Terms of Service for the flenski.io Platform#

Last updated: 1 August 2026

This English translation is provided for convenience only. The German version is the legally binding version and prevails in case of discrepancies.

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Section 1 Provider, Scope, and Contract Structure#

(1) Provider. The flenski.io platform is operated by Flenski FZCO, Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates ("Flenski"), registered with the International Free Zone Authority (IFZA), Dubai, represented by Thomas Seewald (Manager).

(2) EU Representative. The appointment of an external representative in the European Union (Art. 27 GDPR and — in the same person — Art. 13 of the EU Digital Services Act (DSA)) has been initiated; once the appointment is complete, the representative will be named identically here as well as in the Legal Notice and the Privacy Policy. Until then, the data protection contact Finn Hansen (finn@flenskiteam.com) is the point of contact for matters that would fall to the EU representative.

(3) Subject Matter of These Terms of Service. These Terms of Service govern the use of the platform only. They do not govern the purchase of a Flenski plan.

(4) Purchase via the Merchant of Record. Flenski plans are purchased through a merchant of record (currently: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany). For the purchase, the Creator's contracting party is exclusively the merchant of record. Ordering, payment, subscription term, renewal, cancellation of the subscription, withdrawal, and refunds are governed exclusively by the contract with the merchant of record and its terms as applicable from time to time; these are available on its website (currently: https://www.digistore24.com/page/terms). This reference is provided for information only; the merchant of record's terms do not become part of these Terms of Service, and Flenski accepts no responsibility for their content. These Terms of Service govern the use of the platform only; they neither restate nor modify the merchant of record's provisions. Which plan includes which features and quotas is set out in the current plan overview.

(4a) Business and Consumer Purchases. Flenski's offering is directed at businesses; prices are exclusive of VAT. In the merchant of record's checkout, orders can also be placed as a consumer (private purchase). For orders placed through the merchant of record, its terms provide a 14-day right of withdrawal and a 30-day goodwill refund policy.

(5) Personal Scope. These Terms of Service apply to Creators, including their team members (Section 2). For members, only Sections 5 (Accounts), 8 (Prohibited Content and Uses), 9 (Notice Procedures and Complaints), 13(3) (AI Output Disclaimer), and 16 (Intellectual Property) apply, and only insofar as they concern members' use of the platform. The obligations of Creators — in particular indemnification (Section 19), the legal-pages obligation (Section 6), and the choice of law (Section 22(2)) — do not bind members. A member's contractual relationship regarding content and offerings exists exclusively with the respective Creator (Section 4).

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Section 2 Definitions#

• Platform: the SaaS platform flenski.io as a whole (software, infrastructure, interfaces).
• Creator (community operator): Flenski's customer — the natural or legal person who operates a workspace and publishes Memberapps.
• Member (the Creator's end customer): the end user of a Memberapp; the Creator's contracting party and data subject under data protection law.
• User: umbrella term for Creators and members. Where these Terms of Service use "user", they apply to both groups; otherwise, each provision states whom it binds.
• Memberapp (app): an individual members area with its own URL, its own members, and its own content within a workspace — reachable at a subdomain of the form name.flenski.app (name.flenski.net for existing customers; in the future also under additional platform domains) or at the Creator's own domain.
• Workspace: the account-level container of a Creator (plan, team, domains, integrations, legal pages, contacts, cloud, access plans).
• Team member: a person invited into the workspace by the Creator; team roles are Owner, Admin, and Team member.
• Contact (lead): a personal data record at workspace level without an app membership (e.g. from lead forms).

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Section 3 Description of the Platform#

(1) Flenski is a cloud-based software-as-a-service platform that provides technical tools and infrastructure, in particular to: build digital communities, manage members areas (Memberapps), provide digital content, organize online courses, provide downloads, manage events, enable community communication, use automations and integrations, and use AI-powered features (Section 13).

(2) The specific scope of services depends on the booked plan, the features available at the time, and any individual supplementary agreements. Flenski does not owe any particular commercial outcome.

(3) Ongoing Development. The platform is continuously developed. Flenski may change, add, or discontinue features, provided the core of the contractually owed service is preserved and the change is reasonable for the Creator, taking both parties' interests into account. Flenski will notify Creators of the discontinuation of material features at least 30 days in advance in text form.

