This is an English courtesy translation. The Spanish version (Términos y condiciones) is the legally binding text and prevails in case of any discrepancy.

Terms and conditions

Last updated: 4 July 2026

These Terms of Use and Purchase govern access to, registration with, use of and purchase of the services offered through the Novelingo Studio platform, available on the website novelingostudio.com and, where applicable, on its subdomains, applications, test environments or associated services.

Use of Novelingo Studio implies acceptance of these Terms. If you do not agree to them, you must not register with or use the platform.

1. Service provider

The owner of Novelingo Studio is:

NOVELINGO, S.L.
Registered office: Avenida Sor Teresa Prat 15, 29003 Málaga
NIF/CIF (Spanish tax identification number): B44628329
Registered in the Málaga Commercial Registry (Registro Mercantil de Málaga), volume 6293, folio 106, sheet MA-172402, entry 1
Contact email: info@novelingo.com
Website: novelingostudio.com

Hereinafter, Novelingo, Novelingo Studio, the platform, we or the provider.

2. What Novelingo Studio is

Novelingo Studio is a no-code SaaS platform with artificial intelligence assistance that allows users to create, edit, publish and export interactive experiences, serious games, simulations, training content, interactive narratives and other digital resources.

The platform may include, among other features:

• creation of projects and interactive experiences;
• assisted generation of structure, narrative, scenes, dialogues, questions, answers and resources;
• editing and review of generated content;
• publication via link, QR code, PWA or other formats;
• SCORM export where available;
• management of credits, usage limits and plans;
• access to demos, tutorials, templates or examples;
• augmented reality features or other interactive formats;
• basic usage, completion or interaction metrics, if enabled.

Novelingo Studio does not replace the user's professional, pedagogical, legal, technical, medical, preventive or compliance judgement. The platform is a creation and support tool, not an automatic content validation system.

3. Who the service is aimed at

Novelingo Studio is aimed primarily at companies, training bodies, consultancies, institutions, museums, schools and colleges, cultural organisations, public administrations, and training, communications, human resources, compliance, occupational risk prevention (PRL), cybersecurity and outreach teams, as well as other professional users.

The platform is not aimed at minors. Minors may use experiences created with Novelingo Studio only under the responsibility of the school, body, company, family, legal guardian or responsible adult organising the activity.

4. Acceptance of the Terms

By registering with, accessing or using Novelingo Studio, you declare that:

• you have read and accept these Terms;
• you have sufficient legal capacity to accept them;
• if you act on behalf of a company, body or institution, you have sufficient authority to bind it;
• you will use the platform in accordance with the law, good faith and these Terms;
• you will provide truthful, up-to-date and complete information whenever it is needed for use or purchase of the service.

Novelingo may request additional confirmation if it detects professional, institutional or business use of the platform.

5. Registration and user account

To use certain features of Novelingo Studio, it may be necessary to create an account or identify yourself by email.

Access may be provided through passwordless systems, temporary codes sent by email or other methods enabled by Novelingo.

The user is responsible for:

• using a valid email address;
• keeping control of their account;
• not sharing access with unauthorised persons;
• notifying Novelingo if they suspect unauthorised access;
• ensuring that the people in their organisation who access the platform are authorised to do so.

Novelingo may block, restrict or suspend an account if it detects fraudulent or abusive use, use contrary to these Terms, or use that could compromise the security of the platform.

6. Free trial, demos and initial credits

Novelingo Studio may offer free access, demos, initial credits or test environments so that users can get to know how the platform works.

The free trial does not entail any obligation to subscribe or purchase afterwards.

Free credits:

• may be subject to usage limits;
• may be subject to expiry;
• may vary depending on campaigns, promotions or agreements;
• cannot be exchanged for money;
• are not transferable without Novelingo's express authorisation;
• may be withdrawn if abusive or fraudulent use, or use contrary to these Terms, is detected.

Novelingo may modify, suspend or cancel free trials whenever it considers it necessary for technical, commercial or security reasons, or because of abuse of the service.

