Content & Notice-and-Action Policy

Effective date: 29 June 2026

This Policy is read together with the Terms of Service, the Consumer (Guest) Terms of Use, the Privacy Policy and the Cookie Policy.

Introduction

"Tabb Pay Private Company" (trade name "TabbPay"), established in the Municipality of Galatsi, Attica (39 Farron Street, P.C. 11147), contact e-mail support@tabbpay.com and privacy@tabbpay.com (the "Company" or "TabbPay"), provides a software-as-a-service (SaaS) platform for electronic ordering, payment, tipping and reviewing via QR code (the "Platform").

In the course of operating the Platform, third parties post, store and display content: Business Customers (venues) upload their menus, descriptions and images; Guests (consumers) submit reviews, ratings and comments; venue staff enter operational content. With respect to such content, the Company acts as a hosting service provider within the meaning of e-commerce law.

This Content & Notice-and-Action Policy (the "Policy") sets out: (a) the rules for content hosted on the Platform; (b) the roles and responsibilities of the Company and of users; and (c) the notice-and-action mechanism for illegal or rights-infringing content.

Article 1 — Legal Framework

1.1 This Policy is grounded in the liability framework for intermediary information-society service providers, namely:

(a) Directive 2000/31/EC on electronic commerce, as transposed into Greek law by Presidential Decree 131/2003 (Π.Δ. 131/2003) — in particular as regards the liability of the hosting service provider and the notice-and-takedown procedure; and

(b) the notice-and-action principles of Regulation (EU) 2022/2065 on a Single Market for Digital Services (the Digital Services Act — "DSA").

1.2 Scaling for micro and small enterprises. The Company honestly states that it is a small, private service and is not a "very large online platform" (VLOP) nor a "very large online search engine" (VLOSE) under the DSA. Accordingly, certain enhanced DSA obligations addressed to VLOPs (by way of example: systemic-risk assessment, independent audits, advertising repository) do not apply to the Company. Furthermore, under Article 19 of the DSA, micro and small enterprises (within the meaning of Recommendation 2003/361/EC) are exempt from certain obligations of Section 3 of Chapter III (by way of example: the obligation to operate an internal complaint-handling system under Article 20, out-of-court dispute settlement under Article 21, and certain transparency obligations). Nonetheless, the Company voluntarily operates a basic notice-and-action mechanism, as well as the fundamental obligations of a hosting provider under Π.Δ. 131/2003 and Article 16 of the DSA.

1.3 This Policy does not limit any stricter obligations imposed by mandatory law or by a competent authority or court.

Article 2 — Scope and Definitions

2.1 This Policy applies to all content posted, stored, transmitted or displayed through the Platform by users or on their behalf.

2.2 Capitalised terms not defined below have the meaning given to them in the Terms of Service, the Privacy Policy or applicable law.

• "Customer Content": the content uploaded by the Business Customer or its staff, in particular menus, product names and descriptions, prices, ingredient and allergen information, and venue images and logos.
• "Guest Content" / "Reviews": the content submitted by the Guest (consumer), in particular reviews, ratings, comments and order notes. Where the venue has enabled it, the Guest may be redirected to an external review platform (in particular a Google-review flow); reviews submitted directly to a third-party platform are governed by that third party's terms and do not constitute content hosted by the Company.
• "User Content": collectively, the Customer Content and the Guest Content.
• "Illegal Content": any information that, in itself or in relation to an activity, is not in compliance with Union or national law, irrespective of the precise subject matter or nature of that law (Article 3(h) DSA) — in particular content that infringes intellectual-property rights, defamatory content, misleading commercial practices, hate speech, or content that breaches consumer-protection law or food-information law.
• "Notice": the notification under Article 7 by which anyone informs the Company of content they consider Illegal.
• "Notifier": the natural or legal person who submits a Notice.

Article 3 — Roles and Responsibilities

3.1 The Business Customer as responsible for Customer Content. The Business Customer is solely responsible for the Customer Content it uploads, in particular for the accuracy and completeness of menus, prices, descriptions and, critically, ingredient and allergen information, in accordance with applicable food-information consumer law. The Company does not check, verify or warrant the accuracy of the Customer Content.

