User Agreement (Offer)

1. General Provisions

1.1. This User Agreement (hereinafter referred to as the “Agreement”) is a public offer under Articles 437 and 438 of the Civil Code of the Russian Federation and an adhesion contract under Article 428 of the Civil Code of the Russian Federation. The Agreement defines the terms of use of the website tloa.app, the progressive web application “TLOA — Law of Attraction” located at web.tloa.app (hereinafter referred to as the “Application”), as well as other related services (hereinafter collectively referred to as the “Services”).

1.2. This Agreement is entered into between Individual Entrepreneur Oksana Vladimirovna Vezhina (OGRNIP 324470400023858, INN 470516487295), hereinafter referred to as the “Operator,” and any natural person who has agreed to its terms (hereinafter referred to as the “User”).

1.3. The Services are intended exclusively for natural persons aged 18 and over. Use of the Services by persons under 18 is prohibited.

1.4. Any actions taken by the User to use the Services (registration, installation of the Application, authorization, access via browser or mobile device) shall be deemed acceptance of this Agreement and constitute full and unconditional acceptance of all its terms, as well as the Privacy Policy, which is an integral part hereof. If the User does not agree with the terms of the Agreement, the User must immediately stop using the Services.

1.5. The Operator has the right to amend the terms of this Agreement unilaterally within the limits permitted by law. The new version of the Agreement shall enter into force from the moment it is published on the website tloa.app, unless otherwise expressly stated in the text. When making material changes, the Operator notifies Users via a banner or notification in the Application and may request renewed confirmation of consent.

1.6. The Privacy Policy is an integral part of this Agreement. Use of functions related to the processing of personal data, including sensitive categories (voice recordings, tests, beliefs, program progress), is permitted only with separate consent from the User.

1.7. This Agreement is governed by the laws of the Russian Federation. For foreign Users, mandatory rules of their country of residence shall also apply (including, without limitation: GDPR — for users from the EU, UK GDPR — for users from the United Kingdom, CCPA/CPRA — for users from the United States, LGPD — for users from Brazil, PIPEDA — for users from Canada). In the event of a conflict of rules, the rule that provides a higher level of protection of the User’s rights shall apply, provided that this does not conflict with the mandatory requirements of the laws of the Russian Federation.

1.8. Disputes and jurisdiction. The procedure for dispute resolution and the applicable law are determined by Section 8 of this Agreement.

2. Terms of Use of the Services

2.1. Age.
The Services are provided exclusively to Users aged 18 and over. Use of the Services by persons under 18 is prohibited. The Operator does not intentionally collect personal data of minors. If it is discovered that a minor is using the Services, the Operator has the right to immediately block and delete the account and related data within the limits permitted by applicable law.

2.2. Registration and account data.
To access certain features of the Services (including checklists, chatbot, voice recordings, subscriptions), the User must register and provide accurate and up-to-date information (at minimum: name, email address, and password). The User undertakes to update such information promptly if it changes.

2.3. Account security.
The User is responsible for the confidentiality of the login/password and for all actions performed through the User’s account. It is recommended to enable two-factor authentication (if available). The User must immediately notify the Operator of any unauthorized access. Transfer of the account to third parties is prohibited.

2.4. Sensitive data and access to features.
Access to features related to the processing of sensitive data (voice recordings, psychological tests, intentions/beliefs, program progress) is provided only with separate express consent from the User. If such consent is absent or withdrawn, the corresponding features automatically become unavailable. The User may withdraw consent at any time through the Services interface; the procedure for data deletion is governed by the Privacy Policy.

2.5. Verification of data accuracy and Operator measures.
The Operator has the right to verify the accuracy of the information provided and compliance with the terms of the Agreement and the Policy. If violations are detected (including inaccurate data, use of another person’s email, circumvention of age/territorial restrictions, fraud, abuse), the Operator has the right to temporarily restrict functionality, block or delete the account, and refuse further provision of the Services within the limits permitted by applicable law.

2.6. Territorial availability, sanctions, and export control.
The Services are available to users worldwide, except mainland China and other countries/territories where the provision of services is prohibited by sanctions, export control, or other mandatory rules. The User confirms that they are not located in and are not a resident of restricted jurisdictions and will not use the Services in violation of sanctions regimes.

2.7. Assignment of the “home hub” and regional regimes.
Upon registration, the Operator assigns the User a “home hub” for data storage (RU hub for Russian citizens; EU hub for others) based on a combination of factors (stated country/citizenship, IP geolocation, etc.). If the factors do not match, the Operator may request confirmation and, if necessary, adjust the hub. Localization and other processing issues are governed by the Privacy Policy. The User is responsible for the accuracy of the information provided about their country of residence and agrees that the country selected during registration is the basis for assigning the home hub. If VPN is used or inaccurate data is provided, responsibility for possible consequences (including storage of data in another jurisdiction) lies with the User.

