Public offer of accession to the partner programme of the Real-bro service

1.1. Operator — Serhii Poliakov EI, entrepreneur individuel (EI) under French law, micro-enterprise regime, SIRET 10527513500017, address 36 rue Victor Hugo, 76530 Grand-Couronne, France, telephone +33 939 24 93 33, email [email protected]. The Operator owns the Real-bro service and administers the partner programme.

1.2. Service (Platform) — the Real-bro service at real-bro.com and its subdomains: property search and rental, a directory of professionals, tenant profiles and AI calls.

1.3. Programme — the partner programme of the Real-bro service, the conditions of which are set out in this offer.

1.4. Partner — a user who has acceded to this offer and participates in the Programme. No application, moderation or approval is required (point 4.1). The word “Partner” denotes a role within the Programme and does not imply entrepreneur status (point 3.3).

1.5. User — any registered person in the Service.

1.6. Invitee — a user who has registered in the Service through another user's referral link and is attributed to that user under section 5.

1.7. Referral link — a user's personal link issued in the personal account. It is the only means of attributing an invitee; referral codes are not entered manually.

1.8. First payment — the invitee's first successful monetary payment in the Service. Remuneration is calculated on the payment amount in euros as recorded in the payment system at the moment of payment, before deduction of the Stripe and bank fees. A purchase paid for entirely with silver or gold, and any internal transaction that brings no monetary receipt to the Operator, is not a first payment. Remuneration arises no more than once per invitee.

1.9. Second-level invitee — a user attributed under section 5 to an invitee of the Partner.

1.10. Silver — an internal currency of the Service, awarded to all users for an invitee's confirmed registration and for the profile they have created. It is not paid out in money and is spent only inside the Service: on plans and on bundles of minutes of AI calls.

1.11. Gold — an internal currency of the Service, awarded for the first payment of an invitee and of a second-level invitee under section 6. Gold may be spent inside the Service on the same conditions as silver or received in money: it is paid out to the account connected through Stripe Connect if the Partner has enabled automatic withdrawal (point 10.6). Gold spent inside the Service is no longer paid out in money. Gold cannot be bought.

1.12. Rate — 10 coins (silver or gold) = €1.

1.13. Milli-coin (mc) — the unit of coin accounting in the system. 1 coin = 1,000 mc; €1 = 10,000 mc.

1.14. Accrual — a record of a Partner's remuneration in the system, having an amount in mc and a status under section 8.

1.15. Public Programme Rules — the eight numbered rules published in the Service (section 9).

1.16. Stripe Connect — a service of Stripe through which the verification of the Partner and monetary payouts are carried out. The Partner's account is opened in Stripe Connect in the recipient configuration as the account of a private individual; entrepreneur status, a company registration and a VAT number are not required. The country of the account is stated once, when it is created, and does not change afterwards.

1.17. Personal account — the section of the Service where the Partner sees their link, their accruals and their statuses, the payout mode selected, the date of the next payout and the history of payouts. Historical records with the status forgone — shares not accrued under the rules applicable before version 2.0 of this offer — are displayed for information only and create no obligation to pay them.

1.18. Payout mode — the procedure chosen by the Partner for the gold awarded to them: “accumulate” (the gold remains in the account and is spent inside the Service; no payouts are formed) or “automatic withdrawal” (the gold is paid out in money in the payout cycle). The default mode is “accumulate” (point 10.6).

1.19. Payout cycle — the calendar procedure under point 10.3 in which the Operator forms and sends payouts. There are no payout requests in the Programme.

2.1. The Operator offers any person meeting the requirements of section 4 to accede to the Programme.

2.2. The Partner brings new users to the Service through their referral link. The Operator awards them remuneration in gold under section 6. The gold is spent inside the Service or paid out in money under section 10 if the Partner has enabled automatic withdrawal (point 10.6).

2.3. There are three reward events in the Programme: an invitee's confirmed registration and the profile they have created give silver; the first payment of an invitee or of a second-level invitee gives gold. There is no reward for a click on the link. Silver is awarded under the general rules of the Service and does not require participation in the Programme.

2.4. Accession to the Programme grants the Partner no rights in the Service, its trade marks, software and databases other than those listed in section 13.

