BRUQI platform

TERMS of service

Valid from: 8 April 2025

Last updated: 8 April 2025

1. GENERAL terms
   
   1. These Bruqi Platform Terms of Service (hereinafter the "Terms") are entered into between you as a private individual or legal entity you represent ("User" or "you") and Bruqi OÜ (a limited liability company registered in the Republic of Estonia with registry code 16686991 and registered address at Tornimäe tn 3, 10122 Tallinn, Estonia, contact e-mail: [email protected]) ("Bruqi", "we", “us” or “our”). These Terms govern the use of the services offered via Bruqi’s platform, which is accessible at www.bruqi.com (“Platform”).
   2. These Terms apply to your access and use of our Platform and accompanying Services (as defined under Section 2 below) provided by Bruqi. In addition to these Terms, your use of our Platform and the Services is also governed by Privacy Policy for Bruqi, which describes, among others, how Bruqi processes personal data in the role of a data controller.
   3. To access and use the Services provided via the Platform, you are required to register a user account in accordance with Section 3 below ("Bruqi Account"). By creating a Bruqi Account and otherwise using our Platform and the Services, you hereby expressly confirm that:
      
      1. You are at least 18 years old or have the permission of your parent or legal guardian to access and use our Platform and the Services;
      2. You have full legal power and capacity to enter into a legally binding agreement with us by accepting these Terms, and are authorised to do so either as a private individual or representative of a legal entity by operating on behalf of a legal entity;
      3. Neither you nor the relevant legal entity you represent are/is prohibited from accepting these Terms and using our Platform and the Services under the laws governing these Terms or which are otherwise applicable to you or the legal entity you represent; and
      4. You undertake to use our Platform and the Services strictly in accordance with these Terms and the laws governing these Terms or which are otherwise applicable to you or the legal entity you represent.
   4. We reserve the sole right to unilaterally modify these Terms, at any time, in case there is a justified basis for introducing any such modifications. Such amendments may be introduced due to, including, but not limited to, changes in applicable laws, our legitimate business interests, or the necessity to introduce improvements to existing features and functionalities regarding our Platform. Any changes to these Terms shall be posted on the Platform. In addition, we shall separately notify you of any material changes to these Terms by sending you a notice via your Bruqi Account or through any other means of contact (e.g., e-mail) that you have provided to us.
2. Provision and use of the services
   
   1. Bruqi provides AI-powered content removal and takedown services to protect content creators’ online presence and their copyrighted or otherwise protected content or materials from any unauthorised use ("Services"). The available Services include, in particular, Bruqi performing the scanning and monitoring of public websites and databases for potentially unauthorised use cases, and thereafter submitting, on behalf of the Users (or other individuals specified by the Users) automated requests both for delisting the search engine results, as well as for content removals, including the removal of deepfakes, as well as impersonated accounts. Upon the User’s instructions, such requests are submitted to selected third parties, including, but not limited to, search engines, social media platforms, and other source websites. The Services can be used either to protect your own rights as an individual content creator (“Creator”) or to protect the rights of third parties by representing such individuals as their manager or agent (“Manager”). The exact scope of available Services and accompanying features depends on the nature of the registered Bruqi Account (in accordance with Section 3.1 below), as well as the relevant selected protection plan with accompanying features, as listed via the Platform.
   2. To be able to access and use the Services, you will be required to log into your Bruqi Account. Using certain Services may require you to take additional steps as may be required by Bruqi. These may include, among others, verifying the User's identity, demonstrating legal rights and authorisations to using the relevant copyrighted or otherwise protected content or materials associated with the Services, as well as adding individuals to be represented in case of operating as a Manager.
   3. You hereby expressly acknowledge and agree that Bruqi does not warrant or guarantee the successful removal, suppression, or alteration of any copyrighted or otherwise protected content or materials (including search engine results) as a result of providing the Services. You further agree that the Services provided do not constitute any legal advice related to, including, but not limited to, unauthorised intellectual property uses. While Bruqi undertakes to act in good faith and take all reasonable efforts to ensure the satisfactory provision of the Services, the efficacy of the Services is contingent upon various factors which are not under the control of Bruqi. These pertain to, among others, the relevant third parties’ (including, but not limited to, search engines, social media platforms, other source websites) compliance with any requests submitted by Bruqi, the technologies employed by such third parties, applicable legal requirements, and User Content (as defined under Section 5.3(a) below) as input provided by the User to identify potential unauthorised use cases of copyrighted or otherwise protected materials. You further agree that that certain Services may use and incorporate artificial intelligence components, which may result in errors, inaccuracies or biases in the course of Bruqi providing the Services. You further expressly acknowledge and agree that you are not entitled to any refunds if removal, suppression, or alteration of any copyrighted or otherwise protected content or materials (including search engine results) is not successful as a result of providing the Services.
   4. Bruqi reserves the right to change the Services offered and their features, including for development purposes, adjustment to new technical environments, or other important reasons relating to substantive changes. Bruqi also has the right to update Services and their features in order to ensure compliance of the Services with these Terms and/or relevant laws and regulations, including for ensuring the secure use of the Services. Information on changes and updates relating to the Services shall be communicated to you via the Platform.
3. Bruqi account
   
