Legal Texts

Legal Notice

Last updated: July 12, 2026

Version 1.0
Effective date: [●]
Last updated: [●]

LEGAL NOTICE OF THE WEBSITE AND DIGITAL PLATFORM "MALLORCA AI TRAVEL ENGINE"

I. PURPOSE OF THE LEGAL NOTICE

This Legal Notice regulates access, navigation, and use of the website, the Progressive Web App (PWA), digital services, applications, programming interfaces (APIs), private dashboards, white-label solutions, SaaS services, and, in general, any digital environment owned by [CORPORATE NAME] (hereinafter, the Platform).

Access to any of the services offered implies full acceptance of the conditions contained in this Legal Notice, without prejudice to the application of any other General Conditions of Use, Contracting Conditions, Privacy Policy, Cookie Policy, Artificial Intelligence Policy, or other contractual documents that may apply depending on the service used.

Where there is a contradiction between this Legal Notice and specific conditions expressly accepted by the user or a professional client, the latter shall prevail exclusively with respect to the specific service contracted.

II. IDENTIFICATION OF THE OWNER

In compliance with the provisions of Law 34/2002, of July 11, on Information Society Services and Electronic Commerce, users are informed that the owner of the Platform is:

• Corporate Name: [●]
• Trade Name: Mallorca AI Travel Engine
• Tax ID (NIF/CIF): [●]
• Registered Office: [●]
• Contact Email: [●]
• Phone: [●]
• Corporate Website: [●]
• Registry Entry: [●]

III. NATURE OF THE PLATFORM

Mallorca AI Travel Engine constitutes a technological infrastructure specialized in the aggregation, organization, analysis, and presentation of tourist information using digital technologies, artificial intelligence systems, contextual recommendation algorithms, and interaction tools between users, tourism businesses, and collaborators.

The purpose of the Platform is to provide users with access to information, recommendations, content, digital services, experiences, and technological solutions related to the tourist destination Mallorca.

The Platform may integrate functionalities aimed at both individual users and businesses, hotels, tour operators, travel agencies, service providers, public administrations, collaborating entities, and third parties integrated through proprietary or third-party technological solutions.

IV. ABSENCE OF TRAVEL AGENCY STATUS

Unless expressly stated otherwise for a specific service, the Platform does not act as a travel agency, organizer of package tours, tourist intermediary subject to a specific license, nor as a direct provider of the activities, experiences, or services offered by third parties.

The recommendations generated by the Platform, including those produced through artificial intelligence systems, are purely informative and indicative in nature and do not constitute professional advice, personalized advice, or a guarantee of suitability, availability, or quality of a particular provider.

When a user contracts directly with an establishment, company, or professional advertised on the Platform, said contractual relationship shall be deemed to be entered into exclusively between the user and the corresponding provider, without the Platform acquiring the status of contracting party, unless expressly established otherwise in the specific terms of the service.

V. PURPOSE OF THE PLATFORM

The Platform may carry out, among others, the following activities:

• a) Provide general tourist information of interest.
• b) Provide contextualized recommendations through artificial intelligence.
• c) Enable the location of activities, establishments, and services.
• d) Facilitate contact between users and companies.
• e) Manage lead generation systems.
• f) Integrate proprietary or third-party booking systems.
• g) Market digital services and SaaS solutions.
• h) Provide technological solutions for hotels, tourist accommodations, and collaborating companies.
• i) Offer white-label solutions and customized technological services.
• j) Integrate third-party services through APIs or other interoperability technologies.

The above list is merely illustrative and not exhaustive.

VI. ACCESS CONDITIONS

Access to the website is, as a general rule, free of charge. However, certain services may require: prior registration, authentication, contracting of a service, subscription, acceptance of specific conditions, identity verification, email verification, or business contracting.

The Platform may limit, suspend, or condition access to certain functionalities when necessary to guarantee the security of the service, regulatory compliance, or the proper provision of the services offered.

VII. PROPER USE OF THE PLATFORM

The user undertakes to use the Platform in accordance with current legislation, good faith, public order, these conditions, and generally accepted uses of the Internet.

In particular, the user shall refrain from carrying out actions that may: alter the normal operation of the Platform; compromise the security of the systems; interfere with other users' access; introduce malicious code; use unauthorized automated systems; extract information through massive scraping techniques; gain access to restricted areas; impersonate third parties; use the Platform for unlawful purposes; infringe intellectual or industrial property rights; disseminate unlawful, offensive, discriminatory, violent, or contrary content to current legislation.

Breach of these obligations shall entitle the Platform to suspend or cancel access without prior notice.

VIII. SERVICE AVAILABILITY

The Platform will make reasonable efforts to maintain continuous availability of its services. However, the user expressly acknowledges that the operation of digital systems depends on multiple technical, technological, and third-party factors beyond the direct control of the owner.

Consequently, permanent availability of the service is not guaranteed, nor the absence of interruptions arising from maintenance operations, technical incidents, updates, computer attacks, communications network failures, supply interruptions, third-party actions, or force majeure events.

Temporary interruption of the Platform shall not give rise to any right to compensation unless otherwise provided by mandatory law.

IX. MODIFICATIONS TO THE PLATFORM

The owner reserves the right to modify, expand, replace, limit, or remove, at any time and without prior notice, any of the elements that make up the Platform, including, but not limited to: its design, functionalities, services, algorithms, artificial intelligence models, recommendation criteria, classification systems, technological integrations, and commercial solutions.

These modifications shall respond to technical, commercial, regulatory, or technological evolution criteria and shall not confer upon the user any right to maintain previous versions of the service.

X. INTELLECTUAL AND INDUSTRIAL PROPERTY

All intellectual and industrial property rights inherent to the Platform belong exclusively to [CORPORATE NAME], or have been assigned, licensed, or sufficiently authorized by their legitimate owners.

The following are considered to be within such protection, by way of illustration and not limitation: the trade name Mallorca AI Travel Engine, the denomination Concierge AI, trademarks, logos, and distinctive signs, the software developed for the Platform, the technological architecture, databases, recommendation algorithms, artificial intelligence models, search engines, graphical interfaces, visual design, navigation structure, user experience (UX), design elements (UI), editorial content, photographs, illustrations, videos, texts, documents, APIs, integration systems, SaaS developments, and any other intangible asset incorporated into the Platform.

Access to the Platform does not imply any transfer of intellectual or industrial property rights. Unless expressly authorized in writing by the owner, the following are prohibited: total or partial reproduction, distribution, transformation, adaptation, reverse engineering, decompilation, systematic data extraction, massive reuse of content, creation of derivative works, use of algorithms for training artificial intelligence models, and commercial use of any element making up the Platform.

References to trademarks, trade names, or distinctive signs of third parties that may appear on the Platform belong to their respective owners and are used solely for identification, descriptive purposes, or as a result of authorized commercial relationships.

XI. THIRD-PARTY CONTENT

The Platform may incorporate content provided by users, collaborating companies, tourist establishments, providers, public administrations, or third parties integrated through APIs, synchronization services, or equivalent technological tools.

The owner does not guarantee the accuracy, timeliness, completeness, or permanent availability of such content. Each provider shall be exclusively responsible for the information it publishes, including, but not limited to: descriptions, prices, photographs, schedules, availability, promotions, commercial conditions, licenses, and administrative authorizations.

The Platform may remove, hide, modify, or suspend any content where there are reasonable indications that it may be unlawful, inaccurate, fraudulent, harmful to third parties, or contrary to these conditions, without such action giving rise to any indemnity.

XII. OPERATION OF ARTIFICIAL INTELLIGENCE SYSTEMS

The Platform incorporates artificial intelligence systems designed to enhance the browsing experience and provide personalized recommendations. The user expressly acknowledges that the responses generated by such systems constitute automated processes of a probabilistic and statistical nature.

Consequently: recommendations may vary for different users even with similar queries; results may change over time; responses may contain inaccuracies; systems may rely on information from external sources; the Platform does not guarantee that a recommendation is objective, complete, or suitable for the user's particular circumstances.

The artificial intelligence systems are merely assistive in nature and do not replace professional, technical, medical, legal, financial, or any other specialized judgment. The user shall assume responsibility for verifying any relevant information before making decisions based solely on the recommendations obtained.

XIII. LINKS TO THIRD-PARTY WEBSITES

The Platform may contain links, hyperlinks, integrations, or access to web pages, applications, or services belonging to third parties. The existence of such links does not imply approval, sponsorship, recommendation, or guarantee by the owner regarding the content, products, services, or policies of said third parties.

The owner shall not be liable for: the availability of such sites; the information published; the commercial conditions applied; the processing of personal data carried out by third parties; or any damages that may arise from accessing such services. Each user shall access external services at their own risk and shall be subject to the conditions established by their respective owners.

XIV. LIABILITY

Within the limits permitted by applicable law, the owner shall only be liable for damages directly attributable to it and for which liability is legally enforceable.

In particular, the owner shall not be liable for: decisions made by users as a result of information obtained on the Platform; actions of tourist providers; cancellations of activities; changes in schedules; price modifications; lack of availability of services; errors provided by third parties; weather incidents; administrative restrictions; alterations arising from emergency situations; telecommunications network interruptions; technological provider failures; loss of profits; loss of earnings; indirect damages; or loss of business opportunity.

In those cases where liability of the owner may legally be declared, it shall be limited, unless otherwise provided by mandatory law, to the amount actually paid by the user during the twelve months immediately preceding the event giving rise to the claim.

XV. COMPUTER SECURITY

The owner adopts reasonable technical and organizational measures intended to preserve the confidentiality, integrity, availability, and resilience of its information systems. However, the user acknowledges that no system connected to the Internet can guarantee an absolute level of security.

Consequently, the owner does not guarantee the absence of viruses, malware, computer attacks, unauthorized access, unknown vulnerabilities, or any other technological incident arising from circumstances beyond its reasonable control. The user shall be responsible for adequately protecting the devices from which they access the Platform.

XVI. PERSONAL DATA PROTECTION

The processing of users' personal data shall be governed by the corresponding Privacy Policy, which forms an integral part of the Platform's legal framework. The user declares to have had access to said policy before providing any personal data.

XVII. COOKIES AND SIMILAR TECHNOLOGIES

The Platform uses cookies, local storage technologies, session identifiers, service workers, and other equivalent mechanisms necessary to ensure the proper functioning of digital services. All information regarding the use of such technologies is regulated in the corresponding Cookie Policy.

XVIII. MODIFICATION OF THIS LEGAL NOTICE

The owner may modify this Legal Notice when necessary to adapt to: legislative changes; judicial rulings; administrative authority criteria; technological innovations; new services; changes in the business model; or organizational improvements. The modifications shall take effect from the time of their publication, unless a different date is expressly indicated.

XIX. PARTIAL NULLITY

If any provision contained in this Legal Notice is declared null, invalid, or unenforceable by a final decision of a competent authority, such circumstance shall not affect the validity of the remaining provisions, which shall remain fully in force. The parties shall endeavor to replace the affected provision with another whose legal and economic purpose is as close as possible to that originally intended.

XX. APPLICABLE LAW AND JURISDICTION

This Legal Notice shall be governed and interpreted in accordance with Spanish law and applicable European Union law. Unless a mandatory rule establishes another territorial jurisdiction, any dispute arising from the interpretation, execution, or validity of this Legal Notice shall be submitted to the Courts and Tribunals of Palma de Mallorca, with the parties expressly waiving any other jurisdiction that may correspond to them.

Where the user has the legal status of consumer, the mandatory rules of territorial jurisdiction provided for in current legislation shall apply.

Terms & Conditions of Use

Last updated: July 12, 2026

TERMS & CONDITIONS OF USE OF THE DIGITAL PLATFORM

MALLORCA AI TRAVEL ENGINE®

Version 1.0
Effective date: [●]

TITLE I — GENERAL PROVISIONS

Article 1. Purpose

1. These Terms & Conditions of Use govern access, navigation, use, and participation in the digital ecosystem known as Mallorca AI Travel Engine®, including all services, functionalities, tools, technological modules, applications, web environments, Progressive Web App (PWA), private dashboards, programming interfaces (API), SaaS solutions, White-Label solutions, artificial intelligence systems, recommendation engines, digital services, and any other functionalities that the Owner makes available to users under any of its domains, subdomains, or technological infrastructures.

2. These Terms constitute the general legal framework governing the relationship between the Owner and any natural or legal person who accesses, uses, consults, browses, interacts with, or contracts any of the services integrated into the Platform, regardless of the device used, the access channel, or the country from which the connection is made.

3. Access to the Platform implies the full, express, and unreserved acceptance of these General Terms, as well as the rest of the contractual documents that, depending on the nature of the service used, may apply, including, among others, the Legal Notice, the Privacy Policy, the Cookie Policy, the Artificial Intelligence Policy, the Contracting Conditions, specific contracts for Partners, Providers, or Business Clients, and any particular conditions governing specific services.

4. When a user accesses simultaneously different services offered by the Platform, these General Terms and the specific conditions governing each service shall apply jointly, the latter prevailing only with respect to the matter expressly regulated.

5. The Owner may develop new functionalities, modify existing ones, or incorporate new technological services that shall automatically be subject to this legal framework from the moment they are made available to users, unless a different contractual regime is expressly established.

Article 2. Definitions

For the purposes of these General Terms, the following terms shall have the meaning attributed to them in this article, regardless of whether they appear in singular or plural.

"Platform": integrated set of technological infrastructures, applications, digital services, algorithms, databases, artificial intelligence systems, recommendation engines, SaaS solutions, APIs, management dashboards, web interfaces, Progressive Web App, and other technical elements developed or operated under the name Mallorca AI Travel Engine®.

"Owner": the legal entity identified in the Legal Notice as the owner and responsible for the Platform.

"User": any natural person who accesses or uses the Platform, regardless of whether they are registered or not.

"Registered User": a User who has completed the registration process and has an active personal account.

"Client": any natural or legal person who contracts any of the paid services offered by the Platform.

"Partner": any company, professional, or entity that maintains a commercial relationship with the Platform for the promotion, marketing, recommendation, or integration of its services.

"Provider": the natural or legal person responsible for directly providing a tourist, commercial, or professional service displayed, recommended, or integrated within the Platform.

"Hotel Establishment": any hotel, aparthotel, holiday accommodation, hotel chain, or accommodation company that uses the Platform's technological solutions, whether through direct integration, SaaS license, or White-Label solution.

"Concierge AI": intelligent digital assistance system based on artificial intelligence models, machine learning, natural language processing, recommendation systems, and probabilistic engines designed to provide contextual information, recommendations, and personalized assistance to users.

"Recommendation Engine": set of algorithms that dynamically and automatically determine the relevance, order, priority, or visibility of content, establishments, activities, services, or experiences within the Platform.

"Lead": any request for information, commercial contact, potential booking, or commercial interaction generated by a User with respect to a Partner or Provider.

"Content": any information, data, document, image, video, audio, text, logo, description, photograph, publication, review, comment, or any other element capable of legal protection incorporated into the Platform.

"Services": all functionalities, digital products, technological tools, automated processes, integrations, and solutions developed or marketed by the Platform.

"Account": individualized digital space associated with a Registered User through which they can access personalized functionalities.

Article 3. Legal nature of the Platform

1. Mallorca AI Travel Engine constitutes a technological infrastructure specialized in the organization, processing, contextualization, and distribution of tourist information through digital tools, artificial intelligence systems, and automated recommendation engines.

2. Unless expressly stated otherwise, the Owner does not act as a travel agency, package tour organizer, tour operator, carrier, hotel establishment, activity company, insurer, or direct provider of the services offered by third parties.

3. The Platform's functionalities are intended to facilitate the location of services, improve the user's digital experience, promote interaction between tourist supply and demand, and provide technological tools aimed at optimizing the User's decision-making.

4. The recommendations issued by the Platform, regardless of whether they have been produced through automated processes, artificial intelligence, predictive algorithms, or human intervention, shall always be advisory in nature and shall not constitute an objective guarantee of the suitability, availability, quality, or final outcome of the recommended service.

5. Depending on the specific service, the Platform may act as: a) digital service provider; b) SaaS solution provider; c) White-Label technology provider; d) API infrastructure provider; e) automated recommendation generator; f) tourist information aggregator; g) commercial opportunity capture channel; h) technological intermediation platform. The specific legal nature of each service shall be determined by the particular conditions governing it.

Article 4. Scope of application

1. These General Terms shall apply to all legal relationships arising from access to or use of the Platform, regardless of the technological modality used.

2. These Terms shall also bind Users who access through: web browsers; Progressive Web App; API integrations; White-Label solutions; hotel environments; embedded applications; authorized third-party services; mobile devices; or compatible virtual assistants.

3. The use of certain professional, business, or corporate services may be subject to specific contracts that complement these General Terms.

4. In the event of contradiction between these General Terms and a business contract expressly signed between the Owner and a Professional Client, the latter shall prevail exclusively with respect to the matters regulated in said contract.

Article 5. Modification of the General Terms

1. The Owner may modify these General Terms when necessary to adapt to legislative changes, court rulings, administrative criteria, technological evolution, functional changes to the Platform, or alterations in the business model.

2. The modifications shall enter into force from their publication, unless a different period is expressly established.

3. When the modification substantially affects the rights or obligations of Registered Users or Clients, the Owner shall endeavor to communicate this circumstance through the Platform's usual communication channels.

4. Continued use of the Platform after publication of the modifications shall imply acceptance of the new General Terms, without prejudice to the User's right to cease using the services if they do not agree with them.

TITLE II — ACCESS TO THE PLATFORM, USER REGISTRATION, AND ACCOUNT MANAGEMENT

Article 6. Access to the Platform

1. Access to the Platform shall, as a general rule, be free of charge, without prejudice to the fact that certain functionalities, services, content, integrations, or technological modules may require prior registration, contracting of a subscription plan, acceptance of specific conditions, or compliance with additional requirements established by the Owner.

2. Access to the Platform does not, by itself, create any right to use all available functionalities, and the Owner reserves the right to enable, restrict, or remove certain features based on technical, commercial, contractual, regulatory, or security criteria.

3. The Owner may establish different access levels, user profiles, or usage modalities, distinguishing, among others, visitor users, registered users, individual clients, professional clients, partners, providers, hotel establishments, administrators, developers integrated via API, and any other profiles necessary for the proper functioning of the Platform.

4. The availability of certain functionalities may depend on the country from which access is made, applicable regulations, technical availability of services, the device used, or the contracting of a particular commercial plan.

Article 7. Capacity to use the Platform

1. Natural persons of legal age with sufficient legal capacity to bind themselves in accordance with the applicable legislation may access the Platform.

2. Minors may only use those services expressly authorized by the Owner and always under the supervision, consent, and responsibility of the holder of parental authority or legal representation.

3. When access is made on behalf of a legal entity, public entity, hotel establishment, company, or any other organization, the person acting on its behalf declares that they have sufficient powers to legally bind the entity represented.

4. The Owner may, at any time, require the documentation it deems necessary to prove the identity, representation, or legal capacity of the user when there are reasonable doubts about the veracity of the information provided or when necessary to comply with legal obligations.

Article 8. User registration

1. Access to certain functionalities will require the creation of an Account through the registration procedure established by the Platform.

2. During such procedure, the User must provide complete, accurate, truthful, and permanently updated information.

3. The User shall be solely responsible for the veracity of the data provided and for any damages that may arise from the use of false, incomplete, inaccurate, or outdated information.

4. The Owner may refuse registration when: a) there are reasonable indications of fraud; b) false identities are detected; c) temporary email addresses or systems intended to conceal the applicant's real identity are used; d) legal restrictions apply; e) there is a history of serious contractual breaches by the applicant; f) it is necessary to preserve the security of the Platform or third parties.

5. The creation of an Account does not confer on the User any vested right regarding its permanence, and its maintenance is conditional upon continued compliance with these General Terms.

Article 9. Identity verification

1. The Owner may establish identity verification mechanisms, enhanced authentication, or documentary validation when necessary to guarantee the security of services, prevent fraud, comply with regulatory obligations, or protect the legitimate interests of the Platform and its users.

2. Among other mechanisms, the Owner may request: a) email verification; b) telephone number verification; c) multi-factor authentication; d) official identity documents; e) proof of business representation; f) tax or commercial information; g) any other reasonably necessary documentation.

3. Unjustified refusal to complete verification processes may prevent access to certain functionalities or lead to the temporary suspension of the Account.

Article 10. User account

1. Each Account shall be personal and non-transferable, unless expressly authorized in writing by the Owner.

2. The User shall be solely responsible for all activities carried out from their Account, regardless of who materially executed them, unless they can prove that they previously reported unauthorized access in accordance with the procedure established by the Platform.

3. The User undertakes to diligently safeguard their access credentials, avoiding their communication, assignment, loan, or use by third parties.

4. The User shall immediately notify the Owner of any suspicion of unauthorized access, loss of credentials, identity theft, or fraudulent use of their Account.

5. The Owner may immediately adopt the necessary technical measures to preserve the security of the system, including preventive blocking of the Account, termination of active sessions, modification of credentials, or temporary limitation of certain functionalities.

Article 11. Security of credentials

1. The User shall be responsible for maintaining the confidentiality of their access keys, passwords, authentication codes, and any other identification mechanisms used to access the Platform.

2. Passwords must meet the minimum security requirements established by the Platform and may be changed periodically when advisable for technical or cybersecurity reasons.

3. The Owner shall not be liable for damages arising from the negligent use of credentials by the User or for access resulting from loss of control over them.

4. The Owner may implement enhanced authentication systems, biometrics, multi-factor authentication, or any other technology intended to increase access security.

Article 12. Professional profiles and business accounts

1. The Platform may enable specific Account modalities for companies, hotels, tourist establishments, agencies, operators, activity providers, technology partners, developers, or any other professional clients.

2. Such accounts may incorporate additional functionalities, administration tools, dashboards, statistics, commercial management systems, API integrations, or any other business service developed by the Owner.

3. The creation of a business Account shall not imply any right to automatic publication of content or effective incorporation of services within the Platform.

4. The Owner may establish documentary validation processes, editorial review, license verification, or any other mechanism prior to the final activation of professional profiles.

Article 13. Temporary suspension of accounts

1. The Owner may temporarily suspend access to an Account when there are reasonable indications of: a) fraudulent use; b) unauthorized access; c) breach of these Terms; d) risk to computer security; e) infringement of third-party rights; f) unauthorized automated use; g) breach of legal obligations; h) existence of requirements issued by a competent authority.

2. During suspension, certain functionalities may be totally or partially blocked while the appropriate checks are carried out.

3. Whenever circumstances permit, the User shall be informed of the suspension and may submit any arguments they deem appropriate.

Article 14. Account cancellation

1. The User may request cancellation of their Account at any time in accordance with the procedure established by the Platform.

2. Cancellation of the Account shall not automatically extinguish outstanding financial obligations nor affect contracts that continue to produce effects in accordance with their own terms.

3. The Owner may retain information whose maintenance is necessary to: a) comply with legal obligations; b) address contractual responsibilities; c) prevent fraud; d) exercise legal actions; e) protect legitimate interests; f) ensure the integrity of historical records where legally required.

4. Personal data shall be processed in accordance with the Privacy Policy and applicable data protection regulations.

Article 15. Termination by the Owner

The Owner may definitively cancel an Account when any of the following circumstances apply: a) serious or repeated breach of these Terms; b) use of false identities; c) manipulation of recommendation systems; d) use of software intended to alter the functioning of the Platform; e) unlawful activities; f) use of the Platform for purposes other than those for which it was designed; g) breach of financial obligations; h) serious reputational damage caused to the Owner or other users; i) requirement issued by competent authority; j) any other circumstance that makes the continuation of the contractual relationship reasonably incompatible. Cancellation may occur without right to compensation when the cause is attributable to the User.

TITLE III — RULES FOR USE OF THE PLATFORM

Article 16. General principles of use

1. The User undertakes to use the Platform diligently, loyally, and in accordance with current legislation, refraining from carrying out any action that may compromise the security, stability, reputation, or proper functioning of the services offered by the Owner.

2. The use of the Platform must at all times respect the rights and legitimate interests of the Owner, other users, integrated providers, commercial partners, and any third party whose rights may be affected by the activity carried out through the Platform.

3. The User expressly acknowledges that the Platform constitutes a complex technological ecosystem whose operation depends on the interaction between multiple digital infrastructures, proprietary services, and third-party services, undertaking not to carry out actions that alter, interfere with, or hinder such operation.

4. No provision contained in these Terms may be interpreted as an authorization to use the Platform for purposes other than those expressly provided for by the Owner.