2.5. Participation is free of charge: the Partner makes no payments for participation, status or a place in the Programme and is not required to buy the Service's services. Remuneration arises only from a payment for the Service's services actually received by the Operator from an invitee and not refunded. No remuneration arises from accession to the Programme, from a registration or from other participants' payments. The Programme is not an investment offer or a financial product.

3.1. The Partner acts independently, in their own name and at their own risk, and determines the means, timing and volume of promotion at their own discretion. Participation does not require entrepreneur status; a Partner carrying on entrepreneurial activity participates in that capacity and bears the related obligations.

3.2. There is no employment relationship between the Operator and the Partner: the contract creates no subordination, working schedule, workplace, leave or other element of an employment contract.

3.3. The Partner is not an agent, representative, commission agent, business partner, franchisee or joint venturer of the Operator.

3.4. The Partner may not act in the name of the Operator, assume obligations on its behalf, negotiate in its name, conclude transactions, accept users' money or make promises about how the Service works.

3.5. The Operator does not guarantee the Partner any volume of click-throughs, registrations, payments or income.

3.6. The contract is not exclusive: the Partner may promote any other services, including competing ones.

3.7. The Operator sets the Partner no plans, quotas, minimum volumes, schedule, place of work or reporting and gives no instructions as to the manner of performing the work. The Partner uses their own means and channels and may engage subcontractors, remaining responsible for them.

3.8. Participation is open to any user of the Service, whether or not they hold entrepreneur status. A Partner registered as an entrepreneur (SIRENE, RCS, the trade register of their country or equivalent) communicates their registration number to the Operator (article L8221-6 of the French Labour Code). A Partner without such status participates as a private individual: remuneration is paid to them in that capacity, the Operator withholds no taxes or social contributions from it, and the Partner declares the income themselves (section 12).

3.9. A Partner participating as an entrepreneur provides, at the Operator's request, an extract of registration (KBIS or equivalent) and, if registered in France, an attestation de vigilance URSSAF where the amount of remuneration reaches the threshold set by law (articles L8222-1 and D8222-5 of the French Labour Code); such documents are requested no more than once every 6 months. Failure to provide a requested document is a ground for suspension under section 16.

3.10. The Partner warrants compliance with the legislation on undeclared work and on the use of their own personnel and indemnifies the Operator for penalties arising from a breach of this warranty.

4.1. Any user of the Service becomes a Partner if they:

4.1.1. accept the terms of this offer; entrepreneur status and the right to issue invoices are not required;

4.1.2. in order to receive payouts in money, are located in a country supported by Stripe Connect and state that country when the account is created in Stripe. Failing that, participation and accruals are retained and the gold is spent inside the Service;

4.1.3. have an account in the Service with a confirmed email;

4.1.4. a Partner participating as an entrepreneur provides their registration number and VAT details before the first payout (section 12).

4.2. The full text of the offer is published in the Service. The offer is accepted when the user proceeds in the personal account to connect a payout account through Stripe Connect; from that moment the contract between the Operator and the Partner is concluded. Before acceptance the user receives accruals under the general rules of the Service, but no payout in money is made.

4.3. Before the operation is confirmed, the user can check and correct the data entered or cancel the operation. The record of acceptance in the system with the date, time and version number constitutes an electronic signature within the meaning of articles 1366 and 1367 of the French Civil Code.

4.4. The system records the date and time of acceptance, the version number and hash of the offer in force at that moment, and hashes of the IP address and of the User-Agent string from which acceptance was given (point 15.5). The version accepted is provided at the Partner's request to [email protected].

4.5. Verification of identity, documents and payment details is carried out by Stripe within Stripe Connect when the account is connected. To receive payouts, the Partner opens a connected account in the recipient configuration and concludes a separate agreement with Stripe, which governs the relationship between the Partner and Stripe directly. Stripe may refuse verification, restrict, suspend or close the Partner's account and hold funds under its own rules; in that case no payouts are formed until the restriction is removed. The Operator receives only the result of the verification and does not request or store identity documents or bank details.

4.6. The Programme has no application, moderation or approval. The statuses none, pending, approved and rejected survive only on records created before version 2.0 of this offer. The only status affecting participation is suspended (section 16).

4.7. The right to be awarded gold arises for the Partner without any application, approval or other precondition.

4.8. No refusal of participation is provided for. The Operator may refuse a particular accrual under section 8, stating the number of the Public Programme Rule breached, and may suspend or terminate participation under section 16. This does not deprive the Partner of access to the Service as a user.

