1. GENERAL INFORMATION

1.2 Company Details This Agreement is concluded between: Company Name: Total Carbon Cleaner Tuvo srl Address: Noua 139, Horpaz, Miroslava, Iasi, Romania EU VAT Number: RO 50565796 Contact Email: info@totalsupervisor.com Phone: +40 76 100 7040 Website: https://totalsupervisor.com

1.2 Acceptance of Terms By using this website, creating an account, or placing an order, you fully and unconditionally accept these Terms and Conditions. If you disagree with any term, please do not use our services.

2. USE OF THE PLATFORM

2.1 Usage Rights We provide you with a limited, non-exclusive, conditionally transferable license to use the platform exclusively for lawful purposes.

Device & Account Transfer: You may transfer one GPS device and the associated account to another user.

Required:

• Written transfer request to info@totalsupervisor.com

• Identity verification of both parties

• Transfer fee payment: €25 per device

The transfer includes:

• The physical device

• Any remaining subscription

Terms:

• The new owner must create an account or link to an existing one

• The old owner permanently loses access

• Transfer is completed within 5 business days

• One transfer per device per 12 months

Physical Device: Fully transferred SIM Card: Remains our property, usage is transferred

Location Data: To protect the privacy of the previous owner, historical location data cannot be transferred.

• Upon transfer approval, all historical data associated with the device is permanently deleted.

• The new owner starts with a clean history log.

• This action is irreversible and automatic.

2.2 Prohibited Uses The following are expressly prohibited:

• Illegal tracking of individuals without their consent

• Violation of privacy and personal data laws

• Use for stalking, harassment, or any illegal activity

• Modification, disassembly, or reverse engineering of products

• Re-transmission of SIM cards to other devices

• Unauthorized access to our servers If we receive a report of illegal use (stalking, harassment), we will:

• Immediately suspend the account

• Reserve the right to notify authorities

• Cooperate with court orders

2.3 Age Restrictions You must be at least 18 years old to make a purchase. We do not knowingly collect information from individuals under 13 years of age. 2.4 Account Creation

• You must provide accurate and complete information

• You are responsible for maintaining the confidentiality of your account

• You must immediately report any unauthorized use

• One account per person/business

3. LAWFUL USE OF GPS TRACKERS 3.1 Customer Liability Statement By making a purchase, you declare and warrant that:

• You are of legal age

• You will use the products lawfully

• You comply with all applicable laws and regulations

• You have obtained necessary consents for tracking

3.2 Legal Framework GPS devices are subject to different laws per country and state: United States:

• Fourth Amendment: Protection against unreasonable searches

• Consent required for tracking private vehicles

• Employers may track company vehicles with notification

• Parents may track minor children European Union:

• GDPR: Strict data protection regulations

• Clear consent required for tracking

• Rights to access, correction, and deletion of data

3.3 Disclaimer of Liability The Company expressly disclaims any liability arising from:

• Illegal or inappropriate use of products

• Violation of privacy laws

• Tracking without consent

• Any civil or criminal sanctions You agree to indemnify, defend, and hold the Company harmless from any claims, damages, liabilities, or legal expenses arising from misuse of the products.

4. PRODUCTS AND ORDERS

4.1 Product Descriptions We make every effort for accurate descriptions. However:

• Colors may vary

• We reserve the right to correct errors

• Technical specifications may change without notice

4.2 Pricing Prices are listed in Euros (€). Upon order completion, the amount is automatically converted to your country’s currency based on the exchange rate on the processing day. Currency & Conversion:

• All transactions are processed in Euros (€).

• If your card currency is different (e.g., RON, USD), your bank will perform the currency conversion.

• The final amount deducted from your account depends on your bank’s exchange rate and any fees they may apply. We do not charge any extra conversion fees. We reserve the right to modify prices without notice. For customers outside the Eurozone:

• You will see the converted amount IN THE CART before payment

• Final charge is made in your currency

• Your bank may add additional fees (beyond our control)

• Prices valid at order completion

• We do not match competitor prices

4.3 Availability Products subject to availability. We reserve the right to cancel orders if out of stock. You will be notified immediately of delays or cancellations.

4.4 Order Processing & Cancellation Window

• Order Confirmation: You will receive an order confirmation via email immediately after payment.

• 24-Hour Cancellation Right (Cooling-off Period): Specifically for models TSV 12G and TSV 14G, you have a strict 24-hour window from the moment of payment confirmation to cancel your order for a full refund.

  • During this period, your order is on “hold” regarding technical configuration.

  • To cancel, you must email info@totalsupervisor.com within these 24 hours.

• Start of Irreversible Configuration: After the 24-hour period lapses, the order enters the “Technical Provisioning” stage. At this point, the SIM card is activated, the device is registered to our servers, and specific firmware/APN settings are flashed onto the hardware.

• Processing Time: Total processing time is approximately 10 business days.

• We reserve the right to refuse/cancel orders or limit quantities.

5. PAYMENTS

5.1 Payment Methods Accepted methods:

• Credit/Debit cards (Visa, Mastercard, American Express)

• PayPal

• Bank transfer

5.2 Payment Security We use SSL/TLS encryption and comply with PCI DSS standards. We do not store complete card details. Payments processed by trusted providers.

5.3 Payment Terms Full payment at order. Amounts charged in euros. Responsible for any currency conversion fees. VAT & Taxes:

• Retail Customers (EU Consumers): Prices include VAT. The applicable VAT rate is determined in accordance with EU tax legislation (Origin principle or OSS Scheme), depending on our annual sales volume and your delivery country.

• Business Customers (EU B2B): If you represent a company in the EU (outside Romania) and provide a valid VIES VAT number at checkout, we will issue an invoice with 0% VAT (Intra-Community Supply / Reverse Charge).

• Non-EU Customers: Orders shipped outside the European Union are VAT-free (0%), but you may be responsible for import duties and taxes in your country.

5.4 Failed Payments Order does not proceed until successful payment. Fees may be charged by your bank. The Company is not responsible for failed transactions.

6. SHIPPING AND DELIVERY

6.1 Geographic Coverage We ship to: Europe, America, Canada, Australia.

6.2 Delivery Times Since products are shipped from our central international warehouse, delivery times are as follows:

• Romania (Domestic orders): 7-12 business days

• International: 15-22 business days Times are estimated. Delays due to customs, weather, or carrier issues are beyond our control. If a delay exceeds 30 days, you have the right to cancel and receive a full refund.

6.3 Shipping Cost Calculated at checkout. Free shipping for orders over €250. Additional customs fees/taxes buyer’s responsibility. For UK shipments, customs fees and VAT may apply post-Brexit.

6.4 Risk of Loss For consumer orders (B2C), the risk of loss or damage to the products passes to you when you (or a third party indicated by you, other than the carrier) acquire physical possession of the goods.

• We are responsible for the package until it is delivered to your address.

• If the package is lost in transit, we will replace it or refund you. 6.5 Tracking Tracking number provided via email when available.

7. RETURNS AND REFUNDS 7.1 Return Period 14 days from receipt. Products must be unused, in original packaging. Proof of purchase included.

7.2 Non-Returnable Items The following items cannot be returned or refunded once the 24-hour cancellation window (see §4.4) has passed:

• Products with visible signs of use.

• Activated SIM cards.

• Devices that have undergone “Pre-shipping Provisioning” (including TSV 12G and TSV 14G).

• Software unsealed or removed from seal.

7.2.1 Exception to the Right of Withdrawal (TSV 12G & TSV 14G) IMPORTANT NOTICE: The GPS Tracker models TSV 12G and TSV 14G are exempted from the standard 14-day Right of Withdrawal pursuant to Article 16(c) and 16(m) of the EU Consumer Rights Directive (2011/83/EU).

• Why are they exempt? These devices are not sold as “off-the-shelf” hardware but as a configured service solution. Once the 24-hour cooling-off period passes, our technicians perform irreversible actions including:

  1. Server Registration: Unique linking of the device IMEI to your user account.

  2. Connectivity Setup: Hard-coding of APN settings and SIM card activation.

  3. Firmware Customization: Installation of vehicle-specific parameters (VIN integration or service protocols selected by the customer).

• Your Rights & Cancellation Policy:

  1. 0-24 Hours: You may cancel for a Full Refund (No fees).

  2. After 24 Hours: The sale is considered final due to the personalization performed.

• Exceptional Returns & Configuration Fee: In the rare event that the Company, at its sole discretion, agrees to accept a return for a non-defective TSV 12G or TSV 14G unit outside the cancellation window (as a gesture of goodwill), a mandatory Configuration & Restocking Fee of €35 per device will be deducted from the refund.

  1. This fee covers the technical labor required to de-register the device, wipe user data, reset firmware to factory settings, and replace the SIM card.

  2. This fee also applies if a configured package is refused at delivery or returned as undeliverable.

7.2.2 Other Products (Standard GPS Trackers & Accessories) For all other products that do not require pre-shipping software customization (e.g., standard GPS trackers without SIM activation, accessories):

• You retain the full 14-day right of withdrawal from the day of receipt.

