1. Identification of Vexia

The website www.vexia.com is provided by:

• VEXIA, LDA.
• NIPC: 516723286
• Registered office: Alameda das Antas, 30, 4350-413 Porto
• Email for privacy and data protection/DPO: dpo@vexia.com
• Website: www.vexia.com

Vexia is a technology and media agency specialised in performance marketing, digital advertising and AdTech, with significant activity in the iGaming, sports betting, casino and poker sectors. The information made available on this website is intended to present Vexia's activity, solutions, channels, methodologies and contacts to brands, operators and partners, including digital performance, advertising, analytics, reporting, campaigns, custom data processing and custom modelling services.

The website www.vexia.com constitutes the common institutional point of presence of the Vexia group, which integrates, in addition to VEXIA, LDA., other companies in different jurisdictions, namely LSPT, UNIPESSOAL LDA. (NIF/NIPC 513410961, Porto, Portugal), LS BRASIL LTDA. (CNPJ 61.886.151/0001-83, Florianópolis, Brazil) and the group companies in Malta, LS MALTA HOLDING and LS MALTA LIMITED (registration number C110898, Ta'Xbiex, Malta). Depending on the operation, the market and the location of the user or client, the group entity that provides the services or operates a given activity may vary; the specific contractual relationship is always governed by the contracts, proposals and other documents entered into with the competent entity.

2. Scope, business models and acceptance of the Terms

These Terms & Conditions of Use ("Terms") govern access to and use of the website www.vexia.com, including pages, content, forms, features, contact buttons, meeting scheduling ("Book a Meeting"), materials, communications and any restricted areas made available by Vexia.

The website is institutional in nature and is directed, in terms of the direct relationship, to brands, operators, advertisers, agencies, partners and their professional representatives (B2B model). Vexia does not market services to end consumers through the website, does not manage player accounts, does not accept bets and does not process gambling payments.

When these Terms refer to the B2C model, they do so in the sense of the processing of end-consumer data (audiences, leads, conversions and players) carried out by Vexia in connection with the execution of campaigns on behalf of its operator clients, and not in the sense of a consumer contractual relationship between Vexia and such consumers. Such processing is governed by the Privacy Policy and by the contracts entered into with clients.

By accessing, browsing or using the website, the User declares that they have read, understood and accept these Terms. If you do not agree with the Terms, you must refrain from using the website. Where the User acts on behalf of a company, brand, operator, corporate group, partner or client, they declare that they have sufficient powers or authorisation to interact with Vexia on behalf of that entity.

These Terms apply only to the website www.vexia.com. The services actually provided by Vexia to clients or partners are governed by contracts, proposals, statements of work, service orders, data processing annexes, confidentiality agreements and other applicable contractual documents.

3. Informational nature of the website

The website is informational, institutional and commercial in nature. The content made available does not constitute a binding contractual offer, a guarantee of results, legal, tax, financial, technical or regulatory advice, nor does it replace specific analysis of each project, campaign, market, jurisdiction, platform, audience, product or service.

Any engagement of Vexia's services depends on the relevant commercial, technical, legal and contractual validation, as well as on the express acceptance of the specific conditions agreed between the parties.

Vexia may change, suspend, remove or update content, features, service descriptions, use cases, statistics, references to partners, brands, channels or technologies, at any time, without prejudice to contracts in force.

4. Services, AdTech, performance and regulated sectors

Vexia carries out activity in areas such as media buying, digital advertising, performance marketing, analytics, AdTech, campaign management, reporting, optimisation, brand safety, measurement technologies, custom data processing, custom modelling, dashboards and campaign activation across digital channels, including website ads, app ads, social, video, streaming/CTV and DOOH.

In regulated sectors, including iGaming, betting, casino, poker, sports betting, social gaming, digital entertainment or other markets subject to legal restrictions, the use of Vexia's services or content must comply with the legislation and regulation applicable in each target jurisdiction.

Vexia is not, through this website, a gambling operator, betting platform, online casino, financial intermediary, licensing entity or regulatory authority. Vexia does not accept bets, does not manage player accounts, does not process gambling deposits or withdrawals and does not grant licences to operate games or betting. Any reference to iGaming, brands, operators, channels, audiences or campaigns must be understood in the context of technology, media, advertising, performance and campaign support activity.

