General Terms of Use and Sale — vinca.chat

Version 1.4

Preamble

These General Terms of Use and Sale (hereinafter "the GTU/GTS") govern access to the vinca.chat service and the purchase of credits. They form a single, versioned and dated document. They are accepted by ticking a dedicated checkbox — never pre-ticked — when the account is created and with each order; the accepted version and the timestamp of acceptance are retained by GHIC (Article 1127-1 et seq. of the French Civil Code; Article L221-7 of the French Consumer Code). The GTU/GTS may be consulted at any time from the application and downloaded in PDF format. These terms come into force on the date of their first publication on vinca.chat.

Article 1 — Publisher, publication director and host

The vinca.chat service (hereinafter "the Service") is published by:

GHIC (Global Human Intelligence Consulting), a limited liability company with a sole shareholder and share capital of €100, registered with the Trade and Companies Register of Paris under number 939 603 593, intra-Community VAT number FR06939603593, whose registered office is located at 60 rue François 1er, 75008 Paris, France (hereinafter "GHIC" or "the Publisher").

• Manager and publication director: Philippe Guillamo.
• Contact: contact@vinca.chat — telephone: +33 1 84 16 38 76.
• Host: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, D02 R296, Ireland — telephone: +353 1 543 1000 (Google's general contact in Ireland) — in accordance with Article 6 III of French Law No. 2004-575 of 21 June 2004 (LCEN), as amended by the French SREN Law of 21 May 2024. The data (database, secrets) are stored in Paris (Google Cloud region europe-west9); application processing, without data storage, is carried out in Belgium (region europe-west1).

This legal information is permanently accessible from the site footer and the application menu (Article 1-1 of French Law No. 2004-575 of 21 June 2004 on confidence in the digital economy).

Article 2 — Definitions

• "Service": the vinca.chat application and website, including the Vinca conversational agent and all associated features.
• "User" (or "you"): any natural person of legal age, acting for personal purposes falling outside the scope of their professional activity (consumer), holding an Account.
• "Account": the User's personal space, created upon registration.
• "Purchased credits": the credits acquired for consideration by the User (1 credit = €1 incl. tax). Unused Purchased credits are refundable under the conditions set out in Articles 9 and 13.
• "Bonus credits": the credits offered by GHIC without financial consideration (welcome credits, additional credits included in certain packs). They are consumed as a priority and are never refundable or exchangeable.
• "Credit gift": the purchase of a pack by a User (hereinafter "the Giver") for the benefit of another User (hereinafter "the Recipient"), designated by the email address of their Account (Article 6.7). The entire pack is credited to the Recipient in the form of "credits received as a gift", which follow the rules applicable to Bonus credits: consumed as a priority, never refundable and never convertible into money in the Recipient's hands.
• "Plan" (or "subscription Plan"): the optional subscription, monthly or yearly, through which a quota of credits is delivered to the Account every month (Article 6.8). Credits delivered under a Plan ("Plan credits") are never refundable nor convertible into money; they are consumed after Bonus credits and before Purchased credits.
• "Group": the conversation space shared between several Users (couple or family), each having their own Account.
• "Memories": the lasting facts extracted from conversations and retained, in encrypted form, to personalise the Service (private memory specific to each User; shared memory specific to each Group).
• "GTU/GTS": this document.

Article 3 — Nature and purpose of the Service

3.1 Description of the Service

Vinca is an emotional and relational well-being companion based on generative artificial intelligence. The Service allows you to converse in writing (or by voice message transcribed into text) with the Vinca conversational agent, alone or within a Group (couple, family), in a "pixel art" style interface whose setting varies according to the season, the time of day and the weather. The Service includes in particular:

• personalised conversations, informed by encrypted Memories (see the Privacy Policy);
• Group spaces allowing shared conversations, with on-the-fly translation between participants of different languages;
• memory management commands ("remember", "forget", voluntary transfer of a conversation to private or shared memory);
• an interface available in eight languages (French, English, Spanish, Russian, Italian, Portuguese, German, Ukrainian).

The essential characteristics of the Service, its features, its compatibility (recent web browser, progressive web application usable on mobile and computer) and the technical prerequisites (Internet connection) are presented on the site before any registration (Article L111-1 of the French Consumer Code). This description sets the conformity standard of the Service within the meaning of Articles L224-25-1 et seq. of the French Consumer Code.

3.2 What Vinca is not — important warning

Vinca is an emotional and relational well-being companion based on artificial intelligence. You are conversing with an artificial intelligence, and not with a human being.