• Products must be returned unused and in original packaging. GPS Trackers (without SIM):

• Full 14-day right.

• Must be returned unused.

7.3 Return Process

• Contact support for approval

• Receive authorization number (RMA)

• Securely package the product

• Ship with tracking

• Responsible for return cost unless defective

7.4 Refunds Processing within 7 days of receipt. Credit to original payment method. Shipping fees not refunded (except defective). Store credit or exchange available.

7.5 Right of Withdrawal (EU) According to the EU Consumer Rights Directive, you have 14 days to withdraw without reason.

8. WARRANTY AND LIABILITY 8.1 Limited Warranty Products covered by limited 24-month warranty for:

• Manufacturing defects

• Material problems in normal use

8.2 Warranty Exclusions The warranty does NOT cover:

• Misuse, negligence, or accident

• Unauthorized modifications/repairs

• Liquid damage, battery overcharging

• Improper installation

• Tampering/removal of serial number

8.3 Warranty Process

• Contact Support: Before returning any item, you must contact technical support to troubleshoot the issue.

• RMA: If the issue cannot be resolved remotely, we will issue a Return Merchandise Authorization (RMA) number.

• Shipping Costs:

  • You are responsible for shipping the device to us for inspection.

  • If the defect is covered by warranty: We will repair/replace the unit for free, refund your shipping cost (up to a standard shipping rate), and pay to ship it back to you.

  • If the device is NOT defective (or damage is not covered): You will be responsible for the inspection fee (€15) and the return shipping costs to get the device back.

8.4 DISCLAIMER OF WARRANTIES PRODUCTS AND SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE”. THE COMPANY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

8.5 GPS Limitations GPS accuracy depends on satellite signal. Coverage and accuracy may be affected by buildings, weather, solar storms, jamming.

• GPS accuracy is typically 1.5-10 meters in ideal conditions, but can reach 50+ meters indoors, urban canyons, or poor weather conditions.

• We do not guarantee uninterrupted service.

• Telecommunications providers may discontinue networks.

• We are not responsible for inaccurate locations.

8.5.1: GPS Accuracy – Realistic Expectations

• TYPICAL ACCURACY (Daily Use): Open space (field, road): 3-15 meters | Urban area: 10-30 meters | Near buildings: 20-50 meters | Inside building: 50-500 meters (or no signal)

• OPTIMAL ACCURACY (Ideal Conditions): Stationary device, open sky, ≥6 satellites. Can reach 1.5-5 meters.

• INFLUENCING FACTORS: Number of visible satellites, Atmospheric conditions (rain, clouds), Urban canyon effect (tall buildings), GPS jamming/spoofing, Tracker antenna quality. IMPORTANT: DO NOT RELY on GPS for critical safety applications. Use as a supplementary tool, not the sole source of location.

8.6 LIMITATION OF LIABILITY IN NO EVENT SHALL THE COMPANY BE LIABLE FOR:

• Indirect, incidental, special, or consequential damages

• Loss of profits, revenue, data, or business opportunities

• Loss of tracked assets or persons

• Network or service failures

• Inaccurate location data OUR TOTAL LIABILITY IS LIMITED TO THE AMOUNT YOU PAID FOR THE PRODUCT/SERVICE IN THE LAST 24 MONTHS. Some jurisdictions do not allow exclusions of warranties or limitation of liability, so the above limitations may not fully apply to you.

9. SUBSCRIPTION SERVICES 9.1 Subscription Structure Annual charge in advance. Subscription required for platform access. SIM card and server access remain our property. Auto-renewal unless cancelled.

9.2 Cancellation Cancel anytime through account. No refunds for partial period. Service continues until end of billing period. Data retained for 7 days after cancellation.

9.3 Service Suspension We reserve the right to suspend for: Late payments (30+ days), Breach of terms, Illegal use, Support abuse.

9.4 Modifications Subscription plans/prices may change. You will receive 30 days’ notice. Continued use constitutes acceptance.

10. INTELLECTUAL PROPERTY 10.1 Ownership Rights All content, including: Logos, trademarks, Website design, graphics, Software code, algorithms, Product content, photos, Documentation, guides, etc. is protected by intellectual property rights and belongs to the Company or our licensors.

10.2 Limited License We grant you a non-exclusive license to: Access and use the platform, Download user manuals, Install applications on your devices, etc.

10.3 Prohibited Uses You may not: Reproduce, distribute content, Modify, reverse engineer software, Remove copyrights/trademarks, Commercial use without license.

10.4 User Content Any content you upload remains yours, but you grant us a license to: Host, store, process, Display on the platform, Create backups.

11. AFFILIATE MARKETING PROGRAM 11.1 Program Overview Our partners earn commission for successful sales referrals through unique referral links or discount coupon codes. 11.2 Affiliate Eligibility To participate you must:

• Be 18+ years old

• Have lawful activity (website/blog/social media)

• Comply with FTC regulations

• Have no history of fraud or spam

11.3 Commission Structure Commission by agreement on eligible sales and products. Payment when order is delivered and passes return period. Minimum payment threshold: €10. Payments via agreed method.

11.4 Acceptable Promotion Practices Affiliates must:

• Use accurate product information

• Clearly disclose affiliate relationship (FTC requirement)

• State: “Contains affiliate links. We may receive commission.”

• Place disclosures near links, visible and understandable

• Comply with all advertising laws

11.4.1: Mandatory FTC Disclosures

• MINIMUM REQUIREMENT: “DISCLOSURE. e.g.: I am an affiliate. If you purchase through links on this page, I receive commission at no extra cost to you.”

• PLACEMENT: Before the FIRST affiliate link on the page, Visible without scrolling (above the fold), Font size ≥ main text, NOT in footer/sidebar (not acceptable to FTC).

• SOCIAL MEDIA: Instagram: “#ad” or “#sponsored” BEFORE text. YouTube: Mention + description. Twitter: “#ad” at beginning of tweet.

• PROHIBITED: Hidden disclosures (e.g., same color as background), Vague language (“I think that…”), Unclear terms (“May”, “Might”).

11.5 Prohibited Practices Not allowed: False or misleading statements, Spam emails without consent, Bidding on our trademark keywords in ads, Cookie stuffing, click fraud, Promotion on inappropriate sites, Self-referral for commissions, Impersonating official representatives, Targeting minors.

11.6 Referral Management Cookies last 90 days. Last click attribution model. Tracking via unique affiliate code. Access to real-time reporting dashboard.

11.7 Sales Verification We reserve the right to: Verify all referrals for fraud, Delay or deny commissions for suspicious activity, Request documentation of promotion methods.

11.8 Termination We may terminate affiliate accounts for breach of terms. Pending commissions lost after termination. Confirmed commissions will be paid.

11.9 Program Modifications We reserve the right to modify commissions/terms. 30 days’ notice for substantial changes. Continued participation constitutes acceptance.

12. VIRAL REFERRAL GAMIFICATION PROGRAM

12.1 Program Overview Our Viral Referral Gamification Program is designed to reward you for promoting our products. The program relies on three (3) distinct reward pillars:

1. Gift Cards & Vouchers: Credits for purchasing products in our store.

2. Cash Rewards: Direct monetary payouts for your referrals.

3. Giveaway (The Draw): Participation in quarterly draws for major prizes based on performance. Participant Status: Depending on your tax status (Business vs Individual), you will be classified as either a Pro Partner or a Standard Member regarding cash payouts (see §12.12).

12.1.1 Structure Definitions (Levels vs. Tiers) To ensure clarity, the program distinguishes between your performance and your billing status:

• Performance Levels (Gold / Platinum): These define how much you earn. Your level is determined solely by the number of successful referrals you bring (e.g., 1-4 referrals = Gold, 5+ = Platinum).

• Membership Tiers (Pro Partner / Standard Member): These define how you are paid. Your tier is determined by your ability to issue a fiscal invoice (see §12.12). A “Platinum” performer can be either a “Standard Member” (if an individual) or a “Pro Partner” (if a business).

12.2 Participation Eligibility IMPORTANT NOTE: NO PURCHASE REQUIRED To participate in the Referral Program:

• No product purchase required

• You can contact customer service to receive a unique referral code

• Must be 18+ years old

• Must have valid email address

• Must have valid personal mobile phone number

• One referral account per person

• Participation must comply with all terms ALTERNATIVE METHOD OF ENTRY (AMOE): If you do not wish to make a purchase, you can receive a free referral code by:

• Sending email to referral@totalsupervisor.com with subject “Free Referral Code Request”

• Completing the form on our website in the WIN section: “Join Referral Program” Free referral codes provide access to the program with certain limitations on rewards (see §12.2.1).

12.2.1 Reward Structure Based on User Status To ensure fairness and functionality, rewards are structured as follows: A. Common Rewards (For ALL Participants): Regardless of whether you have purchased a product, you are fully entitled to:

• All guaranteed Gift Cards and Vouchers corresponding to your referral level (System A).