7. Credits, consumption and usage limits

Novelingo Studio may operate through a system of credits, licences, plans, usage packages or similar arrangements.

Credits may be used, among other purposes, to:

• generate stories, scenes, dialogues, questions or content;
• create or transform resources;
• use AI functions;
• publish, export or process certain experiences;
• access specific features of the platform.

Credit consumption may vary depending on the feature used, the volume of content, the use of AI, the type of resource generated or the terms of the plan purchased.

Unless the offer, contract or commercial proposal states otherwise:

• credits are non-refundable once consumed;
• credits do not guarantee any specific result;
• credits are not electronic money or a means of payment;
• credits may not be resold or transferred to third parties;
• Novelingo may set reasonable limits to prevent abuse, disproportionate costs or unintended uses.

Specific information on credits, expiry, limits, prices and included features will be set out on the platform, in the commercial proposal or in the applicable contractual documentation.

8. Plans, licences and paid services

Novelingo may offer different purchase arrangements, including:

• licence to use Novelingo Studio;
• purchase of credits;
• paid first experience or pilot;
• assisted creation of experiences;
• adaptation, scriptwriting, narrative, design or support services;
• bespoke experiences;
• specific support;
• plans for teams, bodies, schools and colleges, companies or partners;
• enterprise terms under a specific proposal.

Each arrangement may have its own prices, limits, duration, features, support and terms.

In the event of any conflict between these Terms and a commercial proposal signed or accepted by the customer, the commercial proposal will prevail in respect of whatever it expressly regulates.

9. Electronic purchase process

Where the purchase is made through the website or platform, the user must follow the steps indicated at the time.

Before confirming the purchase, the user may review the data entered, correct errors and consult the applicable terms.

Once the process is complete, Novelingo may send a confirmation by email or equivalent means.

Contracts may be formalised in Spanish, unless Novelingo expressly enables other languages.

Novelingo may retain electronic evidence of the purchase, acceptance of terms, accepted proposal, use of credits, invoicing, communications and any other elements needed for contractual, administrative, tax, technical and legal management.

10. Prices, taxes and invoicing

Prices will be those stated on the website, platform, quotation, commercial proposal, contract or equivalent document.

Unless expressly stated otherwise, prices do not include VAT (IVA) or other applicable taxes.

The user must provide truthful and up-to-date invoicing details.

Novelingo may issue electronic invoices where legally required or where the customer agrees.

Non-payment for services, licences, credits or proposals purchased may result in:

• temporary suspension of access;
• blocking of features;
• interruption of support;
• acceleration of outstanding amounts;
• a claim for the amounts owed;
• cancellation of the contracted service.

11. Permitted use of the platform

The user undertakes to use Novelingo Studio only for lawful purposes and in accordance with these Terms.

The platform may be used to create training, educational, cultural, outreach, corporate, awareness-raising, communication, simulation, coaching, storytelling or activation experiences, provided the content is lawful and respects the rights of third parties.

The user is responsible for the content, materials, instructions, data, images, texts, trademarks, names, documents or resources that they enter, upload, generate, edit, publish or export from the platform.

12. Prohibited uses

It is prohibited to use Novelingo Studio to:

• create, publish or distribute unlawful content;
• infringe intellectual property, industrial property, image, honour, privacy or data protection rights;
• generate content that is discriminatory, demeaning, threatening, defamatory, violent, sexually explicit, fraudulent or misleading;
• impersonate identities;
• create disinformation, manipulation, deepfakes or synthetic content without transparency where legally required;
• enter personal, sensitive, health, employment, minors' or third-party data without a sufficient legal basis;
• upload third parties' confidential information without authorisation;
• generate materials that may cause harm, harassment, exclusion or unjustified detriment to individuals or groups;
• carry out reverse engineering, scraping, mass data extraction or attacks against the platform;
• attempt to access other users' accounts, projects or data;
• circumvent technical, credit, security or usage limits;
• use the platform to train external models, create competing products or replicate features without authorisation;
• use the service in a way that degrades, overloads or compromises the infrastructure.