(4) Beta Features. Individual features may be labeled "Beta", "Preview", or equivalent. Beta features are provided at a trial stage; there is no entitlement to their availability, freedom from defects, or continued provision, and they may be changed or discontinued at any time. The Creator is solely responsible for using beta features in production for business-critical processes. In particular, new AI and MCP features may be provided as beta features; for beta features, warranty applies only to the limited extent set out in this paragraph.

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Section 4 Flenski's Role — Separation of Platform / Creator / Member#

(1) Flenski ↔ Creator. Flenski provides the technical platform and infrastructure only. Flenski does not itself become the provider, seller, reseller, or contracting party of the content, products, or services offered by Creators.

(2) Creator ↔ Member. The Creator is the sole provider of, and contracting party for, its members and is solely responsible for its content and offerings. All sales, contracts, and service relationships with members are concluded in the Creator's name, for the Creator's account, and under the Creator's legal responsibility. The Creator is the controller under data protection law for the data of its members and contacts.

(3) Flenski ↔ Member. There is no contractual relationship between Flenski and members regarding content or offerings. Flenski processes members' data as the Creator's processor (Section 17). In particular, Flenski does not act as: merchant of record for Creator sales, payment service provider, reseller, provider of courses or coaching, event organizer, education provider, or intermediary with its own contractual responsibility.

(4) No Access to Content. Flenski does not operate a software backend with visibility into Creators' workspaces and apps. Access by Flenski staff is possible only via a moderator login into the respective app (technically identical to a moderator appointed by the Creator) — and only if the Creator has previously expressly enabled this access via a toggle (workspace settings → Team). This authorization can be revoked at any time. Independently of this, automated technical processing of content takes place (in particular transcoding, transcription, OCR, indexing for search and AI features, and CDN delivery), as described in the Privacy Policy and the Data Processing Agreement.

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Section 5 Registration and Accounts#

(1) Using the platform as a Creator requires an account and a workspace; using a Memberapp as a member generally requires a member account in the respective app.

(2) Users (Creators and members) undertake to: provide truthful information, keep credentials confidential, not enable unauthorized access, not use other people's accounts, and use the platform only within the bounds of applicable law.

(3) The Creator is responsible for all activities carried out through its account, the accounts of its team members, or interface sessions it has authorized (Section 12). A member is responsible for the activities carried out through their own member account.

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Section 6 Creator Obligations; Each Memberapp's Own Legal Pages#

(1) Sole Responsibility. Creators are solely responsible for: all published content; the products and services they offer; pricing information and sales pages; statutory information duties; withdrawal notices; tax obligations; the data protection compliance of their apps, including the trackers, pixels, and consent solutions they embed; Legal Notice requirements; competition law; compliance with the German Distance Learning Protection Act (FernUSG) and the requirements of the German State Central Office for Distance Learning (ZFU); health- and finance-related claims; and compliance with all other laws applicable to them and their offerings. Flenski does not conduct any legal review or ongoing monitoring of Creators' content and offerings.

(2) Obligation to Provide Own Legal Pages — Before Publication. For each Memberapp, the Creator must, before making it accessible to members or other third parties, put in place its own Legal Notice identifying the Creator as the provider and its own Privacy Policy, as well as — where required for its offering — its own terms and conditions and withdrawal notices. The same applies to an app's public surfaces (in particular landing pages, standalone pages, lock screens, and lead forms).

(3) Tool Provided. Flenski provides the "Legal Pages" feature for this purpose (workspace settings → Legal Pages). There, the Creator manages, per set, the documents Legal Notice, Privacy Policy, Terms of Service, and terms and conditions — as its own text or as a reference to an external URL — and assigns the set to one or more apps. The platform automatically links the legal pages stored by the Creator on the Memberapp's surfaces; depending on the design, they are always reachable there within at most two clicks. In addition, the Creator can add them to the app's navigation. The Creator can edit the linking independently; if the Creator edits or removes the automatically placed links, this is solely the Creator's responsibility — the obligation under paragraph 2 and the suspension right under paragraph 5 remain unaffected.

(4) Demo Texts Are Not Sufficient. Every new app is created with a starter set of demo legal texts. These demo texts are placeholders and expressly do not satisfy the obligation under paragraph 2. The Creator must replace them with its own legal texts before publication.

