Terms & Conditions

1.1 These Terms and Conditions ('Terms') form a legally binding agreement between you and The Circle Technologies ('The Circle Technologies', 'we', 'us', 'our'), the company that owns and operates the technology platform known as The Circle by REEVO (the 'Platform').

1.2 These Terms govern your access to and use of the Platform, including the REVA conversational intake assistant, the REMP matching protocol, the ambassador referral programme, agent and brokerage onboarding, the lead file, electronic agreements and automated settlement.

1.3 By creating an account, scanning or sharing an ambassador QR code, submitting a brief to REVA, accepting a lead, signing an agreement on the Platform, or otherwise using the Platform, you confirm that you have read, understood and accepted these Terms.

1.4 These Terms apply to every participant in the ecosystem, whether you act as a Client, an Ambassador, an Agent, a Managing Broker, a corporate account holder or an administrator.

1.5 Where you accept these Terms on behalf of a company or partnership, you confirm that you have authority to bind that entity, and 'you' includes that entity.

1.6 Our Privacy Notice forms part of these Terms. Where these Terms conflict with a mandatory provision of the law of your country of residence, that provision prevails.

2.1 In these Terms, the following words have the meanings set out below.

• 'Platform' means the software, websites, applications, interfaces and services operated by The Circle Technologies under the name The Circle by REEVO.
• 'REVA' means the Real Estate Virtual Assistant, an artificial-intelligence assistant that conducts conversational client intake.
• 'REMP' means the Real Estate Matching Protocol, the weighted scoring and ranking method used to rank professionals for a Client brief.
• 'Client' means a person seeking to buy, sell, rent or invest in real property who submits a brief through REVA.
• 'Ambassador' means a private individual or corporate entity that refers Clients to the Platform using a Referral Code.
• 'Agent' means a licensed real-estate professional who accepts leads through the Platform.
• 'Managing Broker' means the licensed broker or brokerage that supervises an Agent and holds the applicable brokerage licence.
• 'Lead' or 'Lead File' means the structured record of a Client brief created from a REVA intake, including requirements, budget, timeline and attribution.
• 'Unlock' means the release of a Client's identifying details to an Agent following a valid Agreement and the Client's consent.
• 'Agreement' means the electronic agreement, including any non-disclosure and commission-split terms, executed by an Agent and a Managing Broker in respect of a Lead.
• 'Gross Commission' means the total commission actually received and cleared by The Circle Technologies or the brokerage in respect of a completed property transaction.
• 'Settlement' means the programmatic distribution of Gross Commission under the Yield Distribution.
• 'Yield Distribution' means the fixed allocation of Gross Commission set out in Section 10.
• 'Referral Code' means the unique attribution code assigned to an Ambassador.
• 'Registry' means the global partner network of professionals and brokerages referenced on the Platform.
• 'Verified Profile' means a professional record that has been checked against a documented source and carries verified status.

3.1 The Platform is a technology and matching platform. It introduces Clients to independently licensed real-estate professionals and provides the tools for introduction, verification, agreement and settlement.

3.2 The Circle Technologies is not a real-estate brokerage, agency, or mediator. We do not list properties, market properties for sale, negotiate on behalf of any party, hold client money, or act as agent for a Client, an Agent or a Managing Broker.

3.3 Every property transaction is negotiated and concluded directly between the Client and the licensed professional or brokerage, on terms agreed between them. We are not a party to any mandate, agreement, promise of sale or deed of sale.

3.4 The Circle Technologies is not a law firm, tax adviser, investment adviser, financial institution or insurance intermediary. Nothing on the Platform constitutes legal, tax, investment or financial advice, and nothing constitutes a property valuation.

3.5 Where the law of a territory requires a licence, registration or authorisation to carry out real-estate mediation or brokerage, that licence is held by the professional or brokerage, not by us. We do not perform, and do not hold ourselves out as performing, licensed brokerage activity in any jurisdiction.

3.6 Registry figures describe the reach of a global partner network. Verified profile figures describe locally verified records. Registry membership does not mean that a person is an agent of The Circle Technologies, and we make no representation of affiliation beyond what a Verified Profile states.

3.7 We provide technology. We do not guarantee that any Client will transact, that any Agent will be selected, or that any commission will arise.

4.1 You must be at least 18 years old and have full legal capacity to enter into these Terms. If you do not, you must not use the Platform.

4.2 You must provide accurate, current and complete information, keep it up to date, and maintain the confidentiality of your credentials. You are responsible for all activity under your account and must notify us immediately of any unauthorised use.