• Full entry into the Prize Draw (System B) if eligible.

• The exact same chances of winning in the draw. B. Functional Limitation regarding Subscriptions:

• For Participants WITH GPS Tracker (Full Status): You receive the free subscription rewards immediately, as you have the necessary hardware to use the service.

• For Participants WITHOUT GPS Tracker (Basic Status): You receive all monetary rewards (Gift Cards/Vouchers) normally.

  • Regarding Subscriptions: Since the subscription is a functional service that operates only in conjunction with our GPS device, it cannot be activated without the hardware.

  • Reservation of Benefit: This benefit is not lost but held in reserve. If you choose to acquire a GPS tracker at any later time, your status is automatically upgraded, and the earned subscription period will be applied to your device immediately.

12.3 Geographic Availability of Program COUNTRY RESTRICTIONS: The Viral Referral Gamification Program is available ONLY in countries where our e-shop ships products (see §6.1 Geographic Shipping Coverage).

• Full Participation Allowed (Referral + Gamification with Draw): European Union (27 member states), United Kingdom, Switzerland, Norway, Iceland, USA (except FL, NY, RI), Canada (except Quebec), Australia, New Zealand, Japan, South Korea, Singapore, Hong Kong, UAE, Saudi Arabia.

• Basic Referral Program Only (WITHOUT Draw): Regions with strict sweepstakes laws: USA (Florida, New York, Rhode Island), Canada (Quebec), Brazil, Mexico, China, India, Russia, Turkey.

• Exceptions – Program NOT Available: North Korea, Iran, Syria, Cuba, and other countries where e-shop does not ship. AUTOMATIC VERIFICATION: The system automatically checks your shipping address upon registration. If your country is not supported, a message will appear.

12.4 System Participation Choice Upon enrolling in the program, each participant chooses ONE of the two systems:

• SYSTEM A: Scheduled Rewards (No Draw): 100% guaranteed rewards, Predictable results, No draw or chance element, Available in all countries (see §12.3).

• SYSTEM B: Gamification with Draw: Guaranteed 4-year subscription (for full status) + draw for bigger prizes. Requires higher referral threshold. Greater potential gain. Available only in selected countries (see §12.3). You can change systems ONLY if: You have not yet had any verified referral in the current period Or for System B: before draw lockdown (before 50 participants reached). After the first verified referral (System A) or after lockdown (System B), the choice becomes final for the current period. Referrals do NOT transfer between systems. In a new program period you can choose a different system.

12.5 SYSTEM A: REFERRAL PROGRAM WITHOUT DRAW 12.5.1 System A Features No draw (100% guaranteed rewards). Predictable rewards based on number of referrals. Immediate reward distribution after verification. Tiered rewards per level. No minimum referral threshold to start. Available worldwide (except excluded countries).

12.5.2 System A Reward Structure NOTE: Rewards differ based on customer status (see §12.2.1). Level 1: GOLD (1-4 successful referrals)

• Reward for each new referred customer: New customer receives: €50 discount on first tracker purchase order.

• Reward for referrer:

  • WITH GPS tracker purchase (Full Status): 1 year free Premium subscription per successful referral, €10 gift card per successful referral.

  • WITHOUT GPS tracker purchase (Basic Status): €10 gift card per successful referral. Level 2: PLATINUM (5+ successful referrals)

• Reward for each new referred customer: New customer receives: €50 discount on first tracker purchase order.

• Reward for referrer (cumulative upon reaching level):

  • WITH GPS tracker purchase (Full Status): 4 years free Premium subscription (total, replaces the 1 year from Gold). €20 gift card per new successful referral.

  • WITHOUT GPS tracker purchase (Basic Status): €20 gift card per new successful referral.

12.5.3 System A Terms

• Reward Distribution: Rewards distributed automatically within 5 business days of reaching level. Vouchers/gift cards sent via email. Subscriptions activated automatically in account. Badges appear immediately in profile.

• Reward Validity: Vouchers/gift cards: Valid for 9 months from issue. Subscriptions: Start immediately or after current subscription expires (user choice). Badges: Permanent.

• Restrictions: No limit on number of referrals. All rewards are guaranteed (no draw). Rewards not transferable to other accounts. Vouchers not exchangeable for cash. Subscriptions not sold or transferred.

• Combining Rewards: Vouchers can be combined with each other. Vouchers do NOT combine with other promotional discounts (unless explicitly stated). Subscriptions accumulate consecutively.

12.6 SYSTEM B: GAMIFICATION PROGRAM WITH DRAW

12.6.1 System B Features Requires minimum number of referrals (10+) for entry. Combines guaranteed rewards AND draw for premium prizes. Greater potential rewards than System A. Categorization based on performance (Bronze/Silver/Gold/Platinum). Quarterly draws. Available only in selected countries (see §12.3).

12.6.2 System B Participation Requirements Minimum Number of Referrals for Entry: To participate in the draw, you must achieve the minimum threshold for your category:

• Category J: 10-14 successful verified referrals

• Category I: 15-19 successful verified referrals

• Category H: 20-24 successful verified referrals

• Category G: 25-29 successful verified referrals

• Category F: 30-34 successful verified referrals

• Category E: 35-39 successful verified referrals

• Category D: 40-44 successful verified referrals

• Category C: 45-49 successful verified referrals

• Category B: 50-59 successful verified referrals

• Category A: 60 successful verified referrals

• IMPORTANT – GUARANTEED REWARD FOR ALL: Every participant who achieves the minimum number of referrals (10+) receives GUARANTEED the following reward BEFORE the draw:

• WITH GPS tracker purchase (Full Status): 4-year (48 months) Free Premium Subscription (total value: €200). This subscription is given to ALL who reach the threshold, regardless of draw outcome. Activated immediately or after current subscription expires.

• WITHOUT GPS tracker purchase (Basic Status): Do NOT receive the guaranteed 4-year subscription (as they have no device for use). Enter the draw for prizes (provided prizes are not subscriptions). Ability to upgrade to Full Status at any time.

• IMPORTANT – REPEAT PARTICIPATION: When you achieve 60+ referrals in the same quarterly period: You enter Category A for the current draw. You earn the guaranteed 4-year subscription (once). After the draw, the counter resets to 0 for the next quarter. If you bring MORE than 60 referrals in the same period: E.g., 75 referrals in Q1. You enter Category A for Q1 (with 60 referrals). The extra 15 do NOT carry to Q2. For Q2 you start from 0. You can win in Category A multiple times (different quarters), but: The 4-year subscription is given only the FIRST time you reach 10+ referrals. Subsequent times you ONLY enter the draw for prizes. Additional Opportunity: After receiving the guaranteed reward, you ALSO enter the draw for premium prizes in your category.

12.6.3 System B Draw Structure LEGAL DRAW STATEMENT: NO PURCHASE NECESSARY. A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING. This is a lawful sweepstakes, NOT a lottery.

• No purchase required to participate

• Alternative method of entry (AMOE) available (see §12.2)

• Probability of winning depends on number of eligible participants in each category

• The draw is governed by the laws of Romania

• Independent supervision/audit

Draw Period: Draws held Quarterly (every 3 months). Draw dates for 2026: Q1: March 31, 2026 Q2: June 30, 2026 Q3: September 30, 2026 Q4: December 31, 2026 Each participant meeting criteria within the quarterly period automatically enters the draw. No separate registration required – participation is automatic.

PRIZE CATEGORIES:

• CATEGORY J (10-14 referrals): Prizes up to €3,100

• CATEGORY I (15-19 referrals): Prizes up to €6,500

• CATEGORY H (20-24 referrals): Prizes up to €10,000

• CATEGORY G (25-29 referrals): Prizes up to €14,000

• CATEGORY F (30-34 referrals): Prizes up to €19,000

• CATEGORY E (35-39 referrals): Prizes up to €23,000

• CATEGORY D (40-44 referrals): Prizes up to €27,000

• CATEGORY C (45-49 referrals): Prizes up to €31,000

• CATEGORY B (50-59 referrals): Prizes up to €35,000

• CATEGORY A (60 referrals): Prizes up to €42,000

NOTE FOR BASIC STATUS: Participants WITHOUT GPS tracker purchase can win prizes that include GPS trackers and vouchers. If they win a prize with subscriptions, the subscription is activated when/if they acquire a device. The subscription portion of the prize cannot be exchanged for vouchers or cash.

12.6.3.1 Minimum Number of Participants & Locked Draws CRITICAL TERM – THRESHOLD & CAP PARTICIPATION: For a draw to take place in any category (J, I, H, G, F, E, D, C, B, A), the following apply:

• Minimum Number (Minimum Threshold): At least 50 eligible and verified participants required in the category.

• Maximum Number per Draw (Maximum Cap): Once the category reaches exactly 50 participants, the draw locks automatically. The draw is conducted with these 50 participants. All additional participants (51st, 52nd, 53rd, etc.) who reach the goal after lockdown: Receive the guaranteed 4-year subscription (if Full Status). Automatically enter the NEXT quarterly draw for the same category. Retain their status without needing to bring referrals again.