(5) Breach as Grounds for Suspension. If a Creator makes an app accessible without its own Legal Notice or without its own Privacy Policy, or leaves demo legal texts live, Flenski is entitled, following the procedure in Section 20, to unpublish the affected app (make it inaccessible to third parties) and, in the event of continued breach, to suspend the account. The indemnification under Section 19 expressly also covers claims and regulatory measures arising from the Creator's breach of statutory information duties.

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Section 7 User Content and Grant of Rights#

(1) Users can publish or upload content on the platform, in particular text, images, videos, audio files, PDFs, community posts, comments, chat messages, downloads, and course content. The user who publishes content is solely responsible for it. Flenski does not adopt third-party content as its own.

(2) The user warrants that they hold all rights required for the content they upload.

(3) Grant of Rights. The user grants Flenski the simple, non-exclusive, worldwide right to reproduce, store, technically process, and make accessible the content they post, solely for the purpose of operating the platform — in particular for hosting, transcoding, transcription, optical character recognition (OCR), indexing for search and AI features, and delivery via content delivery networks. This grant of rights is limited to the purpose of the contract and ends when the content is deleted or the contract ends, subject to technically required residual storage in backups in accordance with the Data Processing Agreement.

(4) No AI Training. Flenski does not use user content in any form to train AI models — including for the locally operated Flenski AI (Section 13). This assurance does not apply to third-party providers that the Creator connects via its own API key (Section 13(1) no. 2); their handling of transmitted data is governed exclusively by the respective provider's terms and is the Creator's responsibility.

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Section 8 Prohibited Content and Uses#

(1) The following in particular are prohibited: unlawful content, hate speech, glorification of violence, discriminatory content, terrorist content, pornographic content, copyright infringement, fraudulent content, spam, malware, phishing, security attacks, automated abusive use, misleading health or financial promises, and violations of data protection laws.

(2) These prohibitions apply equally to Creators and members. Measures in the event of violations are governed by Sections 9 and 20.

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Section 9 Notice Procedures, Moderation, and Complaints (DSA)#

(1) Notice Procedure. Any person can report content to Flenski that they consider unlawful. Reports must be sent to the central point of contact under Section 22(4) (support@flenski.io); this reporting channel is electronic and accessible without a login. A report should include: the exact location (URL), a statement of the reasons why the content is allegedly unlawful, and the reporting person's name and email address (except for reports concerning criminal offenses within the meaning of the relevant DSA exception). Flenski confirms receipt and informs the reporting person of the decision taken.

(2) Distinction from Reports to the Creator. The reporting feature built into Memberapps for community posts is directed at the respective Creator as the moderator of their app. Paragraph 1 concerns reports to Flenski as a hosting service provider.

(3) Moderation Principles. Flenski does not monitor content without cause. If Flenski becomes aware of allegedly unlawful content or violations of Section 8, Flenski examines the individual case and may remove or block content, restrict its visibility, or take measures under Section 20. When examining reports, Flenski acts diligently, free from arbitrariness, and with due regard for the fundamental rights concerned.

(4) Statement of Reasons. If Flenski removes or blocks a user's content or restricts its visibility, Flenski informs the affected user of the decision and its material reasons, including the legal basis or the contractual provision breached, unless a statutory exception applies (e.g. an official order requiring confidentiality).

(5) Internal Complaint Procedure. The affected user can lodge a complaint with Flenski against decisions under paragraph 4 and against account measures under Section 20 within six months; complaints must be sent through the same contact channel as reports under paragraph 1 (central point of contact under Section 22(4), support@flenski.io). Flenski reviews the decision through a person assigned to it (not exclusively by automated means) and communicates the outcome with reasons.

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Section 10 Creators' Payment Processing#

(1) Creators can use external payment service providers, merchant-of-record providers, checkout systems, or other third-party providers to sell their own products and services — for example via direct payment provider integrations, external checkout systems, payment and registration links, funnel systems, API integrations, or automation services. Providers that may be supported include, for example, Digistore24, CopeCart, Ablefy, ThriveCart, SamCart, Stripe, and PayPal.

(2) The Creator selects and uses such services at its own responsibility (Section 11). In the relationship between Creator and member, Flenski is not a seller, payment service provider, merchant of record, reseller, party to the sales process, or payment processor, and does not process payments in its own name for Creators' products or services. Payment processes, settlements, refunds, tax obligations, and chargebacks are governed exclusively by the terms of the providers used.