Article 17. General obligations of the User

Without prejudice to the other obligations provided for in these Terms, the User undertakes to: a) provide truthful, accurate, and updated information; b) keep their access credentials under their exclusive control; c) use the Platform only for legitimate purposes; d) respect intellectual and industrial property rights; e) act in accordance with the principles of good faith; f) reasonably cooperate with the Owner when necessary to resolve security issues or verify certain information; g) refrain from introducing unlawful, misleading, or harmful content to third parties; h) report any technical vulnerability detected without exploiting it or disclosing it publicly before the Owner has been able to correct it; i) respect the particular conditions applicable to each of the services used.

Article 18. Expressly prohibited conduct

It is expressly prohibited to use the Platform to carry out any of the following actions: a) develop activities contrary to current legislation; b) infringe fundamental rights of third parties; c) disseminate false, defamatory, discriminatory, violent, pornographic, offensive, or contrary to public order content; d) introduce viruses, malware, ransomware, Trojans, or any other code capable of compromising system security; e) gain unauthorized access to restricted areas; f) circumvent authentication or security mechanisms; g) use false identities; h) impersonate natural or legal persons; i) deliberately alter the normal functioning of the Platform; j) generate disproportionate loads on the technological infrastructure; k) use robots, crawlers, scrapers, or automated systems intended to extract information without the express authorization of the Owner; l) systematically reproduce the Platform's database; m) copy, replicate, or reconstruct the functioning of the Recommendation Engine; n) manipulate the positioning of content through fraudulent actions; ñ) reverse engineer any of the technological systems; o) use the Platform to train proprietary or third-party artificial intelligence models without express authorization from the Owner; p) use the Platform for surveillance, commercial espionage, or massive collection of strategic information; q) carry out penetration tests or technical audits without written authorization from the Owner; r) resell, sublicense, or commercially exploit the services outside of the expressly authorized cases. The above list is merely illustrative and shall not limit the Owner's power to consider any other actions that compromise the integrity of the Platform as prohibited.

Article 19. Use of Artificial Intelligence services

1. The Platform incorporates artificial intelligence systems designed to provide contextual information, personalized recommendations, and automated assistance.

2. The User acknowledges that said systems generate responses through probabilistic processes and not through human reasoning, so the recommendations obtained should be interpreted as support for decision-making and never as an objective guarantee of the suitability, quality, availability, or outcome of a particular service.

3. The User undertakes to use the artificial intelligence services responsibly, refraining from using them for unlawful, fraudulent, or contrary to good faith purposes.

4. In particular, it is prohibited to use artificial intelligence systems to: a) generate unlawful content; b) obtain instructions intended to violate current legislation; c) facilitate the commission of crimes; d) disseminate disinformation campaigns; e) infringe intellectual property rights; f) attempt to extract confidential information about the internal functioning of the models used by the Platform; g) carry out attacks intended to modify, degrade, or alter the behavior of artificial intelligence systems.

5. The Owner may establish usage limits, query quotas, supervision mechanisms, automatic filters, and abuse prevention systems when necessary to preserve the quality and security of the service.

Article 20. Nature of recommendations

1. The recommendations offered by the Platform may be generated from one or more of the following elements: a) preferences expressed by the User; b) authorized geographic location; c) weather conditions; d) availability communicated by third parties; e) information provided by providers; f) User's historical behavior; g) usage trends; h) algorithmic criteria; i) artificial intelligence; j) editorial rules defined by the Owner.

2. The order of appearance of establishments, activities, services, or experiences shall not necessarily imply an objective quality assessment nor constitute an official classification.

3. The Platform may modify at any time the criteria used by the Recommendation Engine without prior notice when necessary to improve the functioning of the service, prevent fraud, optimize user experience, or adapt to new technological needs.

4. No provider, establishment, hotel, or partner shall acquire any right to maintain a particular position within the results generated by the Platform unless expressly agreed contractually.

Article 21. Content published by Users

When the Platform allows Users to incorporate content, they guarantee that: a) they are the owners of the necessary rights for its publication; b) the information provided is truthful; c) the content does not infringe third-party rights; d) it does not contain confidential information whose disclosure is unlawful; e) it complies with applicable personal data protection regulations. The User shall be liable to the Owner and third parties for any damages arising from the publication of content that breaches these conditions.

Article 22. License on content provided by the User

By voluntarily incorporating content into the Platform, the User grants the Owner a worldwide, free, non-exclusive, sublicensable when technically necessary, and valid for as long as said content remains published, license to: a) store; b) reproduce; c) technically adapt; d) index; e) publicly communicate; f) digitally distribute; g) integrate the content into the Platform's technological systems; h) use it to improve the provision of the contracted services. The above license shall be understood as limited exclusively to the purposes of the Platform's operation and shall not imply transfer of ownership of intellectual property rights.

Article 23. Content moderation

The Owner may review, moderate, limit, hide, or remove any content when there are reasonable indications that: a) it infringes current legislation; b) it violates third-party rights; c) it breaches these Terms; d) it harms the functioning of the Platform; e) it contains manifestly false information; f) it constitutes unauthorized advertising; g) it may generate risks for other users; h) it negatively affects the reputation or security of the digital ecosystem. The adoption of moderation measures shall not imply a general obligation of prior supervision of all content published by users.

Article 24. System availability and integrity

The User acknowledges that the Platform may be subject to maintenance, updating, functional expansion, technological replacement, or infrastructure migration operations. Consequently, the Owner may temporarily suspend access to all or part of the services when reasonably necessary to guarantee: a) service continuity; b) computer security; c) data protection; d) stability of the technological infrastructure; e) compliance with legal obligations; f) correct evolution of the Platform. Whenever technically possible, such operations shall be carried out seeking to minimize service interruptions.

Article 25. Collaboration in cybersecurity matters

Users who detect security incidents, technical vulnerabilities, or anomalous behavior shall report them to the Owner through the channels enabled for this purpose, refraining from exploiting such vulnerabilities or publicly disseminating information that may compromise the security of the Platform before it has had a reasonable opportunity to correct them. The Owner may publicly acknowledge the collaboration of those who in good faith report relevant vulnerabilities, without this generating any financial obligation unless expressly agreed.

TITLE IV — LEGAL REGIME OF SERVICES, MARKETPLACE, AND TECHNOLOGICAL INTERMEDIATION

Article 26. Nature of services offered by the Platform

1. Mallorca AI Travel Engine constitutes a multifunctional technological platform designed to facilitate interaction between users, tourist establishments, collaborating companies, service providers, and professional clients through digital tools, artificial intelligence systems, and automated recommendation processes.

2. The Platform may offer, independently or in combination, among others, the following services: a) tourist information services; b) intelligent recommendation services; c) contextual search engines; d) geolocation systems; e) virtual assistants based on artificial intelligence; f) business directories; g) lead capture systems; h) communication tools between users and providers; i) SaaS solutions; j) White-Label solutions; k) integration APIs; l) administration dashboards; m) analytics tools; n) booking modules; ñ) payment systems; o) loyalty services; p) subscription programs; q) any other technological developments incorporated by the Owner.

3. The effective availability of each service will depend on the contracted plan, the User's profile, the territory, the device used, and the functional evolution of the Platform.

Article 27. Digital ecosystem

1. The Platform constitutes a technological ecosystem composed of different independent actors who interact with each other through tools developed by the Owner.

2. Unless expressly agreed contractually, the Owner does not acquire the status of direct provider of the activities, products, or services offered by third parties.

3. Each provider shall retain full legal, economic, fiscal, labor, and organizational autonomy with respect to the Owner.

4. No provision contained in these Terms may be interpreted as constituting a partnership, agency, representation, franchise, exclusive distribution, mandate, or employment relationship between the Owner and the various providers integrated into the Platform.

Article 28. Operation of the Marketplace

1. The Platform may incorporate a digital Marketplace designed to facilitate the location, promotion, comparison, recommendation, and, where appropriate, contracting of services offered by third parties.

2. The content published in the Marketplace may include information relating to: tourist experiences, excursions, sports activities, nautical services, restaurants, leisure, transport, vehicle rental, wellness, local commerce, accommodation, events, and any other category incorporated by the Owner.

3. The inclusion of a provider in the Marketplace shall not imply certification, homologation, or guarantee of the quality of its services, unless expressly indicated that a specific verification process exists.

Article 29. Contractual relationships between Users and Providers

1. When a User directly contracts a service offered by a third party integrated into the Platform, the corresponding contract shall be deemed to be entered into exclusively between said User and the provider responsible for the service.

2. The Owner shall remain outside the contractual relationship arising between both parties, unless expressly acting as a contracting party in accordance with different particular conditions.

3. The provider shall be solely responsible for: a) execution of the service; b) its availability; c) its quality; d) its safety; e) its legality; f) customer service; g) issuing invoices where applicable; h) refunds; i) cancellations; j) compliance with applicable sectoral regulations.

Article 30. Information published by providers

1. Each provider shall be responsible for the accuracy, updating, and legality of the information incorporated into the Platform.

2. The Owner may editorially review certain content for the purpose of improving its presentation or adapting it to technical operating criteria, without thereby assuming any responsibility for its material content.

3. The provider undertakes to keep permanently updated, among others: schedules, prices, availability, photographs, commercial conditions, contact details, and administrative licenses where appropriate.

4. The Owner may temporarily suspend the publication of any manifestly outdated content when necessary to protect the interests of users.

Article 31. Recommendation Engine

1. The Platform incorporates a Recommendation Engine whose purpose is to dynamically determine the relevance of the content shown to each User.

2. Said Engine may simultaneously consider multiple variables, including, among others: a) User's location; b) temporal context; c) weather; d) declared preferences; e) usage history; f) availability communicated by providers; g) quality of published information; h) historical performance; i) aggregated user behavior; j) editorial criteria; k) artificial intelligence; l) predictive models; m) machine learning; n) promotional campaigns; ñ) commercial parameters contracted by certain professional clients, always within legally permitted limits.

3. The algorithm used by the Platform constitutes a trade secret protected by current legislation.

4. No User, Partner, or Provider shall acquire any right to know the internal functioning of the algorithm nor to demand a particular position within the results displayed.

Article 32. Absence of positioning guarantee

1. The contracting of a particular service, commercial plan, or collaboration modality shall not imply a guarantee of preferential appearance within the Recommendation Engine unless expressly agreed contractually.

2. The Owner may modify at any time the classification criteria used by the algorithm when necessary to: a) improve User experience; b) combat fraud; c) optimize Platform performance; d) adapt to new technologies; e) comply with regulatory obligations.

Article 33. Commercial Leads

1. The Platform may generate commercial opportunities for providers through contact forms, booking systems, information requests, virtual assistants, or any other functionality designed to facilitate communication between users and companies.

2. The Owner does not guarantee a minimum volume of Leads, bookings, conversions, or income derived from the use of the Platform.

3. The commercial quality of Leads will depend on multiple factors beyond the direct control of the Owner, including the information provided by the User and their willingness to contract.

4. The economic treatment of Leads shall be governed by the specific contracts signed with each Partner or Provider.

Article 34. Bookings

1. The Platform may incorporate proprietary or third-party systems designed to facilitate booking processes.

2. Unless expressly stated otherwise, the Owner shall act exclusively as the provider of the technological infrastructure necessary to channel the User's request.

3. The final confirmation of the booking will depend on the corresponding provider.

4. The Owner shall not be liable for cancellations, modifications, overbookings, temporary closures, operational incidents, or breaches attributable to the provider responsible for the service.

Article 35. Payments

1. Certain services may require payment of amounts.

2. Payments may be managed through proprietary platforms or specialized payment service providers.

3. The Owner may act as a mere technological integrator of said systems.

4. The economic conditions applicable to each service shall be communicated before formalization of the contract.

5. Payments made through external providers shall also be subject to the specific terms established by said operators.

Article 36. Subscriptions

1. The Platform may market subscription plans aimed at both individual users and professional clients.

2. Each subscription modality shall determine the available functionalities, usage limits, economic conditions, and duration of the service.

3. Subscriptions may be automatically renewed when expressly accepted during the contracting process.

4. The User may cancel the renewal in accordance with the procedure established for each contracting modality.

5. Cancellation shall prevent future renewals, without affecting the previously paid period.

Article 37. SaaS and White-Label services

1. The Owner may grant licenses for the use of its technological solutions through SaaS or White-Label contracts.

2. Such solutions may allow hotels, hotel chains, tourist accommodations, travel agencies, collaborating companies, and other organizations to integrate the functionalities developed by the Owner under their own corporate identity.

3. Unless expressly agreed, the contracting of White-Label solutions shall not imply any transfer of intellectual property over the software or over the technological developments used.

4. The specific conditions of these services shall be governed by independent contracts.

Article 38. APIs and technological integrations

1. The Platform may offer programming interfaces designed to facilitate integration with proprietary or third-party applications.

2. Access to said APIs may be subject to technical, economic, contractual, or security limitations.

3. The Owner may modify, update, replace, or withdraw versions of its APIs when necessary to guarantee the technological evolution of the service.

4. Improper use of the APIs may lead to immediate suspension of access.

Article 39. Availability of third-party services

The User acknowledges that part of the functionalities offered by the Platform may depend on technological services provided by third parties, including cloud providers, mapping systems, artificial intelligence engines, payment gateways, weather services, communication platforms, authentication providers, and other external infrastructures. Consequently, the Owner shall not be liable for interruptions, limitations, or incidents exclusively attributable to said third parties, without prejudice to making reasonable efforts to restore the service as soon as possible.

TITLE V — INTELLECTUAL PROPERTY, INDUSTRIAL PROPERTY, SOFTWARE, AND TECHNOLOGICAL ASSETS

Article 40. Ownership of technological assets

1. All intellectual property rights, industrial property rights, sui generis rights over databases, trade secrets, and any other rights of a similar nature related to the Platform belong exclusively to the Owner or to third parties who have legitimately authorized their use.

2. Use of the Platform does not, in any case, imply transmission, assignment, implicit license, or exploitation authorization over any of said rights, except to the extent strictly necessary to allow ordinary use of the Services in accordance with these General Terms.

3. All rights not expressly granted to the User remain reserved to the Owner.

Article 41. Protected assets

The following are protected, among others: a) source and object software; b) technological architecture; c) logical structure of the Platform; d) Progressive Web App; e) web applications; f) administration dashboards; g) APIs; h) programming libraries; i) algorithms; j) predictive models; k) artificial intelligence systems; l) training models developed by the Owner; m) automated processes; n) scoring and classification systems; ñ) the Recommendation Engine; o) calculation methodologies; p) databases; q) technical documentation; r) graphic designs; s) user interface; t) user experience; u) visual identity; v) corporate image; w) trademarks, logos, and distinctive signs; x) domains and subdomains; y) functional documentation; z) any other technological asset developed for the Platform. The above list is merely illustrative.

Article 42. Limited use license

1. The Owner grants the User a limited, personal, revocable, non-exclusive, non-sublicensable, and non-transferable use license to access the Platform solely in accordance with these General Terms.

2. Said license does not confer any right to: a) copy the software; b) modify it; c) distribute it; d) commercialize it; e) rent it; f) sublicense it; g) make it available to third parties; h) integrate it into other technological developments without express authorization.

3. The license shall automatically terminate when the legal relationship between the parties ends or when the Owner legitimately suspends the User's access.

Article 43. Exploitation restrictions

It is expressly prohibited, unless written authorization from the Owner is obtained: a) to reproduce all or part of the Platform; b) to clone its functionalities; c) to replicate its technological architecture; d) to reuse its functional structure; e) to copy the user experience design; f) to use automated captures to recreate the service's operation; g) to develop competing products using information obtained through the Platform; h) to use any part of the Platform to provide equivalent services to third parties. These prohibitions shall apply even when certain functionalities are not protected by patent or specific registration.

Article 44. Reverse engineering

The User shall refrain from carrying out any action intended to: a) decompile the software; b) disassemble programs; c) analyze object code; d) discover source code; e) identify internal algorithms; f) reconstruct automated processes; g) identify internal parameters of the Recommendation Engine; h) obtain protected technical information through reverse engineering. This prohibition shall also extend to any software, API, or component distributed by the Owner.

Article 45. Protection of the Recommendation Engine

1. The Recommendation Engine constitutes an essential technological asset whose internal configuration, calculation methodology, decision rules, weightings, and learning processes form part of the Owner's trade secrets.

2. No User may carry out actions intended to: a) deduce the internal functioning of the algorithm; b) artificially alter its results; c) manipulate variables used by the system; d) interfere with machine learning processes; e) modify the relevance of content through fraudulent techniques; f) systematically analyze results to reconstruct the internal logic of the algorithm.

3. The Owner may freely modify the Recommendation Engine without prior notice.

Article 46. Artificial Intelligence systems

1. The Platform may use proprietary models, models licensed from third parties, or hybrid artificial intelligence systems.

2. The User acknowledges that the internal functioning of said models constitutes confidential information whose protection is essential for the Owner's business activity.

3. Unless expressly authorized, it is forbidden to: a) use the Platform to train external artificial intelligence models; b) collect responses for mass training purposes; c) generate databases intended to reproduce the behavior of Concierge AI; d) develop competing models using information obtained from the Platform.

4. The User's queries shall not imply any assignment of rights over the technological models used by the Owner.

Article 47. Databases

1. The databases that make up the Platform are protected by intellectual property legislation and by the specific regulations relating to the legal protection of databases.

2. Systematic extraction, reuse, copying, or transfer of a substantial part of said databases through manual or automated procedures is prohibited.

3. The repeated extraction of non-substantial parts shall also be considered prohibited when, due to its repetition or purpose, it may affect the normal exploitation of the database.

Article 48. APIs

1. The APIs developed by the Owner constitute protected software.

2. Their use shall be limited exclusively to the purposes authorized in the corresponding contract or license.

3. The Owner may: a) limit the number of calls; b) establish quotas; c) control traffic; d) modify endpoints; e) withdraw obsolete versions; f) block integrations incompatible with the Platform's security.

4. Access to an API shall not imply any right to maintain its future availability.

Article 49. Trademarks and distinctive signs

The trademarks, trade names, logos, domains, service denominations, iconography, graphic elements, and any other distinctive signs used by the Platform belong to the Owner or their respective owners. Any use that may generate a risk of confusion regarding the business origin of the services is prohibited.

Article 50. Feedback and suggestions

1. The User may voluntarily communicate proposals for improvement, ideas, suggestions, functional incidents, or recommendations relating to the Platform.

2. Unless otherwise agreed in writing, such communications shall be free of charge and non-confidential.

3. The Owner may freely incorporate such suggestions into its technological developments without this generating any right to financial compensation, recognition of authorship, or participation in future profits.

4. The foregoing shall not apply where there is a specific joint development or confidentiality agreement signed between the parties.

Article 51. Protection of trade secrets

The User shall refrain from disclosing any technical, functional, commercial, or strategic information obtained as a result of access to restricted areas of the Platform when, by its nature or circumstances, it may reasonably be considered confidential. In particular, the following shall be considered as such: a) technical documentation; b) architecture diagrams; c) internal processes; d) performance metrics; e) business criteria; f) system configurations; g) algorithmic strategies; h) reserved commercial information; i) technological evolution plans.

Article 52. Actions against infringements

The Owner may exercise any civil, commercial, administrative, or criminal actions that may be appropriate for the defense of its intellectual property rights, industrial property, trade secrets, and other technological assets. Likewise, it may adopt technical measures designed to prevent unauthorized access, limit functionalities, block accounts, restrict integrations, or prevent improper use of any of the elements protected by these Terms.

TITLE VI — FINANCIAL REGIME, SUBSCRIPTIONS, BILLING, AND PAYMENT TERMS

Article 53. General principles

1. Certain Services offered by the Platform shall be free of charge, while others shall be subject to payment of a price, commission, periodic fee, license, usage fee, or any other financial consideration established by the Owner.

2. The economic conditions applicable to each Service shall be those in force at the time of its contracting, without prejudice to modifications that may occur in accordance with the provisions of these Terms and the General Contracting Conditions.

3. The use of a paid Service shall imply express acceptance of the corresponding economic conditions.

Article 54. Commercial modalities

The Owner may commercialize its Services under any of the following modalities, without limitation: a) monthly subscriptions; b) annual subscriptions; c) SaaS licenses; d) White-Label licenses; e) scalable plans; f) pay-per-use; g) per-user pricing; h) per-establishment pricing; i) per-room pricing; j) per-API pricing; k) commissions for technological intermediation; l) Lead generation; m) Premium services; n) additional modules; ñ) custom developments; o) technology consulting; p) system integration; q) any other commercial modality that the Owner may implement in the future.

Article 55. Prices

1. All prices shall be published by the Owner with sufficient notice before contracting.

2. Unless expressly stated otherwise, prices are understood before indirect taxes that are legally applicable.

3. Taxes shall be calculated in accordance with the tax regulations applicable depending on the Client's country of residence and the nature of the contracted service.

4. Manifest material errors in the publication of prices may be corrected by the Owner before final acceptance of the order.

Article 56. Price modifications

1. The Owner may modify the prices of the Services when economic, technological, regulatory, or commercial reasons justify it.

2. The modifications shall not affect previously paid periods.

3. In the case of periodic subscriptions, the new rates shall apply from the next renewal period, provided that the Client has been informed with reasonable notice.

4. The Client may cancel the renewal before the new rate comes into effect.

Article 57. Billing

1. The Owner shall issue the corresponding invoice when legally required.

2. Invoices may be issued exclusively in electronic format.

3. The Client expressly accepts the use of electronic invoicing unless applicable law provides otherwise.

4. Invoices shall be available through the Client's private area or through the systems enabled by the Owner.

Article 58. Payment methods

The Platform may accept, among others, the following payment methods: a) bank card; b) bank transfer; c) direct debit; d) international payment providers; e) digital wallets; f) mobile payment systems; g) other methods authorized by the Owner. The Owner may incorporate or withdraw any of them when necessary for technical, commercial, or regulatory reasons.

Article 59. Payment service providers

1. Certain financial transactions may be processed by financial entities or specialized providers independent of the Owner.

2. In such cases, the processing of data strictly necessary to execute the payment shall be carried out in accordance with the terms established by said providers.

3. The Owner shall not store complete bank card data unless strictly necessary and always in accordance with applicable international security standards.

Article 60. Automatic renewals

1. When a subscription includes automatic renewal, it shall occur for successive periods equivalent to the initially contracted period.

2. Renewal shall imply the automatic charge of the corresponding amount using the payment method authorized by the Client.

3. The Client may deactivate automatic renewal before the start of the next billing period.

4. Cancellation of renewal shall not entitle the Client to a refund of the already started period.

Article 61. Non-payment

1. Breach of payment obligations shall entitle the Owner to: a) partially suspend the Services; b) limit functionalities; c) block access; d) cancel professional accounts; e) terminate the corresponding contract; f) claim judicially or extrajudicially the amounts owed.

2. The exercise of any of the foregoing powers shall not imply waiver of the other actions that may correspond to the Owner.

Article 62. Suspension for economic reasons

While a situation of non-payment persists, the Owner may: a) prevent new bookings; b) block API integrations; c) suspend White-Label services; d) limit access to the professional panel; e) stop automated processes; f) hide certain content published by the Professional Client where essential to protect the commercial integrity of the Platform.

Article 63. Refunds

1. The refund regime shall depend on the nature of the contracted Service.

2. Digital services provided immediately may not be subject to withdrawal when any of the circumstances provided for in applicable legislation apply.

3. Refund requests shall be analyzed individually in accordance with the Contracting Conditions.

4. Any refund of amounts shall not imply any acknowledgment of liability on the part of the Owner.

Article 64. Promotional programs

The Owner may establish promotional campaigns consisting of, among others: a) discounts; b) trial periods; c) promotional codes; d) bonuses; e) loyalty programs; f) promotional credits; g) invitations; h) launch campaigns. The specific terms of each promotion shall prevail over these Terms exclusively with respect to the corresponding promotion.

Article 65. Promotional credits

1. Promotional credits shall not be considered electronic money.

2. They shall not be refundable.

3. They shall not accrue interest.

4. They may not be converted into cash unless required by law.

5. The Owner may establish expiration dates, usage limitations, and application restrictions.

Article 66. Commissions

When the commercial model contemplates the accrual of commissions derived from bookings, sales, Leads, or any other operation carried out through the Platform, their calculation, settlement, invoicing, and payment shall be governed by the specific contracts signed with each Partner, Provider, or Professional Client.

Article 67. Set-off of amounts

The Owner may set off any due, liquid, and enforceable amount owed by a Client with other amounts it must pay to the same, provided that such set-off is legally permissible.

