General Terms and Conditions

Part A – General provisions

Applies to both products: the mobile app “fintogo” and the marketplace service “fintogo – Rechnungswesen”

A.1 Scope, provider, structure

A.1.1 Provider

FTG Finance Technologies GmbH, Börsegasse 9/8, 1010 Vienna, Austria, FN 666615t (“Provider” or “fintogo”)

A.1.2 Two products

The Provider operates two separate offerings: the mobile app “fintogo” for private individual users (B2C), available via the Apple App Store or Google Play (governed in Part B), and the web-based marketplace service “fintogo – Rechnungswesen”, distributed via the Marktplatz Lernapps (Marketplace for Learning Apps) to schools, educational institutions and private individuals (governed in Part C). These are separate contractual relationships with their own service description, pricing logic and contracting-party context; a contract for one product does not create a usage relationship for the other.

A.1.3 Applicability of Parts B and C

Decisive for the applicability of Part B or Part C is the distribution channel of the respective contract: app store download/in-app subscription → Part B; order/offer/framework agreement via the Marktplatz Lernapps → Part C. In the event of a conflict between Part A and the relevant special part, the special part prevails. Individual written agreements (in particular framework agreements under Part C) take precedence over all parts of these T&Cs.

A.1.4 Consumer protection

Vis-à-vis consumers, mandatory consumer protection provisions of their respective country of habitual residence (Austria, Germany, Switzerland or another country) take precedence over these T&Cs insofar as they must mandatorily be applied.

A.1.5 Conflicting terms

Deviating terms of users only become part of the contract with the express written consent of the Provider.

A.1.6 Relationship to Apple/Google

For obtaining the app via the Apple App Store or Google Play, their respective terms of use also apply. As between user and Provider, these T&Cs prevail; for payment processing, refunds and account management, the store terms apply with priority (see B.4.5 for details).

A.2 Ownership, intellectual property, trademarks

Software, source code, databases, design and AI functions of both products are owned by the Provider or its licensors. For OER-based content, the underlying open licence (e.g. Creative Commons) remains in place; the Provider claims ownership only of the didactic structure, technical integration and preparation. The name “fintogo”, the logo and other marks are protected; use outside the products requires prior written consent.

A.3 Data protection

The Provider processes personal data in accordance with the GDPR, the DSG and relevant data protection regulations. The joint privacy policy contains separate provisions for the mobile app and the marketplace service, in particular because of different user groups, AI functions and role concepts. For institutional customers of the marketplace service, the data processing agreement (DPA) in accordance with the annex to Part C applies.

Note on the current status (version 1.0): At the time of this version, the app shows no advertising and uses no advertising/retargeting tracking, no analytics and no crash reporting (details in the privacy policy, B.2.7/B.4/B.7). This statement describes only the status at launch; should advertising, sponsoring, affiliate or analytics formats be introduced in future, the T&Cs and privacy policy will be amended accordingly before their introduction (see A.6).

A.4 Liability and warranty

A.4.1 Warranty

Vis-à-vis consumers, the statutory warranty provisions of their respective country of habitual residence apply without restriction. Vis-à-vis businesses (in particular institutional customers under Part C), the warranty period is 12 months from provision; defects must be reported in writing without delay.

A.4.2 Scope of liability

Liability is unlimited for damage resulting from injury to life, body or health and in cases of intent or gross negligence. In cases of slight negligence, the Provider is only liable for breach of essential contractual obligations, limited to foreseeable damage. Indirect damage, consequential damage, loss of profit and loss of data are excluded – to the extent permitted by law. Product liability and mandatory consumer protection provisions remain unaffected.

A.4.3 AI functions

The AI functions of both products (including the learning coach “FINN”, generation of study materials and podcast function in the app; chat assistant in the marketplace service) are provided server-side via the Provider’s backend using external AI infrastructure (see privacy policy B.2.2 for details) and deliver automatically generated suggestions that are not necessarily complete, up to date or error-free. All content is for educational and practice purposes only and does not constitute financial, investment, tax or legal advice. Users check AI outputs on their own responsibility before using them for decisions of financial or legal significance. No liability is accepted for learning success or grade improvements.

