Terms of Service of the ATRIUMA platform

Art. 1. Subject

(1) These Terms of Service govern the relationship between Dzhovi IT EOOD (Джови ИТ ЕООД) (the “Provider” or “ATRIUMA”) and every natural or legal person (the “User”) who visits or uses the website opportunities.atriuma.com and the related websites, mobile applications and programming interfaces offered under the ATRIUMA trademark (together, the “Platform”).

(2) These Terms are issued under Art. 4 et seq. of the Bulgarian Electronic Commerce Act and constitute a contract between the Provider and the User within the meaning of the Bulgarian Obligations and Contracts Act.

Art. 2. Information about the Provider

(1) Information under Art. 4(1) of the Electronic Commerce Act:

• name: Dzhovi IT EOOD (Джови ИТ ЕООД);
• unified identification code (UIC / ЕИК): 206829497;
• registered seat and address: as entered in the Commercial Register and Register of Non-Profit Legal Entities kept by the Bulgarian Registry Agency under the above UIC;
• trademark: ATRIUMA, owned by the Provider;
• contact email: support@atriuma.com; personal data questions: privacy@atriuma.com;
• supervisory authorities: the Commission for Personal Data Protection (www.cpdp.bg) and the Consumer Protection Commission (www.kzp.bg).

Art. 3. Acceptance

(1) The User accepts these Terms by registering on or using the Platform after having been given the opportunity to read them. Acceptance is an electronic statement within the meaning of the Bulgarian Electronic Document and Electronic Trust Services Act.

(2) A User who does not agree with these Terms should stop using the Platform.

(3) The Platform is intended for persons aged 18 or over. Younger persons may use it only with the consent and under the supervision of a parent or guardian.

Art. 4. What ATRIUMA is

(1) ATRIUMA is a technology platform for discovering, researching and managing real estate. Through the Platform, Users can in particular:

• search and view listings for sale and rent published by real estate agencies, developers and owners, including on a map with filters;
• use an artificial intelligence assistant that accepts free-text requests, suggests suitable properties and may forward inquiries to agencies;
• view market information — average prices by year, neighbourhood data, urban planning, transport and other context;
• view public cadastral information on land plots, buildings and units, without owner data unless expressly provided otherwise;
• browse a directory and profiles of real estate agencies;
• send inquiries, viewing requests and requests for assistance to agencies and owners;
• save properties, notes and shared lists with other Users;
• add and manage their own properties — expenses, lease agreements, tenants and co-owners, defects, payments and documents;
• publish listings as owners, including descriptions generated with artificial intelligence;
• generate property brochures in PDF format.

(2) The Provider may add, change, restrict or discontinue individual features of the Platform at any time.

Art. 5. Role of ATRIUMA

(1) ATRIUMA is not a real estate agency, broker, valuer, or financial, legal or tax adviser. The Provider is not a party to transactions, negotiations or contracts that Users conclude with each other or with agencies, owners and other third parties.

(2) Listings, prices, photos and descriptions are published by the respective agencies and owners, who are responsible for their accuracy, lawfulness and currency.

(3) When a User sends an inquiry to an agency or owner, the User's data is provided to the recipient, who processes it as an independent controller, as described in the Privacy Policy.

Art. 6. Registration

(1) Some services are available without registration. An account is required to save properties, manage own properties, publish listings, reveal phone numbers and use other features.

(2) Registration and sign-in take place through the central ATRIUMA identity service — with email and password, a Google or Apple account, or another offered method. The User may verify a phone number with a code sent by SMS.

(3) The User undertakes to provide true, accurate and current information and to keep it up to date.

Art. 7. Account security

(1) The User must keep their access credentials confidential, must not share them with third parties and must notify the Provider immediately of any suspected unauthorised access.

(2) All actions performed through the User's account are deemed to be performed by the User unless the User proves that the account was misused without their fault.

Art. 8. Closing an account

The User may request closure of their account at any time by writing to support@atriuma.com or through the account settings where this option is available. The Provider fulfils the request within one month. The consequences for personal data are described in the Privacy Policy.

Art. 9. Rights of the User

The User may use the Platform in accordance with its purpose, these Terms and applicable law, and may exercise their rights as a data subject under Regulation (EU) 2016/679.