Novelingo may remove content, suspend access or cancel accounts if it detects any of these uses.

13. User-provided content

The user retains whatever rights they legitimately hold in the content they contribute to the platform.

By uploading, entering or using content in Novelingo Studio, the user declares that they have the rights, licences, authorisations or legal bases necessary to do so.

This includes, among other things:

• texts;
• documents;
• images;
• trademarks;
• logos;
• names of companies, schools or colleges, or individuals;
• training materials;
• internal guides;
• customer content;
• content subject to copyright;
• personal data or confidential information.

The user authorises Novelingo to host, process, transform, adapt, display, generate, publish or export such content to the extent necessary to provide the contracted service.

This authorisation does not entail any transfer of ownership to Novelingo.

14. Content generated with artificial intelligence

Novelingo Studio may use artificial intelligence to assist in creating structures, scenes, dialogues, questions, answers, images, resources, translations, adaptations or content variations.

AI-generated content may contain errors, inaccuracies, biases, inconsistencies, omissions or results that are unsuitable for the user's context.

The user must review and validate the content before using, publishing, sharing, exporting or integrating it into training, educational, corporate, legal, preventive, health, financial or compliance processes.

Novelingo does not guarantee that AI-generated content is:

• accurate;
• complete;
• up to date;
• appropriate to a specific regulation;
• pedagogically sufficient;
• free of bias;
• free of potential conflicts with third-party rights;
• suitable for professional use without human review.

When the user uses the platform to generate content intended for the public, employees, students, customers, visitors or third parties, the user will be responsible for reviewing the suitability, legality, tone, accuracy and purpose of the final result.

15. Transparency about the use of AI

Where an experience, resource or piece of content has been generated or assisted by AI, the user must assess whether the recipients should be informed of this, especially when:

• the content is published for end users;
• artificially generated or manipulated images, audio or video are used;
• the end user could reasonably believe that they are interacting with a person;
• the content could influence decisions, training, assessment, awareness-raising or the perception of facts;
• the applicable regulations require specific information.

Novelingo may include notices, labels, marks, metadata or transparency mechanisms when it considers it necessary or advisable.

The user must not remove, hide or tamper with AI transparency notices if they are required by the applicable regulations or form part of the service configuration.

16. Human review and editorial responsibility

The user retains editorial responsibility for the experiences and content that they create, edit, publish, export or share through Novelingo Studio.

AI assistance does not replace human review.

The user must verify, among other things:

• the accuracy of the content;
• its suitability for the target audience;
• compliance with applicable regulations;
• respect for third-party rights;
• the absence of unnecessary personal data;
• suitability where minors are involved;
• the tone and sensitivity of the content;
• pedagogical or training coherence;
• the validity of content on PRL (occupational risk prevention), compliance, health, cybersecurity, equality, data protection or other regulated subjects.

17. Publication, links, QR codes, PWA and distribution

Novelingo Studio may allow experiences to be published via link, QR code, PWA or other formats.

The user is responsible for deciding where, how, to whom and for what purpose a published experience is distributed.

When an experience is published via link or QR code, the user must assume that anyone with access to the link or code could view it, unless specific access-restriction mechanisms have been purchased or activated.

The user must not publish confidential information, personal data, minors' data, sensitive data or internal content without having properly configured access measures and without having a sufficient legal basis.

Novelingo may remove or block published experiences if it detects legal, technical, security or reputational risks, or a breach of these Terms.

18. SCORM export and use in an LMS

Where available, Novelingo Studio may allow experiences to be exported in SCORM format or other LMS-compatible formats.

The user will be responsible for:

• checking compatibility with their LMS;
• importing the package correctly;
• configuring tracking, users, permissions and metrics;
• validating that it works before using it in production;
• ensuring that the LMS complies with the applicable regulations;
• reviewing what personal data the LMS collects and under whose responsibility.