A.4.4 Availability and further development

The Provider endeavours to achieve an average annual availability of at least 95%; excluded are maintenance work, force majeure and disruptions outside its sphere of influence (e.g. store or network outages). The Provider may further develop both products and change functions, provided the main performance obligations are not materially impaired; in the event of material adverse changes, timely information is given, with a special right of termination where applicable. App updates (including technical interim updates to app content without a full store update) may be provided automatically; in this regard, reference is made to the privacy policy (B.8).

A.4.5 User-generated content

For content that users post or share themselves, the Provider gives no guarantee of accuracy or compliance with rights; the person posting is responsible. Unlawful content will be removed once the Provider becomes aware of it. For reporting and remedy procedures for content shared with other users, see B.7.7.

A.5 User obligations (general)

Access credentials must be kept secure and secret; if misuse is suspected, the password must be changed without delay and the Provider informed. In the event of breaches of the T&Cs, the Provider may temporarily block accounts or terminate the contract without notice for good cause; claims for damages remain unaffected. Product-specific rules of conduct for the community functions of the app are set out in Part B.

A.6 Changes to the T&Cs

The Provider may amend these T&Cs, in particular in the event of changes in the law, new features, requirements of authorities or operational needs; a change to one special part does not affect the other product. Material changes will be notified at least 30 days before they take effect by email or in-app/marketplace; if the user does not object in time, they are deemed accepted (this will be pointed out). In the event of an objection, there is an extraordinary right of termination at the time the change takes effect. Purely editorial changes are permitted without a notice period. Price changes are governed by B.4.7 (app) and C.5.5 (marketplace service) respectively.

A.7 Final provisions

Austrian law applies, excluding the UN Convention on Contracts for the International Sale of Goods (CISG); for consumers only insofar as mandatory consumer protection provisions of their country of habitual residence (Austria, Germany, Switzerland or another country) do not conflict. The exclusive place of jurisdiction, where permitted, is the court responsible for Vienna Innere Stadt; for consumers, the statutory place of jurisdiction applies. The invalidity of individual provisions – even of just one special part – does not affect the validity of the remaining provisions or of the other part; it will be replaced by a provision that comes as close as possible to the economic purpose. The Provider does not take part in proceedings before a consumer arbitration board. For users with habitual residence in Switzerland, the above provisions on applicable law and place of jurisdiction apply accordingly, insofar as mandatory Swiss provisions do not conflict (cf. Art. 120 PILA). Contact: the contact details published on fintogo.ai.

Part B – Special provisions for the mobile app “fintogo”

Applies exclusively to the download and use of the app provided via the Apple App Store or Google Play by private individual users (B2C) in Austria, Germany and Switzerland. Supplements Part A; in the event of a conflict, Part B prevails.

B.1 Scope, distribution channels

Part B applies exclusively to the app under A.1.2 and to subscriptions within the app. It does not apply to the marketplace service (Part C applies to that). The app is aimed at users in Austria, Germany and Switzerland; Part B applies uniformly to users in all three countries, unless country-specific particularities (in particular B.2.2, B.6) are expressly regulated differently below. Target group: private individual users, in particular students at vocational secondary schools (including HAK/HAS) from the minimum age under B.2.2, university students and career starters.

Available platforms: At market launch, the app is available via the Apple App Store (iOS); provision via Google Play (Android) is planned. Provisions of these T&Cs that refer to Google Play apply accordingly from the point at which the app is actually offered via Google Play; until then they are to be read as forward-looking and presented accordingly on the website/in the store listing.

Version 1.0 of the app offers the same range of functions for all users regardless of age; an age-differentiated app experience is not planned for version 1.0. Age-related provisions therefore concern only registration, conclusion of contract and consent requirements (B.2.2), not the range of functions itself.

