Terms of Service

These Legal Terms govern access to and use of the Thembi platform and related services. By creating an account or using the platform, the user agrees to these Terms.

1. Service Provider

The service is provided by:

Thembi S.r.l.
Via Comelico 18
20135 Milan
Italy
Codice Fiscale / Partita IVA: 14207690968
VAT: IT14207690968
Contact: info@thembi.ai

2. Nature of the Service

Thembi provides a digital platform for monitoring developments in European Union lawmaking and policy processes. The platform identifies developments relevant to users and provides:

• alerts
• summaries
• contextual information
• relevance assessments
• structured monitoring dashboards

Outputs are generated or assisted by artificial intelligence systems operated by third-party providers. Thembi does not provide legal advice, regulatory advice, compliance certification, or professional advisory services. The service is intended solely as an informational monitoring tool.

3. Intended Users

The service is designed for professional users. By registering, users confirm that they act in a professional capacity. Thembi does not intentionally offer services to consumers. Where mandatory consumer protection laws apply, those rights prevail over conflicting provisions of these Terms.

4. Account Registration

Users must create an account to access the service. Users must:

• provide accurate information
• maintain confidentiality of login credentials
• comply with seat licensing

Users are responsible for activity under their accounts.

5. Security Measures

Thembi implements reasonable security measures including:

• encrypted connections (HTTPS/TLS)
• authentication mechanisms
• session management controls
• monitoring for abnormal access patterns

For secure access the platform uses:

• two-factor authentication (2FA) using mobile OTP
• periodic authentication every 48 hours
• session controls designed to discourage password sharing

6. Free Trial

New users may receive a 14-day free trial of Essential or Team. No payment method is required to start the trial, and no fees are charged during it.

7. Subscription Terms

• Essential and Team plans are available on two billing options: (a) Monthly, billed monthly in advance with no minimum term; or (b) Annual, billed annually in advance for a 12-month term.
• Monthly subscriptions renew automatically each month. The user may cancel at any time via the user profile. Cancellation takes effect on the next billing date. No part-month fees are charged or refunded.
• Annual subscriptions renew automatically for successive 12-month terms unless cancelled at least 30 days before the end of the current term. For Annual subscriptions started by 1 December 2026, the price guarantee in Section 9 applies; once it ends, renewals are at the then-current Annual fee, subject to the price-change notice in Section 9. Other Annual subscriptions renew at the then-current Annual fee, subject to the same price-change notice.
• If a fee is not received on its due date, Thembi may suspend access until payment is made and, for Monthly subscriptions, may treat the subscription as cancelled.
• Add-ons (extra user logins and extra Policy Twins) are billed on the same option and term as the main plan.
• Tailored subscriptions are governed by the applicable order form.
• All fees are exclusive of applicable taxes (such as VAT), applied at the point of purchase based on the user's jurisdiction.

Monthly and Annual billing options

Essential and Team customers may choose between Monthly and Annual billing. Prices are those shown on the pricing page and exclude VAT. Annual prices provide 12 months for the price of 10.

8. Subscription Upgrades

• Upgrades take effect immediately and do not start a new commitment period. On Monthly subscriptions, the fee difference for the remainder of the current month is added to the next monthly bill.
• A user may move from Monthly to Annual at any time. The 12-month term starts on the next billing date and the Annual fee is payable in advance on that date.
• On Annual subscriptions, the fee difference is charged pro rata for the remainder of the current term. The upgraded plan ends on the same date as the existing term.

9. Fees and Price Changes

The fees for each plan, billing option and add-on are those shown on the pricing page at the time of purchase or renewal.

• Fees are payable in advance and are non-refundable, except where required by law or as set out in the Refunds paragraph below.
• Thembi may change its fees with at least 30 days' written notice. For Monthly subscriptions, the new fee applies from the first billing date after the notice period. For Annual subscriptions, fees paid in advance are fixed for the paid term and any change applies from the next renewal, provided notice is given at least 60 days before the renewal date.
• For Annual subscriptions started by 1 December 2026, the price paid at sign-up is guaranteed for the first 24 months of continuous subscription. This guarantee takes precedence over any change of fees for that period. The offer to start an eligible subscription expires on 1 December 2026.
• Refunds. Thembi will refund the fees paid in advance for the unused remainder of an Annual term, calculated pro rata from the date the subscription ends, where: (a) the user terminates the subscription because Thembi is in material breach of these Terms and has not remedied the breach within 30 days of written notice; or (b) Thembi discontinues the service or terminates the subscription other than for the user's breach. No refund is due where Thembi terminates for the user's breach. Monthly subscriptions are not refunded; the user may cancel at any time.

