Date of Revision: June 15, 2026

Welcome to FlirtaGPT®. These Terms of Service (the “Terms” or “TOS”) form a legally binding agreement between you and Aithalon Labs Ltd, a company duly incorporated in the Republic of Cyprus, having its registered address at Lapathou, 6, Strovolos, 2027, Nicosia, Cyprus, and registered with the Cyprus Department of Registrar of Companies and Intellectual Property under company number HE 493820 (“FlirtaGPT,” “we,” “us,” or “our”), governing your access to and use of flirtagpt.ai and any affiliated websites, applications, products and services to which you may be redirected from flirtagpt.ai, including all content contained therein (collectively, the “Services”).

By accessing or using the Services, you agree to be bound by these Terms and by all other policies published on our website, as updated from time to time (the “Policies”), including without limitation our Privacy Notice, Cookies Notice, Blocked Content Policy, Underage Policy, DMCA Policy, 2257 Exemption Statement and Complaint Policy. Our acceptable-use rules are set out in Section 7 of these Terms, and our refund terms are set out in Section 5. If you do not agree with these Terms or our Policies, please cease using the Services.

Language of these Terms. These Terms are originally drafted in English. Translations are provided for convenience only. In the event of any conflict between the English version and any translation, the English version shall prevail, except where applicable consumer-protection law of your country of habitual residence requires otherwise.

For purposes of these Terms, “you” and “your” mean you as a user of the Services. The Services are intended for personal, non-commercial use only by adults aged 18 years or older. You agree not to use the Services for any commercial, illegal, or unauthorised purpose.

Key points to keep in mind before using FlirtaGPT

(a) You are interacting with artificial intelligence. All Characters, companions, voices, images, videos and text available through FlirtaGPT are produced by automated AI systems. They are not real persons, do not have feelings, memories, or consciousness, and any expression of emotion, opinion, or factual claim is automatically generated. Any resemblance to a real person, living or deceased, is unintended unless expressly authorised by that person.

(b) The Services are for adult entertainment and lawful personal expression only. They are not intended as emotional, therapeutic, medical, psychiatric, psychological, legal, financial, tax or other professional advice or support. If you are feeling distressed or experiencing mental-health difficulties, please reach out to a qualified professional. Crisis resources include the 988 Suicide & Crisis Lifeline (United States; call or text 988), Samaritans (United Kingdom and Ireland; 116 123), the EU emergency line 112, the International Association for Suicide Prevention (iasp.info/resources/Crisis_Centres), and Befrienders Worldwide (befrienders.org).

(c) AI outputs may be inaccurate, biased, offensive or fabricated. Because the Services rely on emerging AI technology, generated outputs may sometimes produce content that is inaccurate, incomplete, biased, offensive, or not reflective of human judgement. You are responsible for evaluating the appropriateness of any information provided. You must not rely on Service outputs for any decision producing legal effects or similarly significant effects, and you must independently verify any output before acting on it.

(d) Conversations with AI Companions are entirely fictional. AI Companions are programmed simulations and do not possess genuine emotions, intentions, or the ability to fulfil promises in the real world. Any elements within conversations that may resemble reality — such as offers of real-life meetings or promises of tangible outcomes — are entirely fictional and should not be taken seriously.

(e) The Services are 18+ only. You must be at least 18 years of age (or the age of majority in your jurisdiction, whichever is greater) to access or use the Services. Access by minors is strictly prohibited. We may suspend or terminate accounts that we have reason to believe belong to minors or that fail re-verification. See Section 2 (Age and Eligibility).

Table of Contents

• 1.  General
• 2.  Age and Eligibility
• 3.  Account
• 4.  Premium Subscription, Credits and Paid Services
• 5.  Refund Policy and EU/UK Right of Withdrawal
• 6.  AI-Generated Content; Synthetic-Content Marking; AI Act Disclosures
• 7.  Restrictions of Conduct and Content; Acceptable Use
• 8.  Content Moderation, Notice-and-Action and Internal Complaints (Digital Services Act)
• 9.  Your Content and Licence Grant
• 10. Use of Personal Data and AI Training
• 11. Intellectual Property
• 12. DMCA Policy and Designated Agent
• 13. 18 U.S.C. §§ 2257 and 2257A — Exemption Statement
• 14. No Guarantee of Accuracy, Originality, or Perfection
• 15. Disclaimers and Limitation of Liability
• 16. Indemnification
• 17. Third-Party Links and Services
• 18. Geographic Restrictions
• 19. Governing Law, Jurisdiction and Consumer Carve-Out
• 20. Arbitration Agreement and Class-Action Waiver (United States Users Only)
• 21. Changes to Terms and Policies
• 22. Termination and Assignment
• 23. Complaint Policy
• 24. Miscellaneous
• 25. Contact Information

• Annex A — EU/UK Model Withdrawal Form

1. General

FlirtaGPT is an online application that uses artificial-intelligence algorithms to generate virtual and fictional characters (“AI Companions,” “Characters,” or “AI Characters”), with whom you can chat and exchange messages. The Services also include other media such as AI-generated images, videos and per-message text-to-speech (“TTS”) audio playback of Character text messages. All such media displayed by or generated through the Services is exclusively computer-generated by AI and depicts no actual human being.

You may initiate exchanges with AI Characters that are pre-made and that we make available on the platform. Your exchanges with AI Characters may include text, image requests, TTS playback of Character text messages, or other modes of exchange as we may make available and expand from time to time. We do not currently provide live audio or video calls; the Services use TTS playback of text messages only.

We may de-list (remove) AI Characters and modify or delete features or content at any time in our sole discretion.

The Services are offered in multiple user-interface languages, which may be selected through the language switcher in the user interface and may be updated from time to time. The English version of these Terms prevails in case of conflict between language versions, as set out in the preamble.

2. Age and Eligibility

2.1 Minimum age

You must be at least 18 years of age (or the age of majority in your jurisdiction, whichever is greater) to access or use the Services. The following users are not authorised to access or use the Services and must not sign up for an Account:

1. any individual under 13 years of age;
2. any individual under 16 years of age who is a citizen or resident of the European Economic Area, the United Kingdom or Switzerland;
3. any individual under 18 years of age in any jurisdiction;
4. any individual prohibited by applicable law from accessing online adult content in their jurisdiction.

2.2 Age verification

We require all users to confirm at registration that they are 18 years of age or older. We log the verification timestamp, IP address, user-agent string, and device fingerprint at the time of confirmation. We may, at our sole discretion, require additional verification (including but not limited to facial age estimation, government-issued ID matching, or third-party age-assurance) where we have reason to believe a user may be under 18, where applicable law in the user’s jurisdiction requires it, or where our payment processors require it. We retain age-verification metadata (timestamp, IP address, user-agent and device fingerprint at time of confirmation) for a period of seven (7) years from the date of last activity on the Account, in hashed form where applicable, for the purpose of demonstrating compliance with our age-verification obligations under applicable law.

