General Terms and Conditions (GTC)

PREAMBLE AND CONTRACTUAL ENFORCEABILITY

These General Terms and Conditions (hereinafter the "GTC") define the access, use, and the single, mandatory, and enforceable contractual framework governing the relationship between the company PALINDROME CAPITAL ADVISORY S.à r.l.-S. (hereinafter referred to as "PCA" or "TRNKYLU") and its professional clients registered as Providers (as defined below), as well as TRNKYLU and the end Users (as defined below) registered as Consumers.

TRNKYLU provides tools for connection, booking, payment via a third-party payment service provider, proof of execution, and documentary management of disputes.

TRNKYLU is not a party to the service contract directly concluded between the Provider and the Consumer and does not assume the execution of the Service, unless expressly stated otherwise in writing.

No general or specific conditions emanating from the Provider or the Consumer may prevail over these clauses, unless with prior written agreement from TRNKYLU.

ARTICLE 1 — DEFINITIONS

For the interpretation and execution of these GTC, the following terms have the definitions below:

ARTICLE 2 — PURE INTERMEDIATION AND LIMITATION OF LIABILITY

2.1 Role of the Platform

TRNKYLU acts exclusively as a connection platform operator and digital technical intermediation electronic broker. Specifically, TRNKYLU provides a technical and commercial infrastructure via the Platform allowing: the transmission of Missions, the visibility of Providers, booking, payment processing via a third-party PSP, the issuance of invoices in the name and on behalf of the Provider to the Consumer, and regulatory reporting.

TRNKYLU does not carry out any material craft, cleaning, domestic, or maintenance activities, and in no case acts as a prime contractor, temporary work agency, personal service company, or recruiter.

TRNKYLU does not control the working methods, the tools used, the schedules chosen by the Provider, nor the way the Mission is executed. The Provider carries out their activity in complete commercial and operational independence.

2.2 TRNKYLU's remuneration model

TRNKYLU collects a brokerage commission (hereinafter the "Commission"), calculated based on the price freely set by the Provider for each Mission. The Commission is added to the Provider's price to form the total price incl. VAT displayed to the Consumer on the Platform and/or their invoice.

The Provider receives the entirety of their base price via the PSP, without deduction of the Commission. TRNKYLU collects its Commission directly on the transaction during payment by the Consumer. The price displayed to the Consumer transparently indicates the part returning to the Provider and the TRNKYLU service Commission, in accordance with Article 10.

TRNKYLU does not charge the Consumer access fees to the Platform. TRNKYLU's service fees (Commission) are integrated into the total transaction price and do not constitute an additional charge levied separately on the Consumer outside the transaction.

2.3 Relationship between the Provider and the Consumer

The Mission is provided by the Provider to the Consumer under a direct contract concluded between them at the time of booking confirmation. This contract exclusively binds the Provider and the Consumer. The Provider is solely responsible for the execution, quality, safety, and compliance of the Service. TRNKYLU remains an absolute third party to this enterprise contract.

2.4 Contractual relationship between TRNKYLU and the Provider

The Provider concludes with TRNKYLU under these GTC which constitute a brokerage and technical intermediation contract, allowing access and use of the Platform. The purpose of this contract is the provision of intermediation tools and the collection of the Commission. The method and speed of connection may depend on the rating system. The Provider agrees to comply with the GTC, provide all required documents, and pay the applicable Commission. In the event of a breach of these GTC, TRNKYLU may restrict or suspend the Provider's access to the Platform, according to the procedure set out in Article 14. The Provider is in no way an employee of TRNKYLU.

2.5 Relationship between TRNKYLU and the Consumer

TRNKYLU provides the Consumer with a connection service and booking and payment tools. PCA reserves the right to prioritize Providers according to the rating system. TRNKYLU is not a party to the Mission contract and does not assume responsibility for the execution of the Service, except for gross negligence or willful misconduct by TRNKYLU. The Consumer agrees to comply with these GTC. Once the Mission is completed, the Provider and the Consumer will have a validation tool, allowing the Mission to subsequently be deemed completed.

2.6 User Charter

The User Charter attached as Appendix I is an integral part of these GTC. The Provider and the Consumer agree to comply with it upon Account creation and during each booking.

2.7 Exclusion of operational liability

TRNKYLU acts as an intermediation platform operator and is not a party to the enterprise contract concluded between the Consumer and the Provider. As such, TRNKYLU declines any contractual liability for defects, non-compliance, delays, material damage, theft, or data loss attributable to the execution of the Mission by the Provider.

2.8 Cap on damages

If TRNKYLU's liability is validly established by a final court decision of a Luxembourg court for a proven breach of its exclusive technical intermediation obligations, the total amount of compensation charged to it may not exceed the value of the net brokerage commission received by TRNKYLU on the specific transaction related to the dispute, subject to the mandatory limits referred to in Article 2.7.

