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NAP Store Terms of Service and Public Offer

Version 1.0 of 1 November 2026

Status of this document. This version is published for use and is at the same time under review by a lawyer. Following that review the document may be amended in accordance with Section 2.

Language versions. These Terms are published in Russian and English. In case of any discrepancy, the version in the language of the user's interface at the time of acceptance prevails: the Russian version for Russian-speaking users and the English version for all other users.

1. Definitions

1.1. Operator means [LEGAL ENTITY NAME], a legal entity registered in the Republic of Serbia, which owns and runs the Service. The Operator's details are set out in Section 18.

1.2. Service or NAP Store means the online marketplace available at https://store.napsystem.com, including all its pages, the built-in player, the user profile and related features. The Service operates under the NAP SYSTEM brand; the platform websites are napsystem.ru and napsystem.com.

1.3. User means any individual using the Service, whether registered or not. Buyer means a User who places an Order. Consumer means a Buyer who acquires Digital Content or Hardware for personal, family or household purposes outside any trade, business, craft or profession.

1.4. Account means the User's account in the Service, accessed with an e-mail address and password.

1.5. Developer means a third party that creates and publishes Apps in the Service under a separate agreement with the Operator.

1.6. Supplier means an independent seller of Hardware whose details are shown on the product page and in the Order. The Operator may itself act as one of the Suppliers.

1.7. Digital Content or App means an audio program or set of audio materials (including those using binaural beats: meditation, sleep, focus, audiobooks, music) published in the Service and played in the Service's player.

1.8. Hardware means physical goods offered in the Service: headphones, NAP chairs (vibroacoustic), controllers, sensors, cables, kits and other goods.

1.9. Licence means the right to use Digital Content to the extent and on the terms set out in Section 5.

1.10. Order means a request placed by the Buyer through the Service to acquire a Licence or Hardware, specifying the items, the price, the seller and, for Hardware, delivery details.

1.11. Subscription means a Licence paid periodically (monthly or yearly) and renewed automatically.

1.12. Payment Provider means Stripe (for payments worldwide) or ЮKassa (YooKassa, for payments in Russia), through which payments in the Service are made.

1.13. Profile means the area of the Service available to the User after signing in, including the "Purchases", "Subscriptions", "Orders" and "Data & consent" sections.

1.14. Review means a text and/or rating posted by a User on an App or product page.

1.15. Other terms are to be interpreted in line with applicable law and their ordinary meaning.

2. Subject Matter, Acceptance and Changes

2.1. These Terms govern the use of the Service and constitute a public offer by the Operator (and, in the cases described in Sections 4 and 8, also by the Supplier on whose behalf the Operator acts) to enter into a contract on the terms below with any person who meets the requirements of Section 3.

2.2. The offer is made under the law of the Republic of Serbia. For Users in the Russian Federation, this document is a public offer within the meaning of Article 437(2) of the Civil Code of the Russian Federation.

2.3. Acceptance. The offer is accepted fully and unconditionally by: 2.3.1. ticking the box "I accept the Terms of Service and have read the Privacy Policy" during registration — as regards use of the Service and the Account; and 2.3.2. pressing the purchase button or paying for an Order (including claiming a free Licence) — as regards the relevant sales or licence contract. For Users in Russia, acceptance takes place under Article 438(3) of the Russian Civil Code.

2.4. The checkbox is never pre-ticked. Consent to the processing of personal data is given separately (Section 14) and is not a condition of accepting these Terms beyond what is necessary to perform the contract.

2.5. The contract is concluded electronically. Order confirmation is sent to the Buyer's e-mail address and is available in the Profile.

2.6. Changes to the Terms. The Operator may amend these Terms. Each new version is published in the Service with its number and date. 2.6.1. The Operator will give at least 14 (fourteen) days' notice, by e-mail and/or in-service notification, before any change that makes the User's position less favourable takes effect. 2.6.2. Changes that do not make the User's position less favourable, and changes required by law, may take effect on publication. 2.6.3. A User who does not agree with a change may stop using the Service and delete the Account before the change takes effect; continued use after the effective date means acceptance of the change. 2.6.4. Changes do not apply to Orders paid before their effective date and do not reduce the scope of Licences already acquired, unless required by law. For active Subscriptions, less favourable changes apply from the next billing period. 2.6.5. Previous versions of these Terms remain available in the Service for reference.