10. Acceptable Use

Users must not:

• reverse engineer the platform or attempt to access its underlying code, algorithms, or database structure
• scrape or extract data from the platform by automated or manual means
• share accounts and/or access credentials beyond licensed seats
• build competing monitoring services using the platform content, data, or outputs, including as training data
• introduce malicious code or conduct any security attack, including denial-of-service attacks or unauthorised vulnerability testing
• use automated tools within the platform such as bots, scripts, or crawlers without Thembi's prior written consent
• circumvent access controls, paywalls, or subscription restrictions to access features or content beyond the licensed tier
• misrepresent affiliation with Thembi or use its name, brand, or trademarks without express written authorisation

Thembi may suspend accounts where misuse occurs.

11. Artificial Intelligence Transparency

The platform uses artificial intelligence systems to generate certain outputs. These outputs may include:

• summaries
• contextual explanations
• relevance classifications

AI-generated outputs may contain inaccuracies or omissions. Users must verify information independently. Users have taken note of Thembi's Policy on Responsible AI and agree with its terms.

12. Automated Relevance Classification

The platform automatically evaluates the relevance of monitored information for each user. These relevance assessments may rely on:

• user-selected interests
• explicit configuration choices
• behavioural signals derived from platform usage and/or explicit user feedback

Such automated processing serves only to improve information prioritisation and does not produce legal effects or similarly significant impacts on individuals.

13. Third-Party Information Sources

The platform aggregates information from public third-party sources including but not limited to:

• EU institutions and related bodies
• national governments and authorities
• regulatory bodies
• public databases
• media outlets
• generally available online sources

Thembi cannot guarantee completeness, timeliness or accuracy of such information.

14. No Professional Advice

The platform does not provide legal or other types of professional advice. Users remain responsible for verifying information and making independent decisions.

15. Intellectual Property

All intellectual property relating to the platform belongs to Thembi or its licensors. Nothing in these Terms transfers any ownership rights to users. Users receive only a limited licence to access the platform during the subscription.

16. Personal Data and Privacy

Thembi processes personal data in accordance with applicable data protection laws, including Regulation (EU) 2016/679 (GDPR). Further information regarding the collection, use, storage and protection of personal data is set out in the Privacy Policy, which should be read together with these Terms.

Where users upload documents, information or other materials to the platform, they remain responsible for ensuring that any personal data contained in such materials is processed lawfully and in accordance with applicable law.

17. Subprocessors

Thembi may use subprocessors including:

• cloud infrastructure providers
• AI model providers
• payment processors
• analytics providers

Appropriate contractual safeguards are implemented.

18. Service Availability

Thembi will use commercially reasonable efforts to maintain availability. The platform relies on external infrastructure including cloud providers and AI services. Interruptions caused by such providers may occur. Scheduled and unscheduled maintenance interruptions remain possible. Therefore, uninterrupted service cannot be guaranteed at all times. Thembi strives to minimize service disruptions.

19. Limitation of Liability

To the maximum extent permitted by law, Thembi shall not be liable for:

• indirect damages
• loss of profits
• reliance on platform outputs
• inaccuracies originating from third-party sources
• outputs generated by external AI systems

Total liability is limited to the fees paid by the customer during the preceding 12 months.

20. Suspension and Termination

Thembi may suspend accounts at its own discretion where:

• terms are violated
• payments fail
• security risks arise
• users materially act in contradiction of Thembi's Policy on Responsible AI

Users may terminate subscriptions via the user profile subject to Section 7.

21. Governing Law

These Terms are governed by the laws of Italy. The courts of Milan have exclusive jurisdiction.