TERMS OF USE AND PRIVACY POLICY SEBP PLATFORM

This document establishes the Terms of Use and Privacy Policy governing the SEBP Platform. SEBP operates as a digital marketplace and intermediary service connecting Employees, Companies, and Producers within a sustainable economic ecosystem. By accessing or using SEBP, users acknowledge that they have read, understood, and agreed to these terms. If a user does not agree, they must discontinue use immediately.

TERMS OF USE

Article 1 – Definitions

• “The Good Club LTD” – CIN 207747423. The managing entity of SEBP.

• “The Good Club Platform” – A web-based and mobile platform facilitating:

  • Transactions between Employees and Producers via a marketplace.

  • Voucher-based payments, allowing Employees to redeem Company-issued vouchers.

  • Sustainability assessments for Producers based on the Sustainability Methodology.

  • Impact metrics reporting for Companies, tracking sustainability-related transactions and voucher usage.

• “User” – Any individual or entity utilizing SEBP, categorized as an Employee, a Company, or a Producer.

• “Employee” – An individual registered on SEBP who can purchase from Producers and redeem vouchers issued by their employer.

• “Company” – A registered entity that issues vouchers to Employees and accesses impact metrics based on platform transactions. Participation requires a bilateral agreement with The Good Club.

• “Producer” – A seller offering products through SEBP’s marketplace and/or voucher program. Registration requires a sustainability assessment and a bilateral agreement with The Good Club.

• “Voucher” – A digital credit issued by a Company that Employees can redeem for products from eligible Producers within SEBP or on external Producer platforms.

• “Transaction” – Any exchange within SEBP, including marketplace purchases and voucher redemptions.

• “Impact Metrics” – Sustainability-related indicators, used to assess Companies’ impact and contributions to sustainable production and consumption.

• “Data U” – A GDPR compliance tool within SEBP that ensures lawful data processing, transparent consent management, and secure user data rights exercise.

Article 2 – Scope of Services

The SEBP Platform serves as an intermediary marketplace, facilitating interactions between Employees, Companies, and Producers. Through the Platform:

• Employees can purchase products from Producers using either personal funds or vouchers issued through the platform on behalf of the Companies as part of a corporate sustainability initiative.

• Vouchers issued through the Platform may be redeemed at the external producer marketplace venues, subject to the terms and conditions established by the issuing Companies and Producers.

• Companies gain access to a real-time impact metrics dashboard and sustainability-related data reports, which aggregate and analyze transaction data. These reports are generated based on Platform transactions and are intended to support ESG reporting and Corporate Social Responsibility (CSR) strategies.

• Producers may:

  • Sell their products through the Platform.

  • Participate in the voucher program, allowing them to accept vouchers issued through the platform on behalf of the Companies.

  • Undergo sustainability evaluations, which assess their sustainability performance in accordance with the Platform’s Sustainability Methodology. Producer participation is subject to annual re-evaluation.

• SEBP acts solely as an intermediary and is not responsible for:

  • The sale, delivery, or quality assurance of products and services offered by Producers.

  • The accuracy or completeness of sustainability data statements provided by Producers.

  • Monitoring of the purpose usage by producers of the financial flow received through the Platform.

Article 3 – Company Registration

Companies join the SEBP Platform through direct onboarding, which requires signing a bilateral agreement with The Good Club.

The agreement defines the terms of participation, including:

• Voucher program details, such as but not limited to - allocated budget, issuance frequency, and amount.

• Subscription fees for accessing the platform.

• Access to analytics and sustainability impact data reports to support ESG reporting.

Once registered, companies gain access to a real-time impact dashboard, allowing them to monitor aggregated transaction data and sustainability contributions.

Article 4 – Employee Registration

Employees create a personal account on SEBP.

• During registration, they are redirected to Data U, a GDPR-compliant tool, where they must provide explicit consent regarding the collection and processing of their personal data.

• Employees are not obligated to use the platform or employer-issued vouchers.

Article 5 – Producer Registration

Producers must pass a preliminary sustainability evaluation based on the Sustainability Methodology before being approved for the platform.

The evaluation includes:

• An initial sustainability assessment.

• An annual reassessment to maintain compliance.

