General Terms and Conditions of Contracting

GENERAL TERMS AND CONDITIONS OF CONTRACTING AND ANNEXES: DPA AND SUB‑PROCESSORS

PRE‑CONTRACTING INFORMATION

These General Terms and Conditions of Contracting (hereinafter, the “General Terms”) govern the remote contracting of access, trial, use and subscription of the Blind Reader software through the website https://adaptatuweb.com (hereinafter, the “Website”), owned by IMAT COMUNICACIÓN, S.L. (hereinafter, the “PROVIDER”).

Blind Reader is a technological service provided under a SaaS (Software as a Service) model; therefore, its contracting does not imply the acquisition of the software, but solely the granting of a temporary, limited, non‑exclusive and non‑transferable licence of use, subject in all cases to these General Terms.

The General Terms will remain permanently available on the Website and will remain in force unless replaced or modified through proper publication. If the User does not agree with their content, they must refrain from contracting or using the service.

The PROVIDER may modify these General Terms, as well as the rest of the Website’s legal texts or policies, for reasons such as regulatory changes, service evolution, technical improvements, feature updates or operational needs. Modifications will be published indicating their effective date and will not affect contracts already formalised, unless legally required or when they represent objective improvements for the User.

Prior to contracting or renewal, the User must review the version of the Terms in force at that time.

Contracting, registration, access to the free trial period, installation of the Plugin or use of the service implies the User’s express, full and unconditional acceptance of these General Terms.The User declares and guarantees that they have read and understood its content, that they have sufficient legal capacity to contract, that they have received the necessary pre‑contractual information, and that they understand the digital nature of the service as well as its technical and operational limitations. Acceptance shall be deemed given through positive actions by the User, such as registration, ticking acceptance boxes, or confirming the contracting or payment process.

1. PARTIES AND IDENTIFICATION

On one hand, the PROVIDER of the service is the company IMAT COMUNICACIÓN, S.L., Tax ID B60690153, registered in the Commercial Registry of Barcelona, Volume 27,629, Page 161, Sheet B‑119775, Entry 1, with registered address at Carrer Pins de Can Caralleu, 4, 08017 Barcelona (Spain), and contact email proyectos@adaptatuweb.com (hereinafter, the “PROVIDER”).

On the other hand, the USER or CLIENT is any natural or legal person who accesses, tests or contracts the Blind Reader service through the Website, duly identified during the registration or contracting process, and who accepts these General Terms and, where applicable, any specific conditions (hereinafter, the “USER”).

The User may contract as a registered user or through a simplified onboarding or direct‑access process, and is responsible for the diligent use of their access credentials as well as the accuracy of the information provided during registration or contracting.

The set of documents comprising these General Terms, the Legal Notice, the Privacy Policy, the Cookies Policy, the Data Processing Agreement (DPA) and the pre‑contractual information made available to the User governs the contractual relationship between the parties in relation to the Blind Reader service.

Contracting shall be deemed initiated when the User selects a plan and confirms the payment process through the Website, such action constituting an offer to contract by the User. The contract shall be considered perfected once the payment is duly authorised and validated through the payment gateway and the system proceeds to activate the corresponding service or licence.

Notwithstanding the above, the PROVIDER may reject, suspend or cancel contracting when justified reasons exist, including payment errors, suspected fraud, breach of these Terms or risks to the security of the service or third parties.

Access to the service may include, depending on the case, a free trial period, immediate activation after contracting, or monthly or annual subscription under the SaaS model.

2. PURPOSE OF THE CONTRACT

2.1. Purpose and nature of the service
The purpose of this contract is to regulate the conditions of access, trial, contracting and use of the Blind Reader software, as well as the legal relationship between the PROVIDER and the USER arising from its use.

Blind Reader is a technological solution provided under a SaaS (Software as a Service) model, consisting of making available to the User a digital accessibility plugin designed to improve browsing experience through automated content analysis and the activation of an assistance layer. Access to the service does not imply acquisition of the software, but the granting of a temporary, limited, non‑exclusive and non‑transferable licence of use, subject to the conditions of this contract.

2.2. Scope of the service included
Depending on the selected plan, the service includes access to the Blind Reader Plugin, automated analysis of the User’s web pages, accessibility features and navigation assistance, as well as updates, improvements and maintenance of the software during the subscription period.

The provision of the service may also include technical support under the terms established for each plan, without this implying any obligation to provide additional services not expressly included in the contracting.

2.3. Excluded services
Services not expressly included in the contracted plan are expressly excluded from the scope of the contract, including, among others, legal audits or official accessibility certifications, legal or regulatory consultancy, web development, technical modifications to the User’s website, or custom implementations not included in the standard plans.

These services may be contracted separately through a specific agreement between the parties.

2.4. Access modalities
Access to the service may be provided through a free trial period when available, monthly or annual SaaS subscription, or customised enterprise plans (Enterprise), depending on the offer in force at any given time.

In all cases, the service is provided under a limited, non‑exclusive, non‑transferable and revocable licence of use, without implying any transfer of intellectual property rights over the software.

2.5. Service provision and activation conditions
The provision of the service shall be subject, where applicable, to the proper completion of the registration or contracting process, payment validation through the enabled gateway, and the technical activation of the licence by the system.

