---
doc_id: POL-TOS-002
title: Terms of Service — draft with drafting notes
type: policy-public
status: draft
version: 2.3
date: 2026-09-25
created: 2026-09-07
last_reviewed: 2026-09-25
next_review: 2026-10-09
law_checked: 2026-09-25
owner: Legal Lead (to be appointed — BRF-2026-001 D0)
reviewers: [hidzo-counsel-reviewer (AI), U.S. consumer counsel, Florida counsel, EU/UK consumer counsel, OFAC counsel]
counsel_needed: yes
counsel_status: none
jurisdictions: [US, US-FL, US-CA, US-NY, EU, UK, DE, FR]
related: [DEC-2026-001, DEC-2026-002, POL-ID-001, POL-REF-001, POL-AUP-001, POL-PRIV-002, POL-DEL-001, POL-LE-001, BRF-2026-001]
sources: [EV-002, EV-003, EV-106, EV-211a, EV-211b, EV-218, EV-219, EV-223, EV-225, EV-226, EV-227, EV-231, EV-232, EV-302, EV-303, EV-406]
supersedes: POL-TOS-002 v2.2 (2026-09-25)
print: true
confidentiality: INTERNAL — LEGAL (Part B becomes PUBLIC on publication)
---

# Terms of Service — draft

> **Prepared for review by licensed counsel. Not legal advice.** Part B is the proposed public text. Parts A and C are internal.
> Bracket legend: `[OPEN]` business decision · `[VERIFY]` fact or authority to confirm · `[COUNSEL]` legal judgment ·
> `[ENGINEERING]` technical fact to confirm. Part B may not be published while any bracket remains.

## Part A — Drafting brief (internal)

### A.1 What changed from v2.0 (2026-09-07)
| Topic | v2.0 | v2.1 | Reason |
|---|---|---|---|
| Contracting entity | Florida corporation; Suite 9375 called "principal mailing address" | Entity block from DEC-2026-001 §6.1; address labelled as filed; business address `[OPEN]` | DEC-2026-001; RSK-046 |
| Trial length | "currently advertised as seven days" | Length only "as shown at enrollment"; one length on every channel `[OPEN]` | G-1; CLM-031 |
| Cryptocurrency | Not addressed | Section 9.5: crypto only where offered, under separate crypto payment terms `[OPEN: keep or remove]` | G-2; RSK-011; BRF-2026-001 D7 |
| EU/UK withdrawal right | Not addressed | Section 13.2 (right of withdrawal; express request to start; withdrawal function) | G-4; EV-232 |
| Acceptable use | Full list in §8 | Summary in §8; full text in the Acceptable Use Policy (POL-AUP-001) | DOCUMENT_PROGRAM #5 |
| Refunds, cancellation, deletion, legal requests | Detailed in these Terms | Core rules kept; details in POL-REF-001, POL-DEL-001, POL-LE-001 | Single source of truth |
| Class-action waiver without arbitration | Retained | Two drafted alternatives; choice reserved to DEC-2026-002 `[COUNSEL]` | G-7; RSK-022 |
| Sanctions representation | Apple bullet + §27 | §26 redrafted neutrally; Apple bullet kept as Apple requires it, with counsel note | RSK-044; EV-223 |
| Contacts | support@ for everything | Channels from POL-ID-001 | G-9 |
| Internal checklist | Inside the public text | Moved to Part C | Publication hygiene |

### A.2 Inputs that block publication (not drafting)
- Checkout disclosure and separate affirmative consent to the renewal terms (Payments Rulebook §5.3); confirmation with the required
  acknowledgement (Cal. Bus. & Prof. Code §17602(a)(3); N.Y. Gen. Bus. Law §527-a `[VERIFY]`); logs of consent and cancellation events.
- Board decision D3 (OFAC) on the iOS embargo representation (§17) and on paid plans in sanctioned jurisdictions (§26.4).
- Board decision D4 (advertising) — §§4.1 and 16.1 must match the Privacy Policy §2 alternative chosen.
- EU withdrawal function live on the website (RSK-051).
DEC-2026-001 adopted; DEC-2026-002 decided; trial length fixed on all channels; refund model (BRF-2026-001 D5); crypto decision (D7);
mailboxes live; web self-service cancellation live `[ENGINEERING]`; age rating aligned (BRF-2026-001 P2-4); publication gate of
AUD-2026-09-11 §4; counsel sign-off.

