Terms and conditions

ROBEXA BEAUTY · ROBEXA EOOD · effective from 3 September 2026

SECTION I. GENERAL PROVISIONS

Article 1. (1) These Terms and Conditions govern the relationship between ROBEXA EOOD and users of the ROBEXA BEAUTY mobile application and web platform, accessible on mobile devices (iOS and Android) and through a web browser.

(2) ROBEXA BEAUTY is an online platform through which third parties — beauty salons, studios, medical establishments and training academies — publish and offer users promotional service offers, free model sessions and proposals for collaboration in creating content.

(3) By registering on the platform, the user declares that they have read, understood and accepted these Terms and Conditions, which become an integral part of the relationship between the user and ROBEXA EOOD.

(4) The platform is intended exclusively for natural persons with full legal capacity who are at least 18 years old. Registration and use by persons under 18 are not permitted.

Article 2. (1) The platform is operated by ROBEXA EOOD, UIC 208809810, with its registered office and business address at 124 Knyaz Boris I Boulevard, apartment 1, Primorski district, Varna, Bulgaria, hereinafter referred to as ROBEXA.

(2) Contact details: website www.robexa.app, email info@robexa.app, telephone +359 878 648264.

SECTION II. DEFINITIONS

Article 3. For the purposes of these Terms and Conditions:

1. Partner — a salon, studio, medical establishment, academy or other trader approved by ROBEXA that publishes its own offers through the platform.

2. Promotional offer — a proposal published by a Partner to provide a specific service at a promotional price, available only through the platform.

3. Voucher — an electronic document with a unique QR code certifying the user’s right to receive the paid service from a specific Partner under the terms stated in the offer.

4. Procedure — the service performed by the Partner on the basis of a validated voucher.

5. Virtual wallet — an internal settlement account linked to the user’s account, whose balance is used solely to pay for offers within the ROBEXA BEAUTY network.

6. Platform fee — ROBEXA’s remuneration for its own service of providing access, processing the order and issuing a voucher.

7. Academy — a Partner that provides training and publishes listings for free model sessions.

8. Model session — a free procedure performed by a trainee under an instructor’s supervision.

9. Creator — a user applying to a Beauty collaboration listing.

10. Beauty collaboration — a Partner’s proposal to perform a procedure in exchange for the creation and delivery of content.

SECTION III. THE ROLE OF ROBEXA

Article 4. (1) ROBEXA operates the platform and provides a technological service connecting users with Partners.

(2) ROBEXA does not perform the procedures, is not the provider of the beauty services or medical activities published on the platform, and is not a party to the contract between the user and the Partner. ROBEXA bears no responsibility for any procedure performed or unable to be performed; responsibility rests entirely and exclusively with the relevant salon, studio, medical establishment or academy.

(3) When selling vouchers, ROBEXA acts in the name and on behalf of the relevant Partner under express authorisation in the partnership agreement.

(4) The contract for performing the procedure is concluded directly between the user and the Partner when payment for the voucher is successfully completed on the platform.

(5) The Partner bears full and independent responsibility for:

1. the quality, safety and outcome of the procedure;

2. the qualifications and professional authorisations of its staff;

3. holding all required registrations, licences, permits and insurance;

4. the accuracy of published information, including stated prices and discounts;

5. compliance with sanitary, hygiene and other applicable requirements;

6. issuing the required fiscal and accounting documents for the procedure.

(6) The Partner’s name, UIC and registered business address are displayed on the platform before the order is confirmed and are stated on the voucher.

Article 5. (1) ROBEXA checks the commercial and registration information declared by the Partner within the scope defined in the agreement with the Partner and approves published listings before they are displayed.

(2) The check under paragraph 1 is formal and does not constitute an assessment, guarantee or certification of the quality, safety or professional suitability of the Partner or its staff.

(3) ROBEXA may refuse approval, restrict or remove a listing or Partner where there are reasonable grounds to suspect a breach of the law, these Terms and Conditions or the content rules.

SECTION IV. REGISTRATION AND ACCOUNT

Article 6. (1) Only a natural person with full legal capacity who is at least 18 years old may be a user of the platform.

(2) Basic registration uses a phone number or email address and confirmation through a one-time code.

(3) ROBEXA applies a tiered identification and verification system in which the verification level determines the applicable limits on the user’s balance:

1. basic level — registration with a phone number or email address;

2. full verification — additionally submitting an identity document (identity card or passport) and completing selfie verification.

(4) Full verification is optional. It is carried out at the user’s request and is required only for access to the higher limits under Article 9.