   1. Bruqi Account can be registered either for operating as a Creator or a Manager. For registration, certain registration data must be provided, including your name (or name of the Manager’s organisation), e-mail address, and selecting a password which can be used to access and use the Services. Bruqi Account can be also registered using third party identification tools. After registration, the Users will be then able to sign in to our Plaform by using their Bruqi Account.
   2. By submitting data during the registration process, you warrant that:
      
      1. The registration data is correct, accurate, up-to-date and complete; and
      2. If required, you will update the relevant registration data to ensure its correctness, accuracy and completeness at all times.
   3. Your Bruqi Account is strictly personal (upon operating as a Creator) or intended only for authorised use by designated individuals (upon operating as a Manager). You agree that you are not entitled to permit any unauthorised third party to access our Platform or use the Services via the registered Bruqi Account. You are also responsible for maintaining the confidentiality of your registration data and for any actions that are performed whenever logged in.
   4. You may terminate your Bruqi Account and cease using the Services at any time. Termination shall not entitle the User to any refunds for the Services already provided or fees for Subscription(s) already paid (unless otherwise required by applicable law).
   5. Bruqi reserves the right to deactivate the registered Bruqi Account you manage and suspend your access to our Platform, without prior notice and any compensation or reimbursement, if you fail to comply with any of the obligations or restrictions arising from these Terms, in particular, if you violate the terms of Section 5 below. Failure to comply with these Terms constitutes an infringement that may also result in civil and criminal liability.
4. Subscription FEE and payment Terms
   
   1. The use of certain protection plans offered within the Services may require, in accordance with the pricing plan made available via the Platform, the purchasing of a relevant paid subscription (“Subscription”) for the selected recurring billing period, for, e.g., monthly or annual period (“Subscription Term”). In case a trial period is offered, the fees for the Subscription shall be payable upon expiry of the relevant trial period, unless you notify us of your decision to terminate the registered Bruqi Account before the expiry of the trial period.
   2. The information provided at the time of purchasing the Subscription includes additional information on all applicable payment terms and conditions, instructions for payment of the fees, if applicable. Bruqi may use third-party payment service providers to process all payments for the Subscriptions. Bruqi shall not be responsible for the processing of payments and shall not be liable for any matters relating to the processing of payments. Upon completion of purchasing the Subscription, Bruqi shall send you, via our Platform, an electronic confirmation of the Subscription to use a certain protection plan. Note that the obligation to pay the fees for the Subscription does not depend on whether you will actually use the purchased protection plans.
   3. By purchasing the Subscription for the selected Subscription Term, you agree that the right to use certain protection plans under the Subscription shall automatically renew for the initially selected billing period at the beginning of the each subsequent billing period. In such a case, we shall charge you for the renewal of the corresponding Subscription on the billing date of each billing period in which you originally purchased it.
   4. By using our Platform as a consumer and thereby purchasing or upon automatic renewal of the Subscription, you hereby accept and agree that we start providing you the protection plans from that moment on (as a digital information society service) and, therefore, you lose your right of statutory withdrawal otherwise available for consumers.
   5. The Subscription is automatically renewed until you have cancelled or otherwise terminated the Subscription or your Bruqi Account. Termination of the Subscription shall take effect on the billing date of the next billing period in which you originally purchased the Subscription, after which you will no longer be able to use the respective paid protection plan.
   6. Bruqi reserves the right to increase the applicable fees for the Subscriptions, at any time, by providing you a notice via your Bruqi Account and through any other means of contact (e.g., e-mail) that you have provided to us. For a monthly Subscription, you shall be informed at least 28 calendar days prior to the end of then-current Subscription Term, whereas for a yearly Subscription, the relevant period shall be 45 calendar days. Such fee increases shall take effect at the beginning of the subsequent billing period unless you object to it. Objection to fee increase must be communicated to Bruqi before the modified fees take effect (i.e., on the billing date of the next billing period). In case of objecting, the termination of the Subscription takes effect in accordance with the principles specified in Section 4.5 above.
5. Conditions for use
   