Article 68. Economic audit

With respect to Professional Clients whose contracts contemplate variable settlements, the Owner may establish reasonable verification, data reconciliation, and audit mechanisms to verify the correct determination of the amounts accrued.

Article 69. Reservation of rights

The failure by the Owner to exercise any of the rights arising from these Terms shall not imply any waiver thereof, and it may exercise them at any time as long as they have not expired in accordance with applicable law.

TITLE VII — LIABILITY, EXCLUSION OF WARRANTIES, ASSUMPTION OF RISKS, AND INDEMNITY

Article 70. General principles of liability

1. The Owner's liability shall be determined exclusively in accordance with applicable law, these General Terms, and, where applicable, the Specific Conditions governing each Service.

2. The User acknowledges that the Platform constitutes a complex technological service whose operation depends on multiple internal and external factors, including communications infrastructures, cloud providers, artificial intelligence services, payment operators, mapping systems, data providers, third-party APIs, Internet availability, and other elements beyond the direct control of the Owner.

3. Consequently, the Owner does not guarantee uninterrupted, continuous, or completely error-free operation of the Platform.

Article 71. Availability of Services

1. The Owner shall make reasonable efforts to maintain the availability of the Platform.

2. Nevertheless, interruptions may occur arising from, among others: a) maintenance tasks; b) software updates; c) infrastructure replacement; d) technical incidents; e) power failures; f) unavailability of technology providers; g) computer attacks; h) network congestion; i) administrative actions; j) force majeure.

3. Such interruptions shall not constitute a breach of contract when they are reasonably unavoidable or necessary to guarantee the stability, security, or evolution of the Platform.

Article 72. Accuracy of information

1. The Owner shall endeavor to ensure that the information displayed on the Platform is reasonably accurate and kept up to date.

2. However, part of said information comes from independent third parties.

3. Consequently, the Owner does not guarantee: a) permanent updating of content; b) effective availability of services offered by third parties; c) absolute accuracy of schedules; d) validity of prices; e) continuity of promotions; f) permanence of open establishments; g) absence of material errors.

4. The User should verify directly with the provider any circumstance that is essential for their contracting decision.

Article 73. Services provided by third parties

1. The providers integrated into the Platform shall act under their sole responsibility.

2. The Owner shall not be liable for: a) cancellations; b) delays; c) contractual breaches; d) accidents; e) personal injury; f) material damage; g) financial losses; h) schedule changes; i) itinerary changes; j) deficiencies in the provision of the service.

3. Claims relating to the material execution of the service should be directed initially to the corresponding provider.

Article 74. Operation of Artificial Intelligence

1. The User acknowledges that Concierge AI and other artificial intelligence systems incorporated into the Platform generate responses using statistical and probabilistic models.

2. Consequently, the responses may contain: a) inaccuracies; b) omissions; c) incorrect interpretations; d) outdated information; e) recommendations not suitable for particular circumstances.

3. No response generated by artificial intelligence shall be considered as: a) legal advice; b) medical advice; c) financial advice; d) tax advice; e) technical report; f) professional certification; g) guarantee of outcome.

4. The User shall be solely responsible for verifying any relevant information before making decisions based on the recommendations generated by the Platform.

Article 75. Geolocation

1. Certain functionalities may use the User's geographic location for the purpose of improving the recommendations offered.

2. The accuracy of such services shall depend on multiple technical factors beyond the Owner's control.

3. The Owner shall not be liable for errors arising from: a) loss of GPS signal; b) inaccurate positioning; c) incorrect cartographic information; d) limitations of the User's devices; e) restrictions imposed by operating systems.

Article 76. Weather information and external data

The Platform may incorporate information from weather services, public administrations, mapping providers, or other external sources. The Owner shall not be liable for the consequences of errors, delays, or modifications made by such information providers.

Article 77. Availability of establishments

The appearance of an establishment within the Platform does not imply that it is open, operational, available, or in a position to provide the requested service at a given time. The User should confirm directly with the establishment the effective conditions of contracting when necessary.

Article 78. Liability for external links

The Platform may contain links to third-party websites, applications, or platforms. The Owner shall not be liable for the content, availability, commercial policies, personal data processing, or operation of said external services.

Article 79. User's devices

The User shall be responsible for having: a) an Internet connection; b) a compatible device; c) an updated operating system; d) adequate security software; e) sufficient technical configuration to correctly use the Platform. The Owner shall not be liable for incidents arising from incompatible equipment, incorrect configurations, or the User's own technical deficiencies.

Article 80. Backups

Unless expressly established otherwise by specific contract, the User shall be responsible for keeping backup copies of information whose loss could cause them harm.

Article 81. Force majeure

The Owner shall not be liable for breaches arising from unforeseeable or unavoidable events beyond its reasonable control, including, among others: a) natural disasters; b) pandemics; c) armed conflicts; d) terrorist attacks; e) general strikes; f) Internet outages; g) massive cyberattacks; h) governmental decisions; i) administrative restrictions; j) widespread failures of critical infrastructures.

Article 82. Quantitative limitation of liability

1. Unless otherwise required by mandatory law, the total accumulated liability of the Owner to a User arising from these Terms shall not exceed the amount actually paid by said User to the Owner during the twelve (12) months immediately preceding the event giving rise to the claim.

2. Where the User has not paid any amount, the Owner's liability shall be limited to the maximum permitted by applicable law.

3. This limitation shall not apply in those cases where applicable law expressly prohibits such limitation.

Article 83. Exclusion of certain damages

To the extent permitted by applicable law, the Owner shall not be liable for: a) loss of profits; b) loss of earnings; c) loss of business opportunities; d) loss of customers; e) reputational damage; f) indirect losses; g) consequential damages; h) loss of data not attributable to the Owner; i) damages arising from decisions made by the User using information obtained on the Platform.

Article 84. Indemnity obligation

The User undertakes to indemnify the Owner against any claim, penalty, administrative, judicial, or arbitral proceeding arising from: a) unlawful use of the Platform; b) breach of these Terms; c) infringement of third-party rights; d) publication of unlawful content; e) actions carried out from their Account. This obligation shall also include reasonable legal defense costs necessary for the proper protection of the Owner's interests.

Article 85. Mitigation of damages

The parties undertake to adopt all reasonably feasible measures to reduce or mitigate the damages that may arise from any incident related to the use of the Platform. Failure to adopt such measures may be taken into account when determining the potential liability of each party.

Article 86. Statute of limitations for claims

Unless a mandatory rule establishes a different period, claims arising from the use of the Platform must be brought within the limitation periods provided for by applicable law. Filing internal claims with the customer service department shall not, by itself, interrupt such periods unless expressly provided by law.

TITLE VIII — DATA PROTECTION, CONFIDENTIALITY, ELECTRONIC COMMUNICATIONS, AND REGULATORY COMPLIANCE

Article 87. General principles

1. The Owner shall process personal data obtained through the Platform in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation), applicable national legislation, and other applicable European provisions on data protection, privacy, and digital services.

2. The processing of personal data shall be carried out at all times in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and proactive accountability.

3. These General Terms shall be interpreted jointly with the Privacy Policy, which specifically develops the legal regime applicable to the processing of personal data.

Article 88. Data Controller

1. The Data Controller shall be the entity identified in the Legal Notice of the Platform.

2. Where certain Services are provided jointly with third parties, the regime of joint controllership or data processor shall be determined in accordance with applicable law and the agreements signed between the parties.

3. In those SaaS or White-Label services where the Professional Client determines the purposes and essential means of processing, the relationship between the parties may be governed by the corresponding Data Processing Agreement.

Article 89. Purposes of processing

Personal data may be processed, among others, for the following purposes: a) manage user registration; b) provide the contracted Services; c) personalize the user experience; d) generate recommendations through artificial intelligence; e) manage bookings and information requests; f) process payments and billing; g) provide technical support; h) guarantee the security of the Platform; i) prevent fraud; j) comply with legal obligations; k) improve algorithms and functionalities of the Platform through techniques compatible with current regulations; l) manage commercial relationships with Partners and Professional Clients.

Article 90. Legal bases for processing

The processing carried out by the Owner may be based, as applicable, on: a) performance of a contract; b) application of pre-contractual measures; c) the data subject's consent; d) compliance with legal obligations; e) protection of vital interests; f) public interest where applicable; g) the Owner's legitimate interest, provided that the fundamental rights and freedoms of the data subject do not override.

Article 91. Data provided by the User

1. The User guarantees that all data provided are accurate, complete, and up to date.

2. When providing personal data belonging to third parties, the User declares that they have sufficient legitimacy to do so and assumes full responsibility arising from such communication.

3. The Owner may request updating of data when there are reasonable indications that it has ceased to be accurate.

Article 92. Geolocation

1. Certain functionalities may require access to the User's geographic location.

2. Use of such Services shall be conditional upon the authorization granted by the User through the mechanisms enabled by their device.

3. Denial of geolocation permission may limit certain functionalities without affecting the rest of the Services.

4. The User may revoke at any time the authorization granted from their device settings or through the tools enabled by the Platform.

Article 93. Artificial Intelligence and automated processing

1. The Platform may use artificial intelligence systems to analyze information provided by the User for the purpose of generating personalized recommendations.

2. Such automated processing shall be carried out in accordance with the guarantees provided for in applicable European regulations.

3. The detailed operation of these systems shall be developed in the Platform's Artificial Intelligence Policy.

4. The use of artificial intelligence shall not imply the automatic adoption of decisions with legal effects on the User unless expressly provided for in applicable law or subject to express consent where necessary.

Article 94. Confidentiality

1. All information exchanged between the User and the Owner shall be confidential when by its nature it should reasonably be treated as such.

2. The Owner shall adopt reasonable technical and organizational measures to prevent unauthorized access to such information.

3. The confidentiality obligation shall remain in force even after the legal relationship between the parties has ended with respect to information that continues to be confidential.

Article 95. Electronic communications

1. The User accepts that communications relating to the provision of Services may be carried out by electronic means.

2. Communications sent by: a) email; b) notifications within the Platform; c) private panel; d) mobile applications; e) integrated messaging systems; f) any other channel expressly enabled by the Owner shall have full validity.

3. It shall be the User's responsibility to keep their contact details up to date.

Article 96. Commercial communications

1. Sending commercial communications shall be carried out in accordance with current legislation.

2. Where legally required, such communications shall require the prior consent of the recipient.

3. The User may withdraw such consent at any time through the mechanisms enabled for this purpose.

4. The foregoing shall not prevent the sending of communications strictly necessary for the execution of the contract or for compliance with legal obligations.

Article 97. Retention of information

1. Personal data shall be retained only for as long as necessary to fulfill the purposes for which they were collected.

2. Once the contractual relationship has ended, they may be kept blocked when necessary to address potential legal, administrative, or judicial liabilities.

3. Once the legally required periods have elapsed, the data shall be deleted or anonymized in accordance with the Owner's internal policies.

Article 98. Regulatory compliance

1. The Owner shall conduct its activities in compliance with applicable regulations concerning: a) data protection; b) digital services; c) electronic commerce; d) consumers and users; e) intellectual property; f) cybersecurity; g) fraud prevention; h) artificial intelligence; i) any other applicable provisions.

2. The User likewise undertakes to comply with current regulations during use of the Platform.

Article 99. Fraud prevention

The Owner may implement automated or manual procedures to detect: a) fraudulent access; b) mass creation of accounts; c) automated use of Services; d) attempts to manipulate algorithms; e) economic fraud; f) abusive use of promotions; g) activities likely to compromise the security of the digital ecosystem. Where necessary, the Owner may temporarily suspend certain Services while appropriate checks are carried out.

Article 100. Cooperation with authorities

The Owner may communicate strictly necessary information to judges, courts, administrative authorities, police and security forces, or any other competent authority when there is a legal obligation, valid request, or it is necessary to protect the rights of the Owner or third parties.

Article 101. Document integrity

These General Terms form part of a contractual set comprising the other legal documents published by the Owner. In the event of contradiction between documents, the one specifically regulating the matter in dispute shall prevail, without prejudice to the application of applicable mandatory rules.

Article 102. Independence of clauses

The possible nullity, invalidity, or unenforceability of any of the provisions contained in these Terms shall not affect the validity of the rest of the document. The parties shall endeavor to replace the affected provision with another that produces substantially equivalent legal and economic effects.

Article 103. Applicable law

These General Terms shall be governed by Spanish law and applicable European Union law.

Article 104. Dispute resolution

1. The parties shall endeavor in good faith to resolve any dispute arising from the interpretation or execution of these Terms.

2. Where the User is a consumer, they may, where applicable, use the legally provided out-of-court dispute resolution mechanisms.

3. Unless otherwise provided by mandatory law, any dispute shall be submitted to the competent Courts and Tribunals of Palma de Mallorca, Spain.

Article 105. Entry into force

These General Terms shall enter into force on the date indicated at the beginning of the document and shall remain in force until replaced by a later version published by the Owner.

General Contracting Conditions

Last updated: July 12, 2026

GENERAL CONTRACTING CONDITIONS

TITLE I — GENERAL PROVISIONS

CHAPTER I — Purpose and scope of application

Article 1. Purpose

These General Contracting Conditions (hereinafter, the "GCC") regulate the contracting of the digital services offered by Mallorca AI Travel Engine (hereinafter, "Mallorca AI") through its websites, applications, SaaS platform, mobile applications, APIs, and any other enabled channels.

The GCC constitute the general contractual framework applicable to all contracting carried out with Mallorca AI, without prejudice to the particular conditions that may apply to certain services, plans, products, or Professional Clients.

Article 2. Scope of application

These GCC shall apply, as applicable, to: Individual Users, Travelers, Premium Clients, Pro Clients, Hotels, Tourist Apartments, Travel Agencies, DMCs, Tour Operators, Commercial Partners, Experience Providers, Technology Integrators, and any natural or legal persons who contract services directly offered by Mallorca AI. The contracting of any service shall imply express acceptance of these GCC.

Article 3. Contractual documentation

The contractual relationship between Mallorca AI and the Client may be composed, among others, of the following documents:

1. These General Contracting Conditions.
2. The Terms & Conditions of Use.
3. The Privacy Policy.
4. The Cookie Policy.
5. The Artificial Intelligence & Automation Policy.
6. The API & Integrations Policy (where applicable).
7. The Refund & Cancellation Policy.
8. The specific terms of the contracted plan.
9. The specific contract signed with the Professional Client, where it exists.
10. The technical, functional, or commercial annexes that form part of the contracting.

In case of contradiction, the particular conditions or the specific contract shall prevail with respect to the matter expressly regulated.

Article 4. Definitions

For the purposes of these GCC, the terms "User", "Client", "Professional Client", "Partner", "Marketplace", "Upsell", "Predictive Tourism Intelligence Engine", "Premium Plan", "Pro Plan", "Professional Area", and other concepts defined in the Terms & Conditions of Use shall have the same meaning, unless the context requires a different interpretation.

Article 5. Nature of services

Mallorca AI mainly provides digital services consisting of: access to a technological platform, SaaS tools, predictive tourism intelligence services, recommendation engines, process automation, management tools for Professional Clients, and technological intermediation services where expressly indicated. Unless expressly stated, Mallorca AI does not act as a package tour organizer, retail travel agency, tour operator, or material provider of the services offered by third parties through the Platform.

Article 6. Service evolution

The Client acknowledges that Mallorca AI is a constantly evolving technological platform. Consequently, Mallorca AI may incorporate improvements, new functionalities, technical modifications, optimizations of the Predictive Engine, or changes to the user interface when necessary to improve the service, adapt to regulatory changes, or guarantee the security and stability of the Platform. Provided that such modifications do not substantially alter the object of the contracted service, they shall not give rise to any right to compensation or early termination of the contract.

Article 7. Capacity to contract

Only natural persons of legal age with sufficient legal capacity or duly represented legal entities may contract the services of Mallorca AI. Those contracting on behalf of a company, hotel, agency, or other entity declare and guarantee that they have sufficient powers to legally bind said organization.

Article 8. Good faith

The parties undertake to act in accordance with the principles of good faith, cooperation, transparency, and mutual trust throughout the duration of the contractual relationship. The Client shall use the contracted services diligently and in accordance with applicable law, refraining from carrying out actions that may harm the functioning of the Platform or the rights of other Users.

Article 9. Contractual communications

Communications relating to contracting may be carried out by electronic means, including email, the Professional Area, the administration panel, notifications within the Platform, or other channels enabled by Mallorca AI. The parties acknowledge the validity of such communications as a means of proof, provided they allow reasonable proof of their sending and receipt.

Article 10. Language and versions

These GCC may be available in several languages to facilitate understanding. In case of discrepancy between translations, the version expressly designated as official by Mallorca AI shall prevail, without prejudice to the rights that applicable law recognizes to consumers in matters of contractual information.

TITLE II — CONTRACTING PROCESS

CHAPTER I — Initiation of contracting

Article 11. Contracting modalities

Mallorca AI services may be contracted through any of the channels enabled by the Platform, including, among others: Corporate website, SaaS Platform, Web application (PWA), Mobile applications, Professional Area, Marketplace, APIs enabled for contracting, Authorized commercial teams, Authorized distributors or collaborators, and any other officially enabled channel by Mallorca AI. Contracting carried out through any of these means shall have full legal validity.

Article 12. Contracting request

Contracting shall begin with the request made by the Client through the procedure enabled for each service. Said request may involve, among other actions: creation of an account; completion of forms; selection of a plan; acceptance of these Conditions; acceptance of applicable policies; identification of the Client; validation of the information provided; and payment where applicable.

Article 13. Pre-contractual information

Before completing the contracting, Mallorca AI shall make available to the Client, in a clear and accessible manner, the essential information relating to the contracted service, including, where applicable: main characteristics of the service; included functionalities; plan limitations; price; applicable taxes; duration; renewal modality; cancellation conditions; refund policy; and applicable contractual documentation.

Article 14. Order confirmation

Once the contracting request is received, Mallorca AI may send the Client an electronic acknowledgment of receipt. Such acknowledgment shall solely evidence receipt of the request and shall not necessarily imply final acceptance of the contract.

CHAPTER II — Perfection of the contract

Article 15. Time of perfection

The contract shall be deemed perfected when, as applicable, the following concur: acceptance of the request by Mallorca AI; validation of the necessary information; receipt of payment where required; activation of the contracted service; or any other unequivocal act evidencing acceptance by Mallorca AI. Until that time, Mallorca AI may request additional information or justifiably reject the contracting.

Article 16. Activation of services

Activation may occur: immediately, automatically, deferred, manually, or scheduled. The effective activation date shall determine the start of the service provision period, unless the particular conditions establish otherwise.

Article 17. Reservation of acceptance

Mallorca AI reserves the right not to accept a contracting request when any of the following circumstances apply: false or inaccurate information; unverifiable identity; previous contractual breaches; fraud or reasonable indications of fraud; abusive use of the Platform; breach of applicable regulations; technical impossibility of providing the service; risks to Platform security; or force majeure. The refusal of contracting shall not give rise to any right to compensation, without prejudice to the refund of amounts that, where applicable, may proceed in accordance with applicable law.

CHAPTER III — Registration and user accounts

Article 18. Creation of accounts

Certain services will require the creation of a personal or professional account. The Client must provide truthful, complete, and up-to-date information during the registration process. Mallorca AI may request verification of certain data when necessary to guarantee the security of the service or compliance with legal obligations.

Article 19. Identity verification

Mallorca AI may establish identity verification, representation, or legitimation procedures for certain services, especially in the case of Professional Clients, technological integrations, or services of special economic relevance. Refusal to complete such procedures may prevent the activation of the corresponding service.

Article 20. Accuracy of information

The Client shall be responsible for keeping the data provided during contracting up to date. Mallorca AI shall not be liable for the consequences arising from incorrect, incomplete, or outdated information provided by the Client.

CHAPTER IV — Electronic contracting

Article 21. Electronic means

The parties expressly recognize the legal validity of contracts entered into by electronic means. Acceptance of these GCC through electronic mechanisms shall be equivalent, for all legal purposes, to the signature of the corresponding contract.

Article 22. Contract retention

Mallorca AI may retain electronic evidence of the contracting carried out, including acceptance records, timestamps, IP addresses, session identifiers, and other elements necessary to prove the existence and content of the contract, while in all cases respecting applicable data protection regulations.

Article 23. Error correction

Before finalizing the contracting, the Client shall have reasonable mechanisms to review and correct the data entered. Once the contract is perfected, modifications shall be subject to the conditions applicable to the corresponding service.

CHAPTER V — Special conditions for Professional Clients

Article 24. Business contracting

When the Client acts in the exercise of their business or professional activity, they declare that the contracting is carried out for purposes related to said activity and that they do not hold the status of consumer for the purposes of consumer protection regulations.

Article 25. Representation

Whoever formalizes the contracting on behalf of a legal entity declares that they have sufficient powers to bind it contractually. Mallorca AI may request documentation proving such representation when it deems it necessary.

Article 26. Supplementary documentation

Depending on the contracted service, Mallorca AI may require the signing of specific contracts, technical annexes, data processing agreements, service level agreements (SLA), integration contracts, or any other supplementary documentation. The absence of such documentation, when necessary, may prevent the activation of the service.

CHAPTER VI — Contractual integrity

Article 27. Entire agreement

These General Terms, together with the contractual documents that apply, constitute the entire agreement between the parties regarding the contracting of the service. Any modification must be made in writing or through the electronic mechanisms enabled by Mallorca AI.

Article 28. Independence of clauses

The possible nullity, invalidity, or unenforceability of any of the provisions contained in these GCC shall not affect the validity of the rest of the document, which shall continue to be fully in force to the extent compatible with applicable law.

TITLE III — PLANS, LICENSES, DURATION, AND PROVISION OF SERVICES

CHAPTER I — Contractable services

Article 29. Service catalog

Mallorca AI may offer different digital services, the availability of which may vary depending on the evolution of the Platform. Among others: Premium Plans for travelers, Pro Plans, Temporary Passes, SaaS Licenses, Services for Hotels, Services for Apartments, Services for Agencies, Services for Operators, Marketplace, APIs, Integrations, Additional Modules, Premium Functionalities, and future services that Mallorca AI may incorporate into the ecosystem.

Article 30. Nature of services

Unless expressly stated otherwise, all services offered by Mallorca AI shall be digital in nature and shall consist of the granting of a limited right of access and use of technological functionalities during the contracted period. Contracting shall not imply the acquisition of the software, source code, technological infrastructure, or intellectual property rights associated with the Platform.

Article 31. Services subject to availability

Certain functionalities may depend on: the User's location; technical availability; the existence of integrations with third parties; services provided by external providers; and the contracting of the corresponding plan. Mallorca AI does not guarantee that all functionalities are available in all territories or for all types of Client.

CHAPTER II — Activation and access

Article 32. Start of service

The service shall begin on the activation date communicated by Mallorca AI or, where applicable, from the moment the Client obtains effective access to the contracted functionalities.

Article 33. Access to the Platform

During the term of the service, the Client shall have the right to access the functionalities included in the contracted plan, in accordance with the technical, functional, and commercial limitations that apply.

Article 34. Functional evolution

The Client acknowledges that the available functionalities may evolve during the term of the service. Mallorca AI may incorporate new tools, improvements, automations, optimizations, new modules, improvements to the Predictive Engine, and new integrations. Likewise, it may remove or replace obsolete, insecure, or incompatible functionalities with technological evolution, provided that this does not deprive the Client of the essential object of the contracted service.

CHAPTER III — Duration

Article 35. Temporary plans

Temporary plans shall have the duration expressly indicated during the contracting process. Among others: passes of three days, five days, seven days, and other temporary modalities that Mallorca AI may offer. The duration shall begin from the effective activation of the service. Once said period has ended, access to Premium functionalities shall cease automatically, unless renewed or a new plan is contracted.

Article 36. Subscriptions

When the service takes the form of a subscription, it shall have the duration indicated in the particular conditions of the corresponding plan. Unless otherwise established, renewal shall occur in accordance with the system expressly accepted by the Client during contracting.

Article 37. Services for Professional Clients

Services contracted by Hotels, Agencies, Operators, and other Professional Clients shall have the duration provided for in the specific contract or in the particular conditions of the corresponding plan.

CHAPTER IV — Renewals

Article 38. Automatic renewal

When a service includes automatic renewal, it shall be carried out only if the Client has expressly accepted it during the contracting process and always in full compliance with applicable law. The Client may deactivate automatic renewal through the channels enabled by Mallorca AI before the deadline indicated for each service modality.