### A.3 Facts relied on in Part B
| Fact | Source | Label |
|---|---|---|
| Entity, document number, mailing address | EV-211a, EV-211b | Verified |
| Sales channels: Apple, Google Play, website (Stripe) | EV-003, EV-009, EV-010, QN-08 | Reported |
| Free Service limits (session length, waiting periods); rewarded ads | EV-010, QN-02 | Reported — `[ENGINEERING]` |
| Five devices / five connections | EV-003, EV-010 (CLM-019) | Reported — `[ENGINEERING]` |
| Encryption between device and server | CLM-008 (OPEN) | Unverified — `[ENGINEERING]` |
| Sign-in methods | QN-03 | Reported — `[ENGINEERING]` |
| Cryptocurrency payments | RSK-011 | Reported — decision D7 |
| Trial length | EV-003 (3 days) vs EV-302 (7 days) (CLM-031) | Open |

### A.4 Issue matrix (summary)
Contract formation and assent (core); consumer protection — U.S. automatic-renewal law, EU/UK withdrawal, unfair terms, DCD conformity and
changes (core); platform rules — Apple minimum EULA terms, Guideline 5.4 (core); sanctions (core — §§17, 26); privacy (touched — §15 kept
non-contractual); DSA Art. 14 (touched — §8 and AUP); disputes and forum — Florida, Brussels Ia, arbitration choice (core); IP (touched);
personal liability (touched — renewal flows).

## Part B — Proposed public text

# Terms of Service

**Version:** 2.2 `[OPEN: renumber on publication]` · **Effective:** `[OPEN: date]`

> **Please read these Terms carefully.** They explain how your subscription renews automatically and how to cancel it, what we are
> and are not responsible for, and how disputes are resolved. `[COUNSEL: if Alternative B in Section 28 is chosen, add: "They include an
> agreement to resolve disputes by individual arbitration for U.S. users, with a right to opt out (Section 28)."]`

These Terms of Service ("**Terms**") are an agreement between you and **HidzoVPN, Inc.**, a Florida corporation ("**HidzoVPN**", "**we**",
"**us**" or "**our**"). They apply to the HidzoVPN apps, websites, VPN service, accounts, billing, support and related services that link
to these Terms (together, the "**Services**"). "**Premium**" means the paid HidzoVPN plan described in Section 5.2. The "**Free Service**"
means use of the Services without a paid plan. A "**Billing Provider**" is Apple, Google or, for purchases on our website, HidzoVPN.

You accept these Terms when you tick the box or tap the button that says you agree to them, which we show before you create an account,
start a trial or make a purchase `[ENGINEERING: clickwrap at each of these points, and at first launch for guest use]`. If you do not agree,
do not use the Services. From their effective date, these Terms replace the Terms of Service dated 1 September 2025 `[COUNSEL: acceptance
by existing users — DEC-2026-001 §7; RSK-047]`.

## 1. Other documents that form part of these Terms

1.1 These documents are part of these Terms: the Acceptable Use Policy; the Refund and Cancellation Policy; the plan, price, trial and
offer terms shown to you at checkout; and any additional terms we show you for a specific feature. Our Privacy Policy explains how we
handle personal information; it is not part of this contract, but we recommend that you read it.

1.2 If two of these documents conflict, this order applies: (a) mandatory law; (b) the terms shown and accepted at checkout; (c) for
purchases billed by Apple or Google, the rules of that store for billing, cancellation and refunds; (d) feature-specific terms; (e) these
Terms; (f) the Acceptable Use Policy and the Refund and Cancellation Policy. However, where the Refund and Cancellation Policy gives you more
rights than these Terms, it prevails.

## 2. Who we are and how to contact us

HidzoVPN, Inc. is a Florida profit corporation, Florida Department of State document number P25000060442. Our mailing address is 7901 4th
Street North, Suite 9375, Saint Petersburg, FL 33702, United States. Our business address, telephone number and contact addresses for each
purpose are listed on our Legal Information page at `[OPEN: https://hidzovpn.com/legal]`. Customer support: support@hidzovpn.com.

## 3. Who may use the Services

3.1 You must be at least 18 years old and able to enter into a binding contract. `[OPEN: align app-store age ratings with this rule —
BRF-2026-001 P2-4]`

3.2 If you use the Services for an organization, you confirm that you are authorized to accept these Terms for it, and "you" includes that
organization.

3.3 You may not use the Services where the law, including sanctions and export-control law, prohibits us from providing them to you
(Section 26).

## 4. Accounts, guest access and security

4.1 **Guest access.** Some features of the Free Service can be used without an account. Guest access may use automatic server selection,
limit session length and apply waiting periods between sessions `[ENGINEERING: current values]`. `[OPEN — BRF-2026-001 D4: on the platforms
where advertising is shown, guest access may show advertising and offer optional rewarded advertising to shorten a waiting period; this
sentence must match the Privacy Policy §2 alternative chosen]`

4.2 **Accounts.** An account is needed for Premium, restoring purchases and using more than one device. Sign-in methods are those shown in
the app `[ENGINEERING: e.g. email with a one-time code, Sign in with Apple, Google Sign-In]`.