3. Account

3.1. The Service is intended for persons aged 18 or over. Persons under 18 may use the Service only through the Account, and under the responsibility, of a parent or other legal guardian, who accepts these Terms in their own name and supervises the minor's use of the Service.

3.2. When registering, the User must provide accurate, up-to-date information and keep it current.

3.3. The Account is personal. Each individual may hold one Account unless the Operator agrees otherwise. Transferring the Account, selling it or sharing credentials is prohibited.

3.4. The User must keep the password confidential and notify the Operator at [E-MAIL ДЛЯ ОБРАЩЕНИЙ] (support e-mail) without delay of any unauthorised access. Actions performed in the Account with valid credentials are deemed to be performed by the User unless proven otherwise, in particular until the User has reported a compromise.

3.5. The Operator may temporarily suspend the Account or individual features where it reasonably suspects a breach of these Terms, fraud or a security threat, or where required by a competent authority. The Operator will inform the User of the reasons, unless prohibited by law or where this would compromise security, and will give the User an opportunity to respond.

3.6. In case of a material or repeated breach, the Operator may terminate the Account with notice to the User. If the Account is terminated for reasons not attributable to a breach by the User, the Operator will refund the unused part of any paid Subscriptions. Termination does not deprive a Consumer of any refund required by law.

3.7. The User may delete the Account at any time in the Profile or on request. Deleting the Account ends access to purchased Digital Content; the Service warns the User about this before deletion. Order and payment records are kept for the period required by law (see the Privacy Policy).

4. Roles of the Operator, Developers and Suppliers

4.1. Digital Content. For Apps, the Operator is the seller (merchant of record): it enters into the Licence contract with the Buyer, collects payment in its own name, issues the purchase confirmation and handles complaints and refund requests. The Operator obtains distribution rights to the Apps from Developers under separate agreements.

4.2. Apps are created by Developers. Each Developer is responsible towards the Operator and third parties for the content it uploads, for holding the necessary rights, for the accuracy of descriptions and for legal compliance.

4.3. The Operator moderates Apps before publication. Moderation checks compliance with the Service's rules and does not mean that the Operator confirms or guarantees any effect of using an App (see Section 9). This does not limit the Operator's statutory liability as seller towards Consumers.

4.4. Hardware. The seller of Hardware is the Supplier named on the product page and in the Order. The sales contract for Hardware is concluded between the Buyer and the Supplier. In this case the Operator acts as the marketplace owner (aggregator of product information) and as the Supplier's agent for receiving payments: payment made to the Operator counts as payment to the Supplier. Where the Operator is itself the Supplier, it acts as seller, and the Order says so.

4.5. The Supplier is responsible for the quality, completeness, safety and conformity of the Hardware with its description, for delivery and for warranty obligations. The Operator is responsible for providing accurate information in the Service about the Supplier and the ordering process, and for any other obligations imposed on it directly by law (including, for Russian consumers, Article 12 of the Russian Consumer Protection Law on aggregator owners). The Operator assists the Buyer in resolving complaints against the Supplier.

4.6. Orders paid through ЮKassa. For Orders paid through ЮKassa, the seller (or the seller's payment agent) may be a separate Russian person: [РОССИЙСКОЕ ЮРЛИЦО ИЛИ ИП, ОГРН/ОГРНИП, ИНН, АДРЕС] (Russian legal entity or sole proprietor, with registration and tax numbers and address). In all cases, the seller for such Orders is the person named in the Order and on the receipt, and that person assumes the seller's rights and obligations under these Terms for the relevant Order.

4.7. The Operator's relationships with Developers and Suppliers (revenue share, commission, payouts) are governed by separate agreements and do not affect the Buyer's rights under these Terms.