4.9. One person may have one account and one participation in the Programme (rule 1 of the Public Programme Rules).

4.10. The Partner may withdraw from the contract within 14 calendar days of the date of acceptance without giving reasons and without any cost, by an unequivocal statement to [email protected]. Withdrawal terminates the contract for the future and does not affect remuneration accrued for payments already made by invitees.

4.11. The Partner represents that they and their beneficial owners are not included in the sanctions lists of the EU, France, the UN, the USA and the United Kingdom, are not located in jurisdictions subject to comprehensive sanctions, and that their activity does not fall within Stripe's prohibited and restricted businesses. A breach entails termination of participation and refusal of payout to the extent permitted by law.

5.1. An invitee is attributed only through a click-through from a referral link. Codes are not entered manually and attribution is not made retrospectively.

5.2. The referral link does not expire: it works for as long as the Partner's account and the Programme exist. A person who has followed the link is attributed to the owner of the link if they register within 30 days of the click.

5.3. An invitee's payments are taken into account for 1 year from the date of their registration. A first payment made after that period generates no remuneration.

5.4. An invitee is attributed to one inviting user. Where the person followed several referral links before registering, attribution is made on the basis of the first click-through whose identifier is still stored on their device at the moment of registration (point 5.6); a later click on another link does not replace it. After registration the attribution does not change.

5.5. Clearing browser data, blockers and restrictions on the storage of site data on the invitee's device may prevent attribution. Attribution is not restored manually.

5.6. Attribution is performed by means of an identifier stored on the invitee's device when they follow the referral link, for 30 days; the identifier is described in point 21.8 of the Privacy Policy. If at the moment of registration the identifier is no longer on the device, no attribution is created and no remuneration arises.

6.1. Remuneration is accrued only on the first payment of an invitee or of a second-level invitee (point 1.8).

6.2. The Partner is awarded 10% of the amount of the first payment of their invitee.

6.3. The Partner is awarded 1% of the amount of the first payment of a second-level invitee. Whether the invitee's own share was accrued has no bearing on it.

6.4. Shares are determined by attribution at the moment of the first payment and are not recalculated when a participant leaves the Programme.

6.5. For an invitee's first payment only gold is awarded. For an invitee's confirmed registration and for the profile they have created, silver is awarded under the general rules of the Service.

6.6. An accrual is recorded in milli-coins (mc). Each step's share is rounded down to a whole mc. If, after rounding, a share equals zero, no remuneration is accrued.

6.7. Remuneration is not guaranteed income. The Operator does not promise or forecast any level of earnings, number of invitees or number of payments.

6.8. Indicators of the kind “you could have earned” and the amounts of historical accruals with the status forgone are for information only and are not a promise, forecast or estimate of income.

7.1. The rate of both currencies is 10 coins = €1, for accrual, for spending inside the Service and for payout alike.

7.2. Silver is spent only inside the Service, on plans and on bundles of minutes of AI calls, and is not paid out in money.

7.3. Gold may be spent inside the Service on the same conditions as silver or received in money under section 10. Gold spent inside the Service is not paid out in money; only the gold in the Partner's account at the moment a payout is formed is paid out. Gold reserved for a payout already formed cannot be spent inside the Service. Neither silver nor gold is exchangeable for the other or transferable to other users.

7.4. Gold cannot be bought; the only way to obtain gold is to earn it in the Programme.

7.5. Coins are not a means of payment, electronic money, securities or a crypto-asset. They are a unit of accounting of the Partner's right to remuneration and to payment for the Service's services.

7.6. No interest accrues on a coin balance.

7.7. Where the Service's services are paid for with coins, silver is debited first and gold only for the shortfall. The debiting of gold inside the Service reduces the amount that may be paid out in money.

8.1. Every remuneration event has one of the following statuses:

8.1.1. pending — the accrual has been created and awaits the conditions of accrual (for example, confirmation of the invitee's email);

8.1.2. credited — the accrual has been credited to the Partner's balance. Remuneration for a first payment is credited immediately and may be spent inside the Service from that moment; it is paid out in money in the payout cycle under point 10.3;

8.1.3. held — the accrual is held pending verification;

8.1.4. rejected — the accrual has been refused; the record states the number of the Public Programme Rule breached;

8.1.5. forgone — a historical status: the accrual did not take place because the participant did not hold Partner status under the rules applicable before version 2.0 of this offer; no new accruals with this status are created;

8.1.6. reversed — the accrual has been cancelled, for example upon a refund to the invitee or a chargeback.

