TERMS AND CONDITIONS

TERMS AND CONDITIONS

Allgemeine Geschäftsbedingungen (AGB)

Garritz Marketing Cloud (GMC) --- SaaS Platform Agreement

Operated by Garritz Online Media International GmbH

Effective Date: February 14, 2026 | Version 2.1 | Governed by the laws of the Federal Republic of Germany

1. Scope and Acceptance of Terms (Geltungsbereich)

1.1 These General Terms and Conditions ("Terms" / "AGB") govern the contractual relationship between Garritz Online Media International GmbH, operating the Garritz Marketing Cloud platform ("GMC", "Provider", "we"), and the User ("Customer", "you") for the use of the GMC software-as-a-service platform. These Terms apply to all services provided by GMC, including but not limited to the Platform, APIs, Geo-Intelligence modules, ROVI, NODE, and Activate Segment.

1.2 By creating an account, you accept these Terms in accordance with §305(2) BGB (German Civil Code). If you are accepting on behalf of a legal entity, you represent that you have the authority to bind that entity.

1.3 Conflicting or deviating general terms and conditions of the Customer do not apply, even if GMC does not expressly object to them and executes the contract with the Customer (§305b BGB).

1.4 GMC reserves the right to modify these Terms with 30 days' prior written notice (email to the address on file). Continued use of the Service after the effective date of modifications constitutes acceptance. Material changes to pricing, liability, or scope of service will be highlighted in the notification. The Customer has the right to terminate the contract within 30 days of notification if they do not agree to the modified Terms.

2. Contract Formation and Legal Classification (Vertragsschluss)

2.1 The contract is formed when the Customer completes the registration process and, for paid tiers, successfully completes payment via Stripe. GMC's presentation of subscription plans constitutes an invitation to treat (invitatio ad offerendum), not a binding offer. The Customer's order constitutes the offer, which GMC accepts by activating the account.

2.2 Legal Classification. In accordance with established case law of the Bundesgerichtshof (BGH, 15 November 2006 -- XII ZR 120/04), the provision of SaaS constitutes a lease agreement (Mietvertrag) under §535 et seq. BGB with respect to the ongoing provision of the software. Ancillary services (implementation, training, custom configuration) may constitute contracts for work (Werkvertrag, §631 BGB) or service contracts (Dienstvertrag, §611 BGB) as applicable.

2.3 As a lease agreement, GMC is obligated to maintain the Platform in a usable condition throughout the contract term and to remedy defects in accordance with §535(1) sentence 2 BGB. The Customer's statutory defect rights (Mängelrechte) under §536 et seq. BGB remain unaffected by these Terms.

2.4 The United Nations Convention on Contracts for the International Sale of Goods (CISG) is expressly excluded.

3. Definitions (Begriffsbestimmungen)

  • "Platform" means the GMC SaaS application, including all APIs, dashboards, modules (Buyer Personas, Geo-Intelligence, ROVI, Activate Segment, NODE), and related services.

  • "Subscription Plan" means the tier selected by the Customer (Playground Test, Spark, Signal, Beacon, Pulsar, or Quasar) combined with a Geographic Coverage option, as described in Section 6.

  • "Geographic Coverage" means the countries included in the Customer's plan (1 Country, 2 Countries, 3 Countries, Combo Centroamérica, Combo LATAM, Combo Europa, or Combo Global), as specified in the Leistungsbeschreibung (Service Description).

  • "Buyer Persona" means a synthetic audience profile generated using AI models, enriched with GlobalWebIndex (GWI) data, geo-intelligence matrices, and Deep Campaign Insights (DCI).

  • "Geo-Intelligence Data" means geospatial datasets, socioeconomic indices, heat maps, affinity scores, and POI data provided through the Platform.

  • "ROVI" (Robotic Video Insights) means the audiovisual content analysis module using AI-powered scene and sentiment analysis.

  • "NODE" means the retail analytics solution measuring pedestrian traffic via physical devices in commercial environments.

  • "Activate Segment" means the DSP targeting feature generating semantic exploration, activation IDs, and keywords for programmatic advertising.

  • "Leistungsbeschreibung" (Service Description) means the separate document describing the specific features, availability targets, support levels, and technical specifications of each Subscription Plan tier, incorporated by reference into these Terms.

  • "AVV" / "DPA" (Auftragsverarbeitungsvertrag / Data Processing Agreement) means the separate data processing agreement concluded between GMC and the Customer in accordance with Art. 28 GDPR, incorporated by reference into these Terms.