4.3 Access is role-scoped. The Platform recognises Client, Ambassador, Agent, Managing Broker and Administrator roles. Attempting to access data belonging to another role, another account or another organisation is a material breach of these Terms.

4.4 We may verify your identity, licensing status, brokerage affiliation, tax status and beneficial ownership, and may request supporting evidence. We may refuse, suspend or withdraw access where verification is not satisfied.

4.5 You confirm that you are not subject to sanctions, are not listed on any restricted-party list maintained by the United Nations, the European Union, the United Kingdom, the United States or any other applicable authority, and are not acting on behalf of such a person.

4.6 Accounts are personal and non-transferable. You must not share access, sell an account, or create an account to circumvent a suspension.

5.1 REVA collects your brief, including your intent (buy, sell, rent or invest), target location, budget range, property specifications, timeline, target yield where relevant, and preferred language. You consent to this information being recorded in a Lead File.

5.2 REMP ranks professionals for your brief. The ranking is a recommendation. You decide whether to proceed, and no obligation to transact arises from receiving a match.

5.3 You confirm that the information you provide is accurate and that you have the right to share it. You must not submit another person's personal data without their authority.

5.4 We do not guarantee that a suitable professional, property, price, yield or timescale will be found. Market conditions, availability and licensing vary by territory.

5.5 Your statutory rights as a consumer are not affected by these Terms. Nothing in these Terms limits any right you have under mandatory consumer law in your country of residence.

5.6 Your identifying details are released to a professional only after the applicable Agreement has been executed and you have consented to the release. Once released, your dealings with that professional are governed by your agreement with them.

5.7 You may withdraw from the process at any time. Withdrawal does not affect obligations already accrued between you and a professional you have engaged.

6.1 An Ambassador participates as an independent referrer. An Ambassador is not an employee, agent, partner, joint venturer, franchisee or representative of The Circle Technologies, and has no authority to bind us, to make any representation on our behalf, or to conclude any agreement for us.

6.2 Each Ambassador receives a Referral Code and a QR pass. Attribution arises only where the Referral Code, QR code or associated campaign parameters are used and recorded by the Platform.

6.3 An Ambassador must not present themselves as a real-estate agent, broker or mediator; must not give property, legal, tax, investment or valuation advice; must not promise a particular property, price, return or outcome; and must not negotiate any transaction.

6.4 Ambassador yields (3.5% primary and 1.5% secondary connector, as set out in Section 10) are payable only on Settled transactions, and only where lawful in the territory of the transaction and of the Ambassador. Referral remuneration is suspended wherever local law restricts or prohibits it.

6.5 An Ambassador must place QR material and conduct referral activity lawfully, respecting venue rules, advertising rules, data protection rules and the rights of third parties. Corporate Ambassadors confirm that the venue or business has consented to the placement.

6.6 No yield is payable where a referral is fraudulent, self-referred, generated by an automated or incentivised scheme not approved by us, or where the underlying transaction is cancelled, reversed, refunded or never completes.

6.7 An Ambassador is responsible for their own taxes, social contributions and any registration or licence required in their territory, and must provide the tax identification and documentation we require before any payment is released.

6.8 An Ambassador who introduces another Ambassador creates a secondary connector link. The secondary connector yield is payable only for the period during which the link is active and recorded by the Platform.

6.9 We may suspend or terminate an Ambassador's participation, and withhold accrued yields, where these Terms are breached, where verification fails, or where required by law.

7.1 An Agent must hold and maintain a valid, current licence or registration to carry out real-estate activity in every territory where the Agent accepts leads, and must provide evidence of it on request. Where a licence lapses, we may suspend the Agent's access and exclude the profile from ranking.

7.2 An Agent must keep their profile accurate, including licence number, brokerage, market, languages, specialisation and supported transaction types. Inaccurate information may result in removal from REMP ranking.

7.3 An Agent must respond to leads within the service level stated on the Platform. Persistent non-response may reduce REMP ranking and lead allocation.

7.4 By accepting a lead, an Agent accepts the Yield Distribution in Section 10 and the dual-signature requirement in Section 11.

7.5 An Agent must not solicit a Client to transact outside the Platform for the purpose of avoiding the Yield Distribution, and must not disclose a Client's details to any third party without the Client's consent and our authorisation.

7.6 An Agent is solely responsible for the services provided to the Client, for the accuracy of property information, for compliance with licensing, advertising, anti-money-laundering and record-keeping obligations, and for the conduct of any sub-agent or team member.