The client or partner that requests services in regulated sectors is responsible for ensuring that it holds the licences, authorisations, approvals, policies, terms, responsible gambling mechanisms, notices, age restrictions, exclusion mechanisms and other requirements legally required in the relevant market, unless such responsibility is expressly assumed by Vexia in a specific contract.

Vexia uses artificial intelligence systems and modelling techniques (AI-assisted campaigns, custom modelling and custom data processing) for the planning, optimisation, measurement and reporting of campaigns, as tools supporting the activity provided to clients. These systems do not make, through the website, solely automated decisions that produce legal effects on the User or that significantly affect them in a similar way. Vexia seeks to ensure that the use of artificial intelligence respects the principles of transparency, human oversight, non-discrimination, security and proportionality, in accordance with Regulation (EU) 2024/1689 (Artificial Intelligence Regulation), to the extent applicable to it, and with the GDPR. The definition of purposes, the information provided to data subjects and the conformity assessment of each model or campaign fall, depending on the role assumed, to the responsible operator-client and/or to Vexia, under the applicable contractual terms.

5. Minors, iGaming and responsible advertising

Vexia's website and services are not intended for minors. The User declares that they are at least 18 years old or the applicable minimum legal age in the jurisdiction in which they are located, when accessing content related to iGaming, betting, casino, poker, sports betting or other activities reserved for adults.

In connection with the campaigns it executes on behalf of operators (B2C data-processing model), Vexia does not direct advertising, campaigns, content, segments, landing pages, promotional actions or commercial communications of games and betting to minors, nor does it use minors as participants in such messages, applying reinforced safeguards to exclude minors and vulnerable audiences.

In Portugal, the advertising of games and betting must be carried out in a socially responsible manner, respecting the protection of minors, vulnerable and at-risk groups, not appealing to the easy obtaining of winnings, not suggesting success, social success or special skills as a result of gambling, nor encouraging excessive gambling or betting practices. The advertising of games and betting that is directed at or uses minors as participants in the message is expressly prohibited.

The ultimate definition of the target audience, of the markets and compliance with licensing, age restriction and responsible gambling obligations rest with the operator-client. Vexia may refuse, suspend or terminate the provision of services, the execution of campaigns or the collaboration when it identifies a risk of breach of legal, regulatory or advertising requirements, of the protection of minors, responsible gambling, brand safety, data protection, intellectual property rights or reputation.

6. Permitted use of the website

The User undertakes to use the website in a lawful, correct, transparent manner and in compliance with these Terms, with applicable legislation and with the rights of Vexia, its clients, partners and third parties.

The following is prohibited, in particular:

• using the website for unlawful, fraudulent, abusive, defamatory, discriminatory, offensive purposes or contrary to good faith;
• attempting to access, interfere with, compromise, test or circumvent Vexia's systems, networks, servers, security measures, authentication, firewalls, rate limits, logs or technical mechanisms;
• using bots, crawlers, scrapers, spiders, automated systems or mass-extraction techniques without express authorisation;
• introducing malware, ransomware, spyware, viruses, malicious scripts, denial-of-service attacks or any harmful code;
• copying, modifying, reproducing, distributing, selling, licensing, republishing or commercially exploiting website content without authorisation;
• using Vexia's brands, names, logos, materials, screenshots, images, videos, methodologies, reports or content in an unauthorised manner;
• submitting false, incomplete, misleading, unlawful, third-party information without authorisation or that infringes intellectual property rights, privacy, trade secrets or confidentiality;
• using the website to promote operators, campaigns, products, services or activities that are prohibited, unlicensed or directed at minors or vulnerable groups where this is legally barred.

7. "Book a Meeting", forms and contacts (B2B)

The website provides the "Book a Meeting" feature and may provide other buttons, links or forms for requesting contact, presenting proposals, demonstrations or interacting with the Vexia team. This feature is directed at professional contacts and may be operated through a third-party tool (HubSpot or equivalent).