4.3 **Your responsibilities.** Give accurate information and keep it up to date. Keep your email account, one-time codes and devices secure.
Tell us at support@hidzovpn.com if you think someone has accessed your account. We may ask you to verify your identity before we act on
account requests.

4.4 **Devices and sharing.** Unless your plan says otherwise, a Premium account may be used on up to five supported devices that you own
or control, with up to five simultaneous connections `[ENGINEERING: confirm backend limits — CLM-019]`. You may not sell, rent, share
publicly or resell access to your account.

## 5. Free Service and Premium

5.1 **Free Service.** The Free Service includes VPN connectivity with the limits shown in the app `[ENGINEERING: current values]`. We may
change or end the Free Service at any time.

5.2 **Premium.** Premium features are those described in the offer, store listing or checkout screen when you buy `[ENGINEERING: e.g. manual
server and protocol selection, no in-app advertising, no session time limit, kill switch]`.

5.3 **Platforms.** The Services are available only on the platforms for which we offer an official download `[ENGINEERING: current list,
e.g. iOS and Android]`. Beta and preview features may change or be withdrawn.

## 6. License to use our software

6.1 We give you a personal, limited, revocable, non-exclusive and non-transferable license to install and use our apps on devices you own
or control, only to use the Services in line with these Terms.

6.2 You may not, except where the law expressly allows it or as permitted by our Vulnerability Disclosure Policy: copy, modify or distribute the software; reverse engineer or decompile it;
remove notices; bypass subscription checks, device limits or other technical controls; modify our apps to remove or bypass advertising in the
Free Service; or resell or provide the Services to others as a commercial service without our written permission.

6.3 Open-source components are licensed under their own licenses, which prevail for those components. `[ENGINEERING: publish the list of
open-source licenses in the app — roadmap #29]`

## 7. What a VPN does and does not do

7.1 When the connection is active and working, the VPN encrypts traffic between your device and the VPN server you connect to
`[ENGINEERING: protocol and cipher matrix — CLM-008]`. It does not make you anonymous, protect your device from malware or phishing, or stop
websites, apps or your device from identifying you by other means.

7.2 You are responsible for checking that the VPN is connected, keeping your device and apps updated, and paying your internet and
mobile-data charges.

7.3 We do not guarantee access to any particular website, app, streaming service or content. Other services may block VPN traffic. A server
location shown in the app may be a virtual location that differs from the physical location of the server `[ENGINEERING: confirm whether
virtual locations are used]`.

7.4 Speed and availability depend on factors outside our control. Any description of speed or performance is not a guaranteed minimum.

7.5 You are responsible for complying with the laws of the place where you use the Services. Some countries restrict or prohibit the use of
VPNs. The fact that our app can be downloaded in a country does not mean that its use there is lawful.

7.6 If your personal safety depends on protecting your identity or your communications, do not rely on the Services as your only
protection.

## 8. Acceptable use

You must use the Services lawfully and in accordance with our Acceptable Use Policy, which forms part of these Terms. The Acceptable Use
Policy sets out the restrictions that apply to your use of the Services, how we learn of and handle possible abuse, the measures we may take
(including automated measures), how a person reviews appeals, and how to complain `[COUNSEL: DSA Art. 14(1) — EV-236]`.

## 9. Subscriptions, prices and taxes

9.1 Premium can be bought through the Apple App Store, Google Play or our website `[OPEN: other channels]`, or obtained with an
Activation Code (Section 9.7). The price, billing period and
other material terms shown at checkout apply to your purchase. Prices may differ by channel, country and currency.

9.2 Subscriptions are billed in advance for each billing period. Taxes are included in or added to the price as the law and the Billing
Provider require.

9.3 For purchases through Apple or Google, the store is the seller or billing provider and its terms govern billing, cancellation and refunds.
For website purchases, HidzoVPN is the seller and our payment processor `[OPEN: Stripe entity]` processes the payment.

9.4 If a payment fails, we or the Billing Provider may try again, ask you to update your payment method, or end Premium access.

9.5 **Cryptocurrency.** `[OPEN: keep only if cryptocurrency payments are offered — BRF-2026-001 D7]` Where we accept cryptocurrency, the
purchase is a one-time prepayment for the period shown and does not renew automatically. Refunds for cryptocurrency purchases are described
in the Refund and Cancellation Policy. `[COUNSEL: sanctions and money-transmission review before launch]`

9.6 **Payment authorization.** You authorize the seller shown at checkout to charge your payment method for each billing period, at the price
disclosed to you, until you cancel.