7.7 An Agent consents to REMP scoring based on documented evidence, self-declared data and public sources. Scores are explained on request and may be disputed under Section 9.

8.1 A Managing Broker is responsible for supervising the Agents within their brokerage who use the Platform, and for confirming the licence status and good standing of each of those Agents.

8.2 Dual signature: no Lead is unlocked to an Agent until both the Agent and the Managing Broker have executed the applicable non-disclosure and commission-split terms and the Managing Broker has approved the acceptance. An Agreement that lacks either signature is not valid on the Platform.

8.3 By approving an Agreement, the Managing Broker confirms that they have authority to bind the brokerage to the Yield Distribution and to these Terms.

8.4 A Managing Broker remains responsible for the brokerage's own regulatory, advertising, anti-money-laundering, client-money and record-keeping obligations, and for the acts and omissions of its Agents.

8.5 Brokerage names, logos and marks may be displayed on the Platform for identification purposes only, with the brokerage's authorisation. No partnership, agency or endorsement is created by such display.

8.6 Where a Managing Broker ceases to supervise an Agent, the Agent's access must be revoked and we must be notified without delay.

9.1 REMP ranks professionals for a Client brief using documented, weighted components: Performance (deal velocity, transaction volume, market conversion), Reputation (verified client sentiment and transaction reviews) and ESG (sustainability rating, paperless operations, eco-certified handling).

9.2 The published formula is S = (w1 · P) + (w2 · R) + (w3 · E). Weightings may be tuned to reflect market conditions. Material changes to weightings are published on the Platform.

9.3 Scores are derived from traceable sources. We do not invent a score where evidence is unavailable; a profile without sufficient evidence is not presented as verified.

9.4 Human oversight: no decision producing legal effects or similarly significant effects concerning you is made solely by automated means. A Client always makes the final selection, and a human administrator reviews scoring and verification disputes.

9.5 A professional may request an explanation of their score, the factors that most influenced it, and the correction of underlying data that is inaccurate. Requests are handled under Section 9 and Section 14.

9.6 AI transparency: REVA is an artificial-intelligence assistant. Its responses are informational, are generated automatically, and may be incomplete or incorrect. REVA does not provide legal, tax or investment advice. Always verify material information with a qualified professional.

9.7 We may exclude a professional from ranking, or withdraw verified status, where verification lapses, evidence is withdrawn, or a compliance concern arises.

10.1 Gross Commission arising from a completed property transaction is distributed programmatically at Settlement in the following fixed proportions.

Illustrative Example

On a Gross Commission of 100,000, Settlement distributes: 75,000 to the Agent yield; 19,000 to the Protocol reserve; 3,500 to the primary Ambassador; 1,500 to the secondary connector; and 1,000 to the ESG fund.

10.2 Distribution is calculated on Gross Commission, after deduction of any taxes, payment-provider and banking charges, and any third-party cost properly attributable to the transaction.

10.3 The proportions may be varied prospectively on notice under Section 22. The proportions applying to a Lead are those in force at the date the Agreement was executed.

10.4 No allocation is payable unless and until the transaction completes and the funds clear. Accrued allocations that are not yet due are not transferable and do not bear interest.

10.5 Where the law of the territory of the transaction restricts or prohibits referral remuneration, fee-splitting or unearned fees (including, without limitation, Section 8 of the United States Real Estate Settlement Procedures Act and its implementing regulation), the affected allocation is not payable. The remaining allocations continue to apply, and the affected party is notified.

10.6 Ambassador yields require the Ambassador to be verified and to have completed identity, anti-money-laundering and tax documentation. Payment may be suspended until compliance is satisfied.

10.7 The Protocol reserve is our sole remuneration from the transaction. We do not receive any other fee, mark-up or commission from a Client or a professional in respect of a transaction.

10.8 An Agent must not pay, offer or accept any inducement that would alter the Yield Distribution or circumvent it.

11.1 A Lead File is created from the REVA intake and is confidential to The Circle Technologies until an Unlock takes place.

11.2 A Client's identifying details are released only after (a) the applicable Agreement has been executed by both the Agent and the Managing Broker, (b) the Managing Broker has approved the acceptance, and (c) the Client has consented to the release.

11.3 Agreements are executed electronically. Electronic signatures are valid and enforceable under Regulation (EU) No 910/2014 (eIDAS) and equivalent legislation in other territories. You consent to transact electronically.

11.4 An Agreement states a validity period. On expiry, the reservation over the Lead is released and the Lead may be offered to another professional.