2.8. Technical requirements and permissions.
To use certain features, the following may be required: a stable internet connection, a compatible device/browser, a microphone (for audio recording), permission to receive push notifications (at the User’s option), and cookies enabled to the extent selected by the User. The quality and availability of certain features may depend on the device and settings.

2.9. Audio and storage limits.
One active audio recording per account is allowed; maximum duration is up to 10 minutes; maximum file size is up to 50 MB; recommended storage formats are opus/aac (~64 kbps). When creating a new recording, the previous active recording is deleted. Rules for data storage and deletion are governed by the Privacy Policy (including deletion after 12 months of account inactivity with 30 days’ notice).

2.10. Acceptable Use Policy (AUP).
It is prohibited to:
a) violate the law or the rights of third parties (including intellectual property rights, privacy, reputation);
b) upload or distribute unlawful, harmful, offensive, discriminatory, extremist content;
c) transmit malicious code, carry out DDoS attacks, scraping, vulnerability scanning, or circumvent technical protection measures;
d) decompile, modify, or reverse engineer the Services;
e) use the Services to provide paid services to third parties without the Operator’s consent (reselling, sub-licensing);
f) create more than one active account per person without the Operator’s permission;
g) collect data from other users without their consent or otherwise violate the Policy.

2.11. User Content (UGC).
a) The User warrants that they have all necessary rights to the materials they post (audio, texts, etc.) and that such content does not violate the law or the rights of third parties.
b) The User retains rights to their content but grants the Operator a limited, non-exclusive, revocable license to store, process, reproduce, and technically transform the content solely for the purpose of providing functionality to the User (reproducing their affirmations, progress, etc.) for the duration of use of the Services.
c) The Operator has the right to delete or block content that violates the Agreement, the law, or the rights of third parties, to the extent permitted by law.
d) The Services are not a public platform for content distribution: by default, content is visible only to the User themselves unless otherwise expressly provided by the functionality.

2.12. AI functionality (chatbot).
The chatbot responses are generated automatically using artificial intelligence technologies, including the involvement of an external AI processing provider acting as a processor on behalf of the Operator. The responses are for informational purposes only, are not medical, legal, financial, or other professional advice, and may contain inaccuracies. The User undertakes to independently verify critical information and not to use AI responses in situations where professional assistance is required.

2.13. Notifications.
The User may receive service notifications (including progress updates, document changes, critical security events) via email and/or push notifications. Marketing notifications are sent only with consent and may be disabled at any time. The procedure for managing notifications is governed by the Privacy Policy and the settings in the profile.

2.14. Availability and changes to the Services.
The Operator strives to ensure 24/7 availability, but does not guarantee the absence of failures, interruptions, or errors. The Operator has the right to change, restrict, or discontinue the provision of certain features (including beta features), conduct maintenance, and introduce updates and fixes. The Operator notifies Users of critical changes in advance to the extent reasonably possible.

2.15. Subscriptions and paid features.
2.15.1. Access to certain features of the Services is provided by subscription for a term of 1, 3, or 12 months. The specific scope of features, price, and subscription terms are indicated in the Services interface before payment.
2.15.2. The subscription cost, term, and set of features are displayed on the payment page; these terms take precedence over the general description and the provisions of Section 3 “Subscriptions, Paid Services and Payments” in the event of discrepancies shown immediately before payment.
2.15.3. Payment is made through a payment aggregator (for example, Prodamus). Card details are entered on the aggregator’s side in encrypted form. The Operator does not process or store bank card details.
2.15.4. By default, the subscription is not renewed automatically. Auto-renewal is possible only with the User’s separate consent (checkbox/button at payment).
2.15.5. If auto-renewal is enabled, the plan fee is charged at the start of each new period (1/3/12 months). The User may disable auto-renewal in the personal account; access remains until the end of the paid period.
2.15.6. No refunds are made for digital services already provided, except in cases of mistaken/double charges or a technical error caused by the Operator.

2.16. Prohibition of bad-faith conduct.
Fraud involving subscriptions/payments, bypassing limits, abuse of trial periods, artificial “boosting” of activity, attempts to gain unauthorized access to data or infrastructure, as well as other actions creating risks to security and the rights of third parties, are prohibited.

2.17. Deletion of account and data.
The User may delete the account through the profile settings. The consequences for data and deletion timelines are governed by the Privacy Policy (including deletion after 12 months of account inactivity following 30 days’ notice).

2.18. Priority of mandatory rules.
If the mandatory national rules of the User’s country of residence provide additional rights or impose special requirements (for example, GDPR/UK GDPR, CCPA/CPRA, LGPD, PIPEDA), such rules shall prevail in the relevant part over the terms of this section.