9.7 **Activation Codes.** `[OPEN — POL-RTOS-001 §0: keep only if a reseller program is launched]` Premium may also be obtained with an
Activation Code bought from an authorized reseller. An Activation Code gives Premium for the fixed period stated with it, does not renew
automatically and can be redeemed only at `[OPEN: hidzovpn.com/redeem]`. Unredeemed codes expire `[OPEN]`. The reseller that sold the code is
the seller and handles refunds, as described in the Refund and Cancellation Policy. We may refuse or deactivate a code that was lost, leaked,
obtained fraudulently or sold in breach of the law or of our reseller terms `[COUNSEL: user remedy where a code is deactivated for the
reseller's breach — POL-RTOS-001 §4.3]`.

## 10. Free trials and introductory offers

10.1 A free trial, where offered, lasts for the period shown when you sign up `[OPEN: one trial length on every channel — CLM-031]`.
Eligibility is limited to new users unless the offer says otherwise.

10.2 **AT THE END OF THE TRIAL, YOUR SUBSCRIPTION STARTS AUTOMATICALLY AND YOU WILL BE CHARGED THE PRICE SHOWN WHEN YOU SIGNED UP, UNLESS YOU
CANCEL BEFORE THE CANCELLATION DEADLINE SHOWN AT SIGN-UP.** For trials started through Apple, cancel at least 24 hours before the trial ends
`[VERIFY: Apple Support 118428 — Reported by AI reviewer; Google Play deadline]`. For trials on our website, the deadline is shown at sign-up
and in your confirmation `[ENGINEERING: confirmation email]`.

10.3 An introductory price applies only to the period stated in the offer. After that, the subscription renews at the standard price shown
in the offer.

## 11. Automatic renewal and price changes

11.1 **EXCEPT FOR CRYPTOCURRENCY PREPAYMENTS (SECTION 9.5) AND ACTIVATION CODES (SECTION 9.7), YOUR SUBSCRIPTION RENEWS AUTOMATICALLY AT THE END OF EACH BILLING PERIOD, AND YOU WILL BE CHARGED THE THEN-CURRENT PRICE FOR THE SAME
BILLING PERIOD, UNTIL YOU CANCEL.** You can cancel at any time (Section 12). `[OPEN: if plans of one year or longer are offered, COUNSEL
on German and French renewal rules]`

11.2 For subscriptions bought on our website, we will tell you in advance of any price increase, in the way the law requires, and you may
cancel before the new price applies. For subscriptions bought through Apple or Google, the store notifies you of price changes under its
rules. `[COUNSEL: notice period by jurisdiction — Cal. Bus. & Prof. Code §17602(g)(2); EV-226; EV-232]`

11.3 We will send you reminders of your subscription terms, and notice before a plan of one year or longer renews, where the law requires it
`[COUNSEL: Cal. Bus. & Prof. Code §17602(b)(2), (h)(1); other state laws — EV-226; EV-232]` `[ENGINEERING: reminder channel for users
without an email address]`.

## 12. How to cancel

12.1 Cancelling stops future renewals. You keep Premium until the end of the period you have paid for, unless you receive a refund `[ENGINEERING: QN-08-020]`. Trials
started through a store may end when cancelled, under that store's rules `[VERIFY]`.

12.2 **Apple:** cancel in your Apple Account subscription settings. **Google Play:** cancel in Google Play subscriptions. **Website
purchases:** cancel online in your HidzoVPN account at `[ENGINEERING: self-service cancellation page]`; you can also email
support@hidzovpn.com with the subject "Cancel Subscription" from your account email, or include that address in your message. Online
cancellation is available without any further step that delays or obstructs it `[ENGINEERING: if a retention offer is shown, a clearly
labeled "click to cancel" option must be shown with it — Cal. Bus. & Prof. Code §17602(d), (e)(2); EV-226]`.

12.3 Deleting the app does not cancel a subscription. Deleting your account cancels the renewal of a subscription bought on our website `[ENGINEERING: automatic cancellation of the Stripe subscription — POL-DEL-001 §1]`,
but not of a subscription billed by Apple or Google; cancel those with the store first.

## 13. Refunds

13.1 Refunds are governed by our Refund and Cancellation Policy and, for purchases through Apple or Google, by the rules of that store.
Nothing in these Terms limits any right to a refund or other remedy that the law gives you.