11.5 Breach of confidentiality, of the exclusivity of a Lead, or of the dual-signature requirement may result in forfeiture of accrued allocations, suspension, and termination.

11.6 A Lead File records a full audit trail of stage changes, administrative overrides and signatures. The audit trail is retained as evidence of compliance.

12.1 Payouts are made through regulated payment service providers to the verified payout method recorded on your account, in the currency and on the cycle stated on the Platform.

12.2 The Circle Technologies does not hold client money, does not operate a payment account for third parties, and is not a bank or a payment institution. Funds are transmitted by regulated providers.

12.3 Each party is responsible for its own taxes on amounts it receives. Where required by law, we apply withholding and report accordingly.

12.4 Value added tax: cross-border business-to-business supplies may be subject to the reverse-charge mechanism. You must provide a valid tax or VAT identification number, and you are responsible for accounting for any tax due in your own territory.

12.5 Platform reporting: we may be legally required to collect, verify and report information about you and your transactions to tax authorities, including under Council Directive (EU) 2021/514 (DAC7) and equivalent regimes in other territories. By using the Platform you agree to that collection and reporting.

12.6 Payments may be suspended, delayed or reversed where identity or tax documentation is incomplete, where a sanctions or anti-money-laundering concern arises, or where a transaction is under investigation.

12.7 Chargebacks, reversals, refunds and fraud losses attributable to you are recoverable, including by set-off against any amount we hold for you.

13.1 You must not, and must not permit any person to:

• misrepresent your identity, your licence, your brokerage, your authority or your affiliation;
• carry out, or hold yourself out as carrying out, licensed real-estate activity in a territory where you are not licensed;
• circumvent the Platform by soliciting a Client, an Agent or an Ambassador to transact or pay outside it in order to avoid the Yield Distribution;
• scrape, harvest, index, copy or systematically extract Platform data, or use automated means to access the Platform without our written consent;
• reverse-engineer, decompile or attempt to derive the REMP scoring method, the software or any part of the Platform;
• create false leads, false scans, false accounts, or manipulate referral attribution, scores, reviews or rankings;
• use the Platform for money laundering, terrorist financing, fraud, tax evasion, or the concealment of the proceeds of crime;
• discriminate unlawfully against any person on the basis of race, colour, national origin, religion, sex, familial status, disability, sexual orientation or any other protected characteristic, or breach fair-housing or equal-treatment obligations;
• harass, threaten, defame or abuse any other user;
• evade or breach sanctions or export-control restrictions;
• upload malicious code, or interfere with the integrity, security or availability of the Platform;
• infringe the intellectual-property, privacy or other rights of any person;
• use the Platform for any purpose that is unlawful in the territory in which you are located or in which the transaction takes place.

14.1 The Circle Technologies is the controller of account, referral, scan, attribution and analytics data. Where a Client brief is shared with a professional, we act as controller of the brief and the professional acts as an independent controller of the data once released to them.

14.2 We process personal data on the lawful bases of performance of a contract, compliance with a legal obligation, our legitimate interests in operating and securing the Platform, and consent where consent is required, in accordance with Regulation (EU) 2016/679 (GDPR) and equivalent legislation in other territories.

14.3 Data minimisation: referral scans are recorded at city level only. We do not collect or store precise coordinates, IP addresses, device fingerprints or any data that identifies the physical location of a visitor. Aggregated activity is displayed with obfuscated timings.

14.4 A Client brief contains personal data. It is shared only with the professionals the Client selects and consents to, and only to the extent necessary to respond to the brief.

14.5 You must not submit special-category data (including health, biometric, religious, political or trade-union data) or data relating to criminal convictions, unless a lawful basis exists and you have told us.

14.6 Subject to applicable law, you have the right to access your personal data, to have it rectified or erased, to restrict or object to processing, to data portability, to withdraw consent at any time, and not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects.

14.7 International transfers are made under an adequacy decision or appropriate safeguards, including the European Commission's Standard Contractual Clauses, together with supplementary measures where required.

14.8 Retention: personal data is retained only as long as necessary for the purposes for which it was collected and to meet legal obligations. Anti-money-laundering, tax and transaction records are retained for the statutory period applicable in the relevant territory.

14.9 Security: we apply encryption in transit and at rest, role-based access control, isolated storage for identity data, and monitoring. We will notify you and the competent supervisory authority of a personal-data breach where the law requires it.

14.10 Direct marketing is sent only with your consent or on the basis of a permitted soft opt-in, and you may opt out at any time. Marketing to a professional contact is subject to the rules of the recipient's territory.