We may suspend or terminate any Account that we believe belongs to a minor, that fails re-verification when requested, or that attempts to circumvent our age controls. We may require you to re-verify your age at any time.

2.3 Children’s data

FlirtaGPT does not knowingly collect personal information from any individual under the applicable minimum age threshold. If we learn that we have collected personal information from a child below the applicable threshold, we will delete that information without undue delay and block the relevant Account. To report a suspected underage user, contact [email protected].

2.4 Capacity and authority

By using the Services you represent and warrant that (i) you are entering into these Terms only on behalf of yourself; and (ii) you have the legal capacity to form a binding contract with us. Additional eligibility representations are set out in Section 2.5.

2.5 Eligibility Representations and Compliance Obligations

Adult content; AI-generated only. The Services offer AI-generated adult (“18+”) companion experiences. No content depicts real, identifiable persons. By accessing the Services you confirm that adult, AI-generated sexually explicit material is not unlawful for you to access in your jurisdiction.

Restricted territories. You represent and warrant that you are not accessing the Services from a Restricted Territory listed in Section 18, that you are not a tax resident of a Restricted Territory, and that you will not attempt to circumvent our geo-blocks (including via VPN, proxy, or misrepresentation of location). Accessing the Services from a Restricted Territory is a material breach of these Terms.

Your compliance obligations. It is your sole responsibility to ensure that your access to and use of the Services is lawful in your jurisdiction. Without limiting the foregoing, you are responsible for (a) determining whether AI-generated sexually explicit material is lawful where you access the Services; (b) labelling, declaring, or refraining from sharing AI-generated outputs in accordance with applicable law; (c) taxes on transactions made through the Services; and (d) any local consent, recording, or publication restrictions.

Indemnity (consumer-law-compliant). To the extent permitted by mandatory consumer-protection law of your jurisdiction of habitual residence, you agree to indemnify Aithalon Labs Ltd against third-party claims and regulatory penalties directly caused by (i) your wilful or grossly negligent breach of the Restricted Territories restriction in Section 18, or (ii) your wilful misrepresentation of your age or location. This indemnity does not apply (and shall be deemed not to apply) where you are a consumer protected by Council Directive 93/13/EEC, the UK Consumer Rights Act 2015, or analogous mandatory law, and the obligation it would impose on you would be regarded as unfair under such law.

Mandatory consumer rights preserved. Nothing in these Terms excludes or limits any right you have under mandatory consumer-protection law applicable in your country of habitual residence (including, where applicable, Council Directive 93/13/EEC, Council Directive 2011/83/EU, Cyprus Law 133(I)/2013, the UK Consumer Rights Act 2015, or California Civil Code §1750 et seq.). Nothing in these Terms requires you to waive or limit liability for personal injury, fraud, or wilful misconduct of Aithalon Labs Ltd. If any provision in this Section 2.5 is held unenforceable in any jurisdiction, that provision shall be severed in that jurisdiction only and the remainder of this Section shall continue in force.

3. Account

3.1 Account creation

Parts of our Services require you to create a user account (an “Account”). You may create an Account using one of three authentication methods: (a) email address and password; (b) Google sign-in (OAuth 2.0); or (c) Discord sign-in (OAuth 2.0). Where a third-party identity provider does not return an email address, you may be required to provide one separately for service communications.

We use a soft email-verification model: you may begin using free features without first clicking a verification link, but we require email verification before any paid transaction (including Premium Subscription and Credits purchases). We may restrict or suspend functionality if your email address fails delivery checks or is reported as fraudulent.

3.2 Onboarding flow

After registration you will be asked to complete a Personalisation step (selecting a nickname and gender to be used by AI Characters in addressing you) and an 18+ Age Verification step (recording an *age_verified_at* timestamp on your Account). You must complete both steps to access AI Companion features.

3.3 Account responsibility and security

You are fully responsible for all activities occurring under your Account. Your Account is non-transferrable. You may not sell, lend, or otherwise share your Account with any other person, for commercial purposes or free of charge. You agree to (a) provide true and correct information when registering; (b) keep that information current, accurate and correct; and (c) protect the confidentiality of your Account, login credentials and any session tokens. You must notify us at [email protected] without undue delay if you suspect unauthorised use of your Account.

3.4 Re-verification and supplementary information

We may from time to time require further information from you, including for example information to verify or re-verify that you are an adult, to confirm payment-method ownership, or to investigate suspected fraud or violation of these Terms or our Policies.

3.5 Account suspension and termination

We reserve the right to terminate or restrict your Account, or otherwise revoke your access to the Services, at any time if we, in our sole discretion, have reason to believe or suspect that you have violated these Terms or any other Policy, including the acceptable-use rules in Section 7 and the Blocked Content Policy. Suspension or termination decisions are subject to the internal complaint-handling mechanism in Section 8 and the Complaint Policy in Section 23.

3.6 Account deletion

You may delete your Account at any time from your account settings. Deletion of your Account and personal data is immediate and permanent: there is no grace period and no reactivation. Once deletion is initiated, your personal data will be purged asynchronously by our background-job system in accordance with our Privacy Notice and our Underage Policy. As an exception, anonymised financial records (containing no personal identifiers) will be retained for ten (10) years to comply with applicable tax and accounting laws of the Republic of Cyprus. Anonymised account-deletion feedback (with no user identifier and only month-granularity timestamps) may also be retained for analytics.

3.7 No ownership of the Account

You acknowledge and agree that you have no ownership or other property interest in your Account, and that all rights in and to your Account belong to and inure to the exclusive benefit of FlirtaGPT.

4. Premium Subscription, Credits and Paid Services

4.1 Free use

As a free user, you may generally send a maximum of five (5) messages to AI Companions and view up to five (5) free photos. Further use requires either a Premium Subscription or the purchase of Credits.

4.2 Premium Subscription

Premium Subscriptions are offered in monthly, quarterly (three-month) and annual (twelve-month) plans, billed automatically at the start of each billing period at the price disclosed at checkout. Premium grants unlimited messaging access to AI Companions and a monthly Credits stipend disclosed at checkout, which may be used to access extended features such as additional photos, videos, and TTS audio of Character text messages. The stipend is delivered monthly even on quarterly and annual plans.

Subscriptions are set to renew automatically at the end of each subscription period for the duration and price disclosed at checkout. Auto-renewal can be cancelled at any time in your settings, with cancellation taking effect at the end of the current paid period. We will provide an in-product cancellation function in compliance with Directive (EU) 2023/2673 from 18 June 2026.