13.2 **Right of withdrawal (European Union and United Kingdom).** If you live in the European Union or the United Kingdom and buy a
subscription on our website, you have the right to withdraw from the contract within 14 days after the day the contract is concluded, without giving a reason,
as described in the Refund and Cancellation Policy. To withdraw, use the "Withdraw from contract here" function in your account
`[ENGINEERING: withdrawal function live — RSK-051]` or contact us. If you asked us to start the service during the withdrawal period and then
withdraw, you pay an amount in proportion to the service provided until you told us you were withdrawing `[COUNSEL: wording — CRD Arts. 9,
11a, 14(3); UK CCRs regs. 29–36; EV-232]`. For purchases through Apple or Google, the store's process applies `[VERIFY: trader for Google
Play in the EEA/UK]`.

13.3 Please contact us before disputing a charge with your bank, so we can try to resolve the issue. This does not limit your right to
dispute a charge.

## 14. Deleting your account

You can delete your account in the app or as described in our Account and Data Deletion Policy. Deleting your account cancels the renewal
of a subscription bought on our website `[ENGINEERING: POL-DEL-001 §1]`, but does not cancel a subscription billed by Apple or Google. We delete or de-identify your
information as described in the Privacy Policy and the Account and Data Deletion Policy.

## 15. Privacy

Our Privacy Policy explains what information we process, why, for how long and what choices you have.

## 16. Third-party services

16.1 The Services rely on third parties such as app stores, payment processors, sign-in providers and hosting providers `[OPEN — D4: and, on
platforms where advertising is shown, advertising networks]`. Their own terms apply to your use of their services.

16.2 We are not responsible for third-party websites, content or products, including those shown in advertisements.

## 17. Additional terms for apps downloaded from the Apple App Store

`[Aligned with Apple's "Instructions for Minimum Terms of Developer's End-User License Agreement" (items 1–10, reviewed by AI reviewer on
2026-09-25); ENGINEERING: confirm whether a custom EULA is configured in App Store Connect — if not, Apple's Standard EULA governs the iOS
license alongside these Terms; COUNSEL to confirm]`

This Section applies if you downloaded our app from Apple's App Store. It is included at Apple's requirement.

- These Terms are between you and HidzoVPN, not Apple. HidzoVPN, not Apple, is responsible for the app and its content.
- Your license is a non-transferable license to use the app on Apple-branded products you own or control, as permitted by the Usage Rules in
  the Apple Media Services Terms and Conditions, including use by other accounts associated with the purchaser through Family Sharing or
  volume purchasing.
- Apple has no obligation to provide maintenance or support for the app.
- If the app fails to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price, if any, of the app.
  To the maximum extent permitted by law, Apple has no other warranty obligation for the app.
- HidzoVPN, not Apple, is responsible for addressing any claims relating to the app, including product-liability claims, claims that the
  app fails to meet legal or regulatory requirements, and consumer-protection or privacy claims, and for investigating and defending any
  claim that the app infringes a third party's intellectual-property rights.
- You represent that you are not located in a country that is subject to a U.S. Government embargo or designated by the U.S. Government as
  a "terrorist supporting" country, and that you are not listed on any U.S. Government list of prohibited or restricted parties
  `[COUNSEL (OFAC): this representation is required by Apple; whether the iOS app may be offered to users in comprehensively sanctioned
  jurisdictions is Board decision D3 — RSK-044; EV-223; publication blocker]`.
- Questions, complaints or claims about the app may be sent to HidzoVPN, Inc., 7901 4th Street North, Suite 9375, Saint Petersburg, FL
  33702, United States; `[OPEN: telephone — QN-01-015]`; `[OPEN: legal@hidzovpn.com]`.
- You must comply with third-party terms that apply when you use the app.
- Apple and its subsidiaries are third-party beneficiaries of these Terms and, upon your acceptance of these Terms, may enforce them against
  you.

## 18. Changes to the Services

18.1 We may update, change or stop features, servers, locations, protocols or plans for legitimate reasons, such as security, legal
requirements, technical changes or changes in our providers. We will give reasonable notice of a change that materially reduces a paid
feature, where practicable and where the law requires it.

18.2 If we permanently stop providing a paid subscription that you bought on our website before the end of its paid period, and not because
you broke these Terms, we will refund the unused part of the period or offer you an equivalent service `[OPEN: confirm]`.

18.3 If you are a consumer in the European Union or the United Kingdom and a change to a paid feature has more than a minor negative effect
on you, we will tell you in advance, and you may end your subscription free of charge within 30 days after the change and receive a refund
for the unused period `[COUNSEL: Directive (EU) 2019/770 Art. 19; UK law]`.

## 19. Intellectual property and feedback

19.1 HidzoVPN and its licensors own the Services, including the software, designs, text, trademarks and logos. You receive only the license
described in Section 6.