Contracting shall be deemed formalised upon selection of the corresponding plan, express acceptance of these General Terms, and confirmation of the payment or service activation process.

2.6. Pre‑contractual information and contractual closure
By accepting these Terms, the User declares that they have previously received clear, sufficient and understandable information regarding the digital nature of the service, its main functionalities, its technical limitations and the applicable economic conditions, and undertakes to comply fully with them.

Likewise, the parties expressly agree that the contract is concluded exclusively on the basis of these General Terms, and that neither party has relied on statements, promises or information not expressly incorporated herein.

3. NATURE AND DESCRIPTION OF THE SERVICE

3.1. Nature of the service and operation
Blind Reader is software designed to improve digital accessibility through automated technologies that adapt web navigation for users with different needs.

The service is provided remotely, without requiring mandatory local installation, and may require the integration of scripts or technical configurations on the User’s website for proper operation.

The PROVIDER will make reasonable efforts to keep the service updated, operational and aligned with technical accessibility standards, without this implying any guarantee of specific results or automatic regulatory compliance.

3.2. Continuity, availability and interruptions
The service is provided under a continuous SaaS model, subject to the technical, technological and operational conditions inherent to this type of solution.

The PROVIDER will make reasonable efforts to ensure the availability and continuity of the service; however, the User acknowledges and accepts that uninterrupted operation or the complete absence of incidents cannot be guaranteed.

The service may be temporarily affected by scheduled or urgent maintenance, system updates, functional improvements, technical incidents, failures in infrastructures or services of third‑party technology providers, interruptions in telecommunications networks, or force majeure events.

Such incidents will be handled with reasonable diligence for their resolution, without generating automatic liability for the PROVIDER or any right to compensation, indemnification or refund, unless legally required or attributable to the PROVIDER.

3.3. Plans, pricing and economic conditions
Service prices are expressed in euros (€) and displayed prior to contracting, together with information regarding applicable taxes.

Unless expressly stated otherwise, prices do not include indirect taxes, which will be added in accordance with the applicable tax regulations.

The available plans may include Basic, Premium and Enterprise modalities, each with its own functionalities, usage limits and economic conditions.

The PROVIDER may modify prices, plans or service features, without affecting active subscriptions during their current term. Changes will apply only to renewals or new contracts, with prior notice when relevant.

3.4. Promotional codes
The PROVIDER may offer coupons or promotional codes as an incentive for contracting the Blind Reader service, applicable exclusively to the subscription of the plans available on the Website.

Each coupon or promotional code shall be for limited use, personal when so indicated, and non‑transferable, and may not be sold, assigned or combined with other discounts or promotions unless expressly stated otherwise in its specific conditions.

The USER shall be responsible for correctly entering the promotional code during the contracting process and for verifying that the discount has been properly applied before completing the payment. Retroactive application of coupons will not be accepted once the contracting has been formalised.

The conditions of each promotion, including its validity period, scope, applicable discounts and any possible limitations, shall be those specifically indicated in each promotional campaign or in the coupon itself, and shall be subject to these General Terms.

The PROVIDER reserves the right to modify, suspend or cancel promotional coupons at any time for commercial, technical or fraud‑related reasons, without affecting coupons already validly applied in accordance with their conditions.

In the event of improper, fraudulent or non‑compliant use of a promotion, the PROVIDER may cancel the applied discount, suspend access to the service or limit the USER’s participation in future promotions, adopting proportionate and justified measures.

3.5. Digital nature and access to the service
The User acknowledges that the service constitutes a digital provision with immediate access, without physical product delivery, based on a software usage licence.

Consequently, there are no shipping costs or physical deliveries, and access to the service is activated immediately after contracting or during the free trial period when applicable.

Use of the service is subject to the validity of the subscription and compliance with these General Terms.

4. CONTRACTING PROCESS

4.1. Registration, access and accuracy of information
To access the Blind Reader service, the User must complete the registration form or the contracting process enabled on the Website, providing at all times truthful, accurate, complete and up‑to‑date information necessary for the proper provision of the service.

Access may be arranged, depending on the case, through user registration, creation of a customer account or simplified onboarding or direct contracting processes.

The PROVIDER reserves the right to reject, suspend or cancel access when there are indications of false or inaccurate data, fraudulent use, breach of these Terms or any conduct that may compromise the security or integrity of the service.

4.2. Free trial of the service
The PROVIDER may offer, when enabled, a 15‑day free trial period during which the User may access the service at no cost and without any obligation to contract.

During this period, the User may evaluate the functionalities of the Plugin, with limited and temporary access, without this generating any commitment of continuity or subscription.

The trial period is not automatically renewable, does not imply any obligation to contract afterwards, and may be modified, suspended or cancelled by the PROVIDER for technical, operational or commercial reasons.

Once the trial period has ended, access to the service will be automatically deactivated if the User does not formalise an active subscription.

4.3. Subscription contracting and contracting process
Contracting of the service is carried out by selecting an available plan (Basic, Premium or Enterprise) and confirming payment through the enabled payment gateway.

The User will receive electronic confirmation containing the details of the contracted service, the price and information regarding activation of access.