Note for Locked-in Status: If you enter Q2 draw as “overflow” for Q3: You receive the guaranteed 4-year subscription IMMEDIATELY (Q2). The Q3 draw is for additional prizes (1st, 2nd, 3rd). You do NOT get a second 4-year subscription in Q3 (already received).

Scenario A: Threshold Not Achieved (<50 Participants by Period End) If in any category the number of eligible participants remains below 50 by the deadline of the quarterly period:

• NO draw is conducted for that category.

• ALL eligible participants in the category automatically receive: The 4-year subscription (for Full Status) PLUS The 3rd Prize of their category (without draw, guaranteed).

• 1st and 2nd prizes are not awarded for this period.

• The next quarterly period starts from zero base (no participants carry over).

Scenario B: Threshold Achieved (Reach 50 Participants) Once a category reaches exactly 50 verified participants:

• The draw locks immediately with these 50 participants.

• Notification sent to all 50: “Congratulations! You entered the current quarterly draw”.

• Draw conducted on scheduled quarter-end date.

• Winning odds for these 50 = 1:3.6.

• All additional participants (51+) who reach the goal after lockdown: Notified: “The draw closed. You automatically entered the next quarterly draw!”. Receive the guaranteed 4-year subscription immediately (don’t wait for next draw). Pre-registered for next quarterly draw without needing to bring referrals again. Retain “locked-in” status for next period.

Scenario C: Overflow – Example Quarter Q2 202[x] – Category B: April 15: 50th participant verified → Draw locks. April 20: 51st participant reaches 20 referrals. Gets: 4-year subscription (immediately). Enters: Q3 202[x] draw (automatically). May 10: 52nd-58th participants achieve goal. All get: 4-year subscription (immediately). All enter: Q3 202[x] draw. June 30: Q2 draw conducted. Only first 50 participate. 11 winners selected from them. July 1: Q3 period starts. Already 8 people (51st-58th) are locked-in for Q3 draw. Need 42 more to close Q3 draw. New participants can enter normally.

Logic & Fairness: This policy ensures: Stable Odds: Each draw has exactly 50 participants = predictable probabilities. Fair Treatment: Those who “delayed” don’t lose their spot – they enter the next one. Speed Incentive: The faster you reach the goal, the sooner you enter a draw. Avoid Dilution: Odds don’t decrease with excessively many participants. Continuous Engagement: Overflow participants create “head start” for next period.

Real-Time Notifications: In your dashboard you’ll see: “Category Status: Gold” Current Number: 37/50 (13 more for lockdown). Estimated Lockdown Date: ~May 15. Your status: “Waiting for threshold”. After lockdown: “Gold Q2 Locked! You’re in! Draw date: June 30”. “Current participants joining Q3: 5”. If you enter after lockdown: “Gold Q2 closed. You’re automatically in Q3 draw!”. “Your 4-year subscription activated immediately ✓”. “Q3 draw: July 1 – Sep 30, 202[x]”.

Multiple Draws in Same Quarter (Theoretical): If a category is exceptionally popular and reaches 100 participants early in the quarter: Multiple draws occur in the same quarter. First 50 → Current draw. Remaining 50 → Next draw. If there are 101-150 → Second next draw, etc. All are pre-registered in order of goal achievement (first-come, first-served for lockdown).

Status Transfer: If you enter a draw but don’t win, you do NOT carry to the next. If you want to enter again, you must bring new referrals for the next quarter. Only “overflow” participants (who didn’t make the lockdown) automatically transfer. Exception – Last Period of Year (Q4): If in Q4 a category has overflow participants: They transfer to Q1 of next year. They are notified of the year change. Their status remains valid.

12.6.3.1-b Minimum Number of Participants for Draw CRITICAL TERM – PARTICIPATION THRESHOLD: For a normal draw to take place in any category, a minimum of 50 eligible participants in that category is required.

Scenario A: Threshold Achievement (≥50 Participants) Draw conducted normally as described in §12.6.3. Winners randomly selected for 1st, 2nd, and 3rd Prize. Remaining participants receive only the guaranteed 4-year subscription (or nothing for Basic Status).

Scenario B: Threshold Not Achieved (<50 Participants) If in any category the number of eligible participants is below 50, then: NO draw is conducted for that category. ALL eligible participants in the category automatically receive: The guaranteed 4-year subscription (for Full Status) + The 3rd Prize of their category (without draw, guaranteed). 1st and 2nd prizes are not awarded (reserved for next period or cancelled).

Examples:

• Example 1: Bronze with 35 participants. Threshold: 50 (not achieved). Draw: Does NOT occur. Result: All 35 get: 4-year subscription (if Full Status). GPS accessories package (€150) + €75 voucher (Bronze 3rd Prize).

• Example 2: Gold with 82 participants. Threshold: 50 (achieved). Draw: Occurs normally. Result: 1 winner → Grand Prize, 3 winners → 2nd Prize, 7 winners → 3rd Prize. Remaining 71 → Only the guaranteed 4-year subscription.

• Example 3: Silver with 48 participants (2 with Basic Status). Threshold: 50. Draw: Does NOT occur. Result: 46 with Full Status → 4-year subscription + GPS Tracker Standard (€300) + 6-month subscription + €150 voucher. 2 with Basic Status → GPS Tracker Standard (€300) + €150 voucher (no subscriptions).

Policy Rationale: This policy ensures: Fairness for participants in less popular categories. Reward for all when participation is low. Protection from “empty” draws with very few players. Notification: You will be notified 7 days before period end if your category has <50 participants. You can see real-time count in dashboard (informational, not exact number). Category Combination: If one category doesn’t reach threshold, it’s not combined with others. Each category evaluated separately. Non-Return of Prizes: If un-awarded prizes (1st, 2nd) are carried to next period, it will be announced. There is no right to claim them from current period participants.

12.6.4 Draw Procedure Winner Selection Method: Draw conducted via certified random number generator (RNG). Alternatively: By independent third-party auditor. All eligible participants have equal odds within their category. Selection is 100% random and unbiased. No employee, partner, or affiliate can influence selection. Each draw is recorded and archived for 5 years.

Draw Timeline: Period end: Last day of quarter (00:00 UTC). Participant verification: Next 3 business days. Draw execution: 4th business day after end. Winner notification: Within 7 calendar days from draw.

Winner Notification: Winners notified via: Email (to registration address), Phone contact (if available), Account dashboard notification. Winners have 14 calendar days to respond and claim prize. Failure to respond within 14 days results in: Prize declared forfeit, Selection of alternate winner from same pool. Alternate winner also has 14 days.

Verification & Claiming: Winners must: Verify their identity (scan ID/passport), Confirm shipping address, Sign Affidavit of Eligibility, Sign Liability Release, Sign Publicity Release (where legally permitted) – right to refuse, Provide tax information (if required – prizes >€600), Prove legitimacy of referrals (if requested). Failure to verify leads to prize cancellation.

Winner List: Published on official website within 30 days of draw. Includes: Pseudonym/Initials, City, Country, Prize category. Full names NOT published (except with consent). Available for download in PDF. Physical list available upon request (SASE). Retained for 4 years.

Prize Delivery: Physical products (trackers, accessories): Shipping within 30 days. Gift cards within 14 days After consultation with winner to determine desired type. Vouchers: Email within 7 days. Subscriptions: Activation within 3 days. Winner chooses subscription start date (within 6 months). International shipments may be delayed due to customs.

12.6.5 Legal Draw Terms NO PURCHASE NECESSARY. A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING. OPEN TO: Residents of countries listed in §12.3 (Full Participation), 18 years and older (19+ for Alabama/Nebraska, 21+ for Puerto Rico). CLOSED TO: Company employees, subsidiaries, partners, and advertising agencies. Immediate family members of employees (spouse, parents, children, siblings) and persons living in same household. Affiliate partners of the program. Residents of countries where sweepstakes are prohibited or restricted (see §12.3). Persons terminated from program for terms violation.

Draw Periods (Annual Update) The program runs annually with quarterly draws: DRAW PERIOD: Q1: January 1 – March 31 Q2: April 1 – June 30 Q3: July 1 – September 30 Q4: October 1 – December 31 Referrals must be verified (completed & verified) before period end to count.

ODDS OF WINNING: Odds of winning depend exclusively on number of eligible participants per category. IMPORTANT: Once a category reaches 50 participants, it locks automatically (§12.6.3.1). Additional participants transfer to next draw. This keeps odds stable and fair. If a category has <50 participants by end, ALL get 3rd Prize (100% odds). Actual Winning Probability (50 participants per draw): Probability of winning ANY prize (1st, 2nd or 3rd): 14 total prizes / 50 participants = 28%. That is: approximately 1 in 3.6 participants wins some prize. Example: If you enter Category H (20-24 referrals) and draw has 50 people: 28% probability to win ONE of the 14 prizes. 72% probability to receive ONLY the guaranteed 4-year subscription. Note: Exact odds per prize (1st, 2nd, 3rd) not published to maintain draw surprise element. Selection is 100% random and unbiased.