Article 39. Manual renewal

In those plans that do not contemplate automatic renewal, the service shall end once the contracted period has elapsed. The Client may contract a new period at any time, in accordance with the conditions in force at that time.

CHAPTER V — Service availability

Article 40. Continuous provision

Mallorca AI shall make reasonable efforts to maintain the availability of the Platform during the term of the service. However, interruptions may arise from: maintenance, updates, technical incidents, security actions, force majeure, or failures of external providers. Such circumstances shall not constitute a breach of contract when they are reasonable and proportionate.

Article 41. Maintenance

Mallorca AI may schedule preventive, corrective, or evolutionary maintenance tasks. Whenever possible, such actions shall be communicated in advance when they may significantly affect the availability of the service.

CHAPTER VI — Service modifications

Article 42. Technological changes

Mallorca AI may introduce modifications necessary to improve security, adapt to regulatory changes, incorporate new technologies, optimize performance, integrate new information sources, and evolve the Predictive Engine. These modifications shall form part of the natural evolution of the service.

Article 43. Replacement of functionalities

When a functionality ceases to be available for technical, regulatory, or commercial reasons, Mallorca AI may replace it with another of equivalent or superior features, provided that this is reasonably possible.

Article 44. Beta functionalities

Mallorca AI may offer certain functionalities in beta, experimental, or early access phase. These functionalities may be subject to limitations, frequent modifications, or withdrawal without prior notice, without this giving rise to any right to compensation.

CHAPTER VII — End of service

Article 45. Natural expiration

The services shall end by: expiration of the contracted term, end of the subscription, contractual termination, withdrawal where legally applicable, or causes provided for in these GCC or in the corresponding contract.

Article 46. Effects of termination

Once the service has ended: the right of access to the contracted functionalities shall cease; Mallorca AI may deactivate the account or limit access to Premium functions; the Client shall retain access only to those free functionalities that, where applicable, remain available; and the processing and retention of data shall continue to be governed by the Privacy Policy and applicable legal obligations.

Article 47. Survival of certain obligations

The termination of the contract shall not affect those obligations that, by their nature, must remain in force, including, among others: confidentiality, intellectual property, data protection, limitation of liability, dispute resolution, pending payment obligations, and retention of evidence and records.

TITLE IV — PRICES, BILLING, AND PAYMENT TERMS

CHAPTER I — Prices

Article 48. Determination of prices

The prices of the services offered by Mallorca AI shall be those published at the time of contracting or those expressly agreed by contract with the Professional Client. Unless expressly stated otherwise, prices shall be expressed in euros and shall include or exclude applicable taxes as indicated during the contracting process.

Article 49. Price updates

Mallorca AI may modify its rates for new contracts or future renewals. Modifications shall not affect services already contracted during the previously paid period, unless a mandatory legal provision establishes otherwise or there is an express agreement between the parties. When a modification affects an automatic renewal, the Client shall be informed with reasonable notice, in accordance with applicable law.

Article 50. Promotions and discounts

Mallorca AI may offer promotions, discounts, promotional codes, or commercial campaigns of limited duration. Unless expressly stated, such promotions: shall be temporary; shall not be cumulative with each other; shall not create acquired rights for future contracting; and may be subject to specific conditions.

CHAPTER II — Billing

Article 51. Issuance of invoices

Mallorca AI shall issue the corresponding invoices for the contracted services in accordance with applicable tax legislation. Invoices may be issued exclusively in electronic format, unless applicable law recognizes the Client's right to another format.

Article 52. Billing data

The Client shall be responsible for providing complete, accurate, and up-to-date billing data. Modifications communicated after an invoice has been issued may not have retroactive effect, unless required by law.

Article 53. Taxes

Applicable indirect taxes, including Value Added Tax (VAT) or other equivalent taxes, shall be charged in accordance with the legislation in force at the time of contracting. When the Professional Client is entitled to the application of a specific tax regime (for example, reverse charge or legally provided exemptions), they must provide the necessary documentation for its correct application.

CHAPTER III — Payment methods

Article 54. Payment forms

Mallorca AI may accept different payment methods, including: bank cards, transfers, direct debit, electronic payment platforms, and other means enabled at any time. The availability of each method may vary depending on the type of Client or the contracted service.

Article 55. Advance payment

Unless the particular conditions establish another modality, the digital services of Mallorca AI shall be contracted by advance payment. Activation of the service may be conditional upon correct receipt of the corresponding amount.

Article 56. Payment security

Electronic payments may be processed by specialized providers. Mallorca AI shall not store complete bank card data when such data is managed directly by the payment service provider in accordance with applicable security standards.

CHAPTER IV — Non-payment and delays

Article 57. Non-payment

Total or partial non-payment shall entitle Mallorca AI to: suspend activation of the service; limit certain functionalities; temporarily block access; terminate the contract where the breach persists; and claim judicially or extrajudicially the amounts owed. All of the foregoing without prejudice to other rights that may correspond to it in accordance with applicable law.

Article 58. Resulting expenses

The Client shall be liable for reasonable expenses arising from returned direct debits, unjustified payment chargebacks, or banking costs caused by breaches attributable to the Client, provided that such expenses are duly justified.

Article 59. Default interest

In relations with Professional Clients, due and unpaid amounts may accrue the default interest provided for in applicable law, without prejudice to compensation for collection costs legally applicable.

CHAPTER V — Particularities of digital services

Article 60. Economic nature of the service

The Client acknowledges that the services offered by Mallorca AI consist mainly of access to digital functionalities, technological infrastructures, predictive tourism intelligence engines, and SaaS services whose availability requires ongoing development, maintenance, hosting, processing, technology licensing, and third-party service costs. Consequently, activation of the service implies the effective start of the contracted provision.

Article 61. Technological costs

The economic structure of Mallorca AI's services is based on a continuous provision model that implies permanent costs associated with, among others: technological infrastructure, cloud services, storage, data processing, artificial intelligence, third-party APIs, maintenance, monitoring, technical support, and cybersecurity. This circumstance shall be taken into consideration for the interpretation and application of these Conditions and of the Refund and Cancellation Policy, without prejudice to the inalienable rights that applicable law recognizes to consumers and users.

Article 62. Reference to the Refund Policy

The conditions relating to withdrawal, cancellations, returns, and refunds shall be governed by Mallorca AI's Refund and Cancellation Policy, which forms an integral part of the contractual documentation. In case of conflict, said Policy shall prevail with respect to the matters specifically regulated therein.

CHAPTER VI — Suspension for economic reasons

Article 63. Service suspension

Mallorca AI may temporarily suspend access to services when there are due and enforceable amounts pending payment, following communication to the Client where reasonably possible and where it does not compromise the security or integrity of the Platform. Suspension shall not release the Client from pending financial obligations.

Article 64. Reactivation

Once the financial situation has been regularized, Mallorca AI shall endeavor to restore the service within a reasonable period, provided that this is technically possible and no other legitimate cause for suspension or termination exists.

TITLE V — MARKETPLACE, TECHNOLOGICAL INTERMEDIATION, AND THIRD-PARTY SERVICES

CHAPTER I — Nature of the Marketplace

Article 65. Digital ecosystem

Mallorca AI may incorporate a Marketplace designed to facilitate the discovery, promotion, request, contracting, or booking of products and services offered by third parties. Among others: excursions, activities, experiences, restaurants, transport, rentals, nautical activities, wellness services, guided tours, tourist services, and complementary products. The availability of each service shall depend on the offer existing at any given time.

Article 66. Nature of Mallorca AI's intervention

Unless expressly stated otherwise for a specific service, Mallorca AI shall act as a provider of a technological infrastructure designed to connect Users and Professional Clients. Mallorca AI's intervention may include, among other functions: publication of offers, search engines, intelligent recommendations, communication tools, technological management of requests, integration with external systems, and technical processing of certain operations. The existence of these functionalities shall not, by itself, make Mallorca AI the material provider of the service offered.

Article 67. Effective providers

The products and services published on the Marketplace shall be provided by the Professional Clients or providers who offer them. Each provider shall be solely responsible for: the correct execution of the service, its availability, its quality, its legality, the necessary administrative authorizations, and compliance with applicable sectoral regulations.

CHAPTER II — Publication of offers

Article 68. Content of offers

Each Professional Client shall be responsible for the content of the offers they publish, including: description, images, prices, availability, schedules, particular conditions, limitations, requirements, cancellation conditions, and refund conditions. Mallorca AI may establish common presentation formats to improve the User experience.

Article 69. Accuracy of information

Professional Clients must keep the published information permanently updated. Mallorca AI shall not be liable to Users for errors arising from information directly provided by the provider.

Article 70. Removal of content

Mallorca AI may remove, suspend, or limit the visibility of any offer when: it infringes current legislation; it breaches these GCC; it violates third-party rights; it generates risks for Users; it harms the functioning of the Marketplace; or it affects the reputation of Mallorca AI. The adoption of these measures shall not give rise to any right to compensation when duly justified.

CHAPTER III — Contracting of third-party services

Article 71. Contractual relationship

When a User contracts a service offered by a Professional Client through the Marketplace, the corresponding contract shall be deemed to be entered into between the User and the effective provider of the service, unless Mallorca AI expressly acts as a contracting party.

Article 72. Particular conditions

Each provider may establish particular conditions applicable to their own services. The User must accept them when necessary to complete the contracting. In case of contradiction between the provider's particular conditions and these GCC, the former shall prevail with respect to the specific service, provided they respect applicable mandatory law.

Article 73. Provider obligations

Each Professional Client guarantees that they have: administrative licenses, mandatory insurance, necessary authorizations, qualified personnel, sufficient material resources, compliance with consumer regulations, and compliance with tourist regulations. Mallorca AI may request supporting documentation when necessary to preserve the security and quality of the Marketplace.

CHAPTER IV — Payments and commissions

Article 74. Financial intermediation

When Mallorca AI participates in the technological management of the contracting or collection process for third-party services, it may receive the commission previously agreed with the corresponding Professional Client. The existence of such commission shall not alter the legal nature of the relationship between the User and the effective provider of the service, unless expressly agreed contractually.

Article 75. Nature of the commission

The commission received by Mallorca AI remunerates exclusively the technological services of promotion, digital intermediation, infrastructure, and Platform management. Therefore, unless mandatory law or express agreement provides otherwise, the eventual cancellation or breach of service by the provider shall not automatically imply the refund of the corresponding commission to Mallorca AI when it has correctly executed the technological services under its responsibility.

Article 76. Settlements

The conditions relating to settlements, payments to providers, invoicing, periodicity, set-offs, and other economic aspects may be regulated by specific contracts signed between Mallorca AI and each Professional Client.

CHAPTER V — Liability

Article 77. Limitation of liability

Mallorca AI shall not be liable for: the material execution of services, the quality of the provision, the behavior of the provider, contractual breaches by the Professional Client, damages caused during the effective provision of the service, cancellations attributable to the provider, modifications made by the provider. All of the foregoing without prejudice to the responsibilities that may correspond to it when it acts directly as the service provider.

Article 78. Claims

Claims relating to the effective provision of a service should be directed initially to the responsible provider. Mallorca AI may provide communication or technological mediation tools between the parties, without thereby assuming the status of responsible for the contracted service.

Article 79. Cooperation

Where reasonably possible, Mallorca AI shall cooperate with Users and Professional Clients to facilitate the amicable resolution of incidents arising in connection with services contracted through the Marketplace. Such cooperation shall be voluntary and shall not imply the assumption of obligations that legally or contractually correspond to the effective provider.

CHAPTER VI — Professional Clients' own services

Article 80. Upsells and complementary services

Hotels, Apartments, Agencies, Operators, and other Professional Clients may use Mallorca AI to directly offer complementary services or Upsells to their own clients. The contracting of such services shall be governed by the particular conditions established by the establishment or provider itself.

Article 81. Absence of Mallorca AI liability

Unless expressly agreed otherwise, Mallorca AI shall not participate in the material provision, price setting, execution, guarantee, cancellation, or refund of Upsells commercialized directly by Professional Clients. When Mallorca AI does not receive a commission on such services, its intervention shall be limited exclusively to providing the technological infrastructure necessary for their publication, promotion, and management.

Article 82. Transparency to the User

Mallorca AI shall endeavor to clearly identify the effective provider of each service offered through the Platform, so that the User knows who assumes the obligations arising from the contracting.

CHAPTER VII — Evolution of the Marketplace

Article 83. New service modalities

Mallorca AI may incorporate new product categories, services, or commercialization modalities as the Platform evolves. The incorporation of new services shall not alter the legal nature of existing relationships, unless expressly established in the corresponding particular conditions.

Article 84. Integration with third parties

The Marketplace may be integrated with platforms, booking systems, availability engines, payment tools, or other technological services of third parties. Mallorca AI shall not be liable for incidents arising exclusively from the functioning of said external systems, without prejudice to making reasonable efforts to maintain the interoperability of the ecosystem.

TITLE VI — PREDICTIVE ENGINE, ARTIFICIAL INTELLIGENCE, AND RECOMMENDATIONS

CHAPTER I — Nature of the Predictive Engine

Article 85. Purpose

Mallorca AI incorporates a Predictive Tourism Intelligence Engine designed to assist Users and Professional Clients by analyzing multiple variables to generate recommendations, predictions, classifications, automations, and suggestions related to tourist activity. The Predictive Engine constitutes a decision support tool and does not replace the human judgment of the User or Professional Client.

Article 86. Operation

The Predictive Engine may analyze, among others, the following elements: approximate User location, date and time, weather, seasonality, estimated occupancy, availability communicated by providers, User preferences, Platform usage history, parameters defined by Professional Clients, publicly available information, data from authorized integrations, statistical models, and Mallorca AI's proprietary algorithms. The combination and weighting of these factors forms part of Mallorca AI's Know-How and trade secrets.

Article 87. Probabilistic nature

The recommendations generated by the Predictive Engine are probabilistic in nature and are based on estimates, patterns, mathematical models, and information available at any given time. Consequently, Mallorca AI does not guarantee that the predictions, estimates, or recommendations are accurate, complete, or suitable for all circumstances.

CHAPTER II — Intelligent recommendations

Article 88. Decision support

The recommendations offered by the Platform shall be merely advisory and shall not constitute mandatory instructions or professional advice. The final decision shall always correspond to the User or Professional Client.

Article 89. External factors

Recommendations may be affected by circumstances beyond Mallorca AI's control, including: weather changes, traffic incidents, schedule changes, cancellations, availability of places, administrative closures, third-party errors, extraordinary events, and force majeure. Mallorca AI shall not be liable for consequences arising exclusively from such external factors.

Article 90. Personalization

Recommendations may be automatically adapted to the User's profile, declared preferences, usage context, and other technical parameters legitimately used by the Platform. Personalization shall aim to improve the usefulness of recommendations without limiting the User's freedom of choice.

CHAPTER III — Automations

Article 91. Automated processes

The Platform may execute certain automated processes, including: content classification, prioritization of recommendations, assignment of scores, generation of alerts, automation of communications, ordering of results, and optimization suggestions for Professional Clients. These processes shall be designed to improve operational efficiency and user experience.

Article 92. Human oversight

Where the nature of the process so requires, Mallorca AI may establish human oversight mechanisms over automated decisions that produce relevant effects for Users or Professional Clients.

CHAPTER IV — Information sources

Article 93. Data used

The operation of the Predictive Engine may rely on information from various sources, including: data provided by the User, information provided by Professional Clients, authorized integrations, third-party APIs, public information, statistical data, and information generated by the Platform itself. The use of such sources shall be carried out in accordance with applicable law and the corresponding terms of use.

Article 94. Quality of information

Mallorca AI shall make reasonable efforts to improve the quality of information used by the Predictive Engine. However, it does not guarantee the absolute absence of errors, inconsistencies, or outdated information where these originate from external sources or information provided by third parties.

CHAPTER V — Limitations

Article 95. Absence of guarantee of results

Use of the Predictive Engine does not guarantee: increased sales, increased bookings, improved occupancy, increased revenue, profit generation, complete optimization of business activity, or fulfillment of specific expectations. Results shall depend on multiple factors beyond Mallorca AI's control.

Article 96. Responsible use

The User and Professional Client shall use the recommendations generated by the Platform responsibly, applying their own professional judgment where circumstances advise. Recommendations should not be interpreted as mandatory instructions or as a substitute for human judgment.

Article 97. Evolution of the Predictive Engine

The Predictive Engine shall evolve continuously through the incorporation of technical improvements, new models, new information sources, optimizations, and methodological adjustments. These evolutions form part of the nature of the service and shall not give rise to any right to maintain previous versions of the Predictive Engine.

CHAPTER VI — Transparency

Article 98. Information to the User

Mallorca AI shall endeavor to clearly inform when content, recommendations, or classifications have been generated in whole or in part through automated processes or artificial intelligence technologies, where required by applicable law.

Article 99. Regulatory compliance

Mallorca AI shall develop and operate its Predictive Engine in accordance with the principles of legality, transparency, security, human oversight, proportionality, and accountability, in line with applicable European and national regulations on artificial intelligence.

Article 100. Specific policy

These provisions are complemented by Mallorca AI's Artificial Intelligence & Automation Policy, which develops in greater detail the technical, organizational, and ethical principles applicable to the design, development, and use of artificial intelligence systems integrated into the Platform.

CHAPTER VII — Protection of the Predictive Engine

Article 101. Ownership and protection

The Predictive Tourism Intelligence Engine, its algorithms, models, business rules, methodologies, scoring systems, inference processes, configuration parameters, and other elements that make it up constitute technological and business assets of Mallorca AI, protected by regulations on intellectual property, trade secrets, and unfair competition. No provision of these GCC may be interpreted as an assignment of such rights.

Article 102. Prohibition of improper exploitation

It is forbidden to use the Platform for the purpose of: reconstructing the internal functioning of the Predictive Engine, training competing systems, carrying out systematic extraction of results, developing substantially equivalent products, or obtaining information intended to replicate the operating logic of Mallorca AI. Such conduct may lead to immediate suspension of the service and the exercise of appropriate legal actions.

TITLE VII — RIGHTS AND OBLIGATIONS OF THE PARTIES

CHAPTER I — Obligations of Mallorca AI

Article 103. Provision of service

Mallorca AI shall provide the contracted services with the diligence reasonably expected from a specialized provider of technological solutions, seeking to maintain the availability, stability, security, and continuous evolution of the Platform. The provision of the service shall be carried out in accordance with these GCC, the applicable particular conditions, and current legislation.

Article 104. Technological evolution

Mallorca AI may introduce technical, functional, and security improvements during the term of the contract. These actions shall aim to: improve the user experience, increase security, optimize performance, adapt the Platform to regulatory changes, incorporate new technologies, and evolve the Predictive Engine. Provided that such modifications do not alter the essential object of the contracted service, they shall not constitute a breach of contract.

Article 105. Protection of information

Mallorca AI shall adopt reasonable technical and organizational measures to protect the information processed on the Platform, in accordance with its Information Security Policy and applicable data protection regulations.

Article 106. Support

Mallorca AI may offer technical support services in accordance with the service level contracted by each Client. Response times, available channels, and hours may vary depending on the contracted plan or the specific agreement signed with the Professional Client.

CHAPTER II — Client obligations

Article 107. Diligent use

The Client shall use the Platform responsibly, diligently, and in accordance with current legislation. In particular, they shall refrain from using Mallorca AI for: unlawful purposes, fraudulent activities, distribution of malware, computer attacks, identity theft, infringement of third-party rights, or activities that compromise the security of the Platform.

Article 108. Truthfulness of information

The Client guarantees that all information provided during contracting and during use of the Platform is truthful, complete, and up to date. They shall be responsible for the consequences arising from incorrect, false, or outdated data.

Article 109. Safeguarding credentials

The Client shall be responsible for: safeguarding their credentials, maintaining the confidentiality of their passwords, controlling authorized access, and immediately reporting any unauthorized access or suspicion of improper use. Actions carried out using valid credentials shall be presumed to have been carried out by the corresponding holder, unless proven otherwise.

Article 110. Equipment and connectivity

Unless expressly agreed, it shall be the Client's responsibility to have the equipment, devices, Internet connection, and other resources necessary to correctly use the contracted services. Mallorca AI shall not be liable for incidents arising from equipment or connections not belonging to its infrastructure.

CHAPTER III — Specific obligations of Professional Clients

Article 111. Published information

Professional Clients shall be responsible for the accuracy, timeliness, and legality of all information they publish or manage through the Platform. This includes, among others: descriptions, prices, availability, photographs, schedules, service conditions, commercial offers, promotions, and Upsells.

Article 112. Licenses and authorizations

Each Professional Client declares that they have all the licenses, permits, authorizations, insurance, and qualifications required by applicable law for the development of their activity. Mallorca AI may request supporting documentation when necessary.

Article 113. End customer service

When the Professional Client is the effective provider of the service, they shall assume full responsibility for user service regarding: execution of the service, incidents, modifications, cancellations, claims, guarantees, and refunds that legally or contractually correspond to them. Mallorca AI's intervention as a technology provider shall not alter such responsibility.

CHAPTER IV — Obligations relating to the Platform

Article 114. Use in accordance with the license

The Client shall use the Platform exclusively within the limits established in the granted use license. They may not: sublicense, resell the software as their own, modify the code, decompile, reverse engineer, circumvent security measures, or use the Platform to develop competing solutions. All of the foregoing without prejudice to legally mandatory exceptions.

Article 115. Reasonable use

The Client undertakes to make reasonable use of the technological resources made available to them. Mallorca AI may establish proportionate technical limits relating to, among others: query volume, API calls, storage, concurrent users, processing capacity, and use of advanced functionalities. Where such limits form part of the contracted plan, the Client shall be informed in advance.

Article 116. Integrations

When the Client uses integrations with third-party systems, they guarantee that they have the necessary authorizations to do so. Mallorca AI shall not be responsible for limitations arising from such external systems.

CHAPTER V — Cooperation between the parties

Article 117. Collaboration

The parties undertake to cooperate in good faith to facilitate the correct provision of the service. In particular, the Client shall attend to reasonable requests for information necessary to resolve incidents, implement new functionalities, or verify the correct functioning of the Platform.

Article 118. Reporting incidents

The Client shall notify Mallorca AI, as soon as they become aware, of any relevant incident that may affect: security, availability, data integrity, service operation, or fraudulent use of the Platform.

Article 119. Duty of mitigation

Both parties shall adopt reasonably necessary measures to minimize damages that may arise from technical incidents, operational errors, or contractual breaches, avoiding actions that unnecessarily aggravate their consequences.

CHAPTER VI — Breaches

Article 120. Client breach

Breach of the obligations provided for in these GCC may entitle Mallorca AI to adopt, proportionally to the seriousness of the facts, measures such as: requests for remedy, temporary limitation of functionalities, suspension of service, removal of content, blocking of accounts, termination of the contract, and claim for damages where appropriate.

Article 121. Mallorca AI breach

When Mallorca AI materially breaches the obligations assumed under the contract, the Client may exercise the rights recognized by applicable law and these GCC, without prejudice to the limitations of liability expressly provided for.

Article 122. Good faith and proportionality

The measures adopted by either party in the event of a breach shall respect the principles of good faith, proportionality, and reasonableness, seeking, whenever possible, prior remedy of the breach before resorting to termination of the contract.

TITLE VIII — LIABILITY AND LIMITATION OF LIABILITY

CHAPTER I — General principles

Article 123. Liability in accordance with law

Mallorca AI shall be liable exclusively in those cases where there is legal or contractual liability directly attributable to it, in accordance with applicable law. No provision of these GCC shall exclude or limit those liabilities whose exclusion or limitation is prohibited by mandatory rules.

Article 124. Professional diligence

Mallorca AI shall provide its services with the diligence reasonably expected from a specialized provider of technological solutions. However, given the digital nature of the Platform, the Client acknowledges that no computer system can guarantee absolute availability or total absence of errors.

CHAPTER II — Limitations arising from technological nature

Article 125. Service availability

Mallorca AI shall make reasonable efforts to maintain service continuity. However, it shall not be liable for interruptions caused by: scheduled maintenance, updates, cloud provider incidents, telecommunications network failures, Internet outages, external attacks, force majeure, actions of public authorities, or circumstances beyond its reasonable control.

Article 126. External integrations

The Platform may partially depend on the operation of APIs, cloud services, payment systems, mapping tools, weather services, booking engines, or other solutions provided by third parties. Mallorca AI shall not be liable for errors, unavailability, modifications, or interruptions exclusively attributable to such external providers.