ARTICLE 3 — REGISTRATION, ADMINISTRATIVE OBLIGATIONS, AND KYB/AML PROTOCOL

3.1 Eligibility conditions

Registration as a Provider on the Platform is strictly reserved for registered professionals. The Provider must necessarily be a legally established independent worker, such as a micro-enterprise, a sole proprietorship, or a commercial company able to send its declared employees. Registration of non-professional individuals is prohibited. At the time of Account creation, the Provider, their legal representative, or their employees must be at least eighteen (18) years old.

3.2 Know Your Business (KYB) Verification

To be activated and receive Mission alerts, the Provider must validate their identity and the legitimacy of their structure via the integrated Stripe Identity infrastructure or directly with TRNKYLU. The Provider must expressly indicate the type of Missions that can be performed.

The Provider must be able to provide and keep up to date the following documents (non-exhaustive list):

• Email address and WhatsApp phone number;
• ID of the legal representative;
• Extract from the trade register or equivalent (e.g., Kbis, RCS extract);
• Company statutes, if applicable;
• Tax identification number;
• Intra-community VAT number if applicable;
• Proof of affiliation to a social security system in the country of residence (official certificate);
• Declaration of beneficial owners (UBO), if applicable;
• Bank details (IBAN) in the name of the Provider;
• Valid professional civil liability insurance certificate;
• Proof of activity (invoices, contracts, references), if requested;
• AML questionnaire and information on the origin of funds, if applicable.

TRNKYLU may request any additional document justified by its regulatory obligations, notifying the Provider with reasonable notice.

3.3 Verifications and consequences

In case of failure to communicate certain documents, TRNKYLU will send a request to the Provider, who will have a period of seven (7) days to reply. TRNKYLU performs automated and manual checks. In the event of an anomaly or missing documents, TRNKYLU may suspend the publication of offers, limit functionalities, withhold payments, require additional documents, or delete the Account. Failure to cooperate may be communicated to the competent authorities.

3.4 Updates

The Provider agrees to keep the information and documents provided up to date and to notify TRNKYLU of any relevant change.

ARTICLE 4 — EUROPEAN TAX COMPLIANCE AND DAC 7 COMPLIANCE

4.1 DAC 7 reporting platform status

The Provider is formally informed that TRNKYLU, as a digital collaborative economy platform operator established in Luxembourg, is subject to automatic data collection and reporting obligations resulting from European Directive (EU) 2021/514 (known as "DAC 7").

4.2 Automated data transmission

TRNKYLU has a legal and regulatory obligation to compile all activity data, gross business volume generated, bank details, and tax information of Providers. Certain information may be transmitted automatically each year to the competent tax administrations according to the applicable deadlines and cases.

4.3 Irrevocable consent

The Provider accepts this teletransmission without any prior notice, notification, or additional authorization being required from TRNKYLU at the time of tax filing, as well as to collaborate in the collection of information.

ARTICLE 5 — OFFERS, DEMANDS, ACCEPTANCES, AND EXECUTION OF SERVICES

5.1 Operational model

5.1.1. Registration of the Provider

The Provider registers on the Platform, fills in all required fields, transmits the necessary documents, and indicates their available Offers.

5.1.2. Transmission of the Demand and acceptance by the Provider

The Consumer submits a Demand (description, scope of the Mission (nature, surface, volume, or quantity), date/time, location, possible photos). The Consumer will receive a confirmation email to confirm the Demand and the Consumer's email. After this validation step, the Demand will be transferred to the Providers competent for the requested Mission. Once the Mission is accepted, the Consumer will receive an email detailing in particular the price incl. VAT (including the Commission). Once this email is received, the Consumer will have the opportunity to formulate specific details regarding their request and their Mission. Providers receive the Demand and can accept or refuse via the Platform. The Consumer acknowledges that longer acceptance times may apply outside working days and normal working hours.

5.1.3. Acceptance by the Consumer and payment

Acceptance by a Consumer, via the indication of their bank details and payment via the PSP, constitutes contractual confirmation between this Provider and the Consumer. TRNKYLU is not a party to this contract. However, acceptance constitutes execution of TRNKYLU's intermediation obligation, and the Commission will be due.

The Consumer has a period of twenty-four (24) hours to proceed with this acceptance. After this period, the Provider is entitled to cancel the Mission. The Commission remains due in all cases, in accordance with Article 11.

5.2 Consumer's information obligations

The Consumer must provide an accurate and complete description of the location, constraints, surfaces, and expectations. Any information likely to affect the time, equipment, or safety must be communicated before booking. The Consumer must also provide their email address and WhatsApp number to TRNKYLU for transmission to the Provider.

5.3 Proof of execution, before/after photos, and right of refusal

5.3.1. Mandatory proofs

For the categories defined by TRNKYLU, the Provider must take before/after photos and, if required, an intervention report with a timestamp and geolocation, and transmit them directly to the Consumer to attest to the execution of the Mission.

5.3.2. Right of refusal / interruption

The Provider may refuse to execute or interrupt a Service if, upon arrival or after examination, the condition of the premises presents a risk to safety, health, the integrity of the equipment, or if the scope of work clearly exceeds the booked Service. TRNKYLU is a third party to the contract linking the Provider and the Consumer for the execution of the Mission.