4.3 Credits

Credits are an internal virtual credit denominated and stored in milli-Credits integer units (where 1 Credit = 1,000 milli-Credits). Credits enable access to a la carte features such as media and TTS playback. Credits have no monetary value, are not legal tender, and may not be transferred between Accounts, traded, exchanged for cash, or used to settle outstanding payments. Credits are tracked in a server-authoritative ledger; clients never compute charges.

Two categories of Credits exist: (i) Stipend Credits — Credits granted as part of the Premium Subscription monthly stipend, which expire at the end of each Premium billing period and do not roll over; and (ii) Purchased Credits — Credits acquired through one-time purchases, which persist on your Account permanently until consumed or until the Account is deleted, regardless of Premium status.

4.4 Pricing, taxes and order-button labelling

All applicable fees, taxes, charges and the billing-descriptor that will appear on your statement are disclosed at checkout. The order-confirmation button at checkout is labelled “Order with obligation to pay” in accordance with Article 8(2) of Directive 2011/83/EU on consumer rights, as transposed in Cyprus by Law 133(I)/2013.

4.5 Payment processing

Payments are processed by [Payment Processor — Final Selection Pending], whose privacy notice and terms apply to that processing in addition to ours. We may use one or more payment-service providers and orchestration providers from time to time, and we will list the current providers in our Privacy Notice as Article 28 sub-processors.

Cardholder confirmation. Before completing any purchase, you will be asked to confirm that you are the lawful cardholder of the payment method provided, that the payment method is registered in your name, and that you are authorised to use it for the transaction. This confirmation is required and the transaction will not proceed without it.

4.6 Plan changes mid-cycle

Plan upgrades and downgrades take effect at the start of the next billing cycle. We do not support pro-rated mid-cycle plan changes. To switch plans, cancel your current subscription, wait for it to expire at the end of the current paid period, then purchase the new plan. Any Credits already on your Account persist as described in Section 4.3.

4.7 Auto-renewal disclosure

By initiating a Premium Subscription, you authorise us (acting through our payment-service provider) to charge your designated payment method automatically at the start of each renewal period until you cancel auto-renewal. We will display the renewal terms clearly at checkout, and you may view and cancel auto-renewal at any time in your account settings.

5. Refund Policy and EU/UK Right of Withdrawal

5.1 Premium Subscription refunds

Premium Subscription refunds are issued on a manual case-by-case basis at our discretion via our customer-support team. Where a refund of a Premium Subscription is granted, any Stipend Credits delivered for that period will be deducted from your Credits balance via a negative ledger entry.

If you wish to request a refund, contact [email protected] with your Account email, transaction date and reason for the request.

5.2 Credits — no refunds

All purchases of Credits are final. We do not refund Credits, whether used or unused, save where a refund is required by mandatory consumer-protection law as set out in Section 5.4 below or where a manual ledger adjustment is exceptionally granted in our sole discretion.

5.3 Real-time generation failures — automatic Credits refund

Where you spend Credits on a real-time generation feature (including TTS playback of Character text messages and any future real-time scene-generation feature) and that generation fails for technical reasons attributable to us, the consumed Credits will be automatically refunded to your Account via a positive ledger entry. No further action is required on your part.

5.4 EU/UK 14-day right of withdrawal — Article 16(m) waiver mechanic

Statutory right. If you are a consumer habitually resident in the European Economic Area (“EEA”) or the United Kingdom (“UK”), you have the right under Article 9 of Directive 2011/83/EU on consumer rights (as transposed in Cyprus by Law 133(I)/2013) and the UK Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, to withdraw from a distance contract with FlirtaGPT within fourteen (14) days without giving any reason.

How to exercise. To exercise your right of withdrawal, you may use the model withdrawal form set out in Annex A to these Terms or send any other unequivocal statement to [email protected]. The withdrawal period expires fourteen (14) days from the date on which we sent you confirmation of the contract.

Effects of withdrawal. If you validly exercise your right of withdrawal, we will reimburse you all payments received from you, less any prorated amount reflecting Services consumed between the date of your purchase and the date you requested withdrawal. Reimbursement will be made without undue delay and in any event no later than fourteen (14) days from the day on which we are informed of your decision to withdraw. Reimbursement will be made using the same means of payment used for the initial transaction unless you have expressly agreed otherwise; in any event, no fees will be charged in connection with the reimbursement. The right of withdrawal applies to the initial purchase only and does not apply to renewal periods.

Article 16(m) waiver of the right of withdrawal for digital content not supplied on a tangible medium. Article 16(m) of Directive 2011/83/EU permits a consumer to lose the 14-day right of withdrawal in respect of digital content not supplied on a tangible medium where (i) performance has begun with the consumer’s prior express consent, (ii) the consumer has acknowledged that performance will begin during the withdrawal period and that he or she will thereby lose the right of withdrawal, and (iii) the trader has provided written confirmation of the contract.

By ticking the box at checkout marked “I consent to immediate access and waive my 14-day withdrawal right”, you (a) expressly consent that performance of the digital content (including the delivery of Premium features, the credit of Credits to your Account, and immediate access to AI Companion conversations and AI-generated media) may begin during the 14-day period; and (b) acknowledge that you thereby lose your right of withdrawal in accordance with Article 16(m) of Directive 2011/83/EU. Where this waiver checkbox is not ticked, Credits will not be credited to your Account and Premium features will not be activated until the 14-day withdrawal period has expired.

Where you have given the Article 16(m) waiver, Credits purchases (used or unused) and consumed Premium periods are non-refundable. Where you have not given the Article 16(m) waiver, you may withdraw within 14 days, and Premium fees will be reimbursed less a prorated amount for the days of access provided, and unused Purchased Credits will be reimbursed in full.

5.5 No refund for content moderated, removed, or restricted for policy violations

You will not be refunded or reimbursed for any previously paid-for content that was moderated, restricted, or removed for violating these Terms or any other Policy, nor for restrictions on your use of the Services as a result of moderation actions taken in response to such violations.

5.6 No refund for changes in Service content or functionality

We may modify or delete features, AI Characters, or content at any time at our sole discretion. You will not be refunded or reimbursed for previous payments related to any such modifications or deletions that do not change the core Services within the meaning of applicable law.

5.7 Effect of cancellation, refund or chargeback

Upon cancellation of a Premium Subscription, you will retain access to Premium features until the end of the then-current paid period; thereafter, your access reverts to the free tier and any unused Stipend Credits will expire. Purchased Credits persist. If a payment is refunded or a chargeback is filed, the relevant Premium Subscription or Credits purchase is immediately cancelled, all access to associated Premium features is revoked, and any Credits associated with that purchase are removed from your Account at the time of refund or chargeback.

