USER AGREEMENT

/(PUBLIC OFFER)


Version 2.0

This Policy has been approved by Individual Entrepreneur Vezhina Oksana Vladimirovna
OGRNIP: 324470400023858, TIN: 470516487295
Registered address: 188300, Russia, Leningrad Oblast, Gatchinsky District, Gatchina, Shvedskiy Drive, building 1, apt. 53.
Email for inquiries regarding personal data: info@tloa.app

Effective date: 20 September 2026
Last updated: 20 September 2026

1. General Provisions


1.1. This User Agreement (the “Agreement”) constitutes a public offer in accordance with Articles 437 and 438 of the Civil Code of the Russian Federation and sets out the terms of use of the website tloa.app (the “Website”) and the TLOA progressive web application available at web.tloa.app (the “Application”; collectively, the “Services”).

1.2. The service provider under this Agreement is Individual Entrepreneur Oksana Vladimirovna Vezhina, OGRNIP 324470400023858, INN 470516487295 (the “Provider”).

1.3. A User is an individual aged 18 or over who has registered in the Application and accepted this Agreement (the “User”).

1.4. The Agreement is accepted by checking the separate box “I accept the User Agreement” during registration and completing the registration process.

For paid services, payment also confirms acceptance of the terms of the selected plan disclosed to the User immediately before payment.

1.5. Consent to personal data processing is provided separately from acceptance of this Agreement.

The processing of personal data is governed by the Privacy Policy available at:

https://tloa.app/privacy

A separate consent to personal data processing is available at:

https://tloa.app/personal-data-consent

1.6. The Services are intended exclusively for individuals aged 18 or over.

1.7. This Agreement is governed by the legislation of the Russian Federation, including the Civil Code of the Russian Federation and the Law of the Russian Federation “On Consumer Protection” where the User qualifies as a consumer.


2. Purpose and Functionality of TLOA


2.1. TLOA is a digital service designed for the User’s independent work with materials, practices, exercises and other personal development tools.

2.2. Depending on the current version, plan and available functionality, the Application may include:

  • TLOA materials and programmes;

  • the User’s intentions and beliefs;

  • tests and exercises;

  • progress tracking;

  • checklists;

  • user settings;

  • audio recordings;

  • virtual features and other programme tools;

  • a “Help” section containing predefined questions and answers.

2.3. The range of features may be changed and improved. Such changes must not deprive the User of mandatory rights relating to a period that has already been paid for.

2.4. Certain features may be temporarily unavailable due to maintenance, updates, equipment failures, communication network issues or other technical reasons.

2.5. To use certain features properly, the User may require a compatible device and browser, an Internet connection, permission to use the microphone and/or permission to receive push notifications.


3. Registration and User Account


3.1. To register, the User provides a name, a valid email address and creates a password.

3.2. The User must provide accurate information and keep their email address up to date.

3.3. The User is responsible for maintaining the confidentiality of their password and the security of access to their device and account.

3.4. The User may not transfer their account to third parties.

3.5. The User must promptly notify the Provider at info@tloa.app if they become aware of unauthorised use of their account.

3.6. The Provider may temporarily restrict or block access to an account where there are reasonable grounds to believe that:

  • the account is being used without the User’s authorisation;

  • fraudulent activity is taking place;

  • attempts are being made to interfere with the operation of the Services;

  • the legislation of the Russian Federation is being violated;

  • the terms of this Agreement are being materially breached.


4. User Content and Audio Recordings


4.1. The User may create and store in TLOA their own texts, intentions, beliefs, exercise results, test responses, checklists, audio recordings and other user content supported by the functionality of the Services.

4.2. The User retains the rights to content created by the User.

4.3. By storing content in TLOA, the User grants the Provider a limited, non-exclusive right to technically process such content solely to the extent necessary to provide the functionality of the Services, including storing it, displaying it to the User, reproducing it, creating technical backup copies, converting its format and deleting it.

4.4. The User must not upload or store through the Services any materials that violate the legislation of the Russian Federation or the rights of third parties.

4.5. One active user audio recording with a maximum duration of 10 minutes may be stored in the account.

4.6. When a new audio recording is created, the previous active audio recording is automatically replaced and deleted in accordance with the technical logic of the Service.

4.7. Voice recordings are not used by TLOA to identify or authenticate the User.


5. Subscription and Paid Access


5.1. Certain TLOA features are provided on a paid subscription basis.

5.2. The following subscription periods are available:

  • 1 week;

  • 1 months;

  • 12 months.

5.3. The current price, subscription period and functionality included in the relevant plan are displayed to the User immediately before payment.

5.4. Access to paid functionality is provided after the Service receives confirmation of successful payment from the payment service.

5.5. The paid access period begins when the relevant access is activated, unless otherwise stated immediately before payment.

