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cosmetiFULL Terms of Service

Last updated: 23 August 2026

The English version is the reference version, subject to Article 30.

These terms govern access to and use of the cosmetiFULL platform and of every service provided through it. They apply to business customers and to consumers. Part B applies only to consumers and prevails over Part A wherever the two differ.

Please read Article 3 before you buy anything: it explains what our services do and what they do not do.

PART A. TERMS THAT APPLY TO EVERYONE

Article 1. Who we are

The platform is operated by:

Nicodemo & Signa Company Srl, a company incorporated under Romanian law, legal form societate cu răspundere limitată (Srl)

Registered office: Strada Lucian Blaga nr. 21, ap. 16, 310023 Arad, Romania

Trade Register number: J02/809/2003

Unique registration code / VAT number: RO15617609

Email: info@cosmetifull.com

Telephone: +40 720 797 081

In these terms "we", "us" and "our" mean Nicodemo & Signa Company Srl. "You" and "your" mean the customer, that is the person or the company that registers an account or buys credits.

We are the provider of every service listed in Article 2. There is no other contracting party behind them.

Article 2. The cosmetiFULL platform and its services

cosmetiFULL is a platform of digital services for the cosmetics sector. The services are modules inside the platform, provided by us under one account and paid with the same prepaid credits.

Available today:

Announced and under construction, not available for purchase until we make them available:

We may add further services to the platform over time. Unless a service page says otherwise, new services are governed by these same terms, and any specific conditions of a single service are published on its own page and prevail for that service only.

We describe on the relevant service pages what each service produces as output, which markets it covers and which operations consume credits. Services still under construction cannot be bought and cannot be paid with credits until they are released.

Article 3. What our services are not, and use of artificial intelligence

Our services assist professional review. They do not certify compliance.

We do not sell the services to persons, entities or countries subject to European Union or other applicable sanctions, and you confirm that you are not such a person or entity and that you will not use the services on their behalf.

Article 4. Who these terms apply to

These terms apply:

If you buy for a purpose that is partly inside and partly outside your trade, business, craft or profession, and the professional purpose is not predominant, you are treated as a consumer and Part B applies to you.

Part B of these terms applies only to consumers. Where a provision of Part A conflicts with a provision of Part B, Part B prevails for consumers. Nothing in these terms removes rights that consumer law gives you and that cannot be waived.

If you register on behalf of a company, you confirm that you have the authority to bind that company, and the company is our contracting party.

Article 5. Registration and your account

You must provide accurate and complete information when you register and keep it up to date. This includes the country where you are established or resident, because the applicable tax treatment depends on it (Article 8).

You must keep your credentials confidential, you must not share them, and you must tell us without delay at info@cosmetifull.com if you become aware of any unauthorised use of your account.

We may refuse a registration, and during the beta phase access to a service may be granted on request and subject to approval. If we refuse a registration after a payment has been made, Article 9 applies and we refund the full amount.

Article 6. Company accounts and users

An account can be held by a company. In that case:

Credits are personal to the account holder. They cannot be moved to another account or to another company.

Article 7. Prepaid credits

7.1 What credits are. Credits are bought in advance and are used to pay for operations on the platform. A credit is a contractual right to receive our services. It is not money, it is not a deposit, it is not electronic money and it is not a payment instrument. Credits cannot be converted into cash and cannot be withdrawn. Because they can only be used to obtain services from us, they fall outside the rules on payment services and electronic money (limited network exclusion, Article 3(k)(i) of Directive (EU) 2015/2366).

7.2 Where credits can be spent. Credits are valid on all cosmetiFULL services that are available to your account. All services that can be paid with credits are subject to the same VAT treatment. If we ever offer a service with a different VAT treatment, we will sell it separately and not against credits.

7.3 Personal and non transferable. Credits are issued to the account holder named at registration. They cannot be sold, transferred, assigned or made available to any third party.

If your country of establishment or residence changes, tell us. Credits you have already bought remain valid and usable. Where the change alters the VAT treatment of a purchase already invoiced, we issue a corrective invoice or, at your choice, we refund the credits you have not consumed under Article 11.3. The new country applies to your future purchases.

7.4 How credits are consumed. Each operation has a price in credits, published and visible before you start the operation.

Credits are deducted when the operation is started, because the cost is incurred at that moment. If an operation does not complete, or fails for a reason attributable to us or to one of our providers, the credits are restored to your balance. If that does not happen automatically, write to info@cosmetifull.com and we restore them.