5. Digital Content

5.1. Licence. Upon payment (or, for a free App, upon adding it to the library), the Buyer receives a non-exclusive, personal, non-transferable licence to use the App for personal, non-commercial purposes.

5.2. The Licence includes the right to play the App by streaming or download solely in the Service's player, including by caching files in the browser for offline listening. Cached files may be played only in the Service's player.

5.3. The User may not: copy, extract or save App files outside the Service's player; distribute, publicly perform, broadcast, rent or sell Apps; circumvent technical protection measures; use Apps commercially (including in public venues or paid classes); or modify, decompile or create derivative works, except where expressly permitted by law.

5.4. Pricing models. 5.4.1. Free Apps — the Licence is granted free of charge. 5.4.2. One-time purchase — a perpetual Licence to the published version of the App and its updates for as long as the App is available in the Service. 5.4.3. Subscription — a Licence for the billing period (month or year), renewed automatically.

5.5. Auto-renewal. A Subscription renews automatically for a further period of the same length, and the price is charged through the Payment Provider using the payment method stored with that provider, unless the User cancels before the current period ends. The price and billing frequency are shown before the Subscription is taken out.

5.6. Cancellation. The User may cancel a Subscription at any time in Profile → Subscriptions. Cancellation stops auto-renewal; access continues until the end of the paid period. Consumers' withdrawal and refund rights are set out in Section 7.

5.7. Failed renewal. If a renewal payment fails, access continues until the end of the paid period, and the Payment Provider may retry the charge. If payment is not received, the Subscription ends.

5.8. Free trial. Some Subscriptions may include a trial period; its length and the price after it ends are shown before sign-up. If the User does not cancel before the trial ends, the Subscription converts into a paid one. The Operator sends a reminder before the trial ends where the Service supports this or the law requires it.

5.9. Availability and updates. The Operator aims to keep the Service continuously available, but interruptions for maintenance and for reasons beyond the Operator's control may occur. Developers may release App updates; updates that materially impair purchased Digital Content must not deprive the Buyer of rights under consumer protection law.

5.10. Removal of an App. An App may be removed from the Service by decision of the Developer or the Operator (including at the request of a rights holder or as required by law). Buyers who purchased the App as a one-time purchase keep access to the purchased version where technically and legally possible. If access cannot be maintained, the Operator offers a refund on a pro rata basis or to the extent required by law. For Subscriptions to a removed App, auto-renewal stops and the unused paid period is refunded.

5.11. Technical requirements. Playback requires a compatible browser, an internet connection (except for the offline cache) and, for binaural programs, stereo headphones. Minimum requirements are stated in the App description.

6. Prices, Payment and Receipts

6.1. Prices are set by the Operator (for Hardware, by the Supplier) and are shown in the Service in the currency displayed next to the price (for example, EUR). The final price is fixed when the Order is placed.

6.2. VAT. Prices exclude VAT; VAT is added where the law of the buyer's country requires it. The total amount payable is shown on the checkout page before payment, and no taxes are charged to the Buyer on top of it other than the customs charges under clause 8.4.

6.3. Payment is made through the Payment Providers: Stripe (worldwide) and ЮKassa (Russia). Card details are entered on the Payment Provider's page; the Service never receives or stores full card numbers. Payment is deemed made once confirmed by the Payment Provider.

6.4. Charges may be made in the currency of the price; where a card in another currency is used, the exchange rate and any fees are set by the card issuer and the Payment Provider.

6.5. Payment confirmation is sent to the Buyer's e-mail and shown in the Profile. For payments processed through ЮKassa, fiscal receipts under Russian Federal Law No. 54-FZ are generated through ЮKassa and sent to the Buyer's e-mail.

6.6. The Operator may change prices. A price change does not affect paid Orders. Users are notified of a Subscription price change before the start of the period to which it applies and may cancel before that period begins.

6.7. In case of an obvious technical pricing error (for example, misplaced digits), the Operator or Supplier may cancel the Order before it is performed and refund the amount in full, unless the law provides otherwise.