B.2 Contracting party, conclusion of contract, registration

B.2.1 Contracting party

The sole contracting party is the Provider. Apple and Google are not contracting parties for use of the app, but act as payment and processing partners for store purchases (see B.4.5 for details). For login via the sign-in function (B.2.3), Apple and Google additionally act as independent identity providers; in this respect, too, they do not become contracting parties for use of the app.

B.2.2 Minimum age, store age rating and consent of legal guardians

Relationship to the store age rating: The age rating stated in the Apple App Store or on Google Play is a content classification by the respective store and not a contractual minimum age. Only the minimum age of 14 set out below applies to registration and use.

Uniform minimum age of 14 (AT/DE/CH): Registration and use of the app require a minimum age of 14, regardless of the login route chosen.

Under 14: Independent registration is not possible under the age of 14; a separate account managed by legal guardians for children under 14 is not offered in version 1.0.

Additional confirmation for 14- and 15-year-old users (all three markets): Users who state an age of 14 or 15 during registration additionally confirm that their legal guardians generally agree to use of the app. This confirmation is made uniformly in all three markets as part of the registration process (no different app experience), but serves as special protection with regard to the differing legal standards in Germany and Switzerland (see below). From age 16, this additional confirmation is not required.

Paid Pro subscription: For a Pro subscription, the following applies in addition to the rules above:

• Minors confirm that the costs are covered from their own freely available funds or that their legal guardians have agreed.
• The Provider recommends obtaining the legal guardians' consent before a paid subscription, as the store payment method usually runs in their name.

Where there are justified doubts, the Provider may request proof of age or consent and restrict use until the matter is clarified.

B.2.3 Registration, login

A user account with complete, truthful information is required for use; changes must be updated without delay. Only one account per person is permitted, not transferable to third parties.

Registration or login can be done via: (a) classic registration with an email address and a password of your choice, (b) “Sign in with Apple” or (c) Google Sign-In. For login methods (b) and (c), the identity is confirmed via the respective third-party provider (Apple or Google); which account data is processed in each case, in particular whether and when an actual name rather than a freely selectable display name is stored in the fintogo account, depends on the login route chosen (see privacy policy B.2.1 for details).

B.2.4 Conclusion of contract

A free-of-charge Free usage relationship comes into being on successful registration and confirmation. A Pro subscription comes into being with the final purchase confirmation in the store purchase dialogue (including price, term, automatic renewal); payment and debiting take place via the respective store (B.4.5). The subscription status is technically managed using a specialised subscription management service provider (see privacy policy B.2.6a for details). Services are provided exclusively digitally; there is no entitlement to physical materials.

B.2.5 Refusal and blocking

The Provider may refuse registration or block an account if there are reasonable grounds to suspect a breach of B.2.2 (minimum age) or B.7 (rules of use).

B.3 Service description Free vs. Pro

B.3.1 Two usage tiers

The app is offered in a free tier (“Free”) and a paid tier (“Pro”). The binding scope of services of both tiers is determined by the current feature overview in the app or on the pricing page. Changes to the limits set out there do not require an amendment of the T&Cs as long as the core of the respective tier is not materially worsened.

B.3.2 Free

Free includes: access to all learning areas with a share of modules per area set out in the feature overview (at least 1 module); a daily quota of FINN interactions; a monthly quota of generable study materials with limited scope per document; a one-off quota of AI podcast episodes (“FINN & FINNY”); unrestricted participation in duels and unrestricted rating of other users' study materials; sharing own and saving other users' study materials within the quantity limits under B.3.4; full access to points, levels, streak and leaderboard. Free is free of charge and unlimited in time.

B.3.3 Pro

Pro additionally includes: unrestricted access to all modules including future content; FINN without noticeable limits (fair-use reservation, B.3.5); unlimited generation of study materials on a larger scale; unlimited podcast use; unlimited sharing and saving of study materials (duels and ratings are already unlimited in Free and are therefore not extended in Pro).