Where you hold credits from more than one purchase or grant, the credits that expire first are used first, so that no credit is lost while another one with a later expiry date is still in your balance.

7.5 Balance and history. Your current balance is visible at any time in your account. The history of purchases and consumption is available to the persons who administer the account. Consumption of credits does not generate a further invoice, because the invoice is issued when the credits are bought (Article 8).

At your request, and free of charge, we provide you with a statement of your purchases and consumption and with an export of your analyses and of the documents saved in your account, in a commonly used, machine readable format. This right applies for the whole time your account is open, and not only on termination.

7.6 Validity. Credits you have bought are valid for 12 months from the day of the purchase. Credits you have not used by the end of that period expire and can no longer be used. Where you hold credits with different expiry dates, the ones that expire first are used first (Article 7.4).

Promotional credits may have a different period: where an offer states one, that period is published together with the offer and applies to those credits only (Article 23). Promotional credits are not refundable.

7.7 Suspension and closure. What happens to unused credits if your account is suspended or closed is set out in Article 19.

Article 8. Prices, VAT and invoicing

8.1 Price. This document contains no amounts. The total price, including taxes, is the one shown on the purchase page before you confirm the order, and that price forms part of the contract. The price in credits of each operation is published in the platform and is visible before you start the operation.

8.2 When VAT is charged. Credits can only be used for services whose place of supply and VAT treatment are known when the credits are issued. For VAT purposes they therefore qualify as a single purpose voucher under Articles 30a and 30b of Directive 2006/112/EC. This means that VAT is charged when you buy the credits, not when you use them. Using credits is not a separate taxable transaction and does not give rise to a second invoice.

8.3 Business customers in another EU member state. If you are a taxable person established in another member state, the place of supply is your country. Before payment we check the VAT number you provide in the VIES system of the European Commission. If the number is valid, the reverse charge applies: the invoice carries no Romanian VAT and states "reverse charge", and you account for the tax in your country. If the number is not valid, we apply the treatment provided for non taxable persons.

If the verification system is temporarily unavailable and we cannot obtain an answer, we apply VAT and, once we have been able to verify the number, we correct the invoice with a credit note. We keep the evidence of the verification, including the outcome we obtained and its date.

8.4 Consumers in another EU member state. For electronically supplied services to consumers, the place of supply is the country where you are established or resident, and the VAT of that country applies, declared by us through the One Stop Shop. We apply this rule to every sale, without relying on the threshold of Article 59c of Directive 2006/112/EC. The applicable VAT is shown to you before you confirm the order.

To determine and record your country we use the billing address you give us and the IP address of the purchase, as the VAT rules require (Article 24b of Implementing Regulation (EU) No 282/2011). How we treat those data is described in the Privacy Policy.

8.5 Customers outside the European Union. For business customers established outside the European Union the supply is outside the scope of EU VAT. For consumers resident outside the European Union no EU VAT is charged. Tax obligations that may arise in your own country are your responsibility.

8.6 Invoicing. Invoices are issued through our invoicing provider. To issue an invoice we need your name or company name, your address and, if you are a taxable person, your VAT number. These are requirements of tax law: without them we cannot issue the invoice and therefore cannot sell you credits. You are responsible for the accuracy of the billing data you give us.

8.7 e-Factura. For customers established in Romania, the invoice and any credit note are transmitted to the Romanian tax administration (ANAF) through the RO e-Factura system. This is a legal obligation, it does not require your consent and it cannot be switched off.

Article 9. How the contract is concluded

Before you place the order we show you, in a clear and prominent way, directly before you confirm: the main characteristics of what you are buying, the total price including taxes, the technical requirements described in Article 9a, the duration of the contract and the conditions for terminating it, the validity of the credits, and the minimum duration of your obligations.

Before you place the order we also make available to you the Pre-contractual information sheet on switching to another provider, which sets out the standard service fees, the absence of early termination penalties and of switching charges, the switching procedures and methods, the available export formats and the known technical limitations. You find it on the purchase page, before the button that concludes the order, and at https://cosmetifull.com/switching/. We make these terms available to you in full, in a form you can store and reproduce, before you conclude the contract.

The button that concludes the order is labelled "order with obligation to pay", or in Romanian "comandă ce implică o obligație de plată". If that button is not labelled in this way, a consumer is not bound by the contract.