4. Account Registration and Security (Registrierung)

4.1 To access the Platform, you must create an account providing accurate and complete information, including a valid business email address and company name. For paid tiers, billing information is additionally required.

4.2 You are responsible for maintaining the confidentiality of your credentials and for all activities under your account. Unauthorized use must be reported to GMC immediately at security@garritz.com.

4.3 GMC reserves the right to suspend accounts that provide false information, violate these Terms, or engage in fraudulent activity, subject to reasonable notice and opportunity to cure where practicable.

4.4 Credentials are non-transferable. Admin users may create sub-accounts for team members within their organization according to their Subscription Plan limits.

5. Service Description (Leistungsbeschreibung)

5.1 GMC provides scientific audience targeting and analytics across 24 industry verticals. The detailed scope, features, and technical specifications of each tier are set forth in the Leistungsbeschreibung, which is provided as a separate document and forms an integral part of this agreement.

The Platform includes, but is not limited to, the following capabilities:

  • Buyer Persona generation using AI-powered synthetic ethnographic profiles, enriched with GWI data across 26 chart categories

  • Geo-Intelligence mapping with 0-1000 affinity ranges, household income layers, and POI tracking

  • ROVI audiovisual creative analysis with scene-by-scene sentiment and intensity evaluation

  • Activate Segment for DSP programmatic targeting with semantic exploration and activation IDs

  • Campaign management with KPI tracking (impressions, complete views, clicks, CPM, CPCV, CVR, CTR)

  • Chat interface for first-person conversations with generated Buyer Personas

  • NODE retail analytics for physical pedestrian traffic measurement

5.2 GMC integrates multiple AI providers (including OpenAI, Anthropic, Google, and Mistral). The specific models used may change as GMC optimizes for quality and performance. Material changes to AI capabilities will be communicated in advance.

5.3 Geographic data coverage includes countries across Latin America (GT, SV, NI, CR, PA, HN, DO, AR, MX, CL, EC, CO), Europe (ES, FR, UK, IT, DE, NL, PT, SE, BE, CH), and may be expanded. Coverage availability per tier is defined in the Leistungsbeschreibung.

6. Subscription Plans, Pricing, and Billing (Vergütung)

6.1 Subscription Tiers. The Platform offers six tiers:

  • Playground Test: Free sandbox for evaluation. 1 country, restricted functionality.

  • Spark: Free tier with limited resources. 1 country, basic exploration.

  • Signal: Entry-level paid tier for small teams.

  • Beacon: Mid-tier for growing teams requiring broader capabilities.

  • Pulsar: Advanced tier for professional marketing teams.

  • Quasar: Enterprise-grade for agencies and large organizations.

6.2 Monthly Base Pricing (USD). Pricing depends on the combination of tier and geographic coverage. All prices in USD, exclusive of taxes:


Geography Countries Signal Beacon Pulsar Quasar


1 Country (Base) 1 $49 $150 $350 $700

2 Countries 2 $54 $160 $370 $740

3 Countries 3 $59 $170 $390 $780

Combo 7 $70 $195.02 $434.98 $870.03 Centroamérica

Combo LATAM 12 $84.96 $225 $495 $990

Combo Europa 10 $79.68 $211.68 $475.02 $949.98

Combo Global 22 $112.83 $269.47 $600.67 $1,189.90

6.3 Geographic Combos:

  • Centroamérica (7): Guatemala, El Salvador, Nicaragua, Costa Rica, Panama, Honduras, Dominican Republic

  • LATAM (12): All Centroamérica plus Argentina, Mexico, Chile, Ecuador, Colombia

  • Europa (10): Spain, France, UK, Italy, Germany, Netherlands, Portugal, Sweden, Belgium, Switzerland

  • Global (22): All LATAM and Europa countries combined

6.4 Billing Frequency Discounts:


Billing Frequency Discount Payment Commitment Example Cycle (Signal 1-Co.)


Monthly 0% Every month None $49/mo

Quarterly 5% Every 3 3 months $47/mo months ($141)

Semi-Annual 10% Every 6 6 months $44/mo months ($264)

Annual 15% Yearly 12 months $42/mo ($504)

6.5 Credit Packages. Additional resources are available as one-time credit packs (POI Credits, Buyer Persona Credits, Creative Credits, Video & Creative Reaction Credits, and Survey Execution Credits). Pricing varies by tier and volume. Credit packages are non-refundable, valid for 12 months, non-transferable, and processed via Stripe. Full pricing is specified in the Leistungsbeschreibung, Section 2.6.