   1. By using the Services, you hereby confirm that you grant us all necessary rights, and ensure that those individuals you represent (upon operating as a Manager) grant such rights to Bruqi to enable us to lawfully provide the Services in accordance with these Terms. This includes, in particular, the granting of required authorisations, to the extent required by applicable law, to represent you (or other designated individuals) before third parties by submitting removal and delisting requests, as well as other claims and applications, with Bruqi operating as a relevant authorised representative. Further, it may also involve taking any other necessary actions and operations to provide the Services, including for conducting public scanning and monitoring by processing and reproducing any data associated with you or any other designated individual.
   2. The Users undertake to exercise due diligence in reviewing and validating the accuracy of results related to the removal, suppression, or alteration of any copyrighted or otherwise protected content or materials (including search engine results) in the course of providing the Services. This includes the obligation to immediately notify Bruqi in case of suspicion that the Services may infringe (or may have infringed) the rights of third parties (e.g., by way of wrongful removal).
   3. By using our Platform and the Services, you hereby acknowledge and agree that:
      
      1. You are solely responsible for any content you submit or upload in connection with or for the purposes of using the Services (“User Content”), including by warranting that any User Content submitted or uploaded is accurate, complete, correct and up-to-date;
      2. You warrant that neither using the Services nor submission or uploading the User Content does not infringe on any right (nor any right of third party) or applicable law, including, but not limited to, data privacy and intellectual property rights;
      3. Upon operating as a Manager, you warrant that you must not impersonate designated individuals, misrepresent affiliations or provide information on their behalf without appropriate and valid authorisation;
      4. You ascertain valid legal bases and other authorisations required for the provision of the Services and for submitting, uploading and otherwise processing of the User Content, including regarding any personal data of designated individuals whom you may represent upon operating as a Manager;
      5. You are prohibited from abusing our Platform or the Services in general, using them for commercial purposes beyond their intended use (in accordance with these Terms), in violation of these Terms or in bad faith, or in any inappropriate, defamatory, malicious, fraudulent or otherwise unlawful manner, that could harm Bruqi or its other customers, including through excessive use of the Services;
      6. You are prohibited from transmitting or otherwise uploading any material or content (including User Content) through the Services or our Platform that contains viruses or other malicious code.
6. operation and management of our platform 
   
   1. Our Platform and the Services are provided on an "as is" and "as available" basis without warranties of any kind. We expressly disclaim any and all warranties regarding our Platform and the Services, whether express, implied, or statutory, including, but not limited, to warranties of accuracy, reliability, performance, merchantability, fitness for a particular purpose. In particular, the availability and quality of our Platform and the Services may be excluded or disrupted due to force majeure and regular or extraordinary interruptions caused by maintenance needs, as well as limited access to public platforms (search engines, social media platforms, other source websites) that we use to provide the Services. Notwithstanding Bruqi’s endeavours to provide the highest-quality, safest and secure Platform and Services, Bruqi does not guarantee that our Platform and the Services shall be uninterrupted, timely or error-free or that defects will be remedied. 
   2. We reserve the right, at any time and at our discretion, to partially or entirely suspend or block access to all or parts of our Platform, especially for maintenance work, updates, changes to the range of services (including the Services) on our Platform, in the event of an attack on our Platform, or in the event of termination of operations.
   3. Our Platform may contain hyperlinks to third-party websites, however Bruqi is not responsible for such third-party websites or their content. Our Platform and third-party websites are not related, and the User is responsible for the use and compliance with the terms of use of such linked third-party websites.
   4. You also agree that you use on our Platform at your own risk and we hereby disclaim all liability to you or any third party relating thereto. This means that Bruqi is not responsible for malware that may infect your computer, mobile device, or other hardware or software when using our Platform, nor for data loss or corruption associated with the use of our Platform. You are responsible for taking all necessary measures to protect your data, computer systems, and software from viruses, trojan horses, and all other computer programs that may spread through the digital platform.
7. intellectual property rights
   