The payment methods we accept are shown at the latest at the beginning of the ordering process. Payment is made on a page hosted by Stripe: card details are collected by Stripe on its own systems, they never pass through our systems, and we neither see nor store them.

The contract is concluded when Stripe confirms your payment. At that moment the credits are credited to your account and, for consumers, the 14 day period of Article 33 starts to run. If for any reason we do not credit the purchase, we refund the full amount within 14 days, without you having to ask.

Article 9a. Technical requirements, functionality and interoperability

The services run in a current web browser over an internet connection. There is nothing to install on your device.

The input formats we accept, the maximum size of a submission and the formats in which results can be exported are published on the page of each service, and they form part of the description of what you are buying.

We apply no technical protection measure and no digital rights management to the results we produce for you: you can open, copy, print and pass them on with ordinary software.

We do not guarantee interoperability with any specific third party system beyond what is stated on the service page.

Article 10. Confirmation of your order

After the purchase we send you, by email and on a durable medium, the confirmation of the contract with all the pre contractual information, including the information on the right of withdrawal and the model withdrawal form for consumers, and, where applicable, the confirmation of your express request for immediate performance and of your acknowledgement under Article 34.

We send it at the latest at the moment the credits are credited to your account, and in any case before performance of the services begins. This message is part of the contract and it is not one of the messages you can switch off in your notification preferences.

Article 11. Refunds, cancellation and payment disputes

11.1 Refund of unused credits. You can ask for a refund of the credits you have not used within 14 days of the purchase. Send the request to info@cosmetifull.com, preferably from the email address of the account. Any other clear statement is valid, provided it lets us identify you and the purchase.

11.2 Credits already used. Credits that have already been consumed are not refunded. If part of a purchase has been consumed, we refund the remaining part in proportion.

11.3 How we refund. We cancel the credits that are being refunded, issue a credit note with the corresponding VAT adjustment, and refund through Stripe to the same means of payment you used, at no cost to you, unless you expressly agree otherwise. For customers established in Romania, the credit note is transmitted to ANAF through RO e-Factura. We refund within 14 days of receiving your request.

11.4 Closing your account. You can ask us to close your account at any time by writing to info@cosmetifull.com. Closure does not revive a right to a refund of credits that have already been used.

11.5 Before you open a payment dispute. If something is wrong with a payment, please contact us first at info@cosmetifull.com. We will look into it and answer you. This is faster than a card dispute and it lets us correct genuine mistakes immediately.

11.6 Consumers. The rights in this Article are in addition to the statutory right of withdrawal described in Part B, which prevails where it gives you more.

Article 12. Delivery, availability and maintenance

The services are supplied electronically. There is no physical delivery. Credits are credited to your account when Stripe confirms the payment, as stated in Article 9, together with the confirmation described in Article 10.

We work to keep the platform available and to fix faults within a reasonable time. Planned maintenance is announced in advance where reasonably possible, and we try to schedule it so as to limit disruption. Availability can be affected by events outside our control, including failures of the providers listed in the Privacy Policy.

This Article does not reduce our obligations under Articles 13, 14 and 15.

Article 13. Conformity of the digital service and legal guarantee

Articles 13, 14 and 15 apply to consumers as the legal guarantee of conformity provided by Directive (EU) 2019/770. They apply to business customers as a contractual undertaking, subject to the limits of Article 24.1, and no specific level of availability is promised to business customers unless a separate service level document says so.

We undertake to supply services that are in conformity with the contract, that is that correspond to the description, quantity, quality, functionality, compatibility, interoperability and support that we have agreed with you, and that meet the objective requirements: fitness for the purposes for which services of the same type are normally used, and the quality and performance features that are normal for services of the same type, including continuity, security and accessibility, taking into account any public statement we have made, including in advertising.

A characteristic may deviate from those objective requirements only if you were specifically informed of the deviation when the contract was concluded and you expressly and separately accepted it.

We supply the services without undue delay after the conclusion of the contract, and, where a service is supplied continuously, we keep it in conformity for the duration of the supply.

A legal guarantee of conformity applies to the digital content and digital services we provide, in addition to any commercial undertaking we may give.

Article 14. Updates

We inform you of and supply the updates, including security updates, that are needed to keep the services in conformity, for as long as we supply the services to you or, for one off operations, for the period you can reasonably expect.

The minimum period during which we supply software updates for the platform is the period during which your account is active.