Vinca is not a psychologist, psychotherapist, clinical sexologist or healthcare professional within the meaning of French regulations. Vinca does not provide care, makes no diagnosis and prescribes no treatment. The Service in no way replaces a consultation with a doctor, a psychologist, a psychiatrist or any qualified healthcare professional, and is not a medical device within the meaning of Regulation (EU) 2017/745. The responses are generated by an artificial intelligence model and may be inaccurate, incomplete or unsuited to your situation; they do not constitute professional advice (medical, legal, financial or otherwise).

Vinca is not an emergency service. If you are going through a crisis, have suicidal thoughts or are in danger, contact immediately 3114 (national suicide prevention number, free, 24/7) or 15 / 112 in the event of a life-threatening emergency. In the event of domestic violence within the couple, contact 3919. If you are using the Service from another country, the helplines and emergency numbers for your country are permanently displayed in the application.

This information is also provided in the interface itself, permanently, in accordance with Article 50 of Regulation (EU) 2024/1689 on artificial intelligence.

3.3 Situations for which the Service is not designed

The Service is designed to support everyday personal and relational reflection. It is not suitable and must not be used as a primary response: to suicidal crises or self-harm thoughts; to severe psychiatric disorders requiring medical follow-up; to situations of violence, abuse or danger. In these situations, Vinca will systematically direct you to a healthcare professional or emergency services, and GHIC expressly recommends that you consult a doctor.

Article 4 — Access to the Service: legal age and Account

4.1 The Service is strictly reserved for persons aged 18 or over. Upon registration, the User certifies on their honour that they are of legal age, by means of a dedicated checkbox, never pre-ticked, the acceptance of which is timestamped. GHIC reserves the right to request proof of age in the event of reasonable doubt and to suspend and then delete any account held by a minor.

4.2 The User undertakes to provide accurate information upon registration and to keep it up to date. The Account is strictly personal: login credentials must not be shared, and each participant in a Group has their own Account.

4.3 Inviting a third party to join a Group requires that this third party consents to it by creating their own Account and accepting these terms. The invitation may be passed on by you or, at your request, sent by the application itself in the form of an invitation email, within the limit of five (5) sendings per Account per twenty-four-hour period (anti-abuse measure): the third party's email address is then used only for that sending and is neither retained nor logged beyond what is technically necessary for the sending (see the Privacy Policy), and the content of that email is strictly limited to the invitation. Referral. When a User joins a Group for the first time by means of an invitation code, a referral credit (1 credit) is offered both to that User (the "referred user") and to a member of the Group joined (the "referrer": the longest-standing member who has not yet made a referral). Each Account may benefit from the referral scheme only once as referrer and once as referred user; the two credits are awarded together or not at all — if no member of the Group joined is still able to refer, or if the newcomer has already been referred, no credit is awarded (anti-abuse measure). Referral credits follow the rules applicable to Bonus credits (Article 6.3). Users who mention third parties in their conversations are invited to consult the Privacy Policy, which describes the processing of data concerning third parties.

Article 5 — Acceptance and modification of the GTU/GTS

5.1 Acceptance. The GTU/GTS are accepted by clicking a dedicated checkbox, never pre-ticked, when the Account is created and with each order. GHIC archives the accepted version and the timestamp of acceptance, and makes the GTU/GTS available in a manner that allows their retention and reproduction (Article 1127-1 of the French Civil Code).

5.2 Modification. GHIC may modify these terms for a legitimate reason (evolution of the Service, legal or regulatory changes, changes in the costs of artificial intelligence providers, security). Any modification is subject to prior individual notification (email and/or notification in the application) at least 30 days before it comes into force. If you refuse the modification, you may close your Account before that date: unused Purchased credits are then refunded to you (Article 13). Modifications never apply retroactively, nor to credits already purchased (Articles R212-1, 3° and R212-2, 6° of the French Consumer Code).

Article 6 — Credits and prices

6.1 Operation. The Service operates with prepaid credits: 1 credit = €1 including all taxes (VAT at the rate of 20% included). Credits are consumed progressively according to the actual use of the artificial intelligence (the cost depends on the length of conversations and the features used). Your credit balance and the detailed history of your consumption may be consulted at any time in your Account. An indicative consumption schedule is also available in "My account → My credits" (feature in place since 5 July 2026): as orders of magnitude, an exchange with Vinca represents approximately 0.01 to 0.08 credit; a two-person session, approximately 0.02 to 0.08 shared credit; a voice message, approximately 0.01 credit per minute; a translation, less than 0.01 credit; a memory operation or a guided test, approximately 0.01 to 0.05 credit. These amounts are indicative, including all taxes; the actual charge, calculated according to usage, is visible line by line in the consumption history (Article L112-1 of the French Consumer Code).