3. Subscriptions, Paid Services, and Payments

3.1. Subscription terms
3.1.1. Access to certain features of the Services is provided by paid subscription (“Subscription”). Available plans: 1 month, 3 months, 12 months. The specific scope of features, price, and terms of each plan are indicated in the Services interface before payment.
3.1.2. The subscription cost, term, scope of features, and other material terms are disclosed to the User before payment. The terms shown on the payment page before payment have priority.
3.1.3. Making payment means entering into a contract on the terms of this Agreement and the selected plan.

3.2. Ordering and payment
3.2.1. Payment is made through a payment aggregator (including Prodamus). Card details are entered on the aggregator’s side in encrypted form.
3.2.2. The Operator does not process or store bank card details; it receives only technical information sufficient to track the status of the subscription.
3.2.3. The payment currency and any bank/card issuer commissions are disclosed to the User before payment or are determined by the User’s bank. Third-party fees are paid by the User.

3.3. Automatic renewal (recurring payments)
3.3.1. By default, the subscription is not renewed automatically. Auto-renewal is possible only with the User’s separate consent (checkbox/button at payment).
3.3.2. If auto-renewal is enabled, the plan fee is charged at the start of each new period (1/3/12 months).
3.3.3. The User may disable auto-renewal in the personal account; access remains until the end of the paid period.
3.3.4. If charging is not possible (insufficient funds, card invalid), access remains until the end of the already paid period; no renewal is made.

3.4. Time of service provision
3.4.1. Access to the features is provided immediately after payment is confirmed by the aggregator. For users from the EU/UK, the provision of digital content/services begins only after express consent to immediate performance and confirmation of the loss of the right of withdrawal, if such right is provided by applicable law.

3.5. Withdrawal and refunds
3.5.1. Subscriptions and packages are digital services; no refund is made for access already provided.
3.5.2. An exception may apply in the event of a mistaken/double charge or a technical error that made access impossible due to the Operator’s fault.
3.5.3. Cancellation of auto-renewal stops future charges but does not result in a refund of amounts previously paid.

3.5.4. The provisions of this section apply to the fullest extent permitted by law and do not limit mandatory consumer rights and withdrawal rights provided under applicable law (including, where applicable, rules on digital content in the EU/UK).

3.6. Changes to prices and terms
3.6.1. The Operator has the right to change prices and the scope of features. Changes apply to new subscriptions and subsequent renewals; already paid periods are serviced under the previous terms.
3.6.2. If the price for auto-renewal changes, the Operator notifies the User in advance; the User may disable auto-renewal before the new prices take effect.

3.7. ChatBot packages
3.7.1. Upon registration, the User receives 10 free chatbot requests for every 30 days.
3.7.2. Paid packages: 10 / 50 / 100 requests, validity period — 30 calendar days. Unused balance does not carry over.
3.7.3. 1 request = 1 chatbot response (up to a maximum of 700 tokens).
3.7.4. Payment for packages is made through a payment aggregator under the rules of this section.
3.7.5. No refunds are made for packages.

3.8. International requirements
3.8.1. For EU/UK users, the following rules apply: transparent terms, mandatory pre-payment disclosure, ability to disable auto-renewal, and no hidden charges.
3.8.2. For users in the United States (including California) — CCPA/CPRA rules: transparent terms, prohibition on selling transaction data, and simple subscription management.
3.8.3. For users in Brazil (LGPD), Canada (PIPEDA), India (DPDPA) — similar principles of transparency and control.
3.8.4. For the Russian Federation — the rules of the Civil Code of the Russian Federation and the law on consumer protection, including the rules on services provided remotely.

3.9. Documents and notifications
3.9.1. An electronic receipt/invoice is generated by the payment aggregator and sent to the User’s email.
3.9.2. The User must keep the email address up to date in order to receive documents and notifications.

3.10. Special payment terms via Prodamus
3.10.1. Prodamus accepts and processes payments in accordance with the PCI DSS security standard.
3.10.2. Prodamus is responsible for the technical accuracy of operations (card verification, 3-D Secure/SCA, data protection, refunds for mistaken charges).
3.10.3. The Operator is responsible for providing paid access but is not liable for the actions of banks, exchange rate differences, or commissions beyond its control.
3.10.4. In the event of a mistaken/double charge, the refund is made through Prodamus; the User may contact either Prodamus support or the Operator (info@tloa.app).
3.10.5. In case of a chargeback, access to the paid functionality may be suspended until the dispute is resolved; if the chargeback is found to be justified, access is terminated.
3.10.6. For payment and refund questions, the User may contact:
— the Operator: info@tloa.app;
— Prodamus (contacts in the receipt/payment page).