5.3.3. Procedure

In the event of refusal or interruption, the Provider documents the condition of the premises with proofs (timestamped photos), immediately notifies the Consumer via the Platform's internal messaging system, and offers an additional quote or cancellation. Hereby, the Consumer accepts the taking of photos, subject to the provisions of the TRNKYLU Platform User Charter (Appendix I).

5.3.4. Financial consequences

If the Consumer accepts the quote, the Service resumes after agreement and payment. If the Consumer refuses, the booking is canceled and the cancellation and compensation rules provided for in the GTC apply. TRNKYLU's Commission remains due unless TRNKYLU decides otherwise.

5.3.5. Avenues of recourse

The Consumer and the Provider may resort to mediation (Article 15) or competent legal channels. TRNKYLU is a third party to the contract linking the Provider and the Consumer and does not intervene in legal proceedings between these parties.

5.4 Provider's obligations

The Provider guarantees the conformity, quality, safety, and fairness of the Services. They respect the deadlines, the published descriptions, and the applicable safety rules. The Provider is responsible for all consequences related to the execution of the Mission.

ARTICLE 6 — FIXED PRICING

6.1 Provider's freedom of pricing

The Provider freely sets their price for each Mission offered on the Platform. TRNKYLU provides a tool for presenting and calculating prices but does not determine or validate the prices set by the Providers. TRNKYLU imposes no minimum or maximum price.

6.2 Fixed-price model

The Provider exclusively offers their services in the form of a fixed price. The Provider commits to the Consumer that the fixed price constitutes the final price for the described Mission, regardless of the actual execution time.

6.3 Incompressibility rule

For Missions accepted on a fixed-price basis, the agreed fixed price is fully due to the Provider, regardless of the actual execution time (except for Provider fault). If the Provider completes the Mission below the agreed scope, the total value of the fixed price remains acquired, without the Consumer being able to demand any partial refund, pro-rata, or discount. In accordance with the rules defined in Appendix I, the Provider is entitled to stop their Mission once the agreed scope is completed.

6.4 Absence of automatic overbilling

If the Mission required work exceeding the scope described in the Demand to accomplish their Mission, no additional sum may be demanded from the Consumer or assumed by TRNKYLU, except by explicit agreement between the Provider and the Consumer via the Platform.

However, if before the execution of the Mission the Provider estimates that the Mission requires additional time, equipment, or resources or is not in line with the scope described in the Demand, they must immediately inform the Consumer via the Platform and offer an additional quote. Execution of the additional work only begins after express acceptance by the Consumer and payment of the agreed sums. Failing agreement, the Provider may interrupt the Service and apply the cancellation and compensation rules provided for in the GTC.

ARTICLE 7 — FINANCIAL ESCROW MECHANISM, PAYMENT, AND CHARGEBACKS

7.1 Escrow upon booking

Upon acceptance of the Mission by the Provider, the total amount paid by the Consumer (Provider's base price plus TRNKYLU's Commission) is debited and placed in automated escrow via the Stripe Connect infrastructure, in the form of a delayed capture payment intent. The funds remain blocked for the entire duration of the Mission's execution. TRNKYLU does not store any of the Consumer's banking information. No direct physical settlement, over-the-counter, or cash payment is possible or tolerated.

7.2 Release of funds by the PSP

Unless mandatory legal provisions state otherwise, the sums paid by the Consumer will be transferred to the Provider according to one of the following methods, whichever occurs first:

• Express validation by the Consumer: at the moment the Consumer confirms via the Platform that the Mission has been completed; or
• Automatic deadline: forty-eight (48) hours after the completion date/time indicated in the booking.

Upon release of the funds, the Mission is deemed completed for the purposes of these GTC.

7.3 Consumer disputes

As TRNKYLU is not a party to the contract concluded between the Provider and the Consumer, any dispute relating to the execution, quality, or conformity of the Mission is settled directly between them, without intervention from TRNKYLU. TRNKYLU plays no role as an arbitrator or mediator in these disputes. The parties have the following avenues: direct amicable settlement, mediation (Article 15), or referral to competent courts. TRNKYLU's Commission is acquired once the connection is made and remains independent of any dispute between the parties. This provision is without prejudice to TRNKYLU's liability for its own breaches in its capacity as a platform operator, as defined in Article 2.7.

7.4 Contractual regulation of chargebacks

TRNKYLU assumes technical responsibility for financial disputes with the PSP. In return, the Provider accepts the following risk transfer mechanism:

7.5 Exclusion of liability for PSP failure

Financial services are provided exclusively by Stripe Payments Europe, Ltd. TRNKYLU declines all liability in the event of technical failure of the Stripe infrastructure, errors, transfer latency, account blocking related to Stripe's risk algorithms, or refusal of bank authorization. TRNKYLU is not a custodian of funds and does not store Users' banking data.

7.6 Reference PSP and applicable Terms of Use

Payments between Consumers and Providers are made through the PSP Stripe Payments Europe, Ltd. By using the Platform, the Consumer and the Provider accept the PSP's general terms and conditions accessible at: https://stripe.com/en-lu/privacy. In the event of a change of PSP, TRNKYLU will notify Users in accordance with Article 23 of these GTC.