Producers must enter into bilateral agreement with The Good Club, defining:

• The type of participation either through the marketplace and/or the voucher program.

• The intermediary fee and conditions for payment.

Producers that fail to meet sustainability evaluation re-assessment obligation may be denied platform access or have their accounts suspended until compliance is restored.

Article 6 – Employee Rights and Responsibilities

Employees have the right to:

• Freely choose whether to use the platform and employer-issued vouchers.

• Make purchases using either personal funds or vouchers issued through the platform.

• Request issuing a voucher.

• Access to a data wallet with the issued vouchers.

• Access personal spending and impact statistics.

• Their data rights as specified in Privacy Policy.

Employees are responsible for:

• Keeping their account credentials secure.

• Ensuring they use the platform in compliance with applicable regulations and company policies.

Article 7 – Producer Rights and Responsibilities

Producers have the right to:

• Sell their products via SEBP’s marketplace.

• Participate in the voucher program, subject to their agreement with The Good Club.

• Access sustainability evaluations and receive insights into their performance through Producer Dashboard.

Producers are responsible for:

• Providing accurate and truthful information about their sustainability performance.

• Undergoing an annual sustainability reassessment.

• Complying with the terms of their agreement with The Good Club.

• Ensuring product quality and service delivery, as SEBP does not guarantee product claims.

Article 8 – Company Rights and Responsibilities

Companies have the right to:

• Allocate budgets and define the conditions of their voucher issuance.

• Access real-time impact metrics through the company dashboard.

• Receive a sustainability data report based on platform transactions once per year in accordance with the bilateral agreement between the company and the Good Club.

Companies are responsible for:

• Ensuring compliance with the terms of their bilateral agreement with The Good Club.

• Using platform data for ESG reporting in accordance with applicable regulations.

• Keeping financial and transactional records in line with their own legal obligations.

Article 9 – Acceptable Use and Restrictions

Users shall not engage in fraudulent activities, misuse voucher-based transactions, access unauthorized data, or use the platform in violation of applicable laws. SEBP reserves the right to suspend or terminate accounts violating these provisions.

Article 10 – Marketplace

SEBP facilitates, but does not control, marketplace transactions between Employees and Producers. The platform serves only as a technological intermediary, allowing Producers to list their products and Employees to purchase them using personal funds or vouchers.

Producers are solely responsible for:

• Ensuring the accuracy and completeness of their product listings, including descriptions, prices, and availability.

• Updating their product catalog to reflect real-time availability and ensure that Employees receive up-to-date information.

• Compliance with all applicable laws and regulations, including product safety, consumer protection, and fair trade policies.

• Handling the sale, delivery, and any necessary after-sales support directly with Employees.

SEBP does not:

• Own, sell, or guarantee any product or service listed on the platform.

• Verify the authenticity, legality, or quality of products and services offered by Producers.

• Process or handle financial transactions beyond the provision of technical payment mechanisms.

Producer Choice:

• Producers may choose to participate in the marketplace, the voucher program, or both.

• If a Producer opts to only accept vouchers, they are not required to list their products on SEBP but must ensure that voucher redemption is available within their own online marketplace, subject to agreement with SEBP.

• Producers who participate in the marketplace must accept transactions made with both personal funds and vouchers.

Article 11 – Voucher Transactions

Voucher Issuance and Use

• Vouchers are issued by the platform on behalf of the Companies to Employees as part of their sustainability and corporate benefits programs.

• Employees may use these vouchers:

  • On the SEBP platform for purchases from registered Producers.

  • On a Producer’s external marketplace, if the Producer has agreed to accept SEBP vouchers outside of the platform.

• Vouchers must be used within six (6) months from the date of issuance. After this period, unused vouchers will expire and will no longer be redeemable.

• SEBP guarantees voucher acceptance by all Producers.

• Companies are responsible for the availability of their allocated voucher budgets, ensuring they comply with their bilateral agreements with SEBP and The Good Club.

Producer Participation in the Voucher Program

• Producers who wish to accept SEBP vouchers outside of the platform must enter into a bilateral agreement with SEBP, ensuring compliance with voucher processing and redemption requirements.

• Producers accepting vouchers on their own platforms must validate the voucher and its usage through the Platform.