   1. Our Platform, including the trademarks, logos, other distinctive signs, software, and any other associated content, i.e., all texts, videos, photos, and other information of any form and type published by Bruqi ("Intellectual Property") belongs to Bruqi or third parties who have authorised its use, except for the User Content (as defined under Section 5.3(a) above). The use of the Intellectual Property or any other information published on our Platform for commercial purposes (beyond their intended use) or advertising is strictly prohibited. Any third-party trademarks, logos, or content displayed or referenced on our Platform are used solely for descriptive or instructional purposes and do not imply any legal affiliation, sponsorship, or endorsement.
   2. Copying, using for other purposes, selling, distributing, modifying, adapting, translating, reproducing the information and creating derivative works of such information in any form or media (including the Intellectual Property) or parts thereof published on our Platform without the prior express permission of Bruqi is expressly prohibited. Violation of these prohibitions, including those listed below, may result in civil and criminal liability.
   3. In addition to the prohibitions under Section 7.2 above, you are further prohibited from:
      
      1. Accessing, without authorisation, the system of our Platform, including by discovering the source code or the underlying data, models, or algorithms, as well as aiding third parties in the above-listed activities or performing any such or related acts in order to build a product or service which competes with Bruqi, except to the extent permitted by applicable law;
      2. Disabling, bypassing, or interfering with security features, without authorisation, or attempting to de-compile, reverse-compile, disassemble, reverse-engineer or otherwise reduce to human-perceivable form all or any part of our Platform; and
      3. Using automated tools (bots, scrapers) to access or collect data from our Platform.
   4. In addition to the use of the User Content by Bruqi in accordance with Section 8 below, the User may separately agree (by giving consent or any other explicit testimonial) to provide Bruqi a right to carry out marketing and promotional activities using the User’s objects of the Intellectual Property. In case of such separate agreement, the User grants Bruqi a worldwide, irrevocable, non-exclusive, sublicensable, and royalty-free right to use, store, copy, display the User’s name, any logos, brands, trademarks and other similar objects of the Intellectual Property uploaded to our Platform or otherwise provided to Bruqi by the User, for relevant use on our Platform and other platforms (including social media platforms, websites, other marketing materials and mediums) for the duration of these Terms. This includes, but is not limited to, general marketing and promotional activities as approved by the User, which Bruqi may carry out only in accordance with industry-accepted standards. 
8. rights to and usage of user content
   
   1. The User retains ownership of all the User Content submitted and uploaded to the Platform in the course of using the Services. In order to provide the Services, the User hereby grants, and warrants that any designated individuals (upon operating as a Manager) grant to Bruqi a geographically unlimited, irrevocable, non-exclusive, sub-licensable, transferable and royalty-free right to use, store, copy (and reproduce), modify (and create derivative works), display and distribute the User Content as necessary to provide the Services under these Terms. Bruqi may also retain and disclose the User Content if required to do so by applicable law, or if Bruqi believes in good faith that retention or disclosure of the User Content is necessary to enforce these Terms or to establish, exercise and defend legal claims.
   2. The User acknowledges that a fundamental component of the Services is the training and use of machine learning or other processes, and generating performance metrics for providing and improving the services provided by Bruqi (including the Services). The User agrees that Bruqi may use the User Content for the purpose of training, refining and improving artificial intelligence models that are used by Bruqi. If you provide us with feedback on the provision of the Services or generally regarding our Platform, we may also use it to improve our systems. All such usage of the User Content shall be subject to strict confidentiality measures and, where applicable or technically feasible, anonymisation or aggregation to prevent identification of the User (or any designated individuals). Bruqi shall ensure compliance with all relevant applicable laws and shall neither sell or disclose the User Content to unauthorised third parties without the User’s prior written consent. Bruqi may also collect other information related to the Users (in addition to the User Content) for similar purposes, which may include aggregated, anonymised or analytical information and statistics on the User’s use of the Services (“Usage Metrics”). Bruqi retains ownership of all such Usage Metrics.
9. Personal data processing 
   