14.11 Cookies and similar technologies: essential cookies are used to operate the Platform; analytics and preference cookies are used with consent where consent is required.

14.12 You may lodge a complaint with your supervisory authority. In Portugal, the competent authority is the Comissão Nacional de Proteção de Dados (CNPD).

14.13 We may process aggregated, de-identified and statistical data to operate, benchmark and improve REMP and the Platform. Such data does not identify any individual.

15.1 Attribution is recorded by the Platform from the Referral Code, QR code or campaign parameters (utm_source, utm_medium, utm_campaign) presented at the time of the Client's first qualifying interaction. Unless the Platform states otherwise, the first valid attribution within the attribution window prevails.

15.2 Scans are recorded at city level only, in accordance with Section 14.3.

15.3 You must not tamper with, duplicate, alter or forge a Referral Code, QR code or attribution record, and must not interfere with another Ambassador's attribution.

15.4 A dispute about attribution or about the amount of an allocation must be raised within 30 days of the Settlement in question, with supporting evidence. Determinations are made on the Platform's records.

15.5 Campaign and medium parameters are recorded for attribution, reporting and the prevention of fraud.

16.1 The Platform, its source code, its interfaces, its data model, the Φ emblem, the names 'The Circle by REEVO', 'REVA' and 'REMP', and the vector-based scoring method (patent pending) are owned by The Circle Technologies or its licensors and are protected by copyright, trade-mark, database and other intellectual-property laws.

16.2 Subject to these Terms, we grant you a limited, revocable, non-exclusive, non-transferable licence to access and use the Platform for its intended purpose.

16.3 You must not copy, reproduce, modify, distribute, publish, sell, sublicense, decompile or create derivative works from any part of the Platform.

16.4 You grant us a worldwide, non-exclusive, royalty-free licence to host, store, reproduce, adapt and display the content you upload (including profile information, photographs, venue details and referral materials) for the purpose of operating, promoting and improving the Platform.

16.5 You confirm that you hold all rights necessary to grant that licence and that your content does not infringe the rights of any third party.

16.6 Any feedback you provide may be used by us without restriction or obligation.

16.7 Third-party trade marks, brokerage names and logos are the property of their owners and are used for identification purposes only. Their use does not imply any affiliation, sponsorship or endorsement.

17.1 The Platform is provided on an 'as available' basis. We do not warrant uninterrupted or error-free operation. We may carry out maintenance, updates and security work that interrupt access.

17.2 We may add, change, restrict or remove features, and may make the Platform available in or withdraw it from a territory, at any time.

17.3 We may suspend or terminate your access where you breach these Terms, where a compliance, verification, sanctions or fraud concern arises, where required by law, or where we discontinue the Platform or a feature.

17.4 Where you are a professional user, we will give reasonable notice of a restriction or termination and the reasons for it, except where immediate action is required by law or to prevent harm, in line with platform-to-business rules in the applicable territory.

17.5 You may close your account at any time. Closure does not affect obligations already accrued, including obligations in respect of transactions already in progress.

17.6 The provisions on confidentiality, intellectual property, data protection, liability, indemnity, governing law and jurisdiction survive termination, as do obligations to settle amounts accrued before termination.

18.1 Profile and Registry information is derived from documented sources and public records and is provided 'as is'. We do not warrant that any profile, score, licence status, valuation or other information is complete, current or error-free, and we do not independently guarantee the performance of any professional.

18.2 We do not warrant that a professional will respond or perform, that a property will be available, that a transaction will complete, that a price or yield will be achieved, or that any allocation will be earned.

18.3 To the maximum extent permitted by law, we exclude liability for indirect, incidental, special, consequential or punitive loss, and for loss of profit, revenue, business, opportunity, goodwill or anticipated savings, whether arising in contract, tort, negligence, strict liability or otherwise.

18.4 To the maximum extent permitted by law, our aggregate liability arising out of or in connection with these Terms or the Platform is limited to the greater of (a) the Protocol reserve actually received by us in respect of the transaction giving rise to the claim, and (b) one thousand euro (EUR 1,000).

18.5 Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited, including liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any right you have under mandatory consumer law.

18.6 You indemnify and hold harmless The Circle Technologies, its officers, employees and contractors against all claims, losses, liabilities, costs and expenses arising from your breach of these Terms, your unlawful use of the Platform, your dealings with any Client, professional or Ambassador, or any content you upload.

18.7 We are not responsible for the acts or omissions of any Agent, Managing Broker, Ambassador or Client, or for any agreement made between them.