When submitting a form or booking a meeting, the User must provide true, up-to-date, adequate information that is necessary for the purpose of the contact. Vexia may contact the User to manage the request, prepare the meeting, respond to the message, assess service needs, carry out commercial follow-up or comply with legal and contractual obligations.

The submission of a form does not oblige Vexia to accept any request, meet with the User, present a proposal, provide services, establish a partnership or enter into a contract.

Acceptance of these Terms, the use of a form or the acknowledgement of the Privacy Policy does not in itself constitute consent to direct marketing, which depends on a separate basis.

8. Restricted area, account or login, if any (B2B)

Should Vexia make available a restricted area, dashboard, portal, client account, authentication or login functionality, additional rules, specific terms, access levels, security requirements, password policies, multi-factor authentication and their own conditions of use may apply.

The User is responsible for maintaining the confidentiality of credentials, using individual access, not sharing accounts, not allowing unauthorised access and immediately reporting any suspicion of misuse, loss, theft, compromise or security breach.

Vexia may suspend, limit or cancel access where there are indications of misuse, breach of these Terms, contractual breach, security risk, fraud, unauthorised access or a need to comply with a legal obligation or an order of a competent authority.

9. Intellectual and industrial property

All website content, including texts, brands, logos, trade names, graphics, images, videos, animations, icons, design, layout, code, databases, methodologies, reports, structures, materials, slogans, presentations, know-how and other protected elements, belong to Vexia or to third parties that have authorised their use.

Access to the website does not grant the User any intellectual or industrial property right over the content made available, except for a limited, revocable, non-exclusive and non-transferable licence to access and view the website for legitimate purposes and in accordance with these Terms.

The reproduction, distribution, public communication, transformation, extraction, reuse, licensing, sale, commercial exploitation or unauthorised use of the website content is prohibited, except with the prior written consent of Vexia or where permitted by law.

10. References to brands, clients, partners and third parties

The website may contain references to brands, clients, operators, partners, platforms, suppliers, channels, social networks, trade names, logos or other distinctive signs of third parties, including brands of iGaming operators.

Such references are used for informational, descriptive, commercial or demonstrative purposes regarding Vexia's activity and do not imply, unless expressly stated, that there is a partnership, sponsorship, recommendation, certification, affiliation, representation or approval by the referenced entity.

The display of brands, logos or distinctive signs of clients, operators or partners on the website presupposes the written authorisation of the respective holder or another legitimate basis for use. Vexia keeps a record of such authorisations and removes or updates any reference upon legitimate request of the rights holder. Any content related to games and betting that may be presented is intended exclusively for persons over 18 years of age; Vexia is not a gambling operator and promotes responsible gambling.

The brands, logos and content of third parties belong to their respective holders. Vexia may remove or change references where requested by the legitimate holder, where there is an error, where the commercial relationship ceases or where it considers it necessary for legal, reputational, contractual or compliance reasons.

11. Content submitted by the User

By sending information, documents, materials, briefings, data, files, messages, presentations, brands, images, screenshots, reports, credentials, access or any other content to Vexia, the User declares that they have the legitimacy to do so and that such submission does not infringe third-party rights, confidentiality obligations, intellectual property, data protection or applicable laws.

The User must not send Vexia unnecessary personal data, data of minors, special categories of data, health data, biometric data, sensitive financial data, credentials, client lists, audiences, first-party data or other sensitive information without a legal basis, a concrete need, documented instructions and adequate security measures.

Vexia may delete, return, block, refuse or request the correction of content that it considers excessive, unlawful, unnecessary, insecure, confidential, unauthorised or incompatible with the request presented.

12. Data protection, privacy and cookies

Use of the website may involve the processing of personal data. Such processing is governed by Vexia's Privacy Policy, available at www.vexia.com, which must be read together with these Terms and which expressly covers the B2B model and the B2C data-processing model.

The website may use cookies, pixels, tags, SDKs or similar technologies. The use of cookies or technologies that are not strictly necessary depends on the User's consent or on another applicable legal basis, as described in the Cookie Policy, available at www.vexia.com.