19.2 If you send us feedback or suggestions, you allow us to use them without payment or attribution.

## 20. Disclaimers

TO THE EXTENT PERMITTED BY LAW, THE SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE". WE DO NOT PROMISE THAT THE SERVICES WILL BE
UNINTERRUPTED, ERROR-FREE OR SECURE AGAINST EVERY THREAT, OR THAT THEY WILL GIVE ACCESS TO ANY PARTICULAR CONTENT. TO THE EXTENT PERMITTED BY
LAW, WE EXCLUDE IMPLIED WARRANTIES, INCLUDING OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT.

If you are a consumer in the European Union or the United Kingdom, you have legal rights if a paid service is not provided with reasonable
care and skill or does not conform to the contract; this Section does not limit those rights. If the law of your place of residence gives
you other rights that cannot be excluded, this Section does not affect them.

## 21. Limitation of liability

21.1 TO THE EXTENT PERMITTED BY LAW, WE ARE NOT LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, OR FOR LOSS OF
PROFITS, REVENUE, DATA OR GOODWILL.

21.2 TO THE EXTENT PERMITTED BY LAW, OUR TOTAL LIABILITY FOR ALL CLAIMS RELATING TO THE SERVICES OR THESE TERMS IS LIMITED TO THE AMOUNT YOU
PAID FOR THE SERVICES IN THE 12 MONTHS BEFORE THE EVENT THAT GAVE RISE TO THE CLAIM `[OPEN: add a minimum amount for users of the Free
Service, e.g. US$50]`.

21.3 Nothing in these Terms limits liability that cannot be limited by law, including, where applicable, liability for fraud, gross
negligence, willful misconduct, or death or personal injury caused by negligence, or your statutory rights as a consumer.
`[COUNSEL: New Jersey TCCWNA-specific drafting for Sections 20–22 — Reported]`

## 22. Indemnity

To the extent permitted by law, you will compensate HidzoVPN for claims, losses and reasonable legal costs arising from your unlawful use of
the Services or your breach of these Terms. This does not apply to losses caused by our own fault `[COUNSEL: EU/UK unfair-terms review;
whether to exclude consumers in the EU and UK expressly]`.

## 23. Suspension and termination

23.1 You may stop using the Services at any time. To end a subscription, cancel it (Section 12).

23.2 We may suspend or end your access if you break these Terms or the Acceptable Use Policy, if we reasonably suspect fraud or a security
threat, if payment fails, or if the law, a court, an authority or an app store requires it. Where reasonable and lawful, we will tell you
first and give you a chance to fix the problem. The Acceptable Use Policy explains how decisions are made and how to appeal.

23.3 If we end a paid subscription because we reasonably determined that you seriously broke these Terms, you are not entitled to a refund,
except where the law requires one.

23.4 Sections 9 (amounts owed), 13, 19 to 22 and 26 to 30 continue after termination. Your license under Section 6 ends.

## 24. Requests from authorities

We respond to requests from courts, governments and law-enforcement authorities as described in our Law Enforcement Guidelines
`[OPEN: link — POL-LE-001]`. Requests must be sent to the address given there. We may challenge requests that are invalid or overbroad.

## 25. Changes to these Terms

25.1 We may update these Terms. We will publish the new version with its effective date and keep earlier versions available
`[OPEN: archive]`.

25.2 If a change is material, we will give you reasonable notice before it takes effect, for example by email or in the app, and, where the
law requires it, ask for your agreement. If you do not agree, you may cancel before the change takes effect `[COUNSEL: whether continued use
after notice is sufficient for existing subscribers — DEC-2026-001 §7; RSK-047]`.

25.3 A change to Section 27 or 28 does not apply to a dispute that either of us knew about before the change took effect.

## 26. Sanctions and export controls

`[COUNSEL: OFAC counsel to approve this section — RSK-044; BRF-2026-001 P0-6, P1-1, D3]`

26.1 The Services are subject to United States sanctions and export-control laws and may be subject to the laws of other countries. You may
not use the Services in a way that would cause HidzoVPN to breach those laws.

26.2 You may not use the Services if you are, or act for, a person on a U.S. sanctions list or a person with whom U.S. persons are
prohibited from dealing, or if you are acting for a government that is subject to U.S. sanctions, unless the law permits it.

26.3 We may restrict registration, payment methods, downloads, server access or support in particular countries or regions, or for
particular persons, where we consider it necessary to comply with the law.

26.4 `[OPEN — D3: paid plans are not available to persons located in [countries]]`

## 27. Governing law and courts

27.1 These Terms are governed by the laws of the State of Florida, United States, without regard to its conflict-of-laws rules. The UN
Convention on Contracts for the International Sale of Goods does not apply.

