set up. These are set out in detail in clause 2.6 below.
"Customer" means, Advertisers, Representatives and Publishers, who have created an account on the Platform;
"Data Collector" means any natural or legal person, including vetted researchers (as defined in Article 40(8) of the Digital Services Act, Regulation (EU) 2022/2065, as amended), members of civil society organisations whose statutory objectives are to protect and promote the public interest, political actors, national or international electoral observers recognised in a Member State, journalists, as well as representatives of national regulatory authorities and civil servants exercising oversight functions under the Regulation, who access the Platform to request or obtain data or information pursuant to the Regulation;
"Generated Materials" means the artifacts the Platform produces from Customer content, including Transparency Notices (HTML and PDF), Labels (SVG / PNG / JPG), QR codes, and audio (text-to-speech) renderings;
"Guest" means any natural or legal person who accesses the Platform without creating an account and who is not otherwise registered on the Platform as a Customer or Data Collector, including members of the general public, citizens, non-registered Advertisers, Publishers, intermediaries and other commercial entities, who visit the Platform to view published Labels and Transparency Notices, consult publicly available Political Advertising information, or submit notifications of possibly non-compliant Political Advertisements;
"Implementing Regulation" means Commission Implementing Regulation (EU) 2025/1410 as amended;
"Label" means the label, cf. Article 11 (3) of the Regulation, containing the information, and Transparency Notice or link thereto, stipulated in Article 11 of the Regulation;
"Paddle" means Paddle.com Market Limited (or the applicable Paddle entity), acting as the merchant of record for all paid transactions on the Platform. The Customer's purchase and payment contract for the applicable fees is concluded with Paddle and is additionally subject to Paddle's buyer terms;
"Platform" means the platform polads.eu;
"Political Advertising"/"Political Advertisement" means the preparation, placement, promotion, publication, delivery or dissemination, by any means, of a message, normally provided for remuneration or through in-house activities or as part of a Political Advertising campaign: (a) by, for or on behalf of a political actor, unless it is of a purely private or a purely commercial nature; or (b) which is liable and designed to influence the outcome of an election or referendum, voting behaviour or a legislative or regulatory process, at Union, national, regional or local level;
"Publisher" means a provider of Political Advertising service that publishes, delivers or disseminates Political Advertising through any medium;
"Regulation" means Regulation (EU) 2024/900 of the European Parliament and of the Council of 13 March 2024 on the transparency and targeting of Political Advertising as amended;
"Representative" means any natural or legal person, including an agency, political consultancy or other provider of Political Advertising services, acting with delegated authority on behalf of an Advertiser to register a Political Advertisement and create a Transparency Notice via the Platform. A Representative who submits a Transparency Notice on behalf of an Advertiser confirms, by such submission, that the information provided is complete and accurate for the Advertiser on whose behalf the Representative acts;
"Service" means the Transparency Notice Service, whether purchased as a one-time purchase (cf. clause 3.2(a)) or accessed through a Subscription Service (cf. clause 3.2(b));
"STEP" means the owner of the Platform, the company STEP A/S registered in Denmark with Danish business registration no. 25506227;
"Subscription Service" means for Customers a subscription to the Transparency Notice Service, including, where the Customer has subscribed to a subscription plan, the additional features and benefits included in the applicable subscription plan as described on the Platform;
"Transparency Notice" means the structured registration of information about a Political Advertisement, cf. Article 12 of the Regulation, created via the Platform;
"Transparency Notice Service" means a set of services for Customers related to the collection of transparency information, the creation of a Label and Transparency Notice and follow up with Customers regarding notifications of non-compliant Political Advertisements. Reference is made to Clause 4 for details.
2.1 These Terms of Sale and Delivery of Service apply to all Services purchased by a Customer on the Platform.
2.2 The Terms of Sale and Delivery of Service are supplemented by the Terms of Use for the Platform, which govern the general access to and use of the Platform. In the event of inconsistency between the Terms of Sale and Delivery of Service and the Terms of Use, the Terms of Sale and Delivery of Service shall prevail.
2.3 The Services made available on the Platform are directed exclusively at Customers acting in a professional or political capacity. By creating an account, accepting these Terms of Sale and Delivery of Service, the Terms of Use and making a purchase, the Customer confirms that it is acting in a professional or political capacity. The relationship with Guests and Data Collectors is set out in the Terms of Use.