6.6 Free Tier Geographic Add-ons. Playground Test and Spark tiers include 1 country by default. Additional geographic coverage is available as a paid add-on. Pricing is specified in the Leistungsbeschreibung, Section 2.5.2.

6.9 All prices are exclusive of applicable taxes (VAT/Umsatzsteuer, IVA, sales tax, GST). VAT will be charged at the applicable rate based on the Customer's billing address and tax status. Business customers within the EU providing a valid VAT ID may be eligible for reverse-charge treatment.

6.10 All payments are processed through Stripe, Inc. By providing payment information, you authorize GMC to charge your payment method on a recurring basis per your billing frequency.

6.9 Failed payments: GMC will notify the Customer and provide a 14-day grace period. After 14 days without resolution, the account will be suspended. After 30 days of non-payment, GMC may terminate the contract with immediate effect for good cause (wichtiger Grund).

6.10 Price changes: GMC may adjust pricing with 6 weeks' prior written notice (§315 BGB). If the price increase exceeds 5% of the current rate, the Customer has the right to terminate the contract with effect from the date the new pricing takes effect.

7. Right of Withdrawal for Consumers (Widerrufsbelehrung)

7.1 This section applies exclusively to Customers who qualify as consumers (Verbraucher) within the meaning of §13 BGB --- i.e., natural persons acting for purposes outside their trade, business, craft, or profession. Business customers (Unternehmer, §14 BGB) are excluded from this right of withdrawal.

Widerrufsbelehrung (Cancellation Policy)

Right of withdrawal: You have the right to withdraw from this contract within 14 days without giving any reason. The withdrawal period will expire 14 days from the day of the conclusion of the contract. To exercise the right of withdrawal, you must inform us (Garritz Online Media International GmbH, legal@garritz.com) of your decision by an unequivocal statement (e.g., a letter sent by post or email). You may use the model withdrawal form below, but it is not obligatory.

Effects of withdrawal: If you withdraw from this contract, we shall reimburse all payments received from you without undue delay and in any event not later than 14 days from the day on which we are informed of your decision to withdraw. We will carry out such reimbursement using the same means of payment as you used for the initial transaction, unless you have expressly agreed otherwise.

7.2 Early performance and waiver: If you request that the performance of services begins during the withdrawal period (i.e., immediate access to the Platform upon registration), you acknowledge that you will lose your right of withdrawal once the service has been fully performed. If the service is only partially performed at the time of withdrawal, you shall pay an amount proportional to what has been provided up to the point of withdrawal (§357(8) BGB).

7.3 Model withdrawal form: To: Garritz Online Media International GmbH, legal@garritz.com --- I hereby give notice that I withdraw from my contract for the provision of the following service: [Subscription Plan / date of order / date of receipt] --- Name of consumer --- Address of consumer --- Signature (only if sent by post) --- Date.

8. Contract Term and Termination (Vertragslaufzeit und Kündigung)

8.1 Minimum Term. Monthly plans have no minimum commitment. Quarterly, semi-annual, and annual plans have a minimum term corresponding to the selected billing cycle.

8.2 Ordinary Termination (Ordentliche Kündigung). Either party may terminate the contract at the end of the current billing period with the following notice:

  • Monthly plans: 1 month notice before the end of the billing period

  • Quarterly plans: 1 month notice before the end of the quarter

  • Semi-annual plans: 3 months notice before the end of the 6-month period

  • Annual plans: 3 months notice before the end of the annual period

8.3 Auto-Renewal. After the initial minimum term, subscriptions renew automatically on a month-to-month basis. In accordance with §309 Nr. 9 BGB, the Customer may terminate the renewed contract at any time with no more than 1 month's notice. GMC will send a reminder of upcoming renewal at least 4 weeks before the renewal date.

8.4 Extraordinary Termination (Außerordentliche Kündigung). Either party may terminate the contract without notice for good cause (wichtiger Grund) under §543 BGB (applicable to lease agreements). Good cause includes, but is not limited to:

  • Material breach of these Terms that remains uncured for 14 days after written notice

  • Insolvency proceedings initiated against either party

  • Persistent non-payment (more than 30 days overdue)

  • Repeated or severe violations of the Acceptable Use Policy (Section 11)

  • Platform unavailability materially exceeding the SLA targets for 3 consecutive months

8.5 Data Export and Transition (Exit-Management). Upon termination for any reason, the Customer may export their data (campaign configurations, persona settings, reports) for 30 days following the effective termination date. GMC will provide reasonable cooperation for data migration. After 30 days, GMC will delete Customer data in accordance with Art. 17 GDPR and the AVV.