27.2 Except as Section 27.3 provides, and subject to Section 28, disputes will be heard by the state courts in Pinellas County, Florida, or
the federal court for the district that includes Pinellas County `[COUNSEL: venue — RSK-046]`.

27.3 **Consumers.** If you are a consumer, you keep the protection of the mandatory laws of the country and state where you live. If you
live in the European Union or the United Kingdom, you may bring proceedings in the courts where you live, and we may bring proceedings
against you only in those courts `[COUNSEL: Brussels Ia Arts. 18–19; UK equivalent — VERIFY]`. Either of us may bring an eligible individual
claim in a small-claims court.

## 28. Resolving disputes

28.1 **Talk to us first.** Before starting a claim, please send a written description of the dispute, your account email and the outcome you
want to `[OPEN: legal@hidzovpn.com]`. We will try in good faith to resolve it within 30 days. This does not prevent either party from seeking
urgent relief or from starting proceedings to prevent a claim from becoming time-barred.

28.2 `[COUNSEL: DEC-2026-002 — choose one of the alternatives below and delete the other]`

**Alternative A — courts.** Disputes are resolved in the courts identified in Section 27.

**Alternative B — individual arbitration for U.S. users with opt-out (for counsel to draft in full).** If you live in the United States,
disputes will be resolved by binding individual arbitration administered by `[COUNSEL: provider and rules]`, except for small-claims matters
and claims for injunctive relief concerning intellectual property. You may opt out within 30 days after first accepting these Terms by
emailing `[OPEN]`. **CLASS AND REPRESENTATIVE ACTIONS ARE NOT PERMITTED IN ARBITRATION UNDER THIS SECTION.** `[COUNSEL: full clause; mass-
arbitration protocol; public-injunction carve-out for California; carve-outs; severability; state-law review]`

## 29. General

29.1 **Electronic communications.** You agree that we may give you notices, receipts and other communications electronically, including by
email and in the app.

29.2 **Events outside our control.** We are not responsible for failures caused by events beyond our reasonable control.

29.3 **Transfer.** You may not transfer your rights under these Terms. We may transfer these Terms to a successor to our business, and we will
tell you if we do so.

29.4 **No waiver; severability.** If we do not enforce a provision, we do not give up the right to do so later. If a court finds a provision
unenforceable, the rest of these Terms continue to apply.

29.5 **Entire agreement.** These Terms and the documents listed in Section 1 are the entire agreement between you and us about the Services.
This does not exclude anything we told you that the law treats as part of our contract with you.

29.6 **Language.** These Terms are written in English. If a translation differs, the English version prevails, unless the law of your place of
residence requires otherwise.

## 30. Contact

HidzoVPN, Inc. · Legal Information page: `[OPEN: https://hidzovpn.com/legal]` · Support: support@hidzovpn.com · Legal notices:
`[OPEN: legal@hidzovpn.com]`

## Part C — Drafting notes (internal)

### C.1 Legal basis for key clauses
| Clause | Basis | Label |
|---|---|---|
| Automatic-renewal terms restated in capitals (§§10–11); the checkout must disclose them before billing information is obtained and capture separate consent | ROSCA, 15 U.S.C. §8403 (clear and conspicuous disclosure; express informed consent; simple cancellation) | Reported `[VERIFY]` (EV-225) |
| Express affirmative consent; online cancellation without obstruction; annual reminder (§§11–12) | Cal. Bus. & Prof. Code §17602 as amended by AB 2863 (contracts from 1 July 2025) | Reported `[VERIFY]` (EV-226) |
| New York automatic-renewal law | N.Y. Gen. Bus. Law §527-a as amended (official page revised 7 Nov 2025): clear and conspicuous terms; cancellation "as easy to use" as consent and through every medium used for consent (subd. 1(d), (d-1)); notice before a free trial of more than one month converts (1(h)); annual-renewal notice 15–45 days (1(f)); notice of material changes including price increases (1(g)) `[ENGINEERING: notices]` | Reported (EV-232); amending law and effective date Level C `[VERIFY]` |
| Florida automatic-renewal law | Fla. Stat. §501.165(1)(a): applies to renewal "for a specified period of more than 1 month" that keeps the contract in effect more than 6 months — assessment: monthly plan probably outside; quarterly and annual plans probably inside. Clear and conspicuous disclosure (2)(a); 30–60 day notice for terms of 12 months or more (2)(b); cancellation by the same means as acceptance (2)(d); violation voids the renewal provision (2)(f) | Verified (1)(a) first-hand, leg.state.fl.us 2026 ed.; rest Reported (EV-232); "service contract" coverage of a clickwrap subscription `[COUNSEL]` |
| EU withdrawal function | Directive (EU) 2023/2673, new CRD Art. 11a ("withdraw from contract here"; "confirm withdrawal"; acknowledgement on a durable medium), applied from 19 June 2026 | Reported (EV-232) |
| FDUTPA remedies | Fla. Stat. §501.211 | Reported (EV-232) |
| Online seller identity (§2) | Cal. Bus. & Prof. Code §17538(d) | Verified (EV-219) |
| EU/UK withdrawal right (§13.2) | CRD 2011/83/EU Arts. 9, 14(3), 16(a); Directive (EU) 2023/2673 (withdrawal function); UK CCRs regs. 29–36 | `[VERIFY: EV-232]` |
| Apple minimum terms (§17) | Apple Instructions for Minimum Terms of Developer's EULA (ten items, including developer name and address) | Reported (EV-232) |
| VPN legality notice (§7.5) | Apple Guideline 5.4 ("VPN apps must not violate local laws") | Verified (EV-106) |
| Sanctions (§26; §17 embargo representation) | 31 C.F.R. §560.540 | Verified as to text (EV-223); application `[COUNSEL]` |
| Class waiver without arbitration (§28) | *AT&T Mobility LLC v. Concepcion*, 563 U.S. 333 (2011) held that the FAA preempts a state rule treating class waivers in arbitration agreements as unconscionable; it does not address stand-alone waivers in litigation, so a waiver under Alternative A is of uncertain enforceability | Reported (EV-232); `[COUNSEL]` |
| No absolute privacy claims (§§7, 15) | Claims register; FTC Act §5 | Internal rule; Assessment |