Novelingo will not be liable for failures, limitations, incompatibilities or incorrect configurations of third-party platforms into which the user imports or on which the user runs exported content.

19. Intellectual property and rights in the content

Novelingo is the owner or licensee of all rights in the Novelingo Studio platform, including, among other things, the software, interface, design, architecture, code, features, workflows, templates, documentation, methodology, trademarks, logos, know-how, technology, databases, integrated AI systems, processes and materials proper to Novelingo Studio.

The user receives only a limited, non-exclusive, non-transferable right, revocable in accordance with these Terms, to use the platform in accordance with the applicable plan, licence, proposal or contract.

The following is prohibited:

• copying the platform;
• reproducing how it works;
• reverse engineering;
• extracting its code;
• creating a substantially equivalent product using access to Novelingo Studio;
• removing trademarks or proprietary notices;
• using Novelingo's own materials outside the service without express authorisation.

The user retains all rights in the content, materials, documents, texts, images, trademarks, logos, data, instructions or any other material that they enter, upload or provide in Novelingo Studio.

Unless specifically agreed otherwise, Novelingo does not acquire ownership of the content created by the user on the platform. The user may use, reproduce, publicly communicate, distribute, transform, publish, export and exploit the content and experiences generated in their account or project, provided that such use respects the applicable legislation, third-party rights and these Terms.

Novelingo in all cases retains ownership of the platform, software, editor, code, engine, templates, methodology, creation workflows, base prompts, generation systems, infrastructure, features, technical documentation, know-how, trademark and any pre-existing technological, creative or methodological element of Novelingo.

Where Novelingo participates in an assisted manner in creating an experience for a customer, the exploitation rights in the final content created specifically for that customer will be governed by the applicable proposal, contract or agreement. Unless expressly stated otherwise, such assignment will not include the platform, software, templates, reusable components, know-how or pre-existing elements of Novelingo.

The user warrants that they hold the necessary rights, licences, authorisations or permissions over the materials they enter into the platform. The user will be responsible for ensuring that such materials do not infringe intellectual property, industrial property, image, honour, privacy, confidentiality or data protection rights, or any other third-party rights.

The user grants Novelingo a limited, non-exclusive, royalty-free licence, to the extent necessary, to host, process, generate, edit, store, publish, export, maintain, secure and support the content within the normal operation of the service.

Novelingo will not use customers' private content to train artificial intelligence models without express authorisation.

Novelingo will not publish, disseminate or use the user's private experiences as a case study, commercial demo or promotional material without prior authorisation, unless the content has already been voluntarily published by the user in a public environment.

The user accepts that content generated by artificial intelligence systems may not be exclusive or unique, nor free of similarities with content generated for other users or by third parties. Novelingo does not guarantee that all automatically generated content can be protected as an original work or that it is suitable for any use without prior human review.

20. Rights in the experiences created

Unless otherwise agreed in writing, the user will retain the rights in their own content that they have contributed to the platform.

With respect to the experiences generated in Novelingo Studio:

• the user may use them in accordance with the applicable plan, licence, proposal or contract;
• Novelingo will retain the rights in the platform, engine, tools, templates, technical structure and reusable components;
• the user acquires no rights in the software or in internal elements of the platform;
• Novelingo's generic components, templates, mechanics, structures, workflows and resources may be reused in other projects without this constituting a copy of the user's specific content.

If an experience is developed as a bespoke service, first experience, pilot or specific project, ownership and rights of use must be specified in the corresponding commercial proposal or contract.

21. Use of content for AI training

Novelingo will not use customers' private content to train its own or third-party models without express authorisation, unless the data is anonymised, aggregated or usage metrics that do not allow the customer, end user or specific content to be identified, and always in accordance with the applicable regulations.

Novelingo may use technical information, aggregated metrics, usage statistics, incidents, general interaction patterns and non-confidential feedback to improve the platform, fix errors, strengthen security, optimise features and develop new capabilities.