3.2 The Guest as responsible for Guest Content. The Guest is responsible for the content it submits and warrants, by submitting a review, rating or comment, that it is truthful, based on a genuine experience, and not illegal, offensive, defamatory or misleading, and does not infringe third-party rights.

3.3 The Company as intermediary hosting provider. The Company is limited to the technical, automatic and passive hosting and display of User Content. It does not create, pre-select, modify or endorse User Content, nor is it under any general obligation to monitor the information it hosts or to actively seek facts or circumstances indicating illegal activity (Article 15 Π.Δ. 131/2003, Article 8 DSA).

3.4 Hosting-provider liability exemption. Under Article 13 of Π.Δ. 131/2003 and Article 6 of the DSA, the Company is not liable for the stored User Content, provided that: (a) it does not have actual knowledge of the illegal activity or information and, as regards claims for damages, is not aware of facts or circumstances from which the illegal activity or information is apparent; or (b) upon obtaining such knowledge or awareness, it acts expeditiously to remove or to disable access to the information. This Policy describes the mechanism through which the Company obtains such knowledge and acts.

Article 4 — Prohibited Content

4.1 It is prohibited to post, store or transmit through the Platform content which, by way of example and without limitation:

(a) is illegal or promotes illegal activity;

(b) infringes third-party intellectual-property rights (copyright, trademarks, patents, unfair competition), in breach in particular of Law 2121/1993;

(c) is defamatory, slanderous, abusive or infringes the personality, honour or reputation of a third party;

(d) constitutes hate speech, incitement to violence or discrimination, or a threat;

(e) is misleading or false or constitutes an unfair or misleading commercial practice in breach of consumer-protection law (in particular Law 2251/1994), including false or fake reviews;

(f) contains third-party personal data in breach of data-protection law;

(g) contains malicious software or technically harmful elements;

(h) is obscene, pornographic or inappropriate, or relates to illegal or controlled products;

(i) breaches the Acceptable Use provisions of the Terms of Service or the applicable law on ingredient and allergen labelling.

4.2 The Company may remove or disable access to content that breaches this Article, in accordance with the procedure of Articles 7 and 8 or following its own determination.

Article 5 — Content Licence

5.1 Customer Content. The Business Customer retains ownership of the content it uploads (menus, prices, descriptions, images) and grants the Company a non-exclusive, royalty-free licence to host and display that content for the sole purpose of providing the service. The Business Customer warrants that the content does not infringe third-party rights and complies with law, in particular as to ingredient and allergen labelling.

5.2 Guest Content. By submitting a review, rating or comment, the Guest grants the Company and the venue a non-exclusive, royalty-free licence to use, reproduce and display the Guest Content to operate and improve the service.

5.3 The licence in paragraphs 5.1 and 5.2 terminates upon removal of the relevant content, subject to copies retained for compliance, documentation or lawful-retention purposes.

Article 6 — Automated Review and Human Assessment

6.1 The Company does not carry out general, prior automatic moderation or filtering of User Content. It does not use automated decision-making systems for the removal of content.

6.2 The assessment of Notices and the taking of decisions under Articles 7 and 8 is carried out by authorised personnel (human review). Where automated means may in future be used to detect or prioritise content (by way of example: detection of spam or fake reviews), the Company will inform users accordingly and will ensure the possibility of human review of the relevant decisions.

Article 7 — Notice Mechanism

7.1 Submission of a Notice. Anyone (an individual or an entity) may report content they consider Illegal or rights-infringing by sending a Notice to abuse@tabbpay.com.

7.2 Required elements. In order to be capable of assessment and to establish actual knowledge under Article 3.4, the Notice must include, with sufficient clarity (Article 16(2) DSA):

(a) identification of the content: the exact electronic location (URL or URLs) and/or other information enabling the identification of the content at issue, as well as of the relevant venue;

(b) reasons: a sufficiently substantiated explanation of the reasons why the Notifier considers the content to be Illegal, with reference to the legal provision allegedly infringed;

(c) contact details: the name and e-mail address of the Notifier (except where the Notice concerns offences relating to the sexual integrity of minors, in which case these details are not mandatory);

(d) good-faith statement: a statement that the Notifier is acting in good faith and that the information and allegations contained in the Notice are, to the best of their knowledge, accurate and complete.