Article 15. If we fail to supply, or the service is not in conformity

15.1 Failure to supply. If we do not supply a service, you may call on us to do so. If we still do not supply it without undue delay, or within an additional period expressly agreed between us, you may terminate the contract. You may terminate immediately if we have declared, or it is equally clear from the circumstances, that we will not supply the service, or if the agreed time of supply was essential.

15.2 Lack of conformity. If a service is not in conformity, we will bring it into conformity within a reasonable time from the moment you inform us, free of charge and without significant inconvenience to you. If that is not possible or we fail to do it, you may ask for a proportionate reduction of the price or terminate the contract, and you may terminate only if the lack of conformity is not minor. Where the law places the burden of proving conformity on us, we bear it.

15.3 Reimbursement. Amounts to be reimbursed under this Article are paid within 14 days of the day we are informed of your decision, using the same means of payment you used, at no cost to you.

Article 16. Changes to the service

Where a service is supplied or made accessible over a period of time, we may change it beyond what is necessary to keep it in conformity only if all of the following apply:

If the change negatively affects your access to or use of the service in more than a minor way, we will inform you on a durable medium, with reasonable notice, of the features and timing of the change and of your right to terminate. In that case you may terminate free of charge within 30 days of receiving the information or of the change, whichever is later, and we refund the credits you have not used at the date of termination.

You do not have that right of termination if we allow you to keep using the unchanged service, in conformity, at no additional cost.

Article 17. Changes to these terms and to prices

We may change these terms and our prices for the future only for one of the following reasons: a change in the law or in regulatory guidance, a change in the way the platform works technically or in its security requirements, the replacement of a technical provider, or the addition or withdrawal of a service.

We publish the new version with a new date and, for substantial changes, we notify you on a durable medium with at least 30 days notice. If a change places you in a worse position in more than a minor way, you may terminate free of charge within 30 days of the notice, and we refund the credits you have not consumed.

Changes apply to purchases made after they take effect. Credits you have already bought remain governed by the terms and the price in force when you bought them. We do not change retroactively the value or the validity of credits you have already paid for.

Article 18. Acceptable use

You agree not to:

How you use a result inside your own organisation is not governed by this Article. The warning in Article 3 about not relying on the output as the only basis of a regulatory decision is not an obligation listed here and cannot lead to suspension or termination.

Article 19. Suspension and closure of the account

19.1 Suspension. We may suspend an account or a single access if there is a breach of these terms, a reasonable suspicion of fraudulent use, or a risk to the security of the service or of the data. We tell you the reason, unless prior notice would compromise security. While an account is suspended, credits cannot be consumed.

Where credits in your balance carry an expiry date, that period is suspended for the whole time your account is suspended and starts running again on the day access is restored. If the suspension turns out not to have been justified, we also extend that period by the same number of days as a matter of course.

19.2 Termination by us. If a serious breach is not remedied within a reasonable period we indicate, we may terminate the contract. In that case we refund the credits you have not consumed, less any amount we can show we actually lost as a result of the breach. We tell you in writing how that amount was calculated.

Article 3 and the way you use a result inside your own organisation are not grounds for suspension or for termination.

19.3 Termination without breach on your side. If we close your account, discontinue the platform or discontinue a service without a breach on your side, we give you reasonable notice, your credits remain usable on the services that are still active during that notice, and we refund the credits you have not used at the end of it.

If we discontinue a service you have actually used in the 12 months before the announcement, you may ask us, within 60 days of the announcement, to refund the credits you have not consumed, and we refund them under Article 11.3. You are not obliged to spend them on the other services.

19.4 Closure at your request. Closing your account does not cancel your credits. Credits you have not consumed remain valid and are restored if you reopen the account. Their validity period under Article 7.6 keeps running while the account is closed: closing the account does not extend it. You may also ask us to refund the credits you have not consumed, and we refund them under Article 11.3.

19.5 Your content. Closure does not affect your right to get your content back under Article 21.

Article 20. Your content, confidentiality and artificial intelligence training

The label artwork, texts, formulations, documents and messages you upload remain yours or your own clients'. You grant us a limited licence to use them only to provide the services: to analyse them, to store them in your account, to produce the translations you request, and to support you when you ask us to.

You confirm that you are entitled to submit the materials you upload.

We treat your materials as confidential. We do not share them with third parties other than the processors listed in the Privacy Policy, who act on our instructions.