6. AI-Generated Content; Synthetic-Content Marking; AI Act Disclosures

6.1 Article 50(1) — interaction with AI

You are interacting with an artificial-intelligence system. All Characters, companions, voices, images, videos and synthetic-text outputs available through FlirtaGPT are produced by AI models. They are not real persons, do not have feelings, memories, or consciousness, and any expression of emotion, opinion, or factual claim is automatically generated. Any resemblance to a real person, living or deceased, is unintended unless expressly authorised by that person.

6.2 Article 50(2) — synthetic-content marking

Image, audio, video and synthetic-text outputs delivered through the Services are marked as artificially generated where technically feasible. Marking methods may include visible watermarks, embedded metadata, and machine-readable provenance signals, in each case appropriate to the medium and to the state of the art. We will continue to enhance our marking methods in line with Article 50(2) of Regulation (EU) 2024/1689 (the “EU AI Act”) as those obligations come into force on 2 August 2026 and as common standards (including C2PA) become technically and economically reasonable for our category of provider. You agree (a) not to remove, alter, or attempt to circumvent any such markings; and (b) not to redistribute outputs without preserving them.

6.3 Article 50(4) — deepfake disclosure

Where any synthetic image, audio or video constitutes a “deepfake” within the meaning of Article 3 of Regulation (EU) 2024/1689 (the “EU AI Act”), the Services will clearly and distinguishably disclose that the content has been artificially generated or manipulated, in accordance with Article 50(4).

6.4 Risk classification

FlirtaGPT operates as a limited-risk AI system within the meaning of the EU AI Act. The Services do not use subliminal or purposefully manipulative techniques to materially distort behaviour or impair informed decision-making. The Services do not employ AI systems prohibited under Article 5 of the EU AI Act.

6.5 No professional advice

FlirtaGPT is not a healthcare or medical-device provider. Outputs of the Services are not a substitute for medical, psychiatric, psychological, therapeutic, legal, financial, tax, or other professional advice. Outputs may be inaccurate, biased, offensive, or fabricated. You must not rely on Service outputs for any decision producing legal effects or similarly significant effects, and you must independently verify any output before acting on it.

6.6 Detection and referral for self-harm and suicidal ideation

The Services may use automated and human review protocols designed to detect expressions of self-harm or suicidal ideation. Where such expressions are detected, the Services may display crisis-intervention resources, refer you to a recognised crisis service provider, and periodically remind you that you are not interacting with a human. We do not represent that this functionality is fault-tolerant; users in crisis must seek immediate human assistance from a qualified professional or crisis line. Crisis resources are listed in the preamble of these Terms.

7. Restrictions of Conduct and Content; Acceptable Use

7.1 General restrictions

In accessing and using the Services, you agree to abide by the acceptable-use rules set out in this Section 7, our Blocked Content Policy and the following rules, restrictions, and limitations:

1. you will not modify, translate, adapt or reformat any aspect of the Services;
2. you will not decipher, decompile, disassemble, or reverse-engineer, or otherwise attempt to discover the source code or structure of, the software or materials comprising the Services, except where the foregoing is permitted by applicable local law notwithstanding such restrictions, and then only to the extent that such intended activities are disclosed in advance in writing to us;
3. you will not interfere with or circumvent any security feature of the Services or any feature that restricts or enforces limitations on the use thereof, including age-assurance and content-moderation systems;
4. you will not use the Services to gain unauthorised access to our or any third party’s data, systems or networks;
5. you will not use the Services in any manner that could damage, disable, overburden, impair or otherwise interfere with our systems, networks, or other users’ use of the Services, including denial-of-service attempts, scraping, automated access, or excessive request rates;
6. you will not use the Services in any way that, in our sole discretion, may expose us or others to liability or damages;
7. you will not use the Services to achieve unlawful ends, to offend others, to harass, threaten, defame, or commit a crime;
8. you will not remove, change or obscure any copyright, trademark, hyperlink or other proprietary-rights notices contained in or associated with the Services or in any AI-generated output, including the synthetic-content markings and watermarks referred to in Section 6;
9. you will comply with all applicable laws in your access and use of the Services, including the laws of the jurisdiction where you live and access the Services;
10. you may not access or attempt to access the Services from any jurisdiction listed in Section 18 (Geographic Restrictions). We implement technical measures to enforce these restrictions, and any attempt to access the Services or to evade such technical measures (including via virtual private networks, proxy servers, or misrepresentation of location) is a violation of these Terms and may result in immediate Account termination without refund.

7.2 No real-person impersonation; no deepfakes; no unauthorised likenesses

You will not, and you will not attempt to, use any feature of the Services to:

1. submit recordings, images, audio or other media of any real person (including but not limited to celebrities, public figures, or persons known to you) without that person’s documented written consent;
2. create, request or engage in deepfakes or impersonations of any real person;
3. configure any AI Character to represent, impersonate or simulate a specific real person, living or deceased, by using their name, likeness, biographical details, voice, or other identifying information without that person’s explicit written consent;
4. generate non-consensual intimate imagery of any real person, the creation or distribution of which is prohibited by applicable law including the United States TAKE IT DOWN Act of 2025.

Violations of this Section 7.2 will result in immediate content removal, Account termination, and where required, referral to law-enforcement authorities.

7.3 Content responsibility

You, as a user of the Services, are solely responsible for the inputs you submit and for any output generated by the AI Companions in response to your inputs, including any text messages, voice messages, images, and videos. The AI Companions respond based on the conversations you lead and the settings you select. We do not control or endorse any output generated by the AI Companions.

7.4 No legal-effect or significant-effect decisions

Outputs of the Services do not constitute decisions producing legal effects concerning you or similarly significantly affecting you within the meaning of Article 22 of the EU General Data Protection Regulation. Where any feature of the Services does involve solely automated decision-making producing such effects (for example, automated suspension of Accounts on safety grounds), you have the right to obtain human intervention by contacting [email protected], to express your point of view, and to contest the decision.

8. Content Moderation, Notice-and-Action and Internal Complaints (Digital Services Act)

8.1 Moderation

While lawful adult content is generally permitted for paying adult users, and conversations with AI Companions are generally confidential, we have implemented content-moderation controls to ensure compliance with these Terms, the acceptable-use rules in Section 7, our Blocked Content Policy and applicable law. If our moderation controls detect anything that violates our Policies, we (or authorised partners) may access and manually review the flagged content and other content associated with the Account and take appropriate action. Such actions may include altering or refusing a request, removing content, restricting features, suspending or terminating the Account, or referring the content to appropriate authorities.

8.2 Article 14 — terms and conditions of moderation

Our content-moderation rules, the procedures we apply, and any algorithmic decision-making and human review involved in our moderation are described in plain and intelligible language in this Section 8, in Section 7 (Acceptable Use) and in the Blocked Content Policy. We will apply our moderation rules diligently, objectively and proportionately, with due regard for the rights and legitimate interests of all parties.