5.6. The fact that the User does not actually log in to the Application or use the available features during the paid period does not in itself mean that access to the Service was not provided, provided that such access was technically activated and available to the User.


6. Prodamus, Payments and Recurring Payments


6.1. Payments are accepted and technically processed using the Prodamus payment service.

6.2. Payment card details and other payment credentials are entered and processed within the payment infrastructure of Prodamus and/or participating banks and payment systems.

6.3. The Provider does not receive or store the User’s full payment card details.

6.4. The Provider may receive from Prodamus only the information necessary to perform this Agreement, including transaction status, payment identifier, payment amount, selected plan and subscription status.

6.5. The Provider does not control and, unless otherwise expressly required by law, is not responsible for:

  • technical failures on the Prodamus side;

  • a bank’s refusal to process a transaction;

  • the operation of banks and payment systems;

  • payment card blocking;

  • restrictions and limits imposed by a bank;

  • the operation of 3-D Secure and other bank verification methods;

  • the time taken by a bank to actually credit funds;

  • fees and other conditions imposed by a bank or payment system;

  • technical unavailability of the payment page due to circumstances beyond the Provider’s control.

6.6. Matters directly related to the technical processing of a bank transaction, payment card processing or operation of the payment infrastructure may be handled with the involvement of Prodamus and the relevant bank.

6.7. Automatic subscription renewal is enabled only if the User gives separate consent to recurring payments.

Such consent is not part of the TLOA registration process.

6.8. Recurring payments are governed by a separate document, “Consent to Recurring Payments”.

6.9. The User may electronically withdraw permission for previously provided payment details to be used for recurring charges through the method made available within the Prodamus payment process and/or the Services.

After such withdrawal, the relevant payment details must not be used for new recurring charges.

6.10. Where recurring payments are not available for the selected payment method or region, the User purchases access for a single paid period only. No automatic renewal applies. To continue access after the end of that period, the User must make a new payment.


7. Subscription Cancellation and Refunds


7.1. The User may withdraw from further performance of the service agreement in accordance with the legislation of the Russian Federation.

7.2. If a refund is required by law following such withdrawal, the amount to be refunded is determined taking into account:

  • the period of access actually provided to the User;

  • services actually provided;

  • expenses actually incurred by the Provider and directly related to performance of the agreement;

  • other circumstances that must be taken into account when calculating a refund under the legislation of the Russian Federation.

7.3. Amounts attributable to an access period already provided and services already rendered are non-refundable, except where otherwise expressly required by the legislation of the Russian Federation.

7.4. The User’s failure to use a Service that was available to them, for reasons unrelated to a breach by the Provider, does not in itself constitute a defect in the service.

7.5. Where the User has grounds for a refund under applicable law, the refund transaction may technically be processed through Prodamus.

7.6. The time taken for refunded funds to reach the User after a refund is initiated through the payment system depends on the bank and payment infrastructure and is outside the Provider’s control.

7.7. Nothing in this Section limits consumer rights that cannot lawfully be restricted by agreement between the parties.


8. No Guarantee of Results


8.1. TLOA is an informational, educational and personal development service intended for independent use.

8.2. TLOA is not a medical organisation and does not provide medical, psychotherapeutic, legal, financial or other professional services.

8.3. TLOA materials, exercises and practices do not constitute medical diagnosis, treatment or medical advice.

8.4. The Provider does not guarantee that the User will achieve any specific result through the use of TLOA, including:

  • a change in financial circumstances or income;

  • achievement of a particular personal or professional goal;

  • a change in another person’s behaviour;

  • improvement in health;

  • achievement of a particular psychological or emotional result;

  • occurrence of particular events or circumstances.

8.5. The results of using TLOA depend, among other things, on the User’s individual actions, decisions, circumstances and other factors outside the Provider’s control.

8.6. The User makes decisions independently based on their own experience, circumstances and evaluation of information and is responsible for such decisions.


9. Limitation of Liability


9.1. To the extent permitted by the legislation of the Russian Federation, the Provider is not liable for the inability to use the Services or for resulting consequences where they are caused by circumstances outside the Provider’s reasonable control, including:

  • malfunction of the User’s device;

  • absence or instability of the Internet connection;

  • operating system or browser settings;

  • actions or restrictions of the Internet service provider;

  • actions of banks, payment systems or Prodamus;

  • failures of third-party infrastructure;

  • malware on the User’s device;

  • disclosure by the User of their login credentials to third parties;

  • actions of the User or third parties;

  • force majeure circumstances.

9.2. The Provider is not liable for the subjective failure of materials or features to meet the User’s expectations, provided that the Service corresponds to the description provided before access was purchased.