Your content is not used to train artificial intelligence models. This is also reflected in the commercial terms that govern our use of our artificial intelligence provider.

We may derive aggregated statistics from the analyses, such as which types of issue are most frequent, their severity, and the markets and languages where they occur. These statistics are derived only from metadata about the findings, that is the type of issue, its severity, the market and the language. They are never derived from the substance of the documents you upload, from product names or from formulations. They never identify you, your company or your products, and they are only used or published in aggregate form.

Business customers can ask us at info@cosmetifull.com to exclude their account from this processing, at no cost and without any effect on the service.

Separately from the above, we do not reuse the content of your labels or dossiers to improve our regulatory knowledge base unless you have given us a specific written consent for that, which you can withdraw at any time. This is explained in the Privacy Policy.

Article 21. Getting your content back

On termination of the contract or on closure of your account we refrain from using content other than personal data that you provided or created while using the services, except where that content has no use outside the service, relates only to your activity in the service, has been aggregated with other data and cannot be disaggregated, or was generated jointly with others who can still use it.

For 30 days from the closure of your account we keep your content available for download in your account. After that we delete it. During that window, and at any earlier time under Article 7.5, we make the content available to you free of charge, without hindrance and in a commonly used, machine readable format. We may prevent any further use of the services, but this does not affect this right.

Article 21a. Switching to another provider, portability and exit

This article covers three distinct things: switching to another provider of comparable services, moving your data onto your own infrastructure, or simply closing your account and having everything erased. We apply Chapter VI of Regulation (EU) 2023/2854 to all cosmetiFULL services, without distinguishing between modules.

This article adds to Article 21 and to your rights over personal data, which remain governed by Regulation (EU) 2016/679 and by the Privacy Policy. Where the two sets of rules overlap, both apply; where they diverge, the rules on personal data prevail.

21a.1 The three routes, and how you choose. At any time you may ask us, by writing to info@cosmetifull.com from the email address of the account:

The choice is yours, and you tell us which one in your request. If you do not say, we ask you before starting anything, and the notice period runs from the day you tell us (Article 25(2)(a) and (3) of Regulation (EU) 2023/2854).

21a.2 Notice period. The notice period for initiating the switch is 30 calendar days and runs from the day we receive your complete request. This is our own period, and it is shorter than the maximum of two months that Article 25(2)(d) would allow. If you ask us to start earlier and we are able to, we start earlier.

21a.3 Transitional period. At the end of the notice period a transitional period of 30 calendar days opens. During the transitional period:

You may ask once for the transitional period to be extended, for the duration you need, and we grant it (Article 25(5)).

If the switch is not technically feasible within 30 days, we tell you within 14 working days of your request, explaining the reason in writing, and we propose an alternative transitional period of no more than seven months, with the same business continuity and the same level of security (Article 25(4)).

21a.4 What we do to support your exit. We support your exit strategy within the scope of the services you use (Article 25(2)(b)). Concretely: we tell you where your data is and in what format; we prepare the export described in point 21a.7; we answer the technical questions of the provider you have chosen about data structures and formats, on the basis of the register referred to in point 21a.7; and we tell you in advance what does not transfer, so you can plan. We assist you: the relationship with the destination provider stays yours.

21a.5 What you can take with you. Exportable data means all data and digital assets that you have provided to us or that were generated using the services, whether yours or relating to you, personal and non personal together, including what you submitted, what the service produced and the metadata that goes with it. For the services available today, the list below is exhaustive and detailed (Article 25(2)(e)).

Common to all services:

LabelCheck:

The images and files you upload to have a label analysed are used to produce the report and do not stay on our systems (Privacy Policy, Article 5.2). What stays in your account, and what you can therefore export, is the report with all of its content.

For the services announced and not yet released (Article 2), the list of their exportable data is published in the register referred to in point 21a.7 before the service becomes purchasable.

21a.6 What is not exportable data. The following is not exportable data, because it does not come from you and is protected by intellectual property rights or covered by trade secrets: the platform software, our regulatory knowledge base and its structure, the analysis engines, the system instructions, the expert canons, the document templates and the catalogue templates. They remain ours under Article 22.

Among the data relating to you, the only categories we exclude from export because they are specific to the internal functioning of the platform, and because disclosing them would expose our trade secrets, are the following, exhaustively (Article 25(2)(f)):

None of these categories is needed for you to use your data elsewhere, and the exclusion neither hinders nor delays the switch. If you needed one of them for a dispute or for a verification, we provide it anyway, to the extent needed for that purpose.