ARTICLE 8 — TRNKYLU SERVICE COMMISSION

8.1 Commission structure

The TRNKYLU Commission is calculated at twenty percent (20%) excl. VAT of the base price freely set by the Provider. It is added to this price to constitute the total amount incl. VAT displayed and billed to the Consumer. The Provider receives the entirety of their base price via the PSP. TRNKYLU collects its Commission directly on the transaction.

8.2 Reduced rate for new Providers

For the first five (5) deemed completed Missions by any newly validated Provider, the TRNKYLU Commission is reduced to ten percent (10%) excl. VAT of the Provider's base price.

8.3 Premium Status

Any Provider who completes a minimum volume of ten (10) deemed completed Missions during a rolling calendar month benefits from a Premium status, reducing their Commission to ten percent (10%) excl. VAT for the following calendar month.

ARTICLE 9 — REVIEWS AND TRNKYLU'S RIGHT OF OVERSIGHT

9.1 Peer-to-peer review system

Consumers freely review Providers after each completed Mission, via the Platform interface. TRNKYLU does not manage and does not intervene in the attribution of reviews. The ratings exclusively reflect the autonomous opinion of Consumers. TRNKYLU does not modify, delete, or weight published reviews, except in cases of manifest violation of these GTC (fraudulent review, illicit or defamatory content).

9.2 TRNKYLU's right of oversight and Platform protection measures

TRNKYLU has a right of oversight over the reviews received by Providers, solely to preserve the integrity of the Platform and protect Consumers. TRNKYLU is not a manager of reviews; it can only, based on this right of oversight, take the following measures if the thresholds defined in Article 9.3 are met:

• Notification and improvement plan: when a Provider's average rating is below 3/5 over the last ten reviews.
• Visibility restriction and monitoring: in case of a low rating combined with repeated reports from Consumers.
• Temporary suspension then exclusion: in case of confirmed serious breaches, after an adversarial procedure in accordance with Article 14.

These measures are taken by TRNKYLU autonomously based on objective and predefined criteria, and not as a manager or arbitrator of ratings.

9.3 Display parameters for Providers

In accordance with Regulation (EU) 2019/1150, TRNKYLU informs Providers that the display order of Offers and Missions to Consumers is primarily determined by the rating given by Consumers. PCA reserves the right to introduce additional parameters (acceptance rate, seniority, KYB compliance) with prior notification in accordance with Article 23.

9.4 Reporting a review by a Provider

The Provider may report to TRNKYLU a review they consider fraudulent or contrary to the GTC within thirty (30) days of its publication. TRNKYLU examines the report as part of the internal complaint procedure (Article 16) but does not modify a legitimate review, even an unfavorable one. TRNKYLU does not have the power to impose the modification or deletion of an honest review expressed by a Consumer.

ARTICLE 10 — INVOICING MANDATE

10.1 Mandate

The Provider irrevocably mandates TRNKYLU, upon acceptance of these GTC and for the duration of their contractual relationship with TRNKYLU, to issue, in their name and on their behalf, any invoice, withholding notice, or equivalent document relating to sums due in the event of cancellation by the Consumer after confirmation of the Mission (intermediation fees, administrative fees, charges incl. VAT attributable to the Provider).

This mandate is limited to transactions carried out via the Platform. It is irrevocable for current operations but may be revoked for new operations with reasonable written notice from TRNKYLU, subject to the settlement of all sums due.

10.2 Content and details of invoices

TRNKYLU issues, acting as an agent for the Provider, a single invoice to the Consumer for the total amount of the transaction (Provider's price plus TRNKYLU's Commission). This invoice expressly indicates: (i) that it is issued by TRNKYLU as an agent on behalf of the Provider; (ii) the full identity of the Provider (company name, address, tax identification number, and VAT number); (iii) the description of the Mission and the total amount incl. VAT paid by the Consumer.

TRNKYLU's Commission is deducted directly by the PSP at the time of the transaction split, before the base price is transferred to the Provider. It does not constitute a separate billing line addressed to the Consumer.

10.3 Discharging effect

Payment made by the Consumer to TRNKYLU via the PSP, documented by an invoice issued by TRNKYLU on behalf of the Provider, discharges the Consumer from their debt to the Provider up to the amount billed. The Provider receives their base price via the PSP; TRNKYLU directly collects its Commission.

10.4 Provider's obligations

The Provider guarantees the accuracy of the information provided to TRNKYLU necessary for issuing invoices and agrees to indemnify TRNKYLU for any consequences resulting from inaccurate information.

10.5 VAT and tax compliance

The tax treatment (VAT) of invoices depends on the Provider's tax status and the nature of the services. TRNKYLU recommends that the Provider consult their tax advisor to determine the VAT and accounting consequences applicable to their situation. The Provider is solely responsible for determining and applying the VAT rate applicable to their services and must communicate it to PCA for the issuance of invoices. TRNKYLU does not guarantee that the Provider's VAT rate is identical to the one applicable to its service Commission.