8.6 Downgrading from a paid tier to Playground Test or Spark will result in loss of access to features and geographic coverage beyond free-tier limits at the end of the current billing period.

8.7 Cancellation method. Termination may be submitted via the Platform dashboard, by email to support@garritz.com, or in writing. GMC will confirm receipt of termination within 3 business days.

9. Data Protection (Datenschutz)

9.1 GDPR and BDSG Compliance. GMC processes personal data in accordance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG), and the German Telecommunications and Telemedia Data Protection Act (Telekommunikation-Telemedien-Datenschutz-Gesetz, TTDSG).

9.2 Data Processing Agreement (Auftragsverarbeitungsvertrag). Where GMC processes personal data on behalf of the Customer, the parties shall conclude a Data Processing Agreement (AVV) in accordance with Art. 28 GDPR prior to the commencement of data processing. The AVV is a separate, mandatory document that forms an integral part of this agreement. It cannot be waived. Registration cannot be completed without acceptance of the AVV.

9.3 The AVV specifies: (a) the subject matter and duration of processing; (b) the nature and purpose of processing; (c) the type of personal data and categories of data subjects; (d) the obligations and rights of the Controller (Customer); (e) technical and organizational measures (TOMs) pursuant to Art. 32 GDPR and §64 BDSG; (f) sub-processor management and approval procedures; (g) data breach notification procedures (Art. 33 GDPR); and (h) audit rights of the Customer.

9.4 Geo-Intelligence data, mobility patterns, and audience analytics are derived from aggregated and anonymized sources. GMC does not process PII of end consumers targeted through the Platform.

9.5 Campaign data, creative assets, and persona configurations uploaded by the Customer remain the property of the Customer. GMC processes such data exclusively for the purpose of delivering the Service.

9.6 GWI data is licensed by GMC and subject to GWI's terms. Users may not extract, redistribute, or resell raw GWI data.

9.7 NODE devices collect aggregate pedestrian traffic counts only. No biometric data, facial recognition, or individual tracking is performed.

9.8 Cookies and Tracking (TTDSG §25). The Platform uses only technically necessary cookies without consent. Analytics, tracking, or non-essential cookies require prior informed consent via a compliant consent management platform. The Platform will not set non-essential cookies or tracking technologies without explicit opt-in.

9.9 Data Protection Officer. Where required under Art. 37 GDPR or §38 BDSG, GMC will appoint a Data Protection Officer and provide their contact details to Customers upon request and in the Privacy Policy.

10. Intellectual Property (Geistiges Eigentum)

10.1 The Platform, including all software, algorithms, AI models, interfaces, APIs, and documentation, are protected by copyright (Urheberrecht) under the German Copyright Act (UrhG) and international intellectual property laws. The Customer receives a non-exclusive, non-transferable, time-limited right of use for the duration of the contract (§69d UrhG).

10.2 The Customer's rights under §69d(2) and (3) UrhG and §69e UrhG (decompilation for interoperability) remain unaffected.

10.3 Users retain ownership of their campaign data, creative assets, and custom configurations. GMC is granted a limited license to process such data solely for Service delivery.

10.4 Platform outputs (Buyer Personas, Geo-Intelligence reports, ROVI analyses, segment activations) are licensed for the Customer's internal marketing use. Resale or redistribution to third parties requires prior written consent.

10.5 GMC warrants that the general operation of the Platform does not infringe third-party intellectual property rights. In the event of a third-party infringement claim, GMC shall defend the Customer at its own expense and indemnify the Customer for resulting damages, provided the Customer notifies GMC promptly and grants GMC control of the defense.