B.3.4 Community features as part of the contract

Duels and rating other users' study materials are available identically unlimited in Free and Pro. Sharing your own study materials and saving/adopting other users' is limited in Free by the quantity limits set out in the feature overview (e.g. number of shareable materials per month, number of other users' materials that can be saved at the same time) and unlimited in Pro. These limits are part of the contract, not just UI presentation, and can only be changed by adjusting the feature overview in accordance with B.3.1/A.6.

B.3.5 Fair-use reservation

Even “unlimited” Pro functions are subject to a technical fair-use upper limit against misuse, which is not reached in regular use; reaching it results at most in a temporary restriction.

B.4 Prices, payment terms, subscription terms

For the content of the contract, only the amount actually payable shown on the purchase screen immediately before conclusion of the contract is decisive (see B.4.2/B.4.3).

B.4.1 Free

Free of charge.

B.4.2 Pro monthly subscription

Regular price currently €14.99 per month (Austria/Germany, incl. statutory VAT unless otherwise stated; for Switzerland the price shown in Swiss francs in the store applies), billed monthly in advance, no discount, automatic renewal for a further month at a time at the same price unless cancelled in good time. The price actually payable shown in the store purchase dialogue immediately before completing the purchase is always decisive; this may differ slightly by country (e.g. due to rounding or different tax rates/store price tiers). Cancellable monthly at the end of the current period (B.5.2).

B.4.3 Pro annual subscription and introductory offer

Fixed term of twelve months; the amount for the respective contract period is debited once in advance for the entire term on conclusion of the contract or on renewal. The regular price of the annual subscription is currently €179.99 per year (Austria/Germany, incl. VAT unless otherwise stated; for Switzerland the price shown in Swiss francs there applies).

Introductory offer for new customers: For eligible new customers (eligibility depends on the criteria of the respective store, in particular on whether an introductory or trial offer has previously been used for the relevant subscription group), the following applies in the period from 17.09.2026 to 31.12.2026 for new subscriptions: an introductory price of €89.99 for the first contract year, likewise due once in advance. Compared with the regular annual price of €179.99, this represents a saving of around 50% for the first contract year. This statement relates exclusively to the stated offer period and the stated amounts; it does not automatically apply to later periods or to different prices shown in the store in future.

After the offer period (31.12.2026) expires, the introductory offer is no longer available for new subscriptions unless it is extended; in any case, only the price actually shown in the store purchase dialogue at the time of the respective conclusion of the contract is decisive, not the amounts stated above if these have been changed in the meantime by Apple or Google.

The above amounts apply directly to Austria and Germany (EUR); for Switzerland, the amount shown in the store in Swiss francs, converted at market rates, applies. As, under B.4.2/B.4.3, the price actually shown in the store purchase dialogue is decisive in every case, the specific store price configuration per country has no regulatory effect beyond these T&Cs.

B.4.4 Automatic renewal

An annual subscription taken out under the introductory offer renews automatically after the end of the first contract period for a further year at a time at the then applicable regular annual price (currently €179.99; the regular price actually shown in the store at the time of the respective renewal is decisive if it has changed in the meantime), unless cancelled in good time (B.5.3); the introductory offer applies exclusively to the first contract period. Before the first regular renewal, the Provider or the respective store will point out the price, renewal and cancellation option in good time (e.g. by email or in-app); for subsequent renewals, the then current regular price applies in each case.

B.4.5 Payment processing via Apple/Google

Pro subscriptions are purchased exclusively through the in-app purchase systems of Apple or – once available – Google. Apple/Google bill and automatically issue the purchase receipt/confirmation, not the Provider. The Provider receives from Apple/Google only the purchase, subscription and entitlement information required to activate and manage Pro access (“entitlement information”) – transmitted via the technical subscription management service provider described in the privacy policy (B.2.6a) – as well as periodic store settlement information on paid-out revenue, but no credit card, bank or other payment data of users. For payment methods, chargebacks and refund/withdrawal requests relating to a specific purchase, the store support processes are primarily responsible; the Provider has no direct influence on these. The terms of use of Apple Media Services and Google Play also apply. Cancellation/management takes place via the account settings of the respective store (B.5.2 et seq.).