22. Personal data and data protection

The processing of personal data is governed by the Novelingo Studio Privacy Policy, available on the website.

The user must read and accept the Privacy Policy before using the platform where necessary.

If the user uses Novelingo Studio to enter, upload, generate, process or publish third parties' personal data, the user will be responsible for having an appropriate legal basis and for complying with the applicable regulations.

This includes, among others, data of:

• employees;
• students;
• minors;
• customers;
• end users;
• visitors;
• participants in activities;
• professional contacts;
• vulnerable groups.

If Novelingo processes personal data on behalf of a customer, both parties must, where applicable, enter into a data processing agreement or data processing annex.

The user must not enter sensitive or specially protected personal data unless strictly necessary, there is a sufficient legal basis and the applicable measures have been agreed beforehand.

23. Minors

Novelingo Studio is not directly aimed at minors.

If an educational, cultural, social, sports, public or private body uses experiences created with Novelingo Studio with minors, that body will be responsible for:

• obtaining the necessary authorisations;
• informing families, guardians or legal representatives where applicable;
• avoiding unnecessary collection of personal data;
• reviewing the age-appropriateness of the content;
• ensuring a safe environment;
• complying with the applicable education, data protection, child protection and digital rights regulations.

Novelingo may recommend minimum-data-collection configurations for experiences aimed at minors.

24. Confidentiality

The user must not upload to the platform third parties' confidential information without sufficient authorisation.

Novelingo will treat users' and customers' private information with reasonable confidentiality and security measures.

In B2B projects, pilots, first experiences, enterprise agreements or bespoke work, the parties may sign specific confidentiality agreements.

The following will not be considered confidential information:

• information that is public;
• information that was already lawfully known to the other party;
• information that has been lawfully obtained from third parties;
• information that must be disclosed by legal, judicial or administrative obligation.

25. Platform security

Novelingo will apply reasonable technical and organisational measures to protect the platform, accounts and the data processed.

However, no digital system can guarantee absolute security.

The user must help maintain security through responsible use of the account, the access email address, internal permissions, published links and shared content.

Novelingo may make technical changes, reviews, updates, preventive blocks or temporary suspensions when necessary to protect the security, availability or integrity of the service.

26. Availability, maintenance and changes to the service

Novelingo will endeavour to keep the platform available, stable and functional.

However, the platform may be affected by:

• maintenance tasks;
• updates;
• technical failures;
• provider incidents;
• connectivity problems;
• cyberattacks;
• abusive use;
• force majeure;
• changes to AI services or integrated third-party services.

Unless a specific service level agreement has been signed with the customer, Novelingo does not guarantee continuous, uninterrupted or error-free availability.

Novelingo may modify, improve, replace, limit or withdraw features for technical, commercial, legal or security reasons, or as the product evolves.

27. Support

Novelingo may provide technical or functional support depending on the plan purchased, the access arrangement or the applicable commercial proposal.

Support may include, as the case may be:

• answers to basic questions;
• assistance during the trial;
• help creating experiences;
• review of incidents;
• guided sessions;
• specific support for paying customers;
• assistance with bespoke projects.

Unless expressly agreed, support does not include:

• legal consultancy;
• validation of regulatory content;
• full pedagogical review;
• specialist medical, preventive, financial or technical review;
• administration of the customer's LMS;
• unlimited adaptation of content;
• bespoke development that has not been contracted.

28. Third-party services

Novelingo Studio may integrate with or rely on external technology providers, such as hosting, database, analytics, email, artificial intelligence, resource generation, content processing and payment services, or other services necessary for the operation of the platform.

Novelingo will select suitable providers for the provision of the service, but will not be liable for interruptions, changes, limits, errors or unavailability attributable exclusively to third parties, except in cases where liability is legally enforceable.

Use of certain features may be subject to the terms, limits or technical policies of external providers.