Contracting shall be subject to proper payment authorisation and technical validation by the system.

4.4. Nature of the contract and perfection
The User acknowledges that contracting the service constitutes a request for access to a digital service under a SaaS model, fully accepting these General Terms.

The contract shall be deemed perfected when the PROVIDER activates the service following payment validation.

Such activation determines the effective start of service provision and the User’s access to the contracted functionalities.

4.5. Legal capacity and User responsibility
Contracting is intended for natural persons over 18 years of age and legally constituted legal entities.

When acting on behalf of an entity, the User guarantees that they hold sufficient powers of representation. In all cases, the User shall be responsible for the accuracy of the data provided during registration and contracting.

The PROVIDER may request supporting documentation at any time and suspend or deny access in case of non‑compliance.

4.6. Access modalities and credentials
Access to the service may be carried out through a registered user account, direct onboarding during the contracting process, or enterprise access (B2B / Enterprise).

The User is responsible for safeguarding and properly using their access credentials, as well as for any activity carried out from their account, unless resulting from unauthorised use not attributable to the User.

The PROVIDER shall not be liable for damages arising from loss, misuse or negligent handling of credentials.

4.7. Suspension or denial of the service
The PROVIDER may suspend, limit or cancel access to the service when there are reasonable indications of fraudulent or abusive use, contractual breach, system manipulation or security risks for the platform, other users or third parties.

5. PRICES, BILLING AND TAXATION

5.1. Fees and economic conditions
The service prices shall be those published on the Website at the time of contracting or renewal, or those established in specific commercial proposals in the case of customised (Enterprise) plans.

Unless expressly stated otherwise, prices do not include indirect taxes, which will be applied in accordance with the regulations in force at any given time.

The PROVIDER may modify prices or economic conditions without affecting active subscriptions during their current term. Changes will apply to renewals or new contracts, with prior notice when applicable.

The fees displayed on the Website are considered final prices, except in cases of manifest material or typographical error.

5.2. Electronic invoicing and invoice format
Billing for the service will generally be carried out in electronic format. The User expressly accepts the receipt of invoices by digital means, which will be sent to the email address provided during the contracting process or made available in the customer area when this functionality is available.

The User may request the issuance of the invoice in paper format at any time, without any additional cost or charge of any kind.

The User undertakes to provide complete, truthful and up‑to‑date information for the correct issuance of invoices with fiscal validity, including, where applicable, company name, NIF/VAT number and tax address.

Invoices may be issued in full or simplified format in accordance with the applicable tax regulations at any given time.

5.3. Applicable taxation
The Blind Reader service constitutes a digital service provided under a SaaS model, subject to the tax regulations in force at any given time.

The application of taxes will depend on the User’s status and place of residence or establishment:

In Spain (Peninsula and Balearic Islands), Value Added Tax (VAT) will be applied at the rate in force at any given time.

In the Canary Islands, Ceuta and Melilla, the service is not subject to VAT, and the corresponding indirect taxes will apply in accordance with their specific regulations (IGIC, IPSI or others).

For users established in the European Union acting as businesses or professionals and holding a valid and verified intra‑community VAT number, the reverse charge mechanism may apply in accordance with the applicable regulations.

For final consumers established in the European Union, the VAT of the country of consumption will apply, in accordance with the regulations on electronic commerce and, where applicable, through the OSS (One Stop Shop) scheme.

For users established outside the European Union, the applicable tax treatment will depend on the regulations of the destination country or any applicable international tax obligations.

The PROVIDER shall not be responsible for any additional taxes, duties or charges that may be required under the User’s national regulations.

6. PAYMENT METHOD AND TRANSACTION SECURITY

Payment for the services associated with Blind Reader shall be made exclusively through the Stripe payment gateway, an external provider specialised in the secure management of electronic payments. The User must follow the contracting process indicated on the Website, selecting the corresponding plan and confirming the operation through the enabled gateway, with the final price, including taxes where applicable, clearly displayed before payment acceptance.

The User acknowledges that Stripe acts as an independent payment service provider, accepting its terms of use and privacy policies as part of the contracting process.

Payment processing is carried out entirely through Stripe, and the PROVIDER does not access, store or process the User’s full payment method data at any time, such as card numbers or banking credentials.

In the case of card payments, the operation shall be subject to the verifications and authorisations of the issuing entity. If the operation is not authorised, the contract will not be perfected and the service will not be activated.

The User guarantees that they are the holder of the payment method used or that they have sufficient authorisation for its use, being responsible for any improper use thereof.

The PROVIDER shall not assume any liability arising from fraudulent or unauthorised use of the payment methods employed by the User.

To ensure transaction security, payments are carried out using Strong Customer Authentication (SCA) systems, in accordance with the European PSD2 regulation where applicable, and each operation is identified by a unique code generated by the payment gateway.

The PROVIDER reserves the right not to activate the service until payment has been correctly confirmed, to suspend activation in the event of a rejected or pending operation, and to carry out anti‑fraud checks when deemed necessary.

In the case of recurring subscriptions, the User accepts that charges may be recurrent according to the contracted plan, including automatic renewals unless previously cancelled as established in these General Terms.