4. Rights and Obligations of the Parties

4.1. Rights and obligations of the User

4.1.1. The User confirms that they have reached 18 years of age, have the necessary legal capacity to enter into and perform this Agreement, and are not a person subject to restrictions on access to the Services (including territorial and sanctions restrictions).

4.1.2. The User undertakes, when registering and further using the Services, to provide accurate, up-to-date data (including an email address), to update it promptly, and to ensure the confidentiality of their account credentials (login and password). All actions performed using the User’s account shall be deemed actions of the User themselves.

4.1.3. The User has the right to:

access the paid and free features of the Services to the extent and on the terms indicated on the Website/Application;

manage the subscription and auto-renewal, including disabling recurring charges;

withdraw previously given consents (including consent to processing of sensitive data and marketing notifications) and understand the consequences of such withdrawal (restriction or unavailability of features dependent on consents);

request deletion of the account and all related data, as well as request an export of a copy of their data in machine-readable format in the manner provided by the Privacy Policy;

manage cookie and push-notification preferences;

contact support regarding the functioning of the Services, subscription, and payments.

4.1.4. The User undertakes to use the Services exclusively for personal, non-commercial purposes, not to transfer access to third parties, not to resell, rent, or provide access to the Services as a service to third parties, and not to use the Services to create competing products.

4.1.5. The User undertakes to refrain from actions that violate the rights of the Operator, other users, and third parties, including:

not to post or transmit through the Services information that violates the law, third-party rights, moral and ethical standards (including extremism, violence, discrimination, hatred, pornography, information violating the right to one’s image and privacy);

not to post personal data of third parties without legal grounds and the consent of the relevant persons;

not to violate rights to the results of intellectual activity (copyright and related rights, trademarks, etc.);

not to attempt to bypass technical protection measures, interfere with the operation of the Services, conduct reverse engineering, decompilation, or other actions aimed at obtaining source code;

not to use automated means (robots, scrapers, parsers), except for the interfaces provided;

not to distribute malware and not to attempt unauthorized access;

to comply with established territorial restrictions and not to circumvent them in ways that violate applicable law.

4.1.6. Special rules for sensitive data.

Access to features related to the processing of sensitive data (voice recordings, diaries of intentions and beliefs, tests, program progress) is provided only with the User’s separate consent.

The User may at any time delete individual sensitive records or withdraw consent in full; upon withdrawal, the collection of such data stops, and previously collected data must be deleted, except where retention is required by law.

Refusal or withdrawal of consent may make part of the functionality unavailable.

4.1.7. Rules for using ChatBot.

1 request = 1 response; the response length is limited by technical parameters.

The User undertakes not to enter into the ChatBot data the dissemination of which would violate the law or the rights of third parties.

ChatBot responses are informational only and do not constitute professional advice; the User makes decisions independently.

When limits are exhausted, the User may purchase additional request packages.

4.1.8. The User is responsible for compliance with the requirements of the applicable laws of their country of residence and must stop using the Services if such use violates mandatory rules.

4.2. Rights and obligations of the Operator

4.2.1. The Operator undertakes to provide access to the Services within the limits of technical capabilities and the terms of this Agreement, to implement organizational and technical measures to protect personal data, to comply with regional processing rules (localization of data of Russian citizens in Russia, processing of data of other users in the EU infrastructure), and not to store Users’ bank card details.

4.2.2. The Operator provides the User with tools to manage subscriptions, consents, and the account (deletion, data export, notification and cookie settings) in accordance with the Privacy Policy.

4.2.3. The Operator has the right to:

change functionality, interfaces, subscription prices, and package terms (while preserving terms for the already paid period);

perform maintenance and temporarily restrict access to the Services;

set technical limits (request limits, storage volumes, etc.);

request confirmation of information for assigning the home hub and block access from prohibited jurisdictions;

suspend or terminate access in case of violations, fraud, abuse, or chargebacks.

4.2.4. The Operator undertakes to:

process sensitive data only with the User’s separate consent;

keep records of consents and maintain a history of versions of key documents;

correctly reflect subscription and payment statuses;

send electronic payment documents and notify Users of significant changes to the terms;

review User requests and respond within a reasonable time.

4.2.5. The Operator has the right to implement and change information security measures (logging, MFA, incident monitoring, intrusion protection, etc.).

4.2.6. The home hub is assigned on the basis of data provided by the User themselves.

The Operator relies on this information and is not liable for its inaccuracy.

4.3. User content

4.3.1. All rights to the Application and its elements (code, design, databases, logos, etc.) belong to the Operator or are used by it lawfully.

4.3.2. Content that the User posts or creates (intention texts, notes, exercise results, audio recordings) remains the User’s property. The User grants the Operator a non-exclusive, revocable, purpose-limited license to use the content (storage, processing, backup, display to the User themselves) for the duration of the Services.