B.4.6 Late payment

If a due payment cannot be collected via the store, the Pro subscription ends according to the store rules; access is downgraded to Free.

B.4.7 Price changes to ongoing subscriptions

Price increases do not have retroactive effect. For the monthly subscription, they take effect at the earliest with the next period beginning after the notice period (A.6) has expired; for the annual subscription, at the earliest at the next automatic renewal (B.4.4). The expiry of the introductory offer on 31.12.2026 for new subscriptions is not a price change for existing subscriptions.

B.5 Cancellation

B.5.1 Free

Can be cancelled at any time without giving reasons, in particular by deleting the account. Account deletion is possible directly in the app (in-app deletion path: account settings → danger zone → delete account). In addition, deletion can be requested informally via the contact form on fintogo.ai or by email to office@fintogo.ai (identical to the controller’s contact address given in A.1) (web channel, as additionally required by Google Play).

B.5.2 Pro monthly subscription

Can be cancelled at any time at the end of the current billing period via the account settings of the respective app store. No pro rata refund; access continues until the end of the period.

B.5.3 Pro annual subscription

Cancellation to avoid automatic renewal must be made before the end of the current twelve-month period; the respective store deadline is decisive (generally no later than 24 hours before the end of the period); cancellation is likewise made via the store account settings. No pro rata refund; access continues until the end of the period.

B.5.4 Extraordinary termination

The right of both parties to extraordinary termination for good cause remains unaffected; good cause for the Provider exists in particular in the event of serious or repeated breaches of B.7.

B.5.5 Consequences of termination

After a Pro subscription ends, the account is downgraded to Free; content and progress data are generally retained as part of Free, unless technical or feature overview restrictions prevent this. On complete account deletion, data is deleted in accordance with the app’s privacy policy.

B.6 Right of withdrawal for consumers

B.6.1 Principle and deadline

Consumers with habitual residence in Austria, Germany or another EU/EEA state who conclude a contract at a distance (in particular an in-app purchase) have a right of withdrawal under the FAGG or the respective national implementation of the EU Consumer Rights Directive (in Germany Sections 312g, 356(5) BGB) (period of 14 days from conclusion of the contract). To exercise it, a clear statement (e.g. email) or – where offered by the store – its refund function is sufficient. A model withdrawal form is provided on request.

For consumers with habitual residence in Switzerland, there is no general statutory right of rescission or withdrawal for distance contracts of this kind. The subscription can be cancelled at any time without giving reasons at the end of the current period under B.5.2.

B.6.2 Early expiry

As these are digital services without a physical data carrier, the right of withdrawal under B.6.1 expires early if the user expressly agrees during the order process that performance of the contract (activation) begins before the end of the withdrawal period and acknowledges that they thereby lose the right of withdrawal. This consent is obtained separately before Pro is activated.

B.6.3 Withdrawal for store purchases

Withdrawal/refund requests can additionally be made via the store processes; a right of withdrawal vis-à-vis the Provider granted by law or voluntarily under B.6.1 remains unaffected, but the Provider has no influence on refund decisions made by the store. If the service has already been fully provided and information was properly given under B.6.2, there is no longer a right of withdrawal. Otherwise the FAGG or the respective national implementation applies.

B.7 Rules of use and conduct in the community

B.7.1 Intended use

The app is intended exclusively for educational and practice purposes in the field of business and financial education; it must be used within the framework of applicable laws, good morals and these T&Cs.

B.7.2 Prohibited acts

The following in particular are prohibited:

• unlawful, insulting, discriminatory, sexually abusive, violence-glorifying, youth-endangering or extremist content;
• posting content without sufficient rights of use, in particular other people’s copyrighted study materials without permission;
• circumventing technical protection mechanisms, exploiting security vulnerabilities or undermining feature limits;
• automated scripts/bots, in particular to manipulate duels, leaderboards or ratings;
• disrupting or overloading the functioning of the app;
• insulting or harassing behaviour towards other users in duels, comments or ratings;
• advertising, spam or other commercial content unrelated to the purpose in study materials, comments or ratings;
• entering particularly sensitive data (e.g. health data, political opinions, religion) in the AI chat unless necessary for the learning purpose.