The PROVIDER may retry payment collection in the event of non‑payment and temporarily suspend access to the service until payment is regularised.

7. DURATION, RENEWAL, CANCELLATION AND LICENCE OF USE

7.1. Duration of the contract
This contract shall have the duration corresponding to the subscription plan selected by the User, whether monthly, annual or any other modality that may be offered on the Website or under specific conditions (including Enterprise plans).

The contract shall enter into force at the moment the service is effectively activated, which will occur after proper confirmation and validation of payment or, where applicable, after activation of the free trial period.

Access to the service will be maintained throughout the contracted period, provided that the subscription remains active and no cause for suspension or termination arises in accordance with these General Terms.

7.2. Automatic renewal of the subscription
Subscriptions contracted on a recurring basis will be automatically renewed for successive periods of the same duration as the initial term, unless the User expresses their intention to cancel before the effective renewal date.

Renewal will be carried out under the same economic and functional conditions in force at the time of the original contracting, without prejudice to price or condition updates, which will only apply to new contracts or renewals duly communicated to the User in accordance with applicable regulations.

The User expressly accepts this automatic renewal system as an integral part of the SaaS service model and may deactivate or cancel it at any time as established in this clause.

The User may cancel automatic renewal easily, accessibly and at any time from their customer area or through the enabled channels, without disproportionate additional requirements.

7.3. Cancellation of the subscription
The User may cancel the automatic renewal of the service at any time, without the need for justification, through the means enabled in their customer area or by submitting a request to the PROVIDER’s customer support service.

Cancellation will prevent future renewal of the subscription, but will not affect the period already paid for, during which the User will retain access to the service until the end of the current billing cycle.

Consequently, cancellation does not imply the immediate termination of the contract, but rather its effective conclusion at the end of the current subscription period.

Unless otherwise required by law or in cases attributable to the PROVIDER, no full or partial refund of amounts paid for the current period shall be issued.

7.4. Effects of contract termination
Once the subscription period has ended, whether due to cancellation or non‑renewal, the User will lose access to the Blind Reader service and all associated functionalities.

Likewise, the PROVIDER may proceed with the deactivation of the licence, as well as the deletion or anonymisation of data associated with the service in accordance with applicable regulations and the current Privacy Policy.

Termination of the contract does not exempt the User from fulfilling any outstanding payment obligations or any liability arising from prior use of the service.

7.5. Software licence
Contracting the Blind Reader service does not imply acquisition of the software under any circumstances, but rather the granting of a limited, non‑exclusive, non‑transferable, non‑sublicensable and revocable licence of use, linked exclusively to the validity of the contracted subscription.

This licence authorises the User to use the Plugin solely on the domains, websites or environments expressly authorised under the contracted plan, and any use outside the agreed scope is strictly prohibited.

7. DURATION, RENEWAL, CANCELLATION AND LICENCE OF USE

The User expressly accepts this automatic renewal system as an integral part of the SaaS service model and may deactivate or cancel it at any time as established in this clause.

The User may cancel automatic renewal easily, accessibly and at any time from their customer area or through the enabled channels, without disproportionate additional requirements.

Access to the service is granted exclusively for functional use, and does not entail any transfer of intellectual property, industrial rights or any other rights over the software or its components.

7.6. Licence limitations and prohibited uses
The User is expressly prohibited, unless previously authorised in writing by the PROVIDER, from:

Reproducing, copying, distributing or publicly communicating the software or its components.
Modifying, adapting or transforming the Plugin or any system element.
Performing reverse engineering, decompilation or any attempt to access the source code.
Assigning, sublicensing, renting or transferring access to the service, in whole or in part.
Using the software under conditions other than those established in these General Terms.
Bypassing or attempting to bypass system security measures, access controls or licensing mechanisms.

Failure to comply with these obligations shall entitle the PROVIDER to immediately suspend access to the service, without prejudice to any legal actions that may apply.

7.7. Specific commitment conditions (Enterprise)

The PROVIDER may establish specific commitment conditions, minimum duration requirements or particular cancellation terms for certain plans, especially in Enterprise modalities or customised agreements.

Such conditions must be expressly communicated to the User prior to contracting and shall form an integral part of the contractual agreement when applicable.

8. USER OBLIGATIONS

The User undertakes to use the Blind Reader service in accordance with applicable legislation, these General Terms, contractual good faith and generally accepted practices in the field of digital services.

In particular, the User undertakes to:

Provide truthful, accurate, complete and up‑to‑date information during registration and contracting processes.
Use the service solely for lawful and non‑fraudulent purposes.
Not introduce viruses, malware or any malicious code.
Not perform actions that may damage, interfere with or overload the service.
Not attempt to access systems, accounts or restricted data without authorisation.

The User shall be responsible for the use of the service within their digital environment and for the content managed on their website. Failure to comply with these obligations may result in suspension or termination of the service.

Likewise, the User acknowledges that the use of the service does not exempt them from complying with applicable regulations on accessibility, data protection, electronic commerce or any other legal obligations.

9. RIGHT OF WITHDRAWAL

9.1. General right of withdrawal
When the User qualifies as a consumer, they may withdraw from this contract within fourteen (14) calendar days from its conclusion, without the need for justification and without any penalty, in accordance with the applicable consumer protection regulations.