9.3. The Provider is not liable for the consequences of decisions or actions taken by the User as a result of independently using TLOA materials and practices, except where such liability is expressly imposed by law.

9.4. The Provider is not responsible for user-generated content or information entered by the User, including its accuracy or lawfulness.

9.5. The Provider takes reasonable measures to maintain availability of the Services but does not guarantee absolutely uninterrupted operation, as software, communication networks and third-party technical infrastructure may become temporarily unavailable.

9.6. Temporary maintenance, updates and short-term interruptions do not in themselves constitute a breach of this Agreement where they are objectively necessary for the operation, maintenance, security or development of the Services.

9.7. Nothing in this Section excludes the Provider’s liability in circumstances where exclusion or limitation of such liability is expressly prohibited by the legislation of the Russian Federation.


10. Intellectual Property


10.1. Rights to the software, design, structure of the Services, texts, graphics, audio, video and other TLOA materials belong to the Provider and/or are lawfully used by the Provider.

10.2. The User is granted a limited, non-exclusive right to use the Services solely for personal, non-commercial purposes and only within the functionality available to the User.

10.3. Unless there is a lawful basis or written permission from the relevant rights holder, the User may not:

  • copy or distribute TLOA materials beyond personal use;

  • sell or transfer access to third parties;

  • decompile, interfere with the software code or circumvent technical restrictions;

  • use TLOA designs, texts, trade designations or other materials to create competing products;

  • take actions capable of disrupting the operation or security of the Services.

10.4. User content remains the User’s content and is used by the Provider only to the extent necessary for the operation of TLOA and as provided in this Agreement and the Privacy Policy.


11. Notifications


11.1. The Provider may send the User necessary service communications relating to:

  • registration;

  • account security;

  • account access recovery;

  • payment and subscription status;

  • changes to legal documents;

  • technical or material changes to the Service;

  • deletion of an inactive account;

  • other events necessary for performance of this Agreement.

11.2. Service communications may be sent by email and/or displayed in the Service interface.

11.3. Push notifications are used in accordance with the functionality of the Application and the permissions granted by the User.


12. Account Deletion


12.1. The User may independently delete their account using the “Delete account” function.

12.2. The consequences of deletion of personal data are governed by the Privacy Policy.

12.3. If the User does not log in to TLOA for 12 consecutive months, the Provider sends a warning to the registered email address at least 30 calendar days before the scheduled deletion.

12.4. If the User does not return to TLOA before the relevant deadline, the account is deleted once 12 consecutive months of inactivity have elapsed.

12.5. When the account is deleted, the associated user data and files are deleted, except for information that the Provider is required or entitled to retain in accordance with the legislation of the Russian Federation.


13. Changes to the Agreement and Functionality


13.1. The Provider may update this Agreement in the event of changes to legislation, the functionality of the Service, the terms of service provision or the technologies used.

13.2. The new version is published at:

https://tloa.app/terms

13.3. Material changes affecting the User’s rights or conditions already paid for are communicated to the User in a manner that allows the User to review them.

13.4. Where the law requires new explicit consent from the User in connection with a particular change, the Provider obtains such consent separately.

13.5. Changes to prices and terms apply to future purchases and future subscription periods and do not alter the price of a period that has already been paid for, unless otherwise provided by law or expressly agreed with the User.


14. Dispute Resolution


14.1. The parties may seek to resolve disputes by contacting the Provider’s support service at:

info@tloa.app

14.2. Submitting a prior complaint does not limit a consumer’s right to bring a claim before a court where mandatory pre-trial dispute resolution is not required by law.

14.3. Disputes are resolved in accordance with the legislation of the Russian Federation.

14.4. Where the User qualifies as a consumer, the User may bring a claim before a court in accordance with the jurisdiction rules established by the legislation of the Russian Federation.


15. Final Provisions


15.1. If any provision of this Agreement is held to be invalid, the remaining provisions remain valid and enforceable.

15.2. This Agreement remains in effect from the moment it is accepted by the User until the account is deleted, the User ceases using the Services, or the Agreement is otherwise terminated on a basis provided by law.

15.3. The current version of the Agreement is available at:

https://tloa.app/terms

15.4. The Agreement may be published in Russian and English. For the Russian version of the Services, the Russian-language version is the primary version. The English translation is provided for convenience unless otherwise required by mandatory provisions of applicable law.


16. Provider Details


Individual Entrepreneur Oksana Vladimirovna Vezhina

Primary State Registration Number of the Individual Entrepreneur (OGRNIP): 324470400023858
Taxpayer Identification Number (INN): 470516487295
Registered address: Apt. 53, 1 Shvedsky Proezd, Gatchina, Gatchinsky District, Leningrad Region, 188300, Russian Federation

Website: https://tloa.app
Application: https://web.tloa.app
Email: info@tloa.app