29. Suspension or cancellation of access

Novelingo may suspend, restrict or cancel the user's access when:

• the user breaches these Terms;
• there is non-payment;
• abusive or fraudulent use is detected;
• the security of the platform is compromised;
• unlawful or harmful content is used;
• third-party rights are infringed;
• personal data is entered without sufficient safeguards;
• credit, usage or security limits are circumvented;
• there is a legal, judicial or administrative requirement;
• use of the service could give rise to liability for Novelingo.

Where reasonable, Novelingo will endeavour to inform the user before suspension or cancellation. It will not be obliged to do so where there is a serious risk, urgency, a legal obligation or a need to protect third parties.

30. Account cancellation by the user

The user may request cancellation of their account by writing to info@novelingo.com.

Cancellation will not affect:

• payments already accrued;
• outstanding invoices;
• confidentiality obligations;
• liabilities arising from prior use;
• retention of information necessary for legal, tax, accounting, technical or security reasons;
• contracts or proposals in force.

Novelingo may retain certain information for the periods legally required or for as long as it is necessary to manage liabilities, claims, invoicing, security or regulatory compliance.

31. Limitation of liability

Novelingo will be liable in accordance with the applicable regulations.

However, to the extent permitted by law, Novelingo will not be liable for:

• errors in AI-generated content not reviewed by the user;
• decisions taken by the user or third parties based on unvalidated content;
• use of the platform for purposes other than those intended;
• content uploaded, edited, published or exported by the user;
• infringements of third-party rights committed by the user;
• use of personal data without a sufficient legal basis;
• publication of experiences via links or QR codes without adequate restrictions;
• failures of LMS, external platforms or third-party systems;
• loss of business opportunities, loss of profit or indirect damages;
• expectations of learning, recall, behaviour, conversion or impact that are not expressly guaranteed;
• use of Novelingo Studio as a substitute for professional, legal, medical, preventive, financial, educational or specialist technical advice.

In sensitive areas such as PRL (occupational risk prevention), compliance, cybersecurity, data protection, health, equality, mandatory training or content aimed at minors, the user must obtain professional or expert review where necessary.

32. Warranties

Novelingo Studio is provided according to its state of development, availability and the features existing from time to time.

Novelingo does not guarantee that the platform:

• will suit all of the user's specific needs;
• will be error-free;
• will operate without interruption;
• will be compatible with all devices, browsers, LMS or external systems;
• will produce accurate, complete or suitable results without human review;
• will generate original content in all cases;
• will by itself satisfy the user's legal, training, administrative or regulatory obligations.

Any additional warranty must be expressly set out in a specific proposal, contract or agreement.

33. Right of withdrawal in the case of consumers

Novelingo Studio is aimed primarily at professional users, companies, bodies and institutions.

If a consumer exceptionally enters into a contract, the rights that apply under consumer and user protection legislation will apply.

Where the service consists of digital content or a digital service whose performance begins before the statutory withdrawal period has ended, the consumer may lose the right of withdrawal if they have given their express consent and have acknowledged that they thereby lose that right, where permitted by the applicable regulations.

34. Communications

Novelingo may send service-related communications through the email address provided by the user, in-platform notices or other reasonable means.

These communications may relate to:

• account access;
• verification codes;
• technical changes;
• security;
• invoicing;
• credit consumption;
• incidents;
• updates;
• changes to the terms;
• support;
• contractual information.

Commercial communications will be sent only where there is a legal basis for doing so and in accordance with the Privacy Policy.

35. Changes to these Terms

Novelingo may modify these Terms to adapt them to legal, technical, commercial, security, functional or business-model changes.

Where the changes are significant, Novelingo may inform the user through the website, the platform or by email.

The applicable version will be the one in force at the time of use or purchase, unless a proposal or contract provides otherwise.

If the user does not accept the new Terms, they must stop using the platform.

36. Assignment and subcontracting

The user may not assign their account, contract, licence or rights of use to third parties without Novelingo's prior authorisation.

Novelingo may subcontract technical services, infrastructure, AI, support, hosting, communications, analytics, processing, security or other services necessary to provide Novelingo Studio, always in accordance with the applicable regulations.