The User may communicate their decision to withdraw unequivocally by sending a written notice to the PROVIDER, indicating their identification details, the email associated with the account and the reference of the contracted service.

In the event of a valid withdrawal, the PROVIDER shall refund the amounts paid without undue delay and, in any case, within a maximum period of fourteen (14) calendar days from receipt of the withdrawal notice, using the same payment method employed in the initial transaction, unless expressly agreed otherwise.

9.2. Exception to the right of withdrawal for digital content and services
The User expressly acknowledges and accepts that the Blind Reader service constitutes digital content and a digital service provided under a SaaS model, the execution of which may begin immediately after contracting, at the User’s express request.

In this regard, the User gives their express, prior and unequivocal consent to the immediate commencement of the service during the withdrawal period, through the activation of access to the software, functionalities and Plugin.

The User acknowledges that such consent entails the effective start of the service during the withdrawal period.

In accordance with Article 103(m) of Royal Legislative Decree 1/2007, the User will lose their right of withdrawal once execution has begun with the User’s prior express consent and after being informed of the loss of this right. This consent shall be independent from and not conditioned upon acceptance of the General Terms.

The granting of this consent shall be carried out through a separate and explicit positive action during the contracting process, consisting of the express acceptance of this condition by ticking the dedicated checkbox, separate from the general acceptance of the General Terms.

9.3. Free trial period
During the free trial period, when applicable, no payment is made and the User has no obligation to contract.

The User may stop using the service at any time during this period without needing to exercise the right of withdrawal.

The end of the trial period without contracting does not generate any economic obligation for the User.

10. WARRANTIES, NATURE OF THE SERVICE AND LIMITATION OF LIABILITY

10.1. Nature of the service and absence of guaranteed results
The PROVIDER guarantees the provision of the Blind Reader service with the professional diligence required under the current state of the art, without this implying any guarantee of specific results or error‑free or interruption‑free operation.

However, the User acknowledges that the service is a technological tool designed to assist digital accessibility through automated processes, intended to improve browsing experience, without guaranteeing specific results, defined performance levels or automatic regulatory compliance.

In particular, the PROVIDER does not guarantee the absence of errors, interruptions, incompatibilities or technical incidents arising from the nature of SaaS services or from third‑party infrastructures, networks or services.

10.2. No guarantee of regulatory compliance in accessibility
The Blind Reader service does not constitute an official digital accessibility certification, nor a complete legal or technical audit, nor does it guarantee full compliance with applicable accessibility regulations, including WCAG, EN 301 549 or any other national or international standard.

The PROVIDER does not guarantee that the use of the service will eliminate all accessibility barriers or ensure regulatory compliance of the User’s website, as its operation depends on multiple technical, configuration and content‑related factors.

The service must be understood exclusively as a complementary technological tool to assist digital accessibility, and does not replace professional audits, legal advice or certification processes.

10.3. User obligations
The User assumes primary responsibility with respect to:

Assessing the regulatory compliance of their website.
Implementing the necessary technical, legal and organisational measures for such compliance.
Continuously verifying compliance with the applicable regulations.

The User expressly acknowledges that the use of the service does not exempt them from complying with any legal obligations applicable to them, including, among others, those relating to digital accessibility, data protection, electronic commerce and other applicable sectoral regulations.

10.4. Limitation of liability
To the maximum extent permitted by applicable law, the PROVIDER shall not be liable for:

Temporary service interruptions, scheduled maintenance or technical incidents.
Failures arising from third‑party infrastructures, networks or services.
Improper use of the service or incorrect configurations made by the User.
Results that do not meet the User’s subjective expectations.
Decisions made by the User based on the use of the service.
Penalties, claims or any consequences arising from the User’s regulatory non‑compliance when acting within their business or professional activity or using the service in such context.

In all cases, the User acknowledges that the service is a technological tool designed to assist digital accessibility and not a certification system nor a guarantee of automatic regulatory compliance.

The PROVIDER’s liability, where legally applicable, shall be limited to the amount actually paid by the User for the service during the subscription period in which the event giving rise to the claim occurred, except in cases of wilful misconduct or gross negligence.

This limitation shall not apply to liability arising from personal data protection nor to cases in which mandatory law does not allow such limitation, including, where applicable, personal injury, wilful misconduct or gross negligence.

10.5. Legal liability exclusions
Nothing in these Terms shall exclude or limit the PROVIDER’s liability in cases where such exclusion or limitation is not legally permitted, including, in particular, cases of wilful misconduct, gross negligence or breach of essential obligations under applicable law.

11. INTELLECTUAL AND INDUSTRIAL PROPERTY
All intellectual and industrial property rights over the Blind Reader service—including software, source code, object code, system architecture, algorithms, interfaces, design, databases, technical documentation, trademarks, logos, texts and any associated elements—are the exclusive property of the PROVIDER or its licensors.

Access to the service does not imply any transfer, assignment or additional licence over such rights, beyond the limited, non‑exclusive, non‑transferable and revocable right of use granted to the User during the validity of the subscription.