11. Acceptable Use Policy (Nutzungsrichtlinien)

The Customer agrees not to:

  • Engage in unlawful activity or violate applicable laws

  • Reverse-engineer, decompile, or extract source code beyond the rights granted under §69e UrhG

  • Use automated tools to access the Platform outside of documented APIs

  • Circumvent usage limits, geographic restrictions, or access controls

  • Upload malicious content, malware, or IP-infringing material

  • Use Geo-Intelligence or Buyer Personas for discriminatory targeting based on protected characteristics under Art. 3 GG (German Basic Law) and AGG (General Equal Treatment Act)

  • Resell, sublicense, or redistribute Platform access or outputs

  • Use NODE data to identify, track, or surveil individuals

  • Access countries outside of the selected Geographic Coverage

12. Warranty and Defects (Gewährleistung und Mängelhaftung)

12.1 As a lease-type agreement (Mietvertrag), GMC's warranty obligations are governed by §536 et seq. BGB. GMC shall provide the Platform substantially free of material defects (Sachmängel) and legal defects (Rechtsmängel) as defined in §536 BGB.

12.2 The Customer shall report defects to GMC without undue delay (unverzüglich) upon discovery, providing a detailed description of the issue. GMC shall use commercially reasonable efforts to remedy reported defects within the timeframes specified in the Leistungsbeschreibung / SLA.

12.3 In the event of a material defect that substantially impairs the usability of the Platform, the Customer may reduce the subscription fee proportionally (Mietminderung, §536 BGB). The right to fee reduction arises automatically upon the occurrence of the defect and does not require prior notice.

12.4 Service credits provided under the SLA (Leistungsbeschreibung) are offered as additional compensation and do not exclude or replace the Customer's statutory defect rights under §536 et seq. BGB. The Customer's statutory rights to fee reduction, damages, and extraordinary termination remain fully intact.

12.5 AI Outputs Disclaimer. Buyer Personas, audience insights, and ROVI analyses are generated using AI and statistical models. While GMC strives for accuracy, AI-generated outputs are probabilistic in nature and may contain inaccuracies. GMC does not warrant that outputs will achieve specific commercial results. The Customer is responsible for validating outputs before making business decisions. This disclaimer does not limit GMC's liability under Section 13.

13. Liability (Haftung)

13.1 Unlimited Liability. GMC is liable without limitation for:

  • Damages resulting from injury to life, body, or health caused by negligent or intentional breach of duty by GMC, its legal representatives, or vicarious agents (§§276, 278 BGB)

  • Damages caused by willful misconduct (Vorsatz) or gross negligence (grobe Fahrlässigkeit) by GMC, its legal representatives, or vicarious agents

  • Liability under mandatory statutory provisions, including the German Product Liability Act (Produkthaftungsgesetz)

  • Damages arising from fraudulent concealment of defects (§536d BGB in conjunction with §523 BGB)

13.2 Cardinal Obligations (Kardinalpflichten). In cases of simple negligence (einfache Fahrlässigkeit) breaching an essential contractual obligation (wesentliche Vertragspflicht / Kardinalpflicht) --- i.e., an obligation whose fulfillment is essential to the proper performance of the contract and on whose compliance the Customer regularly relies --- GMC's liability is limited to the foreseeable, typically occurring damage (vertragstypisch vorhersehbarer Schaden). Essential contractual obligations include, in particular, the obligation to provide and maintain the Platform in usable condition, to protect Customer data from unauthorized access, and to process personal data in accordance with the AVV.

13.3 Liability Cap for Cardinal Obligations. The liability for foreseeable, typically occurring damage under Section 13.2 is capped at the greater of: (a) the total fees paid by the Customer in the 12 months preceding the damaging event; or (b) EUR 50,000 per damaging event.

13.4 Exclusion of Liability. Subject to Sections 13.1 and 13.2, GMC shall not be liable for indirect, incidental, or consequential damages (mittelbarer Schaden), including but not limited to lost profits, lost data (to the extent not caused by a breach of data protection obligations), or business interruption, caused by simple negligence in the breach of non-essential obligations.

13.5 The above limitations and exclusions also apply in favor of GMC's employees, legal representatives, and vicarious agents.

13.6 Contributory Negligence. The Customer's obligation to mitigate damages (§254 BGB) remains unaffected. This includes, in particular, the obligation to maintain regular backups of data and to promptly report defects.

14. Service Level Agreement (Verfügbarkeit)

14.1 The detailed Service Level Agreement is set forth in the Leistungsbeschreibung. GMC targets 99.5% monthly uptime, excluding scheduled maintenance (communicated 48 hours in advance via the Platform dashboard and email).

14.2 Service credits for downtime exceeding SLA targets are defined in the Leistungsbeschreibung. As stated in Section 12.4, service credits are additional to, and do not replace, statutory rights.