Where subcontracting involves the processing of personal data on behalf of a customer, the provisions of the Privacy Policy and, where applicable, of the data processing agreement will apply.

37. Force majeure

Novelingo will not be liable for breaches or delays caused by circumstances beyond its reasonable control, including provider failures, internet outages, cyberattacks, labour disputes, legal restrictions, disasters, fires, pandemics, administrative decisions, regulatory changes, supply interruptions or any other cause of force majeure.

38. Partial invalidity

If any clause of these Terms is declared null, invalid or unenforceable, this will not affect the remaining clauses, which will remain valid to the extent permitted by law.

The affected clause will be replaced by a valid one that comes as close as possible to the economic and legal purpose of the original clause.

39. Governing law and jurisdiction

These Terms are governed by Spanish law.

Where the user acts as a company, professional, body or institution, the parties submit to the courts and tribunals of Málaga, unless a mandatory rule establishes a different forum.

Where the user is a consumer, the forum that applies under consumer and user protection legislation will apply.

40. Contact

For any enquiry about these Terms, the user may contact Novelingo at:

Email: lopd@novelingo.com
Postal address: Avenida Sor Teresa Prat 15, 29003 Málaga
Owner: NOVELINGO, S.L.

Annex I — Basic terms for data processing on behalf of the customer

This annex will apply only where Novelingo processes personal data on behalf of a customer acting as data controller.

In those cases, the customer will be responsible for determining the purpose, legal basis, content, recipients and conditions of the processing, and Novelingo will act as data processor only to the extent necessary to provide the service.

1. Subject matter of the processing

The processing will have as its object the provision of the Novelingo Studio service, including access to the platform, creation of experiences, project management, support, publication, export, maintenance, security and associated features.

2. Duration

The duration of the processing will be that linked to the contractual relationship between the customer and Novelingo, without prejudice to any applicable legal, tax, accounting, contractual, technical or security retention periods.

3. Nature and purpose

The processing may include hosting, storage, consultation, structuring, modification, generation, technical support, publication, export, blocking, erasure or any operation necessary to provide the service.

4. Types of data

Depending on how the customer uses the service, the data processed may include identification, professional, academic, access, activity, usage and metrics data, content entered, responses, progress or information associated with experiences.

The customer must not enter special categories of data unless there is a sufficient legal basis and specific measures have been agreed beforehand.

5. Categories of data subjects

These may be users of the platform, employees, students, participants, trainers, administrators, customers, visitors or end users linked to the customer.

6. Novelingo's obligations as data processor

Novelingo undertakes to:

• process the data only on the customer's documented instructions;
• apply reasonable technical and organisational measures;
• maintain confidentiality;
• assist the customer, to a reasonable extent, in responding to data subjects' rights;
• assist with security matters where appropriate;
• report security incidents where legally required;
• not use the data for its own incompatible purposes;
• not disclose data to third parties unless necessary to provide the service, there is a legal obligation or authorisation;
• erase or return the data where appropriate, unless there is an obligation to retain it.

7. Sub-processors

Novelingo may use technology providers necessary to provide the service, including infrastructure, email, AI, storage, support, security and associated services.

Where those providers act as sub-processors, Novelingo will endeavour to ensure that they assume equivalent data protection obligations.

8. Customer's obligations

The customer will be responsible for:

• informing data subjects where applicable;
• having a sufficient legal basis;
• not entering unnecessary data;
• avoiding sensitive data unless there is a justified need;
• reviewing content before publication;
• managing internal permissions;
• configuring access and publications correctly;
• responding to data subjects' rights where this falls to the customer;
• complying with the regulations applicable in its sector.

9. Security measures

Novelingo will apply measures proportionate to the risk, including access controls, limits on attempts, backups, technical maintenance, security review and reasonable infrastructure protection measures.

10. Additional formalisation

Where the customer so requires or the processing involves higher risk, the parties may enter into a more detailed data processing agreement, which will prevail over this annex in the event of any conflict.