8.2. The Operator may move an accrual to the status held until verification is completed. Verification concerns the remuneration only.

8.3. If an invitee's payment is refunded, disputed through a bank or payment system or otherwise cancelled, the Operator moves the corresponding accrual to the status reversed, whether or not it has been credited or paid out.

8.4. If the reversal occurs after the corresponding gold has been paid out in money or spent inside the Service, a negative balance arises. It is set off against the Partner's future accruals (contractual set-off, articles 1347 et seq. of the French Civil Code), starting with the nearest ones, until it is discharged; the Operator notifies the Partner of the set-off with a calculation. If within 6 months the negative balance has not been discharged, the Operator may demand its repayment in money within 30 days of a written demand. While the negative balance remains, no payouts are formed.

8.5. The Partner may challenge a refusal, hold or reversal by a request to [email protected] within 6 months of the date of the change of status. The reply is given by email. If the decision is reversed, the accrual is reinstated and takes part in the nearest payout cycle for which it is eligible under point 10.3.

9.1. Eight Public Programme Rules are published in the Service and form part of this contract:

9.1.1. rule 1 — one person = one account; self-invitation is not permitted;

9.1.2. rule 2 — the invitee must be a new, genuine user;

9.1.3. rule 3 — registration is carried out from the invitee's own device;

9.1.4. rule 4 — accrual is possible only after confirmation of the email;

9.1.5. rule 5 — the percentage is calculated on the first genuine payment; a refund or chargeback reverses the accrual;

9.1.6. rule 6 — automation, scripts and the artificial inflation of click-throughs are prohibited;

9.1.7. rule 7 — temporary and disposable emails do not count;

9.1.8. rule 8 — the link does not expire; registration must follow within 30 days of the click; payments are taken into account for 1 year from registration.

9.2. When refusing an accrual, the Operator states the number of the rule breached.

9.3. Anti-fraud decisions concern only the Partner's remuneration. The invitee's registration, access to the Service and paid features are not affected.

9.4. The specific signals and thresholds of the anti-fraud check are not disclosed; they constitute a trade secret of the Operator. The Partner is told the number of the rule breached.

9.5. Indicators of abuse are detected by automated means; an accrual may be refused, held or reversed by an automated check; the decision is reviewed after moderation at the Partner's request (point 16.2 of the Privacy Policy). The Partner may contest the decision under point 8.5.

10.1. Payout is made in euros to the account connected by the Partner through Stripe Connect. No other means of payout is provided for. A payout is formed and sent by the Operator in the cycle under point 10.3, only in the automatic withdrawal mode (point 10.6); there are no payout requests.

10.2. Payouts are made by the Operator out of its own funds as remuneration under this contract and do not constitute a transfer of third parties' funds, a payment service or safekeeping of funds.

10.3. On the 5th day of each month the Operator forms and sends a payout comprising all the gold awarded to the Partner up to the end of month M−2, where M is the month of the payout. Gold awarded after the cut-off takes part in one of the following cycles.

10.4. Minimum payout amount — 200,000 mc (200 coins, €20). If on the date of a cycle the eligible gold is less than that amount, no payout is formed; the amount is carried over to the following cycles and remains available for paying for the Service's services.

10.5. Maximum amount of a single payout — 500,000,000 mc (500,000 coins, €50,000). The part of the eligible gold exceeding that limit remains in the Partner's account and is paid out in the following cycles.

10.6. The Partner chooses in the personal account one of two modes for the gold awarded to them:

10.6.1. “Accumulate” — the default mode. No payouts are formed; the gold remains in the Partner's account and may be spent inside the Service. While this mode applies, the Operator is under no obligation to pay the remuneration in money and no invoice is issued under point 10.9;

10.6.2. “Automatic withdrawal” — the gold awarded is paid out in money in the cycle under point 10.3, without any action by the Partner.

10.6.3. Automatic withdrawal may be enabled only after Stripe has confirmed the Partner's account and activated the capabilities required to receive transfers and to credit the money to the bank account; in the status suspended (section 16) it is not available. The Partner may switch to “accumulate” at any time; the switch applies to payouts not yet formed and does not cancel a payout already in processing. The choice of mode and any change to it are recorded in the system.