(3) The use of Digistore24 as merchant of record for the purchase of Flenski plans (Section 1(4)) is to be distinguished from this and remains unaffected.

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Section 11 Third-Party Integrations and Services Connected by the Creator#

(1) Flenski provides interfaces and integrations to third-party providers, in particular: payment providers (Section 10), autoresponders/CRM (e.g. KlickTipp, Quentn, ActiveCampaign, Brevo, HubSpot), Zapier and Make, custom webhooks, custom SMTP, external video sources (YouTube, Vimeo, Loom, Spotify), tracking pixels (Google Analytics, Meta, TikTok, LinkedIn), AI providers via the Creator's own API keys (Section 13(3)), and MCP clients (Section 12).

(2) Creator's Responsibility. Services connected by the Creator are recipients or the Creator's own processors, not Flenski's subcontractors or subprocessors. When the Creator activates a connection, this constitutes the Creator's documented instruction to transmit the data required for the function to the connected service. The choice of provider, the legal basis for the transfer, any separate Data Processing Agreement with the provider, any third-country transfers, and any required consents (in particular for tracking pixels) are the Creator's responsibility.

(3) Flenski accepts no responsibility or warranty for third-party services, content, availability, or terms. If a third-party provider changes or discontinues its interfaces, the affected integration may be limited or cease to exist; Section 3(3) applies accordingly.

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Section 12 MCP Interface (Connecting External AI Tools)#

(1) Function. Via the MCP interface (Model Context Protocol; workspace settings → MCP), the Creator can connect an external AI tool (currently supported: Claude and ChatGPT) to exactly one app through an authorized session. Within the authorized session, the connected tool can act on the Creator's behalf, in particular creating and deleting content. The Creator itself configures, at a granular level in the settings, which data and rights an MCP session receives; the chosen configuration and its scope are the Creator's responsibility. Each connection applies to exactly one app; active sessions are displayed with their last activity and can be revoked individually.

(2) Attribution and Authority. The connection is established independently by the Creator (or its team roles authorized to do so) and is the Creator's responsibility. By authorizing an MCP session, the Creator authorizes the connected MCP client to perform acts and make declarations vis-à-vis Flenski with effect for and against the Creator for the duration and within the configured scope of that session (by analogy with Section 164(1) of the German Civil Code (BGB)). In doing so, the MCP client acts exclusively as a technical tool and as a recipient or service provider engaged by the Creator — not as Flenski's vicarious agent, representative, or processor. All actions performed through an authorized MCP session are therefore deemed, in the relationship with Flenski, to be the Creator's own acts and instructions, even if the AI tool performed them autonomously; the Creator cannot object to Flenski that it did not intend or initiate an individual action, as long as the session was authorized and not revoked.

(3) Creator's Duties of Care. The Creator must:

• keep the MCP URL and access/session tokens confidential and not disclose them to unauthorized persons;
• connect only MCP clients whose provider and data processing the Creator has vetted; the connected client is the Creator's recipient or service provider within the meaning of Section 11(2) — including the instruction and data protection consequences set out there;
• take into account that content and data of the connected app may flow to the client provider through an MCP session, and take responsibility for this vis-à-vis its members under data protection law;
• regularly review active sessions and immediately revoke sessions it no longer recognizes or no longer needs.

(4) No Restoration, No Liability for Third-Party Systems. There is no entitlement to the restoration of content changed or deleted through an authorized MCP session. Flenski is not liable for third-party systems connected via MCP, their actions, outages, or data processing; Section 18 remains unaffected.

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Section 13 AI Features#

(1) Two Operating Modes. The platform's AI-powered features run in one of two operating modes:

1. Local Flenski AI (default). All AI features of the platform — in particular transcription of video and audio content, optical character recognition (OCR), indexing for search and AI features, and summaries and AI answers (including GPTs/AI Coach, admin assistant, AI page builder) — run by default on a Flenski-owned server at Hetzner in Germany with locally installed AI. No third-party AI is used for these features and no third-country transfer takes place. 2. Bring Your Own Key (BYOK). The Creator can store its own API key from an AI provider (Claude, ChatGPT, DeepSeek, Gemini) and run AI features through it; the respective feature then runs not through the local Flenski AI but through the provider chosen by the Creator. In that case, the contractual and data protection relationship with the AI provider exists exclusively between the Creator and that provider; the provider's terms and prices apply, and the Creator bears the costs as well as the responsibility for the lawfulness of the processing — including the fact that content of its app and inputs of its members are transmitted to that provider. Section 11(2) applies accordingly. Flenski stores the key solely for the technical execution of the features; the key is stored encrypted, and requests are routed through Flenski as a technical proxy to the respective AI provider.