Where Vexia processes personal data of consumers on behalf of operator clients, in connection with campaigns, analytics, AdTech, reporting, custom data processing, custom modelling or dashboards, it typically acts as a processor or joint controller, with such relationship being governed by contract and, where applicable, by a data-processing agreement, documented instructions, security measures, sub-processing rules, international transfers, retention and deletion.

13. Social networks, plugins and external links

The website may contain links to social networks, third-party pages, advertising platforms, scheduling tools, video services, websites of partners, clients, suppliers or other external resources.

By clicking on external links, the User leaves the environment controlled by Vexia and begins to browse websites or platforms subject to their respective terms of use, privacy policies, cookie policies, community rules, ad preferences and privacy settings.

Vexia does not control and is not responsible, except where legally applicable, for content, availability, security, cookies, policies, privacy practices, advertising, automated decisions, sponsored content, communications, services or damages resulting from the use of third-party websites or platforms.

Where there are social plugins, pixels, tags or integrations with social networks on the website, these must be identified in the Cookie Policy and, where not strictly necessary, depend on the User's prior consent.

14. Availability, security and changes to the website

Vexia seeks to keep the website available, secure, functional and up to date, but does not guarantee that access will be continuous, uninterrupted, error-free, free of vulnerabilities, compatible with all devices or suitable for all the User's needs.

The website may be temporarily suspended, limited or interrupted for reasons of maintenance, updating, security, technical failures, unavailability of suppliers, incidents, force majeure, orders of authorities, legal changes or other justified reasons.

Vexia may implement technical and organisational measures to protect the website, including anti-bot mechanisms, blocking of invalid traffic, filtering of VPN or suspicious traffic, security logs, firewalls, access control, monitoring, backups and incident response.

15. Exclusion and limitation of liability

To the maximum extent permitted by law, Vexia shall not be liable for damages resulting from:

• improper use of the website by the User;
• temporary unavailability, errors, failures, interruptions or technical limitations of the website;
• content, services, cookies, policies or practices of third-party websites, social networks or platforms;
• decisions made on the basis of general information made available on the website without specific contractual, technical, legal or regulatory analysis;
• campaigns, products, services, content or operations of clients, operators, partners or third parties that are not under Vexia's direct control;
• loss of data, loss of profits, loss of opportunity, loss of reputation, indirect, special, incidental or consequential damages, except where liability cannot be excluded by law.

Nothing in these Terms excludes or limits liability that cannot be excluded or limited by law, including liability for wilful misconduct, gross negligence, personal injury where applicable or other legally non-waivable warranties.

Given that the website is institutional and B2B in nature and does not establish consumer relationships with end consumers, the exclusions set out in this clause apply between professionals. If, in any circumstance, the User qualifies as a consumer, these exclusions and limitations apply only to the extent permitted by the regime on general contractual terms (Decreto-Lei n.º 446/85, de 25 de outubro) and by the mandatory consumer-protection rules, without prejudice to the rights conferred on them by law that cannot be set aside by agreement.

16. Confidentiality

Non-public information communicated between Vexia and the User in the context of meetings, proposals, briefings, campaigns, technology, data, pricing, methodologies, reports, commercial documents, access or projects may be subject to confidentiality, even if there is no formal signed contract, whenever by its nature or circumstances it should reasonably be treated as confidential.

The specific confidentiality of projects, clients, campaigns, data, know-how, pricing, proposals, dashboards, integrations, APIs, models or technical materials must be governed by a contract, NDA or specific clause where necessary.

17. Electronic communications

By contacting Vexia through a form, email, scheduling tool, telephone, social networks or another channel, the User accepts that Vexia may respond through the contacts provided, to the extent necessary to manage the request, prepare meetings, provide clarifications, carry out commercial follow-up or comply with legal and contractual obligations.

The sending of commercial communications or newsletters must comply with the applicable legal requirements, including consent where required, clear information about the purpose and a simple mechanism for cancellation or objection.

18. Complaints, Complaints Book and alternative dispute resolution

The User may contact Vexia for matters relating to the website, services, content, commercial requests, privacy or the exercise of rights through the contacts indicated in these Terms and in the Privacy Policy.