Redemption and Restrictions

• Vouchers can only be redeemed for eligible products and producers as defined by the terms set by Companies and Producers.

• Vouchers cannot be exchanged for cash, transferred to third parties, or used outside the SEBP ecosystem and affiliated Producer marketplaces, specified in the conditions of the voucher.

Article 12 – Termination of Registration

Termination by the User

• Employees may request to terminate their registration on SEBP at any time by submitting a formal request through their account settings or by contacting SEBP support.

• Companies and Producers may request to terminate their registration on SEBP according to the conditions of their bilateral agreement.

• Upon termination, the user will lose access to their account and all associated features of the platform.

Termination by SEBP

SEBP reserves the right to suspend or terminate a user’s registration in cases of:

• Breach of the Terms of Use, including fraudulent activities, misuse of vouchers, or non-compliance with agreements.

• Violation of applicable laws and regulations related to marketplace transactions or voucher use.

• Failure of a Producer to maintain compliance with the annual reassessment obligation.

• Non-payment of applicable fees or breach of contractual obligations under bilateral agreements.

In cases of termination due to policy violations, SEBP may take additional measures, including restricting future access to the platform.

Consequences of Termination

Unused Vouchers:

• Employees who terminate their account while holding unused vouchers will forfeit any remaining balance unless otherwise specified in the terms set by their employer.

• In cases where a Company terminates its registration, vouchers already issued to Employees will remain valid until their expiration date unless otherwise agreed with SEBP.

• If a Producer exits the platform but has accepted vouchers, they must still honor valid vouchers within the agreed-upon redemption period.

Access to Data Reports and Aggregated Data:

• SEBP will retain and continue to use aggregated and anonymized transaction data for reporting, impact assessments, and sustainability analytics.

• Individual users' personal data will be handled in accordance with GDPR and SEBP’s Privacy Policy, with the option to request data deletion where applicable.

Special Conditions for Producers and Companies

• Producers exiting the platform must settle any outstanding voucher redemptions and fulfill any pending transactions before termination is finalized.

• Companies terminating their registration must ensure that all voucher commitments are settled, and outstanding sustainability data reports are generated before their access is revoked.

Article 13 – Liability Disclaimer

Neutral Intermediary Role

• SEBP operates solely as a technological intermediary and is not responsible for the quality, legality, authenticity, or delivery of goods and services offered by Producers.

• All transactions, including disputes arising from product defects, misrepresentation, or non-delivery, must be resolved directly between Employees and Producers.

Accuracy of Information

• SEBP does not verify, warrant, or guarantee the accuracy, completeness, or reliability of any information provided by Producers, including but not limited to product descriptions, sustainability claims, and pricing.

• Users acknowledge that reliance on any such information is at their own risk.

Use of Aggregated Data and Reports

• SEBP provides Companies with aggregated impact data for ESG (Environmental, Social, and Governance) reporting purposes. However, SEBP does not guarantee any specific financial, operational, or reputational benefits arising from the use of such data.

• Companies bear sole responsibility for how they interpret and apply SEBP reports in their sustainability strategies and corporate decision-making.

Liability in Cases of Gross Negligence vs. Force Majeure

• SEBP shall be liable if damage arises due to willful misconduct or gross negligence directly attributable to SEBP’s actions, provided that such negligence falls within legally recognized obligations and liabilities.

• SEBP shall not be held liable for failures, disruptions, or damages caused by events beyond its reasonable control, including but not limited to:

  • Natural disasters (earthquakes, floods, fires).

  • Widespread technical failures or cyberattacks affecting third-party infrastructure.

  • Government actions, regulatory changes, or legal restrictions preventing service continuity.

  • Strikes, pandemics, or other unforeseen socio-economic disruptions.

Platform Downtime and Data Security

• SEBP strives to maintain platform availability but does not guarantee uninterrupted service.

• In cases of system maintenance, unexpected downtime, data security incidents, or external service provider failures, SEBP shall only be liable within the scope of its legally mandated obligations and shall take all reasonable steps to mitigate user impact.

User Indemnification

Users agree to indemnify and hold SEBP harmless from any legal claims, damages, or liabilities arising from their use of the platform, including but not limited to:

• Misuse of the voucher system.