Flenski does not use user content to train AI models (Section 7(4)); this assurance does not apply to BYOK third-party providers.

(2) AI Coach / GPTs; AI Labeling (Art. 50 AI Act). Members can chat with AI assistants based on the indexed content of the respective app (in particular transcripts, OCR results, and community posts). A GPT's knowledge is isolated per app. The platform's AI features with which members interact directly (in particular AI Coach/GPTs) are designed so that members can recognize that they are interacting with an AI system; to this end, the platform displays a corresponding label by default (Art. 50(1) of Regulation (EU) 2024/1689 — the "AI Act"). The Creator uses the AI features in its Memberapp at its own responsibility as a deployer within the meaning of the AI Act. The Creator must not remove, obscure, or alter the meaning of the label provided, and must ensure that its use of the AI features complies with the transparency obligations applicable to it. Answers and content generated by AI features are deemed, in the relationship with members, to be the Creator's content within the meaning of these Terms of Service.

(3) AI Output Disclaimer. AI-generated results (transcriptions, summaries, generated content, analysis and recommendation outputs, chat answers) can be incorrect, incomplete, or inaccurate. Users must review AI-generated content on their own responsibility before using or publishing it. Flenski accepts no liability for decisions, publications, or actions based on AI-generated content; Section 18 remains unaffected.

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Section 14 Platform Availability#

(1) Flenski strives for high availability of the platform. There is no entitlement to uninterrupted availability, permanent accessibility, error-free operation, or particular loading times. Maintenance, technical faults, updates, security measures, and force majeure can temporarily restrict use. Flenski announces plannable maintenance with significant impact in advance where possible.

(2) Data Backups. Flenski backs up platform data as part of the technical and organizational measures described in the Data Processing Agreement, in particular through regular backups (daily backups retained for 30 days, monthly backups retained for 12 months, and event-driven update/hotfix backups retained for 30 days). Independently of this, it is the Creator's responsibility to additionally back up business-critical data on a regular basis using the export features provided (Section 20(5)).

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Section 15 Quotas and Usage Limits#

(1) The booked plan determines quotas (in particular the number of apps, members, contacts, connected domains, and team members) and the feature scope. The information under workspace settings → Payment Plan and the plan comparison are decisive.

(2) If a quota is exceeded, the platform can block the creation of new items. If the Owner's plan limits are exceeded, the following staged procedure applies before any suspension or deactivation: first, a clearly visible (red) notice banner is shown to the workspace Admin for 14 days; if the excess is not remedied within that time, the notice banner is additionally shown to the members of the affected apps for a further 30 days; only after these periods have expired are the affected apps suspended or deactivated. Deactivation does not delete any content; after returning within the plan limits or changing plans, the app can be reactivated.

(3) Fair Use. The platform must be used within the contractually intended, customary scope. Abusive use or use that places a disproportionate load on the infrastructure is prohibited, in particular automated bulk retrievals or bulk actions outside the interfaces provided for this purpose, the circumvention of technical limits, and any use that significantly impairs the availability of the platform for other users. For automated access, the interfaces provided (in particular API, webhooks, MCP, Sections 11 and 12) must be used as a matter of priority. Where Flenski sets specific quotas or limits for individual resources, these are stated in the current plan overview and announced with reasonable advance notice. <!-- Internal note: specific fair-use limits (storage, transcription/AI volume, API rates) to be added later — the platform is being continuously overhauled, figures will go into the plan overview. -->

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Section 16 Intellectual Property in the Platform; Reference Naming#

(1) All rights in the platform, its software, its technical structures, designs, trademarks, and features remain with Flenski or the respective rights holders. Users receive only a simple, non-transferable right of use within the scope of the services booked or provided. The following in particular are not permitted: reverse engineering, copying material parts of the platform, reselling the platform software, circumventing technical protection measures, and unauthorized automated data collection.

(2) Reference Naming. Flenski names a Creator (including their name, brand, or logo) as a reference only with their prior consent. The Creator can revoke consent once given at any time with effect for the future.