TOTAL PRIZE VALUE: Category Total Value: Category J €8,668, Category I €14,476, Category H €19,844, Category G €25,124, Category F €31,592, Category E €36,960, Category D €43,340, Category C €48,708, Category B €54,626, Category A €65,274. Total estimated value of all prizes for all categories (J-A) per quarterly period: €348,612 (Assuming full participation in all categories). Estimated Annual total value: €1,394,448 (Assuming full participation in all categories). The guaranteed 4-year subscription is NOT calculated as “draw prize” for legal purposes.

PRIZE CHARACTERISTICS: Prizes provided “AS IS” without warranties. No substitution, transfer, or cash exchange (except where explicitly stated). We reserve right to substitute with prize of equal or greater value. Colors/models may vary from images. Manufacturer warranties apply (where applicable).

TAXES & FEES:

• United States: Winners exclusively responsible for all taxes. For prizes ≥$600, IRS Form 1099-MISC issued. Winners must provide W-9 or W-8BEN.

• Canada: Prizes generally not taxed as income, but consult tax advisor.

• European Union: Tax rules vary by country. Winners responsible for declaration.

• Greece: Draw Prizes (System B): Subject to 10% withholding tax for prizes >€100. Withholding done automatically before award. You receive withholding certificate for your tax return. If referrals constitute systematic activity (>5 referrals/month or annual value >€1,000), consult tax advisor for possible taxation as business income. System A Rewards (Vouchers/Subscriptions): Vouchers: Generally not taxed as income unless considered systematic activity. Subscriptions: Benefit in kind – if total value >€300 annually, consult tax advisor. Professional activity: If referrals are part of your business activity, all rewards taxed as income from business activity (Category C’).

• PRIZE TAXATION: Draw Prizes >€100: Company withholds 10% automatically. E.g., You win €3,100 → You receive €2,790. We issue withholding certificate (for E1). Vouchers/Gift Cards (System A): If annual value <€300: Generally not taxed. If >€300: Consult tax advisor. Systematic Activity (>5 referrals/month): Considered business income. Must be declared as Category C’. Subject to income tax + VAT. Winner Obligations: Provide Tax ID (AFM) before award. Sign tax status declaration. Consult tax advisor for your return.

• International: Winners responsible for customs duties, VAT, and other import fees. Withholding: We reserve right to withhold tax if required by law. PARTICIPATION LIMITS: One (1) draw prize per person per quarterly period. You can win in different quarters. The guaranteed 4-year subscription given only once (not repeated each quarter). You can participate in multiple categories, but only highest counts. You cannot win multiple prizes in same draw. DISCLAIMER: The Company, its employees, directors, partners, and representatives are NOT liable for: Lost, delayed, stolen, altered, or incomplete entries. Technical problems, server errors, network interruptions. Human errors in entry management. Telecommunication or email failures. Unauthorized human intervention. Loss/damage of prizes during transport. Injury, death, or property damage from acceptance/use of prize (except proven negligence). Tax obligations of winners. Product defects (covered by manufacturer warranties). TERMINATION/MODIFICATION/SUSPENSION: We reserve the right to:

• Terminate, suspend, or modify sweepstakes if: Technical problems jeopardize integrity. Force majeure (natural disasters, pandemics, war). Legal prohibitions or law changes. Fraud or rule violations by large number of participants.

• Exclude participants who: Violate rules. Attempt fraud or manipulation. Use bots/automation. Harass staff or other participants. Verify all referrals for legitimacy. Cancel participation in case of violations. In case of force majeure termination, we may: Select winners from eligible entries before termination. Return all to “no winner” status. Transfer prizes to next period. SKILL-TESTING QUESTION (Canada & Australia): For compliance with Canadian and Australian laws: Residents of these countries must correctly answer a time-limited mathematical question before claiming prize. Question is basic level (e.g., “5 × 8 + 12 – 6 = ?”). 5 minutes allowed to answer. Failure = forfeit prize, selection of alternate. DISPUTES: Any disputes regarding sweepstakes: Governed by laws of Romania. Subject to exclusive jurisdiction of courts in Iasi, Romania. All Company decisions are final and binding. You agree to individual resolution, not class actions (where permitted). PUBLICITY: Except where prohibited, participation constitutes consent for use of: Name, city, country, Photo/likeness, Winner statements… for advertising and promotional purposes without additional compensation. Winners may opt-out but remain on official winner list.

12.7 Eligible & Ineligible Referrals (Both Systems)

12.7.1 A Referral Counts When: A referral is considered successful and verified when ALL the following criteria are met:

• New Customer: New customer’s first purchase (never purchased before from our e-shop). New email address (not used previously). No previous account.

• Completed Transaction: Payment successfully processed and confirmed. Order shipped/delivered. Not returned within 30 calendar days. No chargeback or cancellation.

• Unique Identity: Different home shipping address from referrer. Different billing address. Different IP address (unless provably genuine & legitimate referral). Different phone number. Different device/browser fingerprint.

• Valid Code Use: Use of your unique referral code/link. Within code validity period. Code not revoked or deactivated.

• Quality Criteria: Valid contact details (email, phone verifiable). Real person (not bot or fake account). Compliance with terms of use.

• Time Frame: Purchase made within 90 days from referral link click. For System B: Referral must be verified before quarterly period end. IMPORTANT CLARIFICATION – Non-Return within 30 Days: A referral is considered “finally verified” only if: 30 calendar days have passed from delivery AND No product return occurred. If return occurs within 30 days: Referral cancelled retroactively. If you already received reward based on this referral: System A: Reward revoked or you’re charged equivalent amount. System B: If you’ve locked in draw, you remain, but without cancelled referral (e.g., from 15→14 referrals). 12.7.2 Ineligible Referrals The following referrals may be rejected:

• Self-Referrals & Family: Purchases you make with different email/account. Same household members (couples, roommates, family). Use of same shipping or billing address. Use of same IP address (unless provably different people).

• Existing Customers: Customers who already purchased in the past. People who had account but deleted it. Re-activations of old customers.

• False/Temporary Accounts: Use of temporary email services (temp-mail.org, etc.). Fake names or false details. Disposable phone numbers. Obviously fictional persons.

• Returns & Cancellations: Orders returned within 30 days. Chargebacks or transaction disputes. Cancelled orders.

• Fraudulent Activities: Use of stolen credit cards. False shipping addresses. Referrals via bots/automation. Cookie stuffing or click fraud. Violation of terms of use in any way.

• Rule Violations: Referrals from spam campaigns. Purchased email lists. Illegal data collection. Misleading product statements. Intellectual property violation.

• Technical Issues: Duplicate entries (same person, multiple registrations). Cookie/tracking manipulation. Use of VPN/proxy to hide location (unless legitimate reason).

• Special Cases: Referrals from people in excluded countries (see §12.3). Referrals violating local laws. Minors (<18 years).

• 12.7.3 Referral Verification Automatic Verification: Our system automatically checks: Email verification (activity confirmation), IP/Geolocation analysis, Device fingerprinting, Address validation, Payment verification, Purchase completion. Manual Investigation: We reserve the right to investigate any referral for: Suspicious patterns (e.g., 20 referrals in 1 day), Similar addresses/names, High-value referrals (for System B), Reports from other users. Verification Time: Initial verification: Within 3-5 business days from purchase. Final confirmation: After return period passes (30+ days). For System B: Full verification before draw. Appeals: If a referral is rejected and you disagree: Contact referral@totalsupervisor.com. Provide evidence of legitimacy. We will review within 10 business days. Our decision is final.

12.8 Prohibited Activities (Both Systems) The following practices are STRICTLY PROHIBITED and lead to immediate suspension:

12.8.1 Email Marketing Violations: Spam: Sending unsolicited emails without opt-in consent (CAN-SPAM Act, GDPR Article 7 violation). Buying lists: Using purchased or rented email lists. Scraping: Automated email collection from websites/social media. Harvesting: Collecting emails without permission. Missing unsubscribe: Emails without easy opt-out method. Fake headers: Misleading subject lines or sender information.

12.8.2 Technical Abuse: Bots/Automation: Using automated systems to create fake referrals. Click fraud: Artificial inflation of clicks. Cookie stuffing: Placing cookies without actual click. URL hijacking: Replacing others’ referral links. Typosquatting: Creating similar domains for deception. Script injection: Malicious code.

12.8.3 Deceptive Practices: False claims: Untrue statements about products (e.g., “Earn up to 10km range!” when max is 5km). Fake reviews: Fictitious reviews or testimonials. FTC guideline violation: Not disclosing affiliate relationship. Bait & switch: Advertising one product, promoting another. False urgency: Fake deadlines (“Only for today!” every day). Fake scarcity: “Only 2 left” when we have stock.

12.8.4 Trademark & IP Violations: Bid on brand terms: Google Ads with our name/brand. Typo bidding: Ads on common typos of our brand. Trademark violation: Using logo/marks without permission. Domain infringement: Domains containing our brand. Impersonation: Presenting as official representative.