7. Withdrawal and Refunds for Digital Content

7.1. Consumers in the EU and Serbia. A Consumer may withdraw from a distance contract within 14 days without giving a reason. However, for Digital Content not supplied on a tangible medium, the right of withdrawal is lost once supply begins if, before paying, the Consumer: 7.1.1. gave express consent to supply starting immediately, before the withdrawal period expires; and 7.1.2. acknowledged that they thereby lose the right of withdrawal once supply begins (Article 16(m) of Directive 2011/83/EU and the corresponding provisions of the consumer protection law of the Republic of Serbia). The consent and acknowledgment are given on the checkout page next to the payment button, and the Operator confirms them by e-mail together with the Order confirmation.

7.2. If supply has not yet begun, or the consent and acknowledgment were not obtained, the Consumer may withdraw within 14 days. To do so, the Consumer chooses "Withdrawal from the contract (no reason needed)" in the refund request in Profile → Purchases — no explanation is required — or writes to [E-MAIL ДЛЯ ОБРАЩЕНИЙ]. Refunds are made no later than 14 days after the withdrawal notice is received.

7.3. Consumers in Russia. The Russian Consumer Protection Law applies. Providing access to Digital Content is generally treated as a service / licence. The Consumer may withdraw from the contract at any time, subject to paying the costs actually incurred and/or the value of the part already used (Article 32 of that Law), including requesting a refund for the unused part of a paid Subscription period.

7.4. Technical defects. Regardless of country, the Buyer may require a defect to be fixed or a refund to be made if the App does not work or materially fails to match its description and the problem is not fixed within a reasonable time after the Buyer reports it. Consumers' statutory rights in respect of defective Digital Content are not limited.

7.5. How to request a refund. Refund requests are submitted in Profile → Purchases, stating the reason (no reason is needed for a withdrawal under clause 7.2), or by e-mail to [E-MAIL ДЛЯ ОБРАЩЕНИЙ]. Requests are reviewed by a Service administrator.

7.6. Timeline. The Operator reviews the request and, if it is granted, refunds the money within 10 (ten) days of receiving the request (for withdrawal by a Consumer in the EU or Serbia — no later than 14 days, clause 7.2). The money is returned by the same method and through the same Payment Provider used for payment. The time it takes for funds to arrive depends on the bank and the Payment Provider.

7.7. Effect of a refund. A full refund of a one-time purchase ends the Licence and access to the App. A partial refund (compensation) leaves access in place. A Subscription refund ends access from the time of the refund unless agreed otherwise.

7.8. The Operator may refuse a refund where there are no grounds for it under the law or these Terms, giving reasons. A refusal does not prevent the Consumer from going to court or to the competent consumer protection authority.

8. Hardware

8.1. Orders. Items from different Suppliers in the cart are placed as separate Orders — one per Supplier — each with its own delivery and payment. Each Order states the Supplier's details.

8.2. Reservation. When an Order is placed, the goods are reserved for a limited time shown at checkout. If payment arrives after the reservation has expired and the goods are no longer in stock, the Order may be cancelled with a full refund.

8.3. Delivery. Delivery is carried out by CDEK (СДЭК) and DHL; other carriers may also be used. Delivery cost and estimated delivery times are shown at checkout. For oversized items (including NAP chairs), delivery cost and terms are quoted individually and agreed with the Buyer before delivery is paid for.

8.4. Customs duties. For international delivery, the Buyer's country may charge customs duties, import VAT and fees. Unless the Order states otherwise, these are not included in the price and are paid by the Buyer (DAP / DDU terms).

8.5. Passing of risk. For Consumers, the risk of accidental loss of or damage to the goods passes to the Buyer when the goods are handed over to the Buyer or a person designated by the Buyer (other than a carrier chosen by the seller).

8.6. Inspection on receipt. On receipt, the Buyer is advised to check the packaging and completeness of the delivery and, if there is visible damage, to record it with the carrier's representative. Failing to do so does not deprive a Consumer of rights in respect of defects.