10.6 Social security affiliation

The Provider agrees to provide, where applicable, proof of affiliation to social security, particularly in the event of a request for a tax deduction by the Consumer.

10.7 Acceptance of electronic invoicing

The Consumer and the Provider authorize the issuance of invoices electronically.

ARTICLE 11 — RIGHT OF WITHDRAWAL AND CANCELLATION

11.1 Consumer's right of withdrawal

In accordance with Directive 2011/83/EU and the Luxembourg Law of April 2, 2014, on consumer rights, the Consumer has a withdrawal right of fourteen (14) days from the conclusion of the contract, subject to legal exceptions applicable to fully executed services.

TRNKYLU, acting as an agent for the Provider, processes the Consumer's withdrawal requests. In the event of valid exercise of the right of withdrawal, TRNKYLU proceeds with the refund within a period of fourteen (14) days.

The standard withdrawal form is attached in Appendix III of these GTC and is accessible in one click from the booking interface.

11.2 Retention of TRNKYLU's Commission

If the Consumer decides to cancel their Mission after acceptance by the Provider, TRNKYLU's Commission is deemed acquired and remains fully due to TRNKYLU to the extent that TRNKYLU has already performed the intermediation service (visibility, verifications, connection). TRNKYLU will issue, if applicable, an invoice addressed to the Consumer detailing the Commission, in the name and on behalf of the Provider.

However, when the law imposes a free right of withdrawal on the Consumer, TRNKYLU will adapt its billing to comply with applicable law. TRNKYLU will also waive the collection of the Commission if the cancellation is due to its gross negligence or willful misconduct.

11.3 Professional Provider's right of withdrawal

The professional Provider benefits from a legal withdrawal period of fourteen (14) days from their onboarding. The Provider acknowledges that the connection made by TRNKYLU with the Consumer before the expiration of the 14-day period constitutes a distinct and immediately executed service. Consequently, the Commission due to TRNKYLU remains payable even if the Provider cancels after confirmation, except for gross negligence or willful misconduct by TRNKYLU.

ARTICLE 12 — PROTECTION AGAINST DATA SCRAPING AND RE-ENGAGEMENT

12.1 Absolute prohibition of data scraping

It is strictly prohibited to extract, collect, index, or store automatically or manually any information relating to Providers and Consumers, WhatsApp numbers, pricing grids, or profiles, via natural or legal persons, robots, spiders, scraping scripts, or data mining techniques. Any violation of this clause will result in the immediate blocking of the User and the initiation of criminal and civil proceedings by TRNKYLU.

12.2 Declared right of client re-engagement

As an exception to the principle of prohibiting disintermediation, the Consumer is contractually authorized to directly re-engage a Provider previously discovered on TRNKYLU for subsequent work, provided they log into the official TRNKYLU interface and declare the re-engagement via the dedicated form. In the event of non-use of the Platform for this re-engagement, the Penalty Clause provided for in Article 12.3 applies automatically.

12.3 Differentiated Penalty Clause

12.3.1. For Professional Providers

Any circumvention or clandestine direct contracting outside official channels and without prior declaration exposes the Provider to a lump-sum penalty clause of one thousand euros (€1,000) per observed offense, automatically due as damages, without prejudice to TRNKYLU's other remedies. This penalty may be subject to judicial moderation in accordance with Article 1229 of the Luxembourg Civil Code.

12.3.2. For Consumers

Any Consumer who deliberately circumvents the Platform to directly re-engage a Provider discovered on TRNKYLU, without prior declaration, is liable to have their Account suspended and a claim for reimbursement of the savings made on the Commission, up to the limit of the prejudice demonstrated by TRNKYLU. No flat-rate penalty of €1,000 applies to Consumers.

ARTICLE 13 — OBLIGATION OF COOPERATION AND ADMINISTRATIVE AND TAX CO-DEFENSE

13.1 Obligation of cooperation

In the event of an administrative control, audit, investigation, or verification by any competent authority, such as the Labor and Mines Inspectorate (ITM), the Joint Social Security Centre (CCSS), or the Direct Tax Administration (ACD), targeting the TRNKYLU structure or TRNKYLU, the professional Provider agrees to provide total, immediate, and good-faith cooperation to TRNKYLU.

13.2 Provision of documents

The Provider has a contractual obligation to provide TRNKYLU, upon first request and within a maximum period of forty-eight (48) working hours, with all staff registers, tax returns, accounting books, payslips, and VAT evidence required to demonstrate the perfect legality of their interventions and exonerate TRNKYLU from any joint and several liability.

ARTICLE 14 — EXCLUSION OF INFORMAL WORK AND ACCOUNT SANCTION

14.1 Zero tolerance

The Professional and the Consumer agree to respect an absolute integrity charter, as defined in Appendix I, particularly concerning the prohibition of undeclared work and declarative obligations towards the Direct Tax Administration (“ACD”) and any other competent administration.

14.2 Procedure

Except in emergencies or proven risks, TRNKYLU notifies the Provider and allows them a reasonable time to defend themselves and correct the situation before any sanction.