12.8.5 Inappropriate Promotion Sites: Adult content sites: Placing links on pornographic sites. Gambling sites: Online casinos, betting platforms. Hate speech sites: Platforms with racist/discriminatory content. Piracy sites: Torrents, warez, etc. Illegal marketplaces: Dark web, illegal goods.

12.8.6 Social Media Violations: Spam groups/forums: Posting links without relevance/permission. Fake accounts: Creating multiple profiles for self-promotion. Engagement pods: Artificial likes/shares/comments. DM spam: Unsolicited direct messages. Platform rules violation: Instagram/Facebook/TikTok TOS.

12.8.7 Privacy Violations: GDPR violations: Processing data without legal basis. Stalking/harassment: Harassing people for conversions. Doxxing: Publishing personal information. Targeting minors: Targeting individuals (<18). Unauthorized tracking: Cookies/trackers without consent.

12.8.8 Accounts & Structures: Multiple accounts: Creating multiple referral accounts. Account sharing: Sharing credentials with others. Shell companies: Fake businesses for manipulation. Circular referrals: Networks of mutual referrals.

12.9 Anti-Fraud Measures & Detection We use multi-level security system:

12.9.1 Automated Systems: AI/ML algorithms: Real-time unusual pattern detection. IP analysis: Geolocation, VPN/proxy detection, velocity checks. Device fingerprinting: Unique device identification. Email verification: Validity, disposable detection, reputation scoring. Payment fraud detection: AVS checks, velocity limits, blacklists. Behavioral analysis: Mouse movements, typing patterns, session duration.

12.9.2 Manual Checks: Manual review: High-value or suspicious referral review. Cross-reference: Comparison with known fraud patterns. Third-party verification: Using verification services. Customer interviews: Contact with new customers (sample-based).

12.9.3 Collaborative Intelligence: Industry blacklists: Sharing known fraudsters. Fraud networks: Participation in anti-fraud consortiums. Law enforcement: Cooperation where needed.

12.9.4 Anti-Fraud Actions:

• Consequences of Fraud Detection: Level 1 – Suspicious Activity: Temporary reward hold, Verification notification, Additional documents requested, Response time: 7 days. Level 2 – Confirmed Fraud: Immediate referral account suspension, Revocation of all pending rewards, Revocation of recently granted rewards (within 90 days), Ban from future participation, Blacklist IP/email/address, Notification to fraud databases. Level 3 – Serious/Criminal Activity: All above +, Recovery of illegally obtained rewards (by legal means), Report to authorities (police, FTC, etc.), Criminal/civil prosecution, Public notification (where permitted).

• Reward Recovery: We reserve the right to recover: Vouchers (if not redeemed), Monetary value of redeemed rewards, Physical products (if not delivered), Subscriptions (deactivation).

• Legal Prosecution: For serious cases we may pursue: Civil lawsuit for damages, Criminal prosecution (wire fraud, etc.), Court orders (injunctions).

12.10 Transparency & Public Information

12.10.1 Leaderboards & Rankings: Monthly Leaderboard: Updated in real-time, Top 100 referrers (per system), Displays: Pseudonym, City, Number of Referrals, Level/Category. Participation is OPT-IN (must agree). You can choose pseudonym (not real name). Quarterly/Annual Champions: Hall of Fame for top performers, Special recognition, Invitation to VIP events, Additional rewards (surprise bonuses). Opt-Out: You can withdraw from leaderboards at any time, Does not affect your rewards, Simply not displayed publicly.

12.10.2 Program Statistics: We may publish (anonymized): Total number of active referrers, Average referrals per user, Conversion rate (% visitors who buy), Geographic distribution of participation, Most popular products via referrals, Total reward value distributed. Privacy Protected: Never disclose individual data, Never link usernames with real names publicly, GDPR/CCPA compliant.

12.10.3 Reports & Transparency: For Draw Winners (System B): Draw date, Number of participants per category, Actual odds, Winner list (pseudonyms). Annual Transparency Report: We publish annually: Total rewards distributed, Fraud detection statistics, Program improvements, User testimonials.

12.11 Program Modifications & Termination

12.11.1 Right to Modify: Minor Changes (without notice): Typographical error corrections, Link/contact detail updates, UI/UX improvements, Bug fixes. Substantial Changes (with 30 days’ notice): Changes to reward structure, New eligibility terms, Category modifications, Draw rule changes, Geographic availability changes. Notification Method: Email to all active participants, Website banner, In-app notification, Dashboard alert. Your Options: Accept: Continue with new terms. Reject: Leave program. Pending rewards honored under old terms.

12.11.2 Termination of Participation by Company: We may terminate your participation for: Violation of any term of this §12, Fraud, abuse, or illegal activity, Repeated violations after warnings, Harassment of staff or other users, Legal requirements (court order, etc.), Non-payment of debts (if applicable). Process: Written notice with reasons, Opportunity to respond (5 business days), Final decision within 10 days, Account suspension. Consequences: Immediate loss of access, Pending rewards cancelled, Confirmed rewards may be revoked (if earned fraudulently), Permanent ban from future participation. Exception: If termination due to breach by us, you receive all pending rewards.

12.11.3 Voluntary Withdrawal: How to Withdraw: Email: referral@totalsupervisor.com, Dashboard: “Leave Program” button, Written request to our address. What Happens: Your referral code deactivated within 48 hours, Pending verified referrals completed, Confirmed rewards granted, Unverified referrals cancelled, Your data retained according to privacy policy (§13.6). Re-enrollment: You can re-enroll after 90 days, Start from beginning (no referral transfer), New referral code.

12.11.4 Termination of Entire Program: We reserve the right to terminate entire program for: Business reasons, Legal changes making it non-viable, Force majeure (pandemics, economic crises), Mass fraud undermining integrity. Notification: At least 60 days’ notice (except force majeure), Multiple communication methods. Participant Protection: All confirmed rewards honored, Pending verified referrals completed, For System B: Scheduled draws conducted, Vouchers/subscriptions remain valid until expiry.

12.12 TAX COMPLIANCE, INVOICING & PAYOUTS 12.12.1 General Principles & Membership Tiers For the purpose of cash payouts and tax compliance, participants are classified into two distinct categories based on their ability to issue fiscal invoices.

• Tax Responsibility: All rewards (vouchers, subscriptions, gifts, cash payouts) may be considered taxable income depending on your country of residence and total annual reward value. You are responsible for declaring this income and paying any owed taxes.

• We are not tax advisors: The information below is general. Please consult a tax professional for your specific situation.

12.12.2 Payment Categories A. PRO PARTNERS (Business & Freelancers)

• Definition: Participants who are registered businesses, sole traders, or freelancers and can issue a valid fiscal invoice.

• Requirement: You must issue an invoice to “Total Carbon Cleaner Tuvo srl” for “Marketing Services”.

• Payout: You receive 100% of the requested amount. No withholding tax is applied by us.

• Tax Liability: You are solely responsible for declaring this as business income and handling VAT/Income tax in your jurisdiction. B. STANDARD MEMBERS (Private Individuals)

• Definition: Participants acting as private individuals who cannot issue a fiscal invoice.

• Payout: Gross Amount minus 10%.

• The 10% Deduction: Since no invoice is provided, the Company automatically deducts 10% from the payout. This covers applicable withholding taxes on prizes/other income and/or administrative processing fees required to justify the corporate expense.

• Tax Liability: The 10% deduction satisfies the Company’s obligation. You remain responsible for declaring the net income received to your local tax authorities if required by your country’s laws.

12.12.3 United States: IRS Reporting

• IRS Reporting: For US residents, we issue Form 1099-NEC if the total reward value in one tax year is ≥ $600. This includes vouchers, cash payouts, and the Fair Market Value (FMV) of prizes. Forms are sent by January 31 of the following year.

• Required Documents: You must provide a valid Form W-9 (SSN or EIN) to receive payouts. Failure to provide W-9 results in 24% backup withholding (overriding the standard 10% rule).

• Income Types:

  • Cash Payouts & Vouchers: Reportable income.

  • Draw Prizes: Prize income (1099-MISC Box 3).

• State Taxes: Each state has different rules. You are responsible for state filing.

12.12.4 Canada: CRA Reporting

• General Rule: In Canada, prizes and rewards are generally not taxed as income if they arise from games of chance (windfall gains) and are not part of a business activity.

• Business Activity: If referrals are part of your business activity, rewards are considered taxable business income.

• Skill-Testing Question: For Giveaway prizes, correctly answering the skill-testing question converts a “lottery prize” to a “prize for achievement,” which may have different tax treatment.

• Withholding: We do not strictly withhold tax for Canadian residents under “Pro Partner” status, but “Standard Members” are subject to the 10% processing fee. We may request SIN for compliance if necessary.