8.3 Article 16 — notice and action mechanism

If you consider any content available through the Services to be illegal, you may submit a notice to [email protected]. Notices submitted under Article 16 of Regulation (EU) 2022/2065 (the “Digital Services Act” or “DSA”) should include:

1. a sufficiently substantiated explanation of the reasons why you allege the content to be illegal;
2. a clear indication of the exact electronic location of the content (URL or other identifier);
3. your name and email address (except in the case of content believed to involve offences referred to in Articles 3 to 7 of Directive 2011/93/EU);
4. a statement confirming your good-faith belief that the information and allegations contained in the notice are accurate and complete.

8.4 Article 17 — statement of reasons

Where we restrict the visibility of, or remove, your content; suspend, terminate or otherwise restrict monetary payments, the provision of the Services in whole or in part; or suspend or terminate your Account, we will provide you with a clear and specific statement of reasons for that decision in accordance with Article 17 DSA, including the facts and circumstances relied on, identification of any automated tools used, the legal or contractual ground relied on, and information on redress available to you.

8.5 Article 20 — internal complaint-handling system

If you are affected by a moderation decision (whether as a notifier or as the user whose content was actioned), you may lodge an internal complaint, free of charge, against that decision via [email protected] for at least six (6) months from the date of the decision. We will examine complaints in a timely, non-discriminatory, diligent and objective manner. We will reverse a decision where the complaint contains sufficient grounds to consider that the original decision was incorrect.

8.6 Article 21 — out-of-court dispute settlement

Where you remain dissatisfied with the outcome of an internal complaint, you may submit any dispute relating to a moderation decision to a certified out-of-court dispute-settlement body recognised by the Digital Services Coordinator of the Republic of Cyprus. We will engage in good faith with any such certified body.

8.7 Article 23 — measures against misuse

We will suspend, for a reasonable period and after issuing a prior warning, the provision of the Services to users who frequently provide manifestly illegal content, and the processing of notices and complaints submitted by individuals or entities or by complainants that frequently submit notices or complaints that are manifestly unfounded. Three substantiated violations or a single egregious violation will trigger termination.

8.8 DSA points of contact

Single point of contact for Member State authorities, the European Commission and the European Board for Digital Services (Article 11 DSA): [email protected]. Single point of contact for users (Article 12 DSA): [email protected].

8.9 CSAM zero tolerance

We have a zero-tolerance policy for child sexual abuse material (“CSAM”) and any content that sexualises, or appears to sexualise, individuals under 18 years of age. Attempting to create, request, generate, upload, or share such material is prohibited by law and our Blocked Content Policy. We employ industry-standard detection systems, manually review flagged content, and report known CSAM to the National Center for Missing & Exploited Children (NCMEC) and to other competent authorities, including INHOPE-affiliated hotlines, as appropriate.

9. Your Content and Licence Grant

You may provide input while using the Services and receive output based on your input. Inputs and outputs are collectively referred to as “Content”. “Inputs” include anything initiated by you or from your Account, including prompts, exchanges with AI Characters, and uploaded media (where applicable). You represent and warrant that you have all rights, licences, and permissions needed to provide your inputs and that your inputs comply with applicable law and our Policies.

You retain your intellectual-property ownership rights over your inputs. We do not claim ownership of your inputs, but we require a licence to operate the Services.

By providing inputs to the Services, you grant FlirtaGPT a non-exclusive, worldwide, royalty-free, fully paid-up, transferable, sub-licensable licence to host, store, transmit, display, process, modify (for technical reasons such as formatting and language detection), and make available your inputs and outputs solely for the following purposes:

1. to operate, secure, deliver, debug and provide the Services to you;
2. to detect, investigate, and act on violations of these Terms or our Policies, including the prevention of CSAM, fraud, and abuse;
3. to comply with applicable law, court orders, or lawful requests from competent authorities;
4. to defend, exercise, or establish our legal rights.

This licence does not include any right to train, fine-tune, evaluate or otherwise develop our generative AI models on your Content. See Section 10.

10. Use of Personal Data and AI Training

Current practice. As of the Effective Date of these Terms, we do not train, fine-tune, or otherwise develop our generative AI models on user-submitted Content (including conversations with AI Companions, prompts, generated outputs, account-level data, or media uploads). The behaviour of our AI Characters is defined exclusively by character-specific system prompts, persona files and language hints maintained by our internal AI specialists, and is not derived from user data.

We may use de-identified, aggregated technical telemetry (for example, latency metrics, queue depths, error rates) to improve the performance and reliability of the Services. Such telemetry does not include the substance of your conversations or any data through which you may be identified.

Future training. We may, in the future, decide to use certain categories of Content for the training, fine-tuning, or evaluation of our AI models. If we make this change, we will:

1. provide you with prior notice through the Services and by email at least thirty (30) days before any change takes effect;
2. where required by applicable law (including but not limited to Article 6 of the General Data Protection Regulation), obtain your prior, informed, and specific opt-in consent before using any of your Content for training purposes;
3. provide you with the ability to opt out of AI training in your account settings, with such opt-out applying both prospectively and retroactively to data we hold;
4. not use for training any Content from users who have opted out, who are residents of jurisdictions where mandatory consent is required and have not provided it, or who are minors;
5. describe, in our updated Privacy Notice, the categories of Content used for training and the purposes for which they are used.

Our processing of your personal data is described in detail in our Privacy Notice at flirtagpt.ai/privacy, which forms part of these Terms by reference.

11. Intellectual Property

All intellectual-property rights in the Services and any embedded materials — including without limitation technology, systems, files, documents, text, photographs, information, images, videos, audio, software and AI models — are owned by or licensed to FlirtaGPT. You may access and use the Services for your personal, non-commercial use only. We grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to access and use the Services in accordance with these Terms. This licence does not constitute a transfer of title under any circumstances. The licence shall automatically terminate on any violation of these Terms or our Policies and may be terminated by us at any time.

All trademarks, service marks, logos, trade names and any other proprietary designations of FlirtaGPT used herein are trademarks or registered trademarks of FlirtaGPT. Other trademarks, service marks, logos, trade names and any other proprietary designations are the trademarks or registered trademarks of their respective parties.

Your use of the Services may be subject to the licence and use restrictions set forth in third-party model licences, including but not limited to the CreativeML Open RAIL++-M Licence and Apache Licence Version 2.0, as applicable to underlying models used in the Services.

You agree that submission of any ideas, suggestions, documents, and proposals to FlirtaGPT (“Feedback”) is at your own risk and that FlirtaGPT has no obligations with respect to such Feedback, including obligations regarding confidentiality. You agree that FlirtaGPT may use your Feedback without restriction, attribution or compensation to you.