6.2 Packs. The packs available as at the date of these terms are:

Prices are displayed in euros, including all taxes, at each step of the purchase process (Articles L112-1 et seq. of the French Consumer Code; Order of 3 October 1983).

6.3 Bonus credits. Credits exceeding the price paid (as well as the 2 welcome credits offered upon registration and the referral credits of Article 4.3) are Bonus credits: offered without financial consideration, they are consumed as a priority and are never refundable, nor convertible into money. Credits received as a gift (Article 6.7) follow the same rules in the Recipient's hands. In the event of a refund of a purchase (withdrawal, closure of the Account), the Bonus credits attached to that purchase are cancelled.

6.4 Period of validity. Credits have no expiry date: they remain available for as long as the Account exists.

6.5 Balance exhausted. When the credit balance is exhausted, the artificial intelligence features of the Service are suspended until the next top-up. Access to the Account, to the conversation history and to the management features (export, deletion, refund) remains open: exhausting the balance does not result in the loss of any data.

6.6 Modification of prices. GHIC may change the price of packs and the terms of credit consumption for the future only, with the prior notice provided for in Article 5.2. Credits already purchased are never affected by a price change.

6.7 Credit gift — credits given to a third party. You may purchase one of the packs listed in Article 6.2 for the benefit of another User (feature in place since 19 July 2026). The Credit gift is subject to the following rules:

• Designation of the Recipient. The Recipient is designated by the email address associated with their Vinca Account; a gift may only be addressed to an existing active Account. In order not to reveal to third parties the existence — or absence — of an Account associated with an address, verification of the address entered is limited to five (5) verifications per Account per twenty-four-hour period; beyond that, the application gives a neutral response, which does not indicate whether the address corresponds to an Account (an anti-abuse measure protecting the data of other users).
• Crediting of the entire pack to the Recipient. The entirety of the pack — both the credits corresponding to the price paid and the bonus credits included in the pack — is credited to the Recipient in the form of credits received as a gift, which follow the rules applicable to Bonus credits (Article 6.3): they are consumed as a priority and are, in the Recipient's hands, never refundable or convertible into money. The Giver receives no credit in respect of the gift.
• Transparency towards the Recipient. The email address of the Giver's Account is frozen at the time of the gift and presented to the Recipient, in the application, when they next log in: the Recipient always knows who the gift comes from; no anonymous gift is possible (the corresponding data processing is described in the Privacy Policy).
• Non-transferability. Credits received as a gift are attached to the Recipient's Account: they may not be transferred onwards, returned to the Giver, or exchanged or assigned.
• Order and invoice. The order follows the process set out in Article 7: order summary, validation by the "order with obligation to pay" button, confirmation by email on a durable medium. The invoice is issued in the name of the Giver, who alone is liable for the price.
• Finality. The gift is final as soon as the credits are delivered to the Recipient, which takes place immediately after payment; the consequences for the Giver's right of withdrawal are described in Article 9.5.

6.8 Subscription Plans (optional). In addition to the packs, you may subscribe to a Plan (feature in place since 25 July 2026), which delivers a quota of credits to your Account every month:

The Plan is governed by the following rules:

• Monthly delivery, including for the yearly Plan. The quota is credited month by month, on the anniversary date; the yearly Plan never delivers twelve months of credits at once.
• Capped carry-over. Unused Plan credits carry over to the following month, up to one month of quota (the balance of Plan credits can therefore never exceed two months of quota). The monthly delivery is reduced accordingly when this cap is reached.
• Status of Plan credits. Credits delivered under a Plan are consumed after Bonus credits and before Purchased credits; they are never refundable nor convertible into money, including upon closure of the Account. They do not expire and remain yours after termination of the Plan.
• Tacit renewal and information. The Plan renews tacitly at each term (monthly or yearly). In accordance with Articles L215-1 to L215-3 of the French Consumer Code, for the yearly Plan, GHIC informs you in writing, at the earliest three months and at the latest one month before the term, of your right not to renew it.
• Termination at any time, in three clicks. You may terminate your Plan at any time, without reason and free of charge, from "My account → My credits", via an easy, direct and permanent access feature (Article L215-1-1 of the French Consumer Code). Termination takes effect at the end of the period already paid: deliveries already made remain yours, no further payment is taken, and the current period is not refunded (subject to the right of withdrawal in Article 9.6).
• Payment failure. If a payment fails, monthly deliveries are suspended; the Plan is terminated if the situation is not remedied within a reasonable time. Your existing credit balance is never affected.
• One Plan at a time. An Account may hold only one active Plan; changing Plans requires terminating the first (the change takes effect at the end of the paid period). The packs of Article 6.2 remain available for purchase at any time, with or without an active Plan.
• Prices for the future. Article 6.6 applies to Plans: a price change applies only to future periods, after prior notice, and you may terminate before it takes effect.