8.7. Withdrawal for goods of proper quality. 8.7.1. EU and Serbia: a Consumer may withdraw within 14 days of receiving the goods without giving a reason. The Buyer bears the cost of return shipping unless the Supplier has agreed to bear it. The price of the goods and the initial standard delivery charge are refunded no later than 14 days after the withdrawal notice is received; the Supplier may withhold the refund until it has received the goods back or evidence that they have been sent. The Buyer is liable for any diminished value of the goods resulting from handling beyond what is necessary to establish their nature and functioning. 8.7.2. Russia: a Consumer may withdraw at any time before delivery and within 7 days after delivery, or within 3 months after delivery if information on the return procedure and time limits was not provided in writing on delivery (Article 26.1 of the Russian Consumer Protection Law; Rules for Retail Sale approved by Russian Government Resolution No. 2463 of 31 December 2020). Return is possible if the goods' presentation and consumer properties are preserved; the Buyer is refunded the price of the goods, less the seller's costs of return shipping, within 10 days of the request. 8.7.3. Exceptions to the right of withdrawal under applicable law (for example, goods made to the consumer's specifications, or sealed goods unsuitable for return for hygiene reasons once unsealed) are indicated on the product page.

8.8. Defective goods and warranty. If a defect is found, the Buyer may exercise the remedies provided by applicable consumer protection law (repair, replacement, price reduction, termination). The warranty period is stated on the product page; if none is stated, it is 12 months from delivery. This is the Supplier's warranty; it does not shorten the statutory periods for bringing claims in respect of defects (in the EU and Serbia — at least 2 years; in Russia, where no warranty period is set — 2 years, Article 19 of the Russian Consumer Protection Law). The Supplier's warranty does not limit Consumers' statutory rights in respect of lack of conformity.

8.9. Return procedure. The Buyer creates a return request in the Profile ("Orders" section) or by e-mail to [E-MAIL ДЛЯ ОБРАЩЕНИЙ], stating the Order, the item and the reason. The Supplier (assisted by the Operator) provides the return address and shipping method. Returned goods are inspected; the refund is made after inspection within the time limits in clause 8.7 and those required by law, using the original payment method. Where necessary, a quality check or expert examination is carried out as provided by law.

9. Health and Safety

9.1. The Service is not a medical service. Apps (including those with binaural beats), questionnaires, measurements and Hardware (including vibroacoustic chairs) are intended solely for personal wellbeing and relaxation. They are not medical devices, are not intended to diagnose, treat or prevent any disease, and do not replace consultation with a doctor.

9.2. Neither the Operator nor the Developers guarantee any particular effect from using the Apps or Hardware. Individual experience varies.

9.3. Contraindications and precautions. Do not use the Apps and/or Hardware without first consulting a doctor if you have: 9.3.1. epilepsy or another seizure disorder; 9.3.2. a heart rhythm disorder or an implanted pacemaker — in relation to the vibroacoustic chair; 9.3.3. a pregnancy — in relation to the vibroacoustic chair.

9.4. Do not use the Apps while driving or operating machinery, or in any other situation requiring full attention.

9.5. Children may use the Apps and Hardware only under the supervision of parents or legal guardians.

9.6. Stop using the product and see a doctor if you experience discomfort, dizziness, headache or other unpleasant sensations. Keep the volume moderate.

9.7. If you have any doubts about your health, consult a doctor before use. Developers are prohibited from making medical or therapeutic claims in App descriptions.

10. User Content and Reviews

10.1. Users may post Reviews of Apps and goods they have purchased. Reviews may be labelled "verified purchase" where the author bought the App or item through the Service.

10.2. Reviews must not contain: links, contact details or advertising; insults, threats or discriminatory statements; knowingly false statements; third parties' personal data; medical claims presented as fact; material infringing third-party rights or the law; or paid reviews without disclosure.

10.3. The Operator moderates Reviews and may hide or remove a Review that breaches clause 10.2, notifying the author. The Operator does not remove Reviews merely because they are negative. Users may mark Reviews as helpful and report breaches.