Art. 10. Prohibited conduct

The User may not:

• publish false, misleading, outdated or third-party information, or listings for properties they are not authorised to offer;
• publish content that infringes third-party rights, including copyright, image rights and personal data;
• automatically extract (scrape or crawl) listings, data or content from the Platform without the Provider's express written permission;
• circumvent technical limits, request limits or security measures;
• use the Platform to send unsolicited commercial messages, commit fraud or carry out any other unlawful activity;
• use personal data of others obtained through the Platform for purposes other than the specific inquiry or transaction;
• enter sensitive personal data of third parties or unlawful content into the artificial intelligence assistant;
• create accounts in another person's name or more than one account for abusive purposes.

Art. 11. Liability of the User

The User is responsible for the content they publish or send through the Platform and shall indemnify the Provider for damages and reasonable costs arising from third-party claims caused by the User's culpable breach of these Terms.

Art. 12. Content licence

(1) The User retains their rights in the content they upload to the Platform — texts, photos, videos, floor plans, documents and notes.

(2) By uploading, the User grants the Provider a free, non-exclusive, worldwide licence, for the period of publication, to store, reproduce, technically adapt (including resizing and optimisation), display and distribute that content to the extent necessary to provide, promote and improve the Platform's services.

(3) The User declares that they hold the necessary rights in the content and that its publication does not infringe the rights of third parties.

Art. 13. Removal of content

(1) The Provider may remove or restrict access to content that it has reasonable grounds to believe is unlawful, false or in breach of these Terms, including following a notice from a third party.

(2) Anyone may notify the Provider of unlawful content at support@atriuma.com, stating the exact location of the content and the reason for the notice. The Provider handles notices promptly and informs the affected User of its decision and the reasons for it, in accordance with Regulation (EU) 2022/2065 (Digital Services Act).

Art. 14. Data and market information

(1) Market data, average prices, and cadastral, urban planning, transport and other context information are drawn from public registers, open data and third-party sources and are provided for information only. They may be incomplete, inaccurate or out of date and do not constitute a valuation, an offer or a recommendation.

(2) Prices in market data are advertised (asking) prices, not transaction prices, unless expressly stated otherwise.

(3) The User should independently verify any material information, including in the official registers, before making a decision.

Art. 15. Artificial intelligence assistant

(1) The assistant's answers are generated automatically and may contain errors. They are not professional advice and do not bind the Provider, agencies or owners.

(2) The User is informed that they are interacting with an artificial intelligence system. Conversations may be reviewed by the Provider's staff and, when the User is looking for a specific property or agency, passed to the relevant agency for a reply.

Art. 16. Obligations of the Provider

The Provider undertakes to exercise due care in maintaining the Platform, to process personal data in compliance with Regulation (EU) 2016/679 and the Bulgarian Personal Data Protection Act, and to notify Users of material changes to these Terms.

Art. 17. Rights of the Provider

(1) The Provider may carry out maintenance and improvements, during which the Platform may be temporarily unavailable.

(2) The Provider may restrict, suspend or terminate the access of a User who breaches these Terms or applicable law, notifying the User in advance where possible and stating the reasons.

Art. 18.

(1) The ATRIUMA trademark, logos, design, software, databases, the selection and arrangement of data and all other Platform content other than content of Users and third parties are the property of the Provider and are protected by the Bulgarian Copyright and Related Rights Act and the Marks and Geographical Indications Act.

(2) Copying, reproduction, distribution or creation of derivative products without the Provider's prior written consent is not permitted, except within normal personal use of the Platform.

Art. 19. Exclusions

(1) To the extent permitted by applicable law, the Provider is not liable for:

• the accuracy, completeness, lawfulness and currency of listings, prices, photos and other content published by agencies, owners and other Users;
• transactions, contracts, negotiations, viewings and payments between Users, agencies, owners and third parties, or their performance;
• decisions made on the basis of market data, cadastral information or answers of the artificial intelligence assistant;
• the way agencies and owners process data they receive as independent controllers;
• temporary unavailability, interruptions or errors caused by maintenance, third-party providers, network problems or force majeure;
• lost profits and indirect damages.

Art. 20. Extent of liability

(1) Where the Provider is liable, its liability for free services is limited to direct and immediate property damage, and for paid services to the amount paid by the User for the relevant service in the preceding twelve months.