10.7. Only one payout is formed and processed for a Partner at a time. Eligible gold not included in it is carried over to the following cycles.

10.8. If the 5th day of the month is a non-working day, dispatch takes place on the next working day. The time taken for the money to be credited depends on Stripe and the Partner's bank.

10.9. For each payout the Operator draws up a payout statement — where applicable, a self-billing invoice under section 11 — and sends it to the Partner's email. Payment is made on the processing day under point 10.8 and no later than 30 days from the date of the statement (article L441-10 of the French Commercial Code). In the “accumulate” mode no payout is formed and no statement is issued.

10.10. The conditions of points 10.3–10.5, 10.7 and 10.8 are stored in the system as the Programme's parameters and may be changed under section 17. A payout already formed is governed by the parameters in force on the date of its formation.

10.11. The Operator deducts no fee of its own from a payout. Stripe's and banks' fees are deducted by them according to their own tariffs and are not reimbursed by the Operator.

10.12. If the Partner's account is not denominated in euros, conversion is performed by Stripe or the Partner's bank at their own rate; the exchange-rate difference and the conversion fee are borne by the Partner. The Operator's obligation is performed when the amount in euros is sent to Stripe.

10.13. No payout is formed if the Partner has not enabled automatic withdrawal (point 10.6), if the Partner's accruals are under verification (status held), if there is an outstanding negative balance (point 8.4), if the tax information required by Stripe has not been provided, if participation is suspended (section 16), or if Stripe has not confirmed, has restricted or has blocked the Partner's account. The gold remains in the Partner's account and takes part in the nearest cycle after the impediment has ceased.

10.14. The Partner states and corrects their account details in Stripe. If the money has not arrived because of incorrect details, re-dispatch takes place after the details have been corrected; the costs of re-dispatch are borne by the Partner.

10.15. If a transfer has not gone through, has been returned or has been cancelled after dispatch, the payout is closed as unsuccessful; the gold reserved for it is released and takes part in the following cycles once the cause has been remedied. Withdrawal by the Partner of the Operator's access to their Stripe account stops the formation of payouts until access is restored.

11.1. The Partner (mandator) instructs the Operator (mandatary) to issue, in the name and on behalf of the Partner, invoices for their remuneration (mandat de facturation, article 289, I-2 of the French General Tax Code). The mandate takes effect from the date of acceptance of the offer. Where the Partner is not required to issue invoices, the payout statement drawn up by the Operator serves as the settlement document.

11.2. An invoice issued under the mandate bears the mention “Autofacturation”, the details of the Partner and of the Operator, a number, the date, the description of the services, the amount, the VAT treatment and the payment period.

11.3. The Partner may dispute an invoice or statement within 30 days of the date it is sent; where the objection is justified, the Operator issues a corrective document.

11.4. The Partner remains solely responsible before the tax authorities for the content, accounting and declaration of the invoices issued in their name and for the payment of VAT.

11.5. Either party may revoke the mandate by written notice with effect after 30 days; revocation does not affect invoices already issued. From the date of revocation, invoices are issued by the Partner, and no payout is made until they are received.

12.1. The Partner declares the income from the Programme themselves and pays taxes, levies and social contributions under the legislation of their country. A Partner participating as a private individual declares the remuneration as personal income under the rules of their country; the Operator does not verify compliance with that obligation.

12.2. The Operator is not the Partner's tax agent and withholds no taxes or contributions from the remuneration, except where withholding is required by applicable law.

12.3. Amounts of remuneration in this offer are stated excluding VAT. A Partner who is liable to VAT applies it under the rules of their country; the tax information required for payouts is collected by Stripe.

12.4. If, because of inaccurate data supplied by the Partner, the Operator incurs additional assessments, fines or interest, the Partner reimburses them.