10.4. By posting a Review, the User grants the Operator a free, non-exclusive, worldwide licence to reproduce and display it in the Service (together with the author's display name) and to adapt it technically, for as long as it is published. After the Account is deleted, the Review may be shown as by a "deleted user".

10.5. Developers and Suppliers may reply publicly to Reviews. Replies are subject to the same rules as Reviews.

10.6. Users are responsible for the content of their Reviews and warrant that they are entitled to post them.

11. Prohibited Conduct

11.1. Users must not: 11.1.1. break the law or infringe third-party rights when using the Service; 11.1.2. gain unauthorised access to the Service, other Accounts or data, or circumvent security measures and restrictions; 11.1.3. use bots, scripts or other automated means for bulk data collection or to load the Service, unless permitted by the Operator; 11.1.4. distribute malware or attack the Service's infrastructure; 11.1.5. commit fraud, including unjustified chargebacks intended to keep access without paying; 11.1.6. create Accounts to evade a block or manipulate ratings and Reviews; 11.1.7. impersonate another person, the Operator, a Developer or a Supplier; 11.1.8. use the Service or Digital Content in breach of the Licence.

11.2. A breach of this Section may lead to the measures in clauses 3.5–3.6.

12. Intellectual Property

12.1. Rights in the Service, its software, design, trademarks and the NAP Store and NAP SYSTEM signs belong to the Operator or its licensors.

12.2. Rights in the Apps belong to the Developers or their rights holders; the Operator distributes them on the basis of rights granted to it.

12.3. These Terms grant the User no rights other than those expressly included in the Licence.

12.4. A rights holder who believes that material in the Service infringes its rights may send a notice to [E-MAIL ДЛЯ ОБРАЩЕНИЙ], identifying the material, the grounds and contact details. The Operator reviews notices within a reasonable time and restricts access to the material where appropriate.

13. Liability

13.1. Each party is liable in accordance with applicable law and these Terms.

13.2. The Service is provided in the form and with the functionality available at the time of use ("as is"), to the extent permitted by law. This does not limit Consumers' rights to receive Digital Content and goods that conform to the contract and their description.

13.3. The Operator is not liable for: interruptions caused by third parties (telecom providers, Payment Providers, carriers) that it could not influence; incompatibility of User equipment that does not meet the stated requirements; or consequences of the User's breach of these Terms or of the guidance in Section 9.

13.4. Towards persons who are not Consumers, the Operator's liability is limited to direct loss up to the amounts paid by the User to the Operator in the 12 months preceding the event, unless the law sets a higher limit.

13.5. Nothing in these Terms excludes or limits liability for intent or gross negligence, for death or personal injury, or in any other case where limitation is not permitted by law, nor does it limit Consumers' mandatory rights under the law of their country of habitual residence.

13.6. Force majeure. The parties are released from liability for failure to perform caused by force majeure (natural disasters, hostilities, acts of public authorities, large-scale infrastructure failures, sanctions restrictions making performance impossible, and the like) for as long as it lasts. A party affected shall notify the other within a reasonable time. If performance is impossible for more than 30 days, either party may cancel the Order and the amount paid for the unperformed part is refunded.

14. Personal Data

14.1. Personal data is processed in accordance with the Privacy Policy published in the Service.

14.2. Consent to the processing of personal data is given in a separate document during registration. Questionnaire results and measurements (wellbeing data) are processed only with a separate consent, which the User may withdraw at any time in Profile → Data & consent.

14.3. A Supplier receives the data needed to deliver its Order. Developers receive no personal data of Buyers, other than Review texts with display names and anonymised aggregate statistics.

15. Notices and Communications

15.1. The Operator sends legally relevant communications (about Orders, refunds, moderation and changes to these Terms) to the e-mail address in the Account and/or by in-service notification. A communication is deemed received on the day it is sent unless proven otherwise.