Article 7 — Order and payment

7.1 Pre-contractual information. Before any purchase, GHIC provides you with the information required by Articles L221-5 to L221-7 of the French Consumer Code: essential characteristics of the Service, price incl. tax, payment terms, existence and terms of the right of withdrawal, legal guarantees, duration of the contract and conditions for termination, recourse to the consumer mediator.

7.2 Order process. The order is placed in the application: choice of pack, order summary (pack, price incl. tax, credited credits), possibility of correcting errors, then validation by a button bearing the clear and legible wording "order with obligation to pay" (Article L221-14 of the French Consumer Code). An order confirmation setting out all the information, including, where applicable, your request for immediate performance (Article 9), is sent to you by email on a durable medium (Article L221-13).

7.3 Payment. Payment is processed by Stripe, a payment service provider, with strong authentication where required (Directive (EU) 2015/2366 "PSD2"). Your bank card details never pass through GHIC and are not stored by GHIC.

7.4 Supporting documents. An invoice (receipt) is issued for any purchase, including for automatic top-ups, and accessible from "My account → Purchases & invoices" in the form of a page that can be printed and saved in PDF format ("Print / Save as PDF" button); each invoice bears a unique number (format VIN-AAAAMMJJ-XXXXXX), the Publisher's details (GHIC, SIREN, intra-Community VAT FR06939603593) and the breakdown excl. tax / VAT 20% / incl. tax (feature in place since 5 July 2026). It is in any event delivered before payment for any service of an amount greater than or equal to €25 incl. tax (Order No. 83-50/A of 3 October 1983). GHIC keeps a copy for the legal period.

Article 8 — Automatic top-up (optional)

8.1 Automatic top-up is an option, deactivated by default, which requires your express consent, separate from acceptance of these terms, collected by a dedicated checkbox that is never pre-ticked and timestamped:

☐ "I activate automatic top-up: when my balance falls below 1 credit, my registered means of payment will be charged €10 incl. tax for the purchase of a pack of 11 credits (10 purchased credits + 1 bonus credit). At most one top-up attempt per 6-hour period will be made. I can deactivate automatic top-up at any time, in one click, from my account."

Automatic top-up is furthermore capped at four top-ups (€40 incl. tax) per rolling month, in addition to the limit of one attempt per 6-hour period; this cap is enforced by the application, which never attempts a top-up beyond it.

8.2 Each automatic top-up gives rise to a notification and a receipt by email, as well as a downloadable invoice in your Account. Deactivation is possible at any time from your Account, as simply as activation, and takes effect immediately. Closing the Account, like the termination provided for in Article 13, automatically puts an end to automatic top-up.

8.3 Automatic top-up does not constitute a subscription: no amount is charged if you do not use the Service. It is based on the express consent provided for in Articles 1127-2 of the French Civil Code and L221-14 of the French Consumer Code.

Article 9 — Right of withdrawal

9.1 Principle. You have a period of fourteen (14) days from the purchase of a pack of credits to exercise your right of withdrawal, without having to give reasons for your decision (Article L221-18 of the French Consumer Code). In the absence of proper information on this right, the period would be extended by twelve months (Article L221-20). Articles 9.1 to 9.4 apply subject to the special rules governing the Credit gift (Article 9.5).

9.2 Immediate performance and pro rata refund. To use your credits without waiting for the withdrawal period to expire, you are offered, at the time of purchase, the option of expressly requesting the immediate performance of the Service, by means of a dedicated checkbox, never pre-ticked, separate from acceptance of these terms:

☐ "I expressly request that the provision of the service and access to my credits begin immediately, before the end of the 14-day withdrawal period. In the event of withdrawal, I will be refunded pro rata for the unused purchased credits, with the bonus credits offered being cancelled."

This request is set out in the order confirmation email and its timestamped proof is retained by GHIC.