Article 127. Technological evolution

The continuous improvement of the Platform may involve functional modifications, reorganization of processes, incorporation of new technologies, or removal of obsolete functionalities. These actions shall not constitute a breach of contract when they respect the essential object of the contracted service.

CHAPTER III — Artificial Intelligence

Article 128. Predictive nature

The Predictive Tourism Intelligence Engine provides estimates, recommendations, and analyses based on statistical models, algorithms, and multiple sources of information. The recommendations generated are advisory in nature and do not constitute binding decisions or professional advice.

Article 129. Absence of guarantee

Mallorca AI does not guarantee that the recommendations generated will produce: increased sales, increased bookings, improved occupancy, business optimization, fulfillment of specific expectations, or generation of economic benefits. Results shall depend on multiple factors beyond Mallorca AI's control.

Article 130. Final decision

Any decision made by the User or Professional Client based on information provided by the Platform shall be their sole responsibility.

CHAPTER IV — Marketplace and third-party services

Article 131. Effective provision

When a service is materially provided by a Hotel, Agency, Operator, Partner, or any other Professional Client, they shall assume full responsibility arising from its execution.

Article 132. Service quality

Mallorca AI shall not be liable for: delays, cancellations, modifications, breaches, damages caused during the effective provision of the service, quality of experiences, or availability communicated by third parties. All of the foregoing without prejudice to the liabilities that may legally correspond to it as a technology provider.

Article 133. Upsells

Upsells offered directly by Hotels, Agencies, or other Professional Clients shall be the exclusive responsibility of the establishment that commercializes them. When Mallorca AI only provides the technological infrastructure and does not receive a commission on such sales, it shall not assume any obligation regarding their execution, modification, cancellation, or refund.

CHAPTER V — Information and content

Article 134. Third-party information

Mallorca AI may display information from Professional Clients, external APIs, public bodies, or open sources. It shall not be liable for errors originating exclusively from such sources when it has acted with the diligence reasonably expected for their integration.

Article 135. User-generated content

Users and Professional Clients shall be exclusively responsible for the content, images, descriptions, promotions, prices, and other information they publish through the Platform.

CHAPTER VI — Exclusions

Article 136. Indirect damages

Unless applicable law provides otherwise or there is fraud or gross negligence, Mallorca AI shall not be liable for indirect damages, loss of profits, loss of business opportunities, loss of revenue, loss of business reputation, or similar damages arising from the use of the Platform.

Article 137. Client actions

Mallorca AI shall not be liable for damages arising from: incorrect use of the Platform, breach of these GCC, use contrary to the instructions provided, unauthorized manipulation, or use by unauthorized persons.

Article 138. Force majeure

Mallorca AI shall not be liable for breaches arising from unforeseeable or unavoidable events beyond its reasonable control, including, among others: natural disasters, fires, floods, pandemics, armed conflicts, massive cyberattacks, widespread Internet failures, decisions of public authorities, general strikes, and power outages.

CHAPTER VII — Mitigation of damages

Article 139. Duty of cooperation

The Client shall reasonably cooperate with Mallorca AI to reduce the consequences arising from any incident. Lack of cooperation may be taken into account when assessing the potential liability of the parties.

Article 140. Early communication

Any incident that may generate significant harm shall be communicated without undue delay through the channels enabled by Mallorca AI, allowing corrective measures to be adopted as soon as possible.

CHAPTER VIII — Interpretation

Article 141. Systematic interpretation

The limitations of liability provided for in this Title shall be interpreted jointly with: the Artificial Intelligence & Automation Policy, the API & Integrations Policy, the Information Security Policy, the Refund and Cancellation Policy, the particular conditions of the contracted service, and the specific contract signed with the Professional Client, where it exists.

Article 142. Complementary nature

These provisions shall apply without prejudice to the inalienable rights recognized to consumers and users by current legislation.

TITLE IX — SUSPENSION, TERMINATION, AND END OF CONTRACT

CHAPTER I — Temporary suspension

Article 143. Preventive suspension

Mallorca AI may temporarily suspend, in whole or in part, access to the Platform when reasonably necessary to: protect system security, preserve data integrity, prevent fraud, prevent unauthorized access, carry out urgent maintenance tasks, comply with legal obligations, or attend to requests from competent authorities. Whenever circumstances permit, Mallorca AI shall endeavor to inform the Client in advance.

Article 144. Suspension for breach

Mallorca AI may temporarily suspend the service when the Client: breaches these GCC, breaches the particular conditions of the service, maintains due and unpaid amounts, provides false information, uses the Platform fraudulently, compromises system security, or violates third-party rights. Suspension may be maintained as long as the cause that motivated it persists.

Article 145. Technical suspension

Mallorca AI may temporarily suspend certain functionalities when necessary to: apply updates, correct vulnerabilities, make technical improvements, migrate infrastructure, or carry out cybersecurity actions. These actions shall form part of the ordinary maintenance of the Platform.

CHAPTER II — Contractual termination

Article 146. Termination for breach

Either party may terminate the contract when the other materially breaches the essential obligations assumed and such breach has not been remedied within a reasonable period from the corresponding request, unless the seriousness of the breach makes such request unnecessary.

Article 147. Immediate termination

Mallorca AI may immediately terminate the contractual relationship when any of the following circumstances apply: proven fraud, use of the service for unlawful activities, attacks against the Platform, unauthorized reverse engineering, massive extraction of information, use to train competing systems, unauthorized transfer of accounts, prohibited automated use, repeated breaches, or serious risks to security.

Article 148. Termination by Client decision

The Client may terminate the contract in accordance with the particular conditions of the contracted plan and, where applicable, the Refund and Cancellation Policy. When the service has a fixed duration, early termination shall not give the right to a refund of amounts paid unless provided by applicable law, the particular conditions, or the aforementioned Policy.

CHAPTER III — Effects of termination

Article 149. Cessation of access

Once the contract has ended, Mallorca AI may: deactivate users, cancel credentials, revoke API keys, block access, terminate active sessions, and remove administrative permissions.

Article 150. Data retention

The retention, blocking, deletion, or anonymization of personal data shall continue to be governed by the Privacy Policy and applicable data protection regulations. In the case of Professional Clients, Mallorca AI may retain certain contractual, accounting, or technical information when necessary to comply with legal, tax, security obligations, or for the defense against possible claims.

Article 151. Export of information

Where the nature of the service allows and whenever technically feasible, Mallorca AI may provide reasonable mechanisms for the Professional Client to export information in their ownership before the definitive end of the service. The availability, format, scope, and timeframe of such mechanisms may vary depending on the contracted plan and applicable particular conditions.

CHAPTER IV — Survival of obligations

Article 152. Subsequent obligations

Termination of the contract shall not extinguish those obligations that, by their nature, must remain in force. Among others: confidentiality, intellectual property, data protection, trade secrets, pending payment obligations, limitations of liability, dispute resolution, and retention of evidence.

Article 153. Mallorca AI rights

Termination of the contract shall not imply any waiver of the rights that correspond to Mallorca AI to claim outstanding amounts, demand liability, or exercise the legal actions that may be appropriate.

CHAPTER V — Account closure

Article 154. Voluntary deletion

The Client may request the closure of their account through the procedures enabled by Mallorca AI. The closure request shall not automatically extinguish pending contractual obligations nor imply the immediate deletion of all information when there is a legal obligation to retain it.

Article 155. Closure due to inactivity

Mallorca AI may deactivate accounts that remain inactive for prolonged periods, provided this is compatible with applicable law and following communication to the User where reasonably possible.

Article 156. Reopening

The possible reactivation of a previously suspended or closed account shall be at the sole discretion of Mallorca AI, unless applicable law or a court ruling provides otherwise.

CHAPTER VI — Economic consequences

Article 157. Outstanding amounts

Termination of the contract shall not extinguish already accrued financial obligations. Outstanding amounts shall continue to be enforceable in accordance with these GCC and applicable law.

Article 158. Already executed services

Termination of the contract shall not affect digital services already provided, activated, or executed prior to the effective date of termination. Any refunds or compensation shall be governed exclusively by the Refund and Cancellation Policy and applicable law.

CHAPTER VII — Document integration

Article 159. Supplementary documentation

The provisions of this Title shall be interpreted jointly with: the Refund and Cancellation Policy, the Privacy Policy, the Artificial Intelligence & Automation Policy, the API & Integrations Policy, the Intellectual Property Policy, and the specific contracts signed with Professional Clients.

TITLE X — FINAL PROVISIONS

CHAPTER I — Modifications of the Conditions

Article 160. Modification of the GCC

Mallorca AI may modify these General Contracting Conditions when necessary to: adapt to legislative or regulatory changes, incorporate new functionalities, improve Platform security, technologically evolve services, adapt the document to new contracting modalities, or respond to changes in the business model. Modifications shall not have retroactive effects on already consolidated rights, unless a mandatory rule provides otherwise.

Article 161. Communication

When modifications significantly affect the contractual relationship, Mallorca AI shall communicate them to the Client through the channels habitually used for contractual communications. Continued use of the service after the modifications come into force may be understood as acceptance of the same when permitted by applicable law and the Client has been duly informed.

CHAPTER II — Assignment and subcontracting

Article 162. Assignment of contract

The Client may not assign their contractual position without the prior written authorization of Mallorca AI. Mallorca AI may assign all or part of the contractual relationship in the context of corporate transactions, business restructurings, mergers, demergers, transfers of business units, or changes of control, ensuring that the assignee assumes the essential obligations arising from the contract.

Article 163. Subcontracting

Mallorca AI may use specialized technology providers for the partial provision of certain services, including, among others: cloud hosting, data processing, artificial intelligence, communication services, storage, monitoring, technical support, payment services, and cybersecurity. The use of such providers shall not release Mallorca AI from the obligations that legally correspond to it vis-à-vis the Client.

CHAPTER III — Force majeure

Article 164. Force majeure

Neither party shall be liable for failure to perform its obligations when such failure is a direct consequence of unforeseeable or unavoidable events beyond its reasonable control. The following shall be considered, among others: natural disasters, fires, floods, pandemics, armed conflicts, terrorist acts, general strikes, massive cyberattacks, widespread Internet outages, large-scale power failures, decisions of public authorities, and any other comparable circumstance. The affected party shall communicate such circumstance to the other party as soon as reasonably possible.

CHAPTER IV — Waiver and independence

Article 165. Absence of waiver

Failure to exercise or delay in exercising any right recognized in these GCC shall not imply waiver thereof nor prevent its subsequent exercise.

Article 166. Independence of clauses

The possible nullity, invalidity, or unenforceability of any of the provisions contained in these GCC shall not affect the validity of the rest of the document. The affected clauses shall be replaced, to the extent possible, by others that produce an equivalent legal effect in accordance with applicable law.

CHAPTER V — Applicable law and dispute resolution

Article 167. Applicable law

These General Contracting Conditions shall be governed and interpreted in accordance with Spanish law. Where mandatory consumer protection provisions or international provisions of mandatory compliance apply, these shall prevail over the provisions of these GCC.

Article 168. Amicable resolution

The parties shall endeavor in good faith to resolve any dispute arising from the interpretation or execution of these GCC through direct negotiation before resorting to other means of resolution. The foregoing shall not limit the right of either party to exercise the actions that legally correspond to it when necessary for the defense of its rights.

Article 169. Competent jurisdiction

When the Client is a consumer, the courts and tribunals determined by applicable mandatory rules shall have jurisdiction. In relationships exclusively between businesses or professionals (B2B), unless specifically agreed otherwise, the parties expressly submit to the Courts and Tribunals of Palma de Mallorca (Balearic Islands, Spain), waiving any other jurisdiction that may correspond to them, provided such submission is valid under current law.

CHAPTER VI — Entry into force

Article 170. Validity

These General Contracting Conditions shall enter into force on the date of their publication by Mallorca AI or on the date expressly indicated in the document itself. The GCC shall remain in force until modified or replaced by a new version published by Mallorca AI.

Article 171. Document integration

These General Contracting Conditions form part of Mallorca AI's general legal framework and shall be interpreted jointly with: the Legal Notice, the Terms & Conditions of Use, the Privacy Policy, the Cookie Policy, the Artificial Intelligence & Automation Policy, the API & Integrations Policy, the Information Security Policy, the Refund and Cancellation Policy, the Intellectual Property Policy for Professional Clients, Partners and Collaborators, the particular conditions of the contracted service, and the specific contracts signed with Professional Clients, where they exist. In case of conflict, the document specifically regulating the matter in dispute shall prevail, without prejudice to applicable mandatory rules.

FINAL PROVISION

These General Contracting Conditions constitute the general contractual framework for the provision of the digital services of Mallorca AI Travel Engine. Their purpose is to guarantee a transparent, balanced, and secure legal relationship between Mallorca AI, Users, Professional Clients, Partners, technology providers, and other operators that make up the Platform's ecosystem, promoting sustainable, innovative development in accordance with applicable law.

Privacy Policy

Last updated: July 12, 2026

PRIVACY POLICY

MALLORCA AI TRAVEL ENGINE®

Version 1.0
Effective date: [●]
Last updated: [●]

TITLE I — GENERAL PROVISIONS

Article 1. Purpose of the Privacy Policy

1. This Privacy Policy aims to inform in a complete, transparent manner, and in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("General Data Protection Regulation" or GDPR), as well as Organic Law 3/2018 on Personal Data Protection and guarantee of digital rights ("LOPDGDD") and other applicable regulations, about the processing of personal data carried out by Mallorca AI Travel Engine® in the development of its activity.

2. This Policy forms an integral part of the Platform's legal framework and shall be interpreted jointly with the Legal Notice, the Terms & Conditions of Use, the General Contracting Conditions, the Cookie Policy, the Artificial Intelligence Policy, and the rest of the applicable contractual documents.

3. The use of any of the services offered by the Platform implies that the data subject has had the opportunity to know this Privacy Policy before providing their personal data.

Article 2. Identity of the Data Controller

For the purposes of data protection regulations, the Data Controller is:

• Corporate Name: [●]
• Trade Name: Mallorca AI Travel Engine®
• Tax ID (NIF/CIF): [●]
• Registered Office: [●]
• Privacy Email: [privacy@domain.com]
• General Email: [●]
• Phone: [●]
• Corporate Website: [●]

Where applicable, the contact details of the Data Protection Officer (DPO) shall be published in this Policy.

Article 3. Scope of application

This Policy shall apply to all processing of personal data carried out by the Controller through:

• the corporate website;
• the Progressive Web App (PWA);
• private user dashboards;
• professional dashboards;
• SaaS services;
• White-Label solutions;
• proprietary APIs;
• virtual assistants;
• Concierge AI;
• electronic forms;
• contracting processes;
• registration processes;
• support services;
• commercial communications;
• booking systems;
• integrations with third parties;
• any other technological service developed by Mallorca AI Travel Engine®.

Article 4. Definitions

For the purposes of this Policy, in addition to the definitions contained in the Terms & Conditions of Use, the following shall be understood:

Personal Data: any information relating to an identified or identifiable natural person.

Data Subject: natural person whose personal data are processed.

Processing: any operation carried out on personal data, whether automated or manual.

Data Controller: the entity that determines the purposes and means of processing.

Data Processor: the natural or legal person who processes personal data on behalf of the Controller.

Recipient: natural or legal person to whom personal data are disclosed.

Anonymization: procedure whereby data can no longer be reasonably associated with a natural person.

Pseudonymization: processing whereby data cannot be directly attributed to a data subject without using additional information.

Profiling: any automated processing intended to evaluate personal aspects of the data subject.

Concierge AI: intelligent assistance system developed by Mallorca AI Travel Engine® that uses artificial intelligence technologies to generate personalized recommendations.

Article 5. Principles applicable to processing

All processing carried out by Mallorca AI Travel Engine® shall be conducted in accordance with the following principles:

• lawfulness, fairness, and transparency;
• purpose limitation;
• data minimization;
• accuracy;
• storage limitation;
• integrity, confidentiality, and proactive accountability.

The Controller shall adopt the necessary technical and organizational measures to demonstrate effective compliance with said principles.

Article 6. Categories of data subjects

The processing regulated by this Policy may affect, among others, the following categories of persons:

• website visitors;
• PWA users;
• registered users;
• individual clients;
• professional clients;
• hotels;
• tourist apartments;
• travel agencies;
• collaborating companies;
• activity providers;
• commercial partners;
• job applicants (if any);
• legal representatives of companies;
• contact persons;
• subscribers to commercial communications.

Article 7. Categories of data processed

Depending on the Service used, the Controller may process the following categories of data:

Identifiable data: first name, last name, profile photo, preferred language, nationality where necessary for certain services.

Contact data: email, telephone, postal address, country of residence.

Authentication data: username, encrypted password, authentication tokens, access logs, technical identifiers.

Browsing data: IP address, browser, device, operating system, session identifiers, pages visited, browsing time, usage events.

Geolocation data: approximate location, precise location (when authorized by the User), location history strictly necessary for the provision of the corresponding service.

Usage data: searches performed, categories consulted, experiences viewed, favorites, declared preferences, interaction history with the Platform.

Contractual data: contracted services, subscriptions, licenses, bookings, incidents, support history.

Financial data: invoiced amounts, payment status, tax information necessary for invoicing.

Professional data: company, position, hotel establishment, number of rooms, sector of activity, commercial information necessary for the provision of B2B services.

Article 8. Unsolicited data

The Controller expressly requests that Users do not provide special categories of personal data unless strictly necessary for the provision of a specific Service and there is a sufficient legal basis.

In particular, data relating to the following should not be provided voluntarily: health, ideology, religion, sexual orientation, trade union membership, racial or ethnic origin, biometric data, genetic data, or criminal record.

When the User voluntarily provides information belonging to said categories without having been requested, the Controller may proceed to its deletion when appropriate in accordance with applicable law.

Article 9. Accuracy and updating of data

1. The data subject guarantees that the data provided are truthful, accurate, and complete.

2. The data subject undertakes to communicate any modification affecting the information provided.

3. The Controller may periodically request updating of the information when necessary to guarantee the quality of the processing carried out.

Article 10. Minors

1. The Services of Mallorca AI Travel Engine® are not, as a general rule, directed at minors.

2. When a particular Service may be used by minors, the intervention of those holding parental authority or legal representation shall be required in the cases required by current legislation.

3. If the Controller becomes aware that personal data have been collected in breach of the provisions of this article, it shall proceed to adopt the appropriate measures for their deletion or regularization.

TITLE II — PROCESSING ACTIVITIES, PURPOSES, LEGAL BASES, AND RETENTION PERIODS

Article 11. Principle of purpose limitation

1. Personal data shall only be processed for specific, explicit, and legitimate purposes, compatible with the activity carried out by Mallorca AI Travel Engine®.

2. The Controller shall not use personal data for purposes incompatible with those for which they were initially collected, unless there is a new legal basis that allows it or the data subject grants additional consent where legally required.

3. Each processing described in this Title constitutes an independent activity for the purposes of Article 30 of Regulation (EU) 2016/679.

CHAPTER I — Registration and account management

Article 12. Creation of User accounts

Purpose: To manage the User's registration on the Platform, verify their digital identity, allow access to contracted services, and administer their account.

Data categories: name, surname, email, encrypted password, language, country, and internal identifiers.

Legal basis: Article 6.1.b GDPR (performance of a contract or application of pre-contractual measures).

Retention: As long as the account remains active and, subsequently, for the legally required periods.

Article 13. User profile management

Purpose: To allow the User to configure personal preferences, language, tourist interests, favorites, profile settings, and parameters used by the recommendation system.

Legal basis: Article 6.1.b GDPR.

Retention: As long as the User account exists.

CHAPTER II — Provision of digital tourism services

Article 14. Concierge AI management

Purpose: To allow the Concierge AI system to generate personalized recommendations based on the User's context. The following may be used, among others: location, language, preferences, query history, travel dates, weather conditions, declared interests, and service availability.

Legal basis: Article 6.1.b GDPR. Where necessary to use additional data to improve algorithms, the legitimate interest provided for in Article 6.1.f GDPR may apply or specific consent may be requested.

Retention: For as long as necessary to provide the service and improve Platform operation in accordance with internal retention policies.

Article 15. Intelligent recommendation system

Purpose: To automatically determine which content, establishments, experiences, or activities are most relevant to each User. This processing may incorporate: statistical analysis, predictive models, machine learning, scoring systems, and algorithmic classification. The purpose is exclusively to improve the User experience and increase the relevance of the recommendations offered.

Article 16. Geolocation

Purpose: To offer content near the User's location, calculate distances, display nearby experiences, and personalize recommendations.

Data processed: GPS coordinates, approximate location, device accuracy, date and time of query.

Legal basis: Consent of the data subject where necessary and performance of the requested service.

The User may revoke such consent at any time.

CHAPTER III — Bookings

Article 17. Booking requests

Purpose: To manage booking requests directed at establishments, hotels, or collaborating companies.

Data processed: identifiable data, contact details, dates, number of people, comments.

Legal basis: Performance of the contract.

Retention: During the term of the contractual relationship and subsequently for the corresponding legal periods.

Article 18. Marketplace

Purpose: To facilitate the contracting of products and services offered by third parties integrated into the Platform. The necessary data may be communicated exclusively to the corresponding provider for the correct execution of the requested service.

CHAPTER IV — Professional Clients

Article 19. Professional account management

Purpose: To administer accounts belonging to: hotels, apartments, villas, agencies, DMCs, activity companies, and partners.

Data processed: company, tax ID, representative, position, address, tax data, and contact details.

Legal basis: Performance of the contract.

Article 20. SaaS Panel

Purpose: To manage access to the professional software contracted by the Client. Among other processing, the following may be carried out: authentication, license control, module management, establishment configuration, usage statistics, and technical support.

Article 21. White-Label Panel

When the Client uses White-Label solutions, Mallorca AI may act as data processor in accordance with the corresponding data processing agreement (DPA). The distribution of responsibilities shall be regulated in said specific document.

CHAPTER V — Customer Service

Article 22. Support

Purpose: To resolve technical incidents, commercial queries, assistance requests, and claims. Communications with the User may be retained as long as necessary to prove the correct provision of the service.

Article 23. Support chat

When the User uses messaging systems, online chat, or virtual assistants, conversations may be recorded for the purpose of: resolving incidents, improving service quality, training staff, and analyzing recurring errors.

CHAPTER VI — Billing

Article 24. Financial management

Purpose: To issue invoices, manage collections, control payments, and comply with tax obligations.

Legal basis: Compliance with legal obligations.

Financial data shall be retained for the periods required by tax and commercial regulations.

Article 25. Fraud prevention

Purpose: To detect suspicious transactions, prevent fraudulent access, avoid non-payment, and protect the Platform against abusive uses.

Legal basis: Legitimate interest of the Controller.

CHAPTER VII — Security

Article 26. Technical logs

The Controller shall maintain technical logs necessary to guarantee: availability, security, traceability, incident recovery, internal audits, and regulatory compliance. These logs may contain: IP, date, device, browser, technical identifiers, and actions performed.

Article 27. Security monitoring

The Platform may automatically monitor events related to: access attempts, automated attacks, bots, scraping, misuse of APIs, fraud, and potentially unlawful activities.

Article 28. Video demonstrations and commercial meetings

When the User requests demonstrations, online meetings, or personalized assistance, the data strictly necessary to organize such communications may be processed. In case of recording of sessions, the data subject shall be informed in advance.

TITLE III — RECIPIENTS OF DATA, DATA PROCESSORS, INTERNATIONAL TRANSFERS, AND TECHNOLOGY PROVIDERS

Article 29. General principle of confidentiality

1. Mallorca AI Travel Engine® shall not sell, rent, or transfer personal data to third parties for their own commercial purposes.

2. Personal data shall only be disclosed when: a) there is a legal obligation; b) necessary to perform a contract; c) the data subject has given consent; d) there is a legitimate interest in accordance with the GDPR; e) the communication is essential for the provision of the requested service.

3. All third parties accessing personal data shall respect the obligations provided for in European data protection regulations.

Article 30. Categories of recipients

Depending on the service used, data may be communicated, exclusively when necessary, to the following categories of recipients: hotels, tourist apartments, villas, activity companies, restaurants, transport companies, nautical companies, leisure companies, excursion providers, travel agencies, DMCs, commercial partners, technology providers, cloud providers, artificial intelligence providers, financial entities, public administrations, judicial authorities, police and security forces, legal advisors, tax advisors, auditors, and insurance companies where appropriate.