15.2. Users send requests and complaints to [E-MAIL ДЛЯ ОБРАЩЕНИЙ] or through the relevant Profile features. Personal data requests are sent to [E-MAIL ПО ПЕРСОНАЛЬНЫМ ДАННЫМ] (personal data e-mail).

15.3. Users must keep their e-mail address up to date.

15.4. Marketing e-mails are sent only with the User's separate consent.

16. Governing Law and Disputes

16.1. These Terms are governed by the law of the Republic of Serbia. This choice of law does not deprive a Consumer of the protection afforded by the mandatory provisions of the law of the country of their habitual residence (Article 6 of Regulation (EC) No 593/2008 "Rome I" and equivalent rules of applicable law).

16.2. Pre-trial complaint. Before going to court, the User may send a written complaint to [E-MAIL ДЛЯ ОБРАЩЕНИЙ]. The Operator responds within 10 (ten) days of receipt. Using this complaint procedure is not mandatory for Consumers unless the law provides otherwise and does not prevent them from going to court or to a consumer protection authority.

16.3. Disputes with persons who are not Consumers are heard by the competent court in the Republic of Serbia at the Operator's seat. Consumers may bring proceedings in the courts of their place of residence or another court in accordance with applicable law.

17. Final Provisions

17.1. If any provision of these Terms is held invalid or unenforceable, the remaining provisions remain in effect; the invalid provision is replaced by a lawful provision closest to its intended meaning.

17.2. The Operator may transfer its rights and obligations under these Terms to a third party in the course of a reorganisation or transfer of the business, with notice to the User, provided that this does not make the User's position less favourable. The User may not transfer their rights and obligations without the Operator's consent.

17.3. These Terms, together with the Privacy Policy, consents and the terms of a specific Order, constitute the entire agreement between the parties on their subject matter. In case of conflict between the Order terms and these Terms, the Order terms apply to the extent they are more favourable to the Consumer.

17.4. A party's failure to exercise a right does not constitute a waiver of it.

17.5. These Terms take effect on 1 November 2026 and remain in force indefinitely.

18. Operator Details

[LEGAL ENTITY NAME] Republic of Serbia Registration number (MB): [МБ] Tax number (PIB): [ПИБ] Address: [АДРЕС] Support e-mail: [E-MAIL ДЛЯ ОБРАЩЕНИЙ] Personal data e-mail: [E-MAIL ПО ПЕРСОНАЛЬНЫМ ДАННЫМ] Phone: [ТЕЛЕФОН] Service: https://store.napsystem.com

Seller for Orders paid through ЮKassa (where applicable): [РОССИЙСКОЕ ЮРЛИЦО ИЛИ ИП, ОГРН/ОГРНИП, ИНН, АДРЕС]

Hardware Suppliers: the Supplier's details are shown on the product page and in each Order.

Notes for the lawyer (remove after review)