2.4 The Customer's own purchasing or standard terms and conditions shall not apply unless STEP has accepted them in writing. Any such agreement should not undermine the basic function or role of the Platform in relation to supporting the Regulation and the Implementing Regulation on the transparency of Political Advertising.
2.5 Paid products on the Platform are sold through Paddle as merchant of record. This means the Customer's contractual relationship has two distinct legal components: (a) the purchase and payment, which is concluded with Paddle (as seller of record) and governed by Paddle's buyer terms together with these Terms of Sale and Delivery of Service, covering price, payment, collection and remittance of VAT, invoicing, chargebacks and refund processing; and (b) the right to use the Platform and the Services, which is provided by STEP and governed by these Terms of Sale and Delivery of Service and the Terms of Use. Accordingly, Paddle is the seller of record that processes payment and handles VAT and refunds, while STEP provides the Services and operates the Platform.
2.6 The Core Platform Principles referred to in clause 1.1 are as follows:
3.1 An order for purchase of a Service on the Platform is made when the Customer completes all required information to create a Label and Transparency Notice. STEP reserves the right to reject an order if the Customer's information is manifestly incorrect or incomplete, if there is justified suspicion of and verifiable misuse of this Platform and/or another similar Platform or the Customer's behaviour is in breach of the Core Platform Principles.
3.2 A binding agreement ("a Contract") between STEP and the Customer is concluded: (a) for a one-time purchase of the Transparency Notice Service, when the Customer has completed the registration on the Platform, accepted these Terms of Sale and Delivery of Service and the Terms of Use, payment has been completed and the Customer has received an order confirmation by email; or (b) for the Subscription Service (being a subscription to the Transparency Notice Service and, where applicable, the additional features and benefits included in the applicable subscription plan), when the Customer has completed the subscription registration on the Platform, accepted these Terms of Sale and Delivery of Service and the Terms of Use, the first payment has been processed, and the Customer has received an order confirmation by email.
3.3 The Subscription Service is available in two plans: Basic and Pro. The scope, features, pricing and included allowances of each plan, as well as available add-ons and top-ups, are described in the pricing list published on the Platform. STEP reserves the right to update prices in accordance with clause 7.6.
3.4 The scope and features of each Subscription Service plan are as described on the Platform at the time of the Customer's subscription. STEP reserves the right to modify the features included in a Subscription Service plan upon thirty (30) calendar days' written notice to the Customer. Such modifications shall not entitle the Customer to a refund of subscription fees already paid, provided the modifications do not materially reduce the core functionality of the applicable plan.
3.5 Every Contract is subject to these Terms of Sale and Delivery of Service, regardless of whether the Contract refers to these Terms of Sale and Delivery of Service.
4.1 The Transparency Notice Service comprises:
The Transparency Notice Service may be purchased as a one-time purchase (cf. clause 3.2(a)) or accessed through a Subscription Service (cf. clause 3.2(b)).
4.2 The Transparency Notice Service is a digital service that is delivered when the Label and Transparency Notice is published on the Platform upon the Publisher's confirmation of the Transparency Notice. The Customer acknowledges that the Transparency Notice Service is not a physical product and that no physical delivery takes place.
4.3 STEP endeavours to maintain an uptime of 99.5% measured on a monthly basis. Temporary unavailability does not constitute a delay in delivery.
4.4 STEP may continuously improve and update the Platform and its functionality. Such changes do not constitute a modification of the agreed Service, provided they do not materially reduce existing functionality.
5.1 The Customer, including any Representative, is responsible for the verifiable accuracy of all information provided as set out in the Regulation and the Core Platform Principles. Furthermore, the Customer, including any Representative, is responsible for ensuring that all information provided during registration and when creating Labels and Transparency Notices via the Platform is complete, and up to date, cf. Article 7(3) and Article 12(2) of the Regulation. Errors in the Customer's own information do not entitle the Customer to termination of the Contract, redelivery or refund.
5.2 The Customer's, including any Representative's use of the Platform, is conditional upon compliance at all times with the Regulation, the Implementing Regulation, all applicable national legislation on Political Advertising and the Core Platform Principles.
5.3 The Customer is obliged to indemnify and hold STEP harmless against any and all claims, losses, damages, liabilities, costs and expenses (including reasonable legal fees) arising out of or in connection with: (a) the Customer's breach of its obligations under clauses 5.1 and 5.2, including but not limited to the provision of inaccurate, incomplete or misleading information in its customer registration, Labels or Transparency Notices; (b) the Customer's failure to comply with the Regulation, the Implementing Regulation or applicable national legislation on Political Advertising; (c) any third-party claims, including claims from Data Collectors, competent national authorities or other parties, resulting from the Customer's use of the Platform in a manner inconsistent with these Terms of Sale and Delivery of Service or the Core Platform Principles. The Customer's indemnification obligation shall apply regardless of whether STEP has contributed to the loss, provided that STEP's contribution does not amount to gross negligence or willful misconduct.