21a.7 How the export works, and in which formats. From your account you can consult, open and save as PDF every report and every declaration, and see the full list of what you have produced.

At your written request to info@cosmetifull.com we hand over to you, free of charge and in one go, all the exportable data listed in point 21a.5, in a structured, commonly used and machine readable format: JSON for structured data and findings, Markdown or PDF for reports and declarations, the original format for the files you uploaded and that we keep. We do this within 14 working days of the request, and in any event in time for you to use the data within the transitional period of point 21a.3. You may ask for the export at any time, not only on exit, and as many times as you need.

We make open exit interfaces available free of charge, on equal terms for all customers and, on your written instruction, for the destination provider you have chosen (Article 30(2) and (5)). Our commitment covers the export of your data and assistance with the switch, on the terms described in this article.

The technical description of the data structures, the formats, the open interoperability specifications we use, the switching procedures and the known technical limitations is published and kept up to date in the register of formats and interfaces, at https://cosmetifull.com/data-formats/. The register forms part of the information you receive before the contract is concluded (Article 9).

21a.8 How long you have to retrieve your data. After the end of the transitional period you have at least a further 30 calendar days to retrieve your exportable data (Article 25(2)(g)). During those days access to the data stays open even if the service can no longer be used for new operations. Where this period and the one in Article 21 overlap, the longer of the two applies.

21a.9 Final erasure. Once the retrieval period of point 21a.8 has ended, and provided the switch has been completed successfully, we fully erase all exportable data and digital assets generated directly by you or relating to you (Article 25(2)(h)). Backups are overwritten on the cycle set out in the Privacy Policy. We keep only what the law obliges us to keep, in particular tax and accounting documents and contract confirmations, for the period that law provides and for no other purpose.

If you asked us only for erasure, without a switch, we erase at the end of the notice period of point 21a.2 and of the retrieval period of point 21a.8.

21a.10 Costs. Switching, exporting your data, the assistance during the transitional period and the final erasure are free of charge. We apply no switching charges, not even reduced ones, and no early termination penalties (Article 25(2)(i) and Article 29). Article 29(1) of Regulation (EU) 2023/2854 prohibits all switching charges from 12 January 2027: we apply that already today, and it is a term of the contract, not a concession we can withdraw.

The contract has no recurring fee and no minimum duration, so there is nothing to pay in order to leave. Unused credits are refunded to you under Article 11.3.

21a.11 End of the contract. The contract is terminated, on written notice from us on a durable medium (Article 25(2)(c)):

The articles listed in Article 31 remain in force, and the periods in points 21a.8 and 21a.9 are unaffected.

Article 22. Intellectual property

The platform, its software, its knowledge base, its analysis models and its brands belong to Nicodemo & Signa Company Srl or to its licensors. These terms give you a limited, non exclusive and non transferable right to use the services for the duration of your access. Nothing here transfers ownership of the platform to you.

The outputs we generate for you, that is the analyses, the reports, the drafts and the translations produced from the materials you submit, are yours. You may use, reproduce, adapt and pass them to your own clients, to your Responsible Person and to your safety assessor without any further permission from us and without any additional cost. We claim no rights over them.

Article 23. Promotions

If we offer promotional credits, discounts or trials, the conditions of each offer are published together with the offer and apply to it. Promotional credits may have their own validity period, stated in the offer. They are not refundable and they are not transferable.

Promotional credits are used before credits you have paid for, unless a paid credit would expire sooner: in that case the paid credit is used first. We never let a credit you paid for expire while a promotional credit with a later expiry date is still in your balance.

Article 24. Liability

24.1 Business customers. To the extent permitted by law, and towards business customers only: we are not liable for indirect or consequential loss, loss of profit, loss of business, loss of goodwill or loss of data that could have been avoided by keeping your own copies; and our total liability arising from or connected to the services is limited to the higher of the amounts you paid to us in the 12 months preceding the event that gave rise to the claim and the value of the credits in your balance at the time of that event.

24.2 Consumers. The limitations in 24.1 do not apply to consumers. Any term that, before a lack of conformity is brought to our attention, excludes or restricts the rights consumer law gives you is not binding on you.

24.3 In all cases. Nothing in these terms excludes or limits our liability for intent or gross negligence, for death or personal injury, or any other liability that cannot be excluded or limited under applicable law.