(5) Verification is performed through a licensed external provider. ROBEXA does not store images of identity documents or selfie captures, but only the verification result, date and reference. Data is processed solely for establishing identity and preventing misuse, in accordance with the Privacy Policy.

(6) The user account is personal and non-transferable.

(7) ROBEXA may temporarily restrict or deactivate an account where it suspects misuse, fraudulent activity, a breach of these Terms and Conditions or unusual activity, while informing the user of its reasons.

Article 7. (1) The user must provide accurate and up-to-date information.

(2) The user is responsible for safeguarding access to their account and for all actions performed through it.

SECTION V. VIRTUAL WALLET

Article 8. (1) Upon registration, a user account and virtual wallet are created. The wallet is topped up with the user’s own funds.

(2) Offers on the platform are paid for solely using the available balance in the virtual wallet.

(3) The user’s balance is an internal technical balance for use solely on the ROBEXA BEAUTY platform and does not constitute electronic money, a payment account, a deposit or a financial service within the meaning of applicable legislation.

(4) Funds added may be used solely to pay for offers, vouchers and services on the ROBEXA BEAUTY platform.

(5) The balance cannot be transferred to the user’s bank account, withdrawn in cash or transferred to another user account, except in the cases expressly provided for in these Terms and Conditions.

Article 9. (1) The balance may be topped up only by bank card (Visa/Mastercard).

(2) Top-ups are made in predefined amounts, as follows:

(3) A top-up that would exceed the maximum balance for the relevant level is not permitted.

(4) Where the value of a selected offer exceeds the maximum balance for the basic level, the user is informed in the application about the option to complete full verification.

(5) Every top-up is subject to mandatory strong customer authentication (3-D Secure) in accordance with applicable legislation.

(6) ROBEXA may request additional identification, information or documents where it suspects misuse, fraud or a breach of the law, regardless of the verification level. Until the check is completed, ROBEXA may restrict topping up and use of the balance.

(7) ROBEXA maintains registration and audit records of financial operations for security, prevention of misuse and compliance with applicable legislation.

(8) ROBEXA uses licensed external payment service providers to process card payments.

Article 10. (1) Refunds under these Terms and Conditions are made to the user’s virtual wallet.

(2) Funds refunded under paragraph 1 are immediately available for use on the platform and have no expiry date.

(3) When exercising the right of withdrawal under Article 15, the user may request a refund by reversing the card transaction used for the relevant top-up, up to the amount of that transaction. The request must be made at the same time as the withdrawal.

(4) When a user account is closed at the user’s request, the available unused balance is refunded by reversing the card transactions used to add the funds, up to their amounts and within the technically permitted reversal period under the card scheme rules.

(5) Where reversal is technically impossible — because the reversal period has expired, the card has been closed or is invalid, or the account holder has died or been placed under legal incapacity — ROBEXA may, at its discretion, make the refund by bank transfer. The transfer is made only to an account held by the user, only after successful full verification and after confirming that the names match. ROBEXA may refuse or postpone the refund where fraud is suspected, payments are disputed or a check is incomplete.

(6) A refund under paragraphs 4 and 5 is a one-time return of unused advance payment when the relationship ends. It does not constitute a right to redeem the balance on demand and cannot be exercised outside cases of account closure.

(7) If ROBEXA terminates access because of a breach, the available balance is held until the check is completed, but for no longer than 60 days, after which it is refunded under paragraph 4 unless the funds are found to originate from fraudulent or unlawful activity.

(8) If the user does not use their account for 24 months, the account is frozen without deleting the balance available at that time. It can be reactivated at any time by contacting support.

SECTION VI. PROMOTIONAL OFFERS, ORDERS AND VOUCHERS

Article 11. (1) Each promotional offer contains at least: a description of the included services, the standard price, the promotional price, the voucher’s validity period, restrictions and conditions of use, the Partner’s name and details, and the place where the procedure is performed.

(2) The stated standard price used to calculate the discount is determined and declared by the Partner and represents the lowest price applied by that Partner for the same service during the preceding 30 days before the discount was announced.

(3) The Partner is responsible for the accuracy of the information under paragraph 2 and indemnifies ROBEXA for all losses and penalties resulting from an incorrectly advertised discount.

Article 12. (1) By confirming the order, the user declares their intention to conclude a distance contract within the meaning of the Electronic Commerce Act and the Consumer Protection Act.

(2) Before the order is confirmed, the user is shown clearly and understandably: the voucher price, the platform fee and the total amount payable.