12.12.5 European Union: GDPR & Country Specifics Tax data is processed according to GDPR (legal obligation basis). Rules vary by country:

• United Kingdom: Draw prizes are usually tax-free. However, cash rewards from referral activities may be subject to Income Tax & NI contributions if considered “trading income.”

• Germany: Draw prizes <€1,000 are generally tax-free. Rewards from systematic activity (referrals) are taxable. Freiberufler must report this as income.

• France: Occasional gains from prizes (<€30,000) are generally tax-free. Professional activity is taxed as BNC/BIC.

• Greece:

  • Standard Members (Private Individuals): Cash payouts and Draw Prizes are treated as income from prizes/sources without supporting documents. The 10% automatic deduction applied by us covers the withholding tax obligation. We issue a withholding certificate for your tax return (E1).

  • Systematic Activity: If your referrals constitute systematic activity (>5 referrals/month or annual value >€1,000), you should consult a tax advisor regarding taxation as business income (Category C’).

  • Vouchers/Subscriptions: Generally not taxed as income unless considered systematic activity.

  • Winner Obligations: You must provide your Tax ID (AFM) before a cash payout.

• Cyprus: Prizes are usually tax-free for individuals. Business income is subject to corporate tax.

• General EU Note: If the total reward value exceeds national thresholds or you act as a professional affiliate, you likely have tax obligations. Consult a local tax advisor.

12.12.6 Other Countries

• Australia (ATO): Systematic referral activity is considered assessable income.

• International: Winners are responsible for customs duties, VAT, and other import fees for physical prizes.

• Double Taxation: Tax treaties may apply if you reside in one country but are tax resident in another.

12.12.7 Record Keeping We recommend maintaining all reward confirmation emails, copies of invoices (for Pro Partners), and records of redemption.

• Retention: We retain tax-related records for 7-10 years as required by law.

12.13 Referral Program Data Protection

12.13.1 Data We Collect: For Referrers: Name, email, phone (optional), Address (for physical prize shipping), Tax information (when required), Number of referrals, dates, status, Level/category achievement, Earned rewards, Redemption history, Promotion methods (URLs, channels), Interaction with program. For Referred (New Customers): Same as regular customer (see §13), Link with referrer code (for attribution), Click date/time, IP, device. Technical Data: Referral tracking cookies, IP addresses, geolocation, Device fingerprints, Click/conversion timestamps, Session data.

12.13.2 Legal Basis for Processing (GDPR): Contract: Execution of referral agreement. Legitimate Interests: Fraud prevention, program optimization. Legal Obligation: Tax reporting, AML compliance. Consent: Marketing communications (opt-in). 12.13.2-A: Legitimate Interest Assessment: “For fraud prevention, our legitimate interest is: Protection of program integrity, Avoidance of financial losses, Fair distribution of rewards. Processing limited to: Automated pattern analysis, No profiling for other purposes, Data deleted after 10 years. Your rights: You can object based on GDPR Art. 21”.

12.13.3 Data Use: We use data exclusively for: Managing referral program, Referral attribution, Calculating and distributing rewards, Fraud detection & prevention, Program communication, Tax compliance, Legal obligations, Program improvements (anonymized aggregated analytics). We do NOT use for: Sale to third parties, Unrelated marketing (without consent), Profiling outside referral context.

12.13.4 Data Sharing: We share with: Payment processors: For reward payment (Stripe, PayPal, etc.). Shipping providers: For physical prize delivery (FedEx, DHL, etc.). Tax authorities: When legally required (IRS, HMRC, etc.). Fraud prevention services: For security checks (MaxMind, Sift, etc.). Analytics platforms: Anonymized aggregated data (Google Analytics, etc.). Legal/auditors: For compliance. Leaderboards: Only pseudonyms (opt-in). We do NOT share with: Affiliates (they don’t see referred personal data), Competitors, Marketing databases, Data brokers.

12.13.5 Data Retention: Active participants: As long as you participate + 1 year. Inactive: 3 years from last activity. Tax records: 7 years (legal requirement). Fraud records: 10 years (for protection). Anonymous statistics: Unlimited. After expiry: Personal data deleted or anonymized. Tax/legal records retained (encrypted).

12.13.6 Your Rights (GDPR/CCPA): Right of Access: Request copy of your data, Receive within 30 days (GDPR) / 45 days (CCPA). Right of Rectification: Update inaccurate data, Immediate processing via dashboard or request to us. Right to Erasure (“Right to be Forgotten”): Request deletion of personal data. Exceptions: Tax records, legal requirements, pending transactions. Right to Restriction: Restrict processing to specific purposes. Right to Portability: Receive data in structured, machine-readable format (CSV/JSON). Right to Object: Object to marketing communications, Object to profiling (where applicable). Opt-Out from Sale (CCPA): We don’t sell personal data, so not applicable. How to Exercise Rights: Email: legal-privacy@totalsupervisor.com, Dashboard: Privacy Settings, Written request to our address. Response within 30 days.

12.13.7 Data Security: Technical Measures: Encryption in transit (TLS 1.3) and at rest (AES-256), Secure databases with access controls, Regular security audits & penetration testing, Firewall & intrusion detection systems, Encrypted backups. Organizational Measures: Least privilege access (limited employee access), Mandatory staff training, Confidentiality agreements, Incident response plan. Data Breach: In case of breach: Notification within 72 hours (GDPR), Inform affected users, Report to authorities (DPA, ICO, etc.), Take corrective measures. Processor Agreements: All third-party data processors (Stripe, PayPal, etc.) have signed Data Processing Agreements (DPA).

12.14 Customer Status Verification & Transition

12.14.1 Automatic Verification: Our system automatically checks in real-time: Whether account has confirmed GPS tracker purchase, Delivery status (delivered = confirmed), Return status (no return = valid). Real-Time Status: Your status updates immediately: After order: “Pending Verification”, After delivery: “Full Status” (or “Basic Status” if didn’t purchase tracker), After return: Return to “Basic Status”.

12.14.2 Dashboard Updates: In your account you see: Status Badge: “Full Participant” = With GPS tracker purchase → All rewards, “Basic Participant” = Without purchase → Only vouchers/gifts. Available Rewards: List with check (you qualify) or x (you don’t qualify). E.g., “3-month subscription x (Requires GPS tracker purchase)”. CTA Button: For Basic Participants: “Upgrade to Full Status – Shop Trackers”, Link to product page.

12.14.3 Transition to Full Status: Upgrade Process: Purchase GPS Tracker: Any model from e-shop. You can use vouchers you’ve earned! Automatic Detection: System links purchase with your referral account. Within 24 hours of delivery. Status Upgrade: Your badge changes to “Full Participant”. Confirmation email. Dashboard notification. Reward Activation: Future rewards include subscriptions. For System B: If you’ve already achieved 10+ referrals, receive guaranteed 4-year subscription within 7 days. What Does NOT Change Retroactively: Vouchers already earned → Remain as is. If you already passed a level (e.g., Silver) without receiving subscription → Not retroactively returned. Exception System B: Guaranteed 4-year subscription is NOT retroactive UNLESS upgrade happens within same quarterly draw period. Example: January: Registration without purchase (Basic). February: Bring 10 referrals → Don’t get 4-year subscription. March: Purchase tracker → Upgrade to Full. April: Bring 5 more (total 15) → Now get all Silver benefits including subscription.

12.14.4 Downgrade (Tracker Return): If you return your GPS tracker: Return to “Basic Status” within 48 hours. Active subscriptions continue until expiry (not cancelled). Future rewards = only vouchers.

12.15 Disputes, Interpretations & Final Terms

12.15.1 Document Priority Order: In case of conflict or ambiguity, the following apply in order: Official Sweepstakes Rules (System B) – Legally binding document for draws. These Referral Program Terms (§12) – Detailed program rules. General Terms of Use (§1-§11, §13-§20) – Broader e-shop terms. Privacy Policy (§13) – Data protection. Email communications – Notifications & updates.

12.15.2 Interpretation & Discretion: Company Decisions: All decisions regarding eligibility, fraud, rewards, and draws are final and binding. We exercise discretion in good faith. We are not obligated to justify every decision publicly. Exceptions: We may make exceptions for: Technical errors not caused by you, Force majeure affecting your participation, Errors on our part. Exceptions decided case-by-case and don’t create precedent.

12.15.3 Severability: If any provision of this §12: Deemed invalid, illegal, or unenforceable in specific jurisdiction. Remaining provisions remain in full force. Invalid provision modified to minimum necessary to become valid. Geographic Adaptation: Program may be modified for compliance with local laws: E.g., Quebec: Only System A, skill question. E.g., Florida: Bonds, registrations. This doesn’t affect program operation in other regions.

12.15.4 Waiver: Our failure to enforce any right or provision: Does NOT constitute waiver of that right. We can enforce it in future. We can choose which breach to enforce.

12.15.5 Entire Agreement: This §12, together with General Terms (§1-§20), constitutes entire agreement for Referral & Gamification Program. Supersedes: Oral statements, Previous versions of terms, Email communications (unless explicitly modifying terms).