   1. The processing of personal data by Bruqi operating in the role of a data controller for the purposes of providing the Services in accordance with these Terms shall be governed by the Privacy Policy for Bruqi. The User undertakes to make available the said Privacy Policy (relevant where Bruqi determines the means and purposes of data processing) to relevant designated individuals, whose personal data (within the User Content) the User may submit and upload to the Platform.
   2. In the event that Bruqi processes the User’s personal data (within the User Content) on behalf of and in accordance with the instructions of the User (in particular, upon operating as a Manager) by providing the Services, the User (or any end-user of the User) shall be the data controller and Bruqi shall be the data processor. In such a case, the processing of the User’s personal data, performed on behalf of the User, shall be subject to Annex 1 to these Terms (“Data Processing Agreement”).
10. limitation of liability and indemnification
    
    1. We are not responsible for any consequences, including, but not limited, to erroneous removal or delisting requests, or the inability to successfully, by way of providing the Services, remove or delist content from third-party search engines, social media platforms, other source websites. Nor we are responsible for information or its accuracy which we have received from third parties and which we may display or otherwise use in providing the Services. To the maximum extent permitted by applicable law, Bruqi is not liable for any indirect or indirect damage (including loss of profits) related to the use of or inability to use our Platform and the Services, loss of any data or other intangible losses, and more generally, for any breach of these Terms, such as, in particular, technical failures, breakdowns, interruptions, modifications to our Platform and the Services. Bruqi shall be solely liable for damages caused by gross negligence and intentional misconduct.
    2. To the maximum extent permitted by applicable law, Bruqi’s liability is limited to the aggregate amount of the fees paid by you for the Subscriptions during the period of 3 months before the event giving rise to Bruqi’s liability took place. Where no fees have been paid for the Subscriptions, Bruqi’s liability is limited to EUR 250 (two hundred fifty euros) or the actual damages, whichever is less.
    3. You agree to indemnify and hold Bruqi and its affiliates harmless from and against any and all damages, losses, claims, fines, settlements, penalties, costs and expenses of any kind (including reasonable attorney fees and costs) arising out of or related to any misuse of the Services, any breach of these Terms, violation of any applicable law, or any rights of third parties (including data privacy or intellectual property rights).
    4. Nothing in these Terms shall limit or exclude the liability of Bruqi for any liability that cannot be excluded under applicable law.
11. miscellaneous
    
    1. Neither party to these Terms may assign or delegate any rights or obligations under these Terms without the other party’s prior written consent, provided, however that any of the rights or obligations contained herein may be assigned without the User’s consent by Bruqi to any other entity who directly or indirectly, controls, is controlled by or is under common control with Bruqi.
    2. Neither party to these Terms shall be liable for any failure or delay in performing their obligations under these Terms due to circumstances beyond their reasonable control, including but not limited to natural disasters, acts of government, war, cyberattacks, labour disputes, or interruptions in telecommunications or utility services.
    3. Bruqi’s failure to enforce any provision of these Terms or exercise any right on one occasion shall not be deemed a waiver of its right to enforce such provision or exercise such right on future occasions.
    4. If any provision of these Terms is found to be invalid, illegal, or unenforceable, such provision shall be deemed severed from these Terms, and the remaining provisions shall continue in full force and effect.
    5. These Terms shall be governed by and construed in accordance with the laws of the Republic of Estonia. Any disputes arising from or related to these Terms shall be subject to the exclusive jurisdiction of the courts of the Republic of Estonia, whereas the court of first instance shall be the Harju County Court (Tallinn, Estonia). If you are a consumer, you can bring claims against us in the courts of the Member State of the European Union where you are domiciled.