(2) The limitations in this Section do not apply in cases of intent or gross negligence (Art. 94 of the Obligations and Contracts Act), damage to life or health, breaches of Regulation (EU) 2016/679 for which liability cannot be excluded, or where a limitation is not permitted under the Consumer Protection Act.

Art. 21. Data processing

By accepting these Terms, the User confirms that they have read the Privacy Policy and understand how the Provider collects, processes, anonymises and uses data in providing the Platform. Where consent is required for a particular processing operation, it is requested separately and specifically and may be withdrawn at any time without affecting the lawfulness of processing before withdrawal.

Art. 22.

(1) The Provider processes Users' personal data as controller in compliance with Regulation (EU) 2016/679 (GDPR) and the Bulgarian Personal Data Protection Act. The categories of data, purposes, legal bases, recipients, retention periods and User rights are described in the Privacy Policy, which forms an integral part of these Terms.

(2) The Provider anonymises or deletes the data of inactive accounts within the periods and in the manner set out in the Privacy Policy.

Art. 23.

(1) The core services of the Platform are free. The Provider may offer paid subscriptions or individual paid services, whose price, content, term and payment method are stated before ordering. Payments are processed by a licensed payment service provider; the Provider does not store payment card data.

(2) A consumer User may withdraw from a contract for a paid service within 14 days of its conclusion without giving a reason, under Art. 50 et seq. of the Consumer Protection Act. Where the User has expressly requested that the service begin before that period expires, the User owes an amount proportionate to what was provided until withdrawal; for digital content, the right of withdrawal does not apply in the cases under Art. 57 of that Act.

(3) A subscription may be cancelled at any time with effect from the end of the current paid period.

Art. 24.

(1) The contract between the parties is concluded for an indefinite term and terminates:

• at the User's request — by closing the account;
• by the Provider — with 30 days' notice sent by email or through the Platform;
• by the Provider — without notice, in the event of a material or repeated breach of these Terms;
• on discontinuation of the Platform;
• on anonymisation of an inactive account under the Privacy Policy.

(2) Termination does not affect rights and obligations arising before it, or provisions that by their nature continue to apply.

Art. 25.

(1) The Provider may amend these Terms. Registered Users are notified of material amendments by email or through the Platform at least 14 days before they take effect.

(2) A User who does not accept the amendments may close their account before they take effect. Continued use after that date constitutes acceptance of the amendments.

Art. 26.

(1) Matters not covered by these Terms are governed by the laws of the Republic of Bulgaria, including the Obligations and Contracts Act, the Electronic Commerce Act, the Consumer Protection Act, the Personal Data Protection Act and Regulation (EU) 2016/679.

(2) The parties will seek to resolve disputes through negotiation. The User may file a complaint at support@atriuma.com, to which the Provider responds within 30 days.

(3) A consumer User may refer the dispute to the Consumer Protection Commission or to a sectoral conciliation commission under Art. 181a et seq. of the Consumer Protection Act.

(4) Disputes not resolved by agreement are settled by the competent Bulgarian court. For disputes with consumers, territorial jurisdiction is determined under Art. 113 of the Civil Procedure Code.

§ 1. For the purposes of these Terms:

• “Platform” means the websites, mobile applications and programming interfaces offered under the ATRIUMA trademark, including ATRIUMA Opportunities;
• “User” means any person who visits or uses the Platform, with or without registration;
• “Consumer User” means a consumer within the meaning of § 13, item 1 of the Supplementary Provisions of the Consumer Protection Act;
• “Agency” means a legal or natural person engaged in real estate brokerage that publishes listings through ATRIUMA systems;
• “User content” means any information uploaded or sent by a User — text, images, documents, notes, messages;
• “Inactive account” means an account without any sign-in or other activity for the period stated in the Privacy Policy;
• “Anonymisation” means the irreversible transformation of personal data so that the person can no longer be identified.

§ 2.

These Terms were adopted by Dzhovi IT EOOD (Джови ИТ ЕООД) and take effect on 25 September 2026.

§ 3.

These Terms are drawn up in Bulgarian and English. In case of discrepancy, the Bulgarian text prevails.

§ 4.

The invalidity of any provision of these Terms does not render the remaining provisions or the contract as a whole invalid (Art. 26(4) of the Obligations and Contracts Act). An invalid provision is replaced by the mandatory rules of law.