  1. Entity connected to ЮKassa. ЮKassa generally onboards only Russian residents (LLC / sole proprietor / self-employed). A separate Russian entity is assumed: [РОССИЙСКОЕ ЮРЛИЦО ИЛИ ИП, ОГРН/ОГРНИП, ИНН, АДРЕС]. Its role must be decided — seller (sub-licensee / reseller) or agent of the Serbian Operator — with a matching intra-group agreement, currency control and tax treatment, and clause 4.6 adjusted accordingly.
  2. Marketplace vs merchant of record. The draft treats the Operator as seller (MoR) for Digital Content and as aggregator and Supplier's payment-collection agent for Hardware. Check: whether the agency model is permitted under Serbian law (including payment services regulation), under Russian law (Federal Law 103-FZ on payment agents; Articles 12(2.1) and 26.1 of the Consumer Protection Law on aggregator liability), and the Operator's liability when it is itself a Supplier.
  3. Server location and data localisation. Server country — [СТРАНА РАЗМЕЩЕНИЯ СЕРВЕРА], hosting provider — [ХОСТИНГ-ПРОВАЙДЕР]. If Russian users' data is first recorded outside Russia, this conflicts with Article 18(5) of 152-FZ. A cross-border transfer notification to Roskomnadzor is also required (Article 12 of 152-FZ).
  4. 54-FZ receipts. Receipts are assumed to be issued via ЮKassa. Confirm with the accountant: who is the cash-register user, the agent flag on receipts for Hardware, supplier data on receipts, and receipt obligations when Russian buyers pay via Stripe.
  5. VAT. Prices are shown excluding VAT; tax calculation is not yet implemented (tax = 0). Check compliance with total-price disclosure rules (EU: Directives 98/6/EC and 2011/83/EC require consumer prices inclusive of taxes; Russia: Article 10 of the Consumer Protection Law, price in roubles inclusive of taxes; Serbia — similar rules), EU OSS rules for electronic services, Russian VAT on e-services by foreign suppliers (Article 174.2 of the Tax Code), and Serbian PDV. Displaying VAT-inclusive final prices will likely be required.
  6. Consumer withdrawal for subscriptions. For the EU/Serbia, the right is lost with express consent and acknowledgment — check whether Article 16(m) covers a subscription treated as a "digital service" (Directive 2019/770 distinguishes digital content from digital services; for services Article 16(a) and pro rata payment apply). For Russia — application of Article 32 of the Consumer Protection Law and refunds for unused periods, reconciled with the business rule "cancel — access until end of period". Check implementation of the withdrawal button (currently withdrawal is made through the refund request with the option "Withdrawal from the contract (no reason needed)") (Article 11a of Directive 2011/83/EU as amended by Directive 2023/2673) and its transposition in Serbia.
  7. Age. The simplified rule "18+; younger only via a parent's account" is used. Check: Russia — partial capacity of minors aged 14–18 (Article 26 of the Civil Code); EU/Serbia — age of digital consent (Article 8 GDPR, 16; Serbian ZZPL — 15). Consider whether age verification is required.
  8. Governing law clause enforceability. The choice of Serbian law for EU and Russian consumers is limited by Article 6 of Rome I and Article 1212 of the Russian Civil Code / Article 16 of the Consumer Protection Law (unfair terms). Check enforceability of the jurisdiction clause and the complaint procedure (a mandatory pre-trial procedure for Russian consumers may be held to infringe their rights).
  9. Limitation of liability and "as is". Check clauses 13.2–13.4 against Article 16 of the Russian Consumer Protection Law and Directive 93/13/EEC on unfair terms.
  10. Unilateral amendment. For Russian consumers, a unilateral change of terms may be an unfair term (Article 16 of the Consumer Protection Law, Article 310 of the Civil Code). Check the 14-day notice mechanism and how consent is obtained.
  11. Hardware returns in Russia. Deduction of return shipping costs; applicability of the list of non-returnable goods (headphones — hygiene?); whether any items are technically complex goods.
  12. Developer and Supplier agreements. The text assumes they exist (clauses 1.5, 4.1, 4.7); separate documents are needed, including warranties of content rights and a ban on medical claims.
  13. Account deletion and access to purchases. Clause 3.7 ends access to purchased content on deletion — check whether export / additional warning is needed and whether this is an unfair term.
  14. Sanctions and cross-border settlements between Serbia, the EU and Russia (Stripe and ЮKassa) — check the effect on enforceability and the wording of clause 13.6.
  15. Reviews. Check Directive (EU) 2019/2161 requirements to disclose how review authenticity is verified, and Digital Services Act obligations for marketplaces (notice-and-action, statements of reasons for moderation, trader traceability under Article 30 DSA).
  16. Serbian version. Check whether a Serbian-language version is required for consumers in Serbia.
  17. Digital order confirmation. Implemented: the payment e-mail for a digital purchase repeats the consent to immediate access and the acknowledgment of loss of the right of withdrawal and states the Terms version (Article 8(7) of Directive 2011/83/EU). Check that the wording is sufficient.
  18. VAT-inclusive prices. Move to VAT-inclusive prices for consumers (Directives 98/6/EC, 2011/83/EU Article 6(1)(e), Article 10 of the Russian Consumer Protection Law).

Version 1.0 of 11/1/2026