24.4 Regulatory responsibility. As stated in Article 3, responsibility for the compliance of a cosmetic product remains with the economic operator, with the Responsible Person and with the safety assessor.

Article 25. Complaints

If something is not right, write to info@cosmetifull.com with your account email and a description of the problem. We acknowledge complaints and answer them in writing, normally within 14 days of receipt. If a complaint needs more time, we tell you and give you an indication of when we will answer.

A direct complaint to us is the first step, before any out of court procedure. For consumers, Article 39 explains what happens if the complaint is not resolved.

Article 26. Personal data, providers and data processing agreement

How we process personal data is described in the Privacy Policy, which forms part of the information you receive before the contract is concluded.

The complete and current list of the providers and other recipients involved, their role, the data they receive and the safeguards applied to any transfer outside the European Economic Area is in the Privacy Policy, Articles 10 to 15, which forms part of the pre contractual information. That list is kept in one place only, so that it cannot diverge between two documents.

Data processing agreement. For the personal data contained in the materials you upload, you are the controller and we act as processor on your documented instructions. The Data Processing Agreement annexed to these terms sets out that relationship as required by Article 28(3) GDPR, including the list of sub processors, the notice you receive before a sub processor changes and your right to object, the security measures, the assistance we give you on data subject rights and on Articles 32 to 36 GDPR, and what happens to the data when the contract ends. It forms part of the contract for business customers and, where data protection is concerned, it prevails over these terms.

Article 27. Access from other countries of the European Union

Customers in the European Union can access the platform and buy credits under the same general conditions, whatever their nationality, place of residence or place of establishment. We do not block access, we do not redirect you automatically to a different version of the site because of where you are, and we do not apply different payment conditions because of the country of the account or of the payment instrument.

Differences in the price shown may arise only from the VAT rate applicable in your country under Article 8.

Article 28. Governing law

These terms and the contract are governed by Romanian law.

For consumers, this choice does not deprive you of the protection given to you by the provisions that cannot be derogated from under the law of the country where you have your habitual residence, because we direct our activity to that country.

Article 29. Courts

For business customers, the courts of Arad, Romania, have exclusive jurisdiction over any dispute arising from or connected to these terms.

For consumers, you may bring proceedings against us either before the courts of the country where you are domiciled or before the courts of Romania, and we may bring proceedings against you only before the courts of the country where you are domiciled.

Article 30. Language of these terms

The English version is the reference version and prevails in case of divergence between the versions.

For consumers, the version in the language in which you concluded the contract prevails in your favour where the two differ, and where a term is unclear the interpretation most favourable to you prevails.

This does not affect the obligation, under Romanian law, to present the contractual information in Romanian in an accessible form.

Article 31. Other provisions

Survival. Articles 3, 20, 21, 21a, 22, 24, 26, 28, 29 and 30 remain in force after the contract ends.

Severability. If a provision of these terms is found to be invalid, the rest of the terms remain in force.

Transfer. We may transfer the contract to another company that continues the platform, giving you at least 30 days notice on a durable medium. The transfer does not reduce your rights, and your credits pass to that company at their full value and with the same validity. If you are a consumer and you do not accept the transfer, you may terminate and we refund the credits you have not consumed.

Entire agreement. These terms, the Privacy Policy, the Data Processing Agreement, the conditions published for a specific service and the confirmation of your order form the whole agreement between us on their subject matter. This does not exclude or limit the public statements we have made, including in advertising and on the service pages, which remain part of the objective requirements under Article 13, and does not limit any right you have because of information we gave you before the contract.

PART B. PROVISIONS THAT APPLY ONLY TO CONSUMERS

Article 32. Who this Part applies to

This Part applies only if you are a natural person acting for purposes outside your trade, business, craft or profession, or if you buy for a mixed purpose in which the professional purpose is not predominant (Article 4). Where it differs from Part A, this Part prevails.

Article 33. Your right of withdrawal

You have 14 days to withdraw from the contract without giving any reason and without incurring any cost other than the one described in Article 36.

The period runs from the day the contract is concluded, that is from the day Stripe confirms your payment (Article 9).

To withdraw you can:

To meet the deadline it is enough that you send your communication before the period expires.

If we have not given you the information on the right of withdrawal, the withdrawal period is extended by 12 months from the end of the initial 14 day period, and it ends 14 days after the day we provide that information.