12. DMCA Policy and Designated Agent

12.1 Bridge clause

Although FlirtaGPT is established in the Republic of Cyprus, we maintain a notice-and-takedown process in good-faith compliance with Title II of the United States Digital Millennium Copyright Act (the “DMCA”), 17 U.S.C. § 512, in addition to our notice-and-action mechanism under Article 16 of the Digital Services Act (Section 8 of these Terms). Notices may be submitted under either regime, although the elements of a valid notice differ as set out below. We are in the process of registering our designated DMCA agent with the United States Copyright Office Designated Agent Directory; until such registration is completed, copyright complaints may be sent directly to [email protected] under the procedures set out in our DMCA Policy.

12.2 Designated DMCA Agent

We are in the process of designating and registering a DMCA agent with the United States Copyright Office Designated Agent Directory at https://www.copyright.gov/dmca-directory/. Until that registration is complete, notifications of claimed copyright infringement should be sent to:

Recipient: Aithalon Labs Ltd — Copyright Complaints

Address: Lapathou, 6, Strovolos, 2027, Nicosia, Cyprus

Email: [email protected]

12.3 DMCA notice procedures

The detailed procedures for submitting a notice of claimed infringement under 17 U.S.C. § 512(c)(3), our response to notices, counter-notification under 17 U.S.C. § 512(g)(3), our repeat-infringer policy under 17 U.S.C. § 512(i), the misrepresentation warning under 17 U.S.C. § 512(f), and the applicable timeframes, are set out in our DMCA Policy, which forms part of these Terms and is available on our website. Notices and counter-notices should be sent to our DMCA Agent at the contact details in Section 12.2 above; the notice templates included in our DMCA Policy may be used.

13. 18 U.S.C. §§ 2257 and 2257A — Exemption Statement

All visual depictions and content displayed on or generated by the Services are exempt from the record-keeping and labelling requirements of 18 U.S.C. §§ 2257 and 2257A and 28 C.F.R. Part 75 because:

1. the Services do not produce, depict, or contain visual depictions of any actual human being engaged in actual or simulated sexually explicit conduct or in the lascivious exhibition of the genitals or pubic area, within the meaning of those statutes;
2. all Characters, voices, text, images, audio, video and other outputs are wholly computer-generated by artificial-intelligence systems and do not represent or feature any real, identifiable person, living or deceased; the term “simulated sexually explicit conduct” as construed by the United States Department of Justice (73 Fed. Reg. 77,470 (Dec. 18, 2008)) and by the United States Supreme Court in Ashcroft v. Free Speech Coalition, 535 U.S. 234 (2002), means conduct engaged in by real human beings, not by computer-generated images;
3. the Services do not hire, contract for, manage, photograph, film, videotape, or otherwise arrange for the participation of any human performer.

Because all content displayed by or generated through the Services is exclusively computer-generated and depicts no actual human being, FlirtaGPT is not a “producer” within the meaning of 18 U.S.C. § 2257(h)(2) or 28 C.F.R. § 75.1(c) and is not required to maintain or designate a custodian of records under that statute or regulation.

Users are strictly prohibited from uploading images, audio, or other media depicting real people or from prompting the Services to generate the likeness of any identifiable real person without that person’s documented written consent. Any such content will be removed within forty-eight (48) hours of substantiated notice and may result in Account termination, referral to the National Center for Missing & Exploited Children where applicable, and referral to law-enforcement authorities.

Notices regarding allegedly non-consensual or unauthorised content depicting real persons may be submitted to [email protected]. Questions regarding this Statement may be directed to [email protected].

14. No Guarantee of Accuracy, Originality, or Perfection

Some content in the Services is AI-generated and created on demand. By using the Services, you understand and agree that there are limitations inherent in emerging AI technology, and content available through the Services may not be accurate, original, unique to you, or a perfect match to your preferences and expectations. Additionally, our content-moderation controls may moderate or alter your request before an output is generated, including where your request contains or seeks prohibited content. We make every effort to provide the best possible technology and experience for our users, and we appreciate your understanding as we continue to refine the Services.

15. Disclaimers and Limitation of Liability

15.1 Disclaimer

THE SERVICES ARE PROVIDED TO YOU ON AN “AS-IS” AND “AS-AVAILABLE” BASIS AND THE USE THEREOF IS AT YOUR SOLE RISK. WE MAKE NO, AND HEREBY DISCLAIM, ANY REPRESENTATIONS OR WARRANTIES OF ANY KIND, EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, INCLUDING THE WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, SATISFACTORY QUALITY, NON-INFRINGEMENT, AND TITLE WITH RESPECT TO THE SERVICES, TO THE FULLEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW. WE DO NOT WARRANT (A) THAT THE SERVICES (OR THE RESULTS OBTAINED FROM THE USE THEREOF) WILL BE TIMELY, ERROR-FREE, SECURE OR UNINTERRUPTED; (B) THAT THE SERVICES WILL MEET YOUR REQUIREMENTS; (C) THE ACCURACY, LIKELY RESULTS, OR RELIABILITY OF THE USE OF THE MATERIALS ON OUR WEBSITE, OR ANY RESOURCES LINKED TO OUR WEBSITE; (D) THAT ANY MATERIALS, OUTPUTS, OR CONTENT ARE ORIGINAL, ERROR-FREE, OR ACCURATE; OR (E) THAT ANY ERRORS OR MALFUNCTIONS IN THE SERVICES WILL BE CORRECTED.

15.2 Limitation of liability

WE AND ANY OF OUR LICENSORS, OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS SHALL IN NO EVENT BE RESPONSIBLE OR LIABLE TO YOU OR TO ANY THIRD PARTY, WHETHER UNDER CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, INDEMNITY OR OTHER THEORY, FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY, LIQUIDATED OR PUNITIVE DAMAGES OR ANY OTHER DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFIT, REVENUE OR BUSINESS, COST OF SUBSTITUTE PROCUREMENT, ARISING IN WHOLE OR IN PART FROM YOUR USE OF (OR INABILITY TO USE) THE SERVICES, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

15.3 Liability cap

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, OUR TOTAL CUMULATIVE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THE SERVICES OR THESE TERMS IS LIMITED TO THE GREATER OF (A) ONE HUNDRED UNITED STATES DOLLARS (US$100); OR (B) THE FEES PAID BY YOU TO US IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM. The limitations in this Section 15 and the cap above do not apply to, and shall not limit: (a) liability for death or personal injury caused by our negligence; (b) liability for fraud or fraudulent misrepresentation; (c) your indemnification obligations under Section 16 or Section 2.5; or (d) any other liability that cannot be excluded or limited under the mandatory law of your country of habitual residence. Each user’s indemnification obligations are not subject to the monetary cap set out above.

15.4 EEA, UK and Swiss consumer-rights preservation

Nothing in this Section 15 limits or excludes our liability where such limitation or exclusion would be prohibited under applicable consumer-protection law of your country of habitual residence in the EEA, the United Kingdom, or Switzerland, including any liability for death or personal injury caused by our negligence, or for fraud or fraudulent misrepresentation, or for any other liability that cannot be limited or excluded by mandatory law.