14.3 GMC is not responsible for unavailability caused by third-party services (Stripe, AI providers, DSP platforms, GWI), force majeure events (Section 16.4), or Customer-side issues.

15. Governing Law and Dispute Resolution (Anwendbares Recht)

15.1 These Terms are governed exclusively by the laws of the Federal Republic of Germany, excluding the UN Convention on Contracts for the International Sale of Goods (CISG) and excluding German conflict-of-laws provisions (except where mandatory under EU regulations such as Rome I).

15.2 For business customers (Unternehmer), the exclusive place of jurisdiction (Gerichtsstand) for all disputes arising from or in connection with these Terms is Madrid, Spain, unless mandatory provisions of German law require a different jurisdiction.

15.3 For consumers (Verbraucher), the statutory provisions on jurisdiction apply. In particular, consumers may bring claims in the courts of their habitual residence (Art. 18 Brussels Ia Regulation / §§38, 29c ZPO).

15.4 The European Commission provides an Online Dispute Resolution (ODR) platform at https://ec.europa.eu/consumers/odr. GMC is not obligated to participate in dispute resolution proceedings before a consumer arbitration board (Verbraucherschlichtungsstelle) but will consider such participation on a case-by-case basis.

16. General Provisions (Schlussbestimmungen)

16.1 Severability (Salvatorische Klausel). If any provision of these Terms is found to be invalid or unenforceable, it shall be replaced by the applicable statutory provision (§306(2) BGB). The validity of the remaining provisions shall not be affected (§306(1) BGB). If strict adherence to the remaining provisions would constitute an unreasonable hardship, the contract shall be deemed void in its entirety (§306(3) BGB).

16.2 Entire Agreement. These Terms, together with the Leistungsbeschreibung (Service Description / SLA), the Auftragsverarbeitungsvertrag (AVV/DPA), any Order Forms, and the Privacy Policy, constitute the entire agreement between the parties. Side agreements must be in text form (Textform, §126b BGB).

16.3 Assignment. The Customer may not assign rights or obligations under these Terms without GMC's prior written consent. GMC may assign these Terms in connection with a merger, acquisition, or sale of substantially all assets, provided the assignee assumes all obligations.

16.4 Force Majeure (Höhere Gewalt). Neither party shall be liable for failure to perform due to circumstances beyond reasonable control, including natural disasters, government actions, pandemics, war, cyberattacks, or infrastructure failures, provided the affected party notifies the other party without undue delay and uses reasonable efforts to mitigate the effects.

16.5 Notices. Notices to GMC: legal@garritz.com. Notices to the Customer: the email address on file. Notices regarding termination, material changes, or legal claims must be in text form (Textform, §126b BGB). Email satisfies the text form requirement.

16.6 Language. These Terms are drafted in English. In the event of a conflict between English and any translated version, the English version shall prevail for business customers. For consumers, the version in their national language shall prevail where required by applicable consumer protection law.

By creating an account on the Garritz Marketing Cloud platform, you acknowledge that you have read, understood, and agree to be bound by these Terms and Conditions, the Leistungsbeschreibung, and the Auftragsverarbeitungsvertrag (AVV).

GARRITZ ONLINE MEDIA INTERNATIONAL GmbH

Operating the Garritz Marketing Cloud Platform

www.garritz.com | legal@garritz.com

Last updated: February 14, 2026 | Version 2.1

Annex: Related Documents

The following documents form an integral part of the contractual relationship and are incorporated by reference:

Document 1: Leistungsbeschreibung (Service Description / SLA)

Defines: tier-specific features, availability targets (99.5% uptime), scheduled maintenance windows, support response times by tier, service credit calculation, and technical specifications. Provided as a separate document.

Document 2: Auftragsverarbeitungsvertrag (AVV / Data Processing Agreement)

Defines: subject matter and duration of processing, nature and purpose, types of personal data, categories of data subjects, technical and organizational measures (TOMs), sub-processor list and approval, data breach notification, audit rights, data return/deletion. Required under Art. 28 GDPR. Concluded during registration.

Document 3: Privacy Policy (Datenschutzerklärung)

Defines: data collection practices, legal bases for processing (Art. 6 GDPR), data subject rights (Art. 15-22 GDPR), cookie usage, third-party integrations, data retention periods, DPO contact. Published at www.garritz.com/privacy.

Document 4: Acceptable Use Policy (detailed)

Extended version of Section 11 with specific examples, enforcement procedures, and escalation framework. Available in the Platform help center.

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