B.7.3 Duels

Duels are available without limit in Free and Pro. Users undertake to behave fairly and refrain from technical manipulation and insulting behaviour.

B.7.4 Sharing, saving, rating study materials; rights of use

Within the quantity limits under B.3.4, users may share their own study materials and save/adopt other users'; rating other users' study materials is possible without limit. Only your own content or content for which you have sufficient rights of use may be shared; ratings must be factual and truthful, and misuse of the rating function is prohibited. Users remain the rights holders of their own content created or shared in the app (user-generated content, “UGC”). By creating or sharing it, they grant the Provider solely the right to store, reproduce, display and make the content available to other users within the respective function to the extent necessary for the provision, display, moderation and technical safeguarding of the service; any further use (in particular for the Provider’s own advertising purposes outside the app) is not associated with this.

B.7.5 Automated content review, moderation, removal of content

For the community functions (in particular sharing study materials), the Provider operates a two-stage automated content review: a word-list check and an AI-supported assessment (see privacy policy B.2.5a for details). This review takes place automatically at three points: when content is released to the community, immediately after AI-supported generation in the case of direct release, and on every report of content. If a violation of B.7.2 is found, the content concerned is removed from the community (hidden, not deleted); it remains in the creator’s own library.

In the event of repeated confirmed violations, the ability to share content with the community is restricted in stages: first confirmed violation – warning; second violation – temporary sharing block for seven days; third violation – permanent sharing block. Such a block affects only the ability to share content; the account, the own learning library and the other app functions remain usable. The user concerned is informed of every measure; they are free to lodge an objection using the contact address given in A.1, whereupon the decision is reviewed by a natural person.

The Provider may also remove content where there is reasonable suspicion of a breach of B.7.2/B.7.4 and use non-personal, aggregated data for statistical and product-related purposes.

B.7.5a Blocking other users

Users can block other users. A block works both ways and dissolves an existing friendship connection as well as ongoing duels between the accounts concerned. The block remains until it is lifted by the user who imposed it.

B.7.6 Consequences of violations

In the event of violations of B.7, the Provider may, depending on severity, remove content, restrict the sharing of content under B.7.5, restrict functions, block the account or terminate the contract without notice for good cause (B.5.4); claims for damages remain unaffected.

B.7.7 Reporting mechanism, Digital Services Act

Users can report unlawful content or content that violates B.7.2, as well as user profiles, for review via the reporting function available in the app (reason, optional description up to 500 characters) or by email to the contact address given in A.1. The Provider reviews incoming reports automatically and without undue delay (as a rule within a few seconds) and removes content reported with good reason under B.7.4/B.7.6. To protect against abusive use of the reporting function, the number of reports per account per day is limited (currently ten); repeated unfounded reports do not trigger any automatic sanction against the reported person, and a sanction under B.7.5 always requires a confirmed violation, never a report alone.

Persons concerned are informed of the reasons for a removal or restriction and can object to the decision. The objection is reviewed by a natural person.

Version 1.0 of the app offers no direct messaging function between users; interaction is limited to the structured functions of duels, sharing/saving/rating study materials and the leaderboard (B.3.2–B.3.4).

Part C – Special provisions for the marketplace service “fintogo – Rechnungswesen” (Accounting)

Applies exclusively to the service “fintogo – Rechnungswesen” obtained via the Marktplatz Lernapps (Marketplace for Learning Apps) (schools, educational institutions, authorities, teachers, individuals). Supplements Part A; in the event of a conflict, Part C prevails. Does not apply to the app (Part B).

C.1 Scope and user groups

Part C applies to all use of the marketplace service, whether free of charge or paid. User groups: individual users (B2C: students aged 14 and over, university students, private individuals); institutions (B2B/B2G: schools, educational institutions, public bodies, commissioned teachers); partner companies (including CSR/sponsorship/education cooperations).