If you are a consumer, you also have the right to lodge a complaint to the Consumer Disputes Committee, information of which is accessible here. If you, as a consumer, are residing in another Member State of the European Union, you may lodge a complaint on the European Commission’s online dispute resolution platform accessible here. Note that in addition to consumer-specific legal remedies, you can always exercise all other applicable statutory remedies.

Annex 1 to Bruqi Platform Terms of Service: Data Processing Agreement

1. general provisions

6. This Data Processing Agreement forms an integral part of the Terms agreed between Bruqi and the User in relation to the processing of the User’s personal data by Bruqi upon the provision of the Services in accordance with the Terms.
7. The terms and definitions used in this Data Processing Agreement shall have the meaning set out in the Terms and the General Data Protection Regulation (EU) 2016/679 (“GDPR”). In circumstances not covered by this Data Processing Agreement, the Terms shall apply. In the event of any contradictions or inconsistencies between the Data Processing Agreement and the Terms, this Data Processing Agreement shall prevail.

12. Subject Matter of the Processing
    
    1. For the purposes of providing the Services, the User (operating in the role of a data controller) authorises Bruqi (in the role of a data processor) to process the User’s personal data that the User determines to enter through the Platform in the course of using the Services or that the User makes available to Bruqi in any other way in accordance with the Terms for the purposes of providing the Services. The User hereby warrants that it has all the necessary powers to grant the authorisation set out in the preceding sentence, in particular where the User is not the data controller of the User’s personal data made (or to be made) available to Bruqi, including by entering such data through the Platform.
    2. The Terms accompanying this Data Processing Agreement shall be deemed to be the complete and final documented instructions regarding the processing of the User’s personal data by Bruqi, and any further instructions shall require a prior written agreement.
13. the user’s obligations
    
    1. The User shall ensure that any personal data entered through the Platform and otherwise provided to Bruqi in the course of using the Services is processed only in accordance with the applicable laws, in particular the GDPR. In doing so, the User shall ensure, among others, that there is an appropriate legal basis for the processing of the User’s personal data. The provisions of this Section 3 shall apply even if the User is not the data controller of the personal data made (or to be made) available to Bruqi, including by entering such data through the Platform.
14. bruqi’s obligations
    
    1. Bruqi undertakes to process the User’s personal data only in accordance with applicable laws, this Data Processing Agreement and only to the extent and in the manner necessary for the provision of the Services in accordance with the Terms. When processing the User’s personal data, Bruqi undertakes to keep the User’s personal data confidential, while ensuring that access to the necessary personal data is only granted to persons who have a direct need to know in order to fulfil Bruqi’s obligations under the Terms. Bruqi shall ensure that the persons involved in the processing of the User’s personal data have entered into an appropriate confidentiality agreement or have a legal obligation of confidentiality. Bruqi undertakes to provide reasonable assistance to the User in relation to the requirements of applicable law, taking into account the nature of processing and the information available to Bruqi.
    2. Bruqi shall not transfer the User’s personal data to countries outside the European Economic Area or not on the European Commission’s list of countries providing adequate protection of personal data (“Restricted Transfer(s)”) without the User’s prior authorisation (given in accordance with Sections 5 or 8 of this Data Processing Agreement) and applying appropriate safeguards. These safeguards may include, for instance, standard data protection clauses adopted by the European Commission to be agreed between the respective parties (i.e. Bruqi and the data recipient).
15. restricted transfers
    
    1. Where the User’s personal data is transferred from Bruqi (operating in the role of a data processor) to the User (in the role of a data controller) as a Restricted Transfer, the parties to this Data Processing Agreement shall apply module four of the EU Processor-to-Controller Standard Contractual Clauses (“SCCs”) as adopted by the European Commission in the Annex to the Commission Implementing Decision (EU) 2021/914 of 4 June 2021. The SCCs shall be deemed to be incorporated into this DPA by the reference herein, and applied accordingly. The relevant Annexes of the SCCs shall be deemed be completed as set forth in Schedule 2 to this Data Processing Agreement. The parties to this Data Processing Agreement hereby agree that:
       