5.4 STEP recommends that Publishers include in their contracts for the dissemination of Political Advertisements a standard contractual clause obliging Advertisers and Representatives to identify Political Advertisements and to provide the necessary transparency information as set out in Article 7 of the Regulation and Commission guidance 3.2.4 / 3.2.4.1.
6.1 The Customer acknowledges and accepts that Labels and Transparency Notices created via the Platform will be made publicly available in accordance with Articles 11 and 12 of the Regulation. Upon confirmation of a Transparency Notice by the Publisher, particularly the following information is published: the Advertiser's identity, funding amounts and origin, the Publisher used, campaign period, targeting/ad delivery criteria as well as other information required under Article 12(1) of the Regulation.
6.2 Personal contact information is handled and retained by STEP in accordance with the Regulation and the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) as amended. Only information necessary for transparency purposes is displayed publicly.
6.3 Transparency Notices may be amended via the Platform's amendment request system before and during the campaign period (from start date to end date) and after the campaign period following an upheld notification of non-compliance with the Regulation. All amendments are logged in an immutable amendment history (changelog), cf. the Regulation and Implementing Regulation.
6.4 Pursuant to the Regulation and the Implementing Regulation, STEP is obliged, upon request from Data Collectors, to transmit free of charge and in a machine-readable format the information that STEP is required to retain pursuant to Articles 9, 11 and 12 of the Regulation.
6.5 The Customer accepts that registered data must be transmitted by STEP upon request to Data Collectors as described in Articles 16 and 17 of the Regulation, and that STEP cannot restrict or deny access to the information that the Regulation requires to be made available.
7.1 All prices are stated in euro (EUR) and are exclusive of VAT. Current prices are set out in the price list on the Platform. As Paddle is the merchant of record, Paddle calculates, collects and remits VAT and any other applicable charges at checkout. STEP does not operate any VAT logic.
7.2 The price per Label and Transparency Notice under the Transparency Notice Service is a one-off payment covering the Service including a full 7-year retention period. No recurring fees are charged for Labels and Transparency Notices already created and confirmed.
7.3 The price for the Subscription Service is a recurring fee charged in accordance with the billing cycle (monthly or annual) selected by the Customer at the time of subscription, as set out in the applicable price list on the Platform.
7.3.1 Subscriptions are automatically renewed at the end of each billing cycle unless the Customer terminates the Subscription Service for convenience no later than thirty (30) calendar days before the end of the current billing cycle.
7.3.2 Termination for convenience shall be made through the Platform. Upon termination for convenience, the Customer retains access to the Subscription Service until the end of the current billing cycle. No refund shall be made for the remaining period of a billing cycle in which termination for convenience takes effect. STEP may adjust subscription fees with thirty (30) calendar days' written notice prior to the commencement of a new billing cycle. If the Customer does not accept the adjusted fees, the Customer may terminate the Subscription Service in accordance with this clause.
7.3.3 If STEP has materially failed to provide the Subscription Service in accordance with these Terms of Sale and Delivery of Service, the Customer shall be entitled to a pro rata refund of the subscription fee for the period during which the Subscription Service was unavailable, provided the Customer has notified STEP in accordance with clause 10.
7.4 VAT is calculated and collected by Paddle at checkout based on the Customer's registered status and jurisdiction. For private individuals, the VAT-inclusive price applies; for businesses, organisations and public bodies, the VAT-exclusive price applies. The applicable price is determined from the Customer's registered status and is not set by the Customer at checkout.
7.5 For business-to-business transactions within the EU where the Customer holds a valid VAT identification number (validated via the EU VIES service), Paddle applies the reverse-charge mechanism. An invalid or absent VAT number results in standard-rated VAT being charged by Paddle.
7.6 STEP reserves the right to change prices with thirty (30) calendar days' written notice. Price changes do not affect Labels and Transparency Notices already paid for under the Transparency Notice Service. Price changes to the Subscription Service are governed by clause 7.3.2.