Article 31. Technology providers

For the proper functioning of the Platform, various specialized technology providers may intervene. Among others, services may be provided related to: cloud hosting, storage, backups, email sending, authentication, CDN, maps, geolocation, weather, analytics, video conferencing, artificial intelligence, monitoring, support, and payment systems. All of them shall act in accordance with contracts incorporating the guarantees required by Article 28 of the GDPR when they have the status of Data Processors.

Article 32. Data Processors

1. Mallorca AI shall only contract Data Processors that offer sufficient guarantees to apply appropriate technical and organizational measures.

2. All Processors shall contractually assume, at least, the following obligations: a) process data only in accordance with documented instructions; b) guarantee confidentiality; c) implement security measures; d) cooperate in the exercise of rights; e) delete or return data once the service has ended; f) allow audits where appropriate.

Article 33. SaaS Clients

When Mallorca AI provides SaaS services to hotels, hotel chains, tourist apartments, or collaborating companies, it may act: a) as Data Controller; b) as Data Processor; c) as Joint Controller. The specific distribution of responsibilities shall depend on the contracted service and shall be regulated in the corresponding contract and, where applicable, in the Data Processing Agreement.

Article 34. White-Label

White-Label solutions may involve processing carried out on behalf of the Professional Client. In such cases: Mallorca AI shall act in accordance with the Client's instructions, the Client shall determine the purposes of processing, and both parties shall sign the corresponding DPA where legally required.

Article 35. Communications arising from bookings

When the User requests a booking or contracts a service offered by a Partner, Mallorca AI shall communicate exclusively the data essential for the provider to correctly execute the requested service. Unnecessary data shall not be communicated.

Article 36. Communications arising from the Marketplace

The operation of the Marketplace requires that certain providers receive the necessary information to: respond to requests, confirm bookings, issue quotes, contact the User, and provide the contracted service. Each provider shall be responsible for the subsequent processing of the data they receive in accordance with their own Privacy Policy.

Article 37. Communications due to legal obligation

The Controller may communicate personal data when there is a legal obligation arising from, among others: judicial proceedings, administrative requirements, criminal investigations, tax obligations, anti-money laundering prevention where applicable, and compliance with court rulings.

Article 38. International transfers

Certain technology providers used by Mallorca AI may be established outside the European Economic Area. When this occurs, international data transfers shall only be carried out if one of the guarantees provided for in Articles 44 et seq. of the GDPR applies.

Article 39. Applicable guarantees

International transfers may be based, among others, on: a) adequacy decisions adopted by the European Commission; b) Standard Contractual Clauses (SCC); c) Binding Corporate Rules (BCR); d) recognized certification mechanisms; e) any other guarantees admitted by the GDPR.

Article 40. Artificial Intelligence services

Mallorca AI may integrate artificial intelligence solutions developed by third parties to improve the provision of its services. The use of such systems shall be subject to the principles of: minimization, proportionality, security, confidentiality, and purpose limitation. When personal data are processed by AI providers, Mallorca AI shall adopt the necessary contractual and organizational measures to guarantee a level of protection equivalent to that required by European regulations.

Article 41. Payment gateways

Financial transactions may be managed by specialized payment service providers. Mallorca AI shall not store complete bank card data unless strictly necessary and always in accordance with applicable international security standards (such as PCI DSS). Each provider shall act in accordance with its own Privacy Policy and applicable financial regulations.

Article 42. Social networks

When the User interacts with official Mallorca AI profiles on social networks, the processing of data shall be subject both to this Policy and to the conditions established by the corresponding social platform. Mallorca AI shall not be liable for processing carried out directly by said platforms.

Article 43. Corporate control changes

In the event of a merger, demerger, acquisition, transfer of assets, or any equivalent corporate transaction, personal data may be communicated to the acquirer or successor entity when necessary to guarantee the continuity of services, in all cases respecting data protection regulations and maintaining the same purposes for which they were collected.

Article 44. Duty of secrecy

All Mallorca AI personnel, as well as providers who access personal information, shall be subject to the permanent duty of confidentiality with respect to the data processed. Said obligation shall survive even after the contractual relationship that motivated access to the data has ended.

TITLE IV — RIGHTS OF DATA SUBJECTS, EXERCISE OF RIGHTS, DATA RETENTION, AND SECURITY MEASURES

Article 45. Rights of data subjects

1. Any person whose personal data are processed by Mallorca AI Travel Engine® may exercise, in accordance with applicable law, the following rights:

• Right of access.
• Right of rectification.
• Right of erasure ("right to be forgotten").
• Right to restriction of processing.
• Right to object.
• Right to data portability.
• Right to withdraw consent when processing is based on it.
• Right not to be subject to decisions based solely on automated processing, including profiling, when they produce legal effects or significantly affect the data subject, except in cases permitted by applicable law.

2. The exercise of any of these rights shall be free of charge, without prejudice to the fact that legally provided limitations may apply when requests are manifestly unfounded or excessive.

Article 46. Exercise of rights

1. Data subjects may exercise their rights by communication addressed to the Data Controller through the channels enabled for this purpose.

2. The request must allow reasonable identification of the applicant and specify the right they wish to exercise.

3. Where there are reasonable doubts about the applicant's identity, the Controller may require additional information strictly necessary to verify it.

4. Mallorca AI shall respond within the periods established by the GDPR, and may extend such periods when the complexity or number of requests justifies it, informing the data subject of such extension.

Article 47. Withdrawal of consent

1. When processing is based on the data subject's consent, they may withdraw it at any time.

2. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to withdrawal.

3. Revocation may be made through the mechanisms made available to the data subject or by contacting the Data Controller.

Article 48. Right to lodge a complaint

1. If the data subject considers that the processing of their data does not comply with current regulations, they may lodge a complaint with the competent supervisory authority.

2. Prior to this, Mallorca AI recommends that the data subject contact the Data Controller to attempt to resolve the incident in an agile and friendly manner.

3. The foregoing shall not in any way limit the data subject's right to go directly to the competent authority.

Article 49. Data retention

1. Personal data shall be retained only for as long as necessary to fulfill the purpose for which they were collected.

2. Once said purpose has been fulfilled, they may be kept blocked when necessary to address legal, contractual, tax, administrative, or judicial liabilities.

3. Once the applicable legal periods have elapsed, the data shall be securely deleted or anonymized.

Article 50. General retention criteria

For guidance purposes, Mallorca AI shall apply retention criteria based on: a) duration of the contractual relationship; b) tax and commercial obligations; c) limitation periods for legal actions; d) obligations arising from data protection regulations; e) security needs and service continuity; f) defense against possible claims.

Article 51. Deletion and anonymization

1. When data are no longer necessary, Mallorca AI shall proceed to their deletion or anonymization, as most appropriate.

2. Anonymization shall be carried out using reasonable procedures that prevent the direct or indirect identification of the affected persons.

3. Properly anonymized data shall cease to be considered personal data for GDPR purposes.

Article 52. Security measures

1. Mallorca AI shall implement appropriate technical and organizational measures to guarantee a level of security appropriate to the risk.

2. Such measures may include, among others: a) access control; b) robust authentication; c) encryption of communications; d) encryption of sensitive information where appropriate; e) activity logs; f) backups; g) system monitoring; h) network segmentation; i) vulnerability management; j) business continuity plans; k) staff training; l) incident management.

3. The measures adopted shall be periodically reviewed to adapt them to technological evolution and the existing level of risk.

Article 53. Security breaches

1. Mallorca AI shall have internal procedures to detect, analyze, manage, and document security incidents that may affect personal data.

2. When a security breach poses a risk to the rights and freedoms of natural persons, it shall act in accordance with Articles 33 and 34 of the GDPR, notifying, where appropriate, the competent supervisory authority and the affected data subjects.

Article 54. Updating of the Privacy Policy

1. Mallorca AI may modify this Policy to adapt to legislative, technological, organizational, or functional changes.

2. When modifications significantly affect the rights of data subjects or the conditions of processing, the information measures required by applicable law shall be adopted.

3. The current version shall always be the one published on the official channels of Mallorca AI.

Article 55. Integration with the rest of the legal framework

This Privacy Policy forms part of the documentary framework of Mallorca AI Travel Engine® and shall be interpreted jointly with: the Legal Notice, the Terms & Conditions of Use, the General Contracting Conditions, the Cookie Policy, the Artificial Intelligence Policy, the API & Integrations Policy, the specific contracts signed with Professional Clients, Partners, or Providers, and any other applicable policy or contractual document.

ANNEX I — CATEGORIES OF TECHNOLOGICAL SERVICES AND PROVIDERS THAT MAY INTERVENE IN THE PROVISION OF MALLORCA AI TRAVEL ENGINE® SERVICES

Document associated with the Privacy Policy

Version 1.0

1. Purpose

This Annex identifies the categories of technological services that may intervene in the operation of Mallorca AI Travel Engine® and that, when necessary for the provision of Services, may have limited access to personal data as independent Controllers, Data Processors, or Sub-processors, as applicable.

The purpose of this document is to provide transparency regarding the technological architecture of the Platform without necessarily identifying specific providers, whose replacement or incorporation may occur during the evolution of the Service. The inclusion of a category does not imply that all the services described are simultaneously active.

2. Applicable principles

All providers selected by Mallorca AI must offer sufficient guarantees in terms of: compliance with Regulation (EU) 2016/679 (GDPR), information security, confidentiality, technological resilience, service availability, business continuity, protection against security incidents, and cooperation in audits where applicable.

3. Categories of technological services

3.1 Technological infrastructure

Services intended for hosting and general operation of the Platform. They may include, among others: cloud infrastructure, servers, storage, networks, databases, load balancers, virtualization, and availability services.

3.2 Execution platforms

Services intended to run applications, automated processes, containers, serverless functions, or distributed architectures.

3.3 Storage and backups

Services intended to guarantee: data storage, disaster recovery, business continuity, information restoration, and backup retention.

3.4 Electronic communications

Services intended for: sending emails, authentication, account verification, credential recovery, transactional communications, and system notifications.

3.5 Authentication and identity management systems

Services intended for: user identification, multi-factor authentication, session control, permission management, and access recovery.

3.6 Intelligent systems and predictive models

Technological services intended to support the operation of Mallorca AI's Predictive Tourism Intelligence Engine. They may intervene in: contextual analysis, predictive models, classification, recommendation, machine learning, natural language processing, process automation, conversational assistants, and statistical analysis.

3.7 Cartographic and geospatial services

Services intended to provide: maps, geocoding, route calculation, distance calculation, geographical representation, and territorial information.

3.8 Geolocation services

Services intended to determine, when the User authorizes it: approximate location, precise location, proximity between points, and geographical positioning.

3.9 Weather and environmental information

Services intended to incorporate information related to: weather forecast, wind, temperature, sea state, solar radiation, weather alerts, and environmental variables.

3.10 Integrations with tourism services

Services intended to exchange information with: hotels, tourist apartments, villas, activity companies, tour operators, booking systems, availability platforms, experience providers, and mobility services.

3.11 Programming Interfaces (API)

Services intended to allow secure information exchange between Mallorca AI and authorized external systems. The specific conditions for API use shall be developed in the corresponding API & Integrations Policy.

3.12 Payment services

Services intended for: payment processing, subscriptions, refunds, reconciliations, and fraud prevention. Mallorca AI shall not store complete payment method data unless strictly necessary and in accordance with applicable security standards.

3.13 Billing services

Services intended for: invoice issuance, tax management, accounting obligations, and fiscal compliance.

3.14 Customer service services

Services intended for: technical support, incident management, commercial assistance, request tracking, and communications with Users and Clients.

3.15 Analytics and Platform improvement

Services intended for statistical analysis of Platform operation to: improve user experience, detect incidents, optimize processes, measure performance, and evaluate service quality. Whenever possible, aggregated, pseudonymized, or anonymized data shall be used.

3.16 Monitoring and observability

Services intended to supervise: availability, performance, response times, resource utilization, and operational stability.

3.17 Cybersecurity

Services intended to protect the Platform against: unauthorized access, malware, distributed attacks, intrusions, vulnerabilities, fraud, malicious automations, and unauthorized scraping.

3.18 Event logging and auditing

Services intended to retain technical logs related to: authentication, system activity, security events, audits, traceability, and regulatory compliance.

3.19 Mobile communications

Services intended for sending: SMS, verification codes, push notifications, security alerts, and operational communications.

3.20 Internal development tools

Services used exclusively for: development, testing, continuous integration, deployment, version control, and evolutionary maintenance. These environments shall be subject to security measures equivalent to those applicable to production systems when they may contain personal data.

3.21 Specialized professional services

May access strictly necessary information for the performance of their functions: law firms, auditors, tax advisors, technology consultants, cybersecurity companies, experts, and certification entities. Access shall be limited by confidentiality obligations and, where appropriate, by corresponding processing contracts.

4. International transfers

When any of the services described in this Annex involve international transfers of personal data, Mallorca AI shall adopt the guarantees provided for in Chapter V of Regulation (EU) 2016/679 and other applicable regulations.

5. Updating of the Annex

Mallorca AI may incorporate, modify, or replace categories of technological services to adapt to the technical evolution of the Platform, provided that such modifications do not alter the essential purposes of processing or reduce the level of protection recognized to data subjects.

6. Interpretation

This Annex shall be interpreted jointly with: the Privacy Policy, the Policy on Intelligent Systems, Predictive Models, and Automation, the API & Integrations Policy, the Information Security Policy, the Terms & Conditions of Use, and the General Contracting Conditions.

ANNEX II — POLICY ON INTELLIGENT SYSTEMS, PREDICTIVE MODELS, AND AUTOMATION

Document associated with the Privacy Policy of Mallorca AI Travel Engine®

Version: 1.0

1. Purpose

This Annex describes the functional architecture of the intelligent systems used by Mallorca AI Travel Engine®, the purposes for which they are used, the general categories of data that may intervene in their operation, and the guarantees adopted to ensure responsible, transparent, and European-compliant use.

The purpose of this document is to provide Users, Professional Clients, Partners, and Authorities with a clear description of the general operation of the Platform's intelligent systems, without revealing confidential information, trade secrets, proprietary algorithms, or elements whose disclosure could compromise the security or competitive advantage of Mallorca AI.

2. General principles

The intelligent systems developed or used by Mallorca AI shall be governed by the following principles: legality, transparency, proportionality, data minimization, human intervention where necessary, security, Privacy by Design, Privacy by Default, technical robustness, continuous supervision, and permanent improvement.

3. Functional architecture

The Platform may integrate one or more of the following intelligent systems.

3.1 Predictive Tourism Intelligence Engine

This constitutes the technological core of Mallorca AI. Its purpose is to analyze contextual information to determine which recommendations, services, or experiences have the highest probability of being relevant to each User. It may consider, among other factors: geographic location, date, time, weather, sea state, wind, season, estimated occupancy, distance, declared preferences, interaction history, service availability, establishment category, travel profile, business rules, statistical variables, and publicly available information. The system generates scores, priorities, classifications, and personalized recommendations.

3.2 Recommendation Engine

This system determines the order of presentation of activities, establishments, experiences, restaurants, routes, beaches, events, or any other content shown to the User. Recommendations do not constitute mandatory advertising nor imply a guarantee of the quality or availability of the services offered.

3.3 Contextual Engine

This system adapts Platform operation taking into account the User's operational context. Among other elements, it may analyze: location, language, device, time, weather conditions, proximity, service status, and provider availability.

3.4 Personalization System

Its purpose is to adapt the User's experience through dynamic configuration of content, functionalities, and suggestions in accordance with their preferences, previous behavior, and Platform configuration.

3.5 Classification System

Allows sorting results using statistical models, business rules, and prioritization algorithms. Classification may take into account factors such as: relevance, proximity, rating, availability, demand, service quality, User preferences, and predefined commercial parameters.

3.6 Optimization System

Analyzes Platform performance to improve: response times, resource utilization, recommendation quality, stability, and operational efficiency.

3.7 Pattern Detection System

Allows identification of aggregated behaviors, usage trends, seasonality, and statistical patterns that contribute to improving the overall operation of the Platform. Whenever possible, this processing shall be carried out using anonymized or aggregated information.

3.8 Learning System

Mallorca AI may use machine learning techniques to progressively improve the performance of certain predictive models. Learning may be based, among others, on: acceptance of recommendations, bookings made, cancellations, ratings, use of functionalities, and system performance. The objective shall be to increase the accuracy and usefulness of future recommendations.

3.9 Operational Automations

The Platform may execute automated processes intended to: generate alerts, send notifications, detect incidents, synchronize information, update availability, prioritize tasks, and optimize internal processes.

3.10 Conversational Systems

Mallorca AI may incorporate conversational assistants based on artificial intelligence to answer queries, provide tourist information, or assist the User in using the Platform. The responses generated shall be merely informative and shall not constitute professional advice nor replace the User's decision. Conversational systems shall have an auxiliary role and shall not constitute the main element of the Predictive Tourism Intelligence Engine.

4. General categories of data used

The intelligent systems may use, depending on the corresponding service: identifiable data, language, country, geographic location, searches performed, declared preferences, interaction history, bookings, service availability, weather conditions, cartographic data, temporal variables, technical device data, statistical information, anonymized information, and aggregated information.

Special categories of personal data shall not be used for the ordinary operation of the Predictive Tourism Intelligence Engine, unless a specific functionality requires it and there is a sufficient legal basis.

5. Human oversight

Although certain processes may be executed automatically, Mallorca AI shall maintain human oversight mechanisms to: review relevant incidents, correct detected errors, validate substantial modifications to the system, and address claims related to the operation of intelligent systems.

6. Transparency

Mallorca AI shall endeavor to clearly inform when a functionality is significantly based on automated processes or intelligent systems, especially when this may have a relevant influence on the User's experience or the provision of a service.

7. System limitations

The intelligent systems used by Mallorca AI generate recommendations and predictions from statistical models, business rules, and contextual analysis. Consequently: recommendations represent probability estimates and not guarantees of outcome; actual conditions may vary due to external factors; models may contain margins of error inherent to any predictive system; recommendations should be interpreted as an aid to decision-making and not as binding decisions.

8. Technological evolution

Mallorca AI may incorporate new models, algorithms, predictive engines, machine learning techniques, or intelligent systems when they contribute to improving the quality, security, efficiency, or usefulness of the Platform. Technological evolution shall not alter the essential purposes described in this Policy without the corresponding documentary update where legally required.

9. Protection of knowledge and intellectual property

This Policy is informative in nature and does not imply the disclosure of algorithms, mathematical models, decision rules, weights, architectures, training sources, optimization methodologies, or any other elements that constitute trade secrets or intellectual property of Mallorca AI Travel Engine®. The description contained in this document responds to criteria of transparency and regulatory compliance, without prejudice to the legal protection of the Platform's know-how.

Cookie Policy

Last updated: July 12, 2026

COOKIE POLICY, LOCAL STORAGE TECHNOLOGIES, AND SIMILAR TECHNOLOGIES

Mallorca AI Travel Engine®

Version 1.0
Effective date: [●]
Last updated: [●]

TITLE I — GENERAL PROVISIONS

Article 1. Purpose

This Policy aims to inform Users about the use of cookies, local storage technologies, and other similar mechanisms used by Mallorca AI Travel Engine® during the use of the Platform.

This Policy complements the Privacy Policy and the Terms & Conditions of Use, and should be interpreted jointly with said documents.

Article 2. Scope of application

This Policy shall apply to: corporate website, Progressive Web App (PWA), private dashboards, SaaS dashboards, White-Label solutions, APIs when they incorporate web interfaces, professional portals, and any other digital environment developed by Mallorca AI.

Article 3. Purpose

The technologies regulated in this Policy may be used to: enable the technical operation of the Platform, maintain the session open, remember User preferences, guarantee security, improve performance, analyze aggregate use of Services, personalize certain functionalities, facilitate the installation and operation of the PWA, improve browsing experience, prevent fraudulent access, and optimize response times.

Article 4. Definitions

For the purposes of this Policy, the following shall be understood:

Cookie: File or identifier stored on the User's device that allows recognition of certain characteristics of browsing.

Local storage technologies: Any mechanism that allows information to be stored on the User's device other than traditional cookies. Among others: Local Storage, Session Storage, IndexedDB, Cache Storage, and PWA's own storage.

Similar technologies: Any mechanism that allows access to or storage of information on the User's device in accordance with current legislation.

Article 5. Legal basis

The use of cookies and similar technologies shall be carried out in accordance with: Regulation (EU) 2016/679 (GDPR), Organic Law 3/2018, Law 34/2002 on Information Society Services (LSSI-CE), Guidelines of the European Data Protection Board (EDPB), Guide on the use of cookies published by the Spanish Data Protection Agency (AEPD), and any other applicable regulations.

Article 6. Consent

1. Where legally required, Mallorca AI shall request the User's prior consent before installing cookies or equivalent technologies.

2. Consent must be: free, specific, informed, and unambiguous.

3. The User may modify or withdraw their consent at any time through the tools enabled by the Platform.

Article 7. Technologies exempt from consent

Technologies strictly necessary for the following shall not require prior consent: authentication, security, load balancing, session continuity, essential technical preferences, PWA operation, and provision of the expressly requested service.

Article 8. Transparency

Mallorca AI shall endeavor to clearly inform: what technologies it uses, what they are for, who installs them, how long they remain active, and how they can be managed.

Article 9. Relationship with the Privacy Policy

When the use of a cookie or equivalent technology involves the processing of personal data, Mallorca AI's Privacy Policy shall also apply.

Article 10. Updating of the Policy

This Policy may be modified to adapt to: technological changes, regulatory changes, incorporation of new functionalities, evolution of the Platform, and new interpretations by competent authorities. Relevant modifications shall be communicated when legally required.

TITLE II — CATEGORIES OF COOKIES, LOCAL STORAGE TECHNOLOGIES, AND TECHNICAL MECHANISMS USED

Article 11. General principle

Mallorca AI may use different storage or information access technologies on the User's device. Not all of them constitute cookies in the strict sense, although some may be subject to the same legal regime when they allow access to or storage of information on the User's device.

CHAPTER I — Technical Cookies

Article 12. Strictly necessary cookies

These cookies enable the basic functioning of the Platform. Among other functions, they may be used to: log in, maintain authentication, balance load between servers, guarantee security, protect forms, prevent attacks, remember the consent granted by the User, and manage essential technical preferences. Deactivation of these cookies may prevent the normal operation of certain Services.

Article 13. Session cookies

Allow temporary identification of the User while browsing the Platform. They generally disappear when the browser is closed or the session ends.

Article 14. Persistent cookies

Allow certain preferences to be retained for a specific period. Their duration shall depend on the specific purpose for which they have been installed.

CHAPTER II — Authentication technologies

Article 15. Session management

Mallorca AI may use mechanisms intended to maintain User authentication during use of the Platform. Such mechanisms may be based on: session identifiers, secure tokens, encrypted credentials, and temporary identifiers. Their purpose shall be exclusively to maintain the session open and guarantee access security.

Article 16. Enhanced authentication

Where necessary, additional mechanisms may be used to verify the User's identity. Among others: temporary codes, multi-factor authentication, email verifications, and verifications through authorized devices.

CHAPTER III — Local storage technologies

Article 17. Local Storage

The Platform may use Local Storage to store information necessary to improve the User experience. It may be used to retain: language, preferences, interface configuration, navigation parameters, and information necessary for PWA operation.

Article 18. Session Storage

It may be used to store temporary information associated exclusively with the User's active session. The information disappears once the session ends.

Article 19. IndexedDB

The Progressive Web App may use IndexedDB to store information necessary for: offline operation, subsequent synchronization, temporary information storage, and performance improvement. The use of IndexedDB shall respond exclusively to technical purposes related to the operation of the Platform.

Article 20. Cache Storage

Mallorca AI may use caching mechanisms to: speed up loading, reduce data consumption, improve availability, and allow certain offline functionalities. The stored information shall be managed automatically by the Platform.

CHAPTER IV — Specific Progressive Web App technologies

Article 21. Service Workers

The Progressive Web App may install Service Workers to: allow partial offline operation, manage cached resources, optimize response times, synchronize information, manage notifications, and improve service stability. Service Workers shall not have the purpose of commercial tracking of the User.

Article 22. Web App Manifest

PWA installation may require the use of the Web App Manifest. This mechanism may allow, among others: installing the application, configuring icons, defining colors, establishing opening behavior, and improving the usage experience.

Article 23. Storage for offline operation

Mallorca AI may temporarily store certain resources on the User's device to guarantee partial availability of the Platform when there is no Internet connection. The stored information shall respond exclusively to technical needs related to service continuity.

Article 24. Background synchronization

When the device and browser allow, the Platform may use automatic synchronization mechanisms to update information necessary for the correct operation of the service.