The User is expressly prohibited from:

Copying, reproducing or distributing the software or its components.
Modifying, decompiling or performing reverse engineering on the system.
Creating derivative works or products based on the service.
Accessing or attempting to access the source code.
Circumventing security measures or access controls.

Failure to comply with these obligations may result in the immediate suspension of the service and any corresponding legal actions.

The PROVIDER reserves all rights over improvements, updates or future developments of the service, even when derived from User feedback or usage.

12. LINKS TO THIRD-PARTY WEBSITES

The Website and the Blind Reader service may include links, hyperlinks or integrations that redirect to websites, platforms, services or digital resources managed by third parties, including but not limited to technology providers, payment platforms, analytics services, external documentation or complementary tools.

These links or accesses are provided solely for the purpose of offering the User additional information, complementary functionalities or access to services that may be useful in connection with the use of the plugin.

The PROVIDER does not permanently control the content or operation of such third-party sites or services and therefore cannot guarantee their availability, continuity, accuracy, updating, quality, legality or compliance with applicable regulations at any given time.

Consequently, the PROVIDER assumes no responsibility for the content, services, products, information, additional links or privacy practices of such third parties, being liable only in cases legally established and when there is wilful misconduct or negligence directly attributable to the PROVIDER in the selection or maintenance of the link.

Likewise, the User acknowledges that third-party sites or services may use their own cookies, tracking technologies or analytics systems, over which the PROVIDER has no control or responsibility. Such practices shall be governed exclusively by the corresponding third party’s privacy and cookie policies.

13. INFORMATION ON THE PROCESSING OF PERSONAL DATA

In accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 on Personal Data Protection and Digital Rights (LOPDGDD), the PROVIDER, in its capacity as data controller, informs Users that the personal data provided through the Website, registration forms, contracting processes, use of the Blind Reader service, technical support or any other communication channel will be processed in accordance with the applicable data protection regulations.

Personal data will be processed for the following purposes:

Managing user registration, the contractual and pre-contractual relationship, and the activation and provision of the Blind Reader SaaS service.
Enabling access, use and maintenance of the accessibility Plugin.
Managing billing, payments, renewals and service subscriptions.
Handling enquiries, technical support requests, incidents or claims.
Ensuring the security, maintenance and improvement of the service.

Where applicable, sending informational or commercial communications related to the service, when legally permitted or when the User has given express consent.

The legal basis for processing shall be, as applicable:

The performance of a SaaS service contract.
Compliance with legal obligations applicable to the PROVIDER.
The PROVIDER’s legitimate interest in improving and securing the service.
The User’s consent, when required.

The User may withdraw their consent at any time, without affecting the lawfulness of the processing carried out prior to its withdrawal.

Personal data will be retained for the time strictly necessary for the purpose for which they were collected, for as long as the contractual relationship remains in force, or for as long as legal obligations or liabilities arising from the processing exist. Once these periods have ended, the data will be blocked and retained for the legally required periods.

As a general rule, data will not be disclosed to third parties except where legally required or when necessary for the proper provision of the service. In this regard, technology providers, hosting services, communication tools, technical support, analytics services and payment gateways such as Stripe may have access to personal data, acting as data processors in accordance with Article 28 of the GDPR. These providers may, in turn, rely on duly authorised sub‑processors under appropriate contractual safeguards.

The User may consult the updated list of processors and sub‑processors or request additional information about them through the PROVIDER’s contact channels.

The User may exercise their rights of access, rectification, erasure, objection, restriction of processing, data portability and withdrawal of consent at any time by submitting a request to proyectos@adaptatuweb.com.

The User must verify their identity by means of a valid document. Likewise, they may lodge a complaint with the Spanish Data Protection Agency (AEPD) if they consider that their rights have been violated: https://www.aepd.es.

Extended information on the processing of personal data is available in the Website’s Privacy Policy.

14. SECURITY

The PROVIDER implements appropriate and proportionate technical and organisational measures, in accordance with the current state of the art, to ensure the security, integrity, confidentiality and availability of the Blind Reader service, as well as of the information processed through it.

These measures include, among others, access control mechanisms, encrypted communications, system monitoring, software update and maintenance policies, and internal procedures aimed at preventing unauthorised access or misuse of the service.

However, the User acknowledges and accepts that no IT system or Internet‑based service can guarantee absolute security or the complete absence of vulnerabilities, technical incidents or unauthorised access, especially when public networks or third‑party services are involved.

The PROVIDER shall not be liable for damages arising from unauthorised access, unknown vulnerabilities or external attacks, provided that it has acted with the diligence required under applicable regulations.

15. FORCE MAJEURE

The PROVIDER shall not be liable for any failure or delay in the provision of the service when such failure results from force majeure or circumstances beyond its reasonable control.

By way of example, the following shall be considered force majeure events, among others:

Failures or interruptions of the Internet, telecommunications networks or cloud infrastructures.
Cyberattacks, denial-of-service (DDoS) attacks or unforeseeable security incidents.
Natural disasters, fires, floods or extreme weather events.
Labour disputes, strikes or other situations affecting normal operations.
Failures or incidents involving essential external providers required for service delivery.

Supervening regulatory changes or decisions by competent authorities that materially prevent the provision of the service.