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Section 17 Data Protection and Data Processing on Behalf of the Controller#

(1) Insofar as Creators process personal data of their members and contacts, they are independent controllers under data protection law. Flenski processes this data as the Creator's processor.

(2) The Data Processing Agreement (DPA) under Art. 28 GDPR is a mandatory part of the contractual relationship between Flenski and the Creator. It is concluded via the DPA generator in the workspace settings: the Creator enters its details as the controller into a form and thereby creates its own DPA; it can also be retrieved there.

(3) Information on the processing of personal data by Flenski is set out in the Privacy Policy.

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Section 18 Flenski's Liability#

(1) Unlimited Liability. Flenski is liable without limitation: in cases of intent and gross negligence; for damages arising from injury to life, body, or health; under the provisions of the German Product Liability Act; to the extent of a guarantee assumed by Flenski; and in cases of fraudulent concealment of a defect.

(2) Liability for Ordinary Negligence. In cases of ordinarily negligent breach of other obligations, Flenski is liable only if a material contractual obligation (cardinal obligation) is breached. Material contractual obligations are those whose fulfillment is essential to the proper performance of the contract in the first place and on whose observance the contracting party regularly relies and may rely. In that case, liability is limited in amount to the damage typical for the contract and foreseeable at the time the contract was concluded.

(3) Data Loss. For loss of data caused by ordinary negligence, Flenski is liable within the scope of paragraph 2 only up to the typical recovery cost that would have been incurred if the data had been backed up regularly and in a manner appropriate to the risk. The Creator's export options (Section 20(5)) remain unaffected.

(4) Exclusion in All Other Respects. Any further liability of Flenski is excluded. Subject to paragraphs 1 and 2, Flenski is in particular not liable for: Creators' content and offerings, community content, course or coaching outcomes, Creators' loss of revenue or profit, users' actions, third-party integrations and payment providers connected by the Creator (Sections 10–12), technical faults outside Flenski's sphere of influence, and AI-generated content (Section 13(3)).

(5) Scope. The above limitations of liability also apply to the personal liability of Flenski's corporate bodies, legal representatives, employees, and vicarious agents, as well as to concurrent non-contractual claims.

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Section 19 Indemnification (Creators Only)#

(1) Indemnification. The Creator indemnifies Flenski against all third-party claims — including regulatory proceedings and the necessary costs of legal defense in a reasonable amount — that are raised against Flenski and are based on the Creator culpably: having posted unlawful content; having violated statutory provisions, in particular data protection, copyright, trademark, or competition law; having breached statutory information duties (in particular a missing or incorrect Legal Notice or a missing Privacy Policy for a Memberapp, Section 6); having made infringing offers or performed infringing acts within its communities; or having initiated actions through interface sessions it has authorized (Section 12).

(2) Fault Requirement. The indemnification obligation exists only insofar as the Creator is responsible for the underlying infringement. It applies exclusively to Creators, not to members.

(3) Information and Cooperation. Flenski will inform the Creator of asserted claims without undue delay in text form and, insofar as reasonable for Flenski, will not make any acknowledgment or conclude any settlement without the Creator's consent — which must not be unreasonably withheld. The Creator will provide Flenski without undue delay and free of charge with all information and documents required to assess the claims and conduct the legal defense.

(4) Coordination of Defense. Flenski is entitled to conduct and coordinate the defense against the claims itself; the Creator will coordinate with Flenski for this purpose and support legal defense measures to the best of its ability. Flenski's further statutory claims, in particular for damages, remain unaffected.

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Section 20 Measures in Case of Violations; Term, Termination, and Data Export#

(1) Staged Measures. In the event of violations of these Terms of Service or statutory provisions, Flenski may, exercising due discretion and observing proportionality: issue a warning to the user and demand remedy within a reasonable period; remove or block individual content (Section 9); restrict or unpublish individual features or apps; temporarily suspend the account; or terminate the contractual relationship for cause. In the event of serious violations (in particular infringements posing a risk of harm to third parties, security attacks, or criminal content), Flenski may take measures without prior warning.

(2) Statement of Reasons and Complaints. Section 9(4) (statement of reasons) and Section 9(5) (internal complaint procedure) apply accordingly to measures under paragraph 1.