• Fraudulent activities or violations of agreements.

• Any breaches of applicable consumer protection, tax, or data privacy laws by Producers, Companies, or Employees.

Article 14 – Intellectual Property Rights

Ownership of the Sustainability Performance Methodology

• The Sustainability Performance Methodology used within SEBP has been developed by Agriventures and remains its intellectual property.

• The Good Club operates under a non-exclusive, royalty-free license to implement this methodology within SEBP for evaluating Producers and generating sustainability-related insights.

• Users may not copy, distribute, or modify the Sustainability Methodology outside the SEBP platform. Unauthorized use may result in legal action by Agriventures as the rightful owner.

SEBP Platform and Proprietary Content

• The Good Club retains ownership of the SEBP platform, including its design, technology, algorithms, and proprietary tools.

• SEBP-generated reports and sustainability impact data remain the property of The Good Club.

• Users are granted a limited, non-exclusive, non-transferable, and revocable license to access and use SEBP for its intended purposes, including engaging in transactions, redeeming vouchers, and assessing sustainability impact.

• Companies may use SEBP’s aggregated sustainability impact reports for their internal ESG initiatives, but may not commercially exploit SEBP-generated data without explicit authorization.

User-Generated Content

• Users (Employees, Companies, and Producers) may upload or provide content, such as product listings, sustainability-related information, or business descriptions.

• By submitting content, Users grant SEBP a non-exclusive, worldwide, royalty-free license to use, distribute, modify, display, and store this content as necessary for operating the platform.

• Users confirm they have the necessary rights to submit content and agree not to upload copyrighted, trademarked, or proprietary materials without appropriate authorization.

• Users must respect third-party intellectual property rights when uploading content. If you believe your intellectual property has been used on SEBP without authorization, you may report it to contact@wearethegoodclub.com.

Restrictions

Users are prohibited from:

• Copying, modifying, distributing, selling, sublicensing, or exploiting SEBP’s content, design, or sustainability assessment methodology without written permission.

• Using SEBP content, impact reports, or sustainability metrics for unauthorized commercial purposes or outside the platform’s intended use.

Violation of Intellectual Property Rights

• If a User violates intellectual property rights, SEBP reserves the right to suspend or terminate the account and take legal action if necessary.

• SEBP does not claim ownership over third-party trademarks, logos, or materials displayed within the platform but requires Users to respect third-party intellectual property rights.

Article 15 – Dispute Resolution

Disputes Between Companies and SEBP (The Good Club)

• Any disputes regarding a Company’s participation in the voucher program, access to impact reports, subscription fees, or other platform-related services shall be governed by the bilateral agreement between the Company and SEBP (The Good Club).

• In case of disagreement, both parties shall first seek an amicable resolution. If a resolution is not reached, the dispute may be escalated according to the terms outlined in their agreement.

Disputes Between Producers and SEBP

• Any disputes regarding platform access, sustainability compliance, voucher acceptance, or marketplace participation must be resolved through the dispute resolution mechanisms established in the agreement with SEBP.

• If a Producer is found to be in violation of platform policies, SEBP reserves the right to impose penalties, including suspension or termination of access.

Disputes Between Employees and Producers

• Employees and Producers are responsible for resolving any disagreements related to product quality, delivery, misrepresentation, or service fulfillment directly.

• SEBP does not guarantee refunds, returns, or warranties, as these are solely the responsibility of the Producers.

• If a Producer fails to honor a voucher redemption, SEBP may intervene within the scope of its policies to ensure fair use of the platform but does not provide direct compensation.

SEBP’s Limited Role in Dispute Intervention

• SEBP will only intervene in disputes between Employees and Producers when explicitly required under the platform’s intermediary role, such as:

  • Enforcing platform policies related to fraudulent activities or voucher misuse.

  • Addressing violations of SEBP’s agreement with Producers, including cases where a Producer fails to honor the voucher program.

  • Ensuring compliance with consumer protection policies, where applicable.

• SEBP’s intervention is limited to administrative actions (e.g., policy enforcement, account suspension, termination) and does not extend to financial settlements or arbitration between Employees and Producers.