13.1. The Partner promotes the Service honestly and in their own name. It is prohibited to:

13.1.1. send spam — unsolicited emails, messenger messages, SMS, calls, mass comments, or any mailing without the recipient's consent;

13.1.2. run brand-name search advertising — buying advertising on the queries “Real-bro”, “real-bro.com” and their variants and misspellings, or using the brand in displayed URLs and advertisement headlines;

13.1.3. promise income — stating or implying that participation in the Programme or use of the Service will bring any earnings, quoting “guaranteed” figures, or building pay-to-enter schemes;

13.1.4. speak on behalf of the Platform — presenting oneself as an employee, partner manager, official representative or support service of Real-bro, or promising features, discounts, timescales and conditions in the name of the Operator;

13.1.5. use the corporate identity outside the materials provided — logos, fonts, layouts, screenshots and texts of the Service — or create websites, accounts and applications that could be mistaken for official Real-bro resources;

13.1.6. mislead — misrepresenting the terms of the plans, the capabilities of AI calls, the composition of the catalogue or the availability of properties;

13.1.7. register domains, social-media accounts and email addresses containing elements of the Real-bro brand;

13.1.8. bring in invitees by means that breach the Public Programme Rules, in particular through automation, artificial inflation and disposable emails.

13.2. The Partner indicates the advertising nature of all publications, videos, stories, mailings and posts containing a referral link with the mention “Publicité” or “Collaboration commerciale” (or an equivalent in the language of the audience), in accordance with articles L121-1 and L121-3 of the French Consumer Code and French Law No 2023-451 of 9 June 2023 on commercial influence. A breach of this point is a material breach of the contract.

13.3. The Partner may use the materials which the Operator has provided for the Programme — in the form provided, without modification, solely for promoting the Service and only while the contract is in force.

13.4. The Partner is responsible for the lawfulness of their promotion channels, for consents to mailings and for the processing of the data of the recipients of their advertising.

14.1. The Operator is responsible for the correct accounting of accruals under this offer and for the payout of confirmed remuneration.

14.2. The Operator is not responsible for:

14.2.1. the number of click-throughs, registrations and payments, or the Partner's income;

14.2.2. the Partner's expenditure on advertising and content, or loss of profit, save where the loss is a direct and foreseeable consequence of a breach by the Operator of its obligation to account for and pay out remuneration;

14.2.3. the acts of Stripe, banks and payment systems, including refusal of verification, blocking of an account, timescales and fees;

14.2.4. the impossibility of attribution owing to the settings of the invitee's device or browser (point 5.6);

14.2.5. interruptions in the operation of the Service due to outages, attacks, failures at suppliers and other events which the Operator could not prevent.

14.3. The limitation of liability does not extend to the Operator's obligation to pay out remuneration accrued and confirmed under this offer: such remuneration is paid in full.

14.3.1. In other respects, the Operator's aggregate liability for all events over 12 months is limited to the greater of: (a) the amount of remuneration with the status credited awarded to the Partner over the 12 months preceding the event, and (b) €5,000.

14.4. The limitations under points 14.2 and 14.3.1 do not apply in cases of wilful misconduct, gross negligence, death or personal injury, or in other cases where the law does not permit liability to be limited.

14.5. The Partner reimburses the Operator for losses and justified expenses arising from the Partner's breach of section 13, including claims by third parties and authorities concerning their advertising.

15.1. The Operator processes the Partner's personal data as a controller within the meaning of Regulation (EU) 2016/679 (GDPR).

15.2. Categories of the Partner's data: account credentials, contact details, invoicing data, the Stripe account identifier, the result of Stripe's verification, the history of accruals and payouts, technical information about activity in the personal account.

15.3. Legal bases:

15.3.1. performance of the contract — accounting for accruals, forming and sending payouts;

15.3.2. legal obligation — accounting and tax records, anti-money-laundering;

15.3.3. legitimate interest — protecting the Programme against abuse, security of the Service, defence of rights in disputes;

15.3.4. the Partner may object to processing based on legitimate interest by a request to [email protected].

15.4. The Operator processes invitees' data as a controller within the operation of the Service. The Partner sees only anonymised records about invitees: the date of attribution, the channel, the funnel stage and the amounts. Invitees' names, emails, telephone numbers and other identifying data are not disclosed to the Partner. The Partner uses these records only for accounting for their own remuneration and for tax reporting and may not use them to identify invitees or for marketing.

15.5. The Operator does not store raw IP addresses or User-Agent strings; only their hashes are used for anti-fraud checks and are processed on the basis of legitimate interest (point 15.3.3).

15.6. Stripe acts as an independent controller when verifying identity and making payouts and processes data under its own terms and privacy policy. The Operator receives the result of the verification and does not store identity documents or bank details.