19.1 The Platform is operated from Portugal and is designed to be used lawfully in each territory where it is made available. Real-estate brokerage, referral remuneration, consumer protection, data protection, anti-money-laundering and advertising are regulated locally. The rules below apply in addition to the rest of these Terms.

19.2 Where a local rule conflicts with these Terms, the local rule prevails to the extent of the conflict, and we may restrict, modify or withdraw the affected feature, allocation or service in that territory.

19.3 Referral remuneration: where a territory prohibits or restricts unlicensed referral remuneration, fee-splitting or unearned fees, the affected allocation is not payable in that territory and is withheld. The remaining allocations continue to apply, and the affected party is notified.

19.4 Licensing: you must not accept a lead, market a property or perform any service in a territory where you are not properly licensed or registered. You are responsible for determining and meeting the licensing requirements that apply to you.

19.5 Consumers: nothing in these Terms reduces any mandatory right you have under the consumer law of your country of residence. Where you are a consumer, you may bring proceedings in your local courts.

19.6 Sanctions and export control: the Platform may not be used by, or for the benefit of, any person subject to sanctions imposed by the United Nations, the European Union, the United Kingdom, the United States or any other applicable authority, nor in any territory subject to comprehensive sanctions.

19.7 Where we do not make the Platform available in your territory, you must not use it.

20.1 If you have a complaint, contact us first through the contact channel published on the Platform. We will acknowledge your complaint promptly and aim to resolve it within a reasonable period, keeping you informed of progress.

20.2 Complaints about a score, a verification decision, an attribution or an allocation are handled by a human reviewer under Section 9 and Section 15.

20.3 Consumers: where a complaint is not resolved, you may refer it to a competent alternative-dispute-resolution body under Directive 2013/11/EU or the equivalent consumer-dispute scheme in your territory, or to your national consumer authority. This is without prejudice to your right to go to court.

20.4 Professional users: complaints about suspension, termination, ranking or a material change to these Terms are handled through the internal review procedure described on the Platform, and may be escalated to the competent authority in your territory where local platform-to-business rules provide for it.

20.5 The parties will attempt to resolve any dispute by good-faith negotiation before commencing proceedings. Where lawful and appropriate, they may agree to mediation.

20.6 To the extent permitted by applicable law, any claim arising out of or in connection with these Terms must be brought within one year of the date on which the claimant became aware, or ought reasonably to have become aware, of the facts giving rise to it.

21.1 These Terms, and any dispute or claim arising out of or in connection with them or their subject matter, are governed by the laws of Portugal, without regard to conflict-of-law rules.

21.2 Subject to Section 21.3, the courts of Lisbon, Portugal have exclusive jurisdiction.

21.3 Nothing in this Section deprives a consumer of the protection of the mandatory rules of the law of their country of residence, or of the right to bring proceedings in the courts of that country. Where a mandatory rule of a territory in which you use the Platform gives you a right that cannot be waived, that right is preserved.

21.4 The United Nations Convention on Contracts for the International Sale of Goods does not apply to these Terms.

22.1 We may update these Terms. Material changes will be notified in advance through the Platform or by email to the address on your account. Continued use after the effective date of a change constitutes acceptance. If you do not agree, you must stop using the Platform and may close your account.

22.2 Notices to you may be given through the Platform or by email to the address recorded on your account. Notices to us must be given in writing to The Circle Technologies at its registered office in Lisbon, Portugal, or through the contact channel published on the Platform.

22.3 We may assign or transfer our rights and obligations under these Terms, including in connection with a merger, acquisition or reorganisation. You may not assign your rights without our written consent.

22.4 If any provision of these Terms is held to be invalid or unenforceable, that provision will be severed and the remaining provisions will continue in full force.

22.5 No failure or delay by us in exercising a right operates as a waiver of that right.

22.6 These Terms, together with the Privacy Notice and any agreement you execute on the Platform, constitute the entire agreement between you and us in respect of the Platform.

22.7 We are not liable for any failure or delay caused by events beyond our reasonable control, including natural events, war, civil unrest, terrorism, epidemic, failure of utilities or telecommunications, cyber-attack, or action of a public authority.

22.8 These Terms are drafted in English, which is the governing language. Any translation is provided for convenience only; in the event of conflict, the English version prevails.

22.9 A person who is not a party to these Terms has no right to enforce any of its provisions, except where mandatory law provides otherwise.

22.10 Questions about these Terms may be raised through the contact channel published on the Platform.