The website is institutional and B2B in nature and Vexia does not establish, through it, consumer relationships with end consumers. As a result, as a rule, neither the Complaints Book regime nor the consumer alternative dispute resolution regime applies.

Should Vexia establish, currently or in the future, direct consumer relationships with consumers, it will make available access to the Electronic Complaints Book on the website, through a dedicated link to https://www.livroreclamacoes.pt/Inicio/, and will inform about the competent consumer alternative dispute resolution entity or the one to which it is bound, under the terms of Lei n.º 144/2015, de 8 de setembro. ADR entity (where applicable): [x]. Website: [x].

The submission of a complaint, request for information or request for dispute resolution does not prejudice the User's right to resort to the competent authorities or the courts, under applicable legal terms.

19. Suspension or termination of access

Vexia may suspend, block, limit or terminate access to the website, forms, restricted area or features where it finds a breach of these Terms, misuse, security risk, attempted unauthorised access, submission of unlawful information, fraud, infringement of rights, orders of a competent authority or a need to protect Vexia, users, clients, partners, systems or data.

Suspension or termination does not prejudice Vexia's right to resort to the legal and contractual means available to defend its rights and legitimate interests.

20. Changes to the Terms

Vexia may change these Terms at any time, in particular to reflect legal, regulatory, technical, operational, commercial, security, service, feature, business-model or internal-practice changes.

The version in force will be published on the website, indicating the date of the last update. Use of the website after the publication of changes implies acceptance of the updated Terms, except where the law requires another procedure.

21. Governing law and competent jurisdiction

These Terms, relating to the use of the website, are governed by Portuguese law, without prejudice to mandatory consumer-protection rules or other mandatory rules applicable depending on the jurisdiction of the User, the target market, the services contracted or the campaigns developed. Where the User interacts with the Vexia group through a company established in another jurisdiction (in particular in Brazil or Malta), or where the relationship is with that entity, the law and jurisdiction corresponding to that entity may also apply, under the applicable contracts and the mandatory rules in force.

For the resolution of disputes arising from the use of the website, the legally applicable Portuguese courts shall have jurisdiction, without prejudice to mandatory rules of territorial jurisdiction, alternative dispute resolution means or specific contractual provisions agreed with clients or partners.

These Terms may be made available in Portuguese and in English. In the event of a divergence of interpretation between language versions, and except where the applicable law imposes a different solution, the Portuguese version prevails.

22. Contacts

For matters relating to these Terms, the User may contact Vexia through:

• Legal/compliance email: legal@vexia.com
• Privacy/DPO email: dpo@vexia.com
• Address: Alameda das Antas, 30, 4350-413 Porto

23. Legal references considered

In preparing these Terms, the following diplomas and regimes were considered, in particular, without prejudice to a final legal validation in light of Vexia's actual activity and the jurisdictions covered by each campaign:

• Regulation (EU) 2016/679, of 27 April 2016 (GDPR);
• Lei n.º 58/2019, de 8 de agosto, which ensures the implementation of the GDPR in Portugal;
• Lei n.º 41/2004, de 18 de agosto, relating to privacy in electronic communications, as currently in force;
• Decreto-Lei n.º 7/2004, de 7 de janeiro, relating to electronic commerce and information society services, as currently in force;
• Decreto-Lei n.º 446/85, de 25 de outubro, relating to general contractual terms, as currently in force;
• Decreto-Lei n.º 156/2005, de 15 de setembro, relating to the Complaints Book, as currently in force, where applicable;
• Lei n.º 144/2015, de 8 de setembro, relating to consumer alternative dispute resolution, where applicable;
• Advertising Code, approved by Decreto-Lei n.º 330/90, de 23 de outubro, as currently in force, including rules on games and betting;
• Legal Regime for Online Games and Betting, approved by Decreto-Lei n.º 66/2015, de 29 de abril, as currently in force;
• Rules and guidelines applicable to digital advertising, advertising platforms, social media, AdTech, protection of minors, responsible gambling, consumers, intellectual property and regulated sectors.