C.2 Service description

C.2.1 Services

The marketplace service includes in particular: digital learning content in the field of accounting (texts, videos, exercises, quizzes); learning planning and progress tracking; an AI chat assistant for content support; optional teacher/admin views for institutions. The content is for educational and practice purposes only and does not constitute financial, investment, tax or legal advice.

C.2.2 Subscription models

Pro subscription: personal individual subscription with full access to all content and modules (“Full Access”), for private individuals only, not orderable institutionally, regular price. This Pro subscription is a separate product and is not to be confused with the Pro subscription of the app (Part B); the subscriptions entitle exclusively to use of the respective product.

Basic subscription for individuals: access only to content of your own school level/type, directly bookable, regular B2C price.

Basic subscription for educational institutions: same content as the individual Basic subscription, but discounted and with teacher/admin access (viewing learning progress, assigning tasks/quizzes, reports); ordering via offer, bulk order or framework agreement; teacher access is charged separately according to the price list.

Scope, availability and prices are set out in detail in the current service description, price list or individual offers/framework agreements.

C.3 Conclusion of contract and registration

A user account with complete, truthful information is required for use. A Pro or Basic subscription can be taken out by adults and by minors aged 14 and over; minors thereby affirm their minimum age and – where required – the consent of their legal guardians. Accounts for teachers, school administration or students can be commissioned by the school/authority under an institutional contract; the latter thereby confirms its authorisation to process the data of the persons concerned. For online orders, the contract is concluded on completion of the order process and confirmation by the Provider; for institutional customers, by written acceptance of an offer or a framework agreement. Services are provided exclusively digitally.

C.4 Special provisions for schools, authorities and institutional customers

If a school, educational institution or authority orders licences for students, it is the controller under data protection law and the Provider is the processor; the DPA in accordance with the annex to Part C applies. Under the Basic subscription, teachers can manage class accounts, assign tasks and view learning progress, limited to data required for educational purposes. The institution ensures the necessary data protection and school law requirements (information duties, consents, internal policies); the Provider processes student data only to the extent necessary, takes appropriate protective measures and does not transfer data to third countries without suitable safeguards. Use under state funding programmes may be subject to additional, separately regulated terms.

C.5 Prices, payment terms, term, cancellation

Fees are set out in the currently valid price list or an individual offer, incl. statutory VAT unless otherwise stated. Subscriptions have the agreed minimum term (monthly/annual) and renew automatically for the same period unless cancelled in good time. The notice period for paid subscriptions is, unless otherwise agreed, 30 days to the end of the term (receipt of the cancellation is decisive); free usage relationships can be cancelled at any time. The right to extraordinary termination for good cause remains unaffected.

Payment is made via the payment methods offered; the Provider may make activation/renewal dependent on payment. In the event of late payment, the Provider may block access and charge default interest (Section 1333 ABGB or Section 456 UGB) and reasonable reminder fees. Users may only set off counterclaims that have been finally established or acknowledged; consumers may additionally set off undisputed counterclaims or those that are legally connected.

Price changes are governed by A.6; in the case of institutional framework agreements, price adjustment clauses agreed differently take precedence.

For individual users (B2C) who are consumers and conclude a contract at a distance, the right of withdrawal applies in accordance with B.6 (14-day period, early expiry on consent to immediate commencement). Institutional customers have no consumer right of withdrawal.

C.6 Rights of use, content and obligations of users

The Provider grants a simple, non-transferable right of use of the marketplace service to the extent provided for in the contract. Users remain owners of their own content, but grant the Provider a simple, free-of-charge right of use for the performance of the contract (storage, display, editing, backup, technical development). The service is intended exclusively for educational purposes; in particular, unlawful, insulting, discriminatory or youth-endangering content, circumventing protection mechanisms, automated abusive use, disrupting functionality and entering particularly sensitive data in the AI chat without a learning-purpose requirement are prohibited. Institutional customers ensure that only authorised persons have access to institutional accounts and that data protection requirements towards students and legal guardians are met.