4.3.3. If the content relates to sensitive data, it is used only with separate consent and solely for the purpose of providing services; such content is not used for advertising purposes and is not transferred to third parties outside the purposes of the Services’ operation or legal requirements.

4.3.4. The Operator has the right to delete User content that violates the Agreement, the law, or the rights of third parties.

4.4. Moderation and termination of access

4.4.1. The Operator has the right to apply measures such as warning, functionality restriction, suspension of access, deletion of content or the account in case of violations of the Agreement, law, or third-party rights, or in case of fraud, abuse, or chargebacks.

4.4.2. In the event of account inactivity for more than 12 months, the Operator deletes it and related data after notifying the User 30 days in advance.

4.4.3. If access is terminated due to a violation of the Agreement, fees for subscriptions and packages are not refunded. If access is terminated for technical reasons, settlement issues are resolved individually.

4.5. Contractors and cross-border aspects

4.5.1. The Operator may engage contractors and processors (payment aggregators, hosting providers, analytics and AI providers) provided they comply with security and confidentiality requirements.

4.5.2. Data of Russian citizens is stored in Russia; data of users from other countries is stored in the EU. Cross-border transfers may occur where there are legal grounds and protection safeguards.

4.5.3. The Services are unavailable to users from mainland China.

4.6. Feedback and notifications

4.6.1. Official communication is carried out via the Application, the Website, and the email address specified in the account. The User must keep the email address up to date and monitor notifications.

4.6.2. Requests are reviewed within a reasonable time; matters related to personal data are handled within the time frames set by the Privacy Policy.

4.6.3. Updates to key documents are brought to the User’s attention by publication and/or notification in the Services. In cases where express consent is required, data processing continues only after such consent is obtained.

5. Intellectual Property and License

5.1. Rights of the Operator

5.1.1. All exclusive rights to the Services, including software code, design, user interface, database structures and contents, texts, images, audio materials (including meditations), video, animations, illustrations, logos, trademarks, names, and other results of intellectual activity (hereinafter referred to as the “Operator Materials”), belong to the Operator or are used by it lawfully (licenses, agreements with right holders).
5.1.2. Providing access to the Services does not mean transferring exclusive rights to the User; only a limited license is granted to the extent established by this Agreement.
5.1.3. The Operator Materials are protected by the laws of the Russian Federation and international treaties (including the Berne Convention, the Universal Copyright Convention) and the applicable law of the relevant jurisdictions.

5.2. License to use

5.2.1. The User is granted a simple (non-exclusive), non-transferable, non-sublicensable, revocable license limited to the subscription term (or free use) to use the Services solely for personal non-commercial purposes.
5.2.2. The User has the right to:
— install the Application as a PWA on their devices;
— use the functionality of the Services within the provided plans/subscriptions;
— save the results of their activity (checklists, notes, progress history, audio recordings) in the personal account;
— delete their data and manage consent for its processing in the manner established by the Privacy Policy.
5.2.3. The User has no right to:
— copy, modify, distribute, or transfer to third parties the software code, design, interfaces, or databases of the Services;
— decompile, disassemble, reverse engineer, or otherwise attempt to obtain source code;
— create derivative products/services based on the Services without the Operator’s written permission;
— use the Services to provide services to third parties (SaaS, rental, resale);
— bypass technical restrictions (limits, paid packages, geo-blocks);
— use the Operator’s trademarks/logos and other means of individualization without its written consent, except in cases expressly permitted by applicable law.

5.3. User content (in accordance with clause 4.3)

5.3.1. All rights to content created by the User in the Services (including intention texts, notes, audio recordings, test results, etc.; hereinafter referred to as “User Content”) belong to the User.
5.3.2. By posting/storing User Content in the Services, the User grants the Operator a non-exclusive, royalty-free, revocable, purpose-limited license to process it solely for the provision of services: storage, reproduction for the User themselves, technical processing (including encryption, transcoding), backup, deletion upon request. The license is valid for the term of use of the Services and terminates upon deletion of the relevant content/account, except where retention is required by law or within the cycle of technical backup and/or is necessary to resolve disputes and protect rights to the extent permitted by law.
5.3.3. Content relating to sensitive data (voice recordings, beliefs, tests, progress) is processed only with separate consent. Such content is not used for marketing/advertising purposes and is not transferred to third parties, except where necessary for the functioning of the Services or compliance with mandatory legal requirements.

5.4. Liability for User Content

5.4.1. The User bears full responsibility for the legality and accuracy of uploaded/created content, including the existence of all necessary rights and consents.
5.4.2. The Operator does not carry out comprehensive prior moderation, but has the right to delete/restrict access to content that: violates the Agreement or the law; contains extremism, violence, discrimination, pornography; infringes third-party rights (including IP and privacy); or is capable of harming the rights, legitimate interests, or reputation of the Operator/users.