Disputes Between Users and SEBP

• Any legal disputes arising between Users (Employees, Companies, or Producers) and SEBP shall be governed by the laws of Bulgaria.

• Legal proceedings shall be conducted in the courts of Bulgaria, unless both parties have agreed to arbitration.

• If an arbitration agreement is in place, disputes shall be resolved through binding arbitration under the rules of a recognized arbitration body in Bulgaria, with the arbitration decision being final and enforceable.

Privacy Policy

SEBP, managed by The Good Club, values your privacy and is committed to protecting your personal data. This Privacy Policy outlines what data we collect, how we process it, and your rights under the General Data Protection Regulation (GDPR).

This policy primarily applies to individual Users (Employees). For Companies and Producers, as they act as legal entities, this policy applies only where relevant.

Who is the Data Controller?

The data controller of SEBP is The Good Club, which manages and operates the platform. You can contact the data controller at:

The Good Club Email: contact@wearethegoodclub.com

What Information Do We Collect, and How Do We Obtain It?

We collect data directly from you when you register on SEBP. The information processed depends on your role within the platform.

User TypeCollected Data

EmployeeName, email, password, IP address, digital wallet status, transaction history (including marketplace purchases with own resources and voucher usage)

Company representativesRegistration details, contact person details

Producer representativesRegistration details, contact person details, voucher acceptance history, transaction records

Експортиране в Таблици

Some data, such as email, password, and country, is mandatory for account creation. Other data, such as impact metrics and transaction history, is collected automatically when using the platform.

How Do We Process Your Data and For What Purposes?

SEBP processes your data to provide services related to the marketplace, voucher system, and sustainability reporting. Specifically, we use your data for:

• Account management (e.g., profile creation, login authentication).

• Facilitating transactions.

• Managing voucher issuance.

• Assessing Producers' sustainability performance based on the Sustainability Performance Methodology.

• Generating impact metrics reports for Companies based on platform transactions.

• Platform administration and security (e.g., fraud prevention, enforcing Terms of Use).

• Legal compliance in case of disputes or regulatory obligations.

What is the Legal Basis for Data Processing?

SEBP processes personal data under the following legal bases:

PurposeLegal Basis

Account registration and usageContractual necessity (Terms of Use)

Transaction facilitation (marketplace & vouchers)Contractual necessity

Personal Sustainability dashboard dataLegitimate interest (ensuring compliance with sustainability criteria)

Impact metrics reportingLegitimate interest (providing Companies with sustainability insights)

Compliance with legal obligationsLegal requirement (e.g., resolving disputes)

Експортиране в Таблици

Who Has Access to Your Data?

Access to personal data is strictly limited:

• Platform Administrators (The Good Club) have access to all data for platform management and security.

• Companies can access aggregated impact metrics but not individual employee transactions.

• Producers can only see their own sales and voucher redemptions and data needed for the execution of particular sales.

• Employees control their own profile and transactions. We do not sell or share your personal data with third parties.

How Long Do We Store Your Data?

Personal data is stored as long as your account remains active.

• If your account is deleted, all personal data is anonymized except for data used in impact metrics reports (which remain aggregated and non-identifiable).

• Transaction data is retained for up to 10 years for legal and reporting purposes.

What Rights Do You Have Under GDPR?

You have the following rights regarding your personal data:

• ✔ Right to access – You can request a copy of your data.

• ✔ Right to correct – You can update inaccurate data.

• ✔ Right to erasure – You can request deletion of your data (except where legally required).

• ✔ Right to restrict processing – You can limit how we use your data in certain cases.

• ✔ Right to data portability – You can receive your data in a structured format.

• ✔ Right to withdraw consent – If you subscribed to updates, you can unsubscribe anytime.

• ✔ Right to lodge a complaint – You can file a complaint with your national data protection authority if you believe your rights are violated.

To exercise these rights, contact us at: contact@wearethegoodclub.com.

International Data Transfers

SEBP may use cloud hosting providers outside the EU. In such cases, data transfers comply with GDPR safeguards, including:

• Hosting in countries with adequate protection status.

• Using Standard Contractual Clauses (SCCs) for secure data transfer.

Changes to the Privacy Policy

We may update this policy periodically. Any changes will be posted on this page. Last Updated: 07.04.2025