9.3 Withdrawal clause. You have a period of fourteen (14) days from the purchase of a pack of credits to exercise your right of withdrawal, without reason, via the "Withdraw from the contract here" function available in your Account, the standard form attached in Appendix 1 or any unambiguous statement addressed to contact@vinca.chat or to GHIC's registered office. If you have requested the immediate performance of the Service, you remain liable, in accordance with Article L221-25 of the French Consumer Code, for an amount proportional to the credits consumed up to the communication of your withdrawal decision. The refund of unused Purchased credits takes place within 14 days of receipt of your decision, to the means of payment used at the time of purchase. The Bonus credits offered are cancelled.

9.4 Online withdrawal function. In accordance with the articles resulting from Order No. 2026-2 and Decree No. 2026-3 (applicable since 19 June 2026), an online withdrawal function, free of charge, bearing the wording "Withdraw from the contract here", is accessible in your Account during the fourteen-day period following each purchase (one request per purchase). Its exercise triggers the calculation of the pro rata refund provided for in Article L221-25 (unused purchased credits; the bonus credits attached to the purchase are cancelled), the immediate recording of the refund in the credits register, its execution to the original means of payment via Stripe, and an acknowledgement of receipt without delay, on a durable medium (email) mentioning the date and time of receipt. This function has been in place in the application since 5 July 2026; the processing of each request is traceable by GHIC. Purchases made by way of a Credit gift are not eligible for this function, for the reasons set out in Article 9.5.

9.5 Credit gift: immediate performance for the benefit of the third party and waiver of the right of withdrawal. In the case of the Credit gift (Article 6.7), the service consists of crediting the pack immediately and in full to the Recipient you have designated: upon that delivery, the service is fully performed, for the benefit of the third party, before the end of the withdrawal period. In accordance with Article L221-28, 1° of the French Consumer Code, the right of withdrawal may not be exercised in respect of a supply of services fully performed before the end of the withdrawal period where — the contract placing you under an obligation to pay — performance began with your prior express agreement and with your acknowledgement of the loss of your right of withdrawal once the contract has been fully performed by the professional. This agreement, this acknowledgement and this waiver are collected at the time of purchase, by means of a dedicated checkbox, never pre-ticked, separate from acceptance of these terms; as deferred delivery of the credits is not offered, they are a condition for placing a Credit gift order:

☐ "I expressly request that the pack I am giving be credited immediately and in full to the recipient I have designated, before the end of the 14-day withdrawal period. I acknowledge that once the credits have been delivered to the recipient, the service will have been fully performed and that I will lose my right of withdrawal, which I expressly waive for this purchase (Article L221-28, 1° of the French Consumer Code)."

This request and this waiver are set out in the order confirmation email and their timestamped proof is retained by GHIC. Consequently, the "Withdraw from the contract here" function (Article 9.4) is not offered for Credit gift purchases: this exclusion prevents a Giver from being refunded while the Recipient would keep the credits given. The waiver relates only to the right of withdrawal: it deprives the Giver of no other right — the legal guarantees (Article 10), complaints to customer service (contact@vinca.chat, Article 17.1) and consumer mediation (Article 17.2) remain fully open, in particular if the gift has not been performed in accordance with these terms (credits not delivered to the Recipient, malfunction attributable to the Service).

9.6 Withdrawal and subscription Plans. The fourteen (14) day period of Article 9.1 runs from the subscription to a Plan (Article 6.8). By subscribing, you expressly request immediate performance of the service: the first monthly delivery of credits is available upon payment. If you withdraw within the period, the Plan is ended and the price paid is refunded to you, less the value of the credits of the current delivery already consumed (€1 incl. VAT per credit consumed), in accordance with Article L221-25 of the French Consumer Code. The right of withdrawal attaches to the conclusion of the contract: subsequent tacit renewals do not open a new withdrawal period; you retain, at any time, the three-click termination right of Article 6.8.

Article 10 — Legal guarantees

10.1 Legal guarantee of conformity. The Service is a digital service supplied on a continuous basis within the meaning of Articles L224-25-1 et seq. of the French Consumer Code. You benefit from the legal guarantee of conformity throughout the entire period of supply of the Service: GHIC is required to provide a service that conforms to the description in Article 3.1 and to these terms, as well as the updates necessary to maintain this conformity. In the event of a lack of conformity, you are entitled, free of charge: first to the bringing into conformity of the Service without undue delay; failing that, to a reduction in price or to the rescission of the contract (with refund). This guarantee may neither be excluded nor limited. The mandatory information box (Article D211-3 of the French Consumer Code) appears in Appendix 2.