       1. Clause 7 (Docking clause) is not incorporated;
       2. Clause 11 (Redress) optional section is not incorporated; and
       3. Clauses 17 (Governing Law) and 18 (Choice of Forum and Jurisdiction) follow the governing law and choice of forum and jurisdiction as stipulated under the Terms.
    2. To the extent a conflict exists between the terms of the SCCs and any terms of this Data Processing Agreement with respect to Restricted Transfers, the terms of the SCCs shall take precedence over the terms of this Data Processing Agreement.
16. security measures
    
    1. Bruqi shall implement appropriate technical and organisational measures to protect the User’s personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. Bruqi’s security measures comply with the applicable law, taking into account, inter alia, the nature of the personal data processed and the risks associated with the specific processing. When processing the User’s personal data, Bruqi shall apply, inter alia, the security measures listed in Schedule 1 to this Data Processing Agreement.
17. Requests from Data Subjects and Supervisory Authorities
    
    1. Bruqi shall inform the User via the Platform of any enquiries and requests received from data subjects, competent supervisory authorities, or other third parties relating to the processing of the User’s personal data by Bruqi during the course of providing the Services. Where necessary, in particular where the request relates to Bruqi’s systems and the User does not have all the necessary information, Bruqi undertakes to reasonably assist the User in responding to the enquiry or request. Bruqi shall not act on behalf of or as an agent for the User in dealing with any enquiry covered by this Section 7.
18. Sub-Processors and Engagement of Sub-Processors
    
    1. The User authorises Bruqi to use sub-processors for the processing of the User’s personal data, provided that Bruqi only uses sub-processors that provide adequate safeguards in accordance with the applicable laws. Bruqi shall ensure that sub-processors have a contractual obligation to comply with requirements for processing of the User’s personal data that are at least equivalent to those contained in this Data Processing Agreement. In any event, Bruqi shall be fully liable towards the User for any failure of sub-processors to comply with applicable requirements.
    2. In the event that Bruqi intends to involve (or change) sub-processors in the context of the processing of the User’s personal data, Bruqi shall provide the User with the details of the sub-processor to be engaged, thereby giving the User the opportunity to object to the involvement of the relevant sub-processor. Such objection must be reasonably justified and based on the applicable law. If the User does not object to the said changes within 7 calendar days, the User shall be deemed to have accepted the changes to the list of sub-processors. If the parties do not reach an agreement on the objection, and if the new sub-processor is indispensable for Bruqi to provide the Services, Bruqi may terminate the Terms with immediate effect. By entering into this Data Processing Agreement, the User hereby agrees to the engagement of sub-processors listed in Schedule 1 to this Data Processing Agreement.
19. Personal Data Breaches
    
    1. In the event of a personal data breach, Bruqi shall provide reasonable assistance to the User, considering the nature of the processing and the information available to Bruqi, with a view to ensuring compliance with its obligations under applicable law. Bruqi shall further notify the User via the Platform of such a personal data breach without undue delay, but no later than 48 hours after becoming aware of the personal data breach.
20. auditing
    
    1. Upon the User’s request, Bruqi shall allow the User (or an auditor authorised by the User) to conduct audits to the extent necessary to verify compliance with Bruqi’s obligations under this Data Processing Agreement and shall make all relevant information available to the User. In order to exercise the right of audit, the User shall coordinate the time and scope of the audit with Bruqi by giving Bruqi at least 30 calendar days prior notice. The information disclosed to the User (or to the auditor authorised by the latter) in the course of the audit shall be confidential and may only be used for the purpose of the audit. Unless otherwise agreed between Bruqi and the User, the costs of the audit, including Bruqi’s costs, shall be borne by the User. The User shall ensure that the audit takes place during Bruqi’s normal working hours, with the least possible disruption to Bruqi’s business and the activities of Bruqi’s other customers.
21. liability
    