C.7 Termination of the contract and deletion of data

Paid contracts can be terminated observing the period under C.5; the right to extraordinary termination remains unaffected. After the end of the contract, access is deactivated; personal data is deleted or anonymised as soon as it is no longer required for performance of the contract or statutory retention obligations (details in the privacy policy of the marketplace service). Users are themselves responsible for backing up their own data (e.g. learning progress, notes) in good time before the end of the contract; there is no entitlement to subsequent provision of data.

Annex to Part C: Data processing agreement (DPA)

Supplementary to Part C for institutional customers of the marketplace service (schools, educational institutions, authorities). Does not apply to the app (Part B).

AVV.1 Subject matter and duration

The processor (Provider) processes personal data on behalf of the controller (school/educational institution/authority) to provide the services described in the main contract (Part C, framework agreement or individual order) – in particular provision of the marketplace service, hosting of user accounts, processing of learning progress, support through AI functions. This DPA applies for the duration of the main contract and ends automatically on its termination.

AVV.2 Nature and purpose of processing

Permitted processing operations: collection, storage, use, organisation, structuring, retrieval, inspection (by authorised teachers/administrators), platform-internal transmission, restriction, erasure, destruction – exclusively to provide the contractually agreed services (provision of the service, class administration, assignment of learning materials, evaluation of learning progress).

AVV.3 Data subjects and categories of data

Data subjects: students (including minors), teachers, school administration. Categories of data: master data (name, email, school, class, date of birth where applicable); usage data (hashed login data, access times); content data (learning progress, quiz results, answers, notes, chat interactions); technical data (IP address, device/browser information, where necessary). Special categories under Art. 9 GDPR are generally not processed, except on the express written instruction of the controller.

AVV.4 Obligations of the processor

Processing only on documented instructions from the controller (from this DPA and the main contract); deviating instructions require written form, and an infringement of data protection law is reported without delay. Confidentiality obligation of all persons entrusted with processing. Technical and organisational measures under Art. 32 GDPR, in particular:

• encryption of data transmission (SSL/TLS);
• hashed storage of passwords;
• access controls and role concepts;
• regular backups;
• logging of security-relevant events;
• regular security updates.

The processor assists with data subject rights (access, rectification, erasure, restriction, data portability) and with Art. 32–36 GDPR (data security, notification obligations, impact assessment). After the end of the contract, data is deleted or anonymised unless a retention obligation prevents this; on request, return/export takes place in common formats.

AVV.5 Subcontractors

The controller generally authorises the engagement of subcontractors; the current list is published or provided on request. Currently: hosting (easyname, Austria, EU location); AI provider (non-European, safeguards under Art. 46 GDPR; chain described in more detail in privacy policy B.2.2/B.4); email service provider (easyname, see privacy policy). Changes are notified at least 30 days in advance; in the event of a justified objection, the controller may terminate extraordinarily. Subcontractors are contractually bound to the same data protection terms; responsibility remains with the processor.

AVV.6 Personal data breaches

Notification to the controller without delay, at the latest within 48 hours of becoming aware, together with documentation and support for the controller’s notification and information obligations.

AVV.7 Control rights

The controller may check compliance with data protection requirements (provision of documentation/certificates on request) and, after notice (at least 14 days), carry out or have carried out audits; the costs are generally borne by the controller, except in the case of significant violations.

AVV.8 Liability

Liability is governed by Art. 82 GDPR; the processor is liable insofar as it has breached its specific obligations or acted contrary to lawful instructions, and indemnifies the controller against third-party claims in the event of culpable breaches of duty.

AVV.9 Final provisions

In the event of a conflict between this DPA and Part C, the DPA prevails on matters of processing on behalf. Amendments require written form. Otherwise A.7 applies accordingly.

Last updated: 10.09.2026
FTG Finance Technologies GmbH
Börsegasse 9/8, 1010 Vienna