(3) Term. The term of access is determined by the plan booked through the merchant of record (Section 1(4)). If the subscription with the merchant of record ends or the merchant of record notifies Flenski of non-payment, access to the plan-bound services ends or is paused accordingly. Both parties' right to terminate for cause remains unaffected.

(4) Consequences of Termination — Downgrade Instead of Automatic Deletion. Upon termination of the contractual relationship, the Creator's right to use the plan-bound services ends. If the plan is deactivated or expires, the account is downgraded to a free account. The data stored in the workspace is retained until the Creator itself expressly deletes it; no automatic deletion takes place. Deletion on the Creator's instruction and statutory retention obligations are governed by the Data Processing Agreement and remain unaffected.

(5) Data Export. The platform provides export features: members of an app (with selectable columns including custom fields, plans, and tags), contacts at workspace level, downloads, and an app itself as a complete or customized copy via app key. The Creator can use these exports at any time during the contract term. Even after the downgrade under paragraph 4, the data and the export option remain available until the Creator itself expressly deletes its data.

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Section 21 Changes to These Terms of Service#

(1) Right to Amend. Flenski may amend these Terms of Service with effect for the future, provided there is a valid reason for doing so (in particular changes in legislation or case law, new or changed platform features, technical or security-related requirements, or changes to the service providers used) and the amendment does not unreasonably disadvantage the Creator, taking both parties' interests into account. Amendments under this paragraph must not shift the balance of performance and consideration to the Creator's detriment.

(2) Notice. Changes are announced to the Creator at least six weeks before the planned effective date in text form (e.g. by email to the address stored in the account). The announcement contains the changed provisions in highlighted form or the complete new version, the effective date, and an express notice of the Creator's right to object, the objection period, and the meaning of the Creator's silence under paragraph 3.

(3) Deemed Consent. If the Creator does not object in text form before the effective date, the Creator's consent to the announced changes is deemed given. This deemed consent applies only if Flenski has expressly informed the Creator in the announcement of this consequence of the Creator's silence.

(4) Limits of Deemed Consent. Deemed consent under paragraph 3 does not apply to changes that affect the parties' principal performance obligations (the nature and scope of the agreed services) or the fee structure, or that amount to a re-establishment of the contractual relationship. Such changes require the Creator's express consent.

(5) Objection. If the Creator objects within the deadline, the contractual relationship continues under the existing terms. In that case, each party is entitled to end the contractual relationship with effect from the planned effective date of the change; for ongoing subscriptions billed through the merchant of record, its cancellation and refund rules apply.

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Section 22 Final Provisions#

(1) Severability. Should individual provisions of these Terms of Service be or become wholly or partially invalid, the validity of the remaining provisions remains unaffected.

(2) Choice of Law and Jurisdiction. These Terms of Service and the contractual relationship between Flenski and the user are governed by the law of the United Arab Emirates; the United Nations Convention on Contracts for the International Sale of Goods (CISG) does not apply. If the user acts as a consumer, this choice of law does not deprive them of the protection of those provisions from which, under the law of the state of their habitual residence, no derogation is permitted by agreement (Art. 6(2) of Regulation (EC) No 593/2008 — Rome I); these mandatory consumer protection provisions remain unaffected and can continue to be invoked by the consumer. For all disputes arising out of or in connection with these Terms of Service, the exclusive place of jurisdiction — to the extent legally permissible — is Dubai, United Arab Emirates. Mandatory statutory places of jurisdiction, in particular the jurisdictions for consumer matters under Art. 17 to 19 of Regulation (EU) No 1215/2012 (Brussels Ia), remain unaffected.

(3) Consumer Dispute Resolution. Flenski is not willing and not obliged to participate in dispute resolution proceedings before a consumer arbitration board within the meaning of Section 36 of the German Consumer Dispute Resolution Act (VSBG).

(4) Contact; Central Point of Contact (Art. 11, 12 DSA). General inquiries and support: support@flenski.io. Data protection: finn@flenskiteam.com (uniform data protection contact address across all documents). DSA reports and complaints: see Section 9. Flenski maintains a central electronic point of contact for authorities and users within the meaning of Art. 11 and 12 of Regulation (EU) 2022/2065 (DSA): support@flenski.io. Users can additionally contact Flenski at any time via the official Flenski Community (https://app.flenski.community/flenski/starte-hier). Communication is possible in German and English and does not rely exclusively on automated tools.