(3) Each voucher relates to a specific, individually identified service at a specific Partner. Vouchers for packages of unspecified services or for services not individually identified in the offer are not permitted.

(4) Following successful payment, the user receives a voucher with a unique QR code in their account and confirmation at the email address they provided.

(5) Payment made through the platform fully discharges the user’s obligation to the Partner at the time it is made.

(6) The Partner validates the voucher by scanning its QR code when performing the procedure. Once validated, the voucher is considered used and cannot be used again.

(7) When scanning, the Partner may return the voucher if the procedure will not be performed. In that case, the amount paid for the voucher is refunded to the user’s virtual wallet.

(8) Vouchers may not be resold or transferred outside the platform’s functionality.

Article 13. (1) A specific appointment is booked directly between the user and the Partner, outside the platform, using the procedure and contact channels stated in the offer.

(2) The voucher is valid until the date stated in the offer. After that date, it cannot be validated and the Partner has no obligation to perform the procedure.

(3) If the period under paragraph 2 expires without the voucher being used, the voucher is deactivated and the amount paid for it is refunded to the user’s virtual wallet.

(4) Platform fees already paid are not refundable in the cases under paragraph 3 and Article 12(7), as the service for which they are payable has been performed and a fiscal document has been issued for it.

(5) The user receives reminders in the application no later than 14 days and again 3 days before the voucher expires.

(6) The validity period is displayed clearly and visibly in the offer, on the order confirmation screen and on the voucher itself.

SECTION VII. FEES

Article 14. (1) For its service, ROBEXA charges the user a platform fee determined as a fixed amount based on the voucher value. The fee is set for each individual offer and may not exceed the following amounts:

(2) The exact fee for the particular offer is displayed separately and is included in the total amount under Article 12(2) before the order is confirmed.

(3) ROBEXA issues the user a fiscal document for the platform fee.

(4) The Partner issues a fiscal document for the procedure in accordance with applicable legislation.

(5) The platform fee is refundable in the cases under Article 16 (statutory withdrawal), Article 18 (inability to book an appointment for the procedure) and Article 21 (refusal on medical grounds).

SECTION VIII. RIGHT OF WITHDRAWAL

Article 15. (1) The user has the right to withdraw from the concluded contract without giving a reason within 14 days from the date of purchasing the voucher.

(2) The right of withdrawal under paragraph 1 may be exercised only for a valid and unused voucher. Upon validation of the voucher and commencement of the procedure with the user’s express consent, the service is considered performed and the right of withdrawal is lost under Article 57(1) of the Consumer Protection Act.

(3) When confirming the order, the user is expressly informed that they will lose their right of withdrawal after using the voucher and acknowledges that they are aware of this.

(4) The right of withdrawal is exercised through the application’s functionality or by an express statement sent to info@robexa.app. ROBEXA accepts the statement on behalf of the Partner.

Article 16. (1) When the right of withdrawal under Article 15 is exercised, the user is refunded all amounts received from them, including the platform fee.

(2) The refund is made to the user’s virtual wallet, which is the means of payment used for the original transaction. The user may request reversal of the card transaction under Article 10(3).

(3) The refund is made without undue delay and no later than 14 days from the date on which ROBEXA was informed of the withdrawal.

(4) The time for the amount to reach the user’s account depends on their bank and card scheme and may take up to 10 business days after the refund is initiated.

(5) The amounts under paragraph 1 are borne by the Partner. ROBEXA makes the refund on the Partner’s behalf and offsets it in the periodic financial settlement.

SECTION IX. BOOKINGS, CANCELLATIONS AND NO-SHOWS

Article 17. (1) Booking, confirming, rescheduling and cancelling appointments take place directly between the user and the Partner and are governed entirely by the Partner’s rules.

(2) ROBEXA does not participate in organising appointments, does not have information about agreed appointments and is not responsible for appointment availability, adherence to appointments or the consequences of their cancellation.

(3) The Partner must state in the offer itself its rules for booking, cancellation, rescheduling and no-shows, including the consequences for voucher validity. The stated rules may not be applied less favourably to the user than announced.

(4) The Partner may not refuse to accept a valid and unused voucher during its validity period.

(5) The Partner must provide the opportunity to book an appointment for the procedure within the voucher’s validity period, using the contact channels stated in the offer.

Article 18. (1) Where the Partner has refused or failed to provide an appointment within the voucher’s validity period, has ceased operating, has refused to accept a valid voucher or has remained unavailable through the stated contact channels, the user is entitled to a full refund of the amount paid, including the platform fee.