5.5. Intellectual property of third parties

5.5.1. The Services may contain third-party IP objects (including libraries, analytics services, AI services, payment systems). Such objects are protected by the relevant law; the User undertakes to comply with the terms of their use.
5.5.2. Use of third-party services (for example, Prodamus, analytics/AI providers) is governed by their own terms. The Operator is not responsible for the actions of such third parties or their infrastructure insofar as they are beyond the Operator’s control.

5.6. Third-party components and open source software (OSS)

5.6.1. The Services may include components, SDKs, and/or open source software. Such components are subject to the licenses of the relevant right holders. To the extent of any conflict with this Agreement, the terms of the relevant OSS licenses prevail to the necessary extent.
5.6.2. The Operator posts notices of applicable OSS licenses and, where necessary, provides source texts/materials in accordance with their terms.

5.7. Content and AI results (ChatBot)

5.7.1. Individual responses, prompts, and other materials may be generated using AI technologies (including external providers) and are provided “as is” for informational and educational purposes.
5.7.2. The User receives a limited personal (non-exclusive, non-transferable) license to use AI results within the Services. Similarities in responses between different users are possible; such similarities do not create exclusive rights.
5.7.3. Mass exporting/replication/aggregation of AI results for training competing models or systematic distribution without the Operator’s written permission is prohibited.
5.7.4. AI materials do not constitute professional advice; the User independently verifies their applicability and legal compliance.

5.8. Rights to databases and restriction on extraction (EU/UK sui generis)

The Operator is the compiler/right holder of the databases created and maintained within the Services. Systematic and/or substantial extraction or re-use of the contents of such databases without the Operator’s consent is prohibited.

5.9. Trademarks and designations

5.9.1. “TLOA,” “TLOA — Law of Attraction,” logos, and other means of individualization are trademarks/designations of the Operator or are used under license. Any use of them without written permission is prohibited, except in cases of permissible “fair use” expressly allowed by law.
5.9.2. Third-party signs (payment aggregators, platforms, etc.) are used to indicate compatibility/integration and remain the property of their right holders.

5.10. Notice and takedown procedure

Claims of infringement should be sent to info@tloa.app with the following information: (i) the disputed material and its location (URL/screenshots/identifiers); (ii) a description of the rights infringed and evidence of authority; (iii) contact details; (iv) a request for blocking/removal; (v) confirmation of good faith and accuracy of the information. The Operator reviews the notice within a reasonable time and, if grounds exist, takes action; to prevent abuse, verification of the complainant’s identity/rights may be requested.

5.11. Feedback

By providing the Operator with feedback, ideas, and suggestions, the User grants, free of charge, a non-exclusive, irrevocable, perpetual, worldwide license to use them (including implementation in the Services) without any obligation to pay remuneration and without attribution, unless otherwise agreed in writing. Feedback must not include confidential information of third parties.

5.12. Termination of the license and survival of provisions

5.12.1. The license granted under Section 5 terminates automatically upon the User’s violation of the terms of the Agreement, as well as upon deletion of the account. Termination of the license does not affect the validity of previously performed authorized actions and does not deprive the Operator of the right to protect its rights.
5.12.2. Clauses 5.6–5.11 survive termination of access to the Services to the extent necessary to protect rights, comply with the law, and resolve disputes.

6. Limitation of Liability and Warranties

6.1. “As is” and “as available”
6.1.1. The Services are provided “as is” and “as available.” The Operator does not guarantee uninterrupted or error-free operation, the absence of vulnerabilities, conformity with the User’s subjective expectations, or compatibility with specific devices or networks.
6.1.2. To the extent permitted by law, the Operator has the right to change or discontinue the provision of the Services in whole or in part, notifying Users where reasonably possible.

6.2. No professional advice and no guarantee of results
6.2.1. The Services are intended for informational, educational, developmental, and wellness purposes, are not medical, legal, financial, or other professional advice, and do not replace consultation with relevant specialists.
6.2.2. The materials of the Services (including neuro-practices, meditations, programs, chatbot) do not guarantee any specific result (for example, improvement of health, income, employment).
6.2.3. The User undertakes not to use the Services in high-risk situations (driving, working with dangerous equipment) and not to treat recommendations as instructions for action in emergencies.

6.3. AI-generated and User-generated content
6.3.1. Chatbot responses and other AI-processing results are generated automatically and may contain inaccuracies or outdated information. The Operator does not guarantee the completeness or accuracy of such materials and is not responsible for decisions made on their basis, except as expressly provided by law.
6.3.2. The User is responsible for the legality and accuracy of their own content, as well as for the absence of third-party rights violations.