15.7. The Operator engages hosting providers and ancillary services as processors under contracts meeting article 28 GDPR. Transfers outside the EEA are safeguarded by the European Commission's standard contractual clauses or another lawful mechanism.

15.8. The Partner may obtain access to their data, request rectification, erasure or restriction of processing, receive the data in a portable form and object to processing based on legitimate interest, by a request to [email protected]. The Partner may lodge a complaint with the CNIL or with the supervisory authority of their country of residence — in Spain the AEPD, in Italy the Garante per la protezione dei dati personali, in Portugal the CNPD.

15.9. Retention periods: account and Programme data — for the duration of participation and 6 years after its termination; accounting and tax documents, including invoices — 10 years (article L123-22 of the French Commercial Code); click-through records — 90 days, device and payment matches — 13 months, risk assessments — 6 months, or 6 years where a breach of the Programme rules has been established; security logs — 12 months; evidence of acceptance of the offer — for the term of the contract and 6 years thereafter.

15.10. The Partner complies with the GDPR themselves in respect of the data they collect in their promotion channels; the Operator is not the controller of that data.

15.11. The Operator is the controller of the data processed upon a click-through on a referral link and informs the invitee about the attribution identifiers (point 21.8 of the Privacy Policy).

15.12. Full information on the processing of personal data is set out in the Privacy Policy, which is the information provided under articles 13 and 14 GDPR and does not form part of this contract. The controller is Serhii Poliakov EI, SIRET 10527513500017.

16.1. The contract is concluded for an indefinite term.

16.2. The Partner may leave the Programme at any time by a notice to [email protected]. The contract terminates on the date the notice is received.

16.3. The Operator may suspend counter-performance and move the Partner to the status suspended (articles 1219 and 1220 of the French Civil Code) if:

16.3.1. there are indications of a breach of the Public Programme Rules or of section 13;

16.3.2. Stripe has restricted or blocked the Partner's account or withdrawn the result of the verification, or the Partner has withdrawn the Operator's access to their Stripe account;

16.3.3. the Partner's accruals are under verification;

16.3.4. the Partner's invoicing data has proved to be inaccurate or the documents under point 3.9 have not been provided.

16.4. In the status suspended, accruals continue to be recorded and shown in the Partner's account, but no payouts are formed and automatic withdrawal cannot be enabled. The Operator informs the Partner of the suspension and of what is needed to lift it. The suspension is lifted when its ground has ceased to exist; the eligible gold takes part in the nearest payout cycle after the lifting.

16.5. The Operator may terminate the Partner's participation upon a confirmed material breach of the Public Programme Rules or of section 13, upon a failure to perform continuing for more than 15 days after a written demand, and in the event of force majeure. Notice is sent to the Partner's email.

16.6. The Operator may terminate the Partner's participation without fault on their part, or terminate the Programme, by written notice observing a notice period proportionate to the duration of the relationship: at least one month for each full year of the relationship, but not less than 3 months and not more than 18 months (article L442-1, II of the French Commercial Code). During the notice period the conditions of the Programme for the Partner are not made worse.

16.7. Unpaid remuneration on termination:

16.7.1. upon termination on any ground other than a confirmed breach, accruals with the status credited are paid out in the nearest payout cycle under point 10.3 for which they are eligible, provided that automatic withdrawal is enabled and the Stripe account remains connected. In the “accumulate” mode, or where the amount is less than the minimum under point 10.4, the gold remains on the balance and may be spent inside the Service; to receive it in money, the Partner enables automatic withdrawal (point 10.6.3);

16.7.2. upon termination because of a confirmed breach, the accruals connected with the breach are moved to rejected with a reference to the rule number and are not paid out. Accruals unconnected with the breach are paid out under point 16.7.1;

16.7.3. after termination no new attributions are made, and payments by invitees attributed earlier no longer generate remuneration.

16.8. Termination of participation in the Programme does not entail deletion of the Partner's account as a user of the Service.

17.1. The Operator may change this offer and the parameters of the Programme, including percentages, time limits, limits and the processing day.

17.2. A new version is published in the Service with a new version number and effective date. The Operator notifies the Partner by email at least 30 calendar days before the changes take effect. Only changes required by law or by a decision of a competent authority, and the introduction of new optional features not affecting the existing conditions, may take effect without that period.