(2) The right under paragraph 1 is exercised by submitting a report through the platform. ROBEXA requests the Partner’s position within 3 business days. If no position is provided or the Partner does not dispute the report, the refund is made.

(3) Refunds under this Article are borne by the Partner and offset in the periodic financial settlement.

Article 19. The Partner’s rules under Article 17 do not restrict or exclude the statutory right of withdrawal under Section VIII. Where both regimes apply simultaneously, the user is entitled to the more favourable one.

SECTION X. PERFORMANCE OF THE PROCEDURE

Article 20. (1) The user must attend at the agreed time and follow the Partner’s instructions on preparation for the procedure.

(2) The user must inform the Partner of all circumstances that may constitute a contraindication to performing the procedure.

(3) The Partner may refuse to perform a procedure where a contraindication exists, the user is underage, preparation requirements have not been followed, or there are other grounds provided for by law or professional standards.

Article 21. (1) Where the Partner refuses to perform the procedure on medical grounds or because of an identified contraindication, it returns the voucher through the platform and the amount paid for it is refunded to the user’s virtual wallet.

(2) The refund under paragraph 1 is made in accordance with Article 16(2) and (3).

Article 22. (1) Claims concerning the quality, performance or outcome of the procedure are made against the Partner as the service provider.

(2) ROBEXA provides a technical means to submit a report through the platform and forwards it to the Partner within 2 business days, assisting communication between the parties.

(3) The assistance under paragraph 2 does not constitute ROBEXA assuming responsibility for the procedure.

SECTION XI. SPECIAL RULES FOR MEDICAL PROCEDURES

Article 23. (1) The Partner declares that it holds all registrations, licences and permits required for the procedures it offers. It is entirely responsible for obtaining and maintaining them.

(2) Such procedures are performed only by persons who hold the relevant professional qualifications and authorisations.

(3) Informed consent for a medical procedure is given by the patient directly to the medical establishment in the form required by law. The platform does not collect, store or replace informed consent.

(4) Information published on the platform is a commercial communication and does not constitute medical advice, a diagnosis, a treatment recommendation or a guarantee of results.

(5) The medical establishment assesses whether the procedure is appropriate following an examination. Purchasing a voucher does not guarantee that the procedure will be performed.

(6) The medical establishment bears responsibility for complications in accordance with applicable legislation.

SECTION XII. FREE MODEL SESSIONS (ACADEMY)

Article 24. (1) Academies publish listings for free procedures performed by trainees under an instructor’s supervision.

(2) Each listing contains the mandatory notice: “The procedure is performed by a trainee under an instructor’s supervision.” The notice is also reproduced in the confirmation and on the attendance QR code.

(3) The procedure itself is free. The user pays:

1. an attendance deposit, set by the Academy for each individual listing, which may not exceed EUR 10.00; the Academy may also set the amount to zero, in which case no deposit is payable;

2. a platform fee of EUR 0.50 for booking a model session.

(4) The deposit under paragraph 3, item 1 is not a payment, part payment or advance payment for the procedure, but security for attendance.

(5) The platform fee under paragraph 3, item 2 is ROBEXA’s remuneration for connecting the user with the Academy and is non-refundable because the service is performed when the booking is made.

(6) The deposit amount is displayed in the listing and before the booking is confirmed.

Article 25. (1) If the user attends, the deposit is refunded to their virtual wallet within 2 business days after attendance is confirmed by QR code.

(2) If the user cancels more than 24 hours before the session, the deposit is refunded in full.

(3) In the event of a no-show without notice, the deposit is not refunded to the user and is paid to the Academy after deducting the fee it owes under its agreement with ROBEXA. Where the Academy has set a zero deposit, this paragraph does not apply.

(4) If the Academy cancels the session, is more than 30 minutes late, or the session is terminated due to the Academy’s fault, the deposit is refunded in full and the user is entitled to priority booking for a subsequent session.

Article 26. (1) The Academy bears full responsibility for the actions of its trainees and instructors and for damage caused during a model session.

(2) Requirements applicable to the Academy, including insurance requirements, are governed by its agreement with ROBEXA.

SECTION XIII. BEAUTY COLLABORATIONS

Article 27. (1) A Partner may publish a listing offering to perform a procedure in exchange for the creation and delivery of content.

(2) The listing specifies in advance: the procedure offered, location and number of places, the required type and quantity of content, delivery deadlines, applicant requirements and content usage rights — channels, duration, territory and whether paid advertising is permitted.

(3) Applying does not constitute a purchase and does not follow the voucher process. The Partner selects the participant.