### C.2 Consistency sweep
Entity block = DEC-2026-001 §6.1 and POL-ID-001. Device limit and trial length = checkout, store listings and marketing. Refund rules =
POL-REF-001. Deletion = POL-DEL-001. Abuse handling = POL-AUP-001 (replaces v2.0 §10). Legal requests = POL-LE-001.

### C.3 Limits of this analysis
- **Verified first-hand:** Sunbiz; Articles of Domestication; Cal. Bus. & Prof. Code §17538(d); Apple Guideline 5.4; 31 C.F.R. §560.540.
- **Reported or pending:** ROSCA; Cal. Bus. & Prof. Code §17602; other state automatic-renewal laws; EU/UK withdrawal law; Apple minimum EULA
  terms; *Concepcion*; FDUTPA.
- **Not reviewed:** consumer law of countries outside the U.S., EU and UK where the Services are marketed (e.g. Turkey, Indonesia, Saudi
  Arabia, UAE); unfair-terms review of §§20–22 under EU/UK law.
- **Counsel required:** U.S. consumer (renewal, cancellation, disputes); EU/UK consumer (withdrawal, unfair terms); OFAC (§§17, 26);
  Florida (governing law, venue).

### C.4 Review log
| Date | Reviewer | Verdict | Notes |
|---|---|---|---|
| 2026-09-07 | Counsel review draft v2.0 | — | EV-302 |
| 2026-09-23 | AUD-2026-09-11 | 14 gaps | G-1…G-14 |
| 2026-09-25 | Drafted v2.1 | — | See A.1 |
| 2026-09-25 | hidzo-counsel-reviewer (AI), round 2 (full) | REVISE (no Blockers; 14 Majors) | v2.2: Part B rewritten — trial cancellation deadline and Apple 24-hour rule (Reported); reminders (§17602(b)(2), (h)(1)); checkout-consent blockers; Apple item 2/8/10 wording and custom-EULA check; D3 gating of the embargo representation and §26.4; EU/UK forum (§27.3); EU/UK change right (§18.3); statutory-rights carve-outs (§§20, 29.5); DSA Art. 14 reference (§8); §15 no longer contractual; ads tied to D4; no-retroactivity (§25.3); replacement of the 2025 Terms; payment authorization (§9.6); survival (§23.4); U.S. spelling; defined terms; cross-references; REF-prevails rule (§1.2) |
| 2026-09-25 | hidzo-counsel-reviewer (AI) | REVISE (no Blockers; 8 Majors) | Incorporated: clickwrap-only assent; Apple item 8; withdrawal wording and function; store price-change notices; safety-reliance clause; click-to-cancel bracket; state automatic-renewal rows. Research EV-232 incorporated |
| 2026-09-25 | hidzo-counsel-reviewer (AI) — cross-document final audit; research memos EV-232–235 | REVISE (set: 1 Blocker, 8 Majors) | v2.3: cross-document redlines X-01–X-31 applied where they concern this document; authority labels updated from first-hand and research-memo checks (EV-238–264) |
| 2026-09-27 | Correction | — | §9.7 Activation Codes added (text of audit finding X-06, which had been applied only in §11.1 and the Refund Policy); §9.1 refers to it |