8.1 Payment for the Transparency Notice Service and the Subscription Service is processed by Paddle via the Platform's integrated payment solution. Payment for the Transparency Notice Service is made in advance, and payment for the Subscription Service is made in advance for each billing cycle. The Customer must provide and maintain a valid payment method. Paddle is the entity shown on the Customer's card or bank statement.
8.2 A Label and Transparency Notice is only created and published once payment for the Transparency Notice Service has been completed. If payment is declined, the registration is not completed.
8.3 The Customer receives an electronic invoice or receipt from Paddle for each completed payment. Paddle, as merchant of record, is responsible for ensuring that invoices comply with applicable invoicing requirements.
8.4 In the event of a failed payment, STEP shall notify the Customer in writing and grant a grace period of seven (7) calendar days to complete payment via Paddle. If payment remains outstanding upon expiry of the grace period, STEP is entitled to suspend the Customer's access to the Platform until payment has been completed. The Customer acknowledges and accepts that any suspension of access resulting from the Customer's failure to complete payment in accordance with this clause is a consequence of the Customer's own default, and that the Customer bears the full risk of any consequences arising from such suspension, including any delays in meeting, or non-compliance with, the Customer's obligations under the Regulation and the Implementing Regulation. STEP shall not be liable for any such consequences, provided that STEP has duly notified the Customer in accordance with this clause.
8.5 In the event of a failed recurring payment for the Subscription Service, STEP shall notify the Customer in writing and grant a grace period of ten (10) calendar days to update the payment method via Paddle and complete payment. If payment remains outstanding upon expiry of the grace period, STEP is entitled to suspend or downgrade the Customer's Subscription Service at STEP's sole discretion. If payment is not completed within thirty (30) calendar days of the original due date, STEP may terminate the Subscription Service for cause with immediate effect. Termination of the Subscription Service shall not affect the validity or continued hosting of Transparency Notices already created and paid for under the Transparency Notice Service.
9.1 A Contract where the Transparency Notice has been confirmed and published is irrevocable and may not be terminated. The Customer acknowledges that the Service is fully delivered upon publication and that the statutory 7-year retention obligation makes termination of the Contract impossible. The Customer furthermore may not demand deletion of confirmed Transparency Notices before the expiry of this period. This applies regardless of whether the campaign is ongoing, completed or terminated. The Customer may, however, amend a Transparency Notice, cf. clause 6.3.
9.2 Labels and Transparency Notices with status "Started" or "Draft" that have not yet been confirmed by the Publisher may be deleted by the Customer free of charge. Any prepayment shall be refunded in such cases. Labels and Transparency Notices having reached the status "Pending" will not be refunded.
9.4 Refunds are processed by Paddle. As Paddle is the seller of record, refunds and chargebacks are handled under Paddle's buyer terms and refund policy, together with any mandatory statutory rights. STEP will support legitimate refund requests but is not the payment counterparty.
9.3 STEP may, at its discretion, offer a full or partial refund in the event of documented errors in the Platform that have prevented the Customer from creating a correct Label or Transparency Notice.
10.1 The Customer must report defects in the Platform's functionality in writing to STEP without undue delay and no later than fourteen (14) calendar days after the defect was discovered or should have been discovered.
10.2 STEP shall determine whether the remedy consists of correcting the defect or providing a temporary solution (workaround). STEP endeavours to commence remedial action within seven (7) calendar days of receiving a justified notification of defect.
10.3 Errors in data or content registered or provided by the Customer itself do not constitute a defect of the Platform and are not covered by STEP's remedial obligation.
11.1 The Customer is solely responsible for the accuracy, completeness and lawfulness of all information and content registered or provided by the Customer in connection with the creation of Labels and Transparency Notices. The Publisher is solely responsible for the timely confirmation of the Label and Transparency Notice and the timely handling of notifications of possibly non-compliant Political Advertisements. STEP's responsibility is limited to the technical operation of the Platform and does not extend to the content of any Label or Transparency Notice, nor to the confirmation, or the timeliness of the confirmation, of any Label or Transparency Notice by the Publisher, nor to the Publisher's handling of notifications.
11.2 STEP shall not be liable for indirect losses, including but not limited to operational losses, loss of profit, loss of goodwill, losses resulting from regulatory sanctions imposed on the Customer, losses resulting from the Customer's agreements with third parties lapsing or being breached, or consequential damages of any kind, save to the extent such losses or damages are caused by STEP's gross negligence or willful misconduct. This exclusion also applies with respect to product liability damages to the extent not contrary to mandatory applicable law.