6.4. Interruptions, failures, beta features
6.4.1. Temporary failures, errors, notification delays, and unavailability of features may occur due to communications networks, third-party platforms, DDoS attacks, or force majeure. The Operator makes reasonable efforts to restore functionality.
6.4.2. Certain features may be provided as “beta” or “early access” and may be changed or disabled without warranties.

6.5. Third-party services and links
6.5.1. The Services use third-party solutions (payment aggregators, AI providers, analytics, hosting). The Operator is not responsible for their operation, security measures, or privacy policy.
6.5.2. Following external links is at the User’s risk; the Operator is not responsible for the content of third-party resources.

6.6. Limitation of liability
6.6.1. To the maximum extent permitted by law, the Operator and its contractors are not liable for:
a) lost profits, loss of income, or loss of business reputation;
b) indirect, incidental, or special damages;
c) loss of data for reasons beyond the Operator’s control.
6.6.2. The Operator’s aggregate liability is limited to the amount actually paid by the User for the Services during the last 12 months; for free access — the equivalent of RUB 1,000.
6.6.3. These limitations apply to any grounds for claims (contract, tort, etc.), unless otherwise required by a mandatory rule.

6.7. Mandatory exceptions and consumer rights
6.7.1. This section does not exclude liability for intent, gross negligence, harm to life or health, fraud, or misrepresentation.
6.7.2. The terms do not restrict mandatory consumer rights granted by applicable law (Russian Federation, EU/UK, USA, Canada, Brazil, etc.).

6.8. Indemnity and compensation of losses
6.8.1. To the extent permitted by law, the User undertakes to compensate the Operator for direct losses and to hold it harmless from justified claims of third parties arising from:
— unlawful use of the Services;
— violation of third-party rights;
— posting prohibited content;
— violation of the terms of the Agreement.
6.8.2. The User may not enter into agreements imposing obligations on the Operator without its written consent.

6.9. Backups and data
6.9.1. The Operator performs backups in the home hub (RU/EU), but does not guarantee absolute data preservation under circumstances beyond its control.
6.9.2. The User is responsible for local backup of important data and for timely deletion of their records.

6.10. Limitation period for claims
6.10.1. Unless otherwise required by a mandatory rule, claims against the Operator must be brought within 6 months from the moment the User became aware or should have become aware of the basis for the claim.
6.10.2. For consumers, the period provided by law applies if it is longer.

6.11. Applicability by jurisdiction
6.11.1. Some jurisdictions do not allow the exclusion of warranties or limitation of liability. In such cases, the provisions of this section apply to the fullest extent permitted.
6.11.2. In the EU/UK, USA, Canada, Brazil, India, and other countries with mandatory consumer guarantees, this section shall be interpreted in accordance with their law.

6.12. Responsibility for providing inaccurate information about the country of residence (including when using VPN) lies solely with the User. The Operator relies on the data provided by the User and is not responsible for the consequences (including possible storage of data in another jurisdiction) caused by an incorrect country indication. 

7. Force Majeure (Acts of God)

   
   

7.1. Definition
7.1.1. The Parties are released from liability for full or partial non-performance of obligations under this Agreement if such non-performance is caused by force majeure circumstances arising after its conclusion and beyond the reasonable control of the Parties.
7.1.2. Such circumstances include: natural disasters, epidemics/pandemics, wars and conflicts, civil unrest, terrorist acts, acts of government authorities, changes in legislation, sanctions and export control, shutdowns of payment infrastructure, data center and communications network failures, large-scale cyberattacks, accidents and power outages, and other events that could not have been foreseen and prevented by reasonable measures.

7.2. Consequences
7.2.1. During the force majeure period, performance of obligations is suspended to the relevant extent; a breach during this period does not give rise to liability.
7.2.2. Deadlines are extended proportionally to the duration of the force majeure event.
7.2.3. The Parties undertake to take reasonable measures to minimize consequences and resume performance.

7.3. Sanctions and regulatory restrictions
7.3.1. If the provision of the Services becomes unlawful or impossible due to sanctions, export control, or blocking of settlements, the Operator has the right to suspend the provision of services, refuse renewal, or restrict functionality/hosting.
7.3.2. Such actions shall not be deemed a breach of the Agreement. The Operator notifies the User of the reasons when possible.

7.4. Notification
7.4.1. The Party affected by force majeure must notify the other Party within a reasonable time using any available means (for example, publication on the Website or email).
7.4.2. Upon request, confirmation of the nature of the circumstances and the expected duration may be provided, to the extent that it does not compromise security and confidentiality.

7.5. Duration and termination
7.5.1. If force majeure lasts more than 60 days and substantially impedes the provision of paid services, either Party may terminate the Agreement in the affected part by giving the other Party 7 days’ notice.
7.5.2. Termination does not relieve the Parties from performance of monetary obligations incurred before the termination date, unless otherwise required by law.