During the existence of a force majeure event, the PROVIDER’s obligations shall be suspended without giving rise to any right to compensation for the User.

16. SUSPENSION AND TERMINATION OF THE SERVICE

Without prejudice to consumer rights where applicable, the PROVIDER may suspend, limit or terminate access to the Blind Reader service, in whole or in part, when reasonably necessary and proportionate, without prejudice to any required prior notice under applicable law, and may act immediately in cases of particular severity, including in the following situations:

Breach of these General Terms by the User.
Total or partial non-payment of amounts due once the corresponding deadline has passed.
Fraudulent, abusive or improper use of the service.
Attempts to alter, reverse engineer, decompile or gain unauthorised access to the system.
Security risks or incidents that may affect the platform, other users or third parties.
Legal requirements or orders from competent authorities.

Where reasonably possible, the PROVIDER may notify the User of the suspension or termination of the service in advance or simultaneously, indicating, where applicable, the reason for such action.

In the event of termination of the contract due to breach attributable to the User, the User shall not be entitled to a refund of any amounts paid for the current period, without prejudice to any legal actions the PROVIDER may pursue.

17. SERVICE MODIFICATIONS

The PROVIDER reserves the right to modify, update, improve or replace the Blind Reader service at any time, including its functionalities, technical features, interface, analysis modules or service conditions.
Such modifications may be made for reasons including, but not limited to:

Technological or performance improvements to the system.
Adaptations to regulatory or security changes.
Product evolution or incorporation of new functionalities.
Service optimisation or enhancement of the User experience.

When the modifications are substantial and significantly affect the use of the service, the PROVIDER will inform the User with reasonable notice, unless security or urgency reasons prevent it, without undermining the essential functionality of the contracted service.

In no case shall such modifications give rise to automatic compensation, except in cases legally established.

18. CUSTOMER SERVICE, TECHNICAL SUPPORT AND MAINTENANCE

The PROVIDER offers Users a customer service and technical support channel for managing enquiries, incidents, suggestions and requests related to the use of the Blind Reader service.

Requests may be submitted via email: proyectos@adaptatuweb.com

The service is available Monday to Friday from 9:00 to 14:00 and from 15:30 to 18:30, and closed on Saturdays, Sundays and public holidays.

The level of support may vary depending on the contracted plan (Basic, Premium or Enterprise), and may include differentiated conditions or priority or personalised support in higher-tier plans.

Response times may depend on the volume of requests, the nature of the issue and the type of plan contracted, and immediate resolution is not guaranteed unless expressly agreed or covered by a specific SLA. The PROVIDER does not guarantee minimum availability except in Enterprise plans with a specific SLA.

The support service is technical and operational in nature and does not replace legal advice, accessibility audits or external professional services.

19. OUT-OF-COURT DISPUTE RESOLUTION

If the User has any incident, claim or dispute arising from the access, use or contracting of the Blind Reader service, the parties agree to attempt an amicable resolution through the PROVIDER’s customer service and support channels, prior to initiating legal action, whenever possible.

When the User qualifies as a consumer, they may resort to the alternative dispute resolution mechanisms (ADR) provided for in the applicable consumer regulations.

The PROVIDER informs that it is affiliated with the Consumer Arbitration Board of the Barcelona City Council for the out-of-court resolution of consumer disputes, under the terms established by its regulatory framework.

Such affiliation does not imply mandatory arbitration, except in cases where applicable regulations so require, nor does it limit the User’s right to bring legal action.

Consequently, the User may submit a consumer arbitration request to said Arbitration Board when the dispute is eligible for this system, in accordance with its rules of operation and admission.

Access to these mechanisms is without prejudice to the User’s right to bring legal action before the competent courts at any time.

20. APPLICABLE LAW AND JURISDICTION

These General Terms shall be governed by and interpreted in accordance with Spanish law.

For the resolution of any conflict, dispute or claim that may arise in relation to the access, use or contracting of the Blind Reader service, as well as regarding the interpretation, performance or validity of these General Terms:

When the USER acts as a professional or business (B2B), the parties expressly submit to the Courts and Tribunals of Barcelona (Spain), expressly waiving any other jurisdiction that may correspond to them.
When the USER qualifies as a consumer (B2C), the competent courts shall be those of the consumer’s domicile, without prejudice to mandatory consumer protection rules and applicable European regulations.

If any provision of these General Terms is declared null, invalid or unenforceable, in whole or in part, such circumstance shall not affect the validity of the remaining clauses, which shall remain fully in force. The affected provision shall be replaced by another valid one that, to the extent possible, preserves the same legal effect and economic purpose.

These General Terms shall always be subject to the applicable legal and regulatory framework in force at any given time, including, where applicable, consumer law, electronic commerce regulations, data protection rules and digital services legislation.

21. MODIFICATION OF THE TERMS

The PROVIDER reserves the right to modify, update or replace these General Terms at any time, in order to adapt them to regulatory, case-law, technical or operational changes related to the Blind Reader service.

Modifications will be published on the Website indicating their effective date and will apply from that moment onwards.

When the changes are substantial and significantly affect the contractual relationship with the User, the User will be informed with reasonable notice, whenever possible.