10.2 Guarantee against hidden defects. You also benefit from the legal guarantee against hidden defects (Articles 1641 to 1649 of the French Civil Code), which makes it possible to obtain a reduction in price or a refund.

10.3 Modifications of the Service. GHIC may modify the Service beyond what is necessary to maintain its conformity, for a legitimate reason and at no additional cost to you. You will be informed of this in a clear and comprehensible manner and, if the modification has a negative impact on your use of the Service, you may terminate the contract free of charge within thirty days and obtain a refund of unused Purchased credits (Article L224-25-27 of the French Consumer Code).

Article 11 — Safety and crisis situations

11.1 Vinca is not an emergency service and cannot alert the emergency services on your behalf. In the event of a crisis, suicidal thoughts or immediate danger, contact:

• 3114 — national suicide prevention number (free, 24/7);
• 15 (SAMU) or 112 — life-threatening emergency;
• 3919 — Violences Femmes Info (domestic violence within the couple).

If you are using the Service from another country, the application permanently displays the helplines and emergency numbers corresponding to your country; failing that, contact the local emergency services.

11.2 Vinca's behaviour incorporates a crisis protocol: when a situation of serious distress is detected, Vinca systematically directs you to a healthcare professional or emergency services, and expressly recommends consulting a doctor in any critical situation. These safeguards do not replace your own vigilance or that of your loved ones.

11.3 The Service is not designed for the situations described in Article 3.3 (suicidal crisis, severe psychiatric disorders, situations of violence). Its use in these situations in no way exempts you from resorting to the competent professionals and services.

Article 12 — User obligations and acceptable use

The User undertakes to:

• use the Service for strictly personal and non-commercial purposes;
• not resell, rent or share access to the Service or the credits — the Credit gift made through the application's dedicated feature (Article 6.7) is not covered by this prohibition;
• not carry out mass extraction of the Service's content (scraping), not seek to extract, reproduce or misappropriate the Service's artificial intelligence models or instructions (prompts), and not develop a competing service from the Service;
• not circumvent security, limitation or billing measures;
• not use the Service to harass, threaten or harm others, nor to create, obtain or distribute unlawful content — in particular any attempt to generate content of a sexual nature involving minors or targeting a non-consenting person, which will give rise to immediate termination and, where applicable, to a report to the authorities;
• not impersonate a third party or create an account on behalf of a third party without their consent.

Article 13 — Suspension and termination

13.1 Termination by the User. You may close your Account at any time, without reason and free of charge, from the "My account" section, via an easy, direct and permanent access termination feature compliant with Article L215-1-1 of the French Consumer Code ("termination in 3 clicks"). Closure is subject to a double confirmation, then a confirmation of its effective date on a durable medium (email). It entails:

• the immediate and permanent deletion of your conversations, Memories and analyses, and the anonymisation of the Account (see the Privacy Policy — cryptographic erasure by destruction of the encryption key);
• the refund of unused Purchased credits, to the original means of payment, within a maximum period of 14 days; the Bonus credits and the credits received as a gift are cancelled;
• the automatic deactivation of automatic top-up;
• the retention of billing data and payment records only for 10 years (accounting obligation, Article L123-22 of the French Commercial Code).

13.2 Suspension and termination by GHIC. GHIC may suspend or terminate an Account only in the event of the User's breach of one of the obligations listed in Articles 4 and 12, or in the event of a legal obligation. Except in the event of a breach of particular gravity (in particular security, unlawful content, payment fraud), the suspension or termination is preceded by a reasoned warning sent by email, together with a reasonable period for bringing into conformity. Termination is notified in writing and reasoned. In all cases, including in the event of termination for breach, unused Purchased credits are refunded, without prejudice to the damages that GHIC may claim in the event of serious misconduct (Articles R212-1, 8° and 9°, and R212-2, 4° of the French Consumer Code).

13.3 Termination, whatever its origin, puts an end to automatic top-up and does not affect the rights and obligations arising previously, in particular the right to a refund provided for above and the accounting retention obligations.

13.4 Subscription Plan and closure. Closing the Account (Article 13.1), like termination by GHIC (Article 13.2), immediately ends any subscription Plan: no further payment is taken. The period already paid is not refunded (subject to Article 9.6); Plan credits, which are never refundable, are cancelled with the Account.