The following are considered serious breaches justifying immediate and irrevocable exclusion from the Platform, without notice or compensation:

• Any proposal or acceptance of undeclared work (moonlighting) or cash payment aimed at defrauding the AED, the ACD, or any other administration;
• Theft, intentional damage, verbal or physical assault, harassment, or discriminatory remarks observed during a Mission;
• The accumulation of three (3) ratings below 3 stars in the rating system, characterizing an insufficiency in professional quality.

14.3 Effects of termination

Provisions relating to intellectual property, confidentiality, payments, and liability survive the termination of the Account and remain applicable after the end of the contractual relationship.

ARTICLE 15 — MEDIATION AND ALTERNATIVE DISPUTE RESOLUTION

15.1 Prior internal complaint

Before resorting to mediation, the User is invited to submit their complaint to TRNKYLU via the contact details defined in Article 28, in order to find an amicable solution.

15.2 Consumer mediation

In accordance with the Luxembourg Law of February 10, 2016, on consumer mediation and Directive 2013/11/EU, in the event of a dispute between TRNKYLU and a Consumer relating to the services provided by TRNKYLU, and after the failure of an internal complaint, the Consumer may resort free of charge to consumer mediation.

The competent mediation entity is: The Civil and Commercial Mediation Center (Centre de médiation civile et commerciale), accessible at the following address: https://www.cmcc.lu/.

The Consumer may also use the European Online Dispute Resolution (ODR) platform accessible at: https://ec.europa.eu/consumers/odr/

15.3 Professional Provider mediation

Disputes between TRNKYLU and a Professional Provider may, failing an amicable agreement, be submitted to a mediator or arbitrator mutually agreed upon. Failing agreement on the designation of the mediator, the dispute will be submitted to the competent Luxembourg courts.

15.4 Optional nature

Resorting to mediation is optional and does not deprive the User of their right to take legal action. These GTC do not impede the legal rights of Consumers.

ARTICLE 16 — INTERNAL COMPLAINT PROCEDURE (PROVIDERS)

In accordance with Article 11 of Regulation (EU) 2019/1150 (P2B), TRNKYLU provides Providers with an internal complaint handling system, accessible free of charge:

The Provider may challenge any decision of suspension, modification of access conditions, or Commission calculation via this procedure, prior to any legal recourse. The procedure is free of charge and does not exclude legal channels.

ARTICLE 17 — LEGAL LINGUISTIC PRIORITY

The TRNKYLU booking interface is automatically translated into several languages (English, German, Portuguese, Luxembourgish) for the convenience of residents and expatriates. Users acknowledge and expressly accept that only the French version of these GTC is legally binding (available at the following address: https://trnkylu.com/fr/cgvu) and automatically prevails over any other translation in the event of a conflict of interpretation, semantic contradiction, or judicial dispute before the courts of the Grand Duchy of Luxembourg.

ARTICLE 18 — INSURANCE AND LIABILITY

18.1 Provider's insurance

The Provider must take out and maintain in effect a professional civil liability insurance covering all of their activities on the Platform, and provide proof of insurance upon any request from TRNKYLU.

18.2 TRNKYLU's liability

TRNKYLU acts solely as an intermediary. Except for gross negligence or willful misconduct, TRNKYLU's liability is limited to the amount of Commissions received by TRNKYLU in relation to the Mission. TRNKYLU will not be liable for indirect damages, loss of profit, loss of clientele, or commercial prejudice, within the limits of applicable law.

18.3 Provider's liability

The Provider is solely responsible for the execution of their Services, any damages caused to the Consumer or to third parties, and their tax and social obligations.

ARTICLE 19 — PERSONAL DATA AND GDPR COMPLIANCE

The Privacy Policy and the GDPR notice attached in Appendix II are an integral part of these GTC. The Provider and the Consumer have the rights provided for by Regulation (EU) 2016/679 (GDPR) and may exercise them with TRNKYLU's DPO at the address flow@trnkylu.com.

Any User also has the right to file a complaint with the National Commission for Data Protection (CNPD) in Luxembourg: www.cnpd.lu.

ARTICLE 20 — INTELLECTUAL PROPERTY

All contents of the Platform (source code, databases, trademarks, logos, interfaces, texts) are protected by applicable intellectual property rights. The Provider grants TRNKYLU a non-exclusive, worldwide, free, and transferable license to reproduce, represent, adapt, and exploit the contents they provide within the framework of the Platform, for the sole purpose of operating the intermediation service.

ARTICLE 21 — FORCE MAJEURE

The obligations of the parties are suspended in the event of a force majeure event, as defined by Luxembourg law. The party invoking force majeure must immediately notify the other party. In the event of prolonged force majeure beyond thirty (30) days, TRNKYLU may terminate the GTC without compensation.

ARTICLE 22 — COOKIE POLICY

The Platform uses technical cookies necessary for its operation (session, security, language preferences) and, with the User's consent, analytical cookies to improve services.