CHAPTER V — Personalization

Article 25. User preferences

Preferences related to the following may be stored: language, currency, visual configuration, filters, interests, favorite categories, accessibility, and navigation options. Their purpose shall be to improve the user experience of the Platform.

Article 26. Customized configuration

The Platform may remember certain configurations chosen by the User in order to avoid having to reconfigure them on each access.

CHAPTER VI — Security

Article 27. Fraud protection

Technical mechanisms may be used to detect: automated access, intrusion attempts, fraud, scraping, mass account creation, improper use of APIs, and distributed attacks. These technologies shall have exclusively security purposes.

Article 28. Platform integrity

Mallorca AI may use technical identifiers intended to verify the integrity of Platform operation and prevent unauthorized alterations.

CHAPTER VII — Analytics

Article 29. Technical analytics

The Platform may use measurement tools intended to understand: performance, response times, use of functionalities, errors, stability, and technical incidents. Whenever possible, aggregated or pseudonymized data shall be used.

Article 30. Statistics

Statistical data obtained through measurement technologies may be used to: improve the Platform, optimize processes, develop new functionalities, and increase service quality. These processing activities shall not have the purpose of individually identifying the User unless strictly necessary to resolve technical incidents or guarantee security.

TITLE III — CONSENT MANAGEMENT, CONFIGURATION, RETENTION, AND FINAL PROVISIONS

Article 31. Preferences Panel

1. Mallorca AI shall make available to the User a Cookie and Storage Technologies Configuration Panel from which they can manage, in a granular manner, the categories of technologies whose use requires consent.

2. Said panel shall allow, where applicable: accept all categories, reject all those that are not strictly necessary, individually select the authorized categories, modify previously granted preferences, and withdraw consent at any time.

3. Modification of preferences shall not affect the lawfulness of processing carried out prior to modification.

Article 32. Withdrawal of consent

1. The User may withdraw previously granted consent at any time.

2. Withdrawal of consent shall have effect for the future and shall not affect processing already carried out lawfully.

3. Mallorca AI shall provide simple, accessible, and permanent mechanisms to modify said preferences.

Article 33. Browser configuration

In addition to the Preferences Panel offered by Mallorca AI, the User may configure their browser or device to allow, block, or delete cookies and other technologies when technically possible. It should be noted that certain essential functionalities of the Platform may cease to be available if technologies strictly necessary for its operation are blocked.

Article 34. Progressive Web App (PWA) configuration

The User may manage, from their compatible device or browser, certain permissions related to the Progressive Web App, including, where applicable: access to location, push notifications, local storage, background synchronization, browser permissions, and offline operation. Deactivation of these permissions may limit or prevent the operation of certain Platform functionalities.

Article 35. Deletion of stored information

The User may delete, when technically possible: cookies, Local Storage data, Session Storage, IndexedDB, Cache Storage, browsing data, and information stored by the Progressive Web App. Deletion of said elements may imply loss of customized configurations, session closure, or the need to reconfigure certain preferences.

Article 36. Retention of identifiers

The technical identifiers used by Mallorca AI shall remain active only for as long as strictly necessary to fulfill the purpose for which they were created. When they are no longer necessary, they shall be deleted, replaced, or anonymized, as appropriate.

Article 37. Retention of preferences

Preferences relating to consent may be retained for as long as necessary to prove compliance with the Data Controller's legal obligations.

Article 38. Third-party cookies and technologies

When Mallorca AI uses services provided by third parties that install cookies or equivalent technologies, said providers may process information in accordance with their own privacy policies. Mallorca AI shall select, whenever possible, providers that offer adequate guarantees in terms of data protection and information security.

Article 39. Modifications of the Policy

Mallorca AI may update this Policy to adapt to: legislative changes, technological changes, new Platform functionalities, incorporation or replacement of technology providers, organizational changes, and criteria of competent authorities. When modifications significantly affect the processing of information stored on the User's device, the information measures and, where applicable, consent acquisition measures required by law shall be adopted.

Article 40. Relationship with the rest of the documentary framework

This Policy shall be interpreted jointly with: the Legal Notice, the Terms & Conditions of Use, the General Contracting Conditions, the Privacy Policy, the Policy on Intelligent Systems, Predictive Models, and Automation, the API & Integrations Policy, the Information Security Policy, and any other legal documents regulating the use of Mallorca AI Travel Engine®.

Article 41. Applicable law

This Policy shall be governed by Spanish law and applicable European Union law on digital services, privacy, and data protection.

Article 42. Entry into force

This Policy shall enter into force on the date indicated at the beginning of the document and shall remain in force until replaced by a new version duly published.

ANNEX I — INVENTORY OF COOKIES, LOCAL STORAGE TECHNOLOGIES, AND SIMILAR MECHANISMS

Article 43. Purpose of the Inventory

This Inventory identifies the categories of cookies and technologies used by Mallorca AI. In order to facilitate the technological evolution of the Platform, the Inventory may be updated without the need to modify the main text of this Policy, provided that such updates do not alter the essential purposes of processing or reduce the rights of Users.

Article 44. Minimum information in the Inventory

For each technology used, at least the following information shall be documented: identifier or technical name, category, purpose, provider (proprietary or third-party), duration or retention period, technical, functional, analytical, or equivalent nature, need for consent or not, and possibility of configuration by the User.

Article 45. Categories included in the Inventory

The Inventory may include, among others, the following categories: technical cookies, authentication cookies, preference cookies, analytical cookies, Local Storage, Session Storage, IndexedDB, Cache Storage, Service Workers, Web App Manifest, PWA installation identifiers, authentication tokens, synchronization mechanisms, storage for offline operation, push notifications, security identifiers, consent records, and other equivalent technologies that may be incorporated in the future.

Artificial Intelligence & Automation Policy

Last updated: July 12, 2026

ARTIFICIAL INTELLIGENCE & AUTOMATION POLICY

Mallorca AI Travel Engine®

Version 1.0
Effective date: [●]
Last updated: [●]

PREAMBLE

Mallorca AI Travel Engine® integrates intelligent systems designed to improve User experience, optimize the provision of tourist services, and facilitate decision-making through contextual analysis of information.

This Policy establishes the principles governing the design, development, implementation, use, supervision, and evolution of said systems, ensuring their use in accordance with European Union law, the General Data Protection Regulation (GDPR), the European Artificial Intelligence Act (AI Act), and other applicable regulations.

The intelligent systems used by Mallorca AI have as their main purpose to provide recommendations, classifications, predictions, automations, and decision support. Unless expressly indicated, they do not replace the final decision of the User, Professional Client, or Partners using the Platform.

TITLE I — GENERAL PROVISIONS

Article 1. Purpose

This Policy regulates the principles of use of intelligent systems, predictive models, automations, recommendation engines, and artificial intelligence technologies incorporated in Mallorca AI Travel Engine®. It also establishes the guarantees applicable to Users, Professional Clients, Partners, Providers, and other persons who interact with said systems.

Article 2. Scope of application

This Policy shall apply to all services provided by Mallorca AI that incorporate, in whole or in part: predictive models, recommendation systems, automations, machine learning, advanced statistical analysis, decision engines, intelligent information processing, conversational assistants, and decision support systems.

Article 3. Definitions

For the purposes of this Policy, the following shall be understood:

a) Intelligent System: Set of processes, algorithms, business rules, mathematical models, statistical techniques, machine learning, or equivalent technologies used to assist the operation of the Platform.

b) Predictive Tourism Intelligence Engine: Mallorca AI's proprietary system designed to analyze contextual information to generate recommendations, classifications, scores, predictions, and personalized suggestions related to the tourist experience. The Engine may combine statistical techniques, predictive models, business rules, machine learning, and other equivalent technologies.

c) Automation: Process executed wholly or partially by computer systems without direct human intervention to perform predefined tasks.

d) Recommendation System: System designed to prioritize, order, or suggest content, activities, establishments, experiences, services, or resources based on multiple variables.

e) Predictive Model: Mathematical or computational model used to estimate probabilities, trends, behaviors, or future outcomes from analysis of available information.

f) User: Natural or legal person who uses any of the services offered by Mallorca AI.

g) Professional Client: Hotel, hotel chain, tourist apartment, holiday rental company, travel agency, DMC, tour operator, activity company, public administration, or other entity that uses Mallorca AI's professional or SaaS services.

h) Partner: Natural or legal person who offers products, services, or experiences through the Platform or maintains a commercial relationship with Mallorca AI.

Article 4. Nature of intelligent systems

The intelligent systems used by Mallorca AI constitute decision support tools and are intended to improve User experience and the efficiency of the services provided. Unless expressly stated otherwise, the recommendations, predictions, or classifications generated by said systems do not constitute binding decisions nor replace human judgment.

Article 5. Guiding principles

The design, development, and use of Mallorca AI's intelligent systems shall be inspired, among others, by the following principles: legality, transparency, human oversight, proportionality, Privacy by Design, Security by Design, data minimization, information quality, technical robustness, traceability, reasonable explainability, accountability, and continuous improvement.

Article 6. Purpose of intelligent systems

The intelligent systems may be used, among other purposes, to: generate personalized recommendations, adapt content to the User's context, prioritize results, optimize itineraries, identify relevant opportunities, improve the tourist experience, support activity planning, facilitate Professional Client management, optimize internal processes, detect incidents, prevent fraudulent uses, improve Platform performance, and support commercial and operational decision-making.

Article 7. Exclusions

Mallorca AI's intelligent systems shall not have the purpose of: replacing medical, legal, or financial decisions; issuing professional diagnoses; adopting automated decisions with legal effects on persons where the law requires human intervention; discriminating against persons for reasons prohibited by current legislation; or creating profiles based on special categories of personal data unless expressly permitted by law.

Article 8. Relationship with the AI Act and GDPR

Mallorca AI shall develop and use its intelligent systems in compliance with the principles and obligations established in the European Artificial Intelligence Act (AI Act), the General Data Protection Regulation (GDPR), and other applicable regulations. Where a specific functionality is subject to specific obligations arising from the AI Act, Mallorca AI shall adopt the technical, organizational, and documentary measures required according to the risk level assigned to the corresponding system.

Article 9. Evolutionary nature

The intelligent systems used by Mallorca AI may evolve, incorporate new models, improve existing algorithms, or integrate new technologies, provided that such modifications respect the principles established in this Policy and in the rest of the Platform's documentary framework.

TITLE II — INTELLIGENT SYSTEMS, PREDICTIVE ENGINE, AND AUTOMATION

Article 10. General architecture

Mallorca AI Travel Engine® uses a technological architecture based on the combination of business rules, predictive models, statistical analysis, recommendation engines, process automation, and other artificial intelligence techniques. The Platform may integrate different specialized systems that operate in a coordinated manner to provide recommendations, optimize processes, and improve the experience of Users, Professional Clients, and Partners. The technical composition of said systems may evolve over time without altering the essential purposes described in this Policy.

Article 11. Predictive Tourism Intelligence Engine

The Predictive Tourism Intelligence Engine constitutes the functional core of the Platform. Its purpose is to analyze contextual information to estimate which content, services, establishments, activities, or experiences may be most relevant to each User at a given time. The Engine may generate: personalized recommendations, priorities, scores, classifications, suggestions, alerts, opportunity estimates, and operational automations. The recommendations shall be probabilistic in nature and shall not guarantee a determined outcome.

Article 12. Context variables

The Predictive Engine may consider, among others, the following categories of information: geographic location authorized by the User, date and time, weather conditions, sea state, wind forecast, tourist season, service availability, distance from tourist resources, declared preferences, Platform usage history, language, travel profile, type of accommodation, availability communicated by Partners, public information obtained from legitimate sources, and internal indicators generated by the Platform. The specific use of each variable shall depend on the functionality used and the permissions granted by the User.

Article 13. Recommendation Engine

The Platform may order, classify, or prioritize content using recommendation systems. Recommendations may be based, among other factors, on: estimated relevance, proximity, User context, availability, service quality, known preferences, usage patterns, predictive variables, and predefined commercial rules. The position of an establishment, experience, or service within the Platform shall not necessarily imply an objective assessment of its quality nor constitute hidden advertising. Where a recommendation responds to a commercial promotion or sponsored positioning, such circumstance shall be clearly identified in accordance with applicable law.

Article 14. Predictive models

Mallorca AI may use predictive models to estimate probabilities related to: User's potential interest, conversion probability, estimated occupancy, forecast demand, aggregate behavior, temporal evolution, seasonal patterns, resource optimization, and tourism planning. Predictions constitute statistical estimates and may differ from reality due to uncontrollable external factors.

Article 15. Scoring systems

The Platform may generate internal scores intended to facilitate the prioritization of content, resources, or processes. These systems may be used to: order recommendations, optimize search results, improve resource allocation, prioritize incidents, and facilitate operational decisions. The scores generated by the system shall be instrumental in nature and shall not, by themselves, constitute a legal, economic, or professional assessment of the affected persons or entities.

Article 16. Process automation

Mallorca AI may automate certain processes to improve operational efficiency. Among others, the following may be automated: sending communications, generating alerts, updating information, data synchronization, incident detection, task prioritization, request classification, resource allocation, and technical checks. Automation shall not prevent human intervention where necessary or legally required.

Article 17. Conversational systems

The Platform may incorporate conversational assistants to facilitate interaction with Users. These systems may provide: tourist information, help on Platform operation, explanation of services, assistance in booking processes, and answers to frequently asked questions. Where generative models intervene, their responses shall be advisory and may contain inaccuracies inherent to the nature of this technology.

Article 18. Machine learning

Mallorca AI may use machine learning techniques to progressively improve the performance of certain systems. Learning may rely, among other elements, on: acceptance of recommendations, bookings made, cancellations, use of functionalities, aggregate behavior patterns, and observed performance of models. Whenever possible, such processes shall be carried out using aggregated, pseudonymized, or anonymized data.

Article 19. Data used by intelligent systems

The intelligent systems shall only use data that is adequate, relevant, and limited to the purposes pursued. Mallorca AI shall endeavor to avoid processing special categories of personal data for the ordinary operation of the Predictive Tourism Intelligence Engine, unless there is a sufficient legal basis and it is strictly necessary for a specific functionality.

Article 20. Human intervention

Mallorca AI shall maintain human oversight mechanisms over the intelligent systems used on the Platform. Human intervention may occur, among other cases, to: review incidents, correct detected errors, resolve claims, validate relevant modifications to models, and supervise the general operation of the Predictive Engine.

Article 21. Limitations of intelligent systems

The intelligent systems used by Mallorca AI constitute decision support tools. Consequently: recommendations represent probability estimates, results may vary depending on context, the information used may change over time, external factors may alter the predicted outcome, and no predictive model guarantees exact or infallible results. The User and Professional Clients should assess recommendations within the specific context in which they are offered.

Article 22. Protection of the Predictive Engine

The architecture of the Predictive Tourism Intelligence Engine, its algorithms, mathematical models, decision rules, weights, methodologies, training processes, internal parameters, indicators, scores, and any other technical element that constitutes Mallorca AI's own knowledge shall be considered confidential information and trade secrets. The publication of this Policy shall not imply waiver of the intellectual, industrial, or know-how protection rights that correspond to Mallorca AI over said elements.

TITLE III — GOVERNANCE OF INTELLIGENT SYSTEMS, DATA QUALITY, HUMAN OVERSIGHT, AND RISK MANAGEMENT

Article 23. Governance model

Mallorca AI shall establish an internal governance model to ensure that the design, development, implementation, maintenance, and evolution of intelligent systems are carried out in a controlled, documented, and compliant manner. Said model shall include, among other aspects: definition of responsibilities, development procedures, version management, change control, risk assessment, performance supervision, periodic model review, document management, and audit mechanisms.

Article 24. Principle of human oversight

Mallorca AI shall maintain reasonable human oversight mechanisms over the intelligent systems used on the Platform. Human intervention may occur, among other cases, when: anomalous results are detected, there are relevant incidents, a User submits a claim, a Professional Client requests a review, it is necessary to verify system operation, or the law requires human intervention. Human oversight does not necessarily imply individual review of all recommendations generated by the Platform.

Article 25. Data quality

Mallorca AI shall endeavor to ensure that the data used by intelligent systems are, to the extent reasonably possible: relevant, adequate, up-to-date, consistent, complete where necessary, and obtained from legitimate sources. However, the Platform may use information provided by third parties or by Users themselves whose accuracy cannot be guaranteed at all times.

Article 26. Data minimization

Intelligent systems shall be designed to use only the information necessary to achieve the pursued purpose. Whenever possible, Mallorca AI shall favor the use of: aggregated data, statistical data, pseudonymized information, and anonymized information.

Article 27. Model updating

Predictive models may be updated for the purpose of: improving accuracy, correcting deviations, incorporating new variables, adapting to technological changes, responding to new functional needs, and improving User experience. Updates shall be carried out seeking to preserve the stability, security, and reliability of the Platform.

Article 28. Risk management

Mallorca AI shall implement internal procedures to identify, assess, and manage risks arising from the use of intelligent systems. Among others, risks related to: data quality, anomalous operation, prediction errors, cybersecurity, privacy, service continuity, improper use, impact on Users, and regulatory compliance may be assessed. The measures adopted shall be proportionate to the nature, scope, and purpose of each system.

Article 29. Bias prevention

Mallorca AI shall endeavor to design its intelligent systems in a way that reduces, to the extent reasonably possible, the appearance of unjustified biases arising from: errors in data, incomplete information, incorrect configurations, outdated models, and insufficient information sources. The existence of prevention mechanisms does not imply the absolute elimination of any possible statistical deviation inherent to this type of technology.

Article 30. Explainability

Where technically and legally possible, Mallorca AI shall endeavor to offer understandable explanations of the general criteria used by intelligent systems to generate recommendations, classifications, or suggestions. The transparency obligation shall not imply the disclosure of: proprietary algorithms, mathematical models, internal decision rules, training parameters, weights used, optimization methodologies, or trade secrets.

Article 31. Security of intelligent systems

Mallorca AI shall adopt reasonable technical and organizational measures to protect intelligent systems against: unauthorized access, model manipulation, data alteration, fraudulent use, unlawful extraction of information, attacks directed at algorithms, and unauthorized automated access.

Article 32. Logging and traceability

Mallorca AI may maintain technical logs related to the operation of its intelligent systems for the purpose of: detecting incidents, facilitating audits, improving service quality, investigating anomalies, guaranteeing security, and proving regulatory compliance. These logs shall be retained for as long as necessary in accordance with applicable law and internal retention policies.

Article 33. Internal audits

Mallorca AI may conduct periodic audits of its intelligent systems to evaluate, among other aspects: performance, stability, security, data quality, regulatory compliance, effectiveness of control measures, and general operation of the models. Audits may be carried out by internal staff or by specialized entities where appropriate.

Article 34. Continuous improvement

Intelligent systems shall be subject to a permanent process of review and improvement. Modifications may respond, among other reasons, to: technological evolution, User needs, Professional Client suggestions, regulatory changes, new information sources, performance improvement, and reduction of incidents. Continuous improvement is an essential element of Mallorca AI's operation.

Article 35. Technological responsibility

Mallorca AI shall ensure that intelligent systems are developed and used in accordance with reasonable standards of technical and professional diligence. However, the existence of intelligent or predictive processes does not imply that all recommendations, predictions, or automations produce accurate results in all circumstances, given the probabilistic nature of this type of technology.

Article 36. Cooperation with authorities

Where legally required, Mallorca AI shall cooperate with competent authorities in matters of data protection, artificial intelligence, consumer protection, competition, or any other that may be competent, providing the necessary information within the limits established by law and preserving, in all cases, the confidentiality of its trade secrets and intellectual property rights.

TITLE IV — RIGHTS OF USERS, RESPONSIBILITIES, INTELLECTUAL PROPERTY, AND FINAL PROVISIONS

Article 37. Right to information

Users, Professional Clients, and Partners shall have the right to receive clear, accessible, and understandable information about the use of intelligent systems when they significantly intervene in the provision of Services. Mallorca AI shall endeavor to provide such information through this Policy, the Privacy Policy, the General Terms, and any other applicable documentation.

Article 38. Right to request human review

When a User considers that a decision, classification, recommendation, or result generated by intelligent systems has caused them significant harm, they may request review of the case by Mallorca AI, provided that such review is technically and legally appropriate. Human review shall have the purpose of analyzing the operation of the system in the specific case and verifying whether a manifest error, a technical incident, or an incorrect application of the defined rules has occurred.

Article 39. Right to object to automated processing

Where applicable law allows and the legally established requirements are met, the User may object to certain automated processing of their personal data. Exercise of this right may limit or prevent the operation of those functionalities whose provision necessarily depends on such processing.

Article 40. Right to file complaints

Users may report incidents, errors, or complaints related to the operation of intelligent systems through the customer service channels enabled by Mallorca AI. Filing a complaint shall not by itself imply recognition of incorrect operation of the system nor the existence of liability on the part of Mallorca AI.

Article 41. User obligations

Users undertake to use the intelligent functionalities of the Platform lawfully, diligently, and in accordance with these policies. In particular, they shall refrain from: manipulating system results, introducing false or misleading information in order to alter recommendations, using unauthorized automated mechanisms to extract information from the Platform, attempting to access, reproduce, or infer the internal functioning of predictive models, and using the results obtained for unlawful or contrary to good faith purposes.

Article 42. Obligations of Professional Clients and Partners

Professional Clients and Partners who use intelligent functionalities provided by Mallorca AI shall use them in accordance with their purpose and respect applicable law. They may not present as their own the recommendations, scores, or results generated by the Predictive Tourism Intelligence Engine nor modify its operation without the express authorization of Mallorca AI. Likewise, they shall adequately inform their own users when integrating said functionalities into White-Label solutions or services provided under their own brand, in the terms provided for in the contracts signed with Mallorca AI.

Article 43. Limitation of liability

The intelligent systems used by Mallorca AI generate recommendations, predictions, classifications, and automations based on information available at any given time and on probabilistic models. Consequently: recommendations do not constitute guarantees of outcome, predictions may be altered by unforeseen circumstances, external factors may modify the conditions initially analyzed, and information provided by third parties may contain errors or be outdated. Mallorca AI shall not be liable for damages arising exclusively from the use of recommendations when they are the consequence of incorrect information provided by third parties, unforeseeable changes in the circumstances analyzed, or use contrary to these policies. Nothing in this article shall limit liability that cannot be excluded under applicable law.

Article 44. Intellectual property and trade secrets

All intellectual and industrial property rights relating to the intelligent systems used by Mallorca AI belong to Mallorca AI or to third parties who have legitimately authorized their use. The following are protected, among others: algorithms, predictive models, recommendation engines, business rules, calculation methodologies, software architectures, knowledge bases, scoring systems, training methodologies, technical documentation, source code, object code, interfaces, functional designs, data structures, and internal procedures. This Policy does not grant license, assignment, or authorization over said rights, beyond the ordinary use of the Platform in accordance with the Terms & Conditions of Use.

Article 45. Confidentiality

Technical information relating to the internal operation of Mallorca AI's intelligent systems shall be considered confidential information and, where applicable, a trade secret in accordance with current legislation. Users, Professional Clients, and Partners shall refrain from carrying out acts intended to obtain, reproduce, decompile, analyze, or exploit said information without the express and written authorization of Mallorca AI.

Article 46. Technological evolution

Mallorca AI may incorporate new intelligent systems, replace existing technologies, or modify the functional architecture of the Platform in order to improve the quality, security, efficiency, or usefulness of the Services. These modifications shall not alter the fundamental principles established in this Policy without the corresponding documentary update when legally required.

Article 47. Updating of the Policy

This Policy may be modified to adapt to: legislative changes, evolution of the European Artificial Intelligence Act (AI Act), new interpretations by competent authorities, incorporation of new functionalities, technological evolution of the Platform, and organizational modifications. When modifications significantly affect Users' rights or the use of intelligent systems, Mallorca AI shall adopt the information measures that are required.

Article 48. Document integration

This Policy forms part of the legal framework of Mallorca AI Travel Engine® and shall be interpreted jointly with: the Legal Notice, the Terms & Conditions of Use, the General Contracting Conditions, the Privacy Policy, the Cookie, Local Storage, and Similar Technologies Policy, the API & Integrations Policy, the Information Security Policy, contracts signed with Professional Clients, Partners, and Providers, and any other documents regulating the provision of Services.

Article 49. Applicable law and dispute resolution

This Policy shall be governed by Spanish law and applicable European Union law on data protection, artificial intelligence, digital services, consumer protection, intellectual property, competition, and electronic commerce. Disputes arising from its interpretation or application shall be resolved in accordance with the provisions of the Terms & Conditions of Use and applicable procedural law.