Article 14 — Intellectual property

14.1 Elements of the Service. The Service, its code, its interface, its graphic elements (pixel art, landscapes, characters), its trademark and its domain name are protected by intellectual property law and remain the exclusive property of GHIC or its licensors. GHIC grants you a personal, non-exclusive, non-assignable and non-transferable licence to use the Service, limited to the use of the Service in accordance with these terms, for the duration of your Account.

14.2 Your content. Your messages, conversations and Memories belong to you. You grant GHIC a licence strictly limited to what is necessary for the provision of the Service: hosting, encryption, transmission to the artificial intelligence providers (Anthropic for generating responses, OpenAI for voice transcription only) for the duration of processing, backup and display in your Account and, where applicable, in your Group. This licence is granted worldwide (technical necessity of hosting and processing), for the sole duration of your Account's existence, and ends with the deletion of your content. Your conversations and Memories are never used to train artificial intelligence models, neither by GHIC nor by its providers (contractual commitment of the APIs used); any change on this point would require your prior, separate and explicit consent.

14.3 Generated responses. The responses generated by Vinca are provided to you for your personal use. GHIC guarantees neither their originality nor the absence of similarity with content provided to other users, since generation is based on statistical models.

Article 15 — Liability

15.1 GHIC undertakes to provide the Service with diligence and in accordance with these terms; the provision of the Service constitutes an obligation of means, given the probabilistic nature of the artificial intelligence technologies described in Article 3.

15.2 The limitations inherent in the Service — the generated and potentially inaccurate nature of the responses, the absence of medical or professional value, unsuitability for crisis situations — are described in Articles 3 and 11: they define the subject matter of the contract and the level of quality that you may legitimately expect.

15.3 GHIC makes reasonable efforts to ensure the availability of the Service, without guaranteeing uninterrupted availability; scheduled maintenance operations are, as far as possible, announced in advance. GHIC cannot be held liable in the event of force majeure (Article 1218 of the French Civil Code), of fault by the User (in particular use contrary to Articles 3.3, 4 and 12) or of an act of a third party beyond GHIC's control.

15.4 Nothing in these terms excludes or limits GHIC's liability in the event of fault, nor the rights that you hold under the law, in particular the legal guarantees (Article 10) and the law of liability.

Article 16 — Personal data

The processing of your personal data — including data relating to health and sexual life that you may entrust to Vinca, processed on the basis of your explicit consent (Article 9.2.a of the GDPR), collected by a dedicated checkbox at registration — is described in the Privacy Policy, a separate document accessible from all pages of the Service.

In summary: your conversations and Memories are encrypted (AES-256-GCM, one encryption key per user and per group) and stored in Paris (European Union); the encryption protects the data at rest but is not end-to-end encryption — the server decrypts the content for the time necessary to query the artificial intelligence models; your private Memories are never revealed as such in a Group (only "distilled" guidance, without identifiable facts, contributes to it); your data is never sold or used for advertising purposes, and does not serve to train AI models; you have the rights of access, rectification, erasure, portability, objection and withdrawal of consent, exercisable in the application or at the address contact@vinca.chat, as well as the right to define directives relating to the fate of your data after your death (Article 85 of French Law No. 78-17 of 6 January 1978) and the right to lodge a complaint with the CNIL (www.cnil.fr).

Article 17 — Complaints and consumer mediation

17.1 Customer service. For any question or complaint, first contact GHIC's customer service: contact@vinca.chat or by post to GHIC, 60 rue François 1er, 75008 Paris, France. GHIC endeavours to respond to any complaint within a period of 30 days (period set on 5 July 2026).

17.2 Mediation. In accordance with Articles L612-1 et seq. of the French Consumer Code, you have the right to have recourse free of charge to a consumer mediator with a view to the amicable resolution of any dispute between you and GHIC. You must first have addressed a written complaint to our customer service (contact@vinca.chat or GHIC, 60 rue François 1er, 75008 Paris). In the absence of a satisfactory response within the period indicated in Article 17.1, or in the absence of a response, you may refer the matter, within a period of one year from your written complaint, to the following mediator:

SAS Médiation Solution 222 chemin de la bergerie, 01800 Saint Jean de Niost, France Website (online referral): https://sasmediationsolution-conso.fr Email: contact@sasmediationsolution-conso.fr — Telephone: 04 82 53 93 06

Referral procedures: by submitting your request directly online on the mediator's website (referral form), or by postal mail to the address above. Consumer mediation is free for the consumer.

Article 18 — Applicable law and jurisdiction

These GTU/GTS are governed by French law. If you reside in another Member State of the European Union, you retain the benefit of the more protective mandatory provisions of the law of your country of habitual residence (Article 6 of Regulation (EC) No. 593/2008 "Rome I").