The User can manage their cookie preferences via the cookie manager available on the Platform. Refusing non-essential cookies does not affect access to main functionalities. The retention period for technical cookies is a maximum of thirteen (13) months.

ARTICLE 23 — MODIFICATIONS TO THE GTC

TRNKYLU reserves the right to modify these GTC. Any substantial modification will be notified to active Users by email to the address registered on their Account, with a minimum notice period of:

• Fifteen (15) calendar days for any general modification, prior to entry into force;
• Thirty (30) calendar days for modifications affecting commissions, Provider access conditions, or substantial User rights.

During this period, the Provider may terminate their contract without penalty by notifying TRNKYLU by email. The Consumer may close their Account free of charge.

Use of the Platform after the expiration of the notice period constitutes acceptance of the new GTC. Non-substantial modifications (spelling corrections, editorial clarifications) take effect immediately, with simple information.

ARTICLE 24 — TERMINATION

24.1 Termination initiated by the Consumer

The Consumer may close their Account at any time by sending a request to flow@trnkylu.com or via their Account settings. Closure takes effect within five (5) working days following the request, subject to the absence of pending bookings or unresolved disputes. TRNKYLU retains the Consumer's data for the legal retention periods after closure, in accordance with the Privacy Policy (Appendix II).

24.2 Termination initiated by the Provider

The Provider may terminate their contract with TRNKYLU at any time by sending a notification by email to flow@trnkylu.com, subject to a notice period of thirty (30) calendar days. During this period, the Provider honors already confirmed Missions. Termination takes effect at the end of the notice period, subject to the settlement of all Commissions due and the resolution of any pending dispute.

TRNKYLU retains the right to withhold necessary funds to cover potential chargebacks for an additional period of ninety (90) days after termination.

ARTICLE 25 — TEMPORARY SUSPENSION OF SERVICES

TRNKYLU may temporarily suspend access to the Platform for technical, maintenance, security, or update reasons. TRNKYLU endeavors to notify Users with a minimum notice of forty-eight (48) hours, except in cases of technical urgency.

TRNKYLU makes its best efforts to maintain a Platform availability of 99% on a monthly basis. TRNKYLU will not be liable for any losses resulting from a planned or urgent suspension duly notified.

ARTICLE 26 — ASSIGNMENT OF CONTRACT

TRNKYLU reserves the right to assign all or part of its rights and obligations under these GTC to any affiliated entity or acquirer of its Platform operating business, subject to informing Users with a thirty (30) day notice. In the event of assignment, Users may terminate their contract without penalty within thirty (30) days following notification.

The Provider may not assign their rights and obligations under these GTC without TRNKYLU's prior written consent.

ARTICLE 27 — PROTECTION OF MINORS

Access and use of the TRNKYLU Platform are reserved for adult natural persons (18 years or older). TRNKYLU does not knowingly collect personal data concerning minors. If TRNKYLU becomes aware of the registration of a minor, the Account will be immediately suspended and the data deleted in accordance with the GDPR.

Any User guarantees they are of the required age upon registration. Parents or legal guardians are encouraged to report any registration of a minor to the address: flow@trnkylu.com.

ARTICLE 28 — SUPPORT AND CONTACTS

The TRNKYLU Platform support service is available at the following details:

ARTICLE 29 — PARTIAL INVALIDITY AND ENTIRETY

If any clause is held invalid or unenforceable by a competent jurisdiction, the other clauses remain in full force. The parties will replace the invalid clause with a valid clause that best reflects the initial intent of the parties, in compliance with applicable law.

ARTICLE 30 — APPLICABLE LAW AND JURISDICTION

These GTC are governed by Luxembourg law. In the event of a dispute relating to the interpretation, validity, or execution of these GTC, the competent courts of the Grand Duchy of Luxembourg will have sole jurisdiction, except where mandatory provisions applicable to Consumers state otherwise.

APPENDIX I — TRNKYLU PLATFORM USER CHARTER

French version prevails — Integral part of the GTC

1. PURPOSE AND SCOPE

This Charter defines the rules of good conduct applicable to Users (Providers and Consumers), legitimate grounds for refusing a Service, the documentation and notification procedure, rules of evidence, and disciplinary consequences.

2. GENERAL PRINCIPLES

• Respect and courtesy between all Users;
• Transparency and accurate description of needs;
• Safety and legal compliance;
• Prohibition of undeclared work and circumventing the Platform.

3. CONSUMER'S OBLIGATIONS

• Provide an honest and complete description of the location, the nature of the work, the surface, access, and constraints.
• Ensure minimal conditions for intervention (water, electricity, access).
• Respect the Provider and treat them with courtesy, respect, and dignity. Any aggressive, threatening, harassing, insulting, or discriminatory behavior is prohibited.
• Commit to respecting the schedule and being present at the agreed time to welcome the Provider, or ensure proper access to the accommodation. If the Provider is locked out due to an access failure attributable to the Consumer, the cancellation conditions of the GTC apply after twenty (20) minutes of waiting observed on site.
• Do not request illegal work.
• Where applicable, formally object to the taking of photos. In return, the Consumer acknowledges that they cannot rely on this evidence in the event of a dispute.
• Tidy up, secure, and put out of reach of the Provider all valuables, jewelry, cash, portable electronic devices, passports, and confidential documents prior to arrival. Failure to comply with this obligation may result in the Consumer's liability. The Provider remains civilly and criminally liable for any act of theft or intentional damage.