11.3 STEP's liability per Contract, including STEP's product liability, is capped at the greater of: (a) the net amount paid by the Customer to STEP under the Contract in question, or (b) EUR 500 — but not exceeding fifteen thousand EUR (EUR 15,000) in any event.
11.4 STEP is not liable for losses attributable to: (i) inaccurate or incomplete information provided by the Customer, (ii) the Customer's failure to comply with the Regulation or Implementing Regulation, (iii) acts or omissions of third parties, or (iv) circumstances covered by clause 12 (Force Majeure). Notwithstanding the foregoing, STEP shall remain liable, subject to STEP's right to remedy and the limitations of liability set out in these Terms of Sale and Delivery of Service, for direct losses arising from documented defects in the Platform's functionality that are within STEP's reasonable control and that directly prevent the Customer from creating or publishing a Label and Transparency Notice in compliance with the Regulation and the Implementing Regulation.
12.1 Neither party shall be liable for failure to perform obligations under these Terms of Sale and Delivery of Service to the extent that such failure is caused by circumstances beyond the party's reasonable control (force majeure), including but not limited to:
12.2 The affected party shall notify the other party without undue delay. If force majeure persists for more than ninety (90) calendar days, either party may terminate affected Contracts with immediate effect and without any liability.
13.1 All rights to the Platform, including software, design, trademarks and Generated Materials as works of authorship, belong to STEP or its licensors. The Customer obtains only a limited right of use in accordance with the Terms of Use and these Terms of Sale and Delivery of Services.
13.2 The Customer retains ownership of the content it registers but grants STEP the necessary licence to store, process, publish and transmit such content in accordance with the Regulation and Implementing Regulation.
13.3 STEP grants the Customer a non-exclusive, worldwide, royalty-free and non-transferable licence to reproduce, display, embed and adapt the Generated Materials (including Labels, QR codes and Transparency Notice links) in and alongside the specific Political Advertisement(s) to which they relate, to the extent necessary to comply with the labelling and transparency obligations of the Regulation and the Implementing Regulation. This licence subsists for as long as the relevant Political Advertisement is, or is required to remain, available. The Customer may make reasonable adjustments to the Generated Materials (for example to formatting, sizing, placement or styling), provided that such adjustments do not remove, falsify or materially distort the regulated transparency information and that the adjusted materials continue to comply with the Regulation and the Implementing Regulation. The Customer is solely responsible for the regulatory compliance of any Generated Materials it adapts, and STEP gives no warranty in respect of Generated Materials that are not the unaltered Platform-generated materials. For the avoidance of doubt, the Customer may not exploit Generated Materials outside the Political Advertisement(s) to which they relate.
14.1 In case of the Customer's material breach of these Terms of Sale and Delivery of Services, the Terms of Use or the Core Platform Principles, STEP may without prior notice:
Closing the Customer's account shall not affect the validity or continued hosting of Transparency Notices already created and paid for under the Transparency Notice Service.
15.1 STEP may amend these Terms of Sale and Delivery of Service with thirty (30) calendar days' written notice. Notice of amendments shall be provided both on the Platform and by email to the Customer's registered email address. Continued use of the Platform after the amendments take effect constitutes acceptance of the amendments.
15.2 If any provision is found to be invalid, the remaining provisions shall remain in force. The parties shall replace the invalid provision with a valid provision that best fulfils the original purpose.
15.3 STEP's failure to enforce a right under these Terms of Sale and Delivery of Service shall not constitute a waiver of that right.
15.4 The Customer may not assign its rights or obligations under a Contract, including under these Terms of Sale and Delivery of Service, without STEP's prior written consent. STEP may freely assign its rights and obligations under these Terms of Sale and Delivery of Service.
16.1 These Terms of Sale and Delivery of Service are governed by Danish law, excluding Danish rules on conflict of laws.
16.2 Any dispute arising out of or in connection with these Terms of Sale and Delivery of Service shall be resolved in accordance with the following procedure. The party wishing to invoke the dispute resolution procedure shall notify the other party in writing, setting out the nature of the dispute and the relief sought. The parties shall thereafter attempt in good faith to resolve the dispute amicably within thirty (30) calendar days from the date of receipt of such written notice. If the dispute has not been resolved amicably within the afore-mentioned period, either party may refer the dispute to the City Court in Odense, Denmark, as the court of first instance. This jurisdiction clause shall not prevent a party from seeking injunctive relief or any other interim relief from a court of competent jurisdiction.
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