17.3. If the Partner does not agree with the changes, they may leave the Programme under point 16.2 before the date on which the changes take effect; the notice of change states that right and the date. Leaving on that ground does not deprive the Partner of remuneration already accrued, which is paid out under point 16.7.1.

17.4. Continuing to participate after the changes take effect means agreement with the new version.

17.5. Accruals are governed by the conditions in force at the moment of the invitee's first payment; payouts by the conditions in force on the date of the formation of the payout.

17.6. The parties exclude the application of article 1195 of the French Civil Code on the revision of a contract upon a change of circumstances.

18.1. The contract is governed by French law.

18.2. Before applying to a court, a party sends the other party a written claim by email stating the circumstances of the dispute, the accruals or payouts disputed with their identifiers, the demand and its calculation. The Partner's claim is sent to [email protected], the Operator's claim to the email stated in the Partner's account. The recipient replies on the merits within 30 calendar days of receipt. If no reply is received within that period, or the parties have not reached agreement within 15 days after the reply, the pre-action procedure is deemed to have been observed. Failure to observe this procedure is a ground for holding the claim inadmissible (fin de non-recevoir). This point does not prevent an application for interim and urgent measures.

18.3. Disputes not resolved in the pre-action procedure are referred to the competent court at the place where the Operator is established in France: as between traders on the basis of article 48 of the French Code of Civil Procedure; in respect of Partners domiciled in another EU Member State on the basis of article 25 of Regulation (EU) No 1215/2012. If under a mandatory rule the clause is invalid in respect of a particular Partner, jurisdiction is determined by the general rules of law.

18.4. Points 18.2, 18.3, 19.7 and 19.10 apply only to a Partner acting for professional purposes. A Partner who is a consumer under the applicable law may bring proceedings before the courts of their domicile, has access to consumer mediation, benefits from the version in the language in which they acceded, and is subject to the statutory limitation periods only.

18.5. The parties may by mutual agreement refer the matter to a commercial disputes mediator. This is not a precondition for applying to a court.

19.1. The contract consists of this offer, the Public Programme Rules and the parameters of the Programme published in the Service. The Privacy Policy does not form part of the contract (point 15.12).

19.2. If any provision of the contract proves to be invalid, the remaining provisions remain in force.

19.3. Notices are sent by email: to the Operator at [email protected], to the Partner at the address stated in their account.

19.4. The records of the Operator's information systems concerning click-throughs, attributions, accruals, statuses, the payout mode selected and payouts constitute evidence of those facts until proof to the contrary. The Partner may adduce any evidence and may obtain, on request and free of charge, a machine-readable export of the records concerning their accruals, attributions and payouts, including the records that served as the ground for a refusal, to the extent that this does not disclose the methodology of the anti-fraud check.

19.5. The Partner may not transfer rights and obligations under the contract to third parties without the Operator's written consent. The Operator may transfer rights and obligations upon a reorganisation or sale of the Service, having notified the Partner.

19.6. Participation is open to every user meeting point 4.1. The Operator may suspend or terminate the Programme in compliance with point 16.6 and section 17.

19.7. The offer is published in the languages of the Service's interface. The authentic version is the French one; in the event of a discrepancy between versions the French text prevails. Notices and claims may be sent in Russian, French, Spanish or English.

19.8. The parties do not disclose to third parties non-public information obtained in connection with the contract, including data on the funnel, rates, verification methodologies and commercial conditions, for the term of the contract and 3 years after its termination.

19.9. A party is not liable for a failure to perform caused by an event beyond its control which could not reasonably have been foreseen at the conclusion of the contract and the consequences of which cannot be overcome (article 1218 of the French Civil Code). The party notifies the other party within 10 days; where the event lasts more than 3 months, either party may terminate the contract without compensation.

19.10. Any claim arising from accruals and payouts is brought within 24 months of the date of the relevant event (article 2254 of the French Civil Code).

Serhii Poliakov EI (EI)

Entrepreneur individuel (EI) under French law, micro-enterprise regime

SIRET: 10527513500017

Address: 36 rue Victor Hugo, 76530 Grand-Couronne, France

Telephone: +33 939 24 93 33

Email for enquiries, claims and personal data requests: [email protected]

Service: real-bro.com

Document version: 3.1. Effective date: 14 September 2026.