In the event of a dispute and failing amicable resolution, you may refer the matter, at your choice, to one of the courts having territorial jurisdiction under the French Code of Civil Procedure, or to the court of the place where you resided at the time of the conclusion of the contract or of the occurrence of the harmful event (Article R631-3 of the French Consumer Code). These terms contain no jurisdiction clause or mandatory arbitration clause.

Exception: Article 18.1 below applies to residents of the United States of America only.

18.1 — Residents of the United States of America only

This Article 18.1 applies solely to persons whose habitual residence is in the United States of America. It does not apply to consumers residing in the European Union, the European Economic Area, the United Kingdom or Switzerland, whose rights under the preceding paragraphs of Article 18 are unaffected.

(a) Informal resolution first. Before commencing any arbitration, you agree to send a written description of the dispute to contact@vinca.chat and to allow GHIC 60 days to resolve it informally. This period does not shorten any limitation period.

(b) Individual arbitration. If the dispute is not resolved, it shall be settled by binding individual arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules, rather than in court. The arbitration shall be conducted by a single arbitrator, in the English language, by written submissions or videoconference unless the arbitrator determines a hearing is necessary. Judgment on the award may be entered in any court of competent jurisdiction. The Federal Arbitration Act governs the interpretation and enforcement of this provision.

(c) Waiver of class actions. You and GHIC agree that each may bring claims against the other only in an individual capacity, and not as a plaintiff or class member in any purported class, collective, consolidated or representative proceeding. The arbitrator may award relief only in favour of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party's individual claim.

(d) Small claims. Either party may instead bring an individual claim in a small claims court of competent jurisdiction, provided the claim remains in that forum and on an individual basis.

(e) Public injunctive relief. Nothing in this Article waives any right you may have to seek public injunctive relief where such a waiver would be unenforceable under applicable law. Any claim for public injunctive relief shall be severed and stayed pending the outcome of the arbitration.

(f) Your right to opt out. You may reject this Article 18.1 by sending written notice to contact@vinca.chat, stating your name and the email address of your account, within 30 days of first accepting these terms in a version containing this Article. An opt-out is free, has no effect on your use of the Service, and leaves the remainder of these terms in force.

(g) Severability. If paragraph (c) is found unenforceable as to a particular claim or remedy, that claim or remedy shall be severed and brought in court, while all remaining claims proceed in arbitration. If this Article 18.1 is found unenforceable in its entirety, the preceding paragraphs of Article 18 apply.

(h) Not a healthcare service. Nothing in these terms creates a therapist–patient, physician–patient or other professional relationship. The Service is not a healthcare service, employs no licensed practitioners, and does not diagnose or treat any condition. Communications with the Service are protected by the data-protection measures described in our Privacy Policy, and are not subject to any professional privilege or confidentiality of medical records.

Appendix 1 — Standard withdrawal form

*(Form provided for in the appendix to Article R221-1 of the French Consumer Code. Please complete and return this form only if you wish to withdraw from the contract. You may also use the "Withdraw from the contract here" function of your Account, which is faster.)*

For the attention of GHIC (Global Human Intelligence Consulting), 60 rue François 1er, 75008 Paris, France — contact@vinca.chat:

I hereby notify you of my withdrawal from the contract relating to the provision of services below:

— Purchase concerned (pack of credits and amount): ______________________________

— Ordered on: ______________________________

— Email address of the Vinca account: ______________________________

— Name of the consumer: ______________________________

— Address of the consumer: ______________________________

— Signature of the consumer (only in the event of notification of this form on paper): ______________________________

— Date: ______________________________

Appendix 2 — Information box on legal guarantees (Article D211-3 of the French Consumer Code)

*The consumer benefits from the legal guarantee of conformity for the Vinca digital service throughout the entire period of supply of the service. During this period, the consumer is only required to establish the existence of the lack of conformity, and not the date of its appearance.*

*The legal guarantee of conformity entails an obligation to provide all the updates necessary to maintain the conformity of the service.*

*It gives the consumer the right to the bringing into conformity of the service without undue delay, free of charge and without major inconvenience. Failing that, the consumer may obtain a reduction in price or the rescission of the contract, under the conditions provided for in Articles L224-25-1 et seq. of the French Consumer Code.*

*The consumer also benefits from the legal guarantee against hidden defects (Articles 1641 to 1649 of the French Civil Code), which enables them to obtain a reduction in price or a refund of the price in return for renouncing the service.*