4. PROVIDER'S CODE OF CONDUCT

By accepting the GTC, the Provider autonomously commits to respecting this code of conduct, within the framework of the free and independent exercise of their professional activity:

• Commit to declare acting as an independent entrepreneur and assuming sole civil and tax liability for their activity.
• Commit to executing their Missions with the utmost professionalism, respecting trade standards and applicable hygiene standards.
• Commit to accepting or refusing a Demand in good faith, without unjustified discrimination.
• Commit to refusing or interrupting a Service in case of risk to safety, health, or the integrity of equipment.
• Commit to documenting any Service with evidence (timestamped photos before and after) for the relevant categories. The Provider also commits not to photograph valuables or elements of a professional or personal nature at the Consumer's home without their consent. Generally, the Provider commits to respecting the Consumer's privacy and not abusing their position to harm the Consumer in any way.
• Commit to offering an additional quote if the scope of the Mission exceeds the initial booking, without ever coercing the Consumer.
• Commit to complying with applicable regulations, professional standards, and their insurance.
• Commit to respecting the Consumer and treating them with courtesy, respect, and dignity. The Provider refrains from any aggressive, threatening, harassing, insulting, or discriminatory behavior.
• Commit to respecting agreed schedules. In the event of a delay of more than twenty (20) minutes geographically observed on site, the cancellation conditions of the GTC apply.
• Commit to refusing any cash payment and carrying out their transactions exclusively via the Platform and the PSP. Any distribution of personal business cards or attempt at disintermediation exposes the Provider to the application of the penalty clause set out in Article 12.3 of the GTC.

5. REFUSAL FOR NON-COMPLIANT PREMISES

Legitimate grounds: health risk, hazardous materials, extreme accumulation of waste, lack of access, threat to the Provider's safety or health.

Procedure: upload evidence (timestamped photos), notify the Consumer via the Platform's messaging system, propose an additional quote or cancellation.

Consequences: if the Consumer refuses the quote, the cancellation and compensation rules of the GTC apply; TRNKYLU's Commission remains due unless decided otherwise.

6. BEFORE/AFTER PHOTOS AND PROOF OF EXECUTION

• Mandatory upload for Mission categories defined by TRNKYLU.
• Timestamping and geolocated metadata recommended.
• Retention and use in accordance with the Privacy Policy (Appendix II).

7. REVIEWS AND REPORTS

• Consumers can freely review Providers after each Mission — these reviews are autonomous and are not managed by TRNKYLU.
• Dangerous, fraudulent, or illegal behavior can be reported to TRNKYLU.
• Based on its right of oversight (Article 9 of the GTC), TRNKYLU may take graduated measures: warning, visibility restriction, suspension, permanent exclusion after an adversarial procedure.

8. ENTRY INTO FORCE

This Charter comes into force on the date of publication and applies to all bookings made after this date. It is subject to modification under the conditions provided for in Article 23 of the GTC.

APPENDIX II — PRIVACY AND DATA MANAGEMENT POLICY (GDPR)

1. DATA CONTROLLER

The company TRNKYLU commits to processing all personal data collected via the TRNKYLU Platform in strict compliance with the General Data Protection Regulation (GDPR) No. 2016/679 and the directives of the National Commission for Data Protection (CNPD) in Luxembourg.

2. DATA COLLECTED

TRNKYLU automatically collects and processes the following categories of personal data:

• Consumer Data: first name, last name, billing email address, WhatsApp mobile phone number, geographical coordinates of the intervention location, access instructions, description of the Demand.
• Provider Professional Data: company name, mobile phone number, administrative compliance certificates (KYB status, VAT number, RCS registration, social security affiliation), and documents referenced in the GTC.
• Transaction Data: technical identifiers of the PSP. Raw bank card data is processed exclusively via end-to-end encryption by the PSP, without being stored on TRNKYLU's infrastructure.

3. PURPOSES, LEGAL BASES, AND SECURITY

4. SUBCONTRACTORS AND TRANSFERS

TRNKYLU relies on the following main subcontractors for data processing:

TRNKYLU commits to maintaining up-to-date Data Processing Agreements (DPAs) with each of these service providers and informing Users of any significant changes.

5. RETENTION PERIODS

6. RIGHTS OF DATA SUBJECTS

In accordance with the GDPR, each User has the following rights:

APPENDIX III — STANDARD WITHDRAWAL FORM

(In accordance with Annex I of Directive 2011/83/EU and the Luxembourg Law of April 2, 2014)

This form can be sent by email to flow@trnkylu.com or by registered mail with return receipt. TRNKYLU will acknowledge receipt of the form within forty-eight (48) hours and proceed with the refund within fourteen (14) days following receipt of the duly completed form.

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