7.6. Data and security
7.6.1. Force majeure does not release the Operator from mandatory data protection and security breach notification requirements to the extent established by law.
7.6.2. The Operator continues to apply technical security measures where possible and, if not possible, takes alternative risk mitigation measures.

7.7. Subscriptions and compensation
7.7.1. During a force majeure event, auto-renewal of subscriptions may be unavailable; in such case, access ends at the end of the paid period.
7.7.2. If access to the main paid functionality was unavailable for a significant part of the paid period, the Operator may, at its discretion, offer the User compensation in the form of an extension, bonus, or discount. No monetary refund is made, except in cases expressly established by law.
7.7.3. Compensation is not provided if the unavailability is caused by circumstances on the User’s side.

7.8. Priority of mandatory rules
7.8.1. This section applies to the fullest extent permitted and does not limit consumer rights granted by mandatory rules (Russian Federation, EU/UK, USA, etc.).
7.8.2. The Operator is not obliged to provide services if doing so would violate mandatory requirements (sanctions, export control, data localization).

8. Dispute Resolution and Governing Law

   
   

8.1. Governing law.
This Agreement shall be governed by and construed in accordance with the laws of the Russian Federation. For Users who are citizens of the Russian Federation, Russian law applies, including the Civil Code of the Russian Federation, the Law of the Russian Federation “On Protection of Consumer Rights,” and other acts. For Users from other countries, the mandatory rules of their national law apply if they provide a higher level of consumer protection and do not conflict with the mandatory requirements of the laws of the Russian Federation.

8.2. International regulation.
The Operator complies with mandatory international norms in the field of data protection and consumer rights, including (where applicable):
— Regulation (EU) 2016/679 (GDPR) and the ePrivacy Directive (EU);
— UK GDPR (United Kingdom);
— CCPA/CPRA (California, USA);
— LGPD (Brazil);
— PIPEDA (Canada);
— regional U.S. data protection laws (VCDPA, CPA, UCPA, CTDPA, etc.);
— COPPA (USA, insofar as child protection is concerned);
— other mandatory rules applicable to the User in their place of residence.

8.3. Pre-trial procedure.
Before going to court, a User who is a citizen of the Russian Federation must send the Operator a written claim to info@tloa.app. The Operator reviews the claim within up to 30 calendar days and notifies the User of the results. For foreign Users, submitting a claim is recommended unless otherwise provided by the mandatory rules of their national legislation.

8.4. Jurisdiction.
All disputes arising out of or in connection with this Agreement shall be heard by the courts of the Russian Federation at the Operator’s place of registration (Leningrad Region), unless otherwise provided by the mandatory rules of the law of the User’s country of residence.

8.5. Right to contact regulators.
Notwithstanding the provisions of this Agreement, a User located in the EU, the United Kingdom, the USA, Brazil, Canada, and other countries has the right to lodge a complaint with their national data protection or consumer protection authority.

9. Final Provisions

   
   

9.1. Integrity of the document.
This Agreement, together with the Privacy Policy and other documents expressly referenced in the text, constitutes the complete and final agreement between the User and the Operator regarding the use of the Services. All previous arrangements and correspondence on matters governed by this Agreement cease to have effect from the moment this offer is accepted.

9.2. Invalidity of individual provisions.
If any provision of this Agreement is found to be invalid or unenforceable by a competent authority, this does not affect the validity of the remaining provisions. The invalid provision shall be deemed replaced with the closest permissible provision under applicable law in terms of meaning.

9.3. Notification procedure.
Official notices and messages from the Operator are sent to the User at the email address provided during registration or through the Services interface. The User may send notices and claims to info@tloa.app. Messages sent in the specified ways are deemed received:
— when sent by email — 24 hours after sending;
— when published in the interface — from the moment they are displayed to the User.

9.4. Language versions.
The Agreement is drawn up in Russian and English. For Users in the territory of the Russian Federation, the Russian version shall prevail. For Users outside the Russian Federation, the English version shall prevail. In the event of any discrepancy between the texts, the version providing a higher level of protection of the User’s rights applies, unless otherwise provided by mandatory rules.

9.5. Applicability of international rules.
The provisions of this Agreement apply and are interpreted taking into account the mandatory rules of the countries in which Users are located, including the EU (GDPR, ePrivacy), the United Kingdom (UK GDPR), the USA (CCPA/CPRA, COPPA, and other state laws), Canada (PIPEDA), Brazil (LGPD), etc. This Agreement does not apply to Users from mainland China, whose registration is blocked.

9.6. Date and version.
This Agreement comes into force from the moment it is published on the website tloa.app and remains in effect until replaced by a new version. All versions of the Agreement are kept by the Operator and provided to the User upon request.