Article 28. (1) The relationship concerning the creation and use of content is governed by a separate agreement between the Creator and the Partner, concluded through the platform.

(2) ROBEXA provides the technical means to conclude the agreement under paragraph 1 and is not a party to it.

(3) The Creator gives express and separate consent to the use of their image and voice; such consent is not presumed from participation in the collaboration.

(4) The Creator must identify the content as a commercial communication in accordance with applicable legislation. Failure to label the content constitutes a breach of these Terms and Conditions.

(5) The parties are informed that exchanging a procedure for content constitutes a reciprocal supply with tax consequences for both parties, for which each is independently responsible.

SECTION XIV. CHAT AND COMMUNICATION

Article 29. (1) The platform provides internal communication functionality between users and Partners.

(2) Chat is used solely for organisational matters relating to a specific offer, appointment or application.

(3) It is prohibited to exchange information about health conditions, diagnoses, medical documents or medical images through chat. For such communications, the user contacts the Partner directly following the Partner’s established procedure.

(4) Using chat for insults, harassment, advertising messages, arranging payments outside the platform or any unlawful content is prohibited.

(5) ROBEXA may restrict access to chat functionality if the rules are breached, while informing the user of the reasons.

(6) Messages are retained for 12 months in accordance with the Privacy Policy.

SECTION XV. PROHIBITED CONDUCT

Article 30. (1) Using the platform for fraudulent activity, creating false accounts, payment misuse, unjustified chargeback proceedings, automated use or circumvention of functionality is prohibited.

(2) Arranging and making payments outside the platform for offers published on the platform is prohibited.

(3) Where misuse is suspected, ROBEXA may temporarily restrict access, freeze the account, cancel vouchers or hold the available balance until a check is completed, while notifying the user.

SECTION XVI. MODERATION, REPORTS AND COMPLAINTS

Article 31. (1) Any person may report illegal content or content that violates the rules through the platform’s functionality or at info@robexa.app.

(2) ROBEXA reviews the report promptly and informs the reporter of the action taken.

(3) When removing content, restricting visibility or suspending an account, ROBEXA provides the affected person with a reasoned statement of the grounds, including the legal or contractual basis and information about available avenues of appeal.

(4) The affected person may challenge the decision within 14 days through the internal procedure at info@robexa.app.

Article 32. (1) The user may submit an objection or complaint about ROBEXA’s service to info@robexa.app. ROBEXA responds within 14 days.

SECTION XVII. PERSONAL DATA

Article 33. (1) ROBEXA processes personal data in accordance with the Privacy Policy, which forms an integral part of these Terms and Conditions.

(2) ROBEXA is the personal data controller for data relating to registration, the account and the operation of the platform.

(3) For data necessary to organise and perform the procedure, ROBEXA and the Partner are independent controllers, each for its own purposes and on its own legal basis.

(4) Offers on the platform are aesthetic and cosmetic in nature. ROBEXA does not process medical records or collect health data.

SECTION XVIII. LIABILITY

Article 34. (1) ROBEXA is not responsible for:

1. the performance, quality, safety and outcome of procedures;

2. acts and omissions of the Partner and its staff;

3. the accuracy of information published by the Partner;

4. damage arising during or in connection with a procedure.

(2) ROBEXA does not guarantee uninterrupted or error-free operation of the platform and is not responsible for temporary unavailability due to technical maintenance, failures or circumstances beyond its control.

(3) The limitations under paragraphs 1 and 2 do not apply where liability cannot be limited under mandatory provisions of law.

SECTION XIX. AMENDMENTS

Article 35. (1) ROBEXA may amend these Terms and Conditions by publishing them on the website and in the application and notifying users no later than 15 days before they take effect.

(2) Changes have no retroactive effect and do not affect vouchers already purchased or contracts already concluded.

(3) Changes to these Terms and Conditions do not apply to balances already topped up, which remain usable under the terms in effect when the funds were added.

SECTION XX. DISPUTES

Article 36. (1) Users have access to out-of-court dispute resolution procedures through the general conciliation commissions of the Commission for Consumer Protection.

(2) Contact details: Commission for Consumer Protection, 4A Slaveykov Square, floors 3, 4 and 6, Sofia 1000, Bulgaria, telephone 0700 111 22, www.kzp.bg.

(3) These Terms and Conditions are governed by the laws of the Republic of Bulgaria.

(4) Disputes not resolved by mutual agreement are referred to the competent Bulgarian court, without prejudice to users’ rights under the applicable consumer protection legislation in their country of habitual residence.