7.3 Intellectual-property infringement notices. Where the Notice concerns the infringement of intellectual-property rights (in particular Law 2121/1993 on copyright or trademark law), the Notifier must additionally identify the protected work or right and attest that it is the rightholder or duly authorised to act on its behalf.

7.4 Defamation / consumer-law notices. Where the Notice concerns defamatory content or a breach of consumer-protection law (in particular false or misleading reviews), the Notifier must set out the facts that substantiate the false or offensive character of the content.

7.5 Notices that do not meet the above minimum elements may not be capable of assessment; in such a case the Company may ask the Notifier to supply the missing elements.

Article 8 — Assessment, Action and Statement of Reasons

8.1 Acknowledgement of receipt. Where the Notifier has provided contact details, the Company sends, without undue delay, an acknowledgement of receipt of the Notice.

8.2 Assessment. The Company assesses the Notice in a timely, diligent, objective and non-arbitrary manner. The assessment takes into account the elements of the Notice, the nature of the content, the fundamental rights of all those involved (in particular freedom of expression and information) and applicable law.

8.3 Action. Following the assessment, the Company decides on one of the following actions:

(a) removal of the content or disabling of access to it;

(b) no action, where the content is not found to be Illegal or offensive;

(c) another restriction (by way of example: demotion of visibility, a warning to the poster, or suspension/termination of the offender's account in serious or repeated cases).

8.4 Statement of reasons. The Company informs both the Notifier (where contact details exist) and the user who posted the content at issue of its decision and provides a clear and specific statement of reasons (Article 17 DSA), including: the type of action, the grounds (legal or contractual), whether automated means were used, and the redress possibilities under Article 9.

8.5 Cooperation with authorities. The Company acts on the orders or injunctions of competent judicial or administrative authorities (Articles 9 and 10 DSA, Article 14 Π.Δ. 131/2003) and informs the authority of the effect given to them.

Article 9 — Reinstatement, Counter-Notice and Redress

9.1 Counter-notice / Reinstatement. A user whose content has been removed or whose account has been restricted may submit a reasoned counter-notice to abuse@tabbpay.com, setting out the reasons why they consider the decision to be erroneous. The Company re-examines the matter and, if the counter-notice is found to be well-founded, reinstates the content or lifts the restriction, informing the parties.

9.2 Out-of-court settlement. As stated in Article 1.2, as a micro/small enterprise the Company is not required to operate the formal internal complaint-handling (Article 20 DSA) and out-of-court dispute-settlement (Article 21 DSA) mechanisms. Nonetheless, the Company will consider in good faith any counter-notice under paragraph 9.1. In addition, a consumer-Guest retains the possibility of recourse to the Hellenic Consumer Ombudsman (www.synigoroskatanaloti.gr) or to a certified Alternative Dispute Resolution (ADR) body.

9.3 Judicial protection. This procedure does not affect the right of any aggrieved person to bring proceedings before the competent courts or authorities.

Article 10 — Protection Against Abusive or Bad-Faith Notices

10.1 The submission of Notices containing knowingly false or misleading information constitutes an abuse of this procedure and may give rise to liability of the Notifier.

10.2 The Company may, following a warning, suspend for a reasonable period the processing of Notices from persons who frequently submit manifestly unfounded or abusive Notices (by analogy with Article 23 DSA), taking into account all relevant circumstances.

10.3 Correspondingly, the Company may suspend users who frequently post manifestly illegal content.

Article 11 — Contact

Article 12 — Amendments

12.1 The Company may amend this Policy, in particular for legal or operational changes. The version in force bears the effective date set out in the header. Continued use of the Platform after publication constitutes acceptance of the amended Policy, without prejudice to users' mandatory rights.

Article 13 — Governing Law and Jurisdiction

13.1 This Policy is governed by Greek law. The Courts of Athens are designated as competent to resolve any dispute, without prejudice to any mandatory consumer right to bring proceedings before the courts of the consumer's place of residence.

Article 14 — Language

14.1 This Policy is issued in Greek (the binding version) and in English (a convenience translation). In the event of any divergence between the two versions, the Greek version prevails, save that this does not deprive the consumer of the mandatory protections that concern them.

Greek is the binding version of this Policy; the English text is provided for convenience.