Article 34. Immediate performance during the withdrawal period

Credits can be used immediately, which means that performance can begin before the withdrawal period has expired. Before you pay, we therefore ask you to tick the following statement, and the purchase cannot be completed unless you tick it:

"I expressly request that cosmetiFULL begins the performance of the services during the 14 day withdrawal period. I acknowledge that I will lose my right of withdrawal only once the contract has been fully performed, that is once the whole credit balance from this purchase has been consumed, and that if I withdraw before that moment I will have to pay an amount in proportion to what has been provided until the moment I inform cosmetiFULL of my withdrawal."

We keep a record of that request and of that acknowledgement, and we repeat both in the order confirmation we send you under Article 10.

Buying credits does not, by itself, mean that you give up your right of withdrawal.

Article 35. How to send your withdrawal statement

You can send your withdrawal statement by email to info@cosmetifull.com, with or without the model form in the Annex. Any unequivocal statement is valid.

After we receive it we send you, without undue delay, an acknowledgement of receipt on a durable medium, including the content of your statement and the date on which we received it.

Article 36. Effects of withdrawal and reimbursement

If you withdraw, we reimburse all payments received from you without undue delay and in any event within 14 days of the day we are informed of your decision. We use the same means of payment you used for the initial transaction, and you incur no fees as a result.

Where performance began at your express request under Article 34, we deduct from the reimbursement an amount in proportion to the credits you had already consumed when you informed us of your withdrawal. That proportionate amount is calculated on the total price agreed. If that total price is excessive, it is calculated on the market value of what has been supplied.

You bear no cost at all, and we reimburse everything you paid, if we did not give you the information on the right of withdrawal and on the obligation to pay a proportionate amount, or if you did not expressly request the beginning of performance under Article 34.

After withdrawal you must stop using the services and must not make them available to third parties. We may prevent any further use, including by disabling access, without prejudice to your right to get your content back under Article 21.

Article 37. When the right of withdrawal no longer applies

You lose the right of withdrawal only when the contract has been fully performed, that is when the whole credit balance from that purchase has been consumed, and provided that performance began at your express request and with your acknowledgement under Article 34.

In every other case, including where part of the credits are still unused, the right of withdrawal remains for the full 14 days.

Article 38. Legal guarantee and mandatory rights

You benefit from the legal guarantee of conformity for the digital content and digital services we provide. Articles 13, 14 and 15 apply to you, and the limitations of liability in Article 24.1 do not.

Any term of these terms that, before a lack of conformity has been brought to our attention, excludes or restricts the rights that consumer law gives you is not binding on you.

Article 39. Out of court dispute resolution

If you have a complaint, please write to us first at info@cosmetifull.com, as described in Article 25. Most problems are solved this way.

We are not committed to using, and are not obliged to use, a specific alternative dispute resolution entity. If your complaint is not resolved after you have brought it directly to us, we will inform you on a durable medium about the alternative dispute resolution entity that is competent for the dispute, and about whether we intend to take part in the procedure.

In Romania there is an alternative dispute resolution structure within the National Authority for Consumer Protection (ANPC).

The official list of the alternative dispute resolution bodies of the member states is published by the European Commission at commission.europa.eu/topics/consumers/consumer-rights-and-complaints/resolve-your-consumer-complaint_en. For cross border disputes you can also contact the European Consumer Centre in your country.

Using an out of court procedure does not deprive you of the right to go to court under Article 29.

ANNEX 1. Model withdrawal form

Complete and return this form only if you wish to withdraw from the contract.

To: Nicodemo & Signa Company Srl, Strada Lucian Blaga nr. 21, ap. 16, 310023 Arad, Romania, info@cosmetifull.com

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

................................................................

Ordered on / received on: ..............................

Name of the consumer: ..............................

Address of the consumer: ..............................

Signature of the consumer (only if this form is notified on paper): ..............................

Date: ..............................

ANNEX 2. Data Processing Agreement

The Data Processing Agreement referred to in Article 26 is published as a separate document and forms part of these terms for business customers. It contains the elements required by Article 28(3) GDPR: the subject matter and duration of the processing, its nature and purpose, the types of personal data and the categories of data subjects, the list of sub processors together with the notice period before a change and your right to object, the confidentiality undertaking of the persons authorised to process the data, the security measures under Article 32 GDPR, the assistance we give you on data subject rights and on Articles 32 to 36 GDPR, the deletion or return of the data at the end of the relationship, and the information we make available for an audit.

End of the published text.

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