15.5 Force majeure

UNDER NO CIRCUMSTANCES SHALL WE BE HELD LIABLE FOR ANY DELAY OR FAILURE IN PERFORMANCE RESULTING DIRECTLY OR INDIRECTLY FROM ANY CAUSES BEYOND OUR REASONABLE CONTROL, INCLUDING WITHOUT LIMITATION ACTS OF GOD, NATURAL DISASTER, WAR, TERRORISM, CIVIL UNREST, GOVERNMENT ACTIONS, PANDEMIC, INTERNET OR INFRASTRUCTURE OUTAGES, AND DENIAL-OF-SERVICE ATTACKS.

16. Indemnification

16.1 Beneficiaries. In this Section, “Indemnified Parties” means Aithalon Labs Ltd (HE 493820), its parent, subsidiaries and affiliates, and each of their respective founders, shareholders, ultimate beneficial owners, directors, officers, managers, employees, contractors, agents, service providers, suppliers and licensors. Each Indemnified Party may rely on and enforce this Section.

16.2 Business and non-consumer users. If you use the Services as a business or organisation, or otherwise not as a “consumer” under the mandatory law applicable to you, then to the fullest extent permitted by law you will defend, indemnify and hold the Indemnified Parties harmless from and against any and all third-party claims, losses, damages, liabilities, costs and expenses (including reasonable attorneys’ fees) arising out of or relating to (a) your use of the Services or any Content, inputs or outputs; (b) your violation of these Terms or any applicable law; or (c) your violation of any third-party right.

16.3 Consumer users. If you use the Services as a consumer, your indemnification obligation is limited to, and governed exclusively by, Section 2.5 of these Terms, which applies in place of Section 16.2. For the avoidance of doubt, nothing in this Section requires a consumer to indemnify any Indemnified Party for death or personal injury, or for any liability that may not lawfully be shifted to a consumer.

16.4 Mandatory consumer law. Nothing in this Section limits or excludes any right or remedy you have under Council Directive 93/13/EEC, the UK Consumer Rights Act 2015, the consumer-protection law of the Republic of Cyprus, or other analogous mandatory law. To the extent any part of this Section conflicts with such mandatory law as applied to a consumer, that part does not apply to that consumer and the remainder of these Terms continues in full effect.

16.5 Carve-back. No user is obliged to indemnify any Indemnified Party to the extent the relevant loss was caused by that Indemnified Party’s own gross negligence or wilful misconduct.

17. Third-Party Links and Services

The Services may include links or allow access to third-party websites and services. Their presence does not mean that they are recommended or endorsed by us, and we do not guarantee their safety or conformity with any of your expectations. We assume no obligations in the event of any damage or loss, or any other impact, directly or indirectly resulting from the use of any content, goods or services available on or through any such third-party websites and services.

It is your responsibility to take precautions to ensure that anything you select for your use or download, whether from the Services or a third party, is free of items such as viruses, worms, Trojan horses, and other items of a destructive nature. We assume no responsibility, and are not liable, for any transmission or material, or any viral infection of your computer equipment or software, or any other types of damage related to your access, use of, or browsing of third-party services or content. If you decide to access a third-party service or content, you do so entirely at your own risk and you should review the applicable terms and policies governing the use of same.

18. Geographic Restrictions

The Services are not offered in, and you may not access or attempt to access the Services from, the following jurisdictions (each a “Restricted Territory” as referenced in Section 2.5): the People’s Republic of China, the Russian Federation, the Republic of Belarus, the Republic of Kazakhstan, the Islamic Republic of Iran, the Kingdom of Saudi Arabia, the United Arab Emirates, the State of Qatar, the State of Kuwait, the Kingdom of Bahrain, the Sultanate of Oman, the Democratic People’s Republic of Korea, the Republic of Singapore, the Islamic Republic of Pakistan, the Socialist Republic of Vietnam, the Republic of Indonesia, and the Kingdom of Thailand. We implement geographic-routing controls to enforce these restrictions and may extend, restrict, or modify the list of restricted jurisdictions at any time at our sole discretion to comply with applicable law, the requirements of our payment processors, or to manage operational risk. Any attempt to access the Services or to evade these controls (including via VPN, proxy, or misrepresentation of location) is a violation of these Terms.

Where the Services are offered in user-interface languages associated with restricted jurisdictions, such availability is intended exclusively for users in non-restricted jurisdictions. The availability of any language interface is not, and shall not be construed as, an offer of the Services to users in restricted jurisdictions.

You are responsible for compliance with applicable laws of the jurisdiction from which you access the Services, including any laws regulating online adult content, age-verification, taxation, and consumer-protection.

19. Governing Law, Jurisdiction and Consumer Carve-Out

These Terms are governed by the laws of the Republic of Cyprus, without giving effect to its conflict-of-law provisions. Subject to Section 19.2 and Section 20, the courts of Nicosia, Cyprus shall have exclusive jurisdiction over any dispute arising out of or in connection with these Terms or the Services, including any question regarding their existence, validity or termination.

19.1 Cyprus consumer law

Where you are a consumer habitually resident in the Republic of Cyprus, your statutory rights under Cyprus consumer-protection law (including Law 133(I)/2013 transposing Directive 2011/83/EU on consumer rights, as amended by Directive (EU) 2019/2161 and Directive (EU) 2023/2673) are not affected by these Terms.

19.2 EU/EEA, UK and Swiss consumer carve-out

Where you are a consumer habitually resident in another EU/EEA Member State, the United Kingdom, or Switzerland, the mandatory consumer-protection provisions of the law of your country of habitual residence and the right to bring proceedings in the courts of your country of habitual residence shall continue to apply, as required by Regulation (EU) No 1215/2012 (“Brussels Ia”), Regulation (EC) No 593/2008 (“Rome I”), and equivalent UK and Swiss provisions.

19.3 Out-of-court redress in the EU

The European Online Dispute Resolution platform was discontinued by Regulation (EU) 2024/3228 effective 20 July 2025. EU/EEA consumers may seek redress through their national alternative-dispute-resolution body or contact the European Consumer Centre Cyprus at eccyprus.org, or the European Consumer Centre Network in their country of residence.

20. Arbitration Agreement and Class-Action Waiver (United States Users Only)

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT AND TO HAVE A JURY HEAR YOUR CLAIMS. IT CONTAINS PROCEDURES FOR MANDATORY BINDING ARBITRATION AND A CLASS-ACTION WAIVER.

20.1 Application

This Section 20 applies only if you are a resident of, or have your principal place of business in, the United States. It does not apply to consumers habitually resident in the EEA, the United Kingdom, Switzerland, the Republic of Cyprus, or any jurisdiction in which mandatory law prohibits binding arbitration of consumer disputes.