Article 50. Entry into force

This Policy shall enter into force on the date indicated in its heading and shall remain in force until replaced by a new version duly published by Mallorca AI.

ANNEX I — FUNCTIONAL CLASSIFICATION OF INTELLIGENT SYSTEMS

For information purposes, Mallorca AI may use, among others, the following types of systems: Predictive Tourism Intelligence Engine, Recommendation Engine, Personalization System, Contextual Analysis System, Classification and Prioritization System, Operational Optimization System, Pattern Detection System, Machine Learning System, Process Automation System, Conversational Assistance System, Incident and Anomaly Detection System, Fraud Prevention System, Monitoring and Observability System, and Aggregated Analytics System. The incorporation, modification, or replacement of any of these systems shall not by itself alter the essential purposes described in this Policy.

Cancellation & Refund Policy

Last updated: July 12, 2026

CANCELLATION & REFUND POLICY

Mallorca AI Travel Engine®

Version: 1.0
Effective date: [●]
Last updated: [●]

TITLE I — GENERAL PROVISIONS

Article 1. Purpose

This Policy regulates the conditions applicable to cancellations, withdrawals, modifications, returns, and refund requests related to services offered through Mallorca AI Travel Engine® (hereinafter, "Mallorca AI" or "the Platform").

This Policy aims to establish a transparent framework regarding: Mallorca AI's own digital services, Premium access, temporary passes, professional plans, services contracted by collaborating establishments, experiences offered by third parties, and additional services or upgrades offered by partners.

Article 2. Nature of services offered

Mallorca AI is a technological platform specialized in predictive tourism intelligence, personalized recommendations, and digital connection between travelers, establishments, tourism professionals, and service providers.

The services offered may include: access to digital functionalities, intelligent recommendation tools, predictive systems, personalized tourist information, temporary access management, connection with third-party experiences, and tools for professional establishments.

Depending on the contracted service, Mallorca AI may act as: a) direct provider of a digital service; b) provider of technological infrastructure; c) technological intermediary between user and third-party provider. The applicable liability shall depend on the position assumed in each specific service.

Article 3. Acceptance of conditions

Contracting or activation of any service through Mallorca AI implies acceptance of this Policy. Where required by applicable law, the User must expressly accept certain specific conditions before completing the contracting.

TITLE II — MALLORCA AI'S OWN DIGITAL SERVICES

Article 4. Included services

For the purposes of this Policy, Mallorca AI's own digital services shall include, among others: Premium plans for travelers, temporary access, digital passes, Pro plans, advanced functionalities, intelligent tools, and digital accesses marketed directly by Mallorca AI.

Article 5. Immediate activation of service

Due to the digital nature of the services offered, Mallorca AI may begin provision immediately after: payment confirmation, order validation, access activation, and assignment of the corresponding service. Activation may involve: account creation, enabling of functionalities, allocation of technological resources, access to the Predictive Engine, processing of personalized information, and consumption of external technological services.

Article 6. Costs associated with the digital service

The User acknowledges that Mallorca AI's digital services involve technological costs associated with their provision, including: cloud hosting and infrastructure, technical maintenance, API consumption, artificial intelligence services, storage, security, monitoring, and technological evolution. These costs may be incurred from the moment of activation, even if the User does not subsequently use all available functionalities.

Article 7. Limited duration plans

Some Mallorca AI services have a specific and limited duration, including: 3-day passes, 5-day passes, 7-day passes, temporary Premium access, promotional plans, and access associated with collaborating hotels. Contracting these services entails the acquisition of a specific period of digital access.

TITLE III — RIGHT OF WITHDRAWAL AND DIGITAL SERVICES

Article 8. Legal right of withdrawal

Where consumer and user regulations apply, Mallorca AI shall respect the rights legally recognized to the User. However, certain digital services may be subject to legally provided exceptions when: the User expressly requests the immediate start of the service, the service begins before the legal withdrawal period has elapsed, or the User acknowledges the consequences arising from said activation.

Article 9. Consent for immediate activation

Before completing certain contracting processes, Mallorca AI may request express acceptance whereby the User confirms: that they wish immediate activation of the service, that they understand that provision will begin before the end of the applicable legal period, and that they accept the consequences legally provided for regarding the right of withdrawal.

Article 10. Services shorter than the legal withdrawal period

When the contracted service has a duration shorter than the general withdrawal period provided by law, as occurs with certain 3, 5, or 7-day passes, the evaluation of a refund request shall take into account: whether the service has already been activated, time elapsed, functionalities used, degree of execution, and costs incurred. The short duration of the service does not automatically imply a right to refund once provision has begun.

TITLE IV — CANCELLATIONS AND REFUNDS OF DIGITAL SERVICES

Article 11. Cancellation before activation

When a digital service has not been activated and its execution has not begun, Mallorca AI may assess the cancellation request in accordance with applicable law and the specific conditions of the service.

Article 12. Cancellation after activation

Once a digital service has been activated, cancellation by the User's decision shall not automatically imply a right to refund. Mallorca AI shall assess each case considering: nature of the service, degree of execution, period enjoyed, technological costs incurred, and applicable legal obligations.

Article 13. Non-use

Total or partial non-use of an activated digital service shall not automatically generate a right to refund. Availability of the service forms part of the provision carried out by Mallorca AI.

TITLE V — PROFESSIONAL PLANS, HOTELS, AND PARTNERS

Article 14. Professional services

Plans intended for: hotels, agencies, operators, tourism managers, and collaborating companies shall be considered professional digital services. Their economic conditions may be regulated by specific contracts.

Article 15. Passes for guests

When an establishment acquires Mallorca AI access for its guests: activation implies the enabling of technological capacity, access may be generated prior to its use, and non-use by the guest does not necessarily eliminate the costs incurred. Cancellation conditions shall be governed by the corresponding professional contract.

Article 16. Reduced price commercial policy

Mallorca AI may offer professional plans and digital access with promotional or symbolic prices intended to facilitate technological adoption. Such commercial conditions do not imply: absence of real costs, free provision, obligation to maintain promotional prices, or absence of associated technological costs.

TITLE VI — EXPERIENCES AND THIRD-PARTY SERVICES

Article 17. Services provided by third parties

Some experiences, activities, or services available through Mallorca AI may be provided directly by independent third parties. Examples: excursions, nautical activities, restaurants, cultural experiences, transport, and leisure activities.

Article 18. Role of Mallorca AI

In these cases, Mallorca AI may act as a technological connection and intermediation platform. The third-party provider shall be responsible for: provision of the service, availability, quality, cancellations, modifications, and corresponding refunds.

Article 19. Intermediation commission

When Mallorca AI receives a commission for a booking, said commission shall remunerate: technological services, connection between user and provider, digital infrastructure, and Platform management. The commission does not constitute the price of the tourist service provided.

Article 20. Cancellation of experiences

The cancellation and refund conditions applicable to experiences shall depend on the conditions established by each provider. When the impossibility of provision is the responsibility of the third-party provider, Mallorca AI shall not automatically assume financial obligations corresponding to the service not provided.

TITLE VII — UPSELLS AND SERVICES WITHOUT COMMISSION

Article 21. Additional services of partners

Mallorca AI may display additional offers provided directly by partners or establishments. Examples: upgrades, room enhancements, complementary services, extras, and private promotions.

Article 22. Absence of financial responsibility

When Mallorca AI does not receive a commission nor financially participate in the operation: it shall not be the seller of the service, shall not set prices, shall not manage payments, and shall not determine refunds.

Article 23. Application of third-party policies

Additional services shall be subject exclusively to the conditions of the responsible partner. The User should consult: cancellation policy, modification conditions, refund policy, and applicable restrictions.

TITLE VIII — REFUND REQUEST PROCEDURE

Article 24. Request

Requests must include: User identification, contracted service, contracting date, reason for request, and relevant documentation.

Article 25. Evaluation

Mallorca AI shall analyze the request taking into account: applicable law, accepted conditions, nature of the service, degree of execution, and responsibility of each party.

Article 26. Resolution

Mallorca AI shall communicate the decision adopted within a reasonable period. Where a refund is appropriate, it shall be made using the same means used for payment unless otherwise agreed.

TITLE IX — FRAUD AND IMPROPER USE

Article 27. Fraudulent requests

Mallorca AI may reject requests where there are indications of: fraud, abuse of the system, irregular use of accounts, manipulation of promotions, or repeated unjustified requests.

TITLE X — FINAL PROVISIONS

Article 28. Applicable law

This Policy shall be governed by: Spanish law, applicable European regulations, consumer regulations, digital services regulations, and data protection regulations.

Article 29. Modifications

Mallorca AI may update this Policy to adapt to legal, technological, or commercial changes.

Article 30. Entry into force

This Policy shall enter into force on the date indicated and shall remain in force until replaced.

Intellectual Property Policy

Last updated: July 12, 2026

INTELLECTUAL PROPERTY, INDUSTRIAL PROPERTY, CONTENT, AND PLATFORM USE POLICY FOR PROFESSIONAL CLIENTS, PARTNERS, AND COLLABORATORS

Mallorca AI Travel Engine®

Version 1.0

Internal Corporate Document

TITLE I — GENERAL PROVISIONS

Article 1. Purpose

This Policy regulates the regime of intellectual property, industrial property, exploitation rights, use licenses, content use, protection of business knowledge, and use of the Mallorca AI Travel Engine® Platform by all Professional Clients, Partners, Hotels, Agencies, Operators, Experience Companies, Technology Collaborators, and other entities that maintain a commercial relationship with Mallorca AI.

Its purpose is to establish a clear legal framework regarding: ownership of Mallorca AI's technological assets; rights and obligations arising from professional use of the Platform; ownership of content provided by Professional Clients; use of digital tools provided by Mallorca AI; use of the Mallorca AI brand; protection of the Predictive Tourism Intelligence Engine; use of APIs and integrations; protection of trade secrets; and exploitation of content within the Mallorca AI ecosystem.

This Policy complements the Terms & Conditions of Use, professional contracts, service provision contracts, the API & Integrations Policy, the Information Security Policy, and other corporate documents of Mallorca AI.

Article 2. Scope of application

This Policy shall apply, among others, to: hotels, hotel chains, tourist apartments, holiday homes, travel agencies, DMCs, tour operators, activity companies, nautical companies, restaurants, mobility companies, leisure companies, technology providers, integrated developers, distributors, affiliates, commercial collaborators, and any entity that uses Mallorca AI's professional environment.

Article 3. Definitions

For the purposes of this Policy, the following shall be understood:

Mallorca AI: The Mallorca AI Travel Engine® technological platform, including its technical infrastructure, applications, PWA, software, administration panels, APIs, databases, predictive systems, artificial intelligence tools, technical documentation, and any other digital asset developed by the company.

Professional Client: Legal entity or professional who uses Mallorca AI as a technological tool to manage, promote, or commercialize their own services. By way of illustration: hotels, agencies, operators, experience companies, and collaborating companies.

Partner: Entity integrated into the Mallorca AI ecosystem through any of the collaboration modalities provided for by the Platform.

Content: All information incorporated by any of the parties, including: texts, photographs, videos, iconography, documents, rates, schedules, promotions, offers, operational information, audiovisual content, and commercial documentation.

Professional Panel: Private administration area provided by Mallorca AI for the management of professional services.

Predictive Tourism Intelligence Engine: Set of algorithms, processes, business rules, predictive systems, mathematical models, artificial intelligence, automations, recommendation engines, and methodologies developed by Mallorca AI to offer intelligent recommendations and personalized services.

Article 4. General principles

Every professional relationship with Mallorca AI shall be governed by the following principles: a) respect for the intellectual property of all parties; b) respect for industrial property; c) legitimate use of content; d) protection of technological innovation; e) protection of trade secrets; f) collaboration based on good faith; g) respect for applicable European regulations.

Article 5. Absence of rights transfer

The use of Mallorca AI by a Professional Client shall not imply, unless otherwise agreed in writing: assignment of intellectual property rights, transfer of software, assignment of source code, acquisition of rights over the Platform, license over the Predictive Engine, or participation in technological developments. Contracting of services implies exclusively the granting of a limited right of use in accordance with the applicable contractual conditions.

TITLE II — OWNERSHIP OF MALLORCA AI ASSETS

Article 6. Protected assets

All technological assets developed by the company are the exclusive property of Mallorca AI, including, among others: the Mallorca AI Travel Engine® Platform; the Progressive Web App (PWA); the management software; the backend; the frontend; mobile applications; source code; object code; software architecture; APIs; connectors; integration engines; proprietary databases; data structures; artificial intelligence models; predictive algorithms; recommendation systems; business rules; automated processes; dashboards; professional panels; functional documentation; technical documentation; user manuals; graphic image; visual design of the Platform; corporate identity; trade names; trademarks; Internet domains; original designs; and methodologies developed by Mallorca AI.

All these assets shall be protected by legislation on intellectual property, industrial property, unfair competition, trade secrets, and any other applicable rules.

Article 7. Enhanced protection of the Predictive Engine

The Predictive Tourism Intelligence Engine constitutes Mallorca AI's main strategic asset. The following are especially protected: predictive models; decision rules; scoring systems; classification models; recommendation methodologies; prioritization systems; calculation formulas; internal weightings; learning processes; automation logic; and decision architecture. Access to the results generated by the Predictive Engine shall not, in any case, imply access to its internal functioning nor authorization to reproduce, analyze, decompile, or replicate it.

Article 8. Prohibition of reverse engineering

Unless expressly authorized in writing by Mallorca AI, no Professional Client or Partner may: decompile the software; carry out reverse engineering; copy essential functionalities; reproduce the operational design of the Platform; develop solutions intended to replicate in whole or in part the operation of the Predictive Engine; massively extract information through automated procedures; or use robots, crawlers, or equivalent systems to reconstruct the functional architecture of Mallorca AI. Breach of this obligation shall be considered a serious breach of the contractual relationship and may lead to immediate termination of the contract, without prejudice to the corresponding legal actions.

TITLE III — RIGHT OF USE OF THE PLATFORM BY PROFESSIONAL CLIENTS

Article 9. Grant of right of use

During the term of the contractual relationship, Mallorca AI may grant the Professional Client a personal, limited, non-exclusive, non-transferable, and revocable use license to access and use the Platform's professional services in accordance with the contracted plan. Said license shall have the sole purpose of allowing the Professional Client to use the functionalities made available to them within the Mallorca AI ecosystem for the ordinary development of their professional activity. This license does not imply transfer of intellectual, industrial, or technological property over the Platform or any of its components.

Article 10. Nature of the license

The granted license shall be exclusively functional in nature. Consequently, the Professional Client only acquires the right to use the tools expressly enabled during the term of the contract. In no case may it be interpreted that said license implies: transfer of technology; assignment of software; acquisition of rights over source code; authorization to reuse internal components; authorization to develop derivative solutions; or authorization to economically exploit the Platform outside the expressly permitted uses.

Article 11. Mallorca AI Professional Area

Mallorca AI may make available to Hotels, Agencies, Operators, and other Professional Clients a Professional Area designed to facilitate the digital management of the relationship with their guests, clients, or users. The specific content of each Professional Area shall depend on the contracted plan and the functional evolution of the Platform.

Article 12. Functionalities of the Professional Area

Without limitation, the Professional Area may allow: administration of the establishment's profile; updating of commercial information; management of photographs; modification of descriptions; management of schedules; communication of internal rules; publication of operational information; management of welcome information; communication of WiFi keys; information on reception hours; publication of useful telephone numbers; information on internal procedures; provision of instructions for guests; incident management; response to requests; offer management; campaign creation; promotion management; publication of own products; upsell management; consultation of statistics; access to reports; management of integrated bookings; administration of authorized users; and use of tourism intelligence tools made available to the establishment. Mallorca AI may expand, modify, replace, or withdraw functionalities in accordance with the technological evolution of the Platform and applicable contractual conditions.

Article 13. Authorized users

The Professional Client shall be responsible for the persons they authorize to access their Professional Area. They shall ensure that such persons: use the Platform in accordance with this Policy; maintain the confidentiality of their credentials; act within the scope of their functions; respect applicable law; and use the Platform in good faith. The Client shall be liable to Mallorca AI for actions carried out through accounts created under their organization, without prejudice to individual responsibilities that may apply.

Article 14. Credential management

Access credentials shall be strictly personal. The Professional Client shall adopt reasonable measures to prevent: unauthorized access; shared use of users where not permitted; disclosure of passwords; creation of fictitious accounts; and transfer of access to third parties. Mallorca AI may require the use of enhanced authentication mechanisms where necessary to protect the security of the Platform.

CHAPTER II — Management of the establishment's operational content

Article 15. Information for guests

Hotels and other establishments may use Mallorca AI to communicate to their guests relevant information related to their stay. Among other content: WiFi access keys, breakfast times, reception hours, pool hours, spa hours, internal rules, emergency telephone numbers, check-in information, check-out information, available services, instructions for use of facilities, important notices, and operational communications. All this information shall continue to be the property of the establishment that publishes it. Mallorca AI shall act exclusively as the provider of the technological infrastructure necessary for its dissemination.

Article 16. Incident management

The Platform may incorporate tools designed to facilitate communication between guests and establishments for the management of incidents related to the stay. These functionalities may allow, among others: receipt of alerts, incident tracking, exchange of communications, recording of actions, and closure of incidents. Use of these tools shall not imply that Mallorca AI assumes responsibility for the material resolution of the incident, which shall correspond exclusively to the establishment.

Article 17. Communications with guests

The Professional Client may use Mallorca AI to send communications related to the provision of their own services. It shall be the exclusive responsibility of the establishment to ensure that such communications: are truthful; respect applicable law; do not infringe third-party rights; do not include unlawful content; respect data protection regulations; and respect electronic communications regulations. Mallorca AI may suspend those communications that violate current legislation, these policies, or the Terms & Conditions of Use.

CHAPTER III — Use of professional services

Article 18. Use in accordance with the intended purpose

The Professional Client shall use the Platform exclusively for the purposes provided for in the corresponding contract. It is prohibited to use Mallorca AI for: unlawful activities; distribution of malware; fraudulent campaigns; social engineering; spam activities; unauthorized automated exploitation; massive data acquisition; identity theft; or activities that may harm other Clients or Users.

Article 19. Reasonable use of the Platform

The Professional Client undertakes to make reasonable use of the technological resources made available to them. Mallorca AI may adopt measures intended to preserve service stability when it detects anomalous consumption, abusive automations, or behaviors that may compromise the security, availability, or general performance of the Platform.

Article 20. Technological evolution

The Professional Client acknowledges that Mallorca AI is a continuously evolving technological platform. Consequently, Mallorca AI may introduce improvements, modifications, new functionalities, technical adaptations, automations, or innovation processes designed to improve the service, without this implying an essential alteration of the nature of the contract. Whenever possible, such modifications shall be implemented seeking to minimize their impact on the Professional Clients' operations.

Article 21. Absence of rights over improvements

Functional improvements, new tools, technological developments, Predictive Engine optimizations, automations, artificial intelligence processes, and any innovations incorporated by Mallorca AI during the term of the contractual relationship shall continue to be the exclusive property of Mallorca AI, without the Professional Client acquiring any rights over them by the mere fact of using them.

TITLE IV — CONTENT PROVIDED BY PROFESSIONAL CLIENTS, HOTELS, AND PARTNERS

CHAPTER I — Ownership of content

Article 22. Ownership of Professional Client content

Hotels, Agencies, Operators, Partners, and other Professional Clients shall retain at all times ownership of the original content they legitimately incorporate into the Platform. Among others: trade name, brand, logos, photographs, videos, corporate images, descriptive texts, establishment information, menus and menus, rates, promotions, commercial conditions, schedules, internal rules, information for guests, own documents, audiovisual material, and graphic elements. Use of Mallorca AI shall not imply transfer of the intellectual or industrial property of said content.

Article 23. Guarantee of ownership

The Professional Client declares and guarantees that they have the necessary rights to incorporate the content into the Platform. In particular, they guarantee that: they are the owner of the corresponding rights; or they have sufficient authorization for its use. They also declare that said content does not infringe: copyright; trademarks; industrial designs; image rights; trade secrets; third-party rights; or applicable law. The Professional Client shall be liable to Mallorca AI for any claim arising from lack of legitimacy with respect to the content provided.

Article 24. Accuracy of information

The Professional Client shall be responsible for keeping the information published on the Platform up to date. Especially with respect to: schedules, availability, services, prices, promotions, commercial conditions, operational information, telephone numbers, addresses, and contact details. Mallorca AI shall not be liable for damages arising from incorrect information provided by the establishment itself.

CHAPTER II — License granted to Mallorca AI

Article 25. Use license

With the sole purpose of correctly providing the contracted services, the Professional Client grants Mallorca AI a use license: non-exclusive; non-transferable, except to technology providers necessary for service provision; revocable in accordance with contractual conditions; and limited to the object of the commercial relationship. Said license shall allow Mallorca AI to: store content; technically reproduce it; adapt it to the Platform format; index it; display it; distribute it within the Mallorca AI ecosystem; use it in the PWA; use it in future applications; incorporate it into recommendation systems; and use it in communications related to the contracted service.

Article 26. Technical adaptations

Mallorca AI may make the necessary technical adaptations to guarantee the correct visualization of content. Among others: resizing of images, format optimization, compression, automatic translations where activated by the Client, generation of thumbnails, and adaptation to different devices. These adaptations shall not imply alteration of content ownership.

Article 27. Commercial use

Mallorca AI may use Professional Client content to promote the establishment's presence within the Mallorca AI ecosystem, including: internal search engines, recommendations, Platform promotional campaigns, communications directed at Users, newsletters related to the establishment, and official Mallorca AI social networks, provided that the content is related to the Partner's promotion and its image is not distorted. Any use outside the provision of the service shall require authorization where legally required.

CHAPTER III — Content created from the Professional Area

Article 28. Content generated by the Client

Content created directly by the Professional Client through the Professional Area shall remain their property. Among others: welcome messages, instructions for guests, WiFi information, schedules, notices, own recommendations, frequently asked questions, automatic responses configured by the establishment, promotional campaigns, offers, upsells, and temporary promotions. Mallorca AI shall only provide the technological infrastructure for their storage, administration, and distribution.

Article 29. Operational content

Content intended exclusively to facilitate the guest's stay shall be operational in nature. For example: access codes, WiFi keys, check-in instructions, coexistence rules, information on facilities, internal telephones, and schedules. Mallorca AI shall not modify said content except when technically essential to guarantee its correct presentation.

Article 30. Deletion of content

The Professional Client may modify, replace, or delete content in their ownership while the contractual relationship remains in force, without prejudice to backups, legal retention obligations, or technical logs necessary to guarantee the integrity of the Platform.

CHAPTER IV — Content generated through Mallorca AI tools

Article 31. Assistance tools

Mallorca AI may offer tools designed to facilitate content creation through automation, templates, or artificial intelligence systems. These tools shall be assistive in nature and their use shall always be the responsibility of the Professional Client.

Article 32. Content review

The Professional Client shall review content before publishing it. Especially when it has been: automatically suggested, translated, summarized, adapted, or enriched through intelligent tools. Publication shall imply that the Professional Client assumes responsibility for the content finally displayed.

Article 33. Predictive AI and content generation

When Mallorca AI uses its Predictive Tourism Intelligence Engine to suggest texts, commercial recommendations, upselling proposals, descriptions, or any other content intended to facilitate establishment management, such suggestions shall constitute a decision support tool. The final decision to use, modify, publish, or discard said content shall correspond exclusively to the Professional Client. Mallorca AI does not guarantee that the suggestions are suitable for all situations nor that they will produce a particular commercial outcome.

Article 34. Rights over intelligent tools

The use by the Professional Client of artificial intelligence, automation, or assisted generation tools shall not imply any assignment of the models, algorithms, methodologies, or technological systems used by Mallorca AI to produce said suggestions. All rights over these tools shall remain the exclusive property of Mallorca AI.

CHAPTER V — Content retention and removal

Article 35. End of relationship

Once the contractual relationship has ended, Mallorca AI shall remove from the Platform content whose publication depends exclusively on said relationship, unless: there is a legal obligation to retain it; it is necessary to maintain technical or audit logs; or the parties agree on another solution.

Article 36. Backups

The Client acknowledges that Mallorca AI may retain technical backups for as long as strictly necessary to guarantee: service continuity; disaster recovery; information security; and compliance with legal obligations. These copies may not be used for commercial purposes once the contractual relationship has ended.