    1. Bruqi’s liability to the User is limited as set forth in the Terms, taking into account the applicable laws (in particular, the GDPR) and the circumstances and scope of the processing of personal data. In the event that Bruqi is subject to a claim for damages by a data subject or to any sanctions by a supervisory authority or court for a breach of this Data Processing Agreement or applicable law caused by the User, the User shall compensate Bruqi (by way of indemnification) for such damages as set out in section the Terms. If Bruqi and the User are involved in the same personal data processing activities and the parties are therefore jointly and severally liable for the damage caused to data subjects by the processing of personal data, and if one of the parties has paid compensation for the damage, the paying party shall be entitled to reclaim the part of the compensation corresponding to the other party’s liability for the damage from the other party involved in the processing.
22. term and termination
    
    1. This Data Processing Agreement shall enter into force at the same time as the Terms and shall remain in force during the term of the Terms (validity of Bruqi Account) or for as long as Bruqi processes the User’s personal data on behalf of and in accordance with the User’s instructions. Termination of the Data Processing Agreement shall be subject to the termination provisions of the Terms. Upon expiry or termination of the Data Processing Agreement for any reason, Bruqi shall return or destroy the User’s personal data upon the User’s request and undertakes to do so within a reasonable time after receipt of such request. Bruqi shall not return or destroy any User's personal data that Bruqi is obliged to process under applicable law.
23. Modification of the Data Processing Agreement
    
    1. Bruqi reserves the right, at its sole discretion, to modify this Data Processing Agreement at any time, in particular if such modifications are necessary to comply with legal obligations, in connection with changes in the Services provided or in the ordinary course of any other business. Bruqi shall notify the User via the Platform at least 30 calendar days prior to the modification of this Data Processing Agreement. If the User does not agree to the changes to this Data Processing Agreement, the User may terminate the Terms and this Data Processing Agreement by notifying Bruqi via the Platform before the changes take effect. If the User continues to use the Services after 30 calendar days from the date of Bruqi’s modification notice, the User shall be deemed to have accepted the relevant modifications to this Data Processing Agreement.

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SCHEDULE 1 TO THE DATA PROCESSING AGREEMENT

1. DESCRIPTION OF PERSONAL DATA PROCESSING

Provision of the Services by Bruqi in accordance with the User’s request and the Terms.

2. DURATION OF PROCESSING

The duration of the Terms, or until Bruqi processes the User’s personal data on behalf of the User and in accordance with the User’s instructions.

3. NATURE AND PURPOSE OF PROCESSING

Personal data is processed for the purpose of providing the Services in accordance with the User’s request and the Terms, in particular for the provision of content removal and takedown services to protect the data subjects’ online presence (from unauthorised use). The Services that Bruqi shall provide to the User are ultimately determined by the Customer.

4. CATEGORIES OF DATA SUBJECTS

Individuals (in particular, individual content creators in the role of data subjects) duly represented and designated by the User.

5. CATEGORIES OF PERSONAL DATA

As determined by the User, i.e., personal data entered through the Platform by the User for using the Services, including, but not limited to, data subjects’ names, online usernames and profiles, related website links, other online presence and related content (images, other intellectual property objects, etc.).

6. SECURITY MEASURES IMPLEMENTED

Bruqi implements the following technical and organisational measures:

• File Encryption: Bruqi employs AES-256-GCM (Advanced Encryption Standard in Galois/Counter Mode) for file encryption and dual-layer server-side encryption using AWS Key Management Service (KMS) keys (DSSE-KMS), whereas the encryption keys are kept strictly confidential and secure;
• Database Security: Database used by Bruqi is secured by robust, credential-level protections, enforced through authorised, role-based access controls;
• Data Retention: Bruqi stores personal data within the User Content for the period strictly necessary to carry out the processing activities under the Data Processing Agreement, including to provide the Services or as required or permitted by applicable law;
• General Confidentiality: Bruqi enters into confidentiality agreements with persons accessing personal data within the User Content or verifies that persons such accessing personal data are subject to a statutory obligation of confidentiality;
• User Content Deletion: Bruqi deletes all User Content upon request by the User, except in cases where Bruqi has a legal basis or obligation to continue processing of personal data within the User Content.

7. ENGAGED SUB-PROCESSORS

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