20.2 Agreement to arbitrate

Except for the matters carved out in Section 20.5, you and FlirtaGPT agree that any dispute, claim, or controversy arising out of or relating to these Terms, the Services, the relationship between us, or any aspect of your use of the Services (whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory) shall be resolved by final and binding arbitration on an individual basis, administered by JAMS pursuant to its Comprehensive Arbitration Rules and Procedures, or, at your election, by the American Arbitration Association (AAA) under its Consumer Arbitration Rules.

20.3 Class-action waiver

YOU AND FLIRTAGPT AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, OR REPRESENTATIVE PROCEEDING. THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON’S CLAIMS AND MAY NOT OTHERWISE PRESIDE OVER ANY FORM OF A REPRESENTATIVE OR CLASS PROCEEDING. IF A COURT DECIDES THAT APPLICABLE LAW PRECLUDES ENFORCEMENT OF ANY OF THIS PARAGRAPH’S LIMITATIONS AS TO A PARTICULAR CLAIM FOR RELIEF, THEN THAT CLAIM (AND ONLY THAT CLAIM) MUST BE SEVERED FROM THE ARBITRATION AND BROUGHT IN COURT.

20.4 Right to opt out (30 days)

You may opt out of this Arbitration Agreement and Class-Action Waiver by sending an email to [email protected] with subject line “Arbitration Opt-Out” within thirty (30) days of first accepting these Terms. Your opt-out notice must include your full name, email address used for the Account, and a clear statement that you wish to opt out of the Arbitration Agreement. Opting out has no other effect on your relationship with FlirtaGPT.

20.5 Carve-outs

Notwithstanding the foregoing, either party may (a) seek injunctive or other equitable relief in court to protect intellectual-property rights or to enforce confidentiality; and (b) bring an individual action in small-claims court for claims that qualify.

20.6 Arbitration logistics

Arbitration will take place in the county of your residence or any other location agreed in writing. The arbitrator’s decision is final and binding except for any limited review permitted under the United States Federal Arbitration Act. Each party will pay its own attorneys’ fees and costs unless awarded by the arbitrator.

20.7 Survival

This Section 20 survives termination of these Terms or your Account.

21. Changes to Terms and Policies

We reserve the right to update or make changes to these Terms and any other Policy from time to time at our sole discretion. We will notify you of changes by posting the revised version through the Services, and where the changes are substantial, by other means such as in-product notification or email. Changes take effect on the date stated in the revised version. You can determine when these Terms were last revised by referring to the “Date of Revision” at the top of this document. If you do not agree with the revised Terms or Policies, you should immediately stop using the Services. Your continued access or use of the Services after any changes have taken effect means that you agree and consent to such changes.

We may change the platform and the scope of the Services from time to time, with or without notice. We may also stop or restrict provision of the Services in full or in part to a given user, in accordance with these Terms and applicable Policies.

22. Termination and Assignment

These Terms and any other Policy will continue in effect until terminated by either you or us. You may terminate these Terms at any time by ceasing your access and use of the Services and, as applicable, cancelling your Premium Subscription and deleting your Account. If you are a Premium subscriber, the subsequent processing of fees shall be subject to the rules of the payment processor. We may terminate these Terms and your right to access or use the Services, with or without notice to you, for any reason, including actual or suspected breach of these Terms or any other Policy, subject to the internal complaint-handling procedure in Section 8 and the Complaint Policy in Section 23. Where you are a consumer protected by mandatory consumer law of your country of habitual residence requiring reasonable notice of termination of an indeterminate-duration contract, we will provide such reasonable notice except in cases of material breach, illegal conduct, or risk to the safety or integrity of the Services.

We reserve and retain the rights to assign, transfer or subcontract the Services to any third parties. Notice will be posted on the Services and your continued use or update of the Services indicates your consent.

23. Complaint Policy

If you have any complaint regarding the Services, including any complaint regarding a moderation decision, a payment, or any other aspect of your use of the Services, you may submit it to [email protected]. The way in which complaints are submitted, handled, and escalated, and the applicable timeframes, are set out in our Complaint Policy, which forms part of these Terms and is available on our website. Where you remain dissatisfied, EU/EEA, UK and Swiss consumers may further escalate the matter to a competent out-of-court dispute-settlement body, the European Consumer Centre Cyprus, or the courts of their country of habitual residence under Section 19.2.

Australian users may report online-safety concerns to the eSafety Commissioner. Information and instructions regarding reporting to eSafety are available at esafety.gov.au. We would always appreciate the opportunity to address your concerns internally before you approach a supervisory or regulatory authority.

24. Miscellaneous

If any provision of these Terms or any other Policy is found to be unlawful, void or for any reason unenforceable, that provision will not affect the validity and enforceability of any remaining provision and such provision will be enforced to the maximum extent possible, so as to give effect to the intent of the parties.

These Terms and the other Policies constitute your entire agreement with us pertaining to your access to and use of the Services. Any prior or contemporaneous written or oral agreements pertaining thereto are hereby superseded.

Failure of FlirtaGPT to enforce any right or provision of these Terms will not be deemed a waiver of such right or provision. No waiver of any term will be deemed a continuing waiver of such term or any other term. Headings used in these Terms are for convenience only and have no legal or contractual effect. References to laws and regulations include any successor or amending legislation.

We will collect and process your information and technical data in accordance with our Privacy Notice at flirtagpt.ai/privacy.

Where required by US export-control laws and EU/UK/UN/US sanctions regimes, you represent that you are not located in, under the control of, or a national or resident of, a country subject to comprehensive sanctions, and that you are not on any restricted-party list.

25. Contact Information

Operator: Aithalon Labs Ltd

Registered address: Lapathou, 6, Strovolos, 2027, Nicosia, Cyprus

Cyprus registration number: HE 493820

General support: [email protected]

Privacy and data-protection: [email protected]

Formal complaints: [email protected]

Moderation appeals: [email protected]

DSA point of contact (Articles 11/12): [email protected]

Cyprus Office of the Commissioner for Personal Data Protection: [email protected] — www.dataprotection.gov.cy

Annex A — EU/UK Model Withdrawal Form

(Complete and return this form only if you wish to withdraw from the contract within the 14-day withdrawal period and have not waived that right under Article 16(m) of Directive 2011/83/EU.)

To: Aithalon Labs Ltd, Lapathou, 6, Strovolos, 2027, Nicosia, Cyprus — Email: [email protected]

I hereby give notice that I withdraw from my contract for the supply of the following service:

_________________________________________________

Ordered on: _________________________________________________

Your name: _________________________________________________

Your email address: _________________________________________________

Your signature (only if this form is notified on paper): _________________________________________________

Date: ____________________________________________