ANNEX I – DATA PROCESSING AGREEMENT (DPA)

1. Identification of the parties
On the one hand, IMAT COMUNICACIÓN, S.L., with Tax ID B60690153, registered address at Carrer Pins de Can Caralleu, 4 – 08017 Barcelona (Spain), hereinafter, the PROCESSOR.

And on the other hand, the CLIENT / USER, a natural or legal person contracting the Blind Reader service, hereinafter, the CONTROLLER.

Both parties, acknowledging sufficient legal capacity, agree to this Data Processing Agreement pursuant to Article 28 of the GDPR.

2. Purpose of the processing
This Agreement governs the processing of personal data by the PROCESSOR, necessary for the provision of the Blind Reader service in SaaS mode, consisting of a web accessibility plugin.

The processing will be carried out solely to the extent necessary for the execution of the main contract.

3. Nature and purpose of the processing
The processing is intended to:

Enable the operation of the accessibility plugin
Automatically analyse the CONTROLLER’s website content
Provide navigation assistance functionalities
Ensure the maintenance, security and improvement of the service

The processing is ancillary to the main service.

4. Type of personal data and categories of data subjects
Data processed (potentially):

Browsing data (IP, technical identifiers, logs)
Data derived from the use of the CONTROLLER’s website
Technical data associated with the plugin’s operation

Categories of data subjects: Users/visitors of the CONTROLLER’s website.

The PROCESSOR does not intentionally access special categories of data, unless such access results from the content of the CONTROLLER’s website.

5. Duration
This Agreement shall remain in force for the duration of the Blind Reader service.

Once the contract ends, the provisions of clause 12 (data disposition) shall apply.

6. Obligations of the PROCESSOR
The PROCESSOR undertakes to:

a) Process personal data only following documented instructions from the CONTROLLER.
b) Not use the data for its own purposes.
c) Ensure confidentiality of authorised personnel.
d) Apply appropriate technical and organisational measures in accordance with Article 32 GDPR.
e) Assist the CONTROLLER in fulfilling its data protection obligations.
f) Notify without undue delay any personal data breach.
g) Make available to the CONTROLLER all information necessary to demonstrate GDPR compliance.

7. Obligations of the CONTROLLER
The CONTROLLER undertakes to:

a) Comply with applicable data protection regulations.
b) Inform data subjects about the use of the Blind Reader service.
c) Obtain user consent when necessary.
d) Determine the legal basis for the processing.
e) Ensure that the data processed are adequate, relevant and limited to what is necessary.

The CONTROLLER shall be solely responsible for the lawfulness of the processing.

8. Security measures
The PROCESSOR implements appropriate technical and organisational measures, including:

Encrypted communications (HTTPS/TLS)
Access control
System monitoring and activity logs
Vulnerability management
Backups

Security in technology providers

These measures are applied according to risk and the state of the art.

9. Sub-processors
The CONTROLLER authorises the PROCESSOR to engage sub-processors for the provision of the service.

The PROCESSOR undertakes to:

Select providers offering adequate guarantees
Formalise contracts in accordance with Article 28 GDPR
Ensure an equivalent level of protection

The list of sub-processors may be made available to the CONTROLLER upon request or through the Privacy Policy.

10. International transfers
If the PROCESSOR uses providers located outside the European Economic Area, it shall ensure:

The existence of an adequacy decision, or
The signature of Standard Contractual Clauses (SCCs), or other valid mechanisms under the GDPR

11. Data subject rights
The PROCESSOR shall assist the CONTROLLER, to the extent possible, in order to:

Respond to requests for access, rectification, erasure, objection, restriction and portability
Comply with transparency and information obligations

Nevertheless, the CONTROLLER shall be responsible for managing such requests.

12. Data disposition upon termination of the service
Once the service has ended:
The PROCESSOR shall delete or anonymise the personal data.
Data may be retained in a blocked state when there is a legal obligation to do so.
The PROCESSOR shall not use the data for any subsequent purpose.

13. Security breaches
The PROCESSOR shall notify the CONTROLLER without undue delay of any security breach affecting personal data, including:
The nature of the incident
Categories of data affected
Measures adopted

14. Audits
The CONTROLLER may request reasonable information regarding compliance with this Agreement.
Audits must:
Be proportionate and justified
Not interfere with the PROCESSOR’s operations
Respect the confidentiality and security of the service

15. Liability
Each party shall be liable for the responsibilities corresponding to them under the GDPR.
The PROCESSOR shall not be liable when the processing is carried out following unlawful instructions from the CONTROLLER.

16. Precedence
This DPA forms an integral part of the General Terms.
In the event of contradiction, the provisions of this Agreement shall prevail with respect to data protection matters.

17. Applicable law
This Agreement shall be governed by Regulation (EU) 2016/679 (GDPR) and the Spanish data protection regulations in force.

ANNEX II – LIST OF SUB-PROCESSORS

The CONTROLLER authorises the use of the following sub-processors necessary for the provision of the service:

Stripe, Inc. – Payment processing
IONOS Cloud, S.L.U. – Infrastructure and hosting
IONOS Cloud, S.L.U. – Communication services (email / support)

The updated list of sub-processors will be available in:
The Website’s Privacy Policy, or upon request at: proyectos@adaptatuweb.com