12.15.6 Assignment: You: Cannot assign/transfer your participation. Cannot transfer rewards to another account. Cannot sell your referral account. We: Can assign to subsidiaries, partners, or successors. Can transfer program to another entity. Will notify you of significant changes.

12.15.7 Headings: Section/subsection titles: Are only for reference convenience. Don’t affect interpretation. Don’t constitute part of legal text.

12.15.8 Language: Official Language: English version is official/legally binding. Translations provided for convenience. In case of discrepancy, English prevails.

12.15.9 Force Majeure: We’re not liable for delays/failures due to: Natural disasters (earthquakes, floods, fires), Pandemics/epidemics, War, terrorism, civil unrest, Government actions (embargos, sanctions), Telecommunications/internet disruptions, Strikes, labor disputes, Third-party failures (payment processors, shipping). In such cases: Temporarily suspend program, Extend deadlines, Or terminate according to §12.11.4. END OF SECTION 12 – VIRAL REFERRAL GAMIFICATION PROGRAM For questions about Referral Program: Email: referral@totalsupervisor.com Phone: +40 76 100 7040 (Mon-Fri, 9AM-6PM)

13. DATA PROTECTION & PRIVACY

13.1 Legal Framework We comply with:

• GDPR (European Union)

• CCPA (California)

• Other applicable privacy laws

13.2 Data Collection We collect:

• Account details (name, email, address)

• Payment information (via secure providers)

• Device location data (with your consent)

• Usage data (IP, browser, site behavior)

• Cookies & tracking technologies

13.3 Data Use We use data for:

• Executing orders and services

• Account communication

• Product/service improvement

• Marketing (with consent)

• Fraud detection

13.4 Data Sharing We share with:

• Service providers (hosting, payments, shipping)

• Affiliate partners (sales only, not personal details)

• Legal authorities (when required)

13.5 Your Rights You have the right to:

• Access your data

• Correct inaccurate information

• Delete data (right to be forgotten)

• Restrict processing

• Data portability

• Object to marketing

13.6 Data Retention Active accounts: as long as needed. Inactive accounts: 2 years. Location data: 24 months. Transaction records: 7 years (tax compliance).

13.7 Security We implement:

• SSL/TLS encryption

• Secure servers

• Regular security audits

• Limited employee access

• Breach response plans

13.8 Data Protection Officer: Email: dpo@totalsupervisor.com

14. COOKIES & TRACKING

14.1 Cookie Use We use cookies for:

• Basic functionality (cart, login)

• Preferences

• Analytics (Google Analytics)

• Advertising (remarketing)

• Affiliate tracking

14.2 Cookie Types Essential: Required for operation. Functional: Enhance experience. Analytics: Understand usage. Marketing: Targeted ads.

14.3 Cookie Management You can control via browser settings. Disabling affects functionality. Cookie consent banner on first visit.

15. LEGAL COMPLIANCE

15.1 Consumer Laws We comply with:

• EU Consumer Rights Directive

• Consumer Protection Law (Greece)

• FTC Act (USA)

• Sale of Goods Act

• 15.2 Commercial Communications We don’t send spam. Opt-in for marketing email. Easy unsubscribe process. Respect do-not-track requests.

• 15.3 Accessibility We strive to comply with WCAG 2.1 accessibility guidelines.

• 15.4 Export Regulations Certain GPS products may be subject to export restrictions. You’re responsible for compliance with local laws.

16. ACCOUNT TERMINATION

16.1 Termination by You You can delete anytime. Cancel active subscriptions before deletion. Data deleted according to retention policy.

16.2 Termination by Us We may terminate for:

• Terms violation

• Illegal activity

• Non-payment

• System abuse

• Legal authority request

• 16.3 Termination Effects Loss of service access. Location data deleted. Pending affiliate/referral commissions cancelled. No refunds for partial periods.

17. DISPUTE RESOLUTION

17.1 Applicable Law These Terms and Conditions shall be governed by and construed in accordance with the laws of Romania, without regard to its conflict of law provisions.

17.2 Jurisdiction Any dispute, controversy, or claim arising out of or in relation to this Agreement, including the validity, invalidity, breach, or termination thereof, shall be subject to the exclusive jurisdiction of the competent courts located in Iasi, Romania.

17.3 Amicable Resolution Before initiating any legal proceedings, the Parties agree to attempt to resolve any dispute amicably. You agree to contact us at info@totalsupervisor.com describing the issue. We will try to resolve the matter within 30 days.

17.4 Class Action Waiver You agree that any arbitration or proceeding shall be limited to the Dispute between us and you individually. To the full extent permitted by law, no arbitration or proceeding shall be joined with any other or resolved on a class-action basis.

18. TERMS MODIFICATIONS

18.1 Right to Modify We reserve right to modify these terms at any time.

18.2 Change Notification Substantial changes: 30 days’ notice via email. Minor changes: posting on website. “Last updated” date at top.

18.3 Change Acceptance Continued use after changes constitutes acceptance of new terms.

19. MISCELLANEOUS

19.1 Entire Agreement These terms constitute entire agreement between you and Company.

19.2 Severability If any provision is invalid, remaining provisions remain in full force.

19.3 Waiver Failure to enforce any right doesn’t constitute waiver.

19.4 Assignment You cannot assign this agreement. We can assign to partners/successors.

19.5 Headings Section titles for convenience only and don’t affect interpretation.

19.6 Force Majeure We’re not liable for delays due to force majeure events (natural disasters, war, pandemics).

20. CRASH DETECTION & EMERGENCY RESPONSE SERVICE

20.1 Nature of the Service (Best Effort) The “Crash Detection & Emergency Response” service is provided strictly on a “Best Effort” basis. The Company acts solely as an information intermediary between the User and Emergency Services (112).

• NOT a Substitute for eCall: This service is a supplementary safety tool and does NOT replace the mandatory EU eCall system installed in vehicles, nor does it guarantee the preservation of life.

• No Guarantee: We do not guarantee that the crash detection will trigger in all accident scenarios (e.g., low-speed impacts, specific angles) or that the notification will be successfully transmitted if cellular coverage is missing.

20.2 The Emergency Protocol By activating this service, you explicitly agree to the following strict protocol in the event that our system receives a “Crash Alert” from your device:

1. Verification Attempt: Our operators will attempt to contact you immediately via the phone number registered in your account. We may also attempt to contact your designated secondary Emergency Contact (if provided).

2. No-Answer Scenario: If neither you nor your emergency contact answers our call(s) within a reasonable timeframe (typically 1-3 minutes), or if your phone is unreachable:

   • PRESUMPTION OF DANGER: We are contractually authorized by you to presume that you are incapacitated and in need of urgent assistance.

   • MANDATE TO ACT: You hereby grant us an irrevocable mandate to contact the National Emergency Number (112) or relevant authorities on your behalf.

   • DATA TRANSFER: You explicitly consent to the transfer of your location data (GPS coordinates), personal details, and vehicle information to the emergency services (Legal Basis: Protection of Vital Interests, GDPR Art. 6(1)(d)).

20.3 Liability for False Alarms & Costs You acknowledge that automated crash sensors may occasionally produce false positives (e.g., dropping the device, driving over severe potholes).

• Your Responsibility: It is your absolute responsibility to answer our verification call to cancel a false alarm.

• Indemnification: If we proceed to call 112 because you failed to answer our verification attempts, and it is later proven that no accident occurred (False Alarm):

  • You assume FULL LIABILITY for any fines, penalties, or charges imposed by the Police, Fire Department, or Ambulance Services for unnecessary mobilization.

  • You agree to indemnify and hold the Company harmless against any claims or costs arising from such actions taken in good faith following the Protocol.

20.4 Limitations of Service (Force Majeure) The Company shall NOT be liable for any failure to alert emergency services caused by factors beyond our control, including but not limited to:

• Lack of GSM/GNSS Signal: If the device is in a “dead zone” (tunnel, remote area, underwater) and cannot transmit data.

• Device Destruction: If the accident is so severe that the device battery or modem is destroyed before transmitting the alert.

• Emergency Services Response: We are responsible only for relaying the information. We are strictly NOT liable for the response time, negligence, or failure of the 112 operators or ambulance services to arrive at the scene.

20.5 Waiver of Claims YOU EXPRESSLY WAIVE ANY RIGHT TO SUE THE COMPANY FOR DAMAGES, INJURY, OR DEATH RESULTING FROM A FAILURE OF THE DEVICE TO DETECT AN ACCIDENT, A FAILURE OF THE NETWORK TO TRANSMIT THE ALERT, OR A FALSE ALARM THAT RESULTED IN PROPERTY DAMAGE (E.G., FORCED ENTRY BY POLICE).

21. CONTACT INFORMATION

For questions about these Terms: Customer Support: Email: info@totalsupervisor.com Phone: +40 76 100 7040 Hours: Monday-Friday, 09:00-18:00 (EET) Legal & Privacy Matters: Email: legal-privacy@totalsupervisor.com Mailing Address: Noua